ML20211P470
| ML20211P470 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/16/1986 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20211P439 | List: |
| References | |
| FOIA-86-386, FOIA-86-A-197 EA-86-009, EA-86-9, NUDOCS 8612190081 | |
| Download: ML20211P470 (8) | |
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3 POTENTIAL VIOLATIONS NOT INCLUDED IN THE PROPOSED ENF04 CEMENT PACKAGE Issue, 7-7 Inadequate disposition of Nonconformance Reports (NCRs) for terminal lugs in vendor supplied switchgear. - Engineering evaluation for the bent tenninal lugs was acceptaole, but specific details of the evaluation were not included on the NCRs. Problem was appropriately documented and ' evaluated. Therefore no violation exists.
UNSUBSTANTIATED 7-9 Containment Integrated Leak Plate ' Testing (CILRT) - used ANSI /ANS 56.8 l
vice ANSI N45.4-1972 for acceptance criteria as originally stated in FSAR. NRR allowed change to FSAR for ANSI /ANS 56.8 acceptance criteria and found test results acceptable. Thus, no violation exists.
NO REQUIREMENT l 8-7 Field cured test cylinders failed to have 85% of the strength of I laboratory cured cylinders for concrete placement 105-2773-001, Safeguards '
Building. - Schmitdt hammer tests performed in 1976 verified acceptability of concrete in the placement area. Only two cylinders of 15 failed to satisfy the ACI requirements. Concrete was placed in cold weather and
. these results would not be unexpected. Corrective action adequate.
NO REQUIREMENT 8-8 Failure to consolidate concrete around rebar and embeds in the Unit 2 reactor cavity. - When forms were removed, deficiencies were identified by structural engineer promptly, and corrective actions were taken.
Program requirements were follcwed for problem identification and resolution. UNSUBSTANTIATED 8-9 One-half of one cubic yard of concrete placed in the Unit 1 containment dome without quality control (QC) involvement. - Violation. cited in hRC Inspection Report 50-445/79-11, issued on May 14, 1979. PREVIOUS NOV 9-4 Lack of traceability of coatirgs documentation. - Region IV already cited this lack of traceability of coatings documentation in Inspection report 50-445/81-15; 50-446/81-15. PREVIOUS NOV 10-2 Failure to justify use of a dynamic amplification factor (DAF) of 1.0 as required in FSAR 3.78.3.5 for equivalent static analysis of piping system
- seismic response. - FSAR allows use of a DAF between 1.0 and 1.5 with
,g proper justification. TUEC justified use of a DAF equal to 1.0. TRT
-. a. concern involves formal evaluation and approval prior to usage.
3 NO REQUIREMENT 8& - 10-4 Lack of procedures for welding temporary supports. - No requirement
$41 existed to have procedures for the welding of temporary supports.
ggi NO REQUIREMENT o a.m 5$ 10-6 Failure to 3rovide adequate temporary supports for the main steam line 3;gg during flusling. Analysis of repositioning of main steam line from auto temporary to permanent supports was performed by the applicant and was adequate. Problem appropriately documented and analyzed. Thus, there appears to be no basis for this violation. TRT apparently believes analysis should have been more extensive. UNSUBSTANTIATED 2-
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Issue l
10-7 NCR M-1004 for damage to reactor vessel support blocks was incomplete in that it did not contain flatness and parallelism requirements on drawings. -
Wording of NCR was not totally accurate; however, disposition was satisfactory to resolve the identified problem. No more actions necessary.
NO REQUIREMENT ,
10-9 Failure to clean debris (crow bar, 2"x4") from r.eutron detector wells in a timely fashion. - Debris was removed prior to TRT review (existed supposedly from 1980/1981 - 11/1983). No further action necessary, actions completed prior to TRT review. UNSUBSTANTIATED 10-12 Lack of procedures or instructions to implement a requirement in the reinforcing steel specification archibiting welding on rebar. - No violation exists to indicate tha*. tack welding was performed in violation of the specification requirements. UNSUBSTANTIATED 10-13 Changed retention requirements for the Oxygen Analyzer Issue Record Cards (IRCs) by office memo rather than changing the applicable construction
,, procedures. - Retention requirements specified in office memo exceeded the minimum ANSI and site procedural requirements. Viol'ation of procedures for more conservative requirements would not be appropriate.
NO REQUIREMENT 10-14 Piece number of an installed spool piece changed without explanation. -
NCR 49425 cocuments the improper change. No requirement prohibiting piece number changes. Traceability wsa maintained. Thus, no violation existed. NO REQUIREMENT 10-15 Sup) ort bolts did not have traceability records in the installation ,
paccage for vertical residual heat exchanger. - Identified by the applicant's quality assurance (QA) program on NCRs that are still open.
