ML20092P632
| ML20092P632 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/04/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Horin W BISHOP, COOK, PURCELL & REYNOLDS |
| References | |
| OL-1, OL-2, NUDOCS 8407090191 | |
| Download: ML20092P632 (22) | |
Text
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C A S E (CITIZENS ASSN. FOR SOUND ENERGY) a4/946-9446 cc
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July 4, 1984 .o ,
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Mr. William A. Horin, Esq.
Bishop, Liberman, Cook, Purcell & Reynolds 1200 - 17th St., N. W.
Washington, D. C. 20036
Dear Bill:
Subject:
In the Matter of Texas Utilities Electric Company, et al.
Comanche Peak Steam Electric Station Units 1 and 2 Docket Nos. 50-445-1 and 50-445-2 50-446-1 and 50-446-2 Informal Discovery Regarding _
Drug-Related Terminations and Related Developments at CPSES As discussed last week with you and Judge Bloch, we are filing the attached interrogatories and requests for documents on an informal basis.
Although we are filing this informally, we have attempted to make our questions as focussed and detailed as possible to let you know exactly what information we are after. It should also be noted that the fact that we are at this time filing this informally in no way decreases the importance wb'ch we place on this matter. We believe this is very serious, with implications for virtually all aspects of CASE's Contention 5 on OA/QC, including possibly intimidation.
If there is any information requested which you believe to be of a proprietary nature or which should for some other reason be subject of a protectiva order, please contact me so that we can attempt to work out informally an agreement in this regard to avoid unnecessary invasion of privacy, while at the same time providing us with the information we need insofar as the safety of the plant is concerned.
, We hope that it will not be necessary to pursue this further with the l
Licensing Board, and will appreciate your assistance by a prompt response.
Thanks.
Sincerely, l CASE (Citizens Association for Sound Energy) 8407090191 e40704 rs.) Juanita E211s, President PDR ADOCK 05000445 A pgg .
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CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES Please refer to the attached articles from the FORT WORTH STAR-TELEGRAM.
Basically, we want to know everything about the drug-related terminations and related developments at CPSES, including but not limited to:
- 1. When was the investigation into drug use at CPSES initiated by Applicants?
- 2. Who specifically (name, title, organization, authority) instigated the investigation?
- 3. Why was the investigation into drug use at CPSES initiated?
- 4. What was the specific event which triggered the investigation? Give complete details.
- 5. What is the status of the investigation at this time?
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- 6. If the investigation is not complete, when is it expected to be completed?
- 7. What has been done with the drugs confiscated by Applicants?
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- 8. What law enforcement agency (or agencies) have been t.3tified by i Applicants regarding this matter?
- 9. What, if any, law enforcement agency (or agencies) have been involved in the investigation?
- 10. Has the investigation by law enforcement agency (or agencies) been completed?
11.~ If the investigation by law enforcement agency (or agencies) has not been completed, when is it' expected to be completed?
- 12. Supply the name(s) c. che individual (s) with law enforcement agency (or agencies) who have been involved in the investigation and information as to how and where such individual (s) can be contacted.
- 13. How many (total) employees have been investigated to date by Applicants?
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L CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 14. How many employees have Applicants (or others) investigated to date who work or worked for:
(a) Brown & Root; (b) Gibbs & Hill; (c) Ebasco; (d) TUSI; (e) TUGC0; (f) other Texas Utilities organizations; (g) other contractors and sub-contractors (broken down by name of company or organizations).
- 15. How many employees have Applicants (or others) investigated to date who are with the following organizations:
(a) Plant Operations; (b) Quality Assurance (onsite);
(c) Quality Assurance (Dallas);
(d) Quality Control Supervision or Management -- Non-ASME; (e) Quality Control Supervision or Management -- ASME; (f) Quality Control Inspectors -- Non-ASME; (g) Quality Control Inspectors -- ASME;
- (h) Engineering; (i) Engineering Supervision or Management; (j) Construction; (k) Construction Supervision or Management; (1) Building Management; (m) Project Control / Procurement; (n) Project Control / Procurement Supervision or Management;.
- (o)- Project Management Control; (p) Project Management Control Supervision or 11anagement; (q) Document-Control Center; (r) Document Control (Satellites);
(s) Document Control (other);
(t) Personnel or Employment personnel; (u) Personnel;or Employment Supervision or Management; (v) Security personnel; (w) . Security Supervision or Management; i (x) Vendor personnel; (y) Vendor Supervision or' Management.
