ML19341C122

FOIA Request for Documents Re Methodology,Assumptions,Data & Procedures Used by Task Force on Interim Operation of Facility

ML19341C122
Person / Time
Site:	Indian Point
Issue date:	01/27/1981
From:	Holt R NEW YORK UNIV., NEW YORK, NY
To:	Felton J NRC OFFICE OF ADMINISTRATION (ADM)
References
FOIA-81-43 NUDOCS 8103020068
Download: ML19341C122 (2)

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y New York Universit

, A privare uniserssty an the puyhe semce Faculty (if Arts and Science Department of Psychology ,

Pochology Building 27 January 1981 6 Washington Place,4th Floor New York, N.Y.10003 Telephone: (212) 598-2745 FREEDOM 0F INFORMATION ACT REQUEST FREEDOM OF INFORMATION ACT. REQUESI ,.

Mr. ' Joseph Felton, Director Division of Rules and Records bold- P /-

Office of Administration Nuclear Regulatory Commission Q ag g_ Qp -e Washington, D.C. 20555 In re: F0lA-80-578

Dear Mr. Felton:

I have just received your letter of Jan. 21, 1981, with enclosures in reply to my request of Nov. 17, 1980 under the Freedom of Information Act.

You mention that your refusal to send the 15 letters and memos listed in your Appendix B may be appealed, and I want to inform ycu that I will pursue such an appeal promptly and vigorously.

Let me note, however, that your reply strikes me as puzzlingly unrespon-sive to my original request. I asked for " reports, memoranda, drafts, state-nents of data, and other working documents relevant to the report of the Task Force on Interim Operation ( . Indian Point...and any other subsequent reports, memoranda, or correspondence pertaining thereto...." It is rather striking that with the sole exceotion of the first item actually sent (a brief note of transmittal of preliminary findings ~ to Commissioner Hendrie, dated June 13, 1980), nothing in either Appendix A or Appendix B antedates the submission of the Task Force Report itself. I thought it self-evident that my request for "any other subsequent reports" etc. was an addendum for the sake of completeness and that the major emphasis of the request was en antecedent material, but on re-reading my letter I see that perhaps I failed to make clear what I wanted.

In fact, I have just noticed what appears to be a typographical error in my original request: I intended the first word after the colon in line 2 to be "all" and it came out as "real." Of course, "all reports, memoranda...

relevant to the report" would have included much more than you inventoried, and only now do I realize that .the letter did not say what I intended.

Let me clarify my letter of Nov. 17, 1980, therefore. It is clear, from the Commission's recent order instructing the ASLB about the forthcoming hear-ings on the Union of Cnncerned Scientis,is' charges of unsafe conditions at Indian Point, that the 6/80 report of- the staff's Task Force is to play a critical part, and that the Commissioners expect it to be subjected to careful critique. For the necessary scrutiny to take place, it is vital to have full' information nn precisely those matters which the Commission noted were not included in the report itself: its' methodology, assumptions, data, and proce-dures. Because group with which I am associated is considering intervening on the grounds of inadequacies in the Task Force's analysis, it is necessary 8103020 h .

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in the public interest for us to have access to documentary materials describ-ing the CRAC code, the procedures followed in modifying the WASH-1400 a?proach to computing probabilities, just what accident scenarios were consi' ed, what assumptions were made about releases of which fission products a' .at times, what assumptions were made in the computation of consequences about the patho-genicity of various types of exposure to varying quantities of alpha, beta, and gamma radiation, etc. Of particular interest are documentary records demon-strating how decisions were made concerning the aalysis of accidents and con-sequences at Indian Point, including computations of the effects of the changes ordered by Mr. Harold Denton.

I trust that by now it is apparent why, with these desires and expectations, I found the materials you sent of so little interest, and how tangential even the materials listed in Appendix B and withheld are to my purposes and interests.

Therefore, this is a formal request reiterating my earlier request (of 11/17/80) for all " reports, memoranda, drafts, statements of data, and other working docu-ments relevant to the report of the Task Force on Interim Operation of Indian Point, submitted to the Commissioners in June 1980, and any other subsequent reports, memoranda, or correspondence pertaining thereto up to 11/14/1980." In accordance with 10 CFR Section 9.8, I expect a response within 10 working days or sooner, in light of the fact that my counsel and I consider that this request has been pending since Nov. 17, 1980.

Sincerely yours, k%k Y Robert R. Holt, Ph.D.

Professor of Psychology RRH:bb

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