ML20034E150

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Final Response to FOIA Request for Documents.Forwards Documents Listed in App D Which Are Being Made Available in Pdr.Records Subj to Request in App D Are Being Withheld in Part & Entirely (Ref FOIA Exemption 5)
ML20034E150
Person / Time
Site: Dresden, Peach Bottom, Palisades, Fermi, Pilgrim, Turkey Point, Rancho Seco, Fort Saint Vrain  Constellation icon.png
Issue date: 11/16/1992
From: Grimsley D
NRC OFFICE OF ADMINISTRATION (ADM)
To: Rasmey Robinson
ATLAS CONSULTING GROUP, INC.
Shared Package
ML20034E151 List:
References
FOIA-91-438 NUDOCS 9302250180
Download: ML20034E150 (3)


Text

- UL. TsOLLE AR NLGUL AT UR Y CUf.WiSdiUId W e wA MOAe hvwt Maa FOIA 93V

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^A RESPONSE TO FREEDOM OF XJ m*E I I PARTtAL

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  • t[ INFORMATION ACT (FOIA) REQUEST o^u i

NOV 161907 DOCY E T NUMist Rt5t (19anphcamel Q

j PAffT L-AGENCV RECORDS RELE ASED OR NOT LOCATED (See checAedtromes) l No agency records ssbject to the request have been locate 1 No additional agency records subject to t e request have been located.

h Requested records a e available through another pub!ic distribution program. See Commerts section, Agency records suoject to the request that are identified in Append.xicO are already available for pubhc inspectior: and copying at the NRC Pubhc Document Room,2120 L Street, N W., Washington, DC.

Agency records subject to the request that are identified in Appi-ndim(es)

O are being made available for pubbc inspection and copying

. et the NRC Public Documert Room. 2120 L Street, N W.. Wash;ngtort DC, in a folder under this FOl A number.

The nonproprietary version of the proposaHs) that you agreed to accept in a telephone conversation with a member of my staff is now being made avaiaable for pubhc inspect on and copying at the N RC Pubhc Document Room. 2120 L Street, N.W., Washington, DC, in a folder under this FOI A number.

i Agency retorc s subject to the request that are identibed in A;oenda fes!

may be inspec1ed and (.opied at the N RC Local Pub'ic Document Room identified in the Comments section.

Enclosed is inf ormation on how you fray obtain access to and the charEr s f oi copying records loc.ated at the NRC Public Document Room,2120 L Street, N.W., Washing

Aynty retorc> subject to the request are enclosed Records subject to the request have been referred to anot% r Federal agencybes) for review and direct response to you.

Fees Yos wi be bWed by the NRC for fees tota ng S

,- i Yo.; wdi rece ve a refund f rom the N RC m the amount of S in view of NR C's response to this request, no further action is being taken on a;1 peal letter dated

, No.

PART tl. A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certain Information in the requested records is being nithheld from public disclosure pum ant to the exemptions described en ard for the trasons stated

, in Part II, E, C, and D. Any released portions of the documents icr which only part of the record is being withheld are being made available for public inspection and copying in the NRC Public Document Room,2120 L Street N.W., Washing'on, DC in a folder under this FOt A number.

The actual fees associated with the processing of your request COMME NTS I

are as follows:

61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br /> of professional search and review at s27.93 per hour =

$1,703.73.

We have received your check number 1939 in the amount of

$1,477.35.

You will be billed for the additional $226.38.

In accordance with your instructions the records are being placed in the PDR.

$tGNATUFtE. DIRECTOH Divi 5dO OF F PE EDOM OF INFORMATION AND PUBLICATIONS SERVICES N i Mu.E S h SLd qu

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e osa wiefotsi Date RESPONSE TO FREEDOM OF FOIA - $-h p NOV 16 B92 INFORMATION ACT (FOIA) REQUEST (CONTINUATIONI g

PART II.8-APPUCABLE EXEMPTIONS Records subject to the request that are described in the enclosed 4pendix{esL are being withheld in their entirety or in part under the Exemption Nols) and for the reason (s) g;ven below pursuant to 5 U.S.C. 5521tdnd 10 CF R 9.17(a) of NRC regulations.

