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, [ g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
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NOV 1y h
MEMORANDUM FOR: Joseph Scinto, Deputy Director Office of the Executive Legal Director
! .cROM: Vincent S. Noonan, Project Director
! Comanche Peak Technical Review Tdam
SUBJECT:
COMANCHE PEAK TECHNICAL REVIEW TEAM (TRT) AND REGION IV
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INPUT TO THE STAFF'S RESPONSE TO TEXAS UTILITIES i 50.57(C) MOTION TO LOAD FUEL AND CONDUCT CERTAIN l PRECRITICAL TESTING Enclosed are allegations and issues still under evaluation by the TRT in the j Civil / Structural, Mechanical / Piping, Electrical / Instrumentation, Test J Programs, and QA/QC areas affecting systems that mr.y be needed for fuel load
} and the precritical testing requested by the applicant. There are no i outstanding issues in the TRT Coatings area that would affect the systems
! needed for fuel load and precritical testing requested by the applicant.
l Also enclosed is the status of Region IV room inspections as they relate
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to the applicants motion.
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'Io , ro ect Director manche Pe fech ical Review Team 4 cc: E. Case
! D. Eisenhut ;
! R. Martin, Region IV i 1
J. Gagliardo [~
R. Wessman kC]-
A. Vietti
- - R.C. Tang l P. Matthews ~
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! J. Calvo R. Keimig H. Livennore '
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Allegations and Technical Issues Still Under Evaluation By the TRT. .
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, in the Civil / Structural Area Affecting Systems That May Be Needed for Fuel Load and the Precritical Testing Requested By the Applicant
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- 1. Interaction of Seismic Category I Buildings and Systems Housed Within Them .
The TRT investigated the r,equirements to maintain an air gap between p
concrete structures. The TRT reviewed available inspection reports and i related documents, made on field observations, and had discussions wi.th j TUEC engineers.
The TRT found a lack of supportiv'e documentation that an air gap has been provided between concrete structures. TUEC has not adequately demon-strated complia'nce with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and
, 3.7.8.2.8, which require separation of Seismic Category I buildings to prevent seismic interaction during an earthquake. Accordingly, by letter l dated September 18, 1984, TUEC has been required to perfom inspections
- and provide the results of analyses to demonstrate that Seismic j Category I structures, systems, and components are safe in the as-built I condition.
1 In response to the NRC letter of September 18, 1984, the applicant has
) developed a program to resolve the NRC staff concerns which the staff is j .
currently evaluating. The staff met with TUEC in public meetings on f October 19 and 23, 1984, to discuss the staff's comments on the I. applicant's proposed program plan to resolve this issue, and is currently ha preparing a letter to TUEC documenting these specific coments.
t l Since a thorough assessment of this issue has not been completed as yet, t
it is inappropriate to consider fuel load and the precritical testing j requested by the applicant at this time.
l 2. Seismic Design of Control Room Ceiling The TRT investigated the seismic design of the ceiling elements installed
$ in the control room.
Thhs review revealed that TUEC had not adequately demonstrated that the j , suspended ceiling, lighting fixtures and non-safety related conduit over the control room (which are classified seismic Category II or Non-Seismic by TUEC) are appropriately designed such that their failure would not adversely affect the functions of safety-related components in the control room or cause injury to operators. Accordingly, by letter dated n
! Sept r 18, 1984,.TUEC has been required to provide further analyses ,
o and av uations to justify.their design. In addition, TUEC has been' r requi to provide the results of an analysis which demonstrates that -
the foregoing problems are not applicable to other Category II and non-seismic structures, systems and components elsewhere in the plant.
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j In res @ nse to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is '
currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984 to discuss the staff's coments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific comments.
Since a thorough assessment of this issue has not been completed as yet, it is inappropriate to consider fuel load and the precritical testing
, requested by the applicant at this time.
Allegations and Technical Issues Still Under Evaluation By The TRT in Mechanical /Pi Jing Area Affecting the Systems That May Be Needed For Fuel Load and The 'recritical Testing Requested By The Applicant.
TheTRTevaluahtonofallegationsandissuesintheMechanical/ Piping area is still in progress. The staff is planning to have a public meeting with the applicant to identify requests for additional information in the Mechanical / Piping area in late November 1984. The TRT review of the following allegations and issues would require action by the applicant before proceeding with the fuel load licensing process.
- 1. Plug Welds The TRT is evaluating alleged unauthorized and undocumented plug welds that were fabricated in pipe and cable tray supports and base plates located throughout the plant including the South Yard Tunnel and Unit 2 y Cable Spreading Room.
. 2. Piping Systems Between Seismic Category I and Non-Seismic
! Category I Building i ! The TRT is evaluating an issue identified in the April 1984, CPSES j
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, Special Review Team Report that the affects of seismic interactions have not been considered, contrary to the FSAR Section 3.7.B.2.8 comitment.
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- r 3. Skewed Welds On Pipe Supports
~ "The'TRT is evaluating alleged lack of written QC inspection procedures for the examination of certain types f skewed welds on pipe supports N
initially identified in ASLB Hearing July 30, 1982, by Mr. C. Atchison
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[ 4. Cutting Of Bolts On Steam Generator Lateral Supports 5 -
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i The TR is evaluating an allegation that some anchor bolts in the steam genera r upper lateral supportis were shortened without proper authori- p zation uring installation'of the beams because there was concrete in the -
hole.
. 5. Temporary Supports During Piping Installation i
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lr The TRh, while evaluating an allegation that a main steam line was forced .
into place using the main polar crane in Unit 1, identified additional l concerns regarding: 1) the effects of settlements at temporary supports i during flushing of the main t. team line; and 2) the adequacy of temporary supports in general.
Allegations and Technical Issues Still Under Evaluation By The TRT in the Electrical / Instrumentation Area Affecting Systems That May Be Needed for Fuel Load and the Precritical Testing Requested By The
. Applicant ,~
! 1. Electrical QC Inspector Training / Qualification Deficiencies i The TRT examined QC electrical ins'ector p training and certification l files, and requirements for testing program, on-the-job training and recertification program.
The TRT found a lack of supportive documentation regarding personnel qualifications in the training and certification files, as required by procedures and regulatory requirements, and also found a lack of documentation for assuring that the requirements for electrical QC inspector recertification were being met. Accordingly, by letter dated September 18, 1984, the staff requested additional infonnation from TUEC.
In response to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is
- currently evaluating. The staff met with TUEC in public meetings on p-October 19 and 23, 1984, to discuss the staff's connents on the applicant's proposed program plan to resolve this issue, and is currently I -
preparing a letter to TUEC documenting these specific comments.
4 These deficiencies identified with the electrical QC inspections have generic implications to other construction disciplines. The implica,tions i of these findings are being further assessed as part of the TRT overall
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/ programmatic review of QC inspector training and qualification. It is F inappropriate to consider fuel load and the precritical testing requested
, by the applicant at this time, due to the uncertainty regarding the J
. ..qualiffcation 'and training of inspectors involved in inspecting systems needed for this activity.
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- 2. Conduit Support Installation
- Deficiencies in Selected Seismic Category I Areas
! , ,. em a : The TRZ examined the nonsafety related conduit support installation in i select [
for noo[d seismic Category safety-related I areas conduits, less than of theorplant.
equalTheto 2support inches, installation was -
inconsistent with seismic requirements, and no evidence could be found that substantiated the adequacy of the installation for nonsafety-related conduit of any size. Evidence could not be found that substantiated.the l
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I l fai urk would not adversely affect the function of safety-related
, components or.cause injury to plant personnel. ~
L! r The safety significance of the loss or uncertainty about the operability y
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of these systems is that the lack of analysis makes the quality of the supports indetenninent and consequently their behavior during a seismic h event could not be predicted. The TRT concludes that the conformance of the seismic support systent installations with Regulatory Guide 1.29 had f not been demonstrated. Accordingly, by letter dated September 18, 1984, 1 , the staff requested additional information from TUEC.
a x k In response to the NRC letter of September 18, 1984, the applicant has y developed a program to resolve the NRC staff concerns which the staff is l currently evaluating. The staff met with TUEC in public meetings on v . October 19 and123, 1984, to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently
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4 I preparing a letter to TUEC documenting these specific consnents.
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These problem areas identify a potential generic implication to all
] l seismic. Category I areas of the plant. It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this 1 i
- ime, due to the uncertainty of operability of the systems needed for l' this activity.
i i j 3. Electrical Equipment Separation Deficiencies 1
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The TRT review concerned with the separation criteria between separate cables, trays and conduits in the control room and cable spreading room; L
and the compatibility of the electrical erection specifications with
[ regulatory requirements.
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I After reviewing documentation and inspecting random samples of separation j between safety-related cables, trays and conduits and between them and j
I nonsafety-related cables, trays and conduits, the TRT found: (1) d ~
numerous cases of safety-related cables within flexible conduits inside main control room panels, which did not meet minimum separation requirements;'(2) several cases of separate safety /nonsafety cables and l
! separate safety cables within flexible conduits, inside main control room panels, which did not meet minimum separation requirements; and (3) existing TUEC's analysis substantiating the adequacy of the criteria for separation between rigid conduits and open/ ladder cable trays had Tiot
, been reviewed by the NRC staff. Accordingly, by letter dated September p _j ,
18 )964, the staff requested additional information from TUEC.
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In res nse to the NRC letter df September 18, 1984, the applicant has !.;
, develo d a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings.on j October 19 and 23, 1984 to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific consnents.
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The safety significance of the loss or uncertainty about the operability -
of these systems is.the apparent lack of separation that could result in the loss of redundancy when the installation is challenged by design basis events. This could possibly cause loss of capability to achieve safe
- shutdown depending on the circumstances surrounding the event and the j circuits involved.
1 i These problem areas have potential generic implications in all safety-g related control panels and cabinets. It is inappropriate to consider
! fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty of operability of the systems needed for this activity. _
- 4. Electrical Cable Termination Deficiencies 1 The TRT inspected random samples of safety-related terminations, butt 4
i splices inside panels, and vendor-installed terminal lugs in ITE Grinnel i switchgear and motor control centers, and reviewed documentation relative to the installations.
l The TRT-found: (1)lackbfawarenessofQCelectricalinspectorsto j acknowledge requirements for nuclear heat-shrinkable cable insulation ~
- sleeves; (2) selected inspection reports did not indicate the required
! witnessing of splice installation; (3) absence of splice qualification I
requirements in procedures;-and (4) selected cable termination installations were in disagreement with as-built drawings. Accordingly,
, by letter dated September 18, 1984, the staff requested additional
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information from TUEC.
h l In response to the NRC letter of September 18, 1984, the applicant b
developed a program to resolve the NRC staff concerns which the staff is
. currently evaluating. The staff met with TUEC in public meetings on
! October 19 and 23, 1984 to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently
-l preparing a letter to TUEC ' documenting these specific coments.
! ! The implied safety significance of the loss or uncertainty about the j - . operability of these systems is that the lack of witnessing of the h ! installation, disagreement of the installation with as-built drawings, or lj .
improperly dispositioned NCRs, could place the quality of installation in Li question. Furthermore, the absence of qualification requirements, or 1 -
provisions to demonstrate operability cast doubt on the adequacy of the l butt splice 1,nstallation. .
p ,g r-l i These oblem areas.have potential generic implications to all safety-l* relate panels, switchgear. cabinets, motor control centers, and r
tennin ion cabinets. It is inappropriate to consider fuel load and the -
] 3 precritical testing requested by the applicant at this time, due to the uncertainty of operability of the systems needed for this activity.
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Allegations and Technical Issues Still Under Evaluation By The TRT In The Test Program Area Affecting Systems That May Be Needed For Fuel Load and The
. Precritical Testing Requested By The Applicant i
The TRT review of completed Hot Functional Test data packages which had 1{ been reviewed and approved by the Joint Test Group (JTG), revealed that j TUEC had not met the objectives of three of the 17 test data-packages 9 reviewed. Accordingly, TUEC was instructed, by letter dated September :
4 18, 1984, to review all complete preoperational test data packages to
. ensure there are no other instances where test objectives were not met, or prerequisite conditions not satisified.
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j i In response to the NRC letter of September 18, 1984, the applicant has
!j i developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on
];. October 19 and 23, 1984 to discuss the staff's comments on the i; applicant's proposed program plan to resolve this issue, and is currently j preparing a letter to TUEC documenting these specific comments.
] Since a thorough assessmer.t of this issue has not been completed as yet,
, it is inappropriate to consider fuel load and the precritical. testing l
requested by the applicant at this time.
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l l In addition, the TRT is currently investigating the board's concerns
! about startup quality assurance (Board Memorandum dated October 1, 1984) and is scheduled to respond in late November.
, x Allegations and Technical Issues Still Under Evaluation By the TRT In the j Quality Assurance / Quality Control (QA/QC) Area Affecting Systems That 4 May Be Needed For Fuel Load and The Precritical Testing Requested By The j,
Applicant The TRT evaluation of allegations and issues in the QA/QC area is still
'j in progress. The staff is planning to have a public meeting with the applicant to identify requests for additional information in-the QA/QC area in late November. The TRT review of the following allegations and j ,
issues would require action by the applicant before proceeding with the j j - -fuel. load licensing process.
i 1.' Management Coninitment to QA/QC The TRT.is evaluating alleged management directives to not report problems, intimidation of inspectors, and unqualified QA/QC supervisory person 1. nihile no specific-technical issue was identified from the r-
_ indivi ual allegations, a collective concern from these allegations was _
l identi ed relative to QC inspector training and qualification, and the i-i applic t's comitment to an effective QA program. -
- 2. Parts Interchanged In Diaphram Valves ,
. The TRT is evaluating an allegation that* numerous diaphram valves were -
disassembled and subsequently reassembled interchanging certain parts.
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} 3. As-Built Verification .
r The TRT is evaluating the results of an as-built verification effort conducted as an input into the total QA/QC assessment in that it is used j to measure tae effectiveness of the applicant's QA/QC program for work i performed prior to the TRT's review. The TRT performed inspections on
- completed hardware using the final as-built drawings of the hardware.
j Open Items In The Region IV Walkdown Inspections Affecting Systems That I May Be Needed For Fuel Load and the Precritical Testing Requested ByrThe Applicant
- The staff has completed inspection of the Cable Spread Room, Fuel Building, Containment Building, and Safeguards and Aur.iliary Buildings.
