ML20198G753
| ML20198G753 | |
| Person / Time | |
|---|---|
| Issue date: | 12/23/1985 |
| From: | Ankrum G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20198G759 | List: |
| References | |
| FOIA-86-53, FOIA-86-54, FOIA-86-55 NUDOCS 8601070607 | |
| Download: ML20198G753 (9) | |
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o UNITED STATES
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DEC 2 31985 4
MEMORANDUM FOR:
Brian'K~. Grimes, Director Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement FROM:
G. Ted Ankrum, Chief Quality Assurance Branch Division of Quality Assurance, Vendor, and Technical Training Center Programs
SUBJECT:
FOREIGN TRIP REPORT:
MEETINGS WITH BUNDESANSTALT FUR MATERIAL PRUFUNG (BAM), BERLIN, GERMANY DATE:
October 3-4, 1985 LOCATION:
BAM, 87 Unter den Eichen, Berlin, FRG ATTENDEES:
See Enclosure,1 PURPOSE:
To discuss final arrangements for NRC to rely on BAM and TUV-Berlin as an agent for inspection of dry storage casks produced in the FRG.
SUMMARY
- The meeting on October 3, 1985 concentrated on discussion of mechanisms for securing agreement between NRC and BAM for NRC acceptance of BAM or TUV-Berlin inspections in lieu of NRC and licensee inspections.
The meeting con-cluded with agreement between the NRC and BAM counterparts on the proposed program and the draft text of an exchange of correspondence.
DISCUSSION:
General Nuclear Systems Incorporated (GNSI) is a joint venture of Gesellschaft fur Nuklear Systems (GNS) and ChemNuclear, engaged in the manufacture of a spent fuel dry storage cask.
Their CASTOR V cask is currently being y
reviewed for licensing under parts 71 and 72 by NRC-NMSS.
In support of the part 72 license application, NRC-IE has been reviewing th:: QA program for the manufacture of the casks.
During that review, an opportunity was seen for potential use of an in place third party inspection system as a substitute for certain NRC and licensee inspections.
GNS is seeking a German license for its CASTOR V casks, as well as a U.S. license.
The German licensing process requires a QA program and extensive QC inspections during manufacturing by an agency of the German government, the Bundesanstalt fur Material Prufung (BAM) or its designated representative, TUV-Berlin.
It appeared that it would be possible for the NRC to take advantage of these inspections.
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Brian K. Grimes,
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Theascheme arrived at is as follows:
1.
GNSI has submitted a QA Topical Report (QATP) for NRC approval.
In this.
QATR, GNSI has committed to seeking certification by the FRG competent authority that each CASTOR V cask being sold to a U.S. customer has been manufactured in accordance with FRG licensing requirements and is eligible for licensing in the FRG.
2.
GNSI has described the FRG licensing and inspection process in its QATR.
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3.
Both NRC and the FRG government agency (BAM) executing the actions in Germany have reviewed the QATR. The NRC has determined that the process, as described in the QATR, is at least equivalent to U.S. requirements. 'BAM j
has determined that the FRG process has been accurately described.
4.
NRC and BAM plan to exchange correspondence.
NRC will state that it has reviewed the GHSI QATR and finds it acceptable, provided it is accurate, and that the NRC plans to rely on the results of German inspections, subject-to periodic U.S. audits.
BAM will. state that the QATR accurately describes its inspection procedures, takes note'of NRC's plans to rely on BAM/TUV inspection and to audit BAM/TUV, and commits to informing the NRC if it discovers any conditions adveFse to quality.
I 5.
Upon completion of the exchange of correspondence, NRC will approve the l
GNSI QATR and at some time during the manufacture of a CASTOR V cask intended for U.S. licensing, will audit the implementation of the process in Germany and at approximately three year intervals, if there are continuing U.S. sales and licenses are being requested.
6.
The acceptance letter for the QATR will state that utility purchasers may rely on the results of the BAM inspections in Germany as their agent. The license applicants will continue to retain responsibility for the correct-ness of these inspections, however.
NRC will also accept the BAM inspections in lieu of performing its own implementation inspections.
TheresultisexpectedtobeareductionofforeigntravelrequirementsfoMC staff.
