ML20210B919

Second Set of Interrogatories Re Use,Sale & Detection of Illegal Drugs at Facility.W/Certificate of Svc.Related Correspondence

ML20210B919
Person / Time
Site:	South Texas
Issue date:	02/04/1986
From:	Sinkin L CHRISTIC INSTITUTE, Citizens Concerned About Nuclear Power, INC.
To:	HOUSTON LIGHTING & POWER CO.
References
CON-#186-985 OL, NUDOCS 8602100150
Download: ML20210B919 (7)

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Er. ps

. Srcy.unfW s In the Matter of ( 4 U 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)

SgCQND SgI QE INIgBBQQeIQBIES Ig seeLICeNIS Pursuant to the Licensing Board's November 18, 1985 Order and pursuant to 10 C.F.R. Sections 2.740b, Citizens Concerned About Nuclear Power, Inc. (CCANP) herein propounds Interrogatories to Applicants to be answered in accordance with the following instructions:

lOsttuc_t i_ges

1. Each interrogatory shall be answered separately and fully as to each of its parts in writing under oath or affirmation, unless it is objected to, in which event the reasons- for objection shall be stated in lieu of an answer. The answers shall be signed by the person making them, and the objections by the attorney making them.

2. Each interrogatory 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

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

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3. Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory.

Do not combine answers.

4. These interrogatories shall be continuing in nature and subject to supplementing should additional information become available.

lO t ettogatot ies

1. Please provide a detailed description of any program in place at the South Texas Nuclear Project at any time since January 1, 1984 to detect the use and/or sale of illegal drugs by employees working on the Project.

2. For each program described in answer to Interrogatory 1, please provide the following information:

a. Whether the program included the use of tests, such as lie detector tests and urinalyses.

b. For those programs including the use of tests, which employee groups were subject to.such tests and which were not.

3. Please provide the name, job title, and address of the employees who administered or currently administer the program or programs identified in the. answer to Interrogatory 1.

4. Regarding the use of lie detector tests on STNP employees, please:

a. Specify what date lie detector tests were first given in connection with' inquiries related to use and/or sale of illegal drugs by STNP employees.

b. Provide all the dates when such tests were administered.

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c. For each date identified in answer to Interrogatory 4b, provide the name of the company or companies performing the lie detectors tests,

d. For each date and company identified in Interrogatory 4c, provide the names of the personnel who performed the tests and their employers.

e. Provide the questions that were asked in each test given on the dates identified in answer to Interrogatory 4b.

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f. For each date identified in answer to Interrogatory 4b, identify who made the selection of people to be tested.

g. For each date identified in answer to Interrogatory 4b, specify what criteria was used to select the people to be tested.

h. For each date identified in answer to Interrogatory 4b, provide the names of all employees who were given such tests and their positions at the time the lie detector tests were given.

i. For each person identified in answer to Interrogatory 4h, provide the name of the person or persons performing the test on that individual.

5. For each person identified in answer to Interrogatory 4h, state whether said person was considered to have passed or failed the lie detector test regarding the use and/or sale of illegal drugs. If some. evaluation category other that " pass" or " fail" was used, please specify what evaluations were used and provide the evaluation for each person identified in Interrogatory 4h as

.to the use and/or sale of illegal drugs.

6. If a lie detector test indicated possible or actual use and/or sale of illegal drugs, what procedure or procedures were followed 3

to further investigate such evidence?

7. If a lie detector test indicated possible or actual use and/or sale of illegal drugs, what procedure or procedures were to be followed regarding the employee tested?

8. For each person identified in answer to Interrogatory 4h whose evaluation indicated possible or actual use and/or sale of illegal drugs, please detail what subsequent actions, including termination, were taken and the personnel involved in taking those actions.

9. For each person terminated as a result of the lie detector tests identified in answer to Interrogatory.4, please provide:

a. The name, position, and employer on the Project at the time of their termination of each person terminated.

b. The name, position, and employer of the person or persons who evaluated the results of their test.

c. The .last known address and telephone number of each person terminated.

d. The name, position, and employer of the person responsible for their termination,

10. For each person identified in the answer to Interrogatory 4h, identify as completely as possible any other people said person identified as possibly involved in the use and/or sale of illegal drugs.

11. For each person identified in the answer to Interrogatory 10, please specify what further investigation was conducted regarding 4

the use and/or sale of illegal drugs by that person and specify the result of that investigation.

12. Regarding the Operations Group at STNP, please provide the f ollowing inf ormation:

a. The date said group was formed.

b. The functions of said group.

c. The names and employment history (date hired, positions held, date employment ended) of all personnel who were members of this group since the inception of the group.

d. The identity and last known address of any member of this group terminated for reasons related in any way to the use and/or sale of illegal drugs.

13. Please identify any of the employees in interrogatory 4h who implicated members of the Operations Group or the Operations Group generally in the use and/or sale of illegal drugs.

14. Please identify which members of the Operations Group were implicated by the individuals identified in response to Interrogatory 13.

15. Please provide the names and positions of any member of the Operations' Group, not identified in answer to Interrogatory 14, implicated at any time in the use and/or sale of illegal drugs at STNP.

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16. Please detail what actions were taken with regard to each individual identified in response to Interrogatories 14 and 15.

Res ectfully submitted,

, '1 Lanny Alan Sinkin Christic Institute 1324 North Capitol Street Washington, D.C. 20002 (202) 797-8106 Counsel for Intervenor, l Citizens Concerned About Nuclear Power, Inc.

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

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UNITED STATES OF AMERICA a?

NUCLEAR REGULATORY COMMISSION  %')#>

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-O BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g .  ; b II In the Matter of ( ,

HOUSTON LIGHTING AND ( Docket Nos.50-49d"OL. YS' POWER COMPANY, ET AL. ) 50-499 -

(South Texas Project, (

Units 1 and 2) (

CEBILEIC61E QE SERVLCE I hereby certify that copies of CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. (CCANP) SECOND SET OF INTERROGATORIES TO APPLICANTS were served by messenger (*) or be 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 P1rfo, Esquare 313 Woodhaven Road Office of the Exec. Leg. Dir.

Chapel Hill, North Carolina 27514 U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Frederick J. Shon Administrative Judge (*) Jack R. Newman, Esquire U. S. Nuclear Regulatory Commission 1615 L Street, NW, Sutte 1000 Washington, D.C. 20555 Washington, D.C. 20036 Melbert Schwarz, Esquare Baker and Botts Mrs. Peggy Buchorn 300 One 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 Austin, Texas 78701

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