ML20215K552
| ML20215K552 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/20/1986 |
| From: | Kohn S, Michael Scott COALITION FOR RESPONSIBLE ENERGY EDUCATION, GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| CON-#486-1277 2.206, NUDOCS 8610280209 | |
| Download: ML20215K552 (25) | |
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C0ALITION FOR RESPONSTBLE FNEPGY FDt1CATTON 315 West Riviera Drive Tempe, AZ 85282 09[;k!U l
October 20, 1986 Director, Office of Inspection and Enforcement i
i U.S. Nuclear Regulatory Commission
~86 0CT 27 P3 37 l
Washington, D.C. 20555 l
RE: Show Cause Petition Pursuant to 10 CFR 2.206(g) In the '4atter 2
of Arizona Public Service Company, et al. (ArizorfECNuclear Power Project - Palo Verde Nuclear Generating Station), Requesting l
3 Hearings on Management Character and Competence of Licensee.
j Docket Nos. 50-528, 50-529, and 50-530.
i 4
5 1.
This petition is brought by the Coalition for Responsible 6
Energy Education (hereinafter " CREE") before the Director, Office 7
of Inspection and Enforcement, pursuant to 10 CFR 2.206(a).
8 Petitioner submits that recent-deposition testimony by an Arizona H
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9 Public Service Company contract polygraphist (attached Exhibit A,
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go fully incorporated by reference) regarding apparent falsification j
11 of company documents by Executive Vice President E. E. VanBrunt, Jr.,
i and j
12 during the period of his employment by Arizona Public Service, j
13 by certain other top level Palo Verde and APS management personnel,
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14 and apparent false statements to the same company contract poly-l I
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- ra phis t raise serious questions of the fitness of Arizona Public 16 Service to hold licenses for Palo Verde Nuclear Generating Starinn 17 Jnits 1, 2 and 3.
Therefore, CREE requests the scheduling of 4
13 public hearing on APS/Palo Verde plant management character and
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- ompetence and the issuance of an Order to Show Cause why the l
20 aperating licenses for the Palo Verde units should not be lifted, f
21 DESCRIPTION OF PETITIONER I
22 2.
CREE is a non-pr'ofit volunteer organization based in Arizona, j
23 principally Maricopa County.
CREE's headquarters are located at 24 315 W. Riviera Dr., Tempe, AZ 85282.
CREE has represented its-
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25 members and the public interest in show cause petitions filed with l
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26 the NRC and in proceedings before the Arizona Corporation Commissio 1.
i 8610280209 861020
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AUTHORITY 2
3.
Title 10 of the Code of Federal Regulations 2.206(a) i 3
establishes the right of the public to petition the Commission, 4
Director of the Office of Inspection and Enforcement, and other 5
specified directors to institute proceedings pursuant to 10 CFR 6
2.202 for such relief as may be proper.
The Commission may, 7
pursuant to 10 CFR 2.206(a)', institute such a proceeding by serving 8
upon the' licensee an Order to Show Cause.
9 4.
In Houston Lighting and Power Co. (South' Texas Project, Units 10 1 and 2) CLI-80-32, 12 NRC 281 (1980) and other proceedings, the 11 NRC has recognized that management competence and integrity are 12 issues affecting the qualification of licensees.
Moreover, the 13 legislative history of the Energy Reorganization Act and numerous j
14 specific sections of 10 CFR recognize the importance of management 1
15 integrity and character and the ability of the NRC to rely on.the
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16 validity of licensee documentation and representati6ns as an indis-17 pensable adjunct to the regulatory procesn.
18 STATEMENT OF FACTS
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19 5.
During the period of February 27, 1986 through approximately 20 March 11, 1986, Continental Security Systems polygraphist Molly 21 Cannon, under contract to Arizona Public Service Company / Arizona 22 tuclear Power Project,, performed lie detector tests regarding an 23 alleged employee' leak,of Safeguards Information to local news media 24 on some 30 APS, employees, including plant security personnel, quality i
25 control and assurance personnel, compliance officers ~, public rela-26 tions officers, and executives.
