ML20117B146

Discovery Requests to Applicant on Contention WB-3 Re Drug Abuse During Const.Contention by ASLB in 850313 Memorandum & Order.Certificate of Svc Encl.Related Correspondence

ML20117B146
Person / Time
Site:	Harris
Issue date:	05/01/1985
From:	Runkle J CONSERVATION COUNCIL OF NORTH CAROLINA
To:
References
CON-#285-903 OL, NUDOCS 8505080488
Download: ML20117B146 (5)

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mLano May 1, 1985 UNITED STATES OF AMERICA ~

00LKETED USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOED NAY -8 A10:18 In the Matter of ) f)CC I G& h l$t(

) BRANCH Carolina Power & Light Company and ) Docket No. 50-400 OL North Carolina Eastern Municipal )

Power Agency )

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(Shearon Harris Nuclear Power Plant) )

DISCOVERY REQUESTS TO APPLICANTS ON CONTENTION WB-3 (DRUC ABUSE DURING CONSTRUCTION)

Pursuant to 10 C.F.R. 2.740b, now comes the Conservation Council with discovery requests to the Applicants on our Contention WB-3 (Drug Abuse During Construction) which was admitted by the Board in its Memorandum and Order (Ruling on Contentions Concerning Diesel Generators, Drug Use and Harassment at the Harris Site), dated March 13, 1985. Each answer is to be made separately and fully, in writing and under oath or affirmation. When any of the interrogatories below uses the term " drugs," it refers to illegal drugs, not over-the-counter medications. The term " worker (s)" includes all employees, CP&L or contract personnel, who do any portion of their jobs at the Harr!r construction site.

GENERAL INTERROGATORIES 1-WB. State the name, present or last known address, and present or last known employer of each person known to the Applicants to have first-hand knowledge on which the responses to the specific interrogatories are based.

2-WB. Indentify those facts concerning which each person identified in the response to 1-WB has knowledge.

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i 3-WB. State the specific basis or facts which support each response. l 4-WB. State the name, present or last known address, and present or t last employer of each person who provided information upon which the Applicants relied in answereing each interrogatory herein.

5-WB. Indentify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.

6-WB. State the name, address, title, employer and educational and i professional qualifications of each person the Applicants intend to call as an expert or other witness at a hearing on this contention. i i

l- 7-WB. State the subject matter to which each person identified in 6-WB is expected to testify.

8-WB. Identify all documents in Applicants' possession, custody, or control, including all relevanc page citations, pertaining to the subject ,

matter of this contention and upon which Applicants relied upon in ,

formulating responses to these interrogatories.

9-WB. Identify all documents which Applicants indent to offer as exhibits at a hearing on this contention.

I 10-WB. State the name, present or last known address, and present or last known employer of each person referred to in any of the responses to these interrogatories, unless the interrogatory specifically allows names,  :

et al., not to be given.

i SPECIFIC INTERR0CATORIES 11-WB. Do the Applicants admit to the veracity of the facts contained in the newspaper article titled "6 Arrested in Nuclear Plant Drug Probe," on page 1A of the Raleish NEWS & OBSERVER, January 11, 1985, which was attached to the Conservation CouncIT's Request for Addaission of New Contention WB-3 (January 18, 1985)?

12-WB. If the answer to 11-WB is negative, which portions of the  !

-article are in Applicants' opinion not true or otherwise misleadingt i 13-WB. For each portion of the article described in 11-WB which Applicants do not admit to as true, please explain the basis for your assertion that that portion is not true or otherwise uitsleading?  ;

14-WB. For each of the eight workers (which includes the six listed by name in the article and two more who had warrants issued for their arrest) identified in the article described in 11-WB, please describe the positions l each held at the Harris construction site, the length of their employment at l

the site, the specific jobs which each performed (in detail enough that the l an NRC inspector could locate the actual area where the work was performed), L j vho their supervisors were during the different times of their employment at [

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- . s, the Harris sito, the cx:ct ch;rg:3 br ught ag:inct c:ch cne, cnd wh:th:r tha jobs each had performed were reinspected af ter their arrests.

15-WB. Has QA/QC conducted an audit of any of the specific construction areas where any of the workers identified in the article in 11-WB was working or had worked?

16-WB. If the answer to 15-WB was affirmative, please supply copies of any such QA/QC audit?

17-WB. Please supply copies of all inspection reports on the jobs

- performed by the workers identified above.

18-WB. At the present time, how many workers at the Harris site use drugs while on the site? (An answer giving the "best estimate" is adequate). Please break down by types of jobs performed by the workers using drugs on site (again, "best estimate" is adequate).

19-WB. How were the figures (or estimates) in 18-WB above derived?

Please provide all bases and who exactly made the estimate.

20-WB. What types of drugs are used by workers identified in 18-WB above? (Again, "best estimate" is adequate).

