ML20151T378

Second Request for Production of Documents Re Programs Described in Response to Second Set of Interrogatories & Results of Lie Detector Tests Performed Concerning Use of Illegal Drugs.W/Certificate of Svc.Related Correspondence

ML20151T378
Person / Time
Site:	South Texas
Issue date:	02/04/1986
From:	Sinkin L CHRISTIC INSTITUTE, Citizens Concerned About Nuclear Power, INC.
To:
References
CON-#186-984 OL, NUDOCS 8602100246
Download: ML20151T378 (4)

Text

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t FEg .~619sSc UNITED STATES OF AMERICA 2/4/86 c$ - fff NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD /

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In the Matter of (

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HOUSTON LIGHTING AND ( DOCKET NOS. 50-498 OL POWER COMPANY, ET AL. ) 50-499 OL (South Texas Project, (- ,

Units 1 and 2) )

CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. (CCANP)

SECOND REQUEST FOR PRODUCTION OF DOCUMENTS IO BEELICONIS Pursuant to the Licer.cing Board's November 18, 1985 Order and pursuant to 10 C.F.R. Sections 2.741, Citizens Concerned About Nuclear Power, Inc. (CCANP) herein makes its Requests for Production of Documents to be produced in accordance with the following instructions IQstCMChioGR

1. Each production response should include all pertinent information known to Applicants, their officers, directors, or employees, their agents, advisors, or counsel. Employees is to be construed in the broad sense of the word, including specifically 1

Houston Lighting and Power, Bechtel, Ebasco, any consultants, sub-contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.

2. The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, audits, slides, internal memoranda, informal notes, handwritten notes, tape recordings, procedures, specifications, calculations, analyses, and any other data compilations from which information can be 8602100246 060204 DR ADOCK 05000 0 g (()[jd?}3

l obtained.

3. As to each document provided, Applicants shall consider that providing the document constitutes an admission of its authenticity or provide, pursuant to Section 2.742(b) , the basis f or refusing to admit.

4. These requests for production of documents shall be continuing ' in nature and subject to supplementing should additional information become available..

5. For each item supplied in response to a request for production .of documents, identify said item by the specific question number to which it is a response. If the item is excerpted'from a document, identify said item also by the name of the document from which it is excerpted.

BeQ9ests 19C ECgdyctign

1. .All documents relevant to the programs described in answer to Interrogatory 1 of CCANP's Second Set of Interrogatories to Applicants dated February 4, 1986.

2. Documents containing the results of all lie de,tector tests performed on STNP personnel since January 1, 1985 in connection with inquiries related to use and/or sale of illegal drugs.

3. All documentation relevant to each test produced in response to Request for Production 2, including but not limited to all interpretations, analyses, and other evaluations of the results of the lie detector-test.

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4. All documentation of any investigation or inquiry conducted or being conducted on use and/or sale of illegal drugs as a f l

result of any answers received in response to the lie detector l tests produced in response to Request for Production 2.

5. All documentation on any in'estigation v or inquiry conducted since January 1, 1985 on use and/or sale of illegal drugs by STNP personnel not produced in response to Request for Production 4.

6. The exit interviews of all employees identified in answer to Interrogatory 9a of CCANP's Second Set of Interrogatories to Applicants dated February 4, 1986.

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Respectfully submitted, k

Lanny Alan Sinkin Christic Institute 1324 North Capitol Street Washington, D.C. 20002 (202) 797-8106 Counsel for Ir.tervenor ,

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' Citizens Concerned About Nuclear Power, Inc.

Dated: February 4, 1986 Washington, D.C.

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NUCLEAR REGULATORY COMMISSION c- O BEFORE THE ATOMIC SAFETY AND LICENSING BOARD o g aELATED CORRESPONP/-

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% 5 In the Matter of ( - O

, FEB =g HOUSTON LIGHTING AND ( Docket Nos. 50-498 OA" gj POWER COMPANY, ET AL. ) 50-499 (South Texas Project, ( g f" Units.1 and 2) (

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CEBIIEICAIE DE SEBVICE I hereby certify that copies of CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC.. (CCANP) SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO APPLICANTS were served by messenger (*) or deposit in the U.S. Mail, first class postage paid to the following individuals and entities on the 4th day of February 1986.

Charles Bechhoefer, Esquire Brian Berwick, Esquire Chairman Asst. Atty. Gen.

Atomic Safety and Licensing Board State of Texas U.S. Nuclear Regulatory Commission Environmtl. Protection Washington, D.C. 20555 P. O. Box 12548, Capitol Sta.

Austin, Texas 78711 Dr. James C. Lamb, III Administrative Judge Oreste Russ Pirfo, Esquire 313 Woodhaven Road Office of the Exec. Leg. Dir.

U.S. Nuclear Regulatory Comm.

Chapel Hill, North Carolina 27514 Washington, D.C. 20555 Frederick J. Shon Administrative Judge (*) Jack R. Newman, Esquire U. S. Nuclear Regulatory Commission 1615 L Street, NW, Suite 1000 Washington, D.C. 20555 Washington, D.C. 20036 Melbert Schwarz, Esquire Baker and Botts Mrs. Peggy Buchorn 300 Cne Shell Plaza Executive Director, C.E.U. Houston, Texas 77002 Route 1, Box 1684 Brazoria, Texas 77422 Atomic Safety and Lic. Bd.

U.S. Nuclear Regulatory Comm.

Diane Curran, Esquire Washington, D.C. 20555 Harmon, Weiss & Jordan 2001 S Street, N.W., Suite 430 Atomic Safety and Licensing Washington, D.C. 20009 Appeal Board U.S. Nuclear Regulatory Comm.

Pat Coy Washington, D.C. 20555 5106 Casa Oro San Antonio, Texas 78233 Docketing and Service Section Office of the Secretary Ray Goldstein U.S. Nuclear Regulatory Comm.

Gray and Becker Washington, D.C. 20555 901 Vaughn Bldg.

807 Brazos Aastin, Texas 78701 Lanny Sinkin

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