- 16. Have members of middle and upper management been investigated (as well as, for instance, crafts and QC personnel)?'
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- 17. What specific criteria were used to determine.which specific individuals were to be investigated or interviewed?
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- CASE'S INFORMAL DISCOVERY REQUESTS REGARDING-DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 18. Have all of the employees who were/are under suspicion or who have been accused by others of taking or selling drugs been interviewed personally?
- 19. If the answer to 13. is no, what specific criteria were used to '
determine which employees were or will be interviewed personally?
- 20. Have all of the employees who were/are under suspicion or who have been accused by others of taking or selling drugs been asked to take lie detector tests? l
- 21. Have any supervisory employees been asked to take lie detector tests?
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-22. Have any upper management employees been asked to take lie detector tests?-
- 23. If the answer to 20, 21, and/or 22 is no, what specific criteria were used to determine which employees would or will be asked to take lie detector tests?
- 24. Who administered the' lie detector tests which were given (supply specific name(s), title (s), organization (s), address, as well as each such person's background and training for administering such tests)?1
- 25. What form has this investigation taken (personal-interviews by Applicants or their agents, personal interviews by law enforcement officials, written questions, lie' detector tests,-discussions with other employees, etc.)?' Give specific details,' including what' specific actions Applicants have taken to confirm whether.or not specific-individuals have been involved-in drug-related activities.
- 26. What specific drugs -have been found onsite?
27.. If different from above, what specific drugs.have been-identified by employees (or.others) as having been used onsite?
- 28. (a) Have Applicants' oriothers' investigations indicated or confirmed
-(specify which) that. employees have used or have been using drugs onsite?'
l(b) If the-answer to (a)=is yes, how many employees have been j indicated or confirmed to have used drugs onsite?. Supply.the--
total number, and-answer for each organization listed in 14.
preceding.
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4 CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 28. ~(continued):
(c) If the answer to (a) is yes, how many employees have been indicated or confirmed to have used drugs onsite? Answer for each organization listed in 15. preceding.
(d) If the answer to (a) is yes, provide the following information for each such employee (or former employee):
(i) his/her name; (ii) address; I (iii) telephone number, (iv) job title, organization, and a brief description of such person's duties at the time of such sale (s);
(v) job title, organization, and a brief description of such person's duties at the present time; (vi) what action has been taken or will be taken by Applicants or their agents regarding each such present or former employee; (vii) to.your knowledge, has such individual been picked up by law enforcement of ficials, indicted, and/or convicted for drug use? Specify which and give details.
- 29. (a) Have Applicants' or others' investigations indicated cr' confirmed (specify which) that drugs have been sold onsite by employees of Applicants or their agents (including contractors, sub-contractors, vendors, etc.)?
(b) If the answer _to (a) is yes, how many employees have been indicated or confirmed to have sold drugs onsite? Give the total
-number and answer'for each organization listed in 14. preceding..
(c) If the answer to (a) is yes, how many employees have-been indicated or confirmed to have sold drugs onsite? . Answer for each organization listed in 15. preceding..
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I CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
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- 29. (continued):
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(d) If the answer to (a) is yes, provide the following information for each such employee (or former employee):
(i) his/her name; (ii) address; (iii) telephone number; (iv) job title, organization, and a brief description of.such person's duties at the time of such sale (s);
(v) job title, organization, and a brief description of such person's duties at the present time; (vi) what action has been taken or will be taken by Applicants or their agents regarding each such present or former employee; (vii) to your knowledge, has such individual been picked up by law enforcement officials,. indicted, and/or convicted for drug use or sale? Specify which and give details.
- 30. Have Applicants' or others' investigations indicated or confirmed (specify which) that drugs are still being sold onsite?-
31.. What specific drugs have been identified by employees or others as having been sold onsite?
- 32. (a) Have Applicants' or others' investigations _ indicated or confirmed (specify which) that'anyone other than employees-(of Applicants or-their agents) have sold drugs onsite?
(b) If the_ answer _to'(a) is yes, supply complete' details.
~33.LlHave Applicants made any specific efforts to ascertain whether or not.
supervisory, or middle or upper management have been involved. in:
'(a)_ taking drugs at CPSES; or (b) : selling drugs at CPSES?