In the course of conducting those f
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1 exams, the polygraphist formulated a number of " control" auestions 1
3 designed to test the reactivity and deception patterns of test r
3 subjects.
(The polygraph exams themselves are the subject of a 1
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4 separate 2.206 petition filed by CREE with the Director 0.I.E. on i
5' July 16, 1986.)
6 6.
In the course of a deposition on October 14, 1986, polygra-7 phist Molly Cannon in sworn testimony confirmed that several APS t
g management officials had tested deceptive in response to these 9
control questions.
The control questions involved previous acts l
I 10 of company document falsification, lying, and theft in the course 11 of employment.
The APS officials cited as having provided deceptive l
12 responses were:
E. E. VanBrunt, Jr., Executive Vice President and i
13 plant manager; Danny Canady, APS public relations; Frank Kroll,
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14 APS Corporate Security Chief; Jerry Haynes, Vice President reportinn 15 to Mr. Van Brunt; David Lanier, licensing engineer; and Bill Ide, 16 quality control / quality assurance chief.
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17 7.
According to Ms. Cannon's sworn testimony (Exhibit A, page i
18 19), Mr. Van Brunt tested " deceptive" in denying falsification of 19 company documents or paperwork for personal gain between the ages t
j 20 of 40 and 50.
During that entire time, Mr. Van Brunt was employed t
21 by Arizona Public Service Company and involved with the constructior,
22 startup and licensing of the Palo Verde project.
Presen.tly, Mr.
23 Van Brunt is 54 years old and supervises both operatin.g and pre-
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24 operational units at Palo Verde.
Mr. Van Brunt, moreover, is the
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25 primary conduit for NRC communications with the licensee.
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1 8.
The records of polygraph exams submitted by Ms. Cannon also 2
appear to indicate that Mr. Van Brunt and other APS/ANPP officials l
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who ordered the polygraph exams to investigate an alleged violation 4
of Safeguards Information rules did not know all elements of the 5
definition of Safeguards Information, although Ms. Cannon claims l
6 the records are in error on this single point.
7 CONCLUSIONS OF LAW l
8 9.
The testimony of the APS polygraphist Molly Cannon raises 9
serious questions about:
U The apparent falsification of company documents for personal gain by Mr. Van Brunt and possibly other APS/
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Palo Verde management officials during the period of l
their employment by.the licensee; g
the honesty of the above-named APS management officials y3 during their polygraph exams; 14 the apparent bad faith of APS/Palo Verde management
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officials in crdering plant employees to be poly-U graphed as a condition of employment while themselves apparently providing deceptive answers in response to l
96 polygraphist's questions, and in ordering such tests l
for an alleged violation of Safeguards Information 9.,
3 provisions while incompetent'to judge Safeguards Infor-mation issues.
I 10.
These questions strongly suggest APS/Palo Verde management i
g character incompetence sufficient to justify revocation or suspen-20 sion of all Palo Verde licenses on the grounds'of 1icensee lack of integrity and lack of fitness to hold those licenses.
11.
The testimony of the polygraphist regarding the test of plant g
manager E. E. Van Brunt, Jr., particularly in light of previous NRC 1
g enf r ement actions and previous CREE.2.-206 concerns regarding APS l
25 26 management competence and character further justifies revocation or f
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4 ll 1
5.
1 suspension 2
12.
The integral role of licensee documentation to the regula-3 tory process further justifies such stringent enforcement action.
4 RELIEF REQUESTED.
5 13.
WHEREFORE, for all the foregoing reasons, grounds and au
- 6 thorities, CREE and the undersigned hereby respectfully request the 7
following actions:
8 Issuance of an Order to Show Cause why the licenses and permits for all three Palo Verde. units should 9
not be suspended or revoked based upon management character incompetence and lack of. integrity; j
10 Investigation to determine the severity and extent of apparent document falsification by Palo Verde 11 Nuclear Generating Station officials; 12 Ordering of public hearing on the forego'ing; Issuance of a' civil penalty or such add.itional 13 enforcement action as may be deemed necessary.
14 RESPECTFULLY SUBMITTED this 21st day.of October, 1986.
15 C '?
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BY: mW r.VW MYsDN L. SCOTT
,7 Intervention Coordinator
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CREE 18 315 W. Riviera Dr.