The TRT review concluded problem was appropriately identified and handled.
Thus, no violation exists. UNSUBSTANTIATED 10-16 Undocumented weld repairs to Unit 2 Emergency Diesel Generator skid. -
Applicant identified problem via NCRs. Skid was eventually scrapped due to questionable weld repairs at both the site and at the vendor.
NO REQUIREMENT 10-21 A QC inspector failed to write an NCR when he observed an unauthorized weld repair in the fabrication shop. - The hanger was scrapped. Current procedures for field installation would require documentation via an NCR. However, procedures for shop fabrication are not clear on to what requirements are applicable. Violation occurred in 1979. NO REQUIREMENT 10-22 An NCR involving an improper heat number on a piece of tube steel in a Component Cooling Water hanger was improperly dispositioned in that the heat number on the piece could not verified. - No requirements for traceability by specific heat number on ASME Class 3 NF components.
NO REQUIREMENT
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3 Issue 10-23 Inadequate corrective action involving disposition of NCR M-3407: 1.e.,
the failure to provide proper welder retraining involving water soaking of a weld bead, and the failure to adequately reinspect other welds Jerformed by that welder. - This practice was a violation of Brown & Root
)rocedure CP-CPM-6.90. Applicant documented the nonconforming condition which appears to be an isolated instance that is neither repetitive nor generic. UNSUBSTANTIATED 10-24 Possible inadequate corrective action in response to the Special Review Team (SRT) Report finding that inspection of strut angles was inadequate. -
No violation exists in that the ' applicant satisfied its commitment in its response to clarify the inspection procedures and to improve the inspector training. No examples of improper installations were provided by the SRT review. UNSUBSTANTIATED 10-25 Inadequate response to NRC Region IV Notice of Violation (N0V) documented in Inspection Report 445/83-07 in that the construction procedure for skewed welds was not clarified and the previous work by the welder in
,, question was not reinspected (improper fit-up gap on skewed welds). -
No violation exists in that enforcement action for the inspection of the fit-up gap on skewed welds has been taken. No new examples of additional problems involving skewed welds were provided to demonstrate corrective actions were unacceptable. UNSUBSTANTIATED 10-26 Proposed umbrella citation involving inadequate action to prevent recurrence based on NOVs 445-7904/446-7904; 445/83-24-02, 446/83-15-02; QA/QC Allegation Category No. 58 (Category 10, AP-10); and two Construction Appraisal Team (CAT) report findings. - No violation exists.
Citation proposed only because applicant was previously cited with the above violations presumably representative of inadequate corrective actions. No basis provided in SSER for this violation. UNSUBSTANTIATED 10-28 Lack of quality control records involving plug welds. - Plug welds were performed by unqualified personnel and procedures. Since welds that were not in accordance with site requirements, proper documentation was not initiated. Therefore, this issue is adequately covered by the violation cited in Issue 10-17. INCLUDED IN ITEM 10-17 10-31 Lack of audits of ITTG & NPSI Class 5 support procedure. - Scheduled, audits were not performed in 1981, 1982, and 1984. This was cited as a Severity Level IV violation by Region IV in Inspection Report 50-445/
84-32 that was issued February 15, 1985. PREVIOUS NOV 11-1 Lack of training program for document control clerks prior to August 1983. -
No requirement for such training exists. NO REQUIREMENT 11-2 Lack of periodic management review of QA Program. - Cited by Region IV in Inspection Report 50-445/84-32 issued February 15, 1985. PREVIOUS NOV 11-3 Umbrella citation im) lying basis is the other listed QA/0C draft Notices of Violations. - No ) asis provided by the deficiencies identified in the SSER to substantiate this type of significant violation. UNSUBSTANTIATED
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Issue 11-4 Lack of thread engagement on snubber ado)ter plate bolt threads for soma supports. - No criteria specified in ASME,Section III. Procedures have a specified minimum thread engagement, but TRT implies that criteria may not be adequate. TRT believes ASME requirements for thread engagement for nuts should also apply to threaded holes in plates. No basis for violation as no specific requirement violated.. - Bases for site procedural acceptance criteria was not reviewed. NO REQUIREMENT
- 11-8 Procedure CP-QP-i6.1, Significant Construction Deficiencies is inadequate because it does not address 50.55(e) re)ortability. - Procedure appears adequate and addresses 50.55(e) reporta)ility. No examples provided to indicate what specificity the procedure supposedly lacks. NO REQUIREMENT 11-9 No procedure or instruction describing the use of the document control stamp by 8 & R QC from 6/83-8/84. - There is no requirements for this type of procedure. No loss of hanger fabrication / installation control. QC, if it was in possession of the stamp, would abide by the Document Control Procedure. Concern of cited violation is difficult to understand.
