ML20205D685

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Discusses Results of Licensed Operators Requalification Exams Administered During Wk of 860203.Requalification Training Program Unsatisfactory & Not INPO Accredited.Exams Prepared & Administered Per NRR Guidance & NUREG-1122
ML20205D685
Person / Time
Site: 05000000, Turkey Point
Issue date: 03/19/1986
From: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20205D576 List:
References
FOIA-86-126, FOIA-86-127, FOIA-86-131, FOIA-86-166, FOIA-86-201, FOIA-86-209, FOIA-86-263, FOIA-86-80, FOIA-86-82, RTR-NUREG-1122 NUDOCS 8608180145
Download: ML20205D685 (4)


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March 19, 1986 p

,I MEMORANDUM FOR: Victor Stello, Jr., Acting Executive Director for Operations FROM:

J. Nelson Grace, Regional Administrator

SUBJECT:

TURKEY POINT REQUALIFICATION EXAMINATIONS As we discussed by telephone last week, nine of thirteen licensed operators failed requalification examinations administered by Region II at Turkey Point

'during the week of February 3, 1986. Detailed results are as follows:

7 Number Number Examined Failed h

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4 Written and oral examinations were administered to a random sample of operators representing about 24% of the licensed staff at the station. Simulator examina-tions were not given since there is no site-specific simulator for Turkey Point.

These were the first requalification examinations to be administered by the NRC at Turkey Point.

In answer to your question of last ' week, the examiners were different from those who administered the Browns Ferry exam. NRR:DHFS has reviewed the written exams and supports their validity. The exam results indi-cate that the licensee's requalification training program at Turkey Point is unsatisfactory. This program has not been accredited by INPO.

We have administered requalification examinations to operators at eleven power reactor sites in this Region since the program was begun in 1983, and two of the i

sites (Brunswick and Sequoyah) have been examined twice - passing both times.

Initial examination results have revealed training programs to be satisfactory at seven of these sites (based upon 60% of the operators passing), and unsatisfac-tory at four.

The Turkey Point examinations were prepared and administered in accordance with program guidance provided by NRR and utilized the "Knowledges and Abilities Catalog for PWR Operators" (NUREG 1122). You may recall that NUREG 1122 is based upon the INP0 job task analysis for power reactor operators and assigns impor-tance rating factors to each of the cataloged items of knowledge and ability.

The written examinations and answer keys were reviewed by the utility immediately following examination administration and most utility comments were incorporated.

We will, of course, consider any additional comments the utility may have following their detailed review of examination results.

Region II is discussing actions to be taken in response to the examination results with NRR and Florida Power and Light Company (FP&L). Since the opera-tional proficiency of the plant staff is in question, expeditious resolution of 8608180145 060725 y

PDR FOIA GARDE 86-80 PDR

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Victor Stello, Jr.

2 March 19, 1986 this matter is receiving high priority in Region II. Turkey Point 4 is currently shut down for refueling and is scheduled to restart on May 7.

Turkey. Point 3 is shut down to resolve maintenance, surveillance testing, and design problems by the licensee. FP&L hopes to restart Unit 3 next week.

cc: Harold Denton, NRR I

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GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 February 10, 1986 i

FREEDOM OF INFORMATION ACT Director gREg;OM OF INFORM A M-Office of Administration Ac7 oFOttfST Nuclear Regulatory Commission

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RAc b 2-// -G 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 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. Stellots 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

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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 recards which l

have been or are destroyed and/or removed, a description of the I

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 co'cerned with honest n

and open government.

Through public outreach, the Project

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1 February 10, 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 informatilon 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.

Sioncerely, kh Billie Pirner Garde BPG:41901 l

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I GOVERNMENT ACCOUNTABluTY PROJECT 1555 Connecncut Awnue, N.W., Suite 202 (202)232-8550 Washington, D.C. 20036 February 3, 1986 FREEDOM OF INFORMATION ACT M

F INFORMATto e Director ACT 9EQUEST Office of Administration Nuclear Regulatory Commission Q{

gggg Washington, D.C.