t. The wahheid enformation is peoperly classited pursuant to Exeoative Order. 4Emempi+on 1)

2. The withheid informatio.. re:ates solely to the sneernal personnel rules and procedures of NRC (E memDtion 2) n 3 The withheld mformatiors es specificativ exempted from pubhc dSciosure by statute mdicated,(Emempt.on 3)

Sect +ons 141-145 of the Atomic Er.ergy Act. which prohiDits the d$ciosure of Restorted Data or Formerly Restncted Data 142 U.S.C. 2161-2105L a:V j

f Section 147 of the Atomic Energy Act, which prohibits the d'sclosure of Unclasof.ed Safeguards leformation (42 U.S.C.2167).

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4. The wahheld mformation is a trade secret or commercial of f nanc+ai information that is being w,thheld for the reasonts) indicated. (Exemption 4)

T%n information es considered tu be confidential business (p opnetary) miormat.on The wfurmation,s conside ed to te propncia*y mfva con pu want to 10 CF R 2 790,dn u w:2 The information was submated and recewed en conbdence pursuant to 10 CFR 2 790 d92'

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r 5 de withhed enformat.en consats ca eterart y o'.mreagermy ece+ tv aw ni t om o, y.tue.cw oar ; ots.a.oe (Emempt+on 5), Apph. we Prieege hehberatwe Process Dsclosure of p<eseaponst miarmation woukt tend iv enbr the open and fits + e=c hange et ceas essentiat to the fielberat*ve process r

Where reco os are withheld m their entnety. the f acts are one sinc ata, mtertwend with the p*e decisa.nal mformanon There also are no scasonetdy sepegable factual l portions t.ecause the release of the tacts would perm i an endsect mouwv er to the predmumai peor ess of the agent

  • Attorney wo k. product prweiege tDocuments piepared t v an atto'ncy en cuniempla orgt nbcmt.on i n

Attorney.chent privlepa. iContdential communications between an at1omey and h stet thent.)

6. The wntmec.n'umabcm is c=emped Sc& puts deoss e tw a rse e s nensu*e mom met m a tw A ur na amd.nwas.on of persona' pmacy (Exemption 6)
7. The withhew information cons 4:s of records compised for saw enfo+ cement pu rmses and a be.no =>thheld for the reasontsl mdicated (Exemption 7) 1!

Dsclosu e could reasonab!v be expected to interfere nith an enforcement oroceedmg because it could reveal the scope, direction, and focus of en93rcement efforts. am! thus could possibiv allow recipients to take action to sh.cid potent.ai wrongdorng o a v.ointeon of NRC re:autrements

' ram mwettmators (Epemption 7 ( AH D+ closure would c onstitute an unwaaranted mvas on of persona, praety (E nemptic,71C))

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The animmenon conosts o' names of mdmaM and otho atemanon the nm e

  • e+ t evd een-wh tw e.oected in seveW idenot es of confidential sources. (Ememption 7 (DU j

OTHER PART 11. C-DENYING OFFICIALS T

Pursuam to 10 CF R 9 2S(b) aN1 or 9 25(r) of the U S Nutiea P+gmatory Commspon regiatons. it has been stete'emnert that the miomist.on with5r6d es exempt frorn pro duction or dcosure. and that its p oduct-on or d sclosure is cont ar y u the pubbc interest. The pe sona rapanuble foe the denial a*e those offeoa's identdied beiow as denymg officia:s and the Deec*or, Dtvis.on of f'reedom of Iriformation and Publicatior;s Services. Df f ace of Admestrat.on, for any denials that may be appealed to the Emecutwe Detector for Ope anons itDO)

DENYWG OFilCIAL l

TITLE rOF F #CE RtCORDS DINTED APPELLATE OFFICML rDo I SECRE tMY G

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PART 11. D-APPEAL RIGHTS I

The denial by each deny)ng official ident f eed in Part it.C may t,e appesied to the Appelfate Off cial identdied there, Any such appeal must be made in writing withm 30 days of receipt i

of the response. Appeals must be addressed, as appropnete. to the E secutive D. rector for Operations. to the Secretary of the Commission, or to the Inspector General, U.S. Nuclear itgulatory Commisuon. Washington, DC 20555. and should clearly state on the anvelope and in the letter that it is an " Appeal from an initial FOI A Decision."

