ML19199A636
| ML19199A636 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/26/1979 |
| From: | Vanbenberg L NRC OFFICE OF MANAGEMENT AND PROGRAM ANALYSIS (MPA) |
| To: | Crutchfield D, Rehm T, Thompson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 7905070024 | |
| Download: ML19199A636 (8) | |
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April 26, 1979 NOTE FOR: Tom Rehm, EDO Dudley Thompson, IE Bob ~Paulus, IE Denny Crutchfield, fiRR Dan Donoghue, AD:1 Joe Felton, DRR Don Grinsley, DRR DillEesaw, DDC Ann Savolainen, DOC Jin Long, TERA Jim Curnings, OIA
SUBJECT:
PROCEDURES FOR !!A'lDLI?;G DOCCIE:lTS RELATED TO THE TMI ACCIDC5T Attached is a description of procedures for collecting, reviewing and controlling documents related to the TMI accident. The procedures reflect the agreements made at our meeting on April 23 and nave been reviewed by the Division of Document Control, TERA Corp. and the Division of Rules and Records.
Larry Vandenberg Analysis and Planning Branch,i:PA Attachmnt:
As Stated, bc:
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DRAFT - LVandenberg - 4/26/79 Procedures for Control and Release of TMI Documents PROCEDURES 1.
All NRC personnel, in accordance with the ED0's April 13, 1979 memo, snould (1) crepare written recollections of their actions on March 28 and 29, and (2) collect the original or best copy of all cocuments they originated or received from non-NRC sources related to the TMI accident and should forward both these items to their Office Director or to their Office's FOI A coordinator.
In addition, agency records should be identified, to the fullest extent possible, with the name of the originator, office, subject, and the date originated.
2.
Office Directors will make the initial disclosure recommendation according to the attached preliminary guidance which is pending before the Commission. Office Directors will organize the documents into two groups:
a) those recommended for public release b) those recommended for withholding under the FOIA.
After office review and categorizaticn, all documents should be forwarded to the Freedom of Information and Privacy Branch, Division of Rules and Records, ADM.
(MNBB 4210) 3.
OIA and IE will review all documents with respect to determining if release will imoede any TMI investigation.
J.
The FOI Eranch will review Office Director disclosure recommendations and will indicate on each document wnetner it may be released to the 0
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2 public immediately or, if it should be withheld, will indicate the number of the FOIA exemption.
5.
The FOI Branch will supply the original (or best copy) of each docume.it to the Division of Tech. Infor and Document Control (TIDC) for TERA Corp., separating those which may be released from those exempt from release under the FOIA. TERA will print an accession number on each document and process the documents through the document control system, including microfiching and preparation of periodic title list reports upon request. TERA will return the original with a special distribution sheet (see attached flow chart) to the Distribution Services Branch for reproduction.
6.
The origir.al of the document will be forwarded to the Record Services and Facilities Branch in ADM to form the official NRC file on the TMI accident. The TMI documents will be added to the existing Three Mile Island Docket, Number 50-320.
7.
When NRC's document release policy is established, the Director, Division of Rules and Records, will notify TIDC which documents should be released to the H Street PDR and LPDR's. The Division of Tech.
Information and Document Control will be responsible for release of documents to the PDR's.
3.
All documents not recommended for release will be reviewed by CGC and ELD to determine if the document, or any portion, may be legally withheld under the FOIA. OGC will review the withheld documents of nG 130 u
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5 Commission level offices; ELD will review the witnheld documents of offices reporting to the E,0.
RESPONSIBILITIES All NRC Employees
- Prepare and send to Office Directors written recollec-tions of actions on March 28 and 29 as per EDO April 13,1979 memo. Also, give Office Directors (or Office FOIA coordinatcr) all other TMI related documents.
Indicate on each document or group of documents the subject, date originated, originating individual and office.
Office Directors
- Review documents submitted by employees and make initial disclosure recommendation using attached draft guidance.