20555 Glu d 2.-2 44, 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 <3f Mr. Stello, and any documents generated by l

his office staff and over which he excercises control.

We expect that this request will produce records of all meetings Mr. Stello j

has with any industry representatives, such as representatives of l

NUMARC, or the Atomic Industrial Forum including all records of l

conversations with Mr. Stello's predecessor.

This request includes all agency records, whether they I

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 provido 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).

l 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, l

non-partisan public interest organization concerned with honest and open government.

Through public outreach, the Project

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February 3, 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 informatilon 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.

Signcerely, ib Billie Pirner Garde BPG:41901 l

',*4 GOVERNMENT ACCOUNTABluTY PROJECT 1555 Connecticut Awnue, N.W., Suite 202 Washington, D.C. 20036 (202)232-6550 February 24, 1986 FREEDOM OF INFORMATION ACT FREEDOM OF INFORMAUON Director ACT REQUESr Office of Administration

~b Nuclear Regulatory Commission Washington, D.C.

20555 ggg 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 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. Stallo's predecessor.

This request includes all agency records, whether they currently exist in the NRC official," working," investigative er 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 and/or removed after this request, please provide all surrounding records, including but not limitad 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).

i 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 i

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a February 24, 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 informatilon 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 lindex should provide a detailed justification of your grounds 4

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.

Sincerely, NW G

Billie Pirner Garde

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GOVERNMENT ACCOUNTABlU1Y PROJECT 1555 Connecticut Awmue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 March 3, 1986 FREEDOM OF INFORMATION ACT FREEDOM OF INFORMATION ACT RE Fora -QUEST 24r Director Office of Administration t

Nuclear Regulatory Commission g#$

di-9k Washington, D.C.

20555 To Whom It May Concern:

Pursuant to the Freedom of Information Act ("FOIA"), 5 USC section 552, the Government Accountability Project (GAP) and the 1

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-l -

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 Stallo beginning with his appointment as Acting Executive Director.

l This request should be broadly construed tio include all the l

daily activity logs of Mr. Stallo, and any documents generated by

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l 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 and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to 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 Q[,lldGV2pf

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o March 3, 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 informatilon 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 roquest within ten days.

Sincerely,

\\b Billie Pirner Garde BPG:41901 l

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1 GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecncut Awnue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 February 17, 1986 FREEDOM OF INFORMATION ACT FREEDOM OF INFORMATr0N Director ACT REQUEST Office of Administration 60ZA -841-/3/

Nuclear Regulatory Commission h 8*7 Washington, D.C.

20555 To Whom It May Concern:

i Pursuant to the Freedom of Information Act ("FOIA"), 5 USC section 552, the Government Accountability Project (GAP) and the

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l Trial Lawyers for Public Justice (TLPJ) request copies of any and l

all agency records and information, including but not limited to l

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 and/cr removed after this request, please provide all surrounding l

records, including but not limited to a list of all records thich have been or are destroyed and/or removed, a description of tnc action (s) taken relevant to, generated in connection with, ansi /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 3bj91? f 55% 0 f i

f

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February 17, 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 informatilon as part of an.

ongoing monitoring project on the adequacy of the NRC staff's performance of their responsibilities in p'rotecting 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.

Sincerely, Ov--

Billie Pirner Garde BPG:41901 i

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Y GOVERNMENT ACCOUNTABlUTY PROJECT 1555 Connecticut Awnue, N.W., Suite 202 Washington, D.C. 20006 (202)232-8550 March 10, 1986 FREEDOM OF INFORMATION ACT Director FRELDOM OF INFORMATION h 7 [ QUEST-k- / h h ACT RE Office of Administration Nuclear Regulatory Commission Washington, D.C.

20555

'd J~/3-f6 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. Stallo, 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 and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to 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

& Q.l $ 3.S ? 2pp

h March 10, 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 vrongs caused by the actions of others.

TIPJ 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.

Sincerely, U

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Billie Pirner Garde BPG:41901 I

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GOVERNMENT ACCOUNTABIUTY PROJECT 1555 Connectrut Avenue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 March 17, 1986 FREEDOM OF INFORMATION ACT Director Office of Administration FREEDOM OF INFOf(MATION Nuclear Regulatory Commission ACT REQUEST Washington, D.C.