NRC FORM 464 (Part 2) (1-91)

U.S. NUCLEAR REGULATORY COMMISSION

Re:

FOIA-91-438 APPENDIX D DOCUMENTS WITHHELD IN WHOLE OR IN PART EXEMPTION 5 - PREDECISIONAL INFORMATION NUMBER DATE DESCRIPTION 1.

6/2-3/87 Senior Management Meeting material (Volume 1) - Portions Deleted (149 pages) 2.

6/2-3/87 Senior Management Meeting material Denied in Entirety (cover (Volume 2) page enclosed) 3.

11/16-18/87 Senior Management Meeting material (Volume 1) - Portions Deleted (168 pages) 4.

11/16-18/87 Senior Management Meeting material (Volume 2) - Denied in Entirety (cover page enclosed)

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E3t1M October 7,1991 b

F fRE.EDOM Of INFORMATION ACT REQUEST Mr. Donnie Grimsley Director, Division of Fscedom Information

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and Publication Services ADMUSNRC USNRC - Mail Stop P470

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Washington, DC 20555

Dear Mr. Grimsley:

I am a consultant with Atlas Consulting Group worhing on an historical analysis of nuclear power plants.

In the March 1987 issue of NUREG/BR-0125, which we obtained from the Public Occument Room, an article discusses the semi annual NCR Senior Management Meeting held on December 6-7, 1988. I have attached an excerpt from the-NUREG and the discussion of this meeting is marked at /AJ on page 2. The article also discusses the.

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Regional Pre Screening meetings. Isee mark BJ I am interested in obtaining the following specific analysis and reports mentioned in the

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article for these meetings specifically, and for each prior and subsequent set of semi-annual meetings.

4 The risk analysis write-up of each plant to be discussed at the December Senior Manager Meeting developed by the Risk Assessment Branch of the 3

Division of Radiation Protection and Emergency Preparedness and NRR.

t (see mark C)

The Summary and Narrative Analysis for each plant prepared by the Pe formance and Quality Evaluation Branch'which was sent to attendees.

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The Senior Management Meeting Report prepared at the conclusion of the

- semi annual meeting. (see mark El 2s33 South Highway 101 Suite 240

.Cardiff, CA 92007 619-632 9206 FAX 619-632 9603 i

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Mr Donnie Grimsley October 7,1991 page 2 If these analys'es and reports are currently filed in the Public Document Room please provide sufficient bibliographic and accession information to enable retrieval. If they are not in the public domain, could you please tell me where i could obtain these doeurrients, if you are the only source, would you give me an estimate of how much it would cost for you to do the research, retrieval. and copying for us.

Please contact me between 8:00 a.m. and 5:00 Pacific Time if you have any questions at (619) 793 1605.

Sincerely, 5

Roger J. Robinson RJR/cmb t lo.ATsource 30 i

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TECHNICAL nuneo/an-oi2s NEWSLETTER C Of Severe Accident Issues i

by Thomas E. Mufley i

ccatainly dclay closure for years. Instead,it is contemplated that One nf NR R's major ciforts during the past 2 ycars has been to with the Office of Nuclear Regulatory Rescasch, an several actisitics such as improsed plant operations, accident j

desclop, d plan for the closure of scscre accident issues for rnanagement, and containment performance unprow l

integr ale u ould be car ried out in par allclwith the IPE w or k. Por example, operating nu(Icas plants. In ahis context, closure means that all we are working with NUhtARC in its efforts to developi of the major issues have been examined for each plant, and cost-accident management framework. Eachlicensee l cffectisc changes made if needed, so that the NRC can confirm l

the conclusion that thcie is no undac rist to public health and framcworktoincorporate newinformation developedinth ufcty ficm scscre accidents.

into plant specific o oc accident management procedures. It i

would be both illogii il and inefficie nt to aw ait comp 1ction of the Ilhat ir Ac Icchnicalissue ccr.ccming sewre acctients?

IPE t< fore impicmenting an accident management framcwork.

