ML20127M894
| ML20127M894 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/20/1985 |
| From: | Mcdaniel A CAROLINA POWER & LIGHT CO. |
| To: | CONSERVATION COUNCIL OF NORTH CAROLINA |
| References | |
| CON-#285-099, CON-#285-99 OL, NUDOCS 8505230382 | |
| Download: ML20127M894 (19) | |
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MAY te,1985 l
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UNITED STATES OF AMERICA Oggrto e
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAPETY AND LICENSING BOARD 22 M '45
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rg In the Matter of CAROLINA POWER & LIGHT COMPANY
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Docket No. 50-400 OL AND NORTN CAROLINA EASTERN
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MUNICIPAL POWER AOENCY
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Whearon Harris Nuclear Power Plant)
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4 APPLICAN115' ANSWERS TO CONSERVATION COUNCIL'S DISCOVERY REQUESTS TO APPLICANTS ON CONTENTION WB-3 (DRUG ABUSE DURING CONSTRUCTION) l Appuoents Carouna Power & Light Company and North Carouna Eastern Munlolpal Power Ageney, pursuant to 10 C.P.R. St.740b, hereby submit the fcuowing responses to
" Discovery Requests to Applicants on Contention WB-3 (Drug Abuse During i
Construction)." The provision of answers to these interrogatories is not to be deemed a i
representation that Appuoants consider the information sought to be relevant to the issues to be heard in this proceeding.
ANSWERS TO GENERAL INTERROGATORIES l
INTERROGATORY NO.1-WR. State the name, present or last known address, and present or last known employer of each person known to the Appuoants to have first-hand knowledge on whleh the responses to the speelflo interrogator es are based.
ANSWER: Appileants assume this question to mean those persons with "first-hand i
knowledge" of the speelfle responses as herein provided and, as such, the answer to this i
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. interrogatory is contahed in ATTACllMENT A attached hereto.
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INTERROGATOhi 10. 2-WN. Indentify those facts concerning whleh each person i
identitled in the response o 1-WM has knowled. ge.
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e ANSWER: The answer to this interrogatory is contained in ATTACllMENT A attached hereto.
INTERROOATORY NO. 3-WB. State the specific basis or facts which support each response.
ANSWER: The specific basis or facts supporting each response are indicated in the answere to each specific interrogatory.
INidRROOATORY NO. 4-WB. State the name, present or last known address, and present or last employer of each person who provided information upon which the Applicants relied in answereing (sic] each interrogatory herein.
ANSWER: The answer to this interrogatory is contained in ATTACllMENT A attached hereto.
INTERROOATORY NO. 5-WH. Indentify all such information which was provided by each such person and the specific interrogatory response in which such Information is contained.
ANSWER: The answer to this Interrogatory is contained in ATTACilMENT A attached hereto.
INTERROOATOltY NO. 6-WU.
State the name, address, title, employer and educational and professional qualifications of each person the Applicants intend to call as an expert or other witness at a hearing on this contention.
ANSWER: Applicants do not know at this time which, if any, expert or other witnesses they expect to call relating to this contention.
INTEltitOOATORY NO. 7-WH.
State the subject matter to which each person identified in 6-WH is expected to testify.
ANSWER: See answer to Interrogatory No. 6-Wil above.
INTEnitOOATORY NO. 8-Wil. Identify all documents in Applicants' possession, custody, or control, Inc!uding all relevant page citations, portalning to the subject matter of this contention and upon which Appliennts rolled upon in formulating responses to these interrogatories.
ANSWER: Documents in Appliennts' possession, custody, or control upon which Applicants rolled in formulating responses to those Interrogatories and which nre identified in nald responses will be made nynllable to a representative of the 2-
Conservation Council of North Carolina for inspection and copying at the corporate offices of Carolina Power & Light Company,411 Fayetteville Street Mall, Raleigh, NC.