Note that the BAM/TUV inspection costs will be billed to GNSI, who plans to include the costs in the 'verall purchase price of the cask.
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l The draft exchange of correspondence is attached.
The QATR is available for inspection ~in the IE QA Branch files and under the docketed QATR application.
The meeting minutes of the October 3-4 me ting are also attached, f
t G. T. Ankrum, Chief 1
Quality Assurance Branch
(
Division of Quality Assurance, Vendor, j
and Technical Training Center Programs Office of Inspection and Enforcement
GENERALNUCLEAR SYSTEMS,INC.
A CFEM-NUCL:g,A COf#MNY A
135 Darlang Drrve
- Mm Connectcut 06001
- 203/67N457 i
DATE:
October 23, 1985 C8510-06 TO:
Distribution LOCATION:
Various FROM:
Kevin Kings 1 LOCATION:
Avon
SUBJECT:
Meeting Minutes - GNSI Qualf ty Assurance Topical Report, Berlin, FRG 3 October 1985 ATTENDEES:
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K. E. Wieser, BAM H. Kraus, BN1 G. T. Ankrum, U.S. NRC J. P. Roberts, U.S. NRC Dr. Ing R. Rudel, TUV-Berlin R. Bittner, GNS A. B. Bonifacio, GNSI K. R. Kingsley, GNSI A meeting was convened in the Berlin offices of the Bundesantalt fur fiaterialprufung (BR1) to discuss the contents of the Quality Assurance _ Topical Report submitteo by General Nuclear Systems, Inc. (GNSI) to the U.S. Nuclear Regulatory Commission (U.S.
NRC). This QATR provides for a cooperative agreement between the BN1 and NRC for c.artain U.S. licensed products manufactured in Germany for use in the United States.
inis meeting was held to perform a detailed review of the QATR contents, especially as related to the description of BNi activities for Compliance Assurance. Attached are OATP, Sections 6.0 through 8.0 revised to include wording as agreed during the meeting.
Any objections or further comments on these revised Sections should be directed to GNSI
( A. Bonifacio or K. Kingsley) as soon as possible.
The chronology of events to be followed for the remaining review effort of this (ATR will be as follows:
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GNSI will incorporate all NRC and BN1 coments into a new draft version of the QATR.
This draft will be made available to NRC, BN4, et al for concurrence of incorporated changes.
GNSI will formally submit the new revision to the NRC docket.
NRC will initiate correspondence to BN4 B#1 will respond to NRC corresponaence.
(Note:
It was further agreed at the meeting that the correspondence exchange should identify a contact person in each organization for efficient communication).
Pending BN1 concurrence of 0ATR accuracy as it relates to BN1 activities, NRC can issue approval of the OATR.
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ATTACHMENT TO QATR MEETDIG MINUTES 6.0 c0MPLIANCE ASSURANCE 6.1 PHYSIKALISCH - TECHNISCHE BUNDESANSTALT (PTB)/BUNDESANSTALT FUR MATERIALPRUFUNG (BAM), FRG 6.1.1 Certificate of Approval - PTB is the Competent Authority of FRG:and issues a Certificate of Anproval for the manufacture of items that are important to Safety. A condition of the Certificate of Ap;;roval is evaluation and acceptance of the manufacturer's Quality Assurance Program by the BAM.
6.1. 2 Evaluation of Quality Assurance Programs - BAM shall be responsible for evaluating Quality Assurance Programs of GNS and their subsuppliers in FRG. PTB also contributes in the evaluation of Quality Assurance Prograns as far as certain physical test procedures (e.g. shielding, dose rate, criticality) are concerned.. Approval and acceptance of the manufacturer's quality assurance program shall be granted by B#1 on behalf of PTB.
6.1. 3 Audit of Quality Assurance Program - BAM and/or experts designated by them, normally TUV, Berlin shall perform audits of GNS and their subsuppliers to verify compliance with all aspects of their Quality Assurance Program and to determine its effectiveness.
6.1.4 Inspections - The following inspection requirement is established by BAM on behalf of PTB.
A. Inspection Plan - Inspection planning is to assure that the stipulations of the authorization for manufacturing licensed products are maintained by means of suitable fabrication and inspection plans. The plans should be documented using PTB/BN1 Standard Fom, Fertigungs - u.