20555 g y._ f 6 2 C /

To Whom It May Concern:

b 'c/ 3 V h NP 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 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 I

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 and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to 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 1

s n rir?!'l / !_ jag).

s i qup11 if'*'

lo

l March 17, 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 intervanors in several cases now before the NRC.

We are requesting the above information 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 axemption, 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.

Sincerely, N

IW Billie Pirner Garde BPG:41901 l

l l

l 1

FV t

GOVERNMENT ACCOUNTABluTY PROJECT 1555 Connecticut Awnue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 March 24, 1986 FREEDOM OF INFORMATION ACT FREEDOM OF INFORMAT10N j

ACT REQUEST Director Office of Administration S1 AO~

3 Nuclear Regulatory Commission

'~ R g Q 3 g. 2 6 Washington, D.C.

20555 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, remoranda, 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 l

his office staff and over which he excercises control.

We expect l

that this request will produce records of all meetings Mr. Stello ha: with any industry representatives, such as representatives of NUMARC, or the Atomic Industrial Forum including all records of conversations with Mr. Stallo'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 and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to 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, i

non-partisan public interest organization concerned with honest l

and open government.

Through public outreach, the Project

_gf 93 Y f ?$9 ff

E March 24, 1986 Page Two s

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 intervanors in several cases now before the NRC.

We are requesting the above informatilon 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 l

relevant to the document or portion of the document withheld.

This index is required under Vaughn v. Rosen (I), 484 F.2d.

I 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.

Sincerely,

\\W l

Billie Pirner Garde l

BPG:41901 l

r

GOVERNMENT ACCOUNTABILm' PROJECT 1555 Connecticut Avenue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 March 31, 1986 FREEDOM OF INFORMATION ACT g

Director ACI EN Office of Administration

$ 7A-/f,-eMP3 Nuclear Regulatory Commission Gadd 4"//*8b Washington, D.C.

20555 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, volca 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 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 descripticn of the action (s) taken relevant to, generated f.n 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 censidered 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 g71?f ?O-h

1 s4 s

March 31, 1986 Page Two I

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.

i We are requesting the above information as part of an j

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, pleans 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.

l Sincerely,

\\W Billie Pirner Garde BPG:41901 l

l l

l

Od6

/

%qk UNITED STATES

[

p NUCLEAR REGULATORY COMMISSION i

f wAsHWGTON, D. C. 20555 5

FEB 08 W MEMORANDUM FOR:

John G. Davis, Director, NMSS Harold R. Denton, Director, NRR Robert B. Minogue, Director, RES James M. Taylor, Director. IE Clemens J. Heltemes, Director, AEOD Guy H. Cunningham, Executive Legal Director Ronald M. Scroggins, Director, RM Thomas E. Murley, Regional Administrator, Region-I J. Nelson Grace, Regional Administrator, Region-II James G. Keppler, Regional Administrator, Region-III Robert D. Martin, Regional Administrator, Region-IV John B. Martin, Regional Administrator, Region-V FROM:

Victor Stello, Jr.

Acting Executive Director for Operations

SUBJECT:

DAVIS-BESSE EVENT LESSONS LEARNED Reference 1:

Memorandum dated November 26, 1985, Dircks to Denton et al, 4

" Davis-Besse Event - NRC Lessons Learned" Reference 2:

Memorandum dated January 13, 1986, Sniezek to Davis et al,

" Agenda for NRC Lessons Learned Meeting" On January 16, 1986, I discussed with you or representatives of your offices, actions we should take to improve our internal agency operations as a result of insights we have gained thus far from the Davis-Besse and (to a limited extent) the Rancho Seco events. Enclosed is the summary of that meeting which documents the decisions we reached and delineates which senior managers are responsible to develop and implement the initiatives taken and the time frames for accomplishing these important objectives.

If for some reason these schedules cannot be met, discuss the specifics with me and I will consider what actions must be taken.

I was impressed by the frank and constructive nature of the coments provided by you in advance of the meeting (which helped determine the topics and focus the discussion during the meeting).