The documents will be made available during CP&Us business hours. Appointments to inspect the documents may be arranged by telephoning Andrew McDaniel (CP&L Associate General Counsel) at (919) 836-6513. Inspected documents which the Council wishes to have copied will be reproduced by CP&L on a scheduto compatible with other demands for duplicating equipment. A CP&L employee will be made available during the inspection to receive any requests for copying. Copies of any such documents will then be furnished to the Council upon payment of 7 cents per page to meet CP&Us cost of reproduction.
INTERROGATORY NO. 9-WII. Identify all documents which Applicants indent (sic) to offer as exhibits at a hearing on this contention.
ANSWER: Applicants have not at this timo identified which documents, if any, they intend to offer as exhibits at any hearing on this contention.
INTERROGATORY NO.10-Wil. 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.
ANSWER: See ATTACllMENT A.
R. A. Watson Shenron llarris Nuclear Power Plant floute 1,llox 101 New lilli, North Carolina 27562 CP&Us Vice President -linrris Nuclear Project 11arney L. Rickenbacker 305 Lawyer's llullding Rntolgh, North Caroling 27602 CP&Un Director - Employco Assistance Program Hl'RCIFIC INTEllROG ATOlllES INTERROGAToltY NO. Il-Wil. Do the Appliennts ndmit to the veracity of the facts contained in the newspaper nrticle titled "O Arrested in Nucionr Plant Drug Probo,"
on pago I A of the Rntolgh NI?WM & OllNERVPlt, Janunty 11,1985, which was attached to the Conservation Council's Hequest for Addmission (sic) of New Contention Wil-3 (January 18, 1985)?
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ANSWER: Information indleated in the referenced newspaper article appeers to be an aceurate reporting of statements made. However, Applicants do not have information to sestantiate two statements attributed to Major T. W. Lanier of the Wake County Sheriff's Department.
INTERROGATORY NO.12-WB. If the answer to ll-WB is negative, whleh portions of the artiene are in Applicants' opinion not true or otherwise misleading?
ANSWER: 1) Drug use at the plant was widespread, mainly involving coesine.
- 2) About 100 of the 6,000 workers at the plant used drugs on the site.
INTERROGATORY NO.13-WB. For each portion of the artiene described in Il-WB whleh Appiloants do not admit to as true, please explain the basis for your assertion tliat t
that perilon is not true or otherwise misleading?
ANSWER: Following a two-months inveatisation by penfassional law enforcement offloors, including two undercover agents on-site, only six Inelividuals were identitled and arrested with two other Individuals,l.aving, warrants lesihR ff their arrest. fhe individuals were charged with possession with Intent to sell and deliver small amounts of s
&ugs. Eight workers in possession of dmgs, out 4f more than 6,000 workers at the site, I
does not constitute " widespread" uso; Major Lanier's estimate that about 100 'of the '
i 4,000 workers used &ugs at the site must be Yonsidered as en estimate without
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supportive evidence or basis.
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x INTERROGATORY NO.14-WB. Foi each of the eightyorkers (whle's includes the '
sin listed by name in the actiola and two more who had warrsts (assed for their arrest) identitled in the article described in ll-WB, please describe the pwitWeach held at the Harris construotlen site, the length of their emplo ment at the site,'ituispeelfic jobs
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whleh each performed (in detall enou(h that the an [s al NRC inspector could locate the
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actual area whleh the work was performe<t), who their supervise were 'during the different times of their employment at the Harth site, the onset ehefges brought against m
each one, and whether the jobs each had performed were reingeoted after their arrests.
