ML20211E980

FOIA Request for All Documents Re Deposition of NRC Personnel Deposed in Litigation Between Util & Brown & Root, Inc Over Facilities

ML20211E980
Person / Time
Site:	South Texas
Issue date:	05/16/1985
From:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FOIA-85-378 NUDOCS 8610310004
Download: ML20211E980 (2)

Text

GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 ESEDao oc tNre,r.w aw..r May 16, 1985 .

FREEDOM OF INFORMATION ACT REQUEST FoI A-05-378 Director  % M Office of Administration Nuclear Regulatory Coramission Washington, D.C. 20555 To Whom It May Concern:

Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. $552, the Government Accountability Project ( "G A P " )

requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebook s, books, telephone messages, computations, voice recordings, computer runoffs, any other data compilations, i,nterim and/or final reports, status reports, and any and all other records relevant to and/or generated in connection with the information regarding copies of the depositions of all NRC personnel deposed in the litigation between Houston Light and Power Company and Brown and Root, Inc. over the South Texas Project.

This request includea all agency records es defined in 10 C.F.k. 99.3a(b) and the NRC Manual, Appendix 0211, Parts 1. A.2 and A.3 (approved October 8, 1980) whether they currently exist in the NRC official, " working", investigative or other files, or at any other l > cation, including private residences.

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

8610310004 850516 PDR FOIA CARDE85-378 PDR

GAP requests that fees be waived, because " finding the information can be considered as primarily benefitting the general public, " 5 U.S.C. 552(a)(4)(a). GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability.

Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Citizens Clinic is currently assisting several citizens groups, local governments and intervenors in the central Texas area concerning the constraction of the Comanche Peak nuclear power plant.

We are requesting the above information as part of an ongoing monitoring project on the adequacy of Region IV and the N RC 's efforts to protect public safety and health at nuclear power plants.

~

For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index should provide a detailed 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 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974).

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

Sincerely, Mb  %

Billie Pirner Garde Director, Citizens Clinic