ML20137E006

Addl Response to FOIA Request for Documents Re Comanche Peak Task Force.Forwards Listed App D Documents.Other Listed Documents Partially or Completely Withheld (Ref FOIA Exemptions 6 & 7)

ML20137E006
Person / Time
Site:	Comanche Peak
Issue date:	12/13/1985
From:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
To:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
Shared Package
ML20136F037	List: ML20136F034 ML20136F056 ML20137E006 ML20137E284 ML20137E320 ML20137E351 ML20137E391 ML20137E441 ML20137E455 ML20137E504 ML20137E558 ML20137E687 ML20137E744 ML20137E751
References
FOIA-85-59 NUDOCS 8601170140
Download: ML20137E006 (3)

Text

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• UNITED STATES

• 8 o NUCLEAR REGULATORY COMMISSION r, WASHINGTON, D. C. 20555 k ...*[j December 13, 1985 Docket No. 50-445/50-446 Ms. Billie Pirner Garde Citizens Clinic Director Government Accountability Project 1555 Connecticut Avenue, Suite 202 IN RESPONSE REFER Washington, DC 20036 TO F01A-85-59

Dear Ms. Garde:

This is in further response to your letter dated January 21, 1985, in.which you requested, pursuant to the Freedom of Information Act (F0IA), records related to the NRC Comanche Peak Task Force established in March, 1984.

With the exception of document number 269, the NRC staff has completed its review of those records subject to your request that were identified by asterisks in Appendix D (Electrical / Instrumentation category) transmitted to you by our letters dated November 13 and 15,1985. We will address document number 269 in a future letter to you. The disposition of the remaining records is described below.

Documents 280, 343, 345, 406, 407, and 440 on Appendix D are being placed in the NRC Public Document Room (PDR) in file folder F01A-85-59 under your name.

Documents ublic disclosure pursuant to Exemption (7)(C) of the F0IA112, 113, 5 U.S.C. 145,(7)(C))

552(b 243, 296, and 426 and 10 CFR 9.5(a)(7)(iii) of the Commission's regulations. These records contain personal information regarding several individuals. The release of this information would constitute a clearly unwarranted invasion of personal privacy. There are no reasonably segregable portions of these documents, and they are being withheld in their entirety.

Documents 425 and 702 through 711 are being withheld from public disclosure pursuant to Exemptions (6) and (7)(D) of the F0IA (5 U.S.C. 552(b)(6) and (7)(D)) and 10 CFR 9.5(a)(6) and (7)(iv) of the Commission's_ regulations.

These records contain personal privacy information, the names of allegers, and other identifying information concerning individuals who provided information to the NRC during the agency's investigative activities. These records are being withheld in their entirety because their release would ~ constitute a clearly unwarranted invasion of personal privacy and disclose the identity of confidential sources.

Eleven of the Appendix D documents listed below are being withheld in part, as indicated by asterisks, and the remaining 30 documents contain deletions without invocation of an F0IA exemption, for the reasons set out-following the-

document listing

l 8601170140 851213 ^

t PDR FOIA

( GARDE 85-59 PDR L - i

1 (ELECTRICAL / INSTRUMENTATION RECORDS) l APPENDIX D - PARTIALLY WITHHELD DOCUMENTS LIST l

1 2 3 6 26 27 28 69* I i

70* 71* 144 198 262 266 274 306 307 308 309 310 311* 312 316 326-339* 362* 366* 369* 390 391* 392 393*

394 395 396 405 520 521 522 523*

524 Portions of documents 339, 362, 366, 369, 391, and 393 are being withheld pursuant to Exemptions (6) and (7)(C) of the F01A.(5 U.S.C. 552(b)(6) and-(7)(C)) and 10 CFR 9.5(a)(6) and (7)(iii) of the Comission's regulations.-

The exempt portions of these records contain personal identifiers and other personal privacy information, such as home addresses and home telephone numbers regarding several individuals. To disclose the personal identifiers-and other identifying information concerning these individuals would constitute a clearly unwarranted invasion of personal privacy.

Portions of documents 69, 70, 71, 311, 366, 369, 391, 393, and 523 are being withheld from public disclosure pursuant to Exemption (7)(D) of the F0IA (5 U.S.C. 552(b)(7)(D)) and 10 CFR 9.5(a)(7)(iv) of the Commission's regulations. The exempt portions of these records contain the names of allegers and other identifying information concerning individuals who provided information to the NRC during the agency's investigative activities. Release of this information would disclose the identity of confidential sources.