Tem AZ l 528/
9 and:
t 20 i
STEPHEN M. KOHN G vernment Accountability 2,
Project 1555 Connecticut Ave., NW 22 Washington, D.C.20036 23 cc: U.S. Nuclear Regulatory Commission Arizona Public Service Company 24 Director, NRR the general public j
25 26 i
2 Esaisir /1-1 1
2 1EDEE 3
4 EXANINATION Page 5
By:
Mr. Kohn 5, 93 6
7 By:
Ms. Payne 75 8
9 10 EXHIBITS 11 No. 6 Van Brunt Polygraph examination file 8
12 No. 86-0410 13 No. 7 The Pill Book of High Blood Pressure 24 14 No. 8 The Pill Book of Anxiety and Depression 24 15 No. 9 The Pill Book 24 16 No. 10 Examiner's data sheet for Frank Kroll 32 17 No. 11 Handwritten test questions for Frank 39 Kroll 18 i
No.12 ' Typed test questions for Frank Kroll 39 I
19 No. 13 Examiner's data sheet for Jerry Haynes 48 20 No. 14 Typed test questions for Jerry Haynes 50 21 No. 15 Examinar's daca sheet for Danny Canady 53 22 dated 2/27/06 23 No. 16 Handwritten test. questions for Canady 55 dated 3/27/86 24 i
25 i
VOSS & ASSOCIN2ES, INC.
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No. 17 Examiner's data sheet for Canady dated 63 3/7/ 86 2
No. 18 Handwetten test questions for Canady 66 3
dated 3/7/06 4
No. 19 Examiner's data sheet for David Lanier 75 5
No. 20 Handwritten test questions for Lanier 77 6
No. 21 Typed test questions for Lanier 80 7
No. 22 Examiner's data sheet for William Ide 82 8
No. 23 Handwritten test questions for Mr. Ide 84 9
No. 24 Typed test questions for Mr. Ide 87 10 11 12 i
13 14 15 16 l
17 18 f
19 20 21 22 23 24 25 VOSS & ASSOCIATES, INC.
1 2
3 DEPOSITION OF tiOLLY CAliNON 4
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commenced at 5:35 p.m. on October 14, 1923, at the offices 6
of SNELL & WILMER, 2900 Valley Bank Center, Phoenix, 7
Arizona, before CAROL KELLY REILL, a Notary Public in and 0
for the County of Maricopa, State of Arizona.
9 10 11 12 APPEARANCES:
13 For the Complainant:
14 GOVERN!!ENT ACCOUNTABILITY PROJECT 15 Mr. Steven M. Kohn Ms. Deth Payne 16 COALITION FOR RESPONSIBLE ENERGY EDUCATION 17
!!r. Myron Scott Ms. Lyn McKay 18 For the Respondent:
19 SHELL & WILMER 20
!!r. William R. Hayden Ms. Rebecca A. Winterscheidt 21 Also present:
22 Mr. Blaine Thompson 23 24 25 vnss r. AASOCTATES. THC.
f Bym air Al-E 8
1 identification.)
2 Q.
(BY MR. KOHN)
I am showing you an item 3
marked CX-6.
Do you know what that is?
4 A.
That's a consent form signed by Mr. Van 5
Brunt.
6 Q.
CX-6 says in the upper lef t-hand corner, it 7
has File No:
86-0410 in the right-hand corner.
It has 8
Time In:
10:30, circled, a.m.
9 okay.
Also, for the record, the form 10 consists of two types of markings on it.
One was done in 11 pen and one, it appears to be a form that was typed.
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i 12 In relationship to the typed part of this, 13 did you type it out yourself?
14 A.
No, I had it typed out.
15 Q.
Did you draft the language of this form?
16 A.
Yes.
17 Q.
Is this a standard form you use?
18 A.
I use this consent form for all tests that I 19 do, yes.
20 Q.
How long have you been using this consent 21 form?
22 A.
Since 197 8 or 1979.
It was a change 23 regarding the company.