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- The staff concludes that inspection of the Cable Spread Room and Fuel
, Building did not reveal matters that would affect system operability for
, the systems and components required for fuel load and the precritical testing requested by the applicant.
As part of the inspection of the Containment Building, the staff identified a violation related to the as Built Design Documentation Program that may affect system operability for the systems and components required for fuel load and the precritical testing requested by the i ,
applicant.
[_ A review of the licensee's program for verification and control of design t? documents was conducted. Specific drawings and diagrams were selected by the manager, nuclear operation and TUGC0 Nuclear Engineering for updating prior to fuel loading. The inspecticn was conducted to detennine (1) adequacy of procedures governing the generation and completion of
, as-built design documents (drawings and specifications) and (2) the
- schedule for completion of the as-built drawing documentation. The 1 inspection of document control resulted in findings that the actual status of certain design drawings could not be determined and that some design drawings available for use by the control room were out of date.
These findings were cited as a violation of Criterion V to Appendix B of e - CFR Part 50.
The staff c6ncludes that while the Unit 1 containment building inspection i did not identify violations which specifically indicate programmatic j weaknesses in the applicant's program relative to the operability of systems necassary for fuel loading and precritical testing, a violation concerning ttie as-Built Design Documentation Program was identified for r' which the NRC staff. position is indetenninate until the applicant's e responge,totheviolationisevaluated. {
Finally, the results of room inspection of the Safeguards and Auxiliary Building are still under evaluation.- Consequently, the NRC staff i
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P position is indeterminate until the inspection report is issued and the .
applicant's response is evaluated.
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TEXAS UTILITIES GENERATING COMPANY TXX-4367 d ;
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meen.sto.sesacs November 21, 1984 -
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Mr. Darrell G. Eisenhut ,
", Director, Division of Licensing U.S. Nuclear Regulatory Comission 1 Washington, D.C. 20555 ae j
Dear Mr. Eisenhut:
q j d Ch October 8,1984, Texas Utilities Electric Company (1UEC) submitted our response to the NRC-Technical Review Team initial transmittal of potential open a
d items. Our response consisted of two principal elements, the Comanche Peak
.] Response Team (CPRT) Program Plan and issue-specific Action Plans.
n Subsequent to our meetings of October 19 and 23, during which TUEC had the U benefit of NRC Staff feedback and carne.nts on our October 8 submittal, we have 1 substantially revised our Program Plan. Enclosed with this letter is Revision 1 q tc the Program Plan.
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The revisions focus on enhancing three aspects of the plan. First, we have I
added two members to the Senior Review Team (SRT) from outside IUEC. We have 1 also replaced all the Issue Team leaders with experts from outside IUEC. Our objective in filling these key, decision-making positions by experienced, nuclear industry experts is to eliminate any questions regarding the credibility and objectivity of the program by providing fresh perspective.
Second, the Program Plan has been revised to include more specificity
( regarding the determination of root causes and potential generic implications.
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The manner in which such detenninations shall be incorporated in the scope and content of Issue-Specific Action Plans has been clarified.
f, Third, the Propam Plan now contains guidance with respect to relevant j infonnation raised by or presented to the Comanche Peak Atomic Safety and
] Licensing Board in the scope and content of the specific Action Plans.
Ao We are currently revising Appendix A of the Program Plan (i.e., the issue specific Action Plans) to address the NRC staff cm nents provided to us at the recent meetings. The Issue-Specific Action Plans will be resutxaitted under separate cover after our newly-assigned Review Team Leaders have incorporated any appropriate revisions.
' Sincerely, a F01A-85-59' .
q chael D. Spence .
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COMANCHE PEAK STEAM ELECTRIC STATION UNITS I AND 2 .
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1 DROGRAM PLAN AND ISSUE-S3EC?lC ACTION PLANS REVISION I NOVEMBER 19,1984 j .
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. TEXAS UTILITIES GENERATING COMPANY ~
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COMANCHE PEAK STEAM ELECTRIC STATION j UNITS 1 AND 2 t
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TEIAS UTILITIES GENERATING COMPANT
{ A DIVISION OF TEIAS UTILITIES ELECTRIC COMPANT -
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-a Revision: 1 TABLE OF CONTENTS I. INTRODUCTION II. PROGRAM PLAN OBJECTIVES e
III. PROGRAM PLAN PRINCIPLES .
. IV. PROGRAM ORGANIZATICN AND PUNCTIONAL RESPONSIBILITIES Y. PROGRAM PROCESS e
!* VI. PROGRAM OUTPUTS i i.
l VII. PROGRAM QUALITY ASSURANCE i
VIII. PRCCRAM RECORDS
- II. SCHEDULE
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ATTACHMENT 1: CPRT ORGANIZATION CHART j ATTACHMENT 2: ACTION PLAN FORMAT AITACHMEET 3: ACTION PLAN RESULTS REPORT PORMAT ATTACHMENT 4:
SUMMARY
OF PROGRAM PROCESS APPENDII A: ISSUE - SPECIPIC ACTION PLANS f
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l Rev. Description Prepared by Date Approved by Date
{~ Program Manager Senior Review .
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[ Comanche Peak Steam Electric Station Consuche Peak Response Team Program Plan 3
I. INTRODUCTION -
j The Nuclear Regulatory Commission (NRC) established a l Technical Review Team (TRT) t ' o review cartain aspe.ts of the Comanche Peak Steam Electric Station (CPSEC). The purpose of
. the TRT is to evaluate certain technical issues and l allegations of improper construction practices at CPSES. In July, 1984, the TRT began onsite activities as part of its review plan using a team divided into five groups:
electrical / instrumentation, civil / mechanical, QA/QC, prdtective coatings, and test programs.
On September 18, 1984, a public meeting was held in the NRC's i
offices in Bethesda, Maryland, at which NRC management and the TRT presented Texas Utilities Electric Company (TUEC) with a request for additional information. This request was based on the results of the TRT efforts to da.te in the electrical /
instrumentation, civil, and testing program areas. The TRT i stated that they required additional information in order to
! make a determination of the safety significance of certain i- concerns.
l The TRT request for information was documented in an
[ attschment to an NRC 1stter dated September 18, 1984. The b request was divided into three primary areas and several g sub-areas, each representing a subject of concern to the TRT.
TUIC developed a Program Plan and individual Action Plans for j such of the issues identified in the September 18, 1984, 7 letter. The Program Plan and the Issue-Specific Action Plans j were submitted to the NRC by letter dated October 8, 1984.
4 Subsequently, public meetings were held at the NRC's Bethesda, 1- -
Maryland, offices on October 19 and 23 at which TUEC made J verbal presentations of the Program Plan and the Action Plans,
!. obtained verbal NRC comments, and provided clarifications by
. answering questions.
@ As a result of the meetings with the NRC, TUIC has revised the
) Program Plan and is in the process of revising the
{ Issue-Specific Action Plans. These revisions reflect 1 consideration of the REC's couments and observations, f clarifications needed to respond'to questions that were raised, and experience gained during the initial stages of
, implementation'of the original version of the Program Plan and if the Action Plans. '
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l The overall Program Plan, as revised, is presented below. The 0, revised' Issue-Specific Action Plans will be provided in a
- j. future revision co Appendix,A. Similar Issue-Specific Action 4 -
Plans will be developed to respond to any additional TRT
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issues identified to TUIC in the future.
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- II. PROGRAM PLAN OBJECTIVES -
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TUEC continues to be comeitted to the safe, reliable, and efficient design, construction, and operation of CPSES and 1 will cooperate fully with the NRC and its TRT to resolve the l, identified issues. The Program Plan described in this document is intended to establish a framework for responding i to the TRT's requests for additional information and to assist in,dispositioning the associated issues. Where necessary, corrective action will be taken. Appropriate action will also be taken to preclude similar deficiencias from occurring in the future. Therefore, the objectives of the Program Plan are
, to:
Evaluate and respond to the issues raised by the TRT Identify the root cause and evaluate the generic l implications of identified deficiencies l l -
Evaluate the collective significance of identified j deficiencies Define necessary corrective actions for identified deficiencias j -
Define steps necessary to preclude similar occurrences in l j the future l l
i i, III. PROGRAM PLAN PRINCIPLIS i
- i. To ensure that the Program Plan objectives are met, the 1 program was developed using the following principles:
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- , A. Thoroush Reviews a
The NRC's September 18, 1984, letter and its attachment identified specific :equests for additional information and provided specific examples of potentia?. deficiencies.
.It is recognized that the specific examples identified by the NRC-TRT may be representative of an underlying concern. 'Accordingly, each of these issues will.be
, thoroughly evaluated, even if a preliminary assessment of the specific examples indicates that they have no safety significance. .
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The NRC-TRT used sampling techniques in the performance of its reviews. In some cases it will be appropriate to expand the size of the sample to explore the issues j} identified by the NRC-TRT acre thoroughly. This will enable TUEC to obtain~a acre complete understanding of l'
root causes, potential generic implications, and safety significance of any identified deficiencies and to
,, achieve a higher degree of confidence in the Program Plan results.
" Some of the issues identified by the NRC-TRT are directly
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, related to similar questions currently before the j Comanche Peak Atomic Safety and Licensing Hearing Board j *
(ASLB). For those instances where TUEC is aware of 1 additional information that has been presented to the 3 , Board (or matters raised directly by the Board) and that A -
is directly relevant to an issue identified by the d NRC-TRT, the Iseue-Specific Action Plans will j ,
appropriately include consideration of such information.
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Root Cause Determinations
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Root causes will be determined for each issue identified by the NRC-TRT and for all valid deficiencies identified by the NRC-TRT or by TUEC. Such determinations will p enable TUEC to identify potential generic implications, j
to establish appropriate expanded scopes of review, and to define appropriate corrective actions.
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)' In some cases, preliminry determinations of root causes can be made during the development of the Issue-Specific
] Action ~ Plans and, where appropriate,' reflected in an
)
Lt expanded scope of review in an Issue-Specific Action il Plan. ,However, in most cases, the root causes of j potential or actual deficiencies cannot be famediately j
determined. The Issue-Specific Action Plans are being developed to include tasks that are intended to identify
- root causes of identified deficiencies. These tasks are oriented both at specific testing of initial root cause j
hypothesis as well as more general exploratory efforts j 0 that will lead to new root cause hypothesis. The Action 1 Plans will provide a description of the iterative actions 1 and alternatives used to identify root causes.
I f It is recognized that tha determinations of root cruses I any result in a need for changes to the Issue-Specific Action Plans. The Action Plans will be structured to eliminate .the need for unnecessary revisions. TUEC will it strive to identify the root causes conclusively as soon er
] possible for each Issue-Specific Action Plan.
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) Generic Implications Evaluations u C.
-i
? At such time as the root causes of identified I '
deficiencies have been determined, an evaluation will be j performed to identify any associated potential generic j implications. Such evaluations will enable TUEC to
- i determine whether the deficiencies represent isolated d occurrences, non-isolated or generic weaknesses within a particular area, or generic weaknesses that are programmatic in nature.
The results of such evaluations, in conjunction with an
, assessment of the safety-significance of the deficiencies
'; and weaknesses, will enable TUIC to define appropriate expanded scopes of review and to identify appropriate corrective actions.
N D. Safety Significance Evaluations The safety-significance of identified deficiencies, both specific and generic / programmatic, will be evaluatsd to facilitate the definition of the scope of appropriate expanded reviews and the definition of appropriate corrective action.
i E. Collective Sinnificance Evaluation The Collective Significance Evaluation will focus on the integrated impact of the identified deficiencies, both
,' specific and generic / programmatic, on the CPSES project.
g This evaluation will be based primarily on the information developed through the root cause determinations, generic implications evaluations, and safety significancu evaluations. It will include a determination as to whether the existence of multiple,
. apparently isolated and relatively minor deficiencies j
indicates a cosmon shortcoming in the programs and procedures applicable to the CPSES project. It will also 3 , identify " lessons learned" as they apply to future 3 - -
activities at CPSES Units 1 and 2.
i; H
j F. Corrective Actions 4 ;
Appropriate corrective actions will be defined and i
implemented to resolve all specific deficiencies identified by the NRC-TRT and by TUIC during the course of this review and evaluation program.
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I In addition to corrective actions designed to resolve 4 specific deficiencies, actions will be identified to prevent the future occurrence of similar deficiencies at CPSES Units 1 and 2. Such actions will be developed p -
using the results of the evaluations of root causes, generic implications, and collective significance.
. . Accordingly, the focus of these corrective actions will
, be to resolve actual or potential weaknesses that are j generic or programmatic' in nature.
i: -
).
G. Objectivity .
! The Program Plan submitted to the NRC staff by TUIC on i October 8, 1984, included a number of features that were 1* intended to provide assurance regarding the objectivity i ', of the Program. Nonetheless, during subsequent public j meetings with the NRC staff, it became apparent that it
] would be necessary to incorporate additional features to i further ensure the objectivity and credibility of the i Program. Accordingly, additional programmatic features j have been implemented to ensure that the Program is conducted in such a manner that its objectivity and '
credibility will be beyond question.
. As described in Section IV, the CPRT Program Organization includes a substantial number of participants in key
! decision-making positions who are affiliated with j organizations external to TUIC. Three of the six members
! of the Senior Review Team and all five Review Team Leaders are experienced nuclear-industry consultants who have not been previously involved with the CPSES activities that they will now be reviewing. The Review Team Leaders, subject to Senior Review Team review and approval, have the authority and respons_ibility to establish the scope and content of the Issue-Specific
]ip Action Plans and to determine how and by whom the Issue-Specific Action Plans will be implemented. The
. members of the SRT and the Review Team Leaders have access to all plant areas, documentation, calculations, j files, and personnel as they deem necessary to meet the Program Objectives. .
i The Senior Review Team has established the following
. guidelines with respect to the objectivity in implementation of the Action Plans:
Analyses and calculations either will be pe.rformed L by an organization not previously responsible for E the technical subject area for the CPSES project g an engineering design verification of the L
analysis / calculation will be performed by a -
third-party organization.
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Revision: 1 f . . Page 6 of 17 i
t Inspections either will be performed by qualified
. inspectors not previously affiliated with the CPSES project and not currently affiliated with TUEC or -
, its principal contractors for the CPSES project E the inspections will be performed by qualified j inspectors who were not personally involved in the j inspection activities in question and an inspection validation program will be conducted on a sampling .
basis by third-party inspection personnel, j -
Selection of personnel for, inspection activities will be mutually agreed upon by the responsible j -
Review Team Leader and the Review Team Leader for the QA/QC area.