Pruffolgeplan (FPP - Fabrication and Test Plan) and shall be reviewed by BAM and/or experts designated by th,em prior to use. During the review, BAM and/or l
experts designated by them shall assign their Witngsl and Hold points in the FPP. See Exhibit A.
The
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l following information must be included or referenced in this plan.
Specification of work and inspection in the form of work and test instructions, including qualitative and quantitative acceptance criteria.
Time periods or limits for the activity to be performed.
Specification of data to be maintained in the form of technical drawings, material specification, procedures, instructions, etc.
Person (s) responsible for perfoming, witnessing or-certifying the activityNication and documentation Type and extent of ver required.
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B. In-Process Inspection - In-Process Inspections must be performed in accordance with the requirements stipulated in the FPP.
Inspections shall be determined by the importance of the item or feature influenced by the: manufacturing process. Test results must be verified against procedures, drawings, applicable codes and standards and recorded in the FPP. The following activities are typical Witness and Hold Points and shall be inspected, witnessed and verified by BAM and/or experts designated by them during the manufacturing of licensed products.
ACTIVITY ITEM
- GNS DOCUMENT USED
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- Ultrasonic Examination (UT)
Cask Body PV 10 Trunnions PV 12 Primary Lid (P)
PV 11 Secondary Lid (S)
PV 11 P and S Bolts PV 13 Trunnion Bolts PV 13
- Identification (Stamping Cask Body WB 02 and re-stamping during Trunnions WB 12 cutting / machining) of Radionox Plates for materials and test spec-Fuel Baskets WB 15/18 WB 16/1 imens and Examination Primary Lid WB 20 of Mechanical Properties Bottom Closure Plate WB 6 including Spectroscopic Secondary Lid WB 20 and Boron content Exam-P & S Bolts WB 14
'ination of Radionox Trunnion Bolts WB 13 Plates for Fuel Basket.
Blind Flanges WB 6
- Dimensional Examination Cask Body A 500.11-02/3 and Final Identification Trunnions C 500.11-12 check.
Primary Lid A 500.11-20 Bottom Closure Plate E 500.12-29 Secondary Lid A 500.11-55/2 1
4 0 & S Bolts MUN 601.11/2 Trunnion Bolts MUN 601.11/2 Blind Flanges E 528.13-89
- Surface Cracks Examination Trunnion Housing and Sealing Surfaces on Cask Body PV 20 Trunnions PV 22 Primary Lid PV 21 Secondary Lid PV 21
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P & S Bol ts PV 23 or PV 26 Trunnion Bolts PV 23 or PV 26
- Leak Test Completed Cask (Primary and Secondary Lids)
PV 32-1
- Procedures, Drawings, Material Specification, etc.
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- C. Final Insxction - After manufacturing, each completed item which is important to safety will be inspected prior' to final acceptance and use. This inspection sh'all be performed by BAM and/or experts designated by' them. The final inspection will be classified according to their safety significance. The graded approach will be contained in the FPP. Part of the final inspection shall be verification of documents as to completeness and accuracy.
6.1.5 Certification - After final inspection, documentation review and evaluation of test results, BAH will issue a Certi ff.cate. This Certificate will confirm that the material, parts, or completed component or cask system was manufactured in accordance with the requirements of the*
FPP. The Certification will be a part of the Final Docuwntation/ Quality Assurance Record.
6.1.6 Enforcement - An essential part of any Compliance Assur-ance Program is a system for enforcement of regulatory compliance. The FRG Federal Law for Transport of Dangerous Go6ds does not apply to items manufactured for use in the U.S.
However, NRC is placing reliance on the
- BAM inspection process fdr its own purposes. Accordingly, BAM will inform NRC in writing of any information which could result in enforcement action under the FRG Federal Law for Transport of Dangerous Goods. The NRC may use this information as necessary for U.S. enforcement purposes.
l 6.2 NUCLEAR REGULATORY C0ffilSSION (NRC), USA
- 6. 2.1 Evaluation of Quality Assurance Program - NRC shall be responsible for evaluating Purchaser-Utilities and GNS Quality Assurance Program and this QATR. Approval andI acceptance of Purchaser-Utilities and GNS Quality 1
Assurance Program and this QATR shall be granted by NRC prior to use.