t ANSWER: WORKEM #1:
[
h Job
Description:
Electriolaa 1.ength of Employment: 20-l/2 months Work Area / Performance Fuol llandling Hulldings installed non-safety related grounding, conduit, panels, cable tray supports, condult supports and t
safety related boxesi elevations 236', 286', 306' and L
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324' i
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1
WORKER #2:
Job
Description:
Electrician Length of Employment: 15 months Work Area / Performance: Fuel Handling Buuding instaued lighting raceways (non-safety related);
elevation 236' WORKER #3 '
l Job
Description:
Electrician Length of Employment: 9-1/2 months -
L Work Area / Performance: Fuel Handung Bundi f
instaued safety related conduits, box rs, cable tray, boxes; and non-safety related conduits, supports, raceways, cable trays elevations 216',236'
.and261' WORKER #4
' Job
Description:
Electriolan Length of Employment: 8 months Work Area / Performance: Fuel Handling Buuding; puuing cables (non-safety related); elevations 216',
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236', 261', 286' and 305' Weste Processing Buudings puulng omble (non-safety related): elevations 236',246',276' and 291 Rosetor Auxillary Buudings puuing emble (non-safety related) elevations 19F,280' and 308' Emergency Servloe Water intake Structure Seeurity Building Also performed cable research WORKER #5:
Job
Description:
Electriolan 4
Length of Employment: 6 months Work Area / Performance: Fuel Handling Huildings pulling cables (non-eafety related); elevations 216',
236',26l',286' and 305'
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Waste Processing Bulldings puulng emble (non-safety related) elevations 236',246',278' and 291 f
h Reneter Auxillary Buildings puulng cable (non-P safety related); elevations 19F,286' and 30S' g
gmergency servloe Water Intake Structures I
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Security Building j
i Also performed cable research WORKER #6:
Job
Description:
Electrician Length of Employment: 6 months Work Area / Performance: Fuel Handling Building; install safety.. related conduits and non-safety related conduits and supports; elevation 261'
/
M Reactor Containment Building; installing non-safety boxes and conduits WORKER #7:
- s. -
Job
Description:
Electrician Length of Employment: 58 months Work Area / Performance:. Temporary electrical work throughout the Plant; troubla calls on tower, polar and gantry cranes; oxygen sensors in Reactor Containment. Building and Fuel Handling Building; weld machine repair, lighting, cord repair, and electrical boards WORKER #8:
Job
Description:
Pipe Hanger Fitter Length of Employment 5 months Work Area / Performance: Various buildings involving fit-up on pipe hangers I
The above workers would have had numerous foremen, general foremen and supervisors during their different times of employment at the Harris site. Applicants have not undertaken an exhaustive search of the time cards relative to these workers to determine their foremen and supervisors.
The exact charges pending against the above workers are not specifically known by Applicants but such information is readily available as a public record on file in the General Court of Justice, Wake County Courthouse, Raleigh, NC.
The jobs the above workers performed were not reinspected after their arrests.
INTERROGATORY NO.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 Il-WB was working or had worked?
. ANSWER: ' A formal audit has not been performed because of the said arrests, although an evaluation of these workers' work has been conducted to assess any quality implications of their work. Audits do take place at the site, however, and it is possible that the work of these individuals has incidentally been subjected to audit under the on-
- going QA program.
INTERROGATORY NO.16-WB. If the answer to 15-WB was affirmative, please supply copies of any such QA/QC audit?
i ANSWER: Not applicable.
. INTERROGATORY NO.17-WB. Please supply copies of all inspection reports on the jobs performed by the workers identified above.
NSWER: Inspection reports are not recorded in all cases on the basis of individual
. craftsmen involved in the work. A reasonable effort has been made to identify reports -
. applicable to the ' work areas in which these individuals worked. These reports will be produced for inspection and copying per Applicants' response to Interrogatory No. 8-WB
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above.
INTERROGATORY NO.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).
ANSWER: There are presently no workers who Applicants are aware of using drugs while on the site. Consequently, Applicants have no "best estimate" to provide.
' INTERROGATORY NO.19-WB. How were the figures (or estimates) in 18-WB
' above derived? Please provide all bases and who exactly made the estimate.
ANSWER: See response to Interrogatory No.18-WB above.
. INTERROGATORY NO. 20-WB. What types of drugs are used by workers identified in 18-WB above? (Again,"best estimate" is adequate).
' ANSWER: See response to Interrogatory No.18-WB above.