.i .
- Records reviews and evaluations either will be performed by third-party personnel g by CPSES
, project personnel with a third-party validation on a sampling basis.
Testing and NDE activities (other than preoperational testing) will be corducted and test' results will be certified by third-party personnel.
H. Personnel Qualifications /Trainins
- Issue-3pecific Action Plan implementation activities (such as analyses, inspections, records reviews, and j testing) will be performed by personnel selected by the h
d Review Team Leaders on the basis of technical competence and subject to the objectivity guidelines noted above.
. . (For Action Plan activities performed prior to the N .
adoption of Revision 1 of the Program Plan, each Reviev li Team Leader will determine the acceptability of that work C relative to the additional objectivity and other
'4
. requirements contained in Revision 1.) Where applicable.
L such personnel will also receive training on the p* procedures to be utilized and will be qualified / certified j in accordance with the existing CPSES QA Program j provisions.
i . .
j I. Samplins
.t ij Issue-Specific Action Plan implementation activities may faciude the use of sempling techniques. The bases for j- using sampling and the sampling method will be
'j . documente.d in each Issue-Specific Action Plan when sampling is used. ,
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Samples will be randomly selected from populations or subpopulations of concern (e.g. of concern to
, safety) for the purpose of identifying the existence and/or the extent of potential deficiencies.
MIL-STD 105D or other appropriate procedures, will be used to determine sample. size. Sampling programs i will be designed to include a limiting quality of 5 l
percent with an acceptance probability of 0.05 (i.e.
j at least 95% of the popu'Istion is in conformance
- j. with the acceptance criteria at the 95% confidence-
,1 level). .
Acceptance / rejection criteria will be explicitly
- ] , i defined.
H Mr. John Reed of Jack Benjamin & Associates will be used f as a third-party engineering statistics consultant to
<! provide an objective evaluation of the adequacy of the j design of each sampling program and to ensure consistency in the interpretation of results.
9 4
, J. Records and Quality Assurance o
The Program Plan requires that the activities performed in accordance with each Action Plan be documented appropriately along with the ra.1.alts of the Action Plan.
The resulting records will be maintained in auditsble y form.
l; Action Plan activities that otherwise would be subject to
( the CPSES QA program shall be performed in accordance with the applicable portions of ,that program.
ll ij Utilizing the general principles presented above, revised Issue-Specific Action Plans are being developed for each issue l1 identified in the September- 18, 1984,. letter with '
C consideration given to cosments received at the October 18 and i' 23 meetings. These revised Action Plans v111 be provided as a
- j. revision to Appendix A of this document. Similar j Issue-Specific Action Plans will be developed to respond to lj TRT questions in the mechanical, QA/QC, and protective 1
q coatings areas when they are identified to TUEC.
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s Page 8 of 17 IV. PROGRAM ORGANIZATION AND PUNCTIONAL RESPONSIBILITIES A. Introduction f .
The organization established by TUEC to develop and 3 implement this Program Plan has been designated as the
] Comanche Peak Response Team (CPRT). A chart depicting i the organizational structure and principal members of the CPRT is presented as Attachment 1. The personnel assignments to this project reflect the importance that 1
TUIC has attributed to its successful conduct and i completion.
f.- .
f . B. Team Members - Roles and Responsibilities I.
- 1. Senior Review Team
- t' l A Senior Review Team, consisting of senior TUCCO 4j line managers and senior nuclear-industry consultants, has been established with overall responsibility for the development, implementation, i, and management of the CPRT Program.
\
, The Senior Review Team (SRT) for the CPRT Program
+
consists of the following members:
! / r. MLou F. Fikar, Executive Vice-President, Engineering, TUGC0 Mr. Billy R. Clements, Vice-President, Nuclear
! O
+ \ perations. TUCCO l
) , > Mr. John W. Beck, Manager, Nuclear Licensing, j <
TUCCO e .
] [ \ Mr. John C. Guibert, Consultant; Manager, Nuclear Safety & Licensing, TERA Corporation p
b Mr. Anthony R. Buhl, Consultant; President, Energx Corporation V Mr. John L. French, Consultant; Vice-President, i .
Delian Corporation 1
] The specific responsibilities of the' Senior Review
( Team include the following:
a
'1 Development of the CPRT Program Plan, and any subsequent revisions thereof Establishment of CPRT Program standards for personnel qualifications and objectivity e
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, Page 9 of 17 l, 1 Assignment of CPRT Program Review Team Leaders
[V l
Review and approval of Issue-Specific Action )
Plans, and any subsequent revisions thereof !
i '
4 -
Rasuring that necessary resources are provided j to support the successful implementation of the CPRT Program A .
i -
EEsuring that " root cause" and " generic
}. implications" evaluations are conducted as soon as possible for each issue identified by the
. TRT i
j -
Review and approval of " root cause" determinations and " generic implications" l) , , assessments, including evaluations of the j -
adequacy of the Action Plans to address these d
matters l
Monitoring the status of the implementation of j the Issue-Specific Action Plans Review and approval of the Issue-Specific i
Action Plan Results Reports Review and approval of the Collective i Significance Ivaluation Report f
Advising the President of TUCCO regarding the g adequacy and status of the implementation of
{ the CPRT Program I
i Mr. Pikar is chairman of the SRT. The SRT chairman j .
has assigned additional responsibilities to certain t,c SRT members. Mr. Beck will serve as the principal j interface with the NRC staff's TRT Program Director H , for CPRT/TRT matters. Mr. Guibert will be 1 responsible for the development of the Collective H* Significance Evaluation Report.
ll li
- l. 2. Senior Review Team Support Group I; -
In order to assist the SRT in the execution of its responsibili*:ies, an SRT Support Group has been established. The functions of the SRT Support Group fall within the two general categories of project coordination and project administration and include the following' specific activities:
}* ,- Assisting the Review Team Leaders in obtai.ning j access to CPSES project personnel, project q '
documentation, and project, physical spaces
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- iProviding necessary on-site clerical and
[- ' administrative support to the SRT and to the i
Review Team Leaders
! - Maintaining the CPRT Project Central File 1
Developing programmatic procedures and j guidelines at the request and for the approval g
of the SRT Assisting the SRT in monitoring the t
implementation schedules for the Issue-Specific
, Action Plans Other support functions as assigned by the SRT
- t. 3. Review Team Leaders Review Team Leaders have been assigned to develop and manage the implementation of the Issue-Specific Action Plans within each of the six general areas evaluated by the NRC's TRT. Each of the Review Tema Leaders is a member of an organization external to TUEC.
Review-Team Leaders were selected by the Senior Review Team using the following criteria:
Knowledge and experience in quality assurance, nuclear safety, and the review area subject matter, as appropriate.
j -
Managerial competence based on experience in managing technical projects and reviews t,
- ! - Integrity of both the individuals and the
! organizations with which they are affiliated 1 based upon their reputation and standing within ,
,8
- the nuclear industry l
L - Objectivity of both the individuals and the (j , organizations with which they are affiliated 1 based upon their demonstrated capability and
] reputation for providing objective, dispassionate technical judgements on the basis
(
of technical merit.
1 1
Objectivity of both'the individuals and the
. organizations with which they are affiliated
' based upon the lack of previous involvement in l the CPSES project activities in question b .
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Revision: 1 l
. , Page 11 of 17 1 1 f The specific Review Team Leader assignments are as I
l follows:
1 I
i
' ,/ Mr. Howard A. Levin; Manager, Engineering,- TERI. -
Corporation; Review Team Leader for the Civil, Structural, and Mechanical Areas Mr. John L. Hansel; Director, Energy & Environmental Science Division. Evaluation Research Corporation; Review Team Leader for the Quality Assurance / Quality :
Control Area j .
\/ Mr. Martin B. Jones, Jr.; Private Consultant; Review i Team Leader for the Electrical / Instrumentation Area j
}., Mr. E. P. Stroupe; Director, Technical Services
. t Division. Technology for Energy Corporation; Review I
Team Leader for the Protective Coatings Arna h
Mr. Monte J. Wise; President, Wise & Associates; Review Team Leader for the Testing Programa Area The specific responsibilities of the Review Team Leaders include the following:
Serving as the principal interface with the NRC-TRT Leaders in their respective areas for the purpose of
- ensuring that additional clarifying information is j obtained (where necessary), for obtaining feedback.
on the adequacy of Action Plans within their area, and for ensuring that responses to NRC questions
.i regarding implementation of Actio'n Plans within j their area are provided Development of the Issue-Specific Action Plans j within their area, and any subsequent revisions j thereof, using the format and content guidelines set 3 forth in Attachment 2 a-'
Ensuring that personnel implementing the Action Plans (including personnel performing validations or design verifications described in Section III.G.
j . above) within their area meet CPRT Program standards for personnel qualifications a. ' objectivity
- Assignment of Issus Coordinators Identifying and obtaining necessary resources to implement the Action Plans within their area Ensuring that the Action Plans within their area are 4
being,fsplemented appropriately Providing periodic status reports to the Senior ,
Review Team on the implementation of the Issue-Specific Action Plans within their area e
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. Revision: 1 Page 12 of 17 Determining " root causes" and " generic implications" of identified deficiencies within their area;
, ensuring that these determinations are adequately addressed in the associated Action Plans g ensuring
- that the Action Plans are appropriately revised Identifying and defining corrective actions for any identified deficiencies within their ares Identifying and defining necessary actions to l preclude occurrence of similar deficiencies in the l future
[ -
Developing Issue-Specific Action Plan Results Reports, using the format and content guidelines set forth in Attachment 3 1, -
Maintaining a Project Working File for each Action Plan within their ares I -
Transferring Project Working Files to the Project i Central File at such time that each Action Plan is completed (i.e.. Action Plan Results Report reviewed and approved by the Senior Review Team) 1
- 4. Issue Coordinators In order to assist the Review Team Leaders in j implementing the Issue-5pecific Action Plans within j their area, they have been au,thorized to assign Issue Coordinators for each of their specific Action Plans. Re~few Team Leaders also have the option of assigning themselvee : Isen* Coordinator for some or all of the Action Plans within their asse.
l The criteria for selection of Issue Coordinators is essentially the same as that for selection of Review
]
Team Leaders. In cases where an Issue Coordinator has had some degree of previous involvement in the CPSRS project activities in question, specific provisions will be established in the Action Plan to
, ensure that the objectivity guidelines of Section I
III.G are set.
Issua Coordinators are responsible for assisting the Eawiew Tama Leaders is Issee-5pecific activities as directed by the Review Team Leaders.
8 1 e S
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, , Fase 13 of 17 Y. FROGRAM PROCESS The overa12 process for the development and implemencation of this Program Plan and its associated individual Action Flans l was presented, to a large extent, in the proceeding sections. I A summary of the key elements of the overall program process is presented in Attachment 4.
Additional information related to the process for developing -
Issue-Specific Action Plans is presented in Attachment 2.
- While each Action Plan is unique, the programmatic guidelines
, set forth in Attachment 2 and the Action Flan review and approval process ensure that each Action Plan is developed and implemented in a manner that meets the Program Flan Objectives
(
- and the Program Plan Principles. Each Action Plan includes a l f
description, where applicable, of the following l scope and methodology l .' -
identification of procedures and checklists
- i
- participating personnel t
l qualifications of participet.ing personnel
) -
training of participating personnel l
- sempling plan l l.
- relevant standards applicable acceptance criteria, and j
- applicable decision criteria.
Additional information related to the process for developing Issue-Specific Action Plan Results Reports is presented in l Attachment 3. The programmatic guidelines set forth in l
Attachment 3 and the Results Report review and approval ,!
l process ensure that the following subjects are adequately addressed where appropriate during the implementation of the
. Action Plan: ]
I -
identification of root causes of identified deficiencies, '
an evaluation of the safety significance of any identified deficiencies, a determination regarding potential generic implications
- and a description of how they were addressed, identification of necessary corrective actions to resolve identified deficiencies.-
1 -
identification of necessary action to preclude recurrence
. in the future.
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To the maximum extent possible, the scope of the
?
Issue-Specific Action F1sas will be based on a preliminary l- assessment of the root cause and potential generic implications of the identified deficiencies. Action Plans will be sufficiently broad to identify and assess root causes, i
generic implications, and safety significance. Accordingly, most of the Issue-Specific Action Plans will utilize iterative or phased implementation approaches that include an initial phase which is exploratory in nature. Conclusive '
determi itions of root causes and potential generic implicatuns will be made as soon as possible. Determinations with respect to the safety significance of identified or
. potential deficiencies will also be reached. The adequacy of the scope of the associated Issue-Specific Action Plans will be reassessed in light of these determinations. If an Action
, Plan is determined not to be sufficiently broad to meet program requirements, it will be appropriately revised and new Action Plans may be developed (if appropriate) to ensure that
,. the potential generic implications of identified deficiencies i .
are properly investigated and addressed.
VI. PROGRAM OUTFUTS The principal outputs of the CFRT Program will be the Action Plan Results Reports. The format and content to be utilised in the development of these Reports is presented in Attachment
- 3. Specific conclusions will be reached regarding root cause, safety significance, and generic implications. Necessary corrective actions will be identified to resolve deficiencies, including any corrective actions necessary to preclude recurrence of similar deficiencies in the future.
An additional report documenting the results of the Collective
[ Significance Evaluation will be developed. This report will, I in large measure, be based upon an integrated assessment of the Action Plan Results Reports. The principal focus of this
- evaluation will be to identify additional pregrasmatic ,
" lessons learned" which should be reflected in future project-related activities for both Comanche Peak Unit i and Comanche Peak Unit 2.
) . At the conclusion of the CFRT Program, a Final Report summarising the results and conclusions of the Program will be submitted to the NRC. Interim status reports or briefings 4
, will be provided to the NBC staff as requested.
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. . Page 15 of 17
[ VII. PROGRAM QUALITY ASSURANCR t
t Activities associated with the implementation of individual Action Plans will be conducted within the framewJrk of the existing CPSRS QA Program. Existing procedures, revised or supplemented as necessary to address special requirements, will be used to perform reassessment activities, reinspection activities, and rework activities performed by engineering, construction, and QA/QC personnel.
- I I VIII. PROGRAM RICORDS In order to ensure that an auditable record of the CPRT Program is available, the documentation described below will be developed and maintained.
