ML20129H073
| 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: |
| References | |
| OL, NUDOCS 8507180495 | |
| Download: ML20129H073 (3) | |
Text
_ _ _ _ _ _ _ - - _ _ _
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 )
)
CAROLINA POWER & LIGHT COMPANY )
and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL -
MUNICIPAL POWER AGENCY )
)
(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.
7100 h,j 0 0
)
- 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
4 i
1 j ,
,L___
m
)
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
/