ML20134F558
| ML20134F558 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/1985 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Leighton A SHAW, PITTMAN, POTTS & TROWBRIDGE |
| Shared Package | |
| ML20132B439 | List: |
| References | |
| FOIA-84-293 SECY-83-026, SECY-83-26, NUDOCS 8508210157 | |
| Download: ML20134F558 (4) | |
Text
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i AUG 5 1985 A. Patrick Leighton, III, Esquire Shaw, Patrick, Potts, & Trowbridge 1800 M Street, NW IN RESPONSE REFER Washington, DC 20036 TO F01A-84-293
Dear Mr. Leighton:
This is in further response to your letter dated April 17, 1984, in which you requested, pursuant to the Freedom of Information Act (F0IA), all records relating to the Ford Amendment Study. '
We previously made available documents identified in letters to you dated May 3, 1984, May 17, 1984, June 13, 1984, June 27, 1984, August 1, 1984, September 4, 1984, June 10, 1985, and July 3, 1985.
The records identified on the enclosed Appendix M are subject to your F0IA recuest and are now available for public inspection and copying at the NRC Putilic Document Room in folder F01 A-84-293 under your name.
The three records identified on Appendix N are being withheld from public disclosure pursuant to Exemption (5) of the F0IA (5 U.S.C. 552(b)(5)) and 10 CFR 9.5(a)(5) of the Comission's regulations. These records are withheld in their entirety because they contain predecisional advice and opinions regarding the Concission's current consideration of a quality assurance program plan.
Pursuant to 10 CFR 9.15 of the Commission's regulations, it has been deterinined that the infortnation withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest. The person responsible for denial of items one and two on Appendix N is Mr. John C.
Hoyle, Assistant Secretary of the Corsnission. The person responsible for denial of item three on Appendix N is Mr. John E. Zerbe, Director, Office of Policy Evaluation.
This denial may be appealed to the Secretary of the Connission within 30 days from the receipt of this letter. Any such appeal must be in writing, addressed to the Secretary of the Comission, U.S. Nuclear Regulatory Comission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial F0IA Decision."
B508210157 850005 PDR FOIA LEIGHTO84-293 PDR
We will communicate with you in the near future regarding additional records related to the Ford Amendment Study. "
i Sincerely,
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< /g. M. Felton, Director
. 'if Division of Rules and Records Of fice of Administration
Enclosures:
As stated I
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Re: F01A-84-293 APPENDIX M RECORDS IN POR FILE F01A-84-293
- 1. 11/27/81 Memorandum for William J. Dircks, EDO, from Nunzio J.
Palladino, Chairman, entitled " Quality Assurance" (1 page).
- 2. 08/10/82 Memorandum for William J. Dircks, EDO, from Richard C. DeYoung, IE, entitled " Quality Assurance" (46 pages).
- 3. 08/20/82 SECY-82-352,"AssuranceofQuality"(39pages).
- 4. 09/30/82 Memorandum for Secretary from John Ahearne, Comissioner, entitled, " Assurance of Quality (SECY-82-352)" (1 page).
- 5. 10/07/82 Memorandum for William J. Dircks, EDO, from Samuel J. Chilk, Secretary, entitled " Staff Requirements - Briefing on Quality Assurance" (1 page).
- 6. 01/28/83 Memorandum for Darrell G. Eisenhut, NRR, from James M. Taylor, IE, entitled " Certification of Licensee Quality Assurance Programs and Role of Designated Representatives" (3 pages),
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- 7. 01/28/83 Memorandum for R. C. Haynes, Region I; J. P. O'Reilly, Region II; J. G. Keppler, Region III; J. T. Collins, Region IV; and R. H. Engelken, Region V, through Richard C. DeYoung, IE,
[d from James M. Taylor, IE, entitled " Certification of Licensee Quality Assurance Programs and Role of Designated Representatives" (24 pages).