INTERROGATORY NO. 21-WB. What is the Applicants' policy about workers using drugs while on site?
= ANSWER: See response to Interrogatories No. 31-WB,32-WB and 33-WB.
INTERROGATORY 'NO.
22-WB.
IIave any workers been fired, suspended,
- reprimanded,' or had other adverse job actions taken against them for using drugs while on site?-
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-.. - - -. - _ - - - - - -. - -..... ~ -,,
. ANSWER: Yes.
INTERROGATORY.~ NO. 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).
ANSWER: Reasonable searches of CP&L and Daniel International personnel records have been conducted to identify workers terminated for activities whb included use of drugs while on site. Applicants are not aware of any lesser adverse job actions
.taken'or of employees' of other contractors at the Harris site identified as having used drugs while on the site.- The following responsive information has been identi' ed:
WORKER A:.
Job
Description:
Utility (housekeeping)
DrugInvolved: marijuana Work Performed: general cleanup of work site in safety and non-safety related areas Work Reinspected:~No WORKER B:
Job
Description:
Carpenter's Helper Drug Involved: marijuana Work Performed: ~ carried lumber and materials during construction on Emergency Service Water Intake Structure Work Reinspected:.No-WORKER C:
Job
Description:
Utility (housekeeping)
Drug Involved: marijuana Work Performed: general cleanup of work site in safety and non-safety related areas Work Reinspected: No WORKER D:
Job
Description:
Sheet Metal Welder Drug Involved: marijuana Work Performed: welding on non-safety HVAC hangers and temporary supports.
Work Reinspected: No WORKER E:
Job
Description:
~ Utility (housekeeping)
Drug Involved: marijuana
- p.
Work Performed: general cleanup of work site in safety and non-safety related areas Work Reinspected: No WORKER F:
Job
Description:
Electrical Helper
- Drug Involved: marijuana Work Performed: install cable tray (non-safety related) in Waste Processing Building Work Reinspected: No WORKER G:
Job
Description:
Utility (tool room)
Drug Involved: marijuana Work performed: issue tools to craft personnel and maintain tool room area Work Reinspected: No
. WORKER H:
Job
Description:
Iron Worker Welder Drug Involved: marijuana Work Performed: are gouged the temporary eat walks off containment liner wall and installed electrical conduit supports in Reactor Auxiliary Building Work Reinspected: No
. WORKER I:
Job
Description:
Iron Worker Welder Drug Involved: marijuana Work Performed: are gouged temporary cat walks off _
containment liner wall and installed electrical conduit
- supports in Reactor Auxiliary Building
- Work Reinspected: No WORKER J:
Job
Description:
Truck Driver Drug Involved: marijuana Work Performed: delivered materials and equipment on job site and off-site to other plants Work Reinspected: No WORKER K:
Job
Description:
Truck Driver Drug Involved: marijuana Work Performed: delivered materials and equipment on job site and off-site to other plants Work Reinspected: No
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WORKER L:
Job
Description:
Truck Driver Drug Involved: marijuana Work Performed: delivered materials and equipment -
on job site and off-site to other plants Work Reinspected: -No.
INTERROGATORY: NO. 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-WB?
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- ANSWER: CP&L requested a meeting with the Wake County Sheriff's Department to explore.the merits of using undercover agents for drug use detection at the Harris Project.
INTERROGATORY. NO. 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..
ANSWER: On August 30, l'984, a written request was made by il. A. Watson, Vice
. President - Harris Nuclear Project, to then Captain T. W. Lanier, Wake County Sheriff's Department, to schedule a meeting to discuss illegal drug activity in the vicinity of the Harris-Nuclear Project. As a result of that meeting, arrangements were made for conducting an undercover operation at the Harris site involving the State Bureau of -
.-Investigation, the Wake County Sheriff's Department, and CP&L's security personnel.
