ML20206D650

Forwards Critique of Criticisms of Lpdrs Contained in Critical Mass Article & Nader/Pollock Ltrs,List of Actions & Resources Required to Upgrade Lpdr Program & Dillehay to Souder

ML20206D650
Person / Time
Issue date:	12/17/1980
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Ahearne NRC COMMISSION (OCM)
Shared Package
ML20206D645	List: IA-88-411, Partially Withheld Commission Paper Requesting Approval of Changes in Policy Re Duration & Location of Lpdrs & Documents Supplied to Lpdrs ML20206D650 ML20206D680 ML20206D733
References
FOIA-88-411 NUDOCS 8811170192
Download: ML20206D650 (12)

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NUCLEAR REGULATO9Y CCMMISSION VW ASHINGTON, D. C. 20664

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DEC 171980 MEMORANDUM FOR: Chainnan Ahearne FROM: William J. Dircks Executive Director for Operations i r

SUBJECT:

NADER/POLLOCK LETTER REGARDING LPDR's In my memorands of October 31,1980, I outlined the initial steps which had been taken to respond to the criticisms of the LPDRs contained in the October 8, 1980 letter from Hader and Pollock. I also indicated that the staff planned to meet with Mr. Pollock, and that I would respond to you further following the rneeting and the staff's analysis of the cornents contained in Mr. Chilk's memorandum of October 27, 1980.

Kevin Cornell and other members of the staff met with Mr. Pollock and Whayne  !!

. Dillehay Editor, Critical Mass Energy Journal, on November 21, 1980. We believe the meeting, which lasted over two hours, was constructive and led to t a better understanding ori both sides. A substantial portion of the meeting was devoted to a discussion of the various points in the Nader/Pollock letter.

... For your information, I am enclosing an updated critique of the criticisms l which reflects actions which were taken during November and the meeting with  ;

Messrs. Pollock and 0111ei.ay (Enclosure A). o. copy of the critique was provided to Mr. Dillehay on December 3,1980.

The most significant part of the discussion with Messrs. Pollock and Dillehay concernea what they riewed as the difficulty of finding Specific information  ;

in the local pubite document collections. We believe these criticisms are valid, and the staff will revise the Users Guide currently in use at the LPDRs with a vitw towards describing in more detail the type of documents contained in each file category and simplifying the methods for locating the dscuments desired. 'the se,aff has agreed to send Messrs. Pollock and Otlichay a copy of the Users Guide when it is revised, and to consider any suggestions they may  ;

have to improve the Guide. The LPDR staff will also be meeting with staff of  ;

the Public Document Room to determine how the LPDRs may utilire the bibliographic i search capabilities of the Washington PDR. In addition, a toll free 800 1

telephone number is being installed in the LPDR Branch, and this will make it ,

easier for the public to seek direct assistance in locating documents. At the suggestion of Messrs. Pollock and 0411ehay, we will also begin making copies of all press announcemants available in the LPDRs. ,

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l Chainnan Ah'earne l Enclosure B is a list of the actions and resources required to upgrade the

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LPDR program and includes the items mentioned in my earlier memorandum to j you and Mr. Chilk's suggestions,. We are currently reviewing the extent to .-

which additional staff and resources can be made available to the LPDR Branch  !

and this will impact directly upon the time frame in which the various items i can be accomplished.

The staff received anothw letter from Mr. 0111ehay (Enclosure C), dated Novenber 30, 1980, which sumarized their criticisms of the EPDR tis 0ren.

Most of these criticisms or suggestions have been addressed by the staff and actions have either been completed or are underway to address them. Several items identified by Mr. 0111ehay, however, address issues which either would raquire a major shift in purpose of the LPDR program or are outside the pur-view of the LPDR operation. Ths issues, which include providing LPDR's with 1 NRC material of a general nature and improving the accessibility of NRC staff

, to consumers, are not therefore addressed in either Enclosure A or 8.