- 34. If the answer: to 33. is yes, ' supply specific details of what ' efforts
- A; plicants have made. -
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CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 35. If the answer to 33. is yes, what have been the results of such efforts? Give specific details.
- 36. (a) What specific criteria have Applicants used to make the determination as to whether or not an employee has:
(1) taken drugs?
(ii) ever been picked up for possession of drugs?
(iii) a conviction record for possession of drugs?
(iv) taken drugs onsite?
(v) taken drugs offsite which may have had an effect on such employee's work?
(vi) sold drugs?
(vii) ever been picked up for selling drugs?
(viii) a conviction record for selling drugs?
(ix) sold drugs onsite?
(x) sold drugs offsite which may have had an effect on the work of other employees at CPSES?
(b) With further reference to 25. preceding, was the same criteria- (to confirm whether or not specific individuals have been involved in drug-related activities) used for all individuals investigated?
(c) If the answer to (b) preceding is no, explain in detail how the criteria differed for different individuals, and explain the reason (s) such criteria differed.
(d) What was the specific criteria used to make a determination that an employee had indeed:
(i) taken drugs?
(ii) ever been picked up for possession of drugs?
(iii) a conviction record for possession of drugs?
(iv) taken drugs onsite?
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CASE'S INFORMAL DISCOVERY REOUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 36. (d) (continued):
(v) taken drugs offsite which may have had an effect on such employee's work?
(vi) sold drugs?
(vii) ever been picked up for selling drugs?
(viii) a convicticn record for selling drugs?
(ix) sold drugs onsite?
(x) sold drugs offsite which may have had an effect on the work of other employees at CPSES?
- 37. (a) Have Applicants made any effort to determine whether or not anyone in a supervisory position or in middle or upper management has ever attempted to force or coerce other employees to take drugs?
(b). If the ' answer to (a) is no, why haven't they?
(c) If the answer to (a) is no, do they have any plans to do so?
(d) If the answer to (a) is yes, what have been the results of such efforts? Provide specific details.
- 38. Was each employee terminated if it was determined that he/she:
(a) had ever taken drugs?
(b) had ever been picked up for possession of drugs?
(c) had a conviction record for possession of drugs? -
, (d) had ever taken drugs onsite?
.(e) had ever taken drugs offsite which may have had an effect on such employee's work?
(f) had ever sold dru,a?.
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~(g) had~ever been picked up for selling drugs?
(h) .had a conviction record for selling drugs?
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(i) _had ever sold ' drugs _onsite?
(j) had ever sold; drugs offsite which may have had an effect on the work of other employees;at CPSES?
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- e CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS
, AND RELATED DEVELOPMENTS AT CPSES (continued):
- 39. (a) Did any employee (s) refuse to take a lie detector test?
(b) Were any employees terminated for refusing to take a lie detector test?
(c) Was each employee who refused to take a lie detector test terminated?
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(d) If the answer to (c) is no, what specific criteria did Applicants use to determine which employees were terminated and which ones were not?
(e)' If the answer to (c) is no, provide the name, and last known address and telephcm number of each employee who was terminated for refusing to take a lie detector test.
(f) Were any employees terminated based on suspicion of having taken or sold drugs without such employee's admitting such use or sale?
I (g) Were any employees terminated based on suspicion of having taken or sold drugs without other (than such employee's admission) supporting evidence (i.e., evidence which wouJd be admissible in court)?
(h) If the answer to (f) or (g) is yes, provide the name, and last known address and telephone number of each employee who was terminated under those circumstances.
- 40. How many employees have been terminated to date who work or worked for:
(a) Brown & Root; (b) Gibbs & Hill;
. (c) Ebasco; (d) TUSI; (e) TUGC0; (f) other Texas Utilities organizations; (g). other contractors and sub-contractors (broken 'down by name of company or organizations)..