24 Q.
Is the handwriting on this -- is any of the 25 handwriting on this yours?
crna:La>\\c446rauwEL mrt
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A.
The " File No." is mine, the "Tima In" is 2
mine, " Time Out" is mine, " Authorized to receive report" 3
with Mr. Frank Kroll's name is mine, and I am the witness.
4 Q.
The signature, do you know who' signed this 5
form under " Examinee's signature"?
6 A.
Mr. Van Brunt.
7 Q.
Is that your standard operating procedure, 8
you will have the person who took the exam sign it?
9 A.
Yes.
10 Q.
In your pre-test at any time during your 11 polygraph examination -- what I mean by polygraph 12 examination, I am talking about from the moment you had 13 contact with him, or any of the examinee's walk in and you 14 meet them in the lobby, your first contact with them until 15 your absolute last contact with them and they are walking 16 out the door, whenever I say that in the examination, 17 that's the period that I mean.
18 During your examination of Mr. Van Brunt, did.
19 you ever mention the Arizona Republic newspaper?
20 A.
Yes, I am sure I did.
21 Q.
Do you remember what the conversation was 22 about the Arizona Republic?
23 A.
Uell, I remember discussing the article that 24 had come out and the information that led up to that i
25 article.
f 10 1
Q.
Did you show him a copy of that article?
2 A.
Well, I believe that we discussed that 3
earlier and I think that I did show him a copy.
4 Q.
Did you discuss what was contained in the 5
article at all?
6 A.
I believe we discussed the general Safeguard 7
information.
8 Q.
Did he talk to you in any way about that 9
article?
Did he comment about it or what did he say?
10 A.
I don't really recall.
11 Q.
Did the name John Staggs come up in the i
12 conversation?
13 A.
Yes, because he was the author of the i
14
- article, 15 Q.
Can you remember what was discussed about 16 John Staggs?
17 A.
!!r. Van Brunt had received a call f rom Staggs 18 a couple of days prior to this polygraph regarding 19 information that came from the exit interview.
And I 20 believe that that's how we tied the article into the 21 reason for the test.
22 Q.
Did he have anything to say about tir. Staggs?
i 23 A.
Well, he said he talked to him on the phone a 24 few days prior.
25 Q.
Did he give any characterization of his
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personality or the type of person he was?
2 A.
Not'that I recall.
3 Q.
Did you ask him about Staggs like "Uhat type 4
of person is Staggs?
What do you think of Staggs"?
5 A.
No.
6 Q.
Did you discuss any other newspaper reporters 7
or any other newspapers?
8 A.
Not that I recall, no.
9 Q.
Did you discuss who he suspected may have 10 been a Safeguards leak?
11 A.
I asked him who he suspected.
De said there 12 was no one in particular that he suspected.
He gave me no 13 names.
14 Q.
Did you ask him what information, what 15 Safeguards information had been released?
16 A.
I don't know that I did, no.
17 Q.
Did you discuss any employees of APS?
Did 18 the name of any other employee at APS come up in the 19 conversation?
20 A.
Not that I recall.
21 Q.
Did he discuss anything about CREE, the 22 Coalition for Responsibility Energy for Education?
Did 23 that come up in the conversation?
24 A.
No.
25 Q.
Did the NRC come up in the conversation?
cw
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A.
I believe that the NRC would have been 2
discussed because of the nature of the information that 3
was coming from Staggs.
At one time van Brunt had thought 4
that Staggs must have gotten his information from the NRC.
5 There was too much specific information being presented to 6
him from Staggs.
7 Q.
Is that what he said to you or is that what 8
you got from Kroll and Nelson from the other meetings?
9 A.
No, I got that from Van Brunt.
10 Q.
Can you remember what else he said?
11 A.
In terms of?
12 Q.
Of his conversation with Staggs and going i
13 into that Staggs had too much information.
14 A.
No.
l 15 Q.
In the questions as we were going through 16 them, I think we got up to question number --
l 17 MS. PAYNE:
Five was the last one we 18 spoke about.
19 Q.
(B'l MR. KOHU)
Question No. 6.
Let me just 20 give you -- this reads:
"During the first 30 years of 21 your life can you recall ever telling a lie to an employer 22 that could have gotten you fired?"