6.2.2 Audit of Quality Assurance Program - NRC may perform a programmatic review / audit of BAM, GNS and their subsuppliers in FRG to verify compliance with all aspects of their Quality Assurance Programs and this QATR and to determine their effectiveness. NRC will perform programmatic reviews / audits at its discretion.
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6.2.3 Inspections - To verify the effectiveness of the GNS and.
their subsupplier Quality Assurance Programs, the NRC is depending on the BAM Compliance Assurance activities to assure that the items are manufactured and documented in accordance with the licensed design. The NRC has satisfied itself through review of this QATR and the audit described in item 6.2.2 above that such assurance can be achieved.
6.2.4 Enforcement - U.S. WRC's enforcement action shall be in accordance with 10 CFR Part 2 Appendix C.
NRC shall apply enforcement action (s) depending en the safety implications of the circumstances of the non-compliance. The
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application of enforcement sanctions.shall be carried out in the appropriate manner applicable to the legal frame work of the U.S. NRC shall also evaluate all non-compliances and violations reported by BAM for potential enforcement action.
7.0 NON-COMPLIARCES AND DEFECTS (10CFR Part 21) 7.1 GNSI, GNS and their subsuppliers shall comply with the requirements of 10CFR Part 21 and shall advise the NRC immediately of any non-compliance or defects. Any person employed by GNSI, GNS and their subsuppliers obtaining information which reasonably indicates that a product or activity or basic component supplied by them faf1s to comply with the Atomic Energy Act of 1954 as amended, or any applicable rule, regulation, order or license of the NRC relating to substantial safety hazards or, contains defects which would create a substantial safety hazard as defined by regulations which the NRC shall promulgate; shall immediately notify their management of such failure or defect for proper evaluation and reporting to the NRC in accordance with 10CFR Part 21.
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7.2 The GNSI Project Manager shall be responsible for official reporting i
l of non-compliance or Defects to the NRC, BAM and Purchaser-Utilities.
8.0 00ALITY ASSURANCE RECORDS 8.1 All records providing documentary evidence of the quality of the item and activities affecting quality shall be maintained throughout the life of the item by GNSI and/or the Purchaser - Utilities.
8.2 Quality Assurance Records will be submitted by GNS to GNSI for proper distribution and maintenance. The Project Manager shall be responsible for the distribution and maintenance of Quality Assurance Records.
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8.3 All Quality Assurance Records shall be made available by GNSI, GNS and their subsuppliers to NRC, BAM, Purchaser - Utilities, their agents, experts, consultants and others designated by NRC, BAM and Purchaser - Utilities.
8.4 The Quality Assurance Records described in this section shall include only the following:
8.4.1 BAM Certification 8.4.2 Index to the QA Records
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8.4.3 As-built Drawings 8.4.4 Material Control Documents (Traceability) 8.4.5 Certified Material Test Reports (CMTR) and Certificates of Conformance/ Compliance (C of C) 8.4.6 Weld Data Reports (weld history) 8.4.7 Welding Procedures and Qualification Records 8.4.8 Heat Treatment Procedures and Reports 8.4.9 Non-destructive Examination Procedures and Reports 8.4.10 Repair Procedures and Repair Records 8.4.11 Test Procedures and Reports (Hydro, Leak, Load, etc.)
8.4.12 Fabrication and Test Plan (FPP).
8.4.13 Non-conformances and Corrective Actions.
- I 8.4.14 Any other documents generated during manufacturing of the item specified and required by the NR', BMt and Purchaser
- Utilities
9.0 CONCLUSION
9.1 This QATR describes the systematic evaluation and documentation of performance judged against regulatory requirements, technical codes
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and engineering standards. The Quality Assurance and Complaince Assurance Program articulated in this QATR will provide assurance that regulatory requirements are being met.
0193V 18 of 18
F1 e
fir. Victor Stello, Jr.