A. Project Central Pile f
The Project Central Pile will be maintained by the SRT Support Group. At the completion of the CPRT Program, it I
will contain all project documentation, including the Project Working Piles maintained by the Review Team Leaders during the conduct of the Program. During the conduct of the Program, the Project Central Pile will
, contain the following asterials A copy of the Program Plan submitted to the NRC and
- any subsequent revisions thereof
- A copy of the individual Action Plans submitted to the NRC and any subsequent revisions thereof I
l A copy of the individual Action Plan Results Reports l L -
A copy of the individual Action Plan Working Pile for all Action Plans which have been complaced (i.e., Action Plan Results Reports reviewed and 1
- spyroved by the Senior Review Team).
i B. Project Workins Piles Project Working Piles will be maintained by the Review
, Team Leaders for each Action Plan under their cognizance until such time as the Act1on Plan has been completed.
j At that time, the Project Werking File for the completed U
Action Plan will be treneferred to the Project Central Pile. The specific material contained in each Project Working Pile will vary, depending upon the nature of the i
associated Action Plan; where applicable, it will
, contain, at a ainimum, the following materials t-t :
1- .
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. Revision: 1
.. Page 16 of 17 l -
Copies of letters, memoranda or reports documenting n the results of analysis performed as part of the
[ Action Flan, including any associated documentation i related to the evaluation of such results.
I '
Copies of letters, memoranda, or reports documenting the results of testing performed as part of the Action Plan, including any* associated documentation
. related to the evaluation of such results.
( - Copies of procedures or checklists used in the performance of testing.
Copies of letters, memoranda, reports, drawings or other means of documenting the results of l , inspections performed as part of the Action Flan,
, including any associated documentation related to l the evaluation of such results.
Copies of procedures or checklists utilized in the
( performance of inspections.
Copies of letters, memoranda, or reports documenting the results of record reviews performed as part of the Action Plan, including any associated documentation related to the evaluation of such results.
Copies of procedures or checklists utilized in the performance of record reviews.
?
)
A record of personnel qualifications and a record of
- . training for personnel participating in the j implementation of the Action Flan.
i 1-r II. SCHEDULE -
I e
i At the present time, it is impractical to accurately estimate I* the schedule for completion of the entire CFRT Program. This f is primarily due to two elements of uncertainty:
l L. -
Several of the Action Plans utilize a phased approach for j -
resolution, consequently the full scope of the necessary
- review effort cannot be determined until preliminary results j become available; and The lif questione in the areas of mechanical, QA/QC, and ,
protective coatings have not yet been provided to TUEC, consequently the nature of the Action Plan activities j necessary to respond to these questions (and their
{ ,
associated schedule) cannot be determined until a later 1, .
date.
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$ The Action Plans presented in Appendix A address, to the
- ' extent practicable at the present time, the current status and l projected schedules for completion of selected elements of the t individual Action Plans and, in a few cases, the schedule for completion of the entire Action Plan. As additional information becomes available regarding projected completion l , schedules for individual Action Plans and for the entire CPRT Program, it will be provided to the NRC staff.
TURC is committed to a thorough and complete review of the
- safety-related issues identified by the TRT. A satisfactory l resolution of these issues which potentially affect'the safe
, operation of the Comanche Peak Units takes precedence over schedule concerns.
I I
5
- As the implementation of the CPRT Program proceeds and after the additional TRT questions have been received and additional
- Ac' tion Plans have been developed to address them. TUEC intends to perform an evaluation to determine, at that time, whether a
, safety basis exists to support authorization for fuel loading 1.
and procritical testing at Comanche Peak Unit 1 prior to the completion of the entire CPRT Program. TUEC will inform the NRC staff of the results of this evaluation.
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COMANCHE PEAK RESPONSE TEAM .
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TUSCO PRESIDENT i .
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- L. F. FlK AR .
' E.R.CLEMENTS A W. BECK >
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! ELECTRICAL # CIVIL # MECK PROTECTIVE COATING GA#0C TESTHIS PROGRAMS l HISTR. LEADER LEADER , LEADER LEADER LE ADER M.S. JONES H. A. LEVIN E. P. STR0uPE J. L. H A NS EL M.A W6SE I-I m
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ATTACHMENT I REVIsl0N l i
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- k. .
S i
f ATTACIDOMT 2 g ACTION PLAN FORMAT l
1rru Naxart r
(Short Title) .
- 1. Description of Issue Identified by NRC
-Verbatim statement of the'TRT issue as stated in the f
, e enclosure to the NRC issue transmitted' letter j
-Develop a separate Action Plan for each numbered TRT item l
- j. 2. Action Identified by NRC ,
i *
-Verbatim statement of NRC - directed action as stated in the 6
u enclosure.to the NRC issue transmitted letter
- 3. Background
-Reisvant information which clarifies the issue definition
-Relevant information to provide additional perspective and understanding of the issue (including consideration of relevant information before the ASLB) 3
[I -An explanation (where applicable) of why TUEC has decided to 1 pursue the approach described under Section 4.0 below, where alternative approaches were available
-If possible, a statement regarding the preliminary
] ,
determination of root cause and potential generic implications J of identified deficiencies ,
P .
L.I 4. TUIC Action Plan N
]* -Scope and Methodology ,
1
[ -Describe approach (phased, if applicable)
]*
j_ -tasks to be performed without conditions l
-tasks to be performed under certain conditions (e.g.,
f "If we find "x", then we will take the following additional action...")
K -tasks to be performed as part of an expanded review g (where applicable and where this has already been l
determined) .
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-describe how potential generic implications are being 0
considered (where applicable and where this has already p ,
been determined)
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-Procedure (s) to be used -
-reference existing procedures
, -describe any new or revised procedures
-Participant's Roles and Responsibilities
-which organizations are involved j -scope for och organization
]11
-identify lead individual
- \
-Qualifications of Personnel
, -state qualifications of personnel implementing the
- ]4 -
Action Plan '
-reference these qualifications to suisting requirements j -discuss training of personnel which will be
- conducted
] , -Sampling Plan
-if performing a 100% review, state that a 100%
review is being done
-if sampling is used, provide information relevant to the sampling plan, and provide justification for the sample size
-Describe any other features of the sampling plan (e.g. random sampling of the universe, random '
sampling of each discipline, etc.)
J -Provide the definition of a " reject"
-Standards / Acceptance Criteria
. -describe the standards (e.g. , FSAR, IEEE, Reg. l Guides, etc.) against which you are performing the
, review -
-Decision Critaria
-describe the criteria to be used for going to the
-next. phase of a phased-approach review or for
- expanding the sample size for a review using sampling techniques-
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-Describe the criteria for closing out this item q (this is rtlated to the standards / acceptance
,; criteria sad the criteria for subsequent phases)
- 5. ,
Schedule / Status
, Describe schedule and current status, to the extent possible. Reference the schedule to the phases where appropriate. If a schedule for a phase cannot be 1
provided inntil , additional information is obtained, state that a schedule will be developed at the completien of the previous phase.
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. ATTACHMENT 3 1
ACTION PLAN RESUI.TS REPORT PORMAT j ITEM NUMBER i
, (Short Title)
.! 1. Description of Issue Identified by NRC
' I. (same as Action Plan) j 2. Action Identified by NRC j , (same as AEtion Plan)
- 3. Background (same as Action Plan)
- 4. TUEC Action Plan
-Scope and Methodology
-Same as Action Plan except:
T
-where conditional phases were implemented, reword the conditional statement so that it is clear that the phase had been implemented
-where a conditional phase was" determined not to be necessary, state that it was not needed and provide a reference to a subsequent part of the report which justifies the decision not to implement the conditional
.: Phase A
1 -describe any other substantive changes to the Action j Plan and why the changes were necessary
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- 5. Discussion of Results
, -Comparison of results against standards / acceptance j criteria
-Comparison of results against decision criteria t
-Discussion of correctiva actions for any identified deficiencies (e.g., any'reinspections, rework.
reanalysis,. etc.)
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'6. Conclusions .
-Identification of root cause of any deficiencies n -
l -Evaluation of safety significance of identified
.l deficiencias 4
- -Evaluation of generic implications
-where applicable, describe expanded scope of review to address them j -demonstrate linkage to the root cause
-where applicable, describe basis for conclusion that no-
. generic implications exist
'7.
. Ongoing Activities 2
-Describe any activities still in progress l
-State whether these on-going activities have safety significance .
-State schedule for completing activities. State what'uer the work must ba completed by fuel load, initial criticality, or
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rower above 5%.
I 8. Action to Preclude Occurrence in the Future j -Training, Procedural changes, etc.
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.s ATTAC1 DENT 4 .
SIDWARY OF PROGRAM PROCESS I 1. . Receipt of NRC-TRT request for additional information.
, 2. Preliminary review of issue by Senior Review Team and j appropriate Review Team Leader.
.1
? 3. Review Team Leader obtain additional, clarifying j information from NRC-TRT to ensure full undarstanding of j the concern (if necessary).
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I 4. Review Team Leader make aJpreliminary determination of
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root cause and potential generic implications of f identified deficiencies (if possible) s 3
- 5. Review Team Leader develop Action Plan to resolve concern j using guidance provided in Attachment 2.
4
- 6. Action Plan approved by Senior Review Team.'
l 7. Review Team Leader implement Action Plan.*
- 8. Review Team Leader make a' conclusive determination of
! root cause and potential generic implications of identified deficiencies.
2
- 9. Review Team Leader obtain concurrence of Senior Reviev Team in root cause definition and potential generic j implications assessment.
- 10. Review Team Leader develop revised Action Plan to reflect the conclusive determination of root cause and potential generic implications (if applicable).
- 11. Revised Action Plan approved by Senior Review Team (if applicable).
l
- 12. Review Team Leader implement Revised Action Plan (if n . applicable).*
- 13. Review Team Leader define necessary corrective action for identified deficiencies (if applicable).
- 14. . Review Team Leader define necessary corrective action to prevent recurrence of similar deficiencies in the future
,(if applicable).
- 15. Review Team Leader develop Action Plan Results Report j using guidance provided in Attachment 3.
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- 16. Action Plan Results Report approved by Senior Review Team.. .
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- 17. 'SRT assese Action Plan Results Report as part of Collective Significance Evaluaeion.
- 18. SRT define necessary corrective actions stemming from the Collective Significance Evaluation j 19. Submit Final Report to NRC, including implementation schedule for necessary corrective actions.
li 20., TUEC implement necessary corrective action.
.. ,
- Action Plans and revised Action Plans will be submitted l to the NRC staff for review and comment at the time they have been approved by the SRT; however, implementation of
- Action Plans will not be delayed pending receipt of NRC staff comments. Any necessary changes to Action Plans resulting from NRC review and comments will be incorporated expeditiously.
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January 14, 1985 TXX-4393 Mr. Richard L. Bangart, Director Region IV Comanche Peak Task Force U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket No.: 50-445 Arlington, TX 76011 COMANCHE PEAK STEAM ELECTRIC STATION ADDITIONAL RESPONSE TO NRC fl0TICE OF VIOLATION INSPECTION REPORT NO. 84-16 FILE NO.: 10130
Dear Mr. Bangart:
In our initial response to this Notice of Violation (B.R. Clements to R.L. Bangart, November 1, 1984, TXX-4346), we stated that we had commenced an evaluation to address the generic implications, if any, of this Item of Noncompliance on Unit 1 Cable Tray Hangers (CTH's) and that we anticipated completing this evaluation by November 30, 1984.
On November 28, 1984, we provided an additional response on this issue (B.R.
Clements to R.L. Bangart, TXX-4369) in which we indicated our actions to perform field walkdowns of CTH's in Unit 1 and evaluate the results of these inspections had been initiated with anticipated completion of this activity by January 15, 1985.
To resolve this issue, we have established a CTH Unit 1 Special Analysis Group consisting of TUGCO, Gibbs & Hill, and Ebasco personnel with personnel from Evaluation Research Corporation providing an independent inspection activity.
The procedures / instructions under which this analysis group will operate have been issued and personnel have been certified to perform the required inspections.
Drawings generated for use during the inspection process are virtually complete.
Currently, we are finalizing the remaining details of our overall plan. The completed action plan will be available for your review by January 21, 1985.
F01A-85-59 V l2I w-porn
- 4 . - . . . .. .-.. .. . . -
0 TXX-4393 1/14/85 Page 2 It is expected that all inspections of these CTH's will be completed by early February, 1985, and final analysis results will be available by mid-February, 1985.
Very truly yours, j0 s ,-
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Director, Inspection & Enforcement (15 copies)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. V.S. floonan 1
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! o NUCLEAR REGULATORY COMMISSION p 5 E WASHINGTON, D. C. 20555 i UY
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Docket Mo.: 50-445 and 50-446 JAN 2 41985
- MEMORANDUM FOR: Hazel I. Smith -
i Technical and Operations Support Branch j Planning and Program Analysis Staff, NRR FROM: Vincent S. Noonan, Project Director Comanche Peak Task Force Division of Licensing, NRR I
i
SUBJECT:
FOIA-84-778 The subject of FOIA-84-778 is being investigated through allegations raised in this area by the Comanche Peak (CP) Technical Review Team (TRT) Quality j Assurance / Quality Control (QA/QC) group. I forwarded the request to Mr. H.
i Livermore, Team Leader QA/QC, CP TRT, for review. Mr. H. Livermore has informed me that our review of allegations related to the subject request is still on
- going and the information is premature for disclosure. Therefore, I have deter-i mined that we cannot release the information we hold on this subject at this time (referencing exemption 7(a) and 5 of the FOIA Act). Enclosed is a list of
] documents which Mr. H. Livermore's QA/QC group holds which are not releasable at this time. The applicable exemption is identified after each document being withheld. Task force members are on notice by copy of this memorandum that the r
nonreleasable material is to remain in their working files in the event there is an appeal request or an adjudicatory action. Also listed are documents already in the POR on this subject which we are considering and documents which .
already exist in the public domain. Where we were unable to provide an j accession number for those documents in the PDR, we enclose the document.
f l Please note that when this information becomes eligible for release, some of j the requested information, if released, could be used to trace the identity of f'
allegers who have requested confidentiality.
/ j h S. Noo n, Project Director 3 omanche eak 4 Division of Licenting 4
$ cc: H; Livermore
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Enclosure:
As stated g w 2n A n K*lpY f' vvf'fe7 -
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- 1. 10/24/75 TUEC Drawing 2323-51-0560 and design change documents
.(approximately 80 pages). (ex. 7(a))
- 2. 11/4/77 TUEC Drawing WF8-00831 (14 pages).'(ex.,7(a))
- 3. Approximately 237 liner inspection travelers (approximately j 948 pages). (ex. 7(a)) .