4'. .How many employees have been terminated to dste who'were with the following organizations:
(a) Plant Operations;
' (b) Quality Assurance'(onsite);
(c) Quality Assurance (Dallas);
(d) _ Quality Control Supervision or Management -- Non-ASME;-
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CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RE
_AND RELATED DEVELOPMENTS AT CPSES_ (continued):
- 41. (continued):
(e) Quality Control Supervision or Management - ASME; (f)
Quality Control Inspectors -- Non-ASME; (g) Quality Control Inspectors -- ASME; (h) Engineering; (i) Engineering Supervision or Management; (j) Construction; (k) Construction Supervision or Management; (1) Building Managenent; (m) Project Control / Procurement; (n) Project Control / Procurement Supervision or Management; (o) Project Management Control; (p) Project Management Control Supervision or Management; (q) Document Control Center; (r) Document Document Control (Satellites);
Control (other);
(s) Personnel or Employment personnel; (t)
(u) Personnel or Employment Supervision or Management; (v) Security personnel; (w) Security Supervision or Management; (x) Vendor personnel; (y) Vendor Supervision or Management.
- 42. (a)
Have there been any mass demonstrations regarding Applicants' investigation into drug use and sale at Comanche Peak?
(b)
If the answer to (a) is yes, give specific details for each_ such Include in your answer what Applicants' response has incident.
been to each such incident; supply complete details.
(c) Specifically, is it true that around 200 OC Inspectors walked d to the gate prepared to quit or stage a wa16.-out, but were stoppe and persuaded to stay by Gordon Purdy?
(d) If the answer to (c) is yes, or if there is some truth to it, Includel in y supply specific details. response has been to such incident (s); supply including whether or not any agreements were made between Applicants and the QC Inspectors, and whether or not Applicants discontinued or cut back in any way on their investigation following such incident (s).
Provide a cc py of the original NCR and all revisions referenced in
- 43. (a) the 6/26/84 and 6/30/84 FORT WORTH STAR-TELEGRAM (We will articles (indicated to be dated 6/15/84, by Victor McDermott).
definitely want copies of these documents.)
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CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 43. (continued):
(b) Provide the following information regarding the author of the NCT :
(i) Name; (ii) Address; (iii) Telephone number; (iv) Job title, discipline, brief job description, contractor or sub-contractor by which he is employed; (v) Buildings and systems on which he has worked or works; (vi) Has the NCR he wrote been discussed with him by his supervisor or other middle or upper management employees?
(vii) If the answer to (vi) is yes, supply the name, job title, brief job description, and organization of each such employee.
(viii) Has he been counseled for any reason since writing the NCR?
(ix) If the answer to (viii) is yes, what was the reason for such counseling?
(x)- If the answer to (viii) is yes,. supply a copy of all such counseling reports. (We will definitely want copies of all such reports.)
(xi) Is he still employed at CPSES?
3 (xii) If the answer to (xi) is yes, is.he still performing exactly
, the same duties in the same area (s) as he was at the time he wrote the NCR?
(xiii) If the answer to (xii) is no, supply specific details as to the change in duties, area (s), etc., and the reason for such
-change (s).
(xiv) If the answer to (xi) is no, supply specific details regarding his termination or resignation, including all documents related in.any way to such termination or resignation.
I (c) Is the NCR in question a generic NCR?
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l CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 43. -(continued):
(d) How many generic NCR's have been written at CPSES?
- 44. (a) Do Applicants have complete records of the buildings in which and systems on which all employees suspected of taking or selling drugs have worked?
(b) If the answer to.(a) is yes, list the specific buildings in which such employees work (ed).
(c) If the answer to (a) is yes, list the specific systems on which such employees work (ed).
(d) If the answer to (a) is yes, list the specific buildings in which such employees who are or were QC Inspectors (Non-ASNE) work (ed).
(e) If the answer to (a) is yes, list the specific systems on which such employees who are or were QC Inspectors (Non-ASME) work (ed).
(f) If the answer to (a) is yes, list the specific buildings in which j
such employees who are or were QC Inspectors '(ASNE) work (ed).
(g) If the answer to (a) is yes, list the specific systems on which such employees who are or were QC Inspectors (ASME) work (ed).
i (d) If the answer to (a) is no, how have (or will) Applicants determine-such buildings and systems?
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- 45. (a) Have Applicants reinspected or do they plan to reinspect the specific buildings and/or systems on which all employees suspected of taking or selling _ drugs work or have worked?
(b) If the answer to'(a) is yes:
(i) list the specific buildings.which have already been reinspected, and indicate the extent and status of such
- reinspections.
(ii) list the specific systema which have already.been reinspected,'and indicate the extent and status of such reinspections.
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(iii) supply specific _ details ~,jgt building and jyt system regarding the results of such reinspections.