21-WB. What is the Applicants' policy about workers using drugs while on site?

22-WB. Have any workers been fired, suspended, reprimanded, or had other adverse job actions taken against them for using drugs while on site?

23-WB. If the answer to 22-WB is affirmative, please describe all such actions, including the jobs being performed by the worker, what drug the worker was using, and whether any of the jobs performed by that worker was reinspected. (Names of workers are not required).

24-WB. Did the Applicants request the Wake County Sheriff's Department to investigate drug abuse at the Harris site, prior to the arrests of the workers identified in the article described in 11-WB7 25-WB. If the answer to 24-WB is affirmative, please describe who initiated the request, to whom on the Sheriff's Department the request was made, on what grounds such a request was made, and the date on which the request was made. Please provide any documentation (including letters, phone logs, etc.) of this request.

26-WB. What actions do the Applicants take to determine if any of the workers at the Harris site are using drugs while on the site? This includos, but is not limited to, searches of persons or property, urine sampling, and lie detector tests. Please describe each action in detail.

27-WB. Approximately how often are the actions in 26-WB conducted?

28-WB. Under what conditions are the actions in 26-WB conducted?

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29-WB. What crit:rio io uncd by managment to dat:rmino which workers are to be searched, etc., for possible drug abuse?

30-WB. How many workers have been determined to be using drugs from the actions described in 26-B7 31-WB. Please provide any documentation, including policy statement or manuals, which describe the Applicants' drug use policy.

32-WB. Do the Applicants have any education, employee development programs, or the like which pertain to the prevention of drug use while on the site?

33-WB. If the answer to 32-WB is affirmative, please submit details of any such programs, including but not limited to the frequency given, who on the staff gives the program, who taceives the program, and what the contents of any such program are. -

34-WB. Do the Applicants hare any drug rehabilitation program for Harris workers or recommend any such prigram for workers who may be using drugs on the site?

35-WB. If the answer to 34-WB is affirmative, please submit details of any such programs, including bt c not 11.,ited to the number of employees referred, who conducts the program, and what the contents of any such program are.

Please contact us if we can provide any needed clarification of the interrogatories above.

Respectfully submitted, John Runkle General Counsel Conservation Council of NC 307 Cranville Road Chapel Hill, NC 27514 919/942-7935, 942-0600 1

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1 O e > q CERTIFICATE OF SERVICE

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I hereby certify that copies of this Discovery Requests to Applicants on Contention WB-3 (Drug Abuse During Construe. tion) were served on the ,

following persons by deposit in the U. S. Mail', postage prepaid, or by hand-delivery. OLKETED USNRC Thomas S. Moore, Chairman (appeals) M. Travis Payne ,

Atomic Safety & Licensing Appeal Board PO Box 12643 <g US Nuclear Regulatory Commission Raleigh, NC 27605 '85 MAY -8 A10 :18 Washington, D. C. 20555

• Dr. Richard D. Wilson Dr. Reginald Cotchy (appeals) 729 Hunter Street OFFICE OF SECRt!Ak' -

Atomic Safety & Licensing Appeal Board Apex, NC 27502 00CKETgyE9vir.f US Nuclear Regulatory Conunission Washington, D. C. 20555 Wells Eddleman 718-A Iredell Street Howard A. Wilber (appeals) Durham, NC .27705 Atomic Safety & Licensing Appeal Board K US Nuclear Regulatory Commission Richard E. Jones Washington, D. C. 20555 Dale Hollar Legal Department James L. Kelley Carolina Power & Light Atomic Safety & Licensing Board PO Box 1551 US Nuclear Regulatory Commission Raleigh, NC 27602 Washington, D. C. 20555 Thomas A. Baxter Glenn O. Bright Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Board 1800 M Street, NW US Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555 Robert Cruber Dr. James H. Carpenter Public Staf f-Utilities Commission Atomic Safety & Licensing Board PO Box 991 US Nuclear Regulatory Commission Raleigh, NC 27602 Washington, D. C. 20$55 Dr. Linda Little Docketing and Service (3 copies) Covernor's Waste Management Board Office of the Secretary 325 N. Salisbury St., Room $13 US Nuclear Regulatory Commission Raleigh, NC 27611 Washington, D. C. 20555 Spence W. Perry-(energ. planning)

Charles A. Barth Associate General Counsel Office of the Executive LeSal Director FEMA US Nuclear Regulatory Commission 500 C Street, SW, Ste. 480 Washington, D. C. 20555 Washington, D. C. 20740 Bradley W. Jones NRC-Region 11 This is the 1st day of May, 101 Marrietta Street 1985 Atlanta, CA 30303 Daniel F. Read j PO Box 2151 ' John Runkle l

Raleigh, NC 27602 Attorney at Law

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