4
] 4. 3/17/83 Nonconformance Report (NCR) 83-00795 (7 pages). (ex. 7(a'))
?
] 5. 8/29/84 Memo to 8. Scott from J. X. (unable to read) transmitting 26
.j Unit 2 Brown & Root inspection travelers signed by alleger 1 (A-3). (ex. 7(a))
)q 6. 8/31/84 Memo to B. Scott frca J. K. (unable to read) transmitting
{ 17 travellers signed by F. Evans (approximately 68 pages).
(ex. 7(a))
1 7. 9/13/84 Computer printout of records signed by alleger A-3 (41 pages).
.j _
(ex. 7(a))
- 8. 1/ 5 [84 Procedure QI-QP-11.14-6, Revision 6 (7 pages). (ex. 7(a))
i 9. 8/23/83 Procedure QI-QP-11.14-6, Revision 5 (6 pages). (ex. 7(a))
- 10. 6/17/83 Procedure QI-QP-11.14-6, Revision 4 (6 pages). (ex. 7(a))
- 11. 3/25'/83 Procedure QI-QP-11.14-6, Revision 3 (7 pages). (ex. 7(a))
?
~
n 12. 3/9/83 Procedure QI-QP-11.14-6, Revision 2 (7 pages). (ex. 7(a)) .
- 13. 9/8/82 Procedure QI-QP-11.14-6, Revision 1 (7 pages). (ex. 7(a))
- 14. 3/26/83 Procedure QI-QP-11.14-6, Revision 0 (4 pages). (ex. 7(a))
- 15. 12/26/70 Procedure QI-QAP-11.1-4, Revision 0 (7 pages). (ex. 7(a))
- 16. 8/24/78 Procedure QI-QAP-10.1-4, Revision 0 (3 pages)'. (ex. 7(a))
- 17. 1/5/84 Brown & Root Specification CCP-38, Revision 4 and j revision pages (19 pages). (ex. 7(a))
1 18. 5/11/79 Gibbs & Hill Specification 2323-SS-18, Revision 3 (33 pages).
(ex. 7(a)) -
_ 19. 8/28/84 Draft Safety Evaluation for Allegation AQ.55 and AQ-78, 9/17/84 Revisions 2 and 3 (39 pages). (ex. 5) 1 e
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I e 20. Undated Comanche Peak (CP) Allegations Chart, pages 2, 4, 8, and 9, summarizing allegations and source documents. (ex. 5) l 21. 3/7/84 Office of Investigation Report No.84-006, Interview of
} Alleger (A-4) (72 pages). (ex. 5) lr
( 22. Undated Affidavit of Alleger (A-3) (3 pages). (ex. 5)
- 23. Undated Interview of Alleger (A-3) pages 60-89. (ex. 5)
- 24. 1/10/79 Interoffice memo IM 16606 to delete CP-QCI-2.11-1 from QC manual i
(1 page). (ex. 7(a))
i 1/9/78
- 25. Instruction CP-CQI-2.11-1, Revision 0 (7 pages). (ex. 7(a))
l
- 26. Undated Technical Review Team (TRT) Action Plan (1 page). (ex. 5) 1 27 3/28/83 Pressure Test Data Sheet Spent Fuel Pool (1 page). (ex. 7(a))
29, 10/14/77 Drawings WRB-105559, 2323-SI-0560 plus 22 DCS's, WRB-00831
. (7 pages). (ex. 7(a))
i l 30. 7/16/84 Draft Safety Evaluation for Allegation AQ-78 (17 pages). (ex. 5) l
- 31. Undated TRT members rough notes (21 pages). (ex. 5) i i 32. 9/22/83 Procedure CP-CPM 6.3, Revision 10 (8 pages). (ex. 7(a))
l
- 33. 10/5/84 Note to R. Bargart (NRC) from S. Treby (NRC) re
- Reopening
- of Inspection Report 79-15 dated July 2, 1984 (29 pages).
(ex. 5)
] '
- 34. 5/11/79 Gibbs & Hill Specification 2323-SS-18 paragraph 8.1 (33 pages).
(ex. 7(a))
- 35. 7/14/77 Bostrom-Bergen Metal Product drawing job #2401, sheet 38, Code 7 (1 page). (ex. 7(a))
- 36. 6/11/84 Technical Review Team (TRT) Approach to Resolution (3 pages).
(ex. 5)
- 37. 7/14/77 Drawing Bostrom-Bergen 2401A (2 pages). (ex. 7(a))
- 38. 6/3/83 Nonconformance Reports M-767, M-6574, M6573 (3 pages).
(ex. 7(a))
- 39. 10/9/84 Draft Safety Evaluation Report for Allegations AQ-55 and AQ-78, Revision 5 (19 pages). (ex. 5)
- 40. 9/17/84 Interview with Witness "Y" by R. C. Tang, T. Curry, H. Livermore (22 pages). (ex. 5) 2
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- 41. Undated Alleger A-5 interview pages 19-23. (ex. 5) l l 42. 3/27/83 Memo to J. George (TUGCO) fron C. Randall re: Travelers q (2 pages). (ex. 7(a))
- 43. Undated TRT members field notes (2 pages). (cx. 5)
- 44. Undated Draft letter to M. Spence (TUGCO) from T. Ippolito (NRC) re: Travelers (2 pages). (ex. 5)
- 45. Revision pages to construction procedure number 35-1195-
, CCP-38 (12 pages). (ex. 7(a))
] 46. 9/13/84 Computer printout of jobs inspected by F. Evans (3 pages).
j (ex. 7(a))
l 47. 1/5/84 Procedure CCP-38, Revision 4, page 4 of 19. (ex. 7(a))
$ 48. 8/23/84 TRT members field notes for AQ-55 (1 page). (ex. 5)
- 49. 8/23/84 Interoffice Memo for Distribution (TUGCO) from J. Duncan 1 and M. Werner re: Stainless steel liner travellers (3 pages). (ex. 7(a))
- 50. 10/21/77 Procedure CCP-38 pages 6 and 16, Revision 1 (2 pages).
(ex. 7(a)) .
1 51. 9/11/84 TUGC0 memo TUQ-2340 on stainless steel liner travellers j (4 pages). (ex. 7(a))
4
- 52. 8/23/84 TRT members field notes (4 pages). (ex. 5) 53, 8/28/84 Draft Safety Evaluation Report for AQ-78 Draft 1 (11 pages).
-) (ex. 5)
- 54. Undated Personal notes on GAP information (1 page). (ex. 5)
Located in the Public Document Room Under Comanche Peak Docket Nos. 50-445
] and 50-446 [
1 j,
- 1. 9/10-9/21/84 Deposition of T. Brandt (12 pages). [
- 2. 9/27/84 CASE filing to ASLB re: CASE's Evidence of A Quality Control
- Breakdown (90 pages). -
. 3. 10/16/84 Letter to ASLB transmitting 10/3/84 deposition of T. Brandt (124 pages). (Accession number 8410170157)
Available in a Public Library
- 1. 9/14/84 Newspaper article Dallas Times Herald.
- 2. 9/13-14/84 Fort Worth Star-Telegram Article.
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UNITED STATES i ! o NUCLEAR REGULATORY COMMISSION
- WASHINGTON, D. C. 20655
%,*****/ JAN 2 91985 I
Docket Nos.: 50-445 and 50-446 .
s .
MEMORANDUM FOR: Those on the Attached List FROM: Vincent S. Noonan, Director 1 for Comanche Peak Project Division of Licensing j
SUBJECT:
FREEDOM OF INFORFATION ACT REQUEST We have (copies recently) enclosed relating received five (5) Peak.
to Comanche Freedom Under ofthe Information Act (FOIA)
FOIA, the NRC must requests identify all records which are subject to a request. After an FOIA request
, is received by the agency, no records in existence at that time may be de-i stroyed. Accordingly, you should all be aware of these requests and should
- identify records that are in your possession and control that reasonably are j asked for in these requests. Please note the date of the requests. The FOIA request is a point-in-time vehicle for access to agency records and a request is only legally entitled to recorJ., in the possession and control of the agency on the date the request is received. Records received after that date may be volunteered to the requester, but they are not required to be processed or maintained. ,
To the extent practicable, we will respond to all FOIA requests as soon as possible. However, in planning the expenditure of time, remember the primary j
t consideration is to assure the prompt resolution of the allegations and to
- j. protect the health and safety of the publid.
. v The five (5) requests pending before us are as follows:
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- 1. FOIA 85-26 from Bruce Millar, Fort Worth Star - Telegram -
dated January 8, 1985 (Enclosure 1)
Request: All preliminary drafts of the Technical Review Team's report regarding quality control at Comanche Peak.
- j Schedule: Responses should be forwarded to A. Vietti, Mail Stop 316, i no later than COB
$ 2. FOIA 85-15 from Billie Pirne'r Garde, GAP - dated January 9, 1985 i (Enclosure 2)
Request: All records connected with the Quality Assurance Report
} by the Technical Review Team about the Comanche Peak nuclear power plant.
" Schedule: Responses should be forwarded to A. Vietti, Mail Stop 316 j no later than j 3. FOIA 85 from Billie Pirner Garde, GAP - dated January 11, 1985 1
- 4. FOIA 85 from Billie Pirner Garde, GAP - dated January 14, 1985
]
, 5. FOIA 85 from Billie Pirner Garde, GAP - dated January 15, 1985
{ Letter to B. P. Garde (GAP) from J. M. Felton (NRC) dated January 22, 1985. (Enclosure 3).
] Request: All records concerning the overview, regulation and j investigation of the Comanche Peak Nuclear Plant by any
.j , person, branch, or department of the NRC since January 9, i 1984. Please note that by letter to B. P. Garde (GAP) i from J. M. Felton (NRC) dated January 22, 1985, the staff reduced the scope of this request to those records related to the NRC, Comanche Peak Task Force which was established j in March 1984.
i Schedule: Responses should be prepared by March 29, 1984. Your index i of records should be forwarded to A. Vietti, Mail Stop 316.
j The records themselves should be forwarded to P-220. The j boxes must clearly identify the records they contain.
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JAN 2 91985 .,
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In responding to the FOIA requests, the following guidelines should be :
followed: ._,
- a. All records which are subject to a request must be listed by date in -
( chronological order (undated documents should be listed at the end)
] with a brief description of the document and number of pages. -
1
} b. All documents, except those that can be located in the public document room, must be provided. If the document is in the public document room,
, you must provide the accession number. If the accession number is not i provided, the document must be provided,
- c. Records containing proprietary information, the names of confidential l sources, personal privacy information, law enforcement information, or
( other information exempt from disclosure under the FOIA should be spe- -
) cifically marked and the exempt portions bracketed. The applicable exemption must be noted after each document, or portion of a document, being withheld. A description of records exempted from disclosure is provided as Enclosure 4. Please note that even if a document is exempt, .
i it must be listed and provided to the FOIA branch in the event there is an appeal request or an adjudicatory action.
1
! d. Where we have investigated allegations and released the Comanche Peak Technical Review Team findings, all records that have been retained in '
y file folders necessary to support conclusions with respect to any d
allegation, shall be listed by allegation number and provided to the requester. If we have not released our findings, the documents must also be listed and provided to the FOIA branch but can be withheld from
=
the requester as predecisional. (Exemption 5 for agency document and 7(a) for applicant documents).
H e. Documents which could be used to trace the identity of allegers can be j withheld under exemptions 6 and 7(d) if the alleger has been granted
[ confidentiality by the staff. (Alleger must have signed a confidentiality agreement). If the alleger has not signed a confidentiality agreement, the identity can be withheld under exemptions 6 and 7(c).
Reproduction facilities are available in the Phillips Building. An example of an F0IA request (FOIA 84-778) recently responded to by the staff is provided as Enclosure 5. I will be preparing the memorandum to the Technical and Oper-7 ations Support Branch; however, you must provide to me the necessary index of documents and copies of the documents to respond to the FOIA requests. If you have any questions concerning the processing of thest requests, please contact hl A. Vietti on x27793.
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f Questions concerning the requirements of the FOIA should be addressed to y Ed Shomaker, Attorney, OELD, on x28653 or Lyn Robinson Chief, Freedom of
- g. Information and Privacy Branch on x28133.
U j ,
B t
e Noon- , Director for C nche P k Project g Divisio of Licensing
Enclosures:
As stated .
[ cc: A. Vietti R. Wessman E. Shomaker a{ J. Felton L. Robinson D. Meyer
., J. Cawley D. Eisenhut H. Thompson H. Smith 9
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1 DISTRIBUTION FOR THE ATTACHED MEMORANDUM DATED:
T. Ippolito f Electrical Team J. Gagliardo J. Calvo, Leader A. Vietti ~
A. Marinos R. Wessman A. Johnson W. 011u H. Li K. Brown * (W-501) W. Marini*
C. Posiusney (P-234) G. Myers*
L. Lazo R. White
- C. Haughney* (P-234) J. Selan*
J. Zudans (P-234)
, SSER Team Cygna Team R. Tang, Leader G. Bagchi, Leader B. Saffel* .
D. Terao C. Hofmeyer*
J. Fair T. Workinger*
P. Chen*
D. Landers
- Test Program Team l
l R. Keimig, Leader ,
Civil Mechanical Team 9. Smith ,
L. Shao, Leader A. Mackley*
D. Terao D. Beahm*
S. Hou ,
- D. Jeng Coatings Team J. Tapia C. McCracken, Leader R. Hubbard* R. Matthews R. Masterson* C. Johnson R. Philleo* S. Kirslis
- V. Ferrarini* J. Taylor
- 4 C. Hofmeyer* -
V. Lettieri*
P. Chen* S. Dechsle*
E. Thompson
- W. Wells
- J. Devers* 8. Hodgson*
l' C. Richards*
J. Melonson*
D. Landers
- j T. Langonski*
j D. Hansen*
R. Ciatto*
j Clausen*
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JAN 2 01985 OA/ Team Miscellaneous Team R. Bangart, Leader
- i -.-v e r sf c7 J. Cummins FC. Hale S. Phillips d L. Jackson D. Kelley vV. Watson
- D. Hunnicutt vT. Curry * -
G. Thomas
- v V. Wenczel* . ";n i . t d *-
-0. Sumers* F. Warren
- vM. Bullock
- K. Ward
- VW. Wade * ,./ //m.d " ""--
- C. Morton* &Eu-/m B. Cloward*
- 8. Payne*
' f .M Eli*
- W. Liu N . ^v. uw P. Snyder*
/J. Harrison - sn-710_S2.g C. Oberg v F. Farmer
- M.