ISIped) Mliam J.Cl,cis

. William J. Dircks Executive Director for Operations

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Enclosures:

'; A. Critique B. List of Actions and Resources C. Ltr 0111ehay to Souder,

• dtd 11/30/80 cc: Comissioner Gilinsky Comissioner Hendrie Comissioner Bradford SECY OGC OPE Distribution _

i Subject file - LPDR Branch

LPDR Rdg F Rdg C% 4/P ,

TARehm EKCornell WJDireb

, PNorry DJDonoghue DHeyer /

i JSouder /

JMFelton DGrimsley SEE PREVIOUS YEt. LOW FOR CONCURRENCES. RETYPED IN OEDO.

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Critique of Criticisms of LPDP.s Contained in the Critical Mass Article and the l'ader/Pollock Letters riticisms 1 and 2 -

! (1) Nuclear power plant documents are not catalogued at most of the LPDRs f and no real system of document cataloguing exists at any but a few of the t

document rooms. Often the filing ' system consists of papers randomly stuffed in cartons left in hallways or in other non-library space. ,

1 (2) No chronological logs are maintained denoting when documents are received  ;

and integrated into the collection, listerial has frequently piled up on  !

, shelves for periods of ilx months or more at LPDRs.

i Response: Current procedures l be divi 7ed into 23 categories.Atprovide the timethat document a document is sent collections to an LPDR, at each LPDR it is mark *.J with the category designation as an aid to filing and retrieval.  ;

Each file cateoory contains all documents relating to that category. In addition, each LPDR has chronological accession lists of all documents in the '

collection, and the document category, indicating where the document may be l found, is shown next to each document Itsted on the accession Itsts. The i accession lists identify the documents entered into the NRC's Document i f.ontrol System for that week. Because of possible . delays in document

• reproduction and distribution, all documents shown or, a weekly accession list ray not be available at an LPDR at the time the accession list is received, but the documents should be available shortly thereafter. While '

here is no requirement that logs be maintained denoting when documents are

( .eceived by an l'DR and integrated into the collection because of additional workload involved, a patron may determine the status of any document by calling the LPDR Branch collect. In addition, th? NRC is now in the process of installing a toll free 800 number, which should be in operation around the i

first of the year.

Under the new NRC document control syrU2 (TERA), the file categories currently l used will be modified slightly. Howrver, there will continue to be l accession lists designating the file category of each document, and the documents will continue to be marked and filed accordingly. This is also the case for the LPDR for the North Anna Nuclear Power Station locatec at '

the Louisa County (Virgtnta) Courthouse, and any complaints such as those described are always promptly investigated end resolved by the LPDR Branch. >

In a recent telephone survey of 110 LPDRs conducted by the NRC, 98 of the i L.PDRs said the filing was up-to-date. I i

for those LPDRs which were behind,10 have already been updated, and the remaining two will be updated when the collections are moved to larger quarters early in 1981. -

t As we indicated during our meeting on November 21, it is the practice of  ;

some LPDRs to file the documents monthly or when the material to be filed  ;

P 5

Enclosure A  !

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, reaches a certain size. This policy is acceptable a'nd sometimes preferred by i PDR users who can review the new material that has come in before it is i

, encorporated into thi 23 file cate'gories utilized in the LPDR collection. .

Criticism 3 No rules or explicit regulations govern the LPDRs. NRC clerica1 l

staff policy determines operating procedures, j t

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Response

The policy covering the operation of the LPDRs has been approved

, by the Connission (SECN8-301). The. official responsible for their operation is the Director. Division of Rules and Records, who has approved til operating procedures. At the time each power reactor LPDR is established, a representative ,

of the LPOR tranch visits the LPDR and instructs the library staff on filing i procedures and operating requirements. Because each library that serves as  !

an LPOR is different -- geographic location, size. filing space, equipment. [

staff users--it is often necessary for the LPDR Branch to treat each LPDR I

individually, without generic rules and regulations. LPDRs are also gtyen 4  !

Users Guide, for the ese of the pSblic, which covers the purpose of the document i

! collec*. tons, instructions on how to use the collections, information concerning -

j the NRC licensing process, and methods of public participation. ,

I As we discussed during our meeting, we wt11 be taking a closer look at the l i Users Guide with a view towards describing in more detail the type of documents i j

• i:ontained in each file category and simpitfying the methods for locating the

documents desired. l I

( riticism 4 Since LPDRs do not receive maintenance funding from the NRC.

l

\ antrained volunteers administer the collections. In several cases utility i

company personnel or their relatives serve as the "volunteers." Utility '

l

! personnel acting as assigned volunt;ers for local public document rooms is  !