Do you remember asking 23 that question?
24 A.
Yes.
25 O.
Do you know why you put "the first 30 years
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of your life"?
2 A.
Well, that's when we talked earlier about 3
control questions.
It is a control question.
In o: der to 4
make a control question work properly, I need to put a 5
time element in it.
6 Q.
When you say "a control question," does that 7
mean you are asking one that you are expecting that he 8
will answer truthfully?
l 9
A.
No.
10 Q.
Do you instruct him to answer?
11 A.
I don't' instruct him.
I ask it in a manner 1
12 that I hope will elicit a deceptive reaction.
i l
13 Q.
"During the first 30 years of your life can 14 you recall ever telling a lie to an employer that could 15 have gotten you fired?"
His answer was no; right?
16 A.
Right.
17 Q.
But you were expecting him to be deceptive 18 with that answer?
19 A.
Right.
20 Q.
Did you tell him to answer no?
21 A.
No.
22 Q.
Did you.tell him to lie?
23 A.
No.
I work the question.
I present the 24 irrelevant and the relevant concerning this inaue.
Those 25 we discuss and we work out together.
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But with control questions, at the end of 2
reviewing the relevance, I take control of the interview 3
and I set up those control questions hoping to elicit a 4
lie so that I have a comparison.
5 There are cases where that doesn't work or 6
the person isn't giving me the deceptive answer.
Then I 7
would say to them:
I am going to ask you, are you 30 8
years of age?
I want you to tell me yes, when in reality j
9 you are 45.
That's called the direct lie.
This itself is 10 called the control.
11 Q.
He answered no.
You assume that he did tell 12 a lie in his first 30 years that could have gotten him 13 fired?
l 14 A.
There is a real good chance that any person 15 in an executive position would have told a lie of some 15 credence in the first 30 years.
17 Q.
Did you ask him if he told a lie on that one?
18 A.
I did, but I asked it in a way that I hoped 19 he would tell me no so that I would get a lying answer to 20 that so I can compare the unknown.
Is he the one that 21 gave out the safeguard information?
I did this in order 22 to make sure that he was being truthful when he said no, 23 he hadn't given out Safeguard.
24 Q.
How do you know that question No. 6 is a lic?
25 A.
I know that it was a lie because there was a
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deceptive reaction to that on the test.
2 Q.
There was a deceptive reaction on the test?
3 A.
Yes.
4 Q.
When it says NDI, there could have been a 5
dec'aptive reaction?
6 A.
In the polygraph exam -- my job in this case 7
was to find out who had leaked Safeguard information.
So j
8 I know as humorous as it seems, I sure hope we don't get 9
this control thing lost, because it's the key to 1
10 polygraph.
11 I lost my thought.
12 MR. EAYDEN:
If I can refresh the 13 witness's recollection, the question was, and correct me 14 if I am wrong, that your ultimate conclusion in this test 4
15 as indicated by the earlier document was, whatever your 16 letters were, how could you say he was not deceptive?
17 I think Mr. Kohn's question was:
How could 18 you have concluded that he was NDI if in fact there was a 19 deceptive response to this question?
If you can answer 20 that.
21 THE WITNESS:
The test that I am being 22 asked to conduct is to verify Nos. 3, 5, 3 and 9.
Those 23 are your relevant questions and those are the questions 24 that we are going to be concerned about.
25 If there is no deception in those areas, l
R'RR
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there is no deception because I was able to score a higher 2
score in my controls.
Then that person has not been 3
deceptive regarding the test I have been paid to conduct.
4 The control questions are very private.
I 5
never give the answers to the employer.
In fact, I 6
normally don't give the control questions.
There is no 7
reason.
I say, "By the way, I asked hLa if lied."
It 8
enables me to do the control test.
~
9 Q.
(BY MR. KOHN)
"Is today Thursday?"
That's 10 question No. 7.
What was that question?
11 A.
That's called an irrelevant.
It's just --
12 you may call it a calming question.
Gives the person a 1
13 chance to just react regularly, normally, not having to j
14 give too much thought.
Just an irrelevant question.