Skow*
-H. Rockhold* . L ..cici;*-
4 . Hedderick* R. Turner
- I
- }. Strait * ..L.n*-
VJ. Schapker* -rh _ L , f x x*-
"3. Vanderbeek* / G. Thorr.as*
W . Chan* % d / VC. Rounds
- S. Bruske*
j ,- - V vC.D. Haughney*
Shultz* # M - "r -
ij <T. Workinger*
lj v R. Bonnenberg*
VR. Harbron*
!):
(' -11. Mang**- t== ~
B. Evans * / - =
v3. Corbett* 1 I
- '1.. Jones
- j /J. Melanson*
Non-Task Force (may hold task force documents) l S. Burwel1 i
- NRC consultants. Consultants copies should be forwarded to the appropriate j team leader. Team leader is responsible for making the NRC consultant aware lt of the FOIA requests and gathering the records held by NRC consultants on 1 treir team.
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[ MORNING EVENING SUNDAY f,
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3 January 8, 1985 4 '
3 M:cscM OF INFORMATWii )
ACI REQUESI , ,
] Di et r les T. Records Division
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] Nuclear Regulatory Commission h4 /g f g_g j Washington, D.C. 20555 d
j n Dear Mr. Felton This request regarding the NRC's Technical Review Team report _
- on quality control issues at Comanche Peak nuclear power plant is made under the Freedom of Information Act, 5 U.S.C. 552.
Please'firnish me or make available to the Star-Telegram one
.]
j copy of all preliminary drafts of the Technical Review team's I
report regarding quality control at Comanche Peak. This request includes all draft versions of the report regardless if the
' study has been released in its final form. ,
3 I am prepared to pay reasonable' duplication fees. Please inform
]
me if th.e costs are going to exceed $50.
This information is of timely value and I will appreciate your
. responding by telephone rather than by mail. I will look forward to receiving your reply within ten business days or no later than January 25, as required by law.
l Thank you for your assistance in this matter.
f
- I, F Yours truly, I r % -
\
W Bruce stillar-n 1 2' W
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400 WEST SEVENTH STREET / FORT WORTH. TEXAS 76102 / AREA CODE 817 / 336-9271
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' UcsNn; ::.m. D.C. 20036 ' (202) 2 ~;2-5550
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5 5 January 9, 1925 s .
. - FREE C." CF INFCEMATION.'ACT F.EOUEST FP.EEDOtA OF INFGEMATION ACT REQ:UEST Oirector . -- ~8bI Office of Admir.istration s
- i. Nuclear F.egulatory Cc :ission J< 'C/'/- j?d8 Washi ngtcr., D.C. 20555 s 2
To Who: It May Concern:
pursuant t: the Freed: cf Informaticn Act ("FOIA"), 5 U.S.C. ! 552, the Godrnment Acccur.tability Frcject (" GAP") reevests copies of any and ali a;er.cy recorcs and infor:aticn, includin5 but n:t limited to notes, letters, mensranda, drafts, tinutes, diaries, icgs, calendars, ta;es, transcri;ts, sur= aries, interview re-a p:rts, pr::edures, instructions, engineering analyses, drawings, files, graphs, l charts, ma;s, ;hotographs, a;reerents, handwritten r.:tes, studies, data s-heets, notebc:ks, bcW., tel.eph:ne ressages, cc putations, vcice recordings , corputer
. runcffs, any other data ec:;ilaticns, interi and/or final rep rts, ststus re-p:rts, and any and all other rec:rds relevant to and/or ;enerated in connection with all ir.ftr:iticn cor.nected with the Q.:ality Assuran:e F.ep:rt by the Technical' j t*
Review Team about the Comanche Peak nuclear power plant.
l this request includes all agency reccrds as defined in 10 C.F.R. $ 9.2a(b) and the GF.C Manual, A;pendix C211, Parts 1. A.2 and A.3 (e;preved October E,1920)
{ whether they :urrently exist in the HF.C cfficial, " working," r.vestigative or t
cther files, cr at any other location, including private rasidences.
l j If any re:Ords as defined in 10 C.F.R. S 9.2a(b) and the NF.C Manual, supra, ar.d covered by this request have been destroyed and/or ra. :ved after this request, please ;.revide all surrounding reccrds, including but not limited to a list of all reccrds which have been er are destrcyed and/or remove'd, a description.of the action (s) taken relevant to, generated in connection with, and/cr i.ssued in. order L
to irple:ent the action (s)
, GAP requests that fees be waived, because " finding the inf rcation can be con-
[ sidered as primarily ber.efitting the ;ereral public," 5 U.S.C. ! 552(a)(4)(a).
L GAP is a r.cn-profit, ncn-pirtisar. pt.blic interest organization con'cerned with L !cnest aid c;en 5:vernter.t. Through ;;blic cutreach, the Prefect prc :tes l whistist".cwers as ager.ts cf g: verr.ner.t acccuntability. Thrcush its Citi: ens
' Clinic, ;AF cffers assistance to iccal public interest and citi: ens grou;s seeking t:, ensure the health and safety cf their cc= unities. The Citizens Citnic is currer.tly.assistir.; several citizens groups, lccal g:vernments and ir.terven:rs in the- central. Te>as area con:erning the construction of the C inche Peak r!; clear power plant.
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i 1.'e' are requestine the at:ye infernsticn as part of an engoing :n/tcring proje:t on the adequacy of the NF.C's efforts to protect public safety ar.d health at
~
nuclear p:wer plants. '
! F:r ar;. fccurents or portions tha' ty:e deny due to a specific.'F".A exemptioni t please ;r; vide an index ite:izir.; arid descricing the d:cuments cr p;rtions of l de:::er.ts withhel d. The index shculd provide a detailed jusitfication of your l grcunds fcr claiming each exes;tien, explaining why each exemption is relevant
- to the document or porti n of the document withheld. This index is required l under '.'auchn v. hsen (I), 484 F.2d 220 (D.C. Cir.1973), cert. denied, 415 U.S.
I 977 (1974).
2
'n's ic:k fcrward to ycur response tc this request within ten days.
l
) Sincerely, I
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Eillie Pirner Garde
! Citizens Clinic Directcr i
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Enclosure 3 GOhEkNMENT ACCOUNTADILITY PROJECT ,
1555 Connecticut Avenue, N.V., Suite 202 p[ Washirgron. D.C. 20036 .
(202)232 8550 E
January 11,1985 FREEDOM OF INFORMATION ACT pr00EST' . ,
OF INFORMATION e ACI REQUEST-
- l fo1A -as- /?
y y l-//-PS 4 Director Office of Administration Nuclear Regulatory Commission -
i
,j Washington, D.C. 20555 ,
[a To Whom It May Concern:
Pursuant to the Freedom of Information Act ("FOI A"), 5 U.S.C. I 552, the Government Accountability Project (" GAP") requests copies of any and all agency records and
- j information, including but not limited to notes, letters, memoranda, drafts, q c;inutes, diaries, logs, calendars, tapes, transcripts, sunnaries, interview re-i ports, procedures, instructions, engineering analyses, drawings, files, graphs,
! charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, bo'oks, telephone messages, computations, voice recordings, computer j runoffs, any other data compilations, interim and/or final reports, status re-3 ports, and any and all other records relevant to and/or generated in connection with the overview, ragulation and investigation of the Comanche Peak Nuclear Plant
' by any person, branch, or department of the NRC since January 9,1984.
This request includes all agency records as defined in 10 C.F.R. I 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, o~r at any other location, including private residences.
If any records as defined in 10 C.F.R. I 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/o'r issued in order-to implement the action (s).
l GAP requests that fees be waived, because " finding the information- can be con-sidered as primarily benefitting the general public," 5 U.S.C. 5 552(a)(4)(a). ,
GAP is a non-profit, non-partisan putlic int! rest organization concerned with _
honest and open government. Thro 0gh public outreach, the Project promotes f' 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
- Coranche Peak nuclear power. plant. __
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4 Office of Administration
' January 1li 1985 Page Two .
We are requesting the above' info'rmation as part of an ongoing mon'itoring 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.
The 'index should provide a detailed jusitfication of your.
documents withheld.
grounds for claiming each exemption, explaining This why index eachisexemption required is relevant i
to the document or portion of the document withheld.
i under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir.1973), cert. denied, 415 U.S.
! 977 (1974).
4 We look forward to your response to this request within ten days.
Sincerely, t
h 'th l
I
' Billie Pirn'er Garde Citizens Clinic Director 3
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.' GOVEMUAENT ACCOUNTABILITY PROJECT
1555 Ccnrecs Awnse. NW.. bie 202 WosNngien: D.C 20036 (202)232 8550 i
January 14, 1985 FREEDOW Or INFORMATiON FREED 0". OF INFORMT10N ACT REQUEST I ,-
h/A-N'N j
Director Q= t/a/K Office of Administration
- Nuclear Regulatory Com.ission Washington, D.C. 20555 To Whoe It May Concern
Pursuant to the Freedot of Information Act ("F01 A"), 5 U.S.C. ! 552, the Government l ' Accountability Prciett (" GAP") requests copies of any and all agency records and inforr.a t i ori, including bat nct Licited to nctes, lettees, me renda, drafts, l
sinates, diaries, logs, calendars, tapes, transcripts, sum. aries, intervien- re-1 ports, procedures, instructions, engineering analyses, drawings, files, graphs.
H charts, maps, photographs, agreements, handwritten notes, studies, data sheets.
E notebooks, books, telephone messages, computations, voice recordings, computer p ,
runoffs, any other data compilations, interim and/or final reports, status re--
"
- ports, and any and all other records relevant to .and/or generated in connection with the overview, ragulation and investigation of the Comanche Peak Nuclear Plant by any person, branch, or deoartment of the NRC since January 11, 1985.
This request includes all agency records as defined in 10 C.T.R. $ 9.3a(b) and trie NRC Manual Appendix 0211, Parts 1.A.? and A.3 (apptcved October 8,1950) a whether they
- currently exist in the NRC of ficial, " working," investigative or
- other files, or at any other location, including private residences.
If any records as defined in 10 C.T.R. $ 9.3a(b) and the NRC Manual, supra, and
' covered by this' request have been destroyed and/or removed after this request, j 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 1
action (s) taken relevant to, generated in connection with, and/or issued in order t to implement the action (s).
GAP requests that fees be waived, because " finding the information can be con-sidered as primarily benefitting the general public," 5 U.S.C. $ 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
)l - whistleblowers as agents of government accountability. Through its Citizens j Clinic, GAP offers assistance to local public interest and citizens groups 3
j seeking to ensure the health and safety of their communities. The Citizens
~ Clinic is currently assistine several citizens groups, local governments and I intervenors in the central Texas area concernir.g the construction of the -
s Comanche Peak nuclear power plant. .
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Januatri 24, 1985
, Page Twc- -
- . We are requesting the above information as part of an ongoing senitoring project
.cn the adequacy of the NF.C's efforts to protect public safety and bealth at nuclear power plants.
_ ' For any documents or portions that you deny. due to a specific F01 A exemption, please provide an inoes iterizing and describing the documents or portions of 1
d:cuments withheld. The index should provide a detailed jusitfication of your ,
grounds for claiming each exemption, explaining why each exemption ~is relevant .
^j 13 the documint or portion of the document withheld. This inder is required under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir.1973), cert. der.ied, 415 U.S.
977 (1974).
) We look forward to your response to this request within ten days.
Sincerely, 1
b M % bb l Billie Pirner Garde
- Citizens Clinic Director i
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s GOVERNMENT ACCOUNTABILITY PROJECT 1555 Cmr.ecicut Annue, N.W., Suite 202 5
Wut.irgeri, D.C. 20036 . (202)232 8550 l
e January 15, 1985 !
i, 1 FREEDOM OF INFORMATION 1' ACI REQUEST. '
l -
FREEDOM 0F INFORMATION ACT REQUEST f0/A-/N Y
,gn-u grpr 1 Director 1 Office of Administration -
j Nuclear Regulatory Commission i e Washington, D.C. 20555 j To Whom It May Concern:
Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. 3 552, 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, sumaries, 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 final reports, status re-
- b. ports, and any and all other records relevant-to and/or generated in connection with the overview, ragulation and investigation of the Comanche Peak Nuclear Plant by any person, branch, or department of the NRC since January 14, 1985.
R lj 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) jj whether they currently exist in the NRC official. " working," investigative or
, other files, or at any other location, inclcding private residences.
If any records as defined in 10 C.F.R 4 19 3a(b) and the NRC Manual, supra, and
', covered by this request have been M cyN and/or removed after this request, j please provide all surrounding re og ':(luding but not limited to a list of all j records which have been or are dedroyeo arJ/or removed, a description of the
! action (s) taken relevant to, generated in connection with, and/or issued in order
- j. to implementtheaction(s).
l;l 6 GAP requests'that fees be waived, because " finding the information can be con-4 sidered as primarily benefitting the general public," 5 U.S.C. 6 552(a)(4)(a).
y GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleb7bwers as agents of government accountability. Through its Citizens ij 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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Office of Administration January 15, 1985 Page Two I,
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L We are requesting the above information as part of an ongoing monitoring project
' on the edequacy 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, i please provide an index itemizing and describing the documents or portions of The index should provide a detailed jusitfication of your 1 documents withheld.
grounds for claiming each exemption, explaining This why index each is exemption required is relevant
=.f to the document or portion of the document withheld.
1 under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir.1973), cert. denied, 415 U.S.
l 977 (1974).
?
We look forward to your response to this request within ten days.
l4 Sincerely, W \\\J%
j Billie Pirner Garde Citizens Clinic Director J -
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JAN 22 E
~, Ms. Billie Pirner Garde Citizens Clinic Director .