) e distt.rbing discovery. This system otves the utility direct control over

. the availability of informatfon. ActMitts are concerned about the possibility ,

of documents slipping out of the collection, i l

l Response: As indicated during our meeting. NRC is in the process of  !

, implementing a program to provide financial support to LPDRs. and to provide ,

{ them with a micrographic capability. The need for applicant assistance in  !

! some cases has been dictated by the limited retources and staff of certain  !

i libraries which house the 1c.,:a1 public document collections. The NRC telephone j surve;; indicated that of 110 LPDRs contacted, filing is done by the library i I staff in g8 of them. In nine LPDRs. a representative of the utility did the i l filing, and volunteers perform the filing task in three others. j i

i

! The NRC and the LPDR maintain an index of the documents that are in the .

l LPDR collection. Therefore, even if a document is missing from the l 1 collection, a record is available at the LPDR and at the NRC to identify  !

1 it as a part of the collection. When the librarian or a patron finds that l l

a record is missing from the collection, the LPDR Branch will proniptly i replace the copy when so notified. All librarians have been told they may I call the LPDR tranch to report missing records or request other assistance. l In addition, each LPDR has franked post cards which may be used to notify  !

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'w LPDR Branch of missing documents. The use of microfiche records is also j j expected to substantially enhance maintenance of file integrity. j 4

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3 ,

Criticism 5 Researchers at the LPDRs have encountered suspicious or ntaoonistic oersonnel when seekina assistanen Personnel are often not  !

.vailable for assistance, or are just unin' forme.d. At one location, they were queried as to whether the researcher was "pro nuclear or anti-

nuclear." j Res>onse

To respond to these points, a clarification of the role of the i LPDL custodians must be provided. First, an LPDR custodian is not expected to be intimately familiar with the contents of the documents in the collection. A LPDR collection for a nuclear power plant may consist of  !

40 fcet of very technical and, scientific infomation. It would be extremely difficult for LPDR librariar.s to have sufficient fastitarity witH the collection to provide reseatch assistance. ' In fact, it is not the

, responsibility of the Itbrarian to serve as a researcher. The indexes and ,  ;

i Users Guide at the LPDRs are designed to provide research tools that . -

patrons may use. In addition, it is important that users of the LPDR ;

collee.tfons take time to familiarize themselves with the collections - - '

the organization, filing system, category designations, etc. - - so that ,

they can more effectively and efficiently utilize the information available i i

to them at the LPDR. Second, most LPDRs are opc.7 not only during normal  !

business hours, but evenings and weekends. Because they are open more than

• 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week, the librarian most familiar with the LPDB collection may L

, not be m duty when a particular patron seeks to review documents'in the

collectii n. By contacting the library in advance of a visit, patrons i

'esiring assistance may make arrangements to assure that the librarian most

( .miliar with the LPDR material will be there at a specific time to rovide (

assistance. In addition, the staff of the LPDR Branch is available y -

p telephone to p. ovide assistance in locating documents. .  ;

I I

With respect to the attitude of the librarians, the NRC staff has always  !

found them to act in a highly professional, courteous, responsive; and responsible manner.

l j j Criticism 6: Business hours at LPDRs discourage public access. Many  !

i citizens are not able to take advantage of limited weekday hours. l l '

i Response: Six of the 110 LPDRs surveyed are Ifmited to normal business -

i l

hours. All others are also open in the evening or on weekends.  !

! The agreement for funding support will require that the recipient library I I

be open in the evening or on weekends. Thus, once all of the libraries (

i are under contract, this problem will be resolved. '

i Criticism 7 NRC makes little effort to monitor the operation of the LPDR.