The answer issimply that core-mcit accidents *cic not included Simitasly, our plan t nsitions that containment pe as part of the original design basis for safety aystems and, improstments can be developed and imple containment structurcs because thclitelihood oIsuch accidents with the IPE work. The staff has years of sev!

experience asallalle to guide us in:ccommendinpost cffcc.

w as tbought to bc 1oc rcmote. Our siews hase changed since the Tb112 accident, of course. We now are faced with the question five generic containment impeosements that c abihty of containments to wuhstand sesere accidents. It would l

'fcatures v pocedurcs,if any,are requiredfor not be efficient to hac cach licensee duplicate the level of of what adJitt-Safcty sysicms ud >ntainmcats to preside reasc,nable assur-analysis that the st aficar. bring lo bcar from our own exp:

ance dpsntccth gainst the risks of core. melt accidents. The Of coupe, any plantacccific containment imptovem Chcinobyl accident miensified the focus on containments and on have to be integraird closely with the iPE resulisiand; icaching an answer to this question.

modifications, whetkr from the CPI or IPE programs, would i

Siarcrnent, issued in have to be carciullyiritgeated at each plant. We will hase lobe

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The Commission's Sesere Accident Pc.ficy!ans to formulate an flexibic in discussing act uat schedules for any plant mod=

August 1985, staies:". the Comrnission p that inight be requned, integrated sysicmatic approach to an examination of each nu-tant now operating or under construction for I

clear fe sign $ cant risk contributors (sometimes called 'outli-Finally it isimportant that we keep the seve ower rogsam gets off the trads and poss;b on the tracis for closure. If the p!y delayed, our pfans for pla cis') that mi ht be plant specific and mighi be inissed absent a closure ap, pears to be substantia!

6 Sysicmatic scarc h.. The c namination willinclude specific atten-i life extcosion would be iminensely compikaled. It would not be tion to contaimnent performance in striling a balance betwcen practical to contctni' tate acnewsng operating licenses if the accident presention and conscquence mitigation" severe accident issucs base not been closed. Therefore,it will-tale close attention and discipline to sesolve problems as they l

in hiay 1958 the siaff developed a severe acciJcnt program that avise and stick to the sescie accident plan.

integi ates ses eral of our segulatory activities and ac3cmh tasks into a plan Icteding to closure of severe accident issues. The k cystone of this plan is the Individual Plant Examination (IPE) that arquires cach licensee to examine his plant for signir. cant What's in thisissuo? Sea Page 2 sisk contributor 5. It is not intended, however, that the JPE bear the fullbu:Jen of settling ati severe accident issues. That would j

overly complicate the IPE methodology and would almost l

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penpccthe cf cach plant in the country.

  • TN TilIS ISSUE rollowing the identification of the plants to be discussed at the Dcccinbcr mecting,the Risk Assessment Dranchofthe Dhision Severe Accident issues..

.. I c,f R adiation Protection anJ Emergency Preparedness and NR R by Thomas E. hturley Pmjects woricdlogether to gcncrate a rish analysis write-up of NRC Senior blanagement bicc:ing

=2 cach plant using available Probabilistic Risk Analysis (PRA)%

by William Datcman information.

This analysis was cettemely informative as it Integrated Performance Aucument Team cvaluated she sisk signiricance of the design and served in inspectiims in itcgian t by James E. Kaucher

.2 cmphasite the importance of strong managcment and good operations and mamtenance staffs.

Reactor Scram at River Bend Station with Subsequent Complications

.3 The performance and Ouality Evaluation Branch tcccived input by Waltcr A. Paulson and Timothy E. Collins for the mccting from most divisions of HRR, the Regions, South Tcras Overcomes Probisms and Gocs AEOD, and RES and inicgrated it allinto both a summary and Commercial

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...A a narrative analysis for rach plant. The schedule required the by Claudia Abbate, George Dick, and report to be sent to attendees two weeks before the meeting, but Patrick O'Reilly it was distributed slightly ahead of sch:dule.g Erosion / Corrosion

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[f] Senior hianagement Meeting Report has been bett by Paul Wu

'Irach NRR Technicat intern Program

,6 the predous one, and each has involved more of the Agency by Valcria H. Wilson among its contributors and in its prepar ation. This fact reflects Service Watcr Operability Issues _........ _