Government Accountability Project IN RESPONSE REFER
- 1555 Connecticut. Avenue, NW TO FOIA-85-1?l, 1 'F01A-85-33, AND Suite.#202 Washington, DC 20036 F0!A-8.5-34
Dear Ms. Gard'e:
- )j This is in regard to'your letters dated January 11,14, and 15,1985, in which 9 you requested, pursuant to the Freedom of Infonnation Act (FOIA), copies of all d records related to the " overview, regulation, and investigation of the Comanche
- Peak nuclear plant by any person, branch, or department of the NRC since January 9, 1984." -r l ,
q 1 In light of recent conversations between you and NRC staff members in which you
! expressed your interest ir; records related to the current Comanche Peak Task
Force activities, we are interpreting the " investigation" aspect of your
- i requests as covering records related to the NRC Comanche Peak Task Force which
( was established in March 1984. We have asked the NRC staff to begin searching
- for all Comanche Peak Task Force documents subject to your requests.
d With respect to the " overview" and " regulation" aspect of your requests, we have
- ) determined, after careful consideration, that these portions of your requests do 9 not " reasonably describe" the records sought, but, rather, are broad, sweeping, indiscriminate requests for production, lacking reasonable specificity. As such, these portions of the requests fail to meet the threshold requirements of '
theFOIA(5U.S.C.552(a)(3)).
It is reasonable to assume that files located throughout various offices and L! divisions of the NRC contain records that might be-considered as related to the l' overview or regulation of the Comanche Peak nuclear plant. We cannot, however, i' short of examining all NRC files, state with any degree of confidence that all l
subject records have been located.
e j The House Report on the 1974 amendment to the FOIA provides that:
I "A ' description' of a requested document would be sufficient if it j
enabled a professional employee of the agency who was familiar with j the subject area of the request to locate the record with a
! reasonable amount of effort." (H.R. Rep.No.93-876, 93d Cong.,
~ 2d Sess.1-6,1974)
As in'dicated above, much more than a reasonable amount of effort would be J
required to comply with your requests.
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- Likewise, the Senate Report indicates that the.1974 amendments to the FOIA were not intended "to authorize broad categorical requests where it is impossible for the agency reasonably.to determine what is sought. (See Irons v. Schuyler, 465 F.2d 608 (D.C. Cir.1972)) ...." (S. Rep. No.93-854 N Cong., 2d. Sess.
10,1974).
j In' view of the scope and nature of yo'ur requests,'the documentary material being sought, and the considerations expressed above, we conclude that your requests
] with regard to " overview" and " regulation" do.not meet the requirements of 1 .
5 U.S.C. 552(a)(3). However, 'as you are aware, the vast majority of the
- material related to these portions of your requests are routinely made
! available in the NRC Public Document Room as p_ art of the Comanche Peak docket j files.
1 i If you consider this response to be a denial of your requests, you may appeal
- this determination within 30 days from the date of this letter. As provided j in 10 CFR 9.11, any such appeal must be in writing, addressed to the Executive Director for Operations, 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 FOIA Decision."
a We will comunicate with you again as soon as the Comanche Peak Task Force has conducted a search for and review of any documents which may be subject to your reque.ts. _
j .
Sincerely, WP M Oh ,
- ! J. M. Felton, Director j, Division of Rules and Records 1 Office of Administration t
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. . . a .. RECORDS EXEMPTED FROM DISCLOSURE -. .
A. Exemption (1): Records "(a) specifically authorized under c iteria .c established by.an Executive Order to be kept secret in the i1terest. : : :=
3 of national defense or foreion policy, and j (b) are in fact properly classifiec j pursuant to such Executive Order." (E0 12356) "
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, 1. To withhcid information from ' disclosure under Exemption (1), the infor . *. *
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mation must be (a) classified in accordance with the criteria set forth
- j in Executive Order 12356, and. ..
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'"F -(b) classified by an authorized classifier.- ' ""
9 2. Classification legends are Top Secret, Secret, and Confidential.
j " Official Use Only" is not a classification. .
I q 3. All classified documents subject to FOIA requests must undergo a O declassification review to segregate exempt classified information .. -
{ from nonexempt unclassified information. -
. 4. Periodically, NRC offices will identify records which have not been
_ . properly g,].assified but which are thought to .contain classified information.. When this occurs, the requester is notified that the
- p records are being withheld pursuant to Exemption (1) pending a classi-fication review. -
~
a Subsequent to the initial denial of the records ' pursuant to Exemption (1), the originating office conducts a declassification review of the documents. Upon completion of that review, nonclassified material is released to the i reque' ster unless it is withholdable under another exemption. .
[1 5. Documents classified by other agencies (DOE, D00, etc.) have to be .
referred to those agencies'for declassification review. Particular problem with NSF Erwin where fuel used in naval propulsion. program p
i and classification based upon DOE guidelines. ,
- 6. Courts have also adopted a " jigsaw puzzle" or " mosaic" approach allowing agencies to classify information, which is otherwise unclassified, if 1
i it could provide the " missing link" to classified information. (Halperin
- v. CIA, 629 F. 2d 144 (1980)). Theory can also be used to protect a j :.. " " compilation" of materials not otherwise classified in their component j parts. (Taylor v.,Oeot of the Army, 684 F. 2d 99 (1982)). _
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.- RECORDS EXEMPTED FR0 DISCLOSURE
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1 Exemption (1):
Records "Ca) specificallylauthorized under criteria .- d i A.
1 established by an Executive Order to be kept secret in the intereE.
i of national defense or foreign policy. and(b) are in fact properly classified ..
j pursuant to such Executive Order." (E0 12356) ..
4 ' der Exemption (1), the infor-
~
j 1 1. To withhold information from disclosumune with the criteria set forth
? mation must be (a) classified in accordanc .
in Executive Order 12356, and. -
}~ - (b) classified by an authorized classifier.
i 2. Classification legends are Top Secret, Secret, and Confidential.
" Official Use Only" is not a classification. :
7 l
- 3. All classified documents subject to FOIA requests must under ..
from. nonexempt unclassified information. i
- 4. Periodically, NRC offices will identify records which have not been properly g.lassified but which are thought to.contain classified information. When this occurs, the requester is notified that the records are being withheld pursuant to Exemption (1) pending a classi-fication review.
' Subsequent to the ini_tial denial of the records pursuant to Exemption Upon (1), the originating office conducts a declassification review of the documents.
.I completion of that review, nonclassified material is released to the reque' ster unless it is withholdable under another exemption,
] .
j 5. Documents classified by other agencies (DOE, D0D, etc.) have to be Particular referred to those agencies for declassification review.
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problem with NSF Erwin where fuel used in naval propulsion. program .
and classification based'upon DOE guidelines. ,
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6.
Courts have also adopted a " jigsaw puzzle" or " mosaic" approach allowing
]' agencies to classify information, which is otherwise unclassified, (Halperin if it could provide the " missing link" to classified information.
- v. CIA, 629 F. 2d 144 (1980)). Theory can also be used to protect a L
"coliipIlation" of materials not otherwise classified in their component parts. (Taylor v., Dept of the Army, 684 F. 2d 99 (1982)).
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B. Exemption (2h Records "which relate solely to the internal ~
personnel rules and practices of an agency." ,
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- 1. Exemption (2) may be_ utilized to exempt internal personnel rules '
1 and practices which do not significantly affect the public. The Senate Report on the FOIA cites as examples the use of parking
] ;
facilities, the regulation of lunch hours, policy as to sick lea 9e,
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and the like.
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- 2. House report is broader. It cover's " operating rules, guidelines,
]i and manuals of procedure for government investigators." This
.i exemption was..used in the past to withhold Section II of the . --
l I&E Manual which specifies the inspection requirements at licensed
~
4 facilities. .
- 3. I&E Manual now in PDR.
I 4. Exemption (2), in recent cases, of little practical use to NRC, except that "' ~
it is still used to withhold testing materials such as clerical or typing tests.
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C. Exemption (3): Records "specifically exemoted from disclosure by statute .
provided that such statute (a) recuires that the matters be withheld f rom the public in such a manner as to leave no discretion on the issue, or . . -
(b) establishes Darticular criteria.for . .
withholding or refers to particular types of matters to be withheld."
- 1. Exemption (3) is utilized as the authority to withhold " Restricted -
Data" from disclosure as required by Sections 141-145 of the Atomic - ~
! Energy Act of 1954, as amended (42.U.S.C. 2161-2165). -
i
! 2. Exemption (3) also used to protect:safeouards information as a result i
of Section 147 being added to the Atomic Energy Act on June 30, 1980. ~
i 3. Under Section 147, NRC can protect information which specifically
- identifies a licensee's or applicant's detailed security measures for
! the physical protection of special nuclear material, source material, j or byproduct material if release of the information could reasonably i be expected to have a "significant adverse effect on the health and . .
1 safety of the public or the common defense and security by signifi-l cantly increasing the likelihood of. theft, diversion, or sabotage."
i
- 4. . Examples gf -safeguards information which are. withheld are security
, plans, procedures, and equipment; safe havens; local law enforcement l . response times; radio frequency transmission data; departure times;
- and anything.else that could reasonably be expected to significantly
} , increase the likelihood of theft, diversion, or sabotage.
- 5. Problem areas-specific safeguard violations identified during inspections, unlocked doors, missing keys, etc.-- problems that go away when resolved.
- 6. Section 147 specifically prohibits the NRC from withholding information pertaining to shipment routes and the quantities of shipments.
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2 I D. Exemption (4h Records "containing trade secrets and commercial or
} financial information obtained from a person and privileged or ~~
confidential." -
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l 1. Exemption (4) is utilized 'to exempt from disclosure information which '~
meets the following two tests:
(a) the information information, andis a trade secret or commercial or financial .. -
)
1 (b) disclosure of the information must either (1) result in sub-d stantial harm to the competitive position of the owner or - -
(2) harm the government's 4, ability to obtain information in the future. (National Parks Conservation Association v. Morton, 498 F. 2d 765 (1974)).
i j 2. NRC deals basically with three types of proprietary information:
f (a) Technical proprietary '* '
i (b) Financial proprietary.(costs, prices, lists of customers, etc.)
, (c) 2.790[d) information: *
(i) Information received in confidence from a foreign source i
, (ii) Material control and accounting information
, (iii) Physical security information at certain facilities .
- 3. If NRC disagrees with a proprietary claim, we normally negotiate the matter with the owner of the information.
- 4. Owner of proprietary information has to show:
(a) Was submitted to the NRC in confidence.
(b) Is not available in public sources.
4
) (c) Is normally treated as confidential by the company.
i, (d) Disclosure would cause substantial harm to the competitive .
j .
position ~of the company. - *
- 5. If NRC plans to rel, ease information claimed to be proprietary, the.
company is given two weeks notice in order to file in court for the injunction. The NRC then has to prove, through expert testimony, l ,
that release would not harm the competitive position of the company.
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E. Exemption (5): " Inter-acency or intra-agency memorandums or letters -
which would not be available by law to a party in-litigation with the agency." -
- 1. To exempt a record from disclosure utilizing. Exemption (5), the record l must normally be either:
1
! . (a) an inter-agency memorandum or letter (i.e. memorandum or lettb'r ,
- transmitted from one Federal _ agency to another), or ,
i l (b) an intra-agency memorandum or letter (i.e. memorandum or letter
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transmitted from one person in an agency to another person in' the same agency).
l 2. The purpose of the exemptions is to encourage the full, frank, and candid exchange of opinions needed for~ good decisionmaking. It recognizes that the government cannot operate in a goldfish bowl.
} 3. Only that part of the record which contains predecisional advice, opinions, i and recommendations of the staff given during a deliberative process, i.e. , the process in which the agency makes its decision, can be exempted. .
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- 4. Segregatio.n Requirement: Factual information must be segregated from advice, opinions, and recommendations in predecisional documents except
. for drafts, certain legal work products, and records covered by the attorney-client privilege.
- 5. As a practical matter, Exemption.(5) is seldom used now at the staff level except for draft documents where the final has not been issued. The offices have recognized that it is easier to let documents go than to
) try and segregate facts, and there has been no noticeable effect of j this policy on staff candor.
t I 6. Advice from a Commissioner's staff to the Commissioner is normally
[ withheld,
- 7. In some cases, it is also possible to withhold information under h Exemption (5) even if the records were prepared by persons outside of 1
j the government. These cases recognize that in some situations the
)
government may have a special need for the opinions and recommendations j of temporary consultants who are experts in their field. If these L consultations were (a) solicited by the agency and (b) are an integral j part of the deliberative process, the informztion may be withheld.
g (Ryanv.DeptofJustice(D.C.Ct.ofApp.,gnuary7,1980) a 8. Cannot withhold document where the product purchased by NRC is a A report or study. NRC will look to underlying contract for purpose--
I are we purchasing a product or someone's special expertise and advice.
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i F. Exemption (6): Records "which are personnel and medical files and ~
similar files, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy." ,, _
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- 1. It applies to the intimate and personal details of one's life, and covers information such as the legitimac of children, medical ' ~ "
j condition welfare payments, religious affil ations, school records, .
j and the llke. , , ,
j 2. Where privacy information is found; the FOIA then requires a balancing 1 of . int.erests between the protection of an individual's private affairs l , from unnecessary public scrutiny, and the preservation of the public's -
j .
right to government information. ,
- 3. The term " clearly unwarranted" contained in the exemption instructs an agency "to tilt the balance in favor of disclosure."
4 4." Where misconduct by a government employee is involved, balance is , , ,
tilted heavily in favor of disclosure. Reason - Courts speak in j terms of the public having "an interest' in whether public servants 1 ,
carry-out their duties in an efficient and law-abiding manner."
I (Columbia Packing Co. v. Dept of Agriculture (563 F. 2d 495 (1977)).
) 5. The following information about government employees is considered public information and is disclosed on request:
(a) Employee's name (b) Present and past position titles (c) Present and past grades (d) Present and past salary (gross salary - not net)
(e) Present and past duty stations The NRC, in response to a FOIA request by an unselected candidate
~
6.
on a vacancy announcement, will make available essentially everything i on a SF 171 that deals with education, training, and qualifications l for employment. We withhold personal information such as birthdates,
_. SSN, home address, home phone number, personal references, and infor-J' l mation about relat,ives. We will also withhold an employee's perfor-mance evaluation.
- 7. The right to privacy is a personal right. h ere is no right to privacy in a corporation. $
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- 8. There is also no right to privacy in a dead person. We have given out, -
f for example, the name and the amount of radiation exposure received by one who is deceased. . -
l 9. If personal information about a dead person would harm the living, it
} may be protected. Examples are--President Kennedy's autopsy repott and . .
photos, information concerning the legitimacy of children, and information concerning the personal and family life of an organized ciime 1 r- '
' figure. , ,
~
- 10. " Mosaic" theory, used for classified information, has also been used to i
withhold the names of drugs prescribed by the Congressional Physiciin ~
' even though the names of Members of Congress were deleted. Court said L
that with a working knowledge of the symptoms and purposes for which l certain drugs are prescribed, the inforr.ation could be the " missing link" for a person with fragmented knowledge about a Member's health (Arieff v. Dept of the Navy (Dist. Ct of D.C., April 27,1982).