We 15 space out the irrelevant questions.
16 Q.
He answered that yes.
Was it Thursday, do 17 you know?
Was that a truthful answer?
18 A.
Yes, I believe so.
I don't try to trick them 19 on irrelevant questions.
20 Q.
With an irrelevant one, would you also use an 21 indication -- look at'the chart to see what someone is 22 like when they are asked a calming question?
23 A.
No.
24 Q.
Essentially when you went back and read the 25 chart, you didn't even have to look at the answer to No.
17 1
77 2
A.
Correct.
3 Q.
Now No. 8.
" Prior to February 14 did you 4
know that Safeguard information was to be given on a 5
'need-to-know' basis only?"
Did you ask that question to 6
Mr. Van Brunt?
7 A.
Yes.
8 Q.
According to your notes, how did he answer 9
that?
10 A.
Well, it's marked here no.
But he answered.
11 yes.
I obviously made an error in going over these notes.
12 Q.
He answered yes?
13 A.
He answered yes to that.
14 MR. KOHN:
Once again, Bill, I think 15 it's obvious the need to -- I don't want to beat a dead 16 horse on this one.-
17 Q.
(BY MR. KOHU)
Why did you use the February 18 14th date?
19 A.
I believe the exit interview was on or about 20 that date.
21 Q.
On what basis do you think that he answered 22 that yes?
23 A.
Because the end result was that he was being 24 truthf ul. throughout the test.
If a person admits to a 25 question -- if the person says, no, I didn't know that, awn
. _ _ _._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ J 18 1
then there is no sense in asking the question on the test.
2 If he had said to me -- the question reads:
Did you know 3
that Safeguard information was to be given out on a 4
need-to-know basis only?
If his answer had been no, then 5
I wouldn't have asked that on the test because he has 6
already answered that question.
But the fact that he is 7
telling me, yes, he knew that --
8 Q.
According to your notes here it was no.
9 A.
Again, I typed these up trying to be helpful 10 after the fact.
11 Q.
But you put ir the little numbers here?
12 A.
Right.
13 Q.
Did you discuss with Mr. Van Brunt what 14 "need-to-know basis only," what that all meant?
15 A.
I believe we did, yes.
16 Q.
Do you have any specific recollection of a 17 conversation with Mr. Van Brunt?
18 A.,
No.
19 Q.
Question No. 9 reads:
"Have you furnished 20 classified / Safeguard information to anyone without 21 authorization?"
Did you ask that question?
22 A.
Yes.
23 Q.
What was his response?
24 A.
No.
25 Q.
Do you know why you asked that question?
19 1
A.
Hell, that's the main issue giving out that 2
Saf eguard information to unauthorized persons.
i 3
Q.
Now, why did you use " classified slash 4
Safeguard"?
5 A.
I just did.
6 Q.
No. los "Between the ages of 40 and 50 did 7
you f alsify company paperwork or documents for personal 8
gain?"
What type of question was that?
9 A.
That's a control question that I am hoping to 10 elicit a deceptive reaction.
11 Q.
How did he answer that question?
12 A.
No.
13 Q.
Do you remember if he tested deceptive on 14 that one?
15 A.
Yes, he was deceptive on that.
16 Q.
What about question No.11?
17 A.
That is another control.
18 Q.
"Would you lie to me if you thought you could 19 beat this test?"
20 A.
Right.
21 Q.
What type of response were you attempting to 22 elicit from that question?
23 A.
I use that question if the other controls 24 aren't going to work for me.
In a case like this I want 25 to have as many controls as possible.
In terms of that
~ n.
I 20 1
question, it worked almost as an irrelevant.
There is 2
very low reaction.
3 Q.
With these questions 1 through 11 here, how 4
many of these.can you remember discussing generally with 3
Mr. Kroll or Mr. Nelson on the day before?
Do you 6
remember if you brought a list of questions or like some 7
notes?
Do you remember which of these were the ones that 8
you had discussed?
9 A.
The only one I recall specifically is lio. 8 10 regarding the need-to-know basis.
11 Q.
What about -- now you said the real relevant 12 ones were 3, 5, 8 and 9.