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II.c competence and commitment of all those invohed in the by Rudolph Bernhard and Ellis Alcischoff production of the report and serves to demonst ate the benefits of effecthe communica' ion and teamwork. The process has blecting. gain to support the Afay 1987 Senior blan3Eement bcgun a NEWSLETTER CONTACT:

Valeria Wihon, NRR.1921208 Integrated Performance l

NRC Senior Management Meeting Assessment Team by William Bateman, POEB Insp0Cli9nS in Region I by James E. Kaucher, DnP, Region I o

cembe,6 7,19s8,;he sich semi. annua Senior Manage.

ment hiceting was held in Art;ngton, Tczas. This mccting afforded the opportunity for seniar NRC rnanagers to eevicw The Integrated Perform mce Assessment Team (IPAT)lnspec.

and discuss scicued plants anddccide what,if any, action should 3"4.was descloped in PJS6 in Region I as a tool to be used to be 1alen to addrest concerns. Other topics ofinterest scre also obtam a more compicic undcastandingof the underlying reasons lbc ussed for, licensee perforrnance as reported in the Systematic Ap.

praisal of Leccnsee Tc ricrmance (SALP) reports and to assess The plant

.c discusscd at the rnceting were deciJcJ upon wbdher muedine adiort programs in place are properlystrue.

following Regional pscac r ec cnin tured and focused to schoc the necessary improscrrents.

September 29 and October 12,g mectingscenJuded bclucen 1988. These incctin6s were aticnded by representatives of the Office for Analysis and The q9 conc eithe lPAT is to delermine how current perfor m.

Coluation of Operational Data (A EOD), the Office of Nuclea, ante unpads safe plant operation.

Regulatory Rescarch (RES) and the Office of Nuclear Reactor IPATs spec.fically addreu most arcas and they atc :ailon J to a bor all of the SAI.P functional Rcgulation (NRR), and the appsopriate Regional Administra-i censce's perforrnance history.

t or.

The scams are comprisol of Regional specialists, Resident in.

Each plant in the R e spcoms, and Headguayects' act:resentattves. They are Icd by a pctfor mance Icvel. gi(m was discussedio evaluate the licensec's mana cr from the..cgnm 1 Dmsmn of Reactor Ps Design strengths and scatnesses were miad,upport Staff. The in<pc ctions are two to thre e wcd s long, meal

>Jcatified and csaluated from a risk perspective. Dascd on a ing preparation time, cskw of these inues and other informahon provided le acet.

og attendecs, a plant discussion list was established.

The first IPATinspections were conducted at Pilgrim and Peach

% substantial cfforI wcnr into prcparing for these prc4crcenirg B trom inearly 1986. Since then,sesen additionallPAT inspec.

. tens hpe been conducic d at both problem andother b,lant sites ucctings. The Divisicm of Engmccring a nd Sysicms Tcc hnolofd n 1. Ahf the mydens have pmdued in e mulon m Rpt.c NRC has used to gam insights on the performance of stcparcJ a list of design issues, and each Prnjed hianager us that 1.is list to asccriain the status of cach design issue at his/her Ecc nscc m a,nage nse nt, and all have pr odde d valuable c alibration iuij;ncd plant. This information obtained was categlesign strengths and weak nesses. It was then used, m,oriecd inin and added mput,to the SALP process. In addition usefulcross-trairung and perspective for the Regionab,they have conjunc.

nspection ion with the Regional presentation on operations and man-igement strengths and weaknesses, to hcip form an overall stalf. The Region's goalis to conduct one IPAT cach quarter, r

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A CONFIRMATION COMOF FAX um i>Ms December 3,1991 Fpl6-Hcj38' Mr. Donnie Grimsley x

Director, Division of Freedom Information and Publication Services ADMUSNRC USNRC - Mail Stop P-370 Washington, DC 20555 f

Reference:

A)

Freedom of information Request (FOIA 91-438)

Dated October 11,1991.

B)

Letter, Mr. Roger J. Robinson, Atlas, to Mr. Donnie Grimsley, NRC, Dated October 7,1991.

C)

Conference call Mr. Ray Ramirer, et al., NRC, and Mr.

Roger Robinson, Atlas, on December 3,1991.