INTERROGATORY NO. 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 includes, but is not limited to, searches of persons or property, urine sampling, and lie detector tests. Please describe each action in detail
~ ANSWER: The. actions taken include observation of incoming workers; periodic searches of lunch boxes, briefcases and other containers being carried by workers upon entering.the site; a search of these containers upon workers leaving the site; personal searches on site; urinalysis drug screen test; and the use of a narcotic detection dog.
In further detail, security personnel are at the entrances to the site and watch for physical signs of incapacity, i.e., staggering, falling, weaving, lack of coordination and odors.
These observations are also made by timekeeping and supervisory personnel
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assigned to monitor the entrance and exit of workers. On a random basis,' lunch boxes,
' briefcases and other containers are opened for inspection. Workers must open their containers 'in such a manner as to allow security personnel to view all contents and compartments thereof. Based on information and/or controlled substance possession /use
' discovered, identified workers are directed to submit to a search and/ot a urinalysis drug screen test. Security, Employee Relations and Industrial Relations personnel conduct the searches and arrange for the urinalysis drug screen test. Searches of workers include detail search of the individual's clothing, work area and any tools, equipment or personal property. ' Any vehicles within the construction security fence are subject to be searched also. At the direction of the Construction Security Unit, a narcotic detection dog is on site a minimum of two days per month. This dog is utilized to search a random sampling
- of areas on site. If specific requests or information is available relative to specific areas, those areas are given priority for search by the narcotic detection dog.
As included in the response hereafter to Interrogatory No. 33-WB, CP&L has undertaken programs to train its supervisory employees to recogniza aberrant behavior in workers, including symptoms of controlled substance abuse. The major construction contractor at the Harris site has also conducted training for its supervisory personnel.
Additionally, management at the Harris site encourages all site employees to observe and report any incident of controlled substance' abuse. CP&L's Quality Check Program allows employees to report drug abuse information and protects their identity. Information received is reviewed and forwarded to the proper level of supervision for follow-up.
Management has given site supervision a set of guidelines to follow in investigating alleged. controlled substance abuse. Under these guidelines allinspector personnel (QA, QC and CI) are required to submit to a urinalysis drug screen test if they are suspected
~ f using controlled substances.
o INTERROGATORY NO. 27-WB. Approximately how often are the actions in 26-WB
. conducted? - -. -
ANSWER: Personnel observation during entrance and exit - every shift change
- Lunch boxes, briefcases and container searches - every shift change Personal searches and urinalysis drug screen test - as warranted Narcotic detection dog-random two days per month at the direction of Construction Security Unit Employee and supervisory observations - on-going.
INTERROGATORY NO. 28-WB. Under what conditions are the actions in 26-WB conducted?
_ ANSWER: See answer to Interrogatory No. 26-WB above.
. INTERROGATORY NO. 29-WB. What criteria is used by management to determine L which workers are to be searched, etc., for possible drug abuse?
ANSWER: Criteria have not been specified for identifying workers to be searched for possible drug abuse. Rather, the procedures identify the necessary decision-makers and provide for case-by-case discretion in utilizing searches.
INTERROGATORY -NO. 30-WB. How many workers have been determined to be using &ugs from the actions described in 26-B?
ANSWER: The best available information is twenty-five (25)..
INTERROGATORY NO. 31-WB.
Please provide any documentation, including policy statement or manuals, which describe the Applicants' drug use policy.
ANSWER: Documentation. will be produced for Inspection and copying per
' Applicants' response to Interrogatory No. 8-WB above.
INTERROGATORY NO. 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? -
ANSWER: Yes.
INTERROGATORY NO. 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, u
who on the staff gives the program, who receives the program, and what the contents of any such program are.
ANSWER: CP&L employees assigned to the Harris site receive an instructional program entitled " Drug and Alcohol Abuse Orientation for CP&L Employees," which was initially presented by supervision, and subsequently by Employee Relations and the Harris Training Unit. The instruction addresses CP&L's Drug and Alcohol Abuse Practice and Procedures, the adverse impact of drug and alcohol abuse, and includes a description of the CP&L's Employee Assistance Program. A presentation by CP&L management is a part of the instruction, and the employee receives the " Drug and Alcohol Abuse Reference Manual."