In particular, I want to commend the spirit of interoffice cooperation that was apparent and contributed to the in depth treatment given the important and challenging topics covered in the meeting. The scope and depth of discussions clearly demonstrated the staff's ability to retrospectively examine our operations and initiate necessary improvements. This continued cooperation will be a crucial factor in accomp-lishing the specific tasks delineated in the meeting sumary and is necessary for accomplishing efficient management in the future.

R O.IS$ 3 N 2 f f

2 I know from our discussions of these matters that all of you understand the importance of following through effectively in the areas for improvement that have been identified. Jim Conran of the ROGR staff is the cognizant individual within the EDO office responsible for monitoring the status of these tasks.

Each program office and regional office should identify a point of contact to Mr. Conran.

4 I anticipate further meetings of this type regularly to discuss with you progress in these important areas.

j l

Original signed by Victor Stello Victor Stello, Jr.

Acting Executive Director for Operations

Enclosure:

Meeting Summary and Attachment cc:

J. Sniezek J. Roe T. Rehm i

l

" Distribution

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JSniezek l

WSchwink JConran DEDROGR cf Central File ED0 rf

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EDO

__..____:.._.j g __.:_...._______:-_..____....:.........__

NAME on n

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__...:........____:..I._*_.....::...'_ek DATE :2/3/86

2/3 /86
2/ 4 86
2/[f/86 OFFICIAL RECORD COPY

I.

February 5,1986 For:

The Commissioners From:

Victor Stello, Jr.

Acting Executive Director for Operations

Subject:

FINAL GAO REPORT ENTITLED " NUCLEAR REGULATION - PROCESS FOR BACKFITTING CHANGES IN NUCLEAR PLANTS HAS IMPROVED"

Purpose:

Approval of a response to Congress on actions taken on GA0 recomendations (pursuant to Section 236 of the Legislative Reorganization Act of 1970).

Discussion:

The GA0 report includes two specific recomendations (Chapter 3, pp. 70-71 of the report). Both these recom-mendations pertain to the agency's plant-specific back-fitting procedures as described in the NRC Manual Chapter 0514.

The first recomends that the Chairman, NRC, revise the agency's plant-specific backfitting procedures to explicitly state that the NRC staff is responsible for identifying and processing, in accordance with the plant-specific backfitting procedures, all new or amended plant-specific positions taken by the staff.

The second recomends that the procedures be revised to explicitly state that to qualify as a plann-specific back-fit, the technical basis for a new or revised staff position taken must be unique to a specific plant or plant location.

The staff agrees with the substance of the first recom-mendation. A change responsive to the first recomenda-tion was incorporated in the Manual Chapter (Section 042, page 11, Final Version) submitted for Comission approval by memorandum from the EDO to the Comission dated November 13, 1985. We differ with GA0 with respect to the second

Contact:

Thomas H. Cox, ROGR Staff

[fy 492-4357 y

"J$O07 if *

. 5 recomendation. Our definition of plant-specific, already included in tha Menual Chapter in Section 01, Purpose, says in effect that a position applied to two or more plants at the 532 site would be a generic position.

This definition is cTaar and has caused no problems in application. The GA0.:lefinition could cause a position unique to a plant Tocation to.be interpreted as plant-specific even though that position may be applicable to more than two essentially different plants at that location. Therefore, we choose to not include the phrase

... or plant location" in the definition. However, for additional clarity, I propose to include our current definition in the first paragraph ~of Section 052 (definition of plant-specific backfit) of the Manual Chapter, as follows:

"Backfitting is plant-specific when it is limited to the imposition of a position that is unique to a specific plant."

Both these proposed responses to the GAO recomendations are presented in Enclosure 1 which would be enclosed with the proposed letter to Congress in fulfilltrent of the reporting requirement.

Recommendation:

That the Comission approve the proposed response to Congress.

Victor Stello, Jr.

1 Acting Deputy Executive Director for Operations

Enclosures:

1 1.

Response to GA0 Recommendations 2.