7 (c) If the answer to (a) is no, give specific-details of Applicants'
' plans andEthe rati nale~for their actions in this regard.
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CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 45. (contirued):
(d) If the answer to (a) is yes:
(i) list the specific buildings which have not yet been reinspected.
(ii) do Applicants plan to reinspect the specific buildings listed in (i) above? If not, why not? If so, when are such reinspections expected to be begun, and when are such reinspections expected to be completed?
(iii) list the specific systems which have not yet been reinspected.
(iv) do Applicants plan to reinspect the specific systems listed in (iii) above? If not, why not? If so, when are such reinspections expected to be begun, and when are such reinspections expected to be completed?
(e) If part of the rationale for Applicants' decisions regarding reinspections is because of redundant and independent inspections:
(i) what specific actions have Applicants taken to determine whether or not (for example) more than one OC inspector suspected of drug use or sale worked in one particular area or on one particular system? Give complete details.
(ii) for each system on which an employee suspected of taking or selling drugs works or has worked, list the categories (such as field engineers, equipment manufacturers, other QC inspectors, Bcown & Root personnel, Authorized Nuclear Inspectors, etc.) on which Applicants are relying for such redundant and independent inspections.
l 46. (a) Have any individuals resigned since the drug-related investigation began?
(b) If the answer co (a) is yes, provide the following information regarding each such individual:
l l (i) Name; l
! (ii) Last known address; l
(iii) Last known telephone number; l (iv) Reason for such resignation; 13 u
CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 46. (b) (continued):
(v) Copies of all exit interviews, counseling reports, or other documents related to such resignation.
- 47. For each of the individuals who were involved in "the T-Shirt incident," provide the following information:
(a) Was such individual suspected of taking or selling drugs?
(b) Was an investigation conducted regarding such suspicions?
(c) Has such individual been terminated since Applicants' 4/5/84 Response to CASE's Seventeenth Set of Interrogatories and Requests to Produce?
(d) Has such individual resigned since Applicants' 4/5/84 Response to CASE's Seventeenth Set?
(e) If the answer to (a), (b), (c), and/or (d) in yes, supply complete details.
(f) If the answer to (a), (b), (c), and/or (d) is yes, supply copies of all exit interviews, counseling reports, all documents related to such termination or resignation.
- 48. (a) Have Applicants contacted the Nuclear Regulatory Commission (NRC) regarding the drug-related terminations and related developments at CPSES?
(b) If the answer to (a) is yes, supply the following information:
(i) Who specifically with the NRC was contacted, and who specifically with Applicants contacted the NRC?
(ii) What has the response of the NRC been? Give full and specific details.
- 49. (a) Isn't it a fact that NRC publication NUREG/CR-3196, " Drug and Alcohol Abuse: The Bases for Employee Assistance-Programs in the Nuclear Utility Industry," published July 1983, offers some guidance regarding the seriousness and potential impact of drug use at nuclear plants?
1 (b) Isn't it a fact that Applicants rely, in part, on the statements l in NUREG/CR-3196 in determining who shall and shall not have unescorted access to CPSES?
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. 1 CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 50. Isn't it a fact that Applicants' policies and procedures utilized in administering its " Security Screening for Unescorted Access" program state, in part:
"A reputation of reliability and trustworthiness will be questioned if the screening reveals any of the following situations:
"(a) Deliberate omission or falsification of information submitted in support of employment or request for unescorted access to Protected or Vital Areas.
"(b) Use of nonprescribed narcotic or hallucinogenic drugs or excessive use of alcohol.
I "(c) . . . any criminal conviction which casually relates to the cafety or security of the Plant.
". . . when the screening procedure produces information as listed in E(1)(a) through E(1)(f) of this document, individuals will not be permitted unescorted access to vital or protected. areas of CPSES unless'a subsequent investigation determines that the information is either untrue or that it is not applicable in determining reliability and trustworthiness of the individual."
- 51. Is it true that:
(a) The NRC has determined that nuclear workers classified as Quality
- Control Inspectors consistently rely upon sensory / perceptual, cognitive and motor performance in the conduct of their duties.
(p. XVi, NUREG/CR-3196)
(b) The NRC has determined that marijuana has its greatest effects on motor and cognitive performance and further affects sensory / perceptual performance, especially vigilance. (p. Xvii,.