Supervisors and managers at the Plant have attended a " Drug and Alcohol Workshop for Supervisors," initially presented by the Plant Manager or his designee, the plant personnel representative and/or designated instructor from the Employee Relations Department.
The purpose of the program is to provide the participants with a comprehensive review of CP&L's Drug and Alcohol Abuse Practices and Procedures, to review supervisory responsibilities, and to provide the participants with skills pertinent to implementing the Drug and. Alcohol Abuse Practices and Procedures. Subsequently, said training was incorporated as part of a Workshop in the Assessment of Aberrant Behavior - a 12 to 16-hour course presented by Management Consultants of Chapel Hill-which Workshop includes 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> devoted to drug and alcohol abuse problems, practices and procedures.
In addition, in 1984 CP&L and contractor supervisors received briefings at the Harris site by an outside consultant and a corporate office manager on drug and alcohol abuse. The. contractor, Danici International, also has a Supervisory Drug Awareness Program to advise supervisors on policy, practices and recognition of drug abuse.
Daniel's Technical Services Department personnel involved in QA/QC activities are likewise indoctrinated on policy, practices and recognition of drug abuse. L b
There is also an 8-hour Drug and Alcohol Abuse Training for Trainers program
' presented' by experienced Human Resources personnel to personnel directors and representatives, select Nuclear Operations staff, select Nuclear Training Unit instructors and select Employee Relations staff to enable these participants to train or provide
- support for the drug and alcohol abuse programs.
. INTERROGATORY NO. 34-WB. Do the Applicants have any drug rehabilitation program for Harris workers or recommend any such program for workers who may be using drugs on the site?
ANSWER: Effective April 1982, CP&L instituted an Employee Assistance Program designed to assist employees who develop personal problems. Part of this program is the availability of assistance in the rehabilitation process for drug related problems. Harris site contractors' employees involved in drug related problems have no formal rehabilitation programs that CP&L is aware of, other than health insurance coverage, due to the temporary nature of their duties.
INTERROGATORY NO. 35-WB. If the answer to 34-WB is affirmative, please submit details of any such programs, including but not limited to the number of employees referred,' who conducts the program, and what the contents of any such program are.
ANSWER: CP&L's Employee Assistance Program is operated by Mr. Barney Rickenbacker, whose title is Director - Employee Assistance Program. Mr. Rickenbacker answers directly to the Senior Vice President - Corporate Services.
As noted in CP&L's Drug and Alcohol Abuse Reference Manual, any employee who reports personal abuse of drugs or controlled substances before it is observed on the job will be counseled and will be referred to the Employee Assistance Program. Employees may also refer themselves to the program should they desire. However, when one of these approaches takes place, each employee is provided with the information that a temporary reassignment of duties may be necessary and that participation in the Employee Assistance Program does not guarantee their continued employment.
I.
Since the beginning of this corporate program, no CP&L employee at the Harris site has been involved in rehabilitation efforts for drug abuse.
Thomas A. Baxter SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D. C. 20036 (202) 822-1090 A)
Andrew McDaniel
' CAROLINA POWER & LIGHT COMPANY 411 Fayetteville Street Raleigh, N. C. 27602 (919) 836-6513 May 20, 1985 ATTACHMENT A
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N. J. Chiangi Answers 15-WB and 16-WB Shearon Harris Nuclear Power Plant Route 1, Box 101 '
New Hill, NC 27562 employed by CP&L John D. Ferguson Answers 21-WB, 22-WB, 23-WB, Shearon Harris Nuclear Power Plant 31-WB, 32-WB, 33-WB, 34-W D, Route 1, Box 93 and 35-WB New Hill, NC 27562 employed by CP&L W. J. Hindman Answers 11-WB,12-WB,13-WB, Shearon Harris Nuclear Power Plant and 14-WB -
Route 1, Box 101 New Hill, NC 27526 employed by CP&L Mike King.