- 8. 03/29/83 Memorandum for William J. Dircks, EDO, from Samuel J. Chilk, Secretary, entitled " Quality Assurance Initiatives (SECY-83-26)" (16 pages).
- 9. 04/07/83 Memorandum for William J. Dircks, EDO, from Samuel J. Chilk, Secretary, entitled " Quality Assurance Initiatives (SECY-83-26)" (17 pages).
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Re: F01A-84-293 APPENDIX N RECORDS SUBJECT TO F01A-84-293 WITHHELD IN THEIR ENTIRETY
- 1. 09/01/82 Notation Vote Response Sheet to Samuel J. Chilk, Secretary, from John Ahearne, Commissioner, regarding SECY-82-352, Assurance of Quality (1 page).
- 2. 02/10/83 Memorandum for Gilinsky, Ahearne, Roberts, and Asselstine from Nunzio J. Palladino, entitled " Quality Assurance Initiatives" (1 page). '
- 3. 08/15/83 Memorandum for Palladino, Gilinsky, Roberts, Asselstine, and Bernthal, from John E. Zerbe, OPE, entitled " Quality Assurance Program Plan" (10pages).
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March 20, 1984 SECY-84-124 (Notation Vote)
For: The Comissioners From: William J. Dircks Executive Director for Operations
Subject:
REPORT TO CONGRESS ON IMPROVING QUALITY AND THE ASSURANCE OF QUALITY IN THE DESIGN AND CONSTRUCTION OF COMMERCIAL NUCLEAR POWER PLANTS (FORD AMENDMENT STUDY)
Purpose:
To request Comission approval of a proposed letter transmitting the QA report to Congress and of three proposed actions recommended by the study beyond the authority of the EDO.
Background:
On January 4,1983, the President signed into law the NRC Authorization Act for fiscal years 1982 and 1983 (P.L.97-415).
Section 13 of.this Act requires the NRC to conduct a study of existing and alternative concepts for improving cuality assurance in the design and construction of nuclear power plants j and to provide a report on the study to Congress within fifteen months (i.e. , by April 4,1984). Section 13 of the Act was introduced by Senator Wendell Ford of Kentucky and was referred '
to by Senate co-sponsors as the Ford Amendment. The Ford Amendment's study requirement can be broken into the following subtasks:
- 1. The study shall include an analysis of quality assurance (QA) and quality control (QC) programs at representative sites and provide an assessment of why some programs are more successful than others.
- 2. The study shall include an analysis of five alternative approaches for improving quality which were described in the language of the Act.
- 3. The study shall include a pilot program to test one or more of the five alternative approaches to assess their benefits and feasibility.
Contacts:
G. T. Ankrum, IE, 24774 W. D. Altman, IE, 28490 D L424-.
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- 4. In conducting the study the NRC shall obtain the coments f of the public, licensees, the ACRS, and organizations of
. professionals having appropriate expertise.
- 5. The results of the study shall be compiled in a report to Congress which shall also include a sumary of the infor-mation gained from the groups listed above, NRC's response to the significant public coments received, and an analysis of the results of the pilot program.
- 6. The report shall be accompanied by the recomendations of the Comission, including any legislative recomendstions, and a description of any administrative actions that the Comission has taken or plans to undertake for improving quality assurance in construction.
Discussion: The enclosed report prepared by IE and reviewed by other staff offices and the regional offices describes the activities under-taken to meet tasks 1-6 above. The report also describes administrative actions underway and those proposed by the study.
The most important administrative actions are described in Section 2.4 of the report and are sumarized in Tables 2.1, 2.2, and 2.3 of Chapter 2. Chapter 2 provides a comprehensive sumary of the study, its conclusions and its recomendations.
The proposed transmittal letter to Congress highlights the study's conclusions and recomendations, and when bound into the front of the completed report will serve as the report's execu-tive sumary. The transmittal letter, together with the staff's report collectively satisfy study requirements 1-6. At this time, there are no legislative recomendations to be proposed.
There are three proposed administrative actions requiring Comission approval. They are:
(1) Preparation of a regulatory analysis which may lead to rulemaking requiring periodic comprehensive third party audits for both future plants and plants currently under construction. (See Sections 2.2 and 2.4 and Chapter 4 of the report.)
(2) Preparation of a regulatory analysis which may lead to rulemaking requiring that organizations building future plants, as a condition of their CP, be required to periodically demonstrate their management capability and effectiveness, including their ability to implement an effective QA program. (See Sections 2.2, 2.4, and 4.3)
(3) Preparation of a regulatory analysis which may lead to establishment of an advisory board to the NRC comprised of senior executives and others with first hand experience
if I
in the managing, designing, constructing, financing, and
' insuring of nuclear construction projects to provide advice on the qualifications and capabilities of a CP applicant to successfully construct a nuclear power plant. (See Sections 2.2 and2.4)
None of the other proposed administrative actions recomended by the report represent new regulatory requirements and they will be evaluated and implemented within the authority of the EDO.
The staff will prepare a program plan which identifies overall QA program goals and objectives and provides a task oriented structure for program implementation. The plan, which will include a prioritization of actions and an assessment of resources, will be completed by September 30, 1984 As indicated in SECY 84-45, quarterly QA status reports to the Comission will be resumed beginning in July 1984.
Action: The staff requests that the Comission approve:
(1) Staff action to begin the regulatory analysis process which may lead to a third-party audit rule.
(2) Staff action to begin the regulatory analysis process which may lead to a post CP demonstration rule. {
' (3) Staff action to begin the regulatory analysis process which f" may lead to the establishment of a construction advisory board to the Comission.
(4) The enclosed letter transmitting the Ford Amendment Study '
to Congress.
Schedule: The Ford Amendment Report is clue to Congress by April 4,1984.
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William J. Dircks Executive Director for Operations
Enclosures:
- 1. Transm'. ital Letter to Congress
- 2. Report to Congress l
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This paper is tentatively scheduled for discussion at an Open Meeting during the Wet'= of April 2, 1984. Please refer to the appropriate Weekly Commission Schedule, when published, for a
/ specific date and time.
If Commissioners do not vote to approve this paper at the meeting, comments or consent should be provided directly to the Office of the Secretary ASAP following the meeting.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Wednesday, March 28, 1984 in preparation for the Commission meeting, with an information copy to the Office of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners OGC OPE OI OCA OIA OPA REGIONAL OFFICES i EDO [
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C H L t R t.* L N MEMORAf;DUM FOR: k'i l l i a m J . Dircks Executive Director for 0;erations FROM: *:unzio J. F a ll a d .:o
SUBJECT:
QUALITY ASSUF.A!CE l !iRC needs to take actiors that will result in ir. proved quality assurance at nuclear pcwer plants.
Steps we are taking or pla.nning, as well as other steps that
, could be ta ken, were brought up during our testimony to 1
l Congressman Udall's Subcommittee last week. A list of corrective measures would include improvements to our l
inspection and enforcement program as well as considerations such as third party audits, strict sanctions acainst non- -
l performers, a pproved bidders lists , gnd certified indepcn-dent performa nce audits of each utiltty's QA activities-
- I would like you to pull together the varicus approaches that could be taken to strengthen quality assurance, and provide the Commission a preliminary evaluation of the ones that appear most promising from an e f f e c ti v~e ne s s and cost standpoint. .
I believe i t" i s d e s i ribl e' t o h a v e ' a'n. i n i t i a l p a p e'r 'o n y o u r recommendations by December 11, 1981. The Commission can then focus on the areas deemed worthy of implementation for f urther s tudy by the Staff.
cc: Commissioner Gilins ky Commiss i oner Bradford Commissioner Ahearne Commissi oner Roberts .
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