Once a room is set u9. most NRC contact is based on telephone calls and j pos tcards. Visits to the LPDRs are made once every two years "if  ;

l possible." the NRC staff told CHN.  :

i Response: NRC policy has been to visit every LPDR at least once every i a years. Because of constraints in travel funds the past several years. -

d particularly because of constraints caused by other necessary travel i l

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folloiling the TMI accident, it has not been pessible to maintain this schedule. Of the 110 LPDRs surveyed, 71 had been visited in the last two

! l years. - -

As part of the funding agreement LPDRs will be required to file a quarterly report which will include, among other things, a description of any problems .

the library may have and whether the filing is up-to-date. Thus, the i NRC will be able to know the condition of each LPDR on a reasonably current basis.. In addition, because constraints in travel funds are likely'to ' '

1 continue in the foreseeable future, NRC will hire as consultants individuals  :

i in ecch of the five NRC Regions to oversee the operations of the LPDRs in those ,

i Regions. This will have the effect of being more responsive to the needs of  :

the libraries while at the same time reducing travel costs.

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" ACTIONS AfC CE50 cCE5 RE0utRED

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TO UPQUOE THE LPDR PROGRAM AS PROVIDED - -

In THE MADEA/POLLCCK LETTER 5 Ape ,, J

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RELATED CDRRESPONDENCE -

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1. Affire Purpose of LPDRs .%

a) Infoin local public <-w b) Supwt hearing process (dhcovery, filings. ZJ';"

tra s.cripts) 7' , .

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(c) Res>>nd to TOIA requests re: plant documents Chilk #2

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1 2. Estab11n Criteria for 1.ocating LPDRs I A" l f al Adepacy of factitty (staff and space) p t ,-

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dj5erviceoffered(custodialorreference) ,

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' 3. Completc Telephone survey -

(a) Idea:1fy f t1 tog problems (b) Iden*1fy oth - Sroblems (weekends. applica.rt f1ltag. ,A repf 3 duction. Iocation) .m +..s Dirck s.14/N/P.182 ($4.000) <+4-

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($37.000)~ s'tacluded'dn FY I Dircks-2c/ Calls-3 ~~ 'hu89et. Amalttog receis .,

6. Issue F rst 10 Funding Contracts Obtain better cost information M/P-3&4 'of revised quotations t'yr 1 "

Eva'uate proposals ** - . r-Ist se contracts s of October 31; .N/P - naars/Pollock letter of M% 8.

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(g) Decision on telephone notification of acetdents or aswreal occurrences (h) Update roster of LPDRs. hours of operetion. and

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b,1 Agrsements with LPDRs on readet/priiters and sataloguing I

c l Sarsice contracts for reader / printers $13.000 Sent. , monitor

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(b Miti LPORs Lc Ressarch and test reactor LPDas 5 4.500 - At $1.%0 exe.,  ;;-

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9. Dectsfin on Fuel Cycle LPDFs uses services to be provided. -

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('c)Fuiding. fat cycle collections in LPDRs '

und also house power reactor CaUettions... f,. 4-i n . . , a ,,

10. Decist we on teether to procose leglsistion to Pnessa1[sMtthto MPA 'N requir., an applicant t, establish an LPDR as port of legislative pactsg.-  !.f when a splic9 tion submitted or require a  ;,fd Catmission. ,~, , , . . ,

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t staff iffort (STArFYEARS) Funding Amuments C. LONG TERM ACTI0tG (To 8a Completed In FY 1982 if resources aval'iable) Reference Dfrcks-12 .2 $42,000

1. twferences with LPDR Librarians N/P-7 .5 $25.000 *ased upon 98 ac*Ive fuit servia

2. kdtt Each LPOR Each Year , ,. .ouer reactor LP 15 and 3 ress-en.

- * ~ red test LPDRs. Tour LPORs

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>41.000, 1.0 $320.000 8 power reactor. at 53.000

3. Yearly Funding Contracts With LPDRs 42 eint at 31.00; (a) Renegotiate yearly contracts 3 eesearch and t it at 11.500.

fb Audit quarterly reports fc Authorize payrent

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Dircks-11 itaff tag and cosa will deper.J 4 Implement Decision Re: Regional And toen decision.

Ch11k-112 State Depositories

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5. Implement Decisions Re: Document Retention y decision. .

-St$efing and ces a will depene d

6. Isiplement Decisions On Fuel Cycle LPDRs rpen decision.

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