NUREG/CR-3196) l (c) The NRC has determined that the effects of the use- of marijuana can last from 2 to 4-1/2 hours after ingestion. (p. 29)'
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l (d) The NRC has concluded that even short-term, low dose use of
- marijuana will result in a " medium" impairing effect on job l performance for employees in the job classification of Quality Centrol Inspector. (p. 9)
(e) The NRC has determined that several studies of interpersonal judgment suggest that social behavior is impaired by marijuana
-use. -(p. 29)' .
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CASE'S INFORMAL DISCOVERY REQUESTS REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS AT CPSES (continued):
- 52. Isn't it a fact that Applicants recently (March 15, 1984) relied upon the statements referenced in 50. and 51. preceding as part of their basis for denying unescorted access to CPSES to a Quality Control Inspector who had sought such access? (Note: If Applicants have difficulty in confirming this, please telephone CASE's representative Juanita Ellis; we do not wish to unnecessarily publicly reveal the name
, of the individual involved. This information was contained in j documents picked up by Mrs. Ellis on 7/2/84 regarding intimidation discovery.)
- 53. Have Applicants also denied unescorted access to CPSES to each Quality Control Inspector and others who:
(a) was suspected of taking drugs?
- (b) admitted taking drugs?
(c) had ever been picked up for possession of drugs?
- (d) had a conviction record for possession of drugs?
(e) had ever 'taken drugs onsite?
(f) was suspected of selling drugs?
(g) had ever been picked up for selling drugs?
, (h) had a conviction record for selling drugs?
(i) had ever sold drugs onsite?
- 54. If the answer to any part of 53. is yes:
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(a) supply complete details of each such instance of denial of unescorted access.
(b) supply for inspection'and-copying all documentation of each such instance of denial of unescorted access.
- 55. If the answer to any part of 53. is no, explain in detail the specific j criteria employed by Applicants in making such determinations.
( 56. (a) List (by title, date, and revision number) all procedures which were in effect.as of 3/15/84 regarding unescorted access to CPSES.
(b) -Supply for inspection and copying all procedures and all revisions to such procedures listed in (a). preceding.
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s 5 CASE'S INFORMAL DISCOVERY REQUESTS REGARDING' DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENTS'AI CPSES (continued):
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- 57. (c) Have Applicants systematically gone through all employees' personnel files to determine which of then have admitted to:
(1) taking drugs, (ii) having been picked upsfor possession of drugs, (iii) having conviction (s) for possession of drugs, (iv) selling drugs, (v) having been picked up fo'r selling drugs, (vi) having conviction (s) for'relling drugs?
(b) If the answer to (a) is no, what ef forts have Applicants made to determine which employees have information in their personnel files which would indicate that such employee has:
(i) taken drugs, (ii) been picked up for possession of drugs, (iii) been convicted for possession of drugs, (iv) sold drugs, (v) been picked up for selling drugs, (vi) been convicted for selling drugs?
(c) What specific efforts have Applicants made to verify whether statements made by employees on resumes and in personnel files regarding drug use, possession, sales, and/or convictions is true?
(d) Are the ef forts referenced in (a), (b), and (c) preceding proceduralized?
(e) If the answer to (d) preceding is no, what other documentation of Applicants' efforts exists?
(f) If the answer to (d) preceding is no, supply for inspection and copying all other documentation.
(g) If the answer to (d) preceding is yes, list the specific procedures.
(h) Supply for inspection and copying the procedures listed in (g).
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9 fortWorthStar-Telegram
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12 ire d at nuclear piant .in drug. inquiry jpgus,e. o,@.,yi4g
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10.nC Co.elaaed from Page I "We investigated sthe allega. Its results. !!e would not say which
- Thoutsdozen"of thefaredworkers tionsa, found them to he true and agency was notafled.
None of the fired workers has been charged with a drug offense, F
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wer employed by her corrpany. hate taken action against the em. "Sance our investigation is not Ramsey said. gj $ . gg $-5 E pF g5 *a ; ", Eg" E1 3 e 8$
Brw is Root. the grant Houston- p:syees." Rar tsey said. complete, we have not provided "The folks have just been termi- -
- a. PEE c 2E ** 3 3 E 2 5o based construction company.is the Ramseysanddrug possess 6onwas themwiththeresultsyet.Wewiiido nated and that's the extent of our 58 "(E{$hECE2 p *:g= E.5
- l T3 5"2 primeevastractorat the $389 bilhon involved *insomeof thefire.gsand that when we're finished."he said. action "hesaid."Any furtheraction =8 a 1-ahEE protecs sear Glen Rose, about 45 that some em loyees acknowI. Spokesmen for the U.S. Drug En- will be up to Itaw enforcement offt-- {g :.:.