Do you remember discussions over 13 those?
14 No. 3, do you remember discussing this 15 question either as its worded here or in a general context 16 at your other meetings?
17 A.
No.
i 18 Q.
How about No. 5?
19 A.
!To.
20 Q.
And 97 21 A.
Yes.
22 Q.
That one you do remember also?
23 A.
In general.
24 Q.
Do you remember how many times you asked 25 these questions to Mr. van Brunt?
21 1
A.
I ran three charts so they were each asked 2
three times.
3 Q.
Were his answers in terms of deception and 4
non-deception consistent in all three runnings?
5 A.
Yes.
6 Q.
Were there any contradictions in deception 7
versus non-deception answers?
8 A.
No.
\\
9 Q.
Did you use these questions as your model for 10 the next set of questions you were going to do?
11 Do you remember -- as you testified before, 12 you first had that list and then you formulated then at 13 the pre-test interview and then you formulated these 14 questions when the next person came into your room.
15 Can you remember what you used as your base 16 for the questions?
Did you use these or your other notes, 17 do you remember?
18 A.
Well, what stands out about van Brunt is that 19 he was one of the few people that dealt with the press, so 20 just trying to recall, I don't think I could have used 21 this on many other people.
22 Q.
Did he discuss his dealings with the press 23 with you?
24 A.
Well, in general.
He said that he does, you 25 know, he is in touch -- the media does get in touch with
7--
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!.DCA ?!CN Ch CASE NO _ h ~ b l
APP *T.
BY f
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APP *T.
DATE TZME TEST ClVEN:
DATE 7
POSITION:
TYPE Of TEST:
PC S
SP SUS.7ECT v
TJsse Niddic
- L.ast~T Masden ADeRESS31/
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PHONE CITY
_ STATE
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50e. 'SEc., tyG.2.2-SGo sex AA ACE NT.
DATE Of BIRTM Ol bQ P
E Of BIRTM _
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CENERAL PHYSICAL CONDITZON:
T TROUBLE WITH NERL'ES REO. MEDICATION.'
Y hi EL*ER UNDER CARE of PSYCHIATRIST:
Y N EVER A PATIENT IN MENTAL HOSPl?AL; Y
N A
ANY HEART TROUBLE:
Y
% D PRES.$UPC NOKMAL:
Y (N buLSE RATE NORNAL:
Y N HOURS QT SI.EEP LAST NIGHT:
( (,
)
INE. 0
[W
&^
LAST ALCOHOLIC DRINK kOURS:
Y N P
DCTECT!0N TEST:
Y N EXPLAIN:
[ _.,P g STATEMENT Of CONSENT SIGNED:
Y N HAVE YOU EVER BCEN ARRESTED:
QN
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TT.DH MIUTARY SERYZCE:
[
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J' DRIVER'S LICENSE I f 3 -3 {2W STA TE L
TEST REQUESTED BY s R
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QCCUPATIOy EeP _,
um REe0.etNDED t
>fM a n, NoT,cCO,cNotD EXNt!NED AT Y C2AMINCO BY TEST COMPLETED PHONED REPORT TO NAZUD REPORT _
TyPg or gxAn hy ( u t) h RENARKS:
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Ed Van Brunt Nb/
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1.
Is your true and legal last name Van Brunt?
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2.
Do you live in Phoenix?
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- 3. Nnforma t'lon',dur'ing~the'pastinitiated rfIscussions with the medikardink.pareguard Have uou
~
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two Ueek's?
,j 4.
Were you born in January?
h 5.
Have you given safeguard information to the media that was not authorized?
6.
During the first 30 years of your 1 s fe, can you recall ever telling a lie to an employer that could have gotten you fired?
Y 7.
Is today Thursday?
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- 8.. Prior to February 14, did you,k, noy Chat Rgf.tgyant inigag.gfgg,yg, go }
Vbe'given on a*"heelf"to know"'ksis only?
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9.
Have you furnished classified / safeguard information to anyone without authoriza tion?
10.
Between the ages of 40 and SO, did you ever falsify comparty paperwork or documents for personal gaio?
11.
Would you lie to me if you thought you could beat this test?
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