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G. Exemotion (7): Investigatory records " compiled for law enforcement purposes," (criminal, civil, or administrative) but only to the ~
extent that production of such records would:
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(a) . interfere with enforcement proceedings (applies to open cases' only and would result in substantial harm t'o government's case.)
Government must show, by more than a conclusory statement,- how the - ' '
- particular kinds of records requested would interfere with a.. -
t pending enforcement action. Material must show the scoce, -
i direction, and focus of the inouiry. Does not have to be done on a j document-by-document basis.-(Camobell v. Dept of Health and
- Human Services, (D.C. Court of Appeals, June 25, 1982)). . -
1 j (b) deprive a person of right to a fair trial or an imoartial adjudication (can't use against person who is subject of investigation ' applies to.3rd parties only).
(c) constitute an unwarranted invasion of personal privacy (balancing test as in Exemption (6). ~ -
(d) disclose the identity of a confidential source and, in the case of
' a record compiled by a criminal law enforcement authority in the courte of a criminal investigation, or by an agency conducting a lawful national security intelligence investigation, confidential
! information furnished only by the confidential source (covers l '
individuals, police files, and Federal and state grand jury informa-tion).
(e) disclose investigative technioues and procedures (designed to protect future effectiveness of procedures).
(f) endancer the life or physical safety of law enforcement personnel.
(used by FBI) ,
I I
- 1. Exemption (7) does not apply to routine inspections; however!,.it does apply i
to the so called "special inspections" conducted by the Regions.
- 2. On a routine inspection, the " investigation" phase starts when evidence of possible wrongdoing is uncovered. '
.. 3. Ask person at the' start of the interview if he wants to be a confidential source and make a note of it on the record. Names of persons contacted'during routine inspections cannot be confidential o source because inspect en is not for law enforcement purpose.
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I H. Exemption (8): Records which relate to the reculation or supervision . .
t of financial institutions. <
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- 1. The exemptio'n is not applicable to the NRC. .
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l I. Exemption (9): "
Geological and Oeophysical information and cata, "
- 1 including maps, concerning wells." **
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s 1. Exemption (9) pertains primarily t'o information relating to oil and j gas wells, and has been used on.only one occasion by the NRC. , _
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il REMINDER (a) Segregation ,
1 - Must segregate exempt from nonexempt portions of documents. -
- Cannot withhold entire document if just a portion is exempt.
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(b) Public Interest Determination ,,
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- Even'if record is exempt, NRC regulations require that a finding 4 must also be made that release is " contrary to the public interest
), or will adversely affect the rights of an individual." ,
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x j RELEASE TO CONGRESS 1
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- 1. FOIA specifically provides that the Exemptions may not be used to witnhold information from the Congrass. -
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'1 2. Must be in Congressman's representative capacity (Committee Chairman) ,
l rather than for personal use.
'l j '- 3 . NRC has given to Congress records containing personal information, J .I&E and OIA investigations, and proprietary information.
1 d 4. Where records requested by Congress are exempt under FOIA, we notify 3
Congress and request that records be maintained in confidence.
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. / UNITED STATES Enclosure 5
! NUCLEAR REGULATORY COMMISSION
(
{ a wAsMNGTON. D. C. 20585 f kCM 9
k h Docket No.: 50-445
- and-50-446 JAN 2 41985 -
lt MEMORANDUM FOR: Hazel I. Smith' Technical and Operations Support Branch
- . Planning and Program Analysis Staff, NRR.
FROM: Vincent S. Noonan, Project Director j) Comanche Peak Task Force Division of Licensing, NRR g .
H SU8 JECT: FOIA-84-778 l
1 The subject of FOIA-84-778 is being investigated through allegations raised in this area by the Comanche Peak (CP) Technical Review Team (TRT) Quality Assurance / Quality Control (QA/QC) group. I forwarded the request to Mr. H.
Livermore, Team Leader QA/QC, CP TRT, for review. Mr. H. Livermore has informed me that our review of allegations related to the subject request is still on going and the information is premature for disclosure. Therefore, I have deter-mined that we cannot release the information we hold on this subject at this time (referencing exemption 7(a) and 5 of the FOIA Act). Enclosed is a list of documents which Mr. H. Livermore's QA/QC group holds which are not releasable at this time. The applicable exemption is identified after each document being
, withheld. Task force members are on notice by copy of this memorandum that the nonreleasable material is to remain in their working files in the event there is an appeal request or an adjudicatory action. Also itsted are documents already in the POR on this subject which we are considering and documents which i already exist in the public domain. Where we were unable to provide an i accession number for those documents in the PDR, we enclose the document.
[ Please note that when this information becomes eligible for release, some of the requested information, if released, could be used to trace the identity of
, allegers who have requested confidentiality.
. oo n, Project Director omanche oak Division of Licensing-d cc: H. Livermore
- T. Curry
Enclosure:
As stated e
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Withheld Documents n 1. 10/24/75 TUEC Drawing 2323-51-0560 and design change documents
[ (approximately 80 pages). (ex. 7(a))
- 2. 11/4/77 TUEC Drawing WFB-0 831 (14 pages). (ex. 7(a))
- 3. Approximately 237 liner inspection travelers (approximately 948 pages). (ex. 7(a))
4 I 4. 3/17/83 Nonconformance Report (NCR) 83-00795 (7 pages). (ex. 7(a))
l J 5. 8/29/84 Memo to B. Scott from J. K. (unable to read) transmitting 26 j Unit 2 Brown & Root inspection travelers signed by alleger (A-3). (ex. 7(a))
- 6. 8/31/84 Memo to B. Scott from J. K. (unable to read) transmitting 17 travellers signed by F. Evans (approximately 68 pages).
(ex. 7(a))
- 7. 9/13/84 Computer printout of records signed by alleger A-3 (41 pages).
(ex. 7(a))
- 8. 1/10/84 Procedure QI-QP-11.14-6, Revision 6 (7 pages). (ex. 7(a))
{ 9. 8/23/83 Procedure QI-QP-11.14-6, Revision 5 (6 pages). (ex. 7(a))
- 10. 6/17/83 Procedure QI-QP-11.14-6, Revision 4 (6 pages). (ex. 7(a))
- 11. 3/25/83 Procedure QI-QP-11.14-6, Revision 3 (7 pages). (ex. 7(a))
- 12. 3/9/83 Procedure QI-QP-11.14-6, Revision 2 (7 pages). (ex. 7(a))
- 13. 9/8/82 Procedure QI-QP-11.14-6, Revision 1 (7 pages). (ex. 7(a))
- 14. 3/26/83 Procedure QI-QP-11.14-6, Revision 0 (4 pages). (ex. 7(a))
- 15. 12/26/79 Procedure QI-QAP-11.1-4, Revision 0 (7 pages). (ex. 7(a))
- 16. 8/24/78 Procedure QI-QAP-10.1-4, Revision 0 (3 pages). (ex. 7(a))
- 17. 1/5/84 Brown & Root Specification CCP-38, Revision 4 and -
revision pages (19 pages). (ex. 7(a))
- 18. 5/11/79 Gibbs & Hill Specification 2323-55-18, Revision 3 (33 pages).
(ex. 7(a))
19, 8/28/84 Oraft Safety Evaluation for Allegation AQ-55 and AQ-78, 9/17/84 Revisions 2 and 3 (39 pages). (ex. 5) -
1
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- 20. Undated Comanche Peak (CP) Allegations Chart, pages 2, 4, 8, and 9,
[
summarizing allegations and, source documents. (ex. 5)
F -
- 21. 3/7/84 Office of Investigation Report No.84-006, Interview of A11eger (A-4) (72 pages). (ex. 5)
. 22. Undated Affidavit of A11eger (A-3) (3 pages). (ex. 5)
- 23. Undated Interview .of. A11eger (A-3) pages 60-89. (ex. 5)
- 24. 1/10/79 Interoffice memo IM 16606 to delete CP-QCI-2.11-1 from QC manual (1 page). (ex. 7(a))
g 25. 1/9/78 Instruction CP-CQI-2.11-1, Revision 0 (7 pages). (ex. 7(a))
l 26. Undated Technical Review Team (TRT) Action Plan (1 page). (ex. 5) 1 j 27. 3/28/83 Pressure Test Data Sheet Spent Fuel Pool (1 page). (ex. 7(a))
- 29. 10/14/77 Drawings WR8-105559, 2323-SI-0560 plus 22 DCS's, WR8-00831 (7 pages). (ex. 7(a))
l
- 30. 7/16/84 Draft Safety Evaluation for Allegation AQ-78 (17 pages). (ex. 5)
- 31. Undated TRT members rough notes (21 pages). (ex. 5) ;
]
1 32. 9/22/83 Procedure CP-CPM 6.3, Revision 10 (8 pages). (ex. 7(a))
- 33. 10/5/84 Note to R. Bargart (NRC) from S. Treby (NRC) re: Reopening of Inspection Report 79-15 dated July 2, 1984 (29 pages).
(ex. 5)
~
34, 5/11/79 Gibbs & Hill Specification 2323-55-18 paragraph 8.1 (33 pages).
. (ex. 7(a))
35, 7/14/77 Bostrom-Bergen Metal Product drawing job #2401, sheet 38, Code 7 (1 page). (ex. 7(a))
l 36. 6/11/84 Technical Review Team (TRT)' Approach to Resolution (3 pages).
(ex. 5), .
- 37. 7/14/77 Orawing Bostrom-Bergen 2401A (2 pages). (ex. 7(a))
- 38. 6,'3/83 Nonconformance Reports M-767, M-6574, M6573 (3 pages).
(ex 7(a))
- 39. 10/9/84 Draft Safety Evaluation Report for Allegations AQ-55 and AQ-78, Revision 5'(19 pages). (ex. 5)
- 40. 9/17/84 Interview with Witness "Y" by R. C. Tang, T. Curry, ,
H. Livermore (22 pages). (ex. 5) 2
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- 41. Undated A11eger A-5 interview pages 19-23. (ex. 5) '
- 42. 3/27/83 Memo to J. George (TUGCO) from C. Randall re: Travelers I (2 pages). (ex. 7(a)) ,
r 43. Undated TRT members field notes (2 pages). (ex. 5) ,
f 44. , Undated ~
. Draft letter to M. Spence (TUGCO) from T. Ippolito (NRC)'
re: Travelers (2 pages)..(ex. 5) -
i 1 45. Revision pages to construction procedure number 35-1195-CCP-38 (12 pages). (ex. 7(a))
l 46. 9/13/84 Computer printout of jobs inspected by F. Evans (3 pages).
l (ex. 7(a))
i 1 47. 1/5/84 Procedure CCP-38, Revision 4, page 4 of 19. (ex. 7(a)) -
- 48. 8/23/84 TRT members field notes for AQ-55 (1 page). (ex. 5) ,
- 49. 8/23/84 Interoffice Memo for Distribution (TUGCO) from J. Duncan and M. Werner re: Stainless steel liner travellers (3 pages). (ex. 7(a))
I
, 50. 10/21/77 Procedure CCP-38 pages 6 and 16, Revision 1 (2 pages). '
(ex. 7(a))
- 51. 9/11/84 TUGC0 memo TUQ-2340 on stainless steel liner travellers (4 pages). (ex. 7(a))
- 52. 8/23/84 TRT members field notes (4 pages). (ex. 5)
- 53. 8/28/84 Draft Safety Evaluation Report for AQ-78 Draft 1 (11 pages).
(ex. 5) 1 1 54. Undated Personal notes on GAP information (1 page). (ex. 5)
Located in the Public Document Room Under Comanche Peak Docket Nos. 50-445 and 50-446
' 1. 9/10-9/21/84 Deposition of T. Brandt (12 pages).
- 2. 9/27/84 CASE filing to ASLI re: CASE's Evidence of A Quality Control
' Breakdown (90 pageh).
- 3. 10/16/84 Letter to ASLB transmitting 10/3/84 deposition of T. Brandt (124 pagGs). (Accessio'n number 8410170157)
Available in a Public Library
- 1. 9/14/84 Newspaper article Dallas Times Herald.
- 2. 9/13-14/84 Fort Worth Star-Telegram Article.
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' jr i.g UNITED STATES NUCLEAR REGULATORY COMMISSION I '
,
- WASHINGTON, D. C. 20555 e
FEB 1E l
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NOTE T0; J. Gagliardo L. Shao ..
i R..Wessman. J. Calvo
- i.
- W. Oliti R. Tang -
K. Brown R. Keimig i C .' ghney J. Zudans R. Bangart G. Bagchj S. Burwell
! FROM: Annette Vietti, Project Manager
{ Comanche Peak Task Force -
SUBJECT:
FREEDOM OF INFORMATION ACT REQUEST (F0IA) 1 j On January 29, 1985, V. Noonan issued a memorandum concerning F01A's
~
- ! received on Comanche Peak. Item e of the guidelines to be followed when i
i responding to an FOIA request discusses exemptions to withhold documents i which could be used to trace the ident'ity of allegers. Enclosed is a list
, of allegers who were granted confidentiality by the staff. Documents, or
- . portions of documents, identifying these allegers can be withheld under v.
exemptions 6 and 7(d). Documents which could be used to trace the identity
! of any of the other allegers can be withheld under exemptions 6 and 7(c).
1 l -
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IM Annette Vietti, Project Manager Comanche Peak Task Force
!I
Enclosure:
L stated
, cc: HThompson t F0lA-85-59 I4l~
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. COMANCHE PEAK ,
- ALLEGER CONFIDENTIALITY AGREEME' NTS
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- 1. A -I 4, y 2. A-2 1 3. A-6 '
- 4. A-10
- 5. A-14
- 6. A-24 '
- 7. A-27
. 8. A-28 I 9. A-29 .
10.. A-32 .
- 11. A-33
- 12. A-34 . ..
- 13. A-39 -
- 14. A-41
- 15. A-59 t 16. A-60 -. ,
- 17. A-62 .
I 18. A-63 .
j 19. A-69 .
- - 20. SRT A-3 .
- 31. GAP - Witness A '
- 22. GAP - Witness H
- 23. GAP - Witness.I
- 24. GAP - Witness J
- 25. GAP - Witness (Anonymous) 9 j
4
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