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Ramsey said theinvestigation be-edged their in vement.
. ganearlylastweekaftersomework- be said.
forcement Administration.theTex- cialsa."
"There wers some admissions." as Department of Public Safety and Ramsey said the allegations sur-the Somervell County shertff's off- faced through a Brown is Root pro -
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! ersalformedcompanyoffacia'sthat Ramsey said the company has no. Ice,allof which could havejurisdic. gramthatencouragesemployeesto i "there were drug activities gosag tified a law enforcement agency tion in the matter,said they were tell manegement about problems at: '28$.E 2 '!( E $ 3,# 5 E573 3 $% (=,$ E ER o-
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.n* 88 the planL about the investigation, but not of unaware of the investigation. the plant. lE5gV C j{k ., u'm *
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m no problems mm m . .
O 14 in inspections l Ey BRUCE MILLAR "As of (Monday' afternoon, we ,
7NL..y h{MMEh.;j star Telegram u nter have notfoundanysafetyareasthat g Nosafetyproblems have been un- need tr, be reinspected." said Dick
- i. i. . covered during a re/iewof portions Ramsey. spokesman forTexas Utili-
$s' of the Comanche Peak nuclearpow. ties Cenerating Co.
. er plant that were inspected by The company is a consortium of N.-y*) ' 3 workerswhoweresuspectedof tak- six utilities that share ownership of 1 -
E ing drugs on thejob.a plant spokes- the 33.89 billion plant, which is un-man said Monday. der construction near Glen Rose 45
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A two week crackdown by plant miles southwest of Fort Worth.
i .i E raanagers resultedin35 workers re- The rechecking of work areas fol-lowedaJune15 non<onformance E R signing or being fired for suspicioa s D of usmg illegal drugs that could report thatcastdoubtonthequality g w ,, g- m -
,$ 0- have affected job performance. of allinspections conducted by the r# 7M&MI Md E Plant officials ordered a review of employees aspected of drug use.
$ the former emplopes' work areas "Due to the termination of QA/
IMT! rd to determine whether a full-scale QC Iquality assurance and quality
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reinspection is necessary. A rein. controh personnel for suspicion of spection would involve costly de. taking drugs whileperformingQA/
M. m lays. QC functions. the quality of any 5 E
- The initial phase of the drug in. itemsinspected orreviewed by QA/
vestigation by plant officials ended QC personnelwho have been termi-Www-[9 Qp2 .. -v .
1 Friday, although the review of in, nated for a drug related charge be-spections is still under way. A plant comes indeterminate." wrote he-
- t. ,4 % g 44:45 spokesman said that only safety re. tor McDermott, a goality control
- ' p_7 lated areas are being reviewed. Please see Nuclear on Page 10 WN' ?d Nuclear plant review
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turns up no problems Continued from Page 9 areaswherecertain formeremploy-g inspector for the primary contrac- eesworked.Hesaidtheinspectionis tor. Brown & Root Co.
g a manageatle tasir because plant of-
, , A copy of that report was ob. ficials have extensive records of all l W tained by the Star-Telegram. areas where the former employees
& Comanche Peak officialssaidlast had inspected work.
O weekth:tonly1percentof theplznt "It's not the sort of thing that we would nquire rechecking. But at like to deal with. Butit's the sort of the bottom of his report. McDer- thing that should be taken care of.
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mon-conformance reportl." sey said, b A generic report hss plantwide W ~
implications. Of the 17.000 non-con. Some plant employees lost their t @ formance reports issued in the last jobs after they were suspected of l eightyears.ont'v50to100havebeen taking illegal drugs. But plant offi-generic. Ramsey said, cials said it would be unfair to use Most nontoniormance reports thesamecriterton tojudgewhether are directed at a specific plant area, the work they left behind is saie.
and many of them have not re- **Therecertainlyhasn-tbeenany quired corrective action. he said. determination this is safety.related.