Fo rward all documents (including individual written recollections) to the FOI Branch, MNBB Room 4210.
FOI Branch - Control all documents received from Office Directors, assion disclosure catecories and send to TERA Corp. for processing through NRC's document control system.
OIA, IE - Review documents for determination to witnhold because dis-closure would impede investigation of the TMI accident.
Division of Tech. Info, and_ Document Control (TIDC)
- Responsible for TERA Corp. processing of documents and release to PRD's.
Record Services and Facilities Branch - Receive documents from FOI Branch fcr addition to TMI Decket.
Enclosures:
i Chart 2.
? :;osed Commission Guidance on FCIA Release of T"I documents.
6 3 1,7. 9 c
NRR I&E Trail er I&E Other City ;
, Region I Offices b
v_
v v
v l
Documents originated by that Office or received From a non-NRC source relating to the TMI incident V
F0IA Branch Make disclosure determination (i.e., POR Release or hold)
Original Copy V
3 TERA
~
(Processing)
Enter into DCS Produce 48x microfiche l
Original Copy with distribution sheet N/
Dist. Serv. Br.
(Reproduction) t 4
+
A(to be released)
S(withheld)
Copies to:
Copies to:
TERA (tc produce 24x microfiche)
TERA PDR F0IA (for further CF (original) disclosure review)
LPDR CF (orig nal) i Reading Rcom OQ 150-Lu n-CC:CCSSION GUIDAbiCE C: FOIA PJLEASE OF DCCUMENTS RELATED TO TEE THREE MILE ISLAND ACCIDENT 1.
Procedure for Review.
The usual procedures specified in Part 9 of the regulations shculd be empicyed.
Deci-sions to withhold or release staff-level documents are made by cognizant staff offices, subject to an appeal to the EDO.
Commission office papers are reviewed by Consissien offices, subject to appeal to the Commi,ssion itself.
2.
Guidance en Withholdinc of Exempt Material.
Reports of document reviews conducted to date by cognizant offices indicate that the bulk of the TMI material thus far assembled probably does not fall within any FOIA exemp-tion, and is therefore subject to disclosure.
This material should be placed in the Public Document Roca as soon as customary assembly and indexing procedures can be completed.
Some TMI documents will fall within an exemption to the FOIA and therefore will not be subject to compulsory disclosure.
However, the Commission proposes to be as forthecring as it can in disclosing TMI documents that are legally exempted fror public disclosure, subject to other overriding considerations.
Questions about with-holding or release of particular documents should senerall:
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2 be reccived in favor of release.
The following guid-ance applies to particular bases for withholding dccuments.
(a)
Investicative Records.
Material which is compiled for the express purpose cf an investigation relat-ing to TM! should be withheld if a determination is made that the disclosure of the caterial would impede the investigation.
That determination, in the case of internal investigations, should be made by the offices conducting the investigation,-
e.g.,
I&E, NRR.
In the case of material assembled in anticipation of the Commission's TMI Special Inquiry, the determination should be made by the Director of OIA.
Examples of records of this kind could be interviews, preliminary reports and drafts of conclusions and recommendations, and communications among investigators and their superiors.
(It is possible that much of this information could later be C selosed when the investigation is ccmpleted).
(b)
Internal Advice and Reccmmendatiens.
Pcrtions of documents containing internal advice and recen-mendations she';1d te 'lithheld 'there disciosure 70 1%)
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3 might result in demonstrable and serious harn to
!TEC's ability to conduct its business.
(c)
Criticism of Mamed Persons.
Fortions of some TMI documents refer critically to named individuals.
Such pcrtions should be withheld if their dis-closure would involve an unwarranted invasion of for example, if public disclosure would privacy cause severe and unnecessary embarrassment for a particular person.
(dl Procrietary Information.
Material should be with-held if disclosure would either (1) cause substantial harm to the competitive position of the person frcm whom the information was obtained or (2) impair the government's ability to obtain information in the future.
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