Dear Mr. Grimsley:

This letter is to clarify my information request identified as FOIA 91-438 (Refarence A) which was initiated by my letter to Mr. Donnie Grimsley on October 7,1991 (Reference B). This clarification is based upon conversations held with Mr. Ray Ramirez, other NRC staff and me on December 3,1991 (Reference C).

In summary, this request deals with the reports and minutes associated with the six previous and an unknown number of subsequent NRC senior management meetings held semi-annually and identified in the attachment to reference B (subsequent item marks refer to this j

attachment).

Based upon today's conference call (Reference C)it is my understanding that, of the items requested in my original letter (Reference B);

item C, the PRA analysis, is included in item D, the summary and e

narrative analysis.

item D, the summary and narrative analysis, are in fact called e

item E, the Senior Management Meeting Reports and they are j

one in the sarne.

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That the post meeting reports (what I had assumed to be' item E) e are in f act called the Senior Management Meeting Minutes.

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Mr. Donnie Grimsley Page 2 l

Tu restate the understanding reached in our conference call and clarify the information desired, the following materialis requested:

1.

The Senior Management Meeting Reports, which are the plant summaries and nitrative analyses and include the risk analysis writeups.

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The Senior Management Meeting Minutes, which are the post meeting reports stating the results and decisions of the meetings.

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I lt is also my understanding that this clarification will not change the previously provided estimated fees for FOIA 91-438. The search, retrieval, and review work will proceed under the advance payment we have already provided.

Thank you for your help in obtaining the information, I appreciate both your and the NRC staff efforts in the retrieval.

Please contact me between 8:00 a.m. and 5:00 p.m. Pacific Time if you have and additional-questions at (619)793-1605.

l Sincerely, g j

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CONFIRMATION sulting N

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December 3,1991 m

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F o M - 9l.- 9 3 8' Mr. Donnie Grimsley Director, Division of Freedom Information and Publication Services ADMUSNRC USNRC - Mail Stop P-370 Washington, DC 20S53

Reference:

A)

Freedom of information Request (FOIA 91-438)

Dated October 11,1991.

B)

Letter, Mr. Roger J. Robinson, Atlas, to Mr. Donnie Grimsley, NRC, Dated October 7,1991.

C)

Conference call Mr. Ray Ramirez, et al., NRC, and Mr.

Roger Robinson, Atlas, on December 3,1991.

Dear Mr. Grimsley:

j This letter is to clarify my information request Identified as FOlA 91-438 (Reference A) which was initiated by my letter'to Mr. Donnie'Grimsley on October 7,1991 (Reference B). This

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clarification is based upon conversations held with Mr. Ray Ramirez, other NRC staff and me on December 3,1991 (Reference C).

in summary, this request deals with the reports and minutes associated with the six previous -

and an unknown number of subsequent NRC senior management meetings held semi annually and identified in the attachment to reference B (subsequent item marks refer.to this-attachment).

Based upon today's conference call (Reference C)it is my understanding that, of the items 1

requested in my originalletter (Reference B);

i item C, the PRA analysis,is included in item D, the summary and e

narrative analysis.

1 item D, the summary and narrative analysis, are in fact called e

item E, the Senior Management Meeting Reports and they are one in the same.

That the post meeting reports (what I had assumed to be itern El are in f act called the Senior Management Meeting Minutes.

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2533 South Highway 101 Suite 240 Carditi, CA 92007..

619-632 9206 FAX 619-632-9603 l

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Mr. Donnie Grimsley Page 2 To restate the understanding reached in our conference call and clarify the information desired, the following materialis requested:

1.

The Senior Management Meeting Reports, which are the plant summaries and

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nitrative analyses and include the risk analysis writeups.

2.

The Senior Management Meeting Minutes, which are the post meeting reports stating the results and decisions of the meetings.

It is also my understanding that this clarification will not change the previously provided estimated fees for FOIA 91-438. The search, retrieval, and review work will proceed under the advance payment we have already provided.

Thank you for your help in obtaining the information, I appreciate both your and the NRC staff efforts in the retrieval.

Please contact me between 8:00 a.m. and 5:00 p.m. Pacific Time if you have and additional questions at (619)793-1605.

Sincerely, g

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Roger J. Robinson RJR:cmb J

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