. Answers ll-WB,12-WB,13-WB, 411 Fayetteville Street Mall 14-WB,18-WB, 19-WB, 20-WB, P. O. Box 1551 22-WB, 24-WB, 25-WB, 26-WB, Raleigh, NC 27602 27-WB, 28-WB, 29-WB and
- employed by CP&L.
30-WB Reid Pannill Answers 22-WB and 23-WB Shearon Harris Nuclear Power Plant Route 1, P. O. Box 105 New Hill, NC 27562 employed by DanielInternational Roland M. Parsons -
Answer 17-WB Shearon Harris Nuclear Power Plant Route 1, Box 101 New Hill,'NC 27562 employed by CP&L,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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Docket No. 50-400 OL AND NORTH CAROLINA EASTERN
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MUNICIPAL POWER AGENCY
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)
(Shearon Harris Nuclear Power Plant)
)
WAKE COUNTY NORTH CAROLINA AFFIDAVIT OF R. A. WATSON R. A. Watson, being duly sworn according to law, deposes and says that he is Vice President - Harris Nuclear Project Department for Carolina Power & Light Company; that the answers to interrogatories on Contention WB-3 contained in
" Applicants' Answers to Conservation Council's Discovery Requests to Applicants on Contention WB-3 (Drug Abuse During Construction)" are true and correct to the best of his information, knowledge and belief; and that the sources of his information and belief are employees, agents and contractors of Carolina Power & Light Company.
b 17hM R. A. Watson Sworn to and subscribed before me this @d day of May,1985.
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May 20,1985 UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DOCKETED USNRC In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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E MY 22 #0:45
. AND NORTH CAROLINA EASTERN
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Docket No.
50-400 OL MUNICIPAL POWER AGENCY
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0FFICE OF SECRt:1/,9y
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00CKETlNG & SERVict (Shearon Harris Nuclear Power Plant)
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BRANCH
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CERTIFICATE OF SERVICE I hereby certify that respective copies of " APPLICANTS' ANSWERS TO CONSERVATION COUNCIL'S DISCOVERY REQUESTS TO APPLICANTS ON CONTENTION WB-3 (DRUG ABUSE DURING CONSTRUCTION)" and " NOTICE OF APPEARANCE" were served this 20th day of MAY,1985 by deposit in the United States Postal Service, first class, postage prepaid, to all parties on the attached Service List.
This the 20th day of May,1985.
//A /h) b AncreviFMcDaniel ~
Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6513
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SERVICE LIST James L. Kelley, Esquire M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Mr. Glenn O. Bright Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulaiory Commission Apex, North Carolina 27502 Washington, D. C. 20555 Mr. Wells Eddleman Dr. James H. Carpenter 718-A Iredell Street Atomic Safety and Licensing Board Durham, North Carolina 27705 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Thomas A. Baxter, Esquire John H. O'Neill, Jr., Esquire Charles A. Barth, Esquire Shaw, Pittman, Potts & Trowbridge Myron Karman, Esquire 1800 M Street, NW
' Office of Executive Legal Director Washington, D.C. 20036 U. S. Nuclear Regulatory Commission Wr.shington, D. C. 20555 Bradley W. Jones, Esquire U. S. Nuclear Regulatory Commission
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. Docketing and Service Section Region II Office of the Secretary 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555 Robert P. Gruber Mr. Daniel F. Read, President Executive Director Chapel Hill Anti-Nuclear Public Staff Group Effort North Carolina Utilities Commission Post Office Box 2151 Post Office Box 29520 Raleigh, North Carolina 27602 Raleigh, North Carolina 27626-0520 Dr. Linda Little John Runkle, Esquire Governor's Waste Management Board Conservation Council of North Carolina 513 Albemarle Building 307 Granville Road 325 Salisbury Street Chapel 11i11, North Carolina 27514 Raleigh, North Carolina 27611 k
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