ML20129H073

Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention WB-3

ML20129H073
Person / Time
Site:	Harris
Issue date:	07/12/1985
From:	Baxter T CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20129H070	List: ML20129H067 ML20129H073 ML20129H082 ML20129H087 ML20129H091 ML20129H094 ML20129H099 ML20129H106
References
OL, NUDOCS 8507180495
Download: ML20129H073 (3)

Text

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4 00CdETED July 12, 198 g5MC

'85 JL 17 AICn58 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CFFICE JF SECRt,Tr,9 y 00CHETING & SERvect~

BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL -

MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

Plant) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CCNC CONTENTION WB-3)

Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support of their Motion for Summary Disposition of CCNC Conten-tion WB-3 (Drug Abuse During Construction), that there is no genuine issue to be heard with respect to the following materi-al facts:

1. Approximately 26,000 personnel have been employed at the Harris Project since January, 1978.

2. Drug abuse in the workplace is a societal problem in the United States.

3. Total elimination of drug activity at a construction site is not practically achievable.

4. Applicants have adopted firm policies to deter drug use at the Harris Project.

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5. Applicants have undertaken reasonable efforts to im-i plement those policies effectively at the Harris Project.

6. Applicants have a reasonably effective capability to

identify violators.of the drug abuse policies.

7. Applicants have terminated or otherwise removed from the project employees who violate the drug abuse policies.

8. No employee has been identified as having performed safety-related work while physically impaired due to the influ-ence of drugs. i

9. No safety-significant construction deficiency has been identified as being caused by an employee impaired due to the influence of drugs, i

10. The Quality Assurance program for construction of the Shearon Harris Nuclear Power Plant has the same capability to identify any safety-significant construction deficiency caused I

l by any employee impaired due to the influence of drugs, as it i

does to identify such deficiencies from other causes.

11. There has been no breakdown in quality assurance pro-cedures, and no pervasive failure to carry out the quality t

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s assurance program, at the Shearon Harris Nuclear Power Plant.

Respectfully submitted, Thomas A. Baxter SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1090 Richard E. Jones Dale E. Hollar CAROLINA POWER & LIGHT COMPANY 411 Fayetteville Street Mall Raleigh, North Carolina 27602 (919) 836-6517 Dated: July 12, 1985 I

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