Acting Executive Director for Operations U.S. Nuclear Regulatory Connission Washington, DC 20555
Dear _Mr. Stello:
We have received your letter of asking that we confirm certain aspects of the Federal Republic of Germany quality assurance and quality control inspection program for dry spent fuel shipping and storage casks manufac'tured by Gesellschaft fur Nuklear-Service mbH for sale to U. S. utilities. We wish to confirm that we have reviewed General Nuclear Systems, Inc., Quality Assurance Topical Report No. 29004-FRG2 of October 10, 1985, and agree that the processes attributed to the Bundesanstalt fur Material Frufung (BAM) and Physikalisch-Technische Bundesanstalt (PTB) are accurately described and that we will be pleased to cooperate in audits by the USNRC or US purchaser utilities of the inspection processes described in the topical report.
We are fully aware of the importance of your reliance on the BAM and PTB inspection and certification process for US licensing and we wish to assure you that these inspection and certification efforts will be given the same care and attention as if the casks were to be licensed in the Federal Republic of Germany. We also will inform you of any circumstances of which we may become aware which would adversely affect use of the casks for their intended purpose.
/s/
}
ENCL (2)
W&
t GOVERNiMENT ACCOUNTADILITY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 Washington. D.C. 20036 (202)232-8550 January 13, 1986 FREEDOM OF INFORMATION ACT Director HIEEDOM og g.47 Office of Administration ACI REQUE -
Nuclear Regulatory Commission F
hk- $]
Washington, D.C.
20555 I
To Whom It May Concern:
k helhb Pursuant to the Freede*n of Information Act.("FOIA"). 5 USC section 552, the Government Accountability Project (GAP),and the Trial Lawyers for Public Justice (TLPJ) request copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, policy discussion papers, recommenda-tions, SECY papers, telephone messages, voice recordings, and any other information compilation or issuances and any and all other records or reports generated or prepared by Victor Stello beginning with his appointment as Acting Executive Director.
This request should be broadly construed to include all the daily activity logs of Mr. Stello, and any documents generated by his office staff and over which he excercises control.
We expect that this request will produce records of all meetings Mr. Stello has with any industry representatives, such as representatives of NUMARC, or the Atomic Industrial Forum including all records of conversations with Mr. Stello's predecessor.
This request includes all agency records, whether they currently exist in the NRC official," working," investigative or other files, or at any other location, including private residences.
If any records as defined in 10 C.F.R. 9.3a(b) and the NRC manual, and covered by this request have been destroyed snd/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s).
GAP and TLPJ request that fees be waived, because " finding i
the information can be considered as primarily benefitting the general public," 5 USC section 552 (a) (4) (a).
CAP is non-profit, non-partisan public interest organization concerned with honest and open government.
Through public outreach, the Project
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January 13, 1986 Page Two promotes whistleblowers as agents of government accountability.
The Trial Lawyers for Public Justice's Citizen Legal Clinic is also a non-profit, public interest group which assists individuals throughout the country to right intentional or unintentional wrongs caused by the actions of others.
TLPJ is assisting citizen intervenors in several cases now before the NRC.
We are requesting the above informatiion as part of an ongoing monitoring project on the adequacy of the NRC staff's performance of their responsibilities in protecting public health and safety.
For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and derscribing the documents or portions of documents withheld.
The iindex should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld.
This index is required under Vaughn v. Rosen (I), 484 F.2d.
section 820 (D.C. Cir. 1973), cert. denied, 415 U.S.
section 977 (1974).
We look forward to your response to this request within ten days.
Sip'ncerely
's \\N..
Billie Pirner Garde BPG:41901 l
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a GOVERNMENT ACCOdtHADILITY PROJECT 1555 Connecticut Avenue, N.W Suite 202 (202)232-8550 Washington, D.C. 20036 January 20, 1986 FREEDnM OF INFORMATION ACT FRdEDOM OF INFORMATION ACT REQUE.ST O
of Administration Nuclear Regulatory Commission Washington, D.C.
20555 j
To Whom It May Concern:
Pursuant to the Freedom of Information Act ("FOIA"). 5 USC section 552, the Government Accountability Project (GAP) and the Trial Lawyers for Public Justice (TLPJ) request copies of,any and all agency records and information, including but not limited to notes, letters, memoranda, draf ts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, policy discussion papers, recommenda-tions, SECY papers, telephone messages,.-voice recordings, and any other information compilation or issuances and any and all other records or reports generated or prepared by Victor Stello beginning with his appointment as Acting Executive Director.
This request should be broadly construed to include all the daily activity logs of Mr. Stello, and any documents generated by his office staff and over which he excercises control.