NO REQUIREMENT
- 11-14 Lack of fabrication procedures for threads to assure they conform to the design specification. - Thread inspections are performed at installation.
Violation implies threads must be inspected during fabrication. No examples of improper thread installations were provided. NO REQUIREMENT 11-20 Sign-off on hold )oints on inspection travellers was not updated daily in accordance wit 1 CP-QCI-211. - Fuel Pool Liner is not safety-related, therefore no violation exists. NO REQUIREMENT 11-21 Lack of inspection procedures for embedded anchor bolts and baseplate hole sizes. - Information provided in SSER does not substantiate violation.
The SSER references a minor discrepancy in anchor bolt installation.
There is no discussion of a lack of inspection procedures.
UNSUBSTANTIATED 11-30 TUGC0 Procedure CPP-22 contained reference to inspection of Category I items in the table of contents and paragraph on procedure scope, but contained no such description in the procedure text. - Information provided in SSER does not substantiate violation. Concern addresses only a scope of work statement and a title in table of contents referencing Category I. No other specifics are provided. Thus, no basis for violation. UNSUBSTANTIATED 11-35 The five-line inspection traveller was inappropriate in that certain in-process inspections were not made before work proceeded. - Fuel Pool liner is not safety-related, therefore no violation exists.
NO REQUIREMENT 1
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Issue 11-36 Brown & Root QC personnel inspected their own documents as part of the ASME N-5 record verification program. - Former construction personnel were hired as QC inspectors. However, there are no specific instances referenced in the SSER where any of the individuals actually inspected their own documents. Therefore, there is no basis for the violation.
UNSUBSTANTIATED 11-37 Procedures for non-ASME NCRs (CP-QP-16.0, Rev.14) id'd not contain specific instructions for transmitting voided NCRs to the vault. -
Procedure requires voided NCRs be transmitted to the vault; however, there appears to be a concern of no specific instructions in the procedure.
There is no adequate basis provided to substantiate the violation.
UNSUBSTANTIATED 11-38 " Tracking NCRs" were used to record removal of equipment or parts, a aractice not defined or described in the NCR Procedure CP-QP-16.0,
.Rev. 14. - Applicant used NCRs to document removal of equipment or ,
parts. Unclear as to why this usage must be explicitly defined in the definition of a nonconformance. No basis for this violation.
NO REQUIREMENT
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11-40 Inadequate and untimely corrective action taken in response to numerous findings from internal inspections and audits involving document control problems. - TRT acknowledges that the current program is very good at the time of its reviews. Violation involves the history of recurring document control deficiencies prior to July 1984. No examples where these problems resulted in hardware deficiencies, with the exception of the coatings area. Information provided in SSER does not support violation. UNSUBSTANTIATED 11-41 Inadequate and untimely corrective action taken to preclude recurrence of lost, misplaced or interchanged valve components. - Procedural controls were provided. Examples of mismatched valve components identified by TRT were documented cn Permanent Equipment Transfers referenced to NCRs. No basis provided in the SSER for this violation.
UNSUBSTANTIATED 11-42 Untimely corrective action taken to N-5 data re) ort deficiencies or repetitive hold point violations. - NCRs and CAls apparently documented in accordance with site program requirements. Unclear from facts presented in the SSER as to why this is a violation. The reference to some nineteen months where CARS were not written may have been an adequate basis for a violation, but no information is provided to indicate that any type of problem existed where a CAR should have been written.
UNSUBSTANTIATED 11-44 Lack of a 50.55(e) report following substantial finding from 1981 survey of B&R. - The 1981 ASME Surevey report findings and resultant prompt actions to bring about a favorable ASME audit do not indicate that a significant breakdown existed in the quality assurance program.
The failure to issue a 50.55(e) notification is not justified.
UNSUBSTANTIATED
VIOLATIONS OF LITTLE SAFETY SIGNIFICANCE NOT INCLUDED ')!
! IN THE PROPOSED ENFORCEMENT PACKAGE i
j Issue
- 7-3 Strip chart speed was changed in violation of test procedure for the i pressurizer level instrument. - Change in speed had no effect on acceptability of.the test. Recorder may not be safety-related.
l 7-4 Prerequisite tests were signed off by craft >ersonnel instead of Shift Test Engineers (STEs) as required by C)-SAP-1-CP-SAP-21. - These i
are prerequisite tests prior to system turnover, and are in fact, construction tests. The normal practice ip for construction personnel
, to perform these' tests. A memorandum directed construction personnel