Proposed Letter to Congress

i ENCLOSURE 1 l

Response to GA0 Recommendations Contained in

" Nuclear Regulation - Process for Backfitting Changes in Nuclear Plant Has Improved" GA0/RCED-86-27 December 1985 Chapter 3 - Recommendations to the Chairman, Nuclear Regulatory Connission.

GA0 recognized that the NRC has a comprehensive backfitting management system in place that relies on its backfitting regulation (10 CFR 50.109) as its foundation. GAO recommended two revisions to the system's plant-specific backfit management procedures to provide additional assurance that the system is operating effectively:

1.

A revision to explicitly state that the NRC staff is responsible for identifying and processing, in accordance with the plant-specific backfitting procedures, all new or amended plant-specific positions taken by the staff.

NRC Response:

The NRC agrees with the substance of this recommendation. Statements conveying

~ this direction are introduced at the beginning of Section 042 of the NRC Manual Chapter 0514, " Identifying Plant-Specific Backfits."

2.

A revision to explicitly state that to qualify as a plant-specific backfit, the technical basis for a new or revised staff position taken must be unique to a specific plant or plant location.

NRC Response:

The NRC differs with the substance of this recommendation. The NRC definition of plant-specific, already included in the Manual Chapter in Section 01, Purpose, says in effect that a position applied to two or more plants at the same site would be a generic position. This definition is clear and has caused no problems in application. The GA0 definition could cause a position unique to a plant locatia to be interpreted as plent-specific even though that position may be applicable to two or more essentially different plar,ts at that location. Therefore, the NRC chooses to not include the phrase ".., or plant location" in the definition. However, for additional clarity, the liRC will include its preferred definition in the first paragraph of Section 052 (definition of plant-specific backfit) of the Manual Chapter, as follows:

"Backfitting is plant-specific when it is limited to the imposition of a position that is unique to a specific plant."

[

\\

UNITED STATES S

NUCLEAR REGULATORY COMMISSION 5

WASHINGTON,Dr 20555

\\*****/

\\

OFFICE OF THE CHAIRMAN The Honorable William V. Roth, Jr.

thaiman, Comittee on Governmental Affairs United States Senate Washington, DC 20510

Dear Mr. Chairman:

In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recomendations made by GA0 in their report

~

entitled, " Nuclear Regulation - Process for Backfitting Changes in Nuclear Plants Has Improved."

l The Comission has responded to the two specific recomendations made by GA0.

These recomendations pertained to statements in 'the NRC aCency-level written procedures directing the program for managemsnt of plant-Specific backfitting of nuclear power plants. The Comission issued a formal regulation governing NRC management of backfitting (10 CFR 50.109 and other conforming amendments),

effective on October 21, 1985. The procedures reviewed by GA0 have recently been revised to conform with the new regulation and those procedures also include most of the substance of the revisions recommended by GAO. The new regulation and agency internal procedures for both plant-specific and generic backfitting form a strong foundation for continued NRC improvement in the management of backfitting.

l As recognized by GAO, these and several other important new initiatives in backfit management are at most only a year old. The NRC is looking forward to integrating and effectively applying the various initiatives as rapidly as possible to yield measurable improvements in the overall backfit management l

program, Specific responses to the GA0 recomendations are presented in the Enclosure.

l Sincerely, Nunzio J. Palladino Chairman

Enclosure:

Responses to GA0 Recomendations cc: Sen. Thomas F. Eagleton (Identical 1trs will be sent to those onattached list)

L The Honorable Jack Brooks, Chairman Committee on Government Operations United States House of Representatives Washington, DC 20515 cc: Rep. Frank Horton The Honorable Alan Simpson, Chairman Subcommittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, DC 20510 cc: Sen, Gary Hart The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United' States House of Representatives Washington, DC 20515 cc: Rep. Manuel Lujan The Honorable Edward J. Markey, Chairman Subcommittee on Energy Conservation and Power Committee on Energy and Commerce United States House of Representatives Washington, DC 20515 cc: Rep. Carlos Moorhead The Honorable Charles A. Bowsher Comptroller General of the United States Get.eral Accounting Office Washington, DC 2054G The Honorable James C. Miller, III Director Office cf Management and Budget Washington, DC 20503 l