We expect that this request will produce records of all meetings Mr. Stello has with any industry representatives,.such as representatives of NUMARC, or the Atomic Industrial' Forum including all records of conversations with Mr. Stello's predecessor.
This request includes all agency records, whether they currently exist in the NRC official," working," investigative or other files, or at any other location, including private residences.
If any records as defined in 10 C.F.R. 9.3a'(b) and the NRC manual, and covered by this request have been destroyed snd/or removed after this request, please provide all surrounding l
records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s).
GAP and TLPJ request that fees be waived, because " finding i
the information can be considered as primarily benefitting the l
general public," 5 USC section 552 (a) (4) (a).
GAP is non-profit, non-partisan public interest organization concerned with honest and open government.
Through public outreach, the Project sf _ hl A f fw ow r v
January 20, 1986 Page Two promotes whistleblowers as agents of government accountability.
The Trial Lawyers for Public Justice's Citizen Legal Clinic is also a non-profit, public interest group which assists individuals throughout the country to right intentional or unintentional wrongs caused by the actions of others.
TLPJ is assisting citizen intervenors in several cases now before the 11RC.
We are requesting the above informatiion as part of an ongoing monitoring project on the adcquacy of the NRC staff's performance of their responsibilities in protecting public health and safety.
For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and derscribing the documents or portions of documents withheld.
The lindex should previde a detailed justification of your grounds for claiming each <2xemption, explaining why each exemption is relevant to the document or portion of the document withheld.
This index is required under Vaughn v. Rosen (I), 484 F.2d.
section 820 (D.C. Cir. 1973), cert. denied, 415 U.S.
section 977 (1974).
We look forward to your response to this request within ten days.
Signcerely,
@ dD tb Billie Pirner Garde BPG:41901 C
\\
' GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 (202)232-8550 Washington. D.C. 20036 January 27, 1986 FREEDOM OF INFORMATION ACT J A>M ')r iNi Uw.r 4 Director m q. p y
- . r Office of Administration Nuclear Regulatory Commission FO-M^Pb-((
Washington, D.C.
20555
'2nd, l-a Hs To Whom It May Concern:
Pursuant to the Freedom of Information Act ("FOIA"). 5 USC section 552, the Government Accountability Project (GAP) and the Trial Lawyers for Public Justice (TLPJ) request copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, policy discussion papers, recommenda-tions, SECY papers, telephone messages, voice recordings, and any other information compilation or issuances and any and all other records or reports generated or prepared by Victor Stello beginning with his appointment as Acting Executive Director.
This request should be broadly construed to include all the daily activity logs of Mr. Stello, and any documents generated by his office staff and over which he excercises control.
We expect e
that this request will produce records of all meetings Mr. Stello has with any industry representatives, such as representatives of NUMARC, or the Atomic Industrial Forum including all records of conversations with Mr. Stello's predecessor.
This request includes all agency records, whether they currently exist in the NRC official," working," investigative or other files, or at any other location, including private residences.
If any records as defined in 10 C.F.R. 9.3a(b) and the NRC manual, and covered by this request have been destroyed snd/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s).
GAP and TLPJ request that fees be waived, because " finding the information can be considered as primarily benefitting the general public," 5 USC section 552 (a) (4) (a).
GAP is non-profit, non-partisan public interest organization concerned with honest and open government.
Through public outreach, the Project A P P'
1 January 27, 1986 Page Two promotes whistleblowers as agents of government accountability.
The Trial Lawyers for Public Justice's Citizen Legal Clinic is also a non-profit, public interest group which assists individuals throughout the country to right intentional or unintentional wrongs caused by the actions of others.
TLPJ is assisting citizen intervenors in several cases now before the IIRC.
We are requesting the above informatiion as part of an ongoing monitoring project on the adequacy of the NRC staff's performance of their responsibilities in protecting public health and safety.
For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and derscribing the documents or portions of documents withheld.
The iindex should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld.
This index is required under Vaughn v. Rosen (I_l, 484 F.2d.
section 820 (D.C. Cir. 1973), cert. denied, 415 U.S.
section 977 (1974).
We look forward to your response to this request within ten days.
Signcerely, d u (v. -
Billie Pirner Garde BPG:41901 1
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