In accordance with the terms of the agreement reached between you and the NRC staff at the May 8,1985, meeting concerning your pending FOIA requests pertaining to the Comanche Peak TRT activities (as outlined in the letter to you from Mr. Joseph M. Felton dated May 15,1985), portions of documents 366,-

393, and 425, and portions of the remaining documents listed above which are not addressed individually by specific F0IA exemptions have been deleted because they contain names and other identifying information concerning allegers, interviewees, and other individuals whose privacy could be invaded by disclosure of this information.

The nonexempt portions of all the documents included in the Appendix D list above are.being placed in the PDR in file FOIA-85-59 under your name. A separate set of the records placed in the PDR under cover of this letter is also being made available for public inspection and copying at the Local Public Document Room located at the University of Texas Library, 701 South Cooper Street, Arlington, Texas.

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I Pursuant to 10 CFR 9.9 of the Conunission's regulations, it has been determined that the information withheld is exempt from production or disclosure'and that its production or disclosure is contrary to the public interest.- The persons

responsible for this denial are the undersigned and Mr. Harold R. Denton, Director, Office of Nuclear Reactor Regulation.

This denial may be appealed to the Executive Director for Operations within 30 days from the receipt of this letter. Any.such appeal must be in writing, addressed to the Executive Director for Operations, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial F0IA Decision."

Sincerely, a c

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Donnie H. Grimsley, Director Division of Rules hnd Records Office of Administration 2

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GOVERNMEhT ACCOUNTABILITY PROJECT

~ 1555 Ccmecticut Avenue. N.W., Suite 202 Woshington D.C. 20036 .

(202)232 8550 G:85:104 January 21, 1985 FREEDOM OF INFORMATION ACT REQUEST FREEDOM OF INFORMATION ACI REQUESI, N M8 Director Office of Administration Nuclear Regulatory Commission Washington, D.C. 20555 To Whom It May Concern:

Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. $ 552, the Government Accountability Project (" GAP") requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview re-ports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer runoffs, any other data compilations, interim and/or finsi reports, status re-ports, and any and all other records relevant to and/or generated in connection i with the overview, ragulation and investigation of the Comanche Peak Nuclear Plant 4

by any person, branch, or department of the NRC since January 18, 1985.

This request includes all agency records as defined in 10 C.F.R. $ 9.3a(b) and the NRC Manual Appendix 0211, Parts 1.A.2 and A.3 (approved October 8,1980) whether they currently exist in the NRC official, " working," investigative or other files, or at any other location, including private residences.

If any records as defined in 10 C.F.R. $ 9.3a(b) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implementtheaction(s).

GAP requests that fees be waived, because " finding the information can b'e con-sidered as primarily benefitting the general public," 5 U.S.C. 6.552(a)(4)(a).

GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability. Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Citizens ,

Clinic is currently assisting several citizens groups, local governments and intervenors in the central Texas area concerning the construction of the Comanche Peak nuclear power plant. .

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.E Director .

Office of Administration Page Two We are requesting the above information as part of an ongoing monitoring project on the adequacy of the NRC's efforts to protect public safety and health at nuclear power plants.

For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index,should provide a detailed jusitfication of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document. withheld. This index is required under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir.1973), cert denied, 415 U.S.

977 (1974).

We look forward to your response to this request within ten days.

Sincerely, lh Billie Pirner Garde Citizens -Clinic Dire _ctor 1

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COMANCHE PEAK PLAN'FOR TyECOMPLETIONOFOUT. STANDING REGULATORY ACTIONS MAY 1984 Approval:

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H.' E. Denton, Director, NRR d .I hk

Date' R.L o n.t L\-ra t % n r. T,,,,,6 s /5/g J. T.*Co114ns,' Administrator ~ ' Date

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. COMANCHE PEAK PLAN FOR THE COMPLETION OF OUTSTANDING REGULATORY ACTIONS

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I. PURPOSE AND SCOPE On March 12, 198A, the EDO directed NRR to manape all necessary NP.C actions leading to licensing decisions for Comanche Peak and Waterford. A copy of that directive is. included as Attachment 1. This plan establishes.the.

program for Comanche Peak.

The purpose of this plan is to assure the overall coordination and integration of the outstanding regulatory actions regarding Comanche Peak, '

and achieving their resolution prior to a licensing decision. This plan l-encompasses all licensing, inspection, hearing, and allegation issues.