' Ramseysaid the" generic"termis You arejustjumpingthe gunif you misleading, however, because in- areassumingthatthereisanysafety spectors arelooking only atspecific . sigr.ificance," Ramsey said.
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FortWorthStar-Telegram naturder. June 30,1984 ***
- G.~.'.L': 7 * ~ ~ .;; .L " 7 ~ ._.;. . .. ' . '..:
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~ Comanche Peak not reviewing safety areas ~
By BRIlCE SIILI.AR oneinspectorwhoconductedsafety control managers for plant owners manufacturers. Brown & Root per. manager forTexas L*tilities Gener-seemsra- mm" (teds an the heart of the nuclear and contractors. sonnel and insurance company in. atins: Co.
Criticalsafetyareas at Comanche reactor. Gordon Purdy.on-site quahty as- spectors. The importance of the TUGCOisaconsortiumofsixutill-i . Peak nuclear pcwer plant are being AJune 15"nonconformance"re- surance manager for general coe. plantequipmentorsystemsdictates tiessharingownersNpof theplant.
, bypassed in an inspection ordered port cast doubt on the quahty of all tractor Brown & Root.said the dece- the degree of inspection. he said. which is under construction near by utthty4wnersaf tera recent dtug. areasinspected by the former work. sion not to reinspect the critscal Glen Rose. 45 miles southwest of
. investigadon, plant officials have ers who veere itre:1 or resistr.ed this safety-telated systems was based on tornot meetingthmquinmentsof Fort Worth.
Thea,ddsof anythinginthereac- ,
acknowledged. monthasaresultof aoruginvestiga- confidence that the plant's elabo- 'I13GCO spokesman Dick Ramsey These areasare beinglgnored de- tion. Bat key safety-related areas rate inspection program would thedesignerarerero. Purdysaid. said that multiple inspections in spite the utthty's acknowledgment including the control rod drive have found defects "The more critical a system. the reactor systems dimmish the im- ,
j that among the 35 workers who re- enechanism. the fuel cell area and Purdy said each critical safety more redundant and independent pact of a single Brown & Root quali-signed or were fired on suspicion of the spent fuel poolare not bemg re- area is inspected as many as four the inspections are." added Tony ty control inspector. Consequently.
taking drugs on the job was atleast examined.sandtwotog>levelquahty. timesbyfieldengineers. equipment- Vega. on-site quahty assurance Please see Sefety on Page 2
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of }{
}{
TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445-1 and 50-445-2 COMPANY, et al. }{ and 50-446-1 and 50-446-2 (Comanche Peak Steam Electric }{
Station, Units 1 and 2) }{
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's 7/3/84 letter to Wn. A. Horin, Applicants, re: Informal Discovery Rc9aruing Uruy-Reioceu it rTriinations ana Keiateo Uevelopments at LFdtd i
have been sent to the names listed below this day of July ,1984 ,
by: Express Mail where indicated by
- and First Class Mail elsewhere.
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C. 20036
- Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission
- Geary S. Mizuno, Esq.
4350 East / West Highway, 4th Floor Office of Executive T.egal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory
- Dr. Kenneth'A. McCollos, Dean Commission Division of Engineering, Maryland National Bank Bldg.
Architecture and TechnologI - Room 10105 Oklahor.a State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Chairman, Atomic Safety anc Licensing 881 W. Outer Drive Board Penel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commissio.-
Washington, D. C. 20555
- Herbert Grossman, Alternate Chairman Atomic' Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Washington, D. C.- 20814
- 1
y
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Chairman Renea Hicka, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division ~
U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C. 20555 Austin, Texas 78711 John Collins Lanny A. Sinkin Regional Administrator, Region IV 114 W. 7th, Suite 220 U. S. Nuclear Regulatory Commission Austin, Texas 78701 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Michael D. Spence, President Dr. David H. Boltz Texas Utilities Generating Company 2012 S. Polk Skyway Tower Dallas, Texas 75224 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section Anthony Roisman, Esq.
(3 copies) Trial Lawyers for Public Justice Office of the Secretary 2000 P St., N.W., Suite 611 U. S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555 Ms. Billie P. Garde Government Accountability Project 1901 Que Street, N. W.
Washington, D. C. 20009 Aun N n fD ps.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk '
Dallas, Texas 75224' 214/946-9446 t
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