Further, this plan addresses the scope of the work needed, specifies the critical path issues, identifies the responsible line organization, the schedule for completion, and (where applicable) the need for additional resources to meet the schedule. .

The planned completion date for all reginatory actions is assumed to be October 1,1984, and resource needs are predicated on that assumption.

l A status report will be issued to management every two weeks starting two weeks after the approval of the plan.

I II. BACKGROUND Comanche Peak Steam Electric Station Unit 1- istin the final stages of the

operating license review process. The Construction Permits for Unit.1 and 2 were issued on December 19, 1974. Texas Utilities docketed their

, application for operating licenses on April 25, 1978. The Final Environmental i Statement was issued September 24, 1981. The Safety Evaluation Report (SER) was issued on July 14, 1981. Because of the large number of outstanding 4

issues identified in the SER, the staff recommended delaying the ACRS review.

SER Supplement No. I was issued on October 16, 1981, and the ACRS meeting

was held on November 13, 1981. The ACRS, by letter dated November 17, 1981, 4

i supported issuance of an operating license. The latest SER supplement' was -

issued on November 23, 1983.

fComanchePeakhasbeeninahe'avilycontestedhearingforovertwoyears.

All but one contention have been dismissed. The remaining contention questions the ability of the applicant's-Quality Assurance / Quality Control-

> Program to prevent deficiencies in the design and. construction of.the plant.

p- The Licensing Board has admitted many allegations of design and construction- _;

deficiencies into the hearing as relevant to this contention.. l The Applicants are currently pro.iecting a fuel-load date for Unit 1 to be  ;

in late September 1984. The basis for this proiection was provided te- j the staff on May 7, 1984 This fuel load date appears achievable but u t , allows no flexibility for unexpected events in a very tight schedule. l l The number of hearing issues and uncertainty regarding the timing of the l l

Licensing Board's initial decision may impact the fuel load. l l

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III. PLAN FOR ThE COMPLETION OF OllTSTANDING REGULATORY ACTIONS q

i This plan describes the method in which coordinated regulatory actions

.( are to be taken by the staff to be ready to support an NRC decision ,

i regarding Comanche Peak licensing. As stated in the Purpose, the-plan '

encompasses all licensing, hearing,1 inspection, and allegation issues.

Tnis suninary addresses the scope o' werk needed, identifies the __

resoonsible line organization, the schedule for connletion, and the resource needs to meet the schedule.

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The' management organizational arrangement responsible for directing the.overall effort and coordinating actions by the various involved offices is shown graphically in the enclosure to the EDO memorandum of March 12, 1984 (Attachment 1). The management is under the overall direction of T. A. Ippolito, who reports to the Director of the .

Division of Licensing. The managers responsible for implementing and directing this organization are the following individuals:

l Project Director (T. A. Ippolito)

- - - 4 0 ELD Contact (J.- Scinto)I

- 4 0I Contact (B. Ha_ves H i NRR Action Region IV Actions- IE Actions

! (T.Novak) (R. Bangart) (R.DeYoung)

The line offices will continue to manage their own responsibilities regarding Comanche Peak in accordance with the schedule and objectives

of this plan. Line office activities are to be coordinated with the-program management organization via their representative as identified i above. Additional resources are expected to be necessary to support 4 licensing, hearing, and inspection issues, and substantial resources are necessary to respond to the approximately 400 allegations regardinn_

Comanche Peak.

-i This plan preposes the formation of an' Technical Review Team (TRT) I i

1- to evaluate and resolve a nuut er of technical issues, including ',

allegations, presently identified.- A proposed organizational. chart of 1 the TRT is shown below. The groups identified will be assigned to-9 evaluate and resolve technical issues and allegations that have been 1 grouped into five technical areas: QA/QC, Electrical / Instrumentation Civil / Mechanical, Coatings, and Test Programs. The groups will be .

comprised of a group leader and reviewers that are specialists in the

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particular technical area.

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- 3-Comanche Peak Technical Review Team (TRT) j l Proiect Director

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L---- Office of Investigations GROUP, LEADERS OAIOC Electrical / Civil /MNhanical Coa' tings Test Program Records Instrumentation and

. Operational Readiness The staffing of these-groups will be drawn fron the various NRC' offices and/or contractors as arranged between the Project Director and line management. The TRY may be called together for a specified period-of time, dispersed back to the individual's parent office, and then reconstituted in whole or in part as needed to complete resolution of like issues. ,

The TRT will be under the direct supervision of the Pro.4ect Director.

In accordance with the EDO memorandum of May 25, 1984, the TRT organization is scheduled to be in place and functioning by June 4, 198A.-

Detailed guidance will be issued by the Project Director to the Technical  !

Review Team and other participants in this effort. This guidance will address the following:

Method and approach for identification and

g disposition of allegations

'! - Tracking Systen

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- Preparation of Documentation and Records I*i, - Protection of Individuals ,

- Initiation of Special NRC actions, such as Confinnation of Action Letters or 50.54(f)-

letters-Manpower accounting

, The basis upon which the schedules and resource estimates have been . <

l developed is that the Comanche Peak fuel load date is October 1, 1984 3 ~

Figure 1 is an overall schedule and Figures 2 throuch 5 are individual '

schedules for the resolution of. Licensing, Hearing, Inspection,' and Allegations Regulatory Actions, respectively.

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. 2 The major issues, schedules, and resource estimates needed to meet the schedules are sumarized as follows:

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A. Licensino Reculatory Actier.s Licensing Actions are those things resulting from the design review of the FSAR. NRR is responsible for the resolutien of these action items.-

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- The total number of outstanding action items is 37.

Four of these action ite":s are considered to have the potential for impacting the schedule. These items relate to 1) the adequacy of the TDI diesel generaters, 2) the the Applicants' exemption request for relief from GDC 4, 3) review of the Cygna Report of an independent assessment of design and construction, and 4) electrical equipment environmental cualification.

NRR experience with other facilities involved in complex licensing -

reviews (Diablo Canyon, Seabrook, and Shoreham) indicates that additional project management resources are necessary. Two additional project managers for the period from June-September will be needed, for a total of 8 man-months of additional effort. -

The technical resources presently assigned by NRR to evaluate and l resolve the remaining open licensing actions are sufficient to meet the schedule shown in Figure 2. Additional IE resources are not -

expected to be required as the CAT. inspection is complete and

OA/QC reviews and emergency preparedness reviews are essentially complete.

! . B. Hearing Reculatory Actions Hearing Actions are those issues-in contentiors before the ASLB.

There are three major issues each with' a number of sub-issues. The (

lj thiee major issues are Design Adequacy and Ouality Assurance, Corstruction Adequacy, and Construction Cuality Assurance.

. ,. 7 There are two critical path actions: ~ Design Adecuacy and' Construction

[ Adecuacy. The design adecuacy action concerns an;1_DYPheing: performed '

i by the Applicants at the staff's request. CYGNA is' perfoming the-review for the Applicants. This is currently under review by the t~

staff. Cygna personnel. actions may have contributed to pe(prenotifi-cation of inspection areas o Applicant OA/QC personnel. Resolution of this concern may make i necessary to request additional .

independent assessment ac vities. ,

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l The critical path issue oncerning Construction Adeouacy is containment liner coating (painting). W['

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Y The resources presently available are sufficient to resolve all i? hearing actions with the exception of the critical path issues.

1 It is estimated that 10 man-months are required to resolve the d Desion Adequacy Action, and 6 man-months to evaluate the Construction t Adequacy Action (painting). The design adeouacy review will reovire

! a team composed of IE and NRR personnel, similar to the Cygna IDVP effort.

Coordination of Hearing activities is expected to be extensive f.

and involve integrating the activities of f!RR, OELD, and Region IV- 1

. with the Technical Review Team. An additional senior manager (SES-level) is needed to manage this- effort as it is expected that the '

! Project Director will devcte full time effort to management of the technical review team actions commencing June 4,1984

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i These estimates assume that the reviews will cenclude that the existing circumstances are acceptable to the staff and/or no major corrective actions are required of the Applicants. Should this prove.

otherwise, additional resources wil1 be required for resolution.

i See Figure 3 for Hearing Testimony Comoletion Schedule.  ;

C. Inspections Regulatorv Actions-p --

Inspection actions are those that assure that adequate completion of plant construction and the readiness of the Applicants to operate

the plant. These actions are the responsibility of-Region IV. ,

The total' number of outstanding action items is 377. These may-be grouped as follows:

SER verification: 30 actions-

- Routine construction inspections, preoperational . test

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program and operationel readiness inspections and

startup test program

121 actions Operating Licensing:- 20 actions Open items inspections (unresolved items, violations,- ,

l. 50.55(e) items, inspector follow-up items and -

l~! Part 21 items: 201 actions-Room inspections: TBD

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' - CAT follow-up: 5 actions

All the inspection items require resolution prior to OL issuance.

.i Many require applicant actions prior to inspection or relate to j hearing issues. Particularly significant is the. retest-inspection effort as the applicant plans to re-run approximately 25 preoperational tests to confirm system readiness subsequent to various modifications

, and design changes. -Many of these tests will be witnessed by.

the NRC and test results will be evaluated as appropriate. Systems involved include safeguards systems, reactor protective system,

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service water, component cooling water, and the diesel generator.

The number of inspection items represents a sizeable effort that H T could impact fuel load. , .

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Some additional resources will be required to complete the routine inspection program and resolve the many open items. It is expected i that this area could require approximately 46 man-months. Considering

- the number of items and based on Waterford experience, the Region estimates that much of this effort can be handled with existing-resources but that approximately 18 man-months additional resourcesi a- will be required. See Figure 4 for the Inspections-Schedule.

D. , Alleaations Regulatory Actions

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The Allegation Actions are those concerns reported by various individuals, intervenors and action groups regarding the safety of construction of-the plant. Concerns regarding wrongdoings,

. intimidation, etc. are not included in the technical review team >

effort but are referred to OI or OIA as appropriate.

i To date the number of individual ac,tions is approximately 400.

These actions are grouped into specific categories to facilitate j their resolution. Resolution of these actions will involve the Technical Review Team, NRR, 01, and Region IV.

The organizational group with primary reshnsibility for resolution of these actions is the Technical Review Team (TRT). The resources-required to resolve these actions are identified below according to the Team functional group:

Resource Functional Group No. of Allegations Estimate (man-months)

OA/QC Records 180 17 Electrical /Instrum. 5 2 Civil / Mechanical 97 17 5 Coatings 11 4 Test Programs 14 2 Estimated Totals 707 T L. -

! The TRT effort is expected to require additional. administrative l

[ .. support (secretarial) of approximately 3 man-months. Fence, I the total TRT resource needs are 45 man-months. _

I- The total program for resolving:the allegations actions is a, ~l

critical path item. See Figure 5 for the schedule for_ completion of the review of these allegations.

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In addition, 97 allegations will be handled by the'following offices:

Responsible .l Functional Group No. of Alleoations Head Office '

Intimidation 30 OI l Design. Pipe / Pipe Supports 19 NRR I' q Vendor / Generic- 18 NRR/IE-Independent Assessment Program 7 NRR Miscellaneous 23 RIV Design of pipe and pipe supports, and the Independent Assessment

. Program allegations will be dispositioned by NRR personnel that

. are handling these issues for the hearings. Intimidation allegations will require additional OI resources as discussed i later in this section. Existing resources in the Vendor. l; Inspection Branch, IE and NRR will disposition the vendor / generic allegations. Existing resources irt Region IV will be responsible-for the miscellaneous allegations.

E. Office of Investigation Actions OI actions are those actions necessary to support the resolution

of allegations. They. involve issues where wrong-doing, intimidation,

, or harrassment may be. involved.

It is clear that with the present resources; assigned to the Comanche

! Peak investigation (one investigator) .the schedule for resolving the allegations and wrongdoing issues will not be met. We estimate several additional investigators will be required on full time basis i

from June through September, for a total of 12 man-months of effort.

During this 4-month period OI will require the full-time support of

-s one individual with a technical background, as many allegations are i1 a combination of technical and wrong-doing issues, for a total of 4 l3 man-months.

1 i The NRC staff effort to complete the actions in the licensing, hearings, .

A inspections and allegations areas will be substantial ~and the impact will be-felt by several Offices. The foregoing susenary lists a total of 821 separate 1 actions. requiring approximately 100 man-months of. effort above the existing i' (budgeted) resources-. Personnel for much of-this effort will be obtained l from contractors. It is estimated that approximately $1 million will be necessary to fund contractor assistance in support of Comanche Peak reviews _

during the remainder of FY 1984. . The estimates are somewhat fragile and assume that no major new issues are raised, that the Applicants meet their projected schedule, and that staff review of the identified issues will conclude that the

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existing circumstances, or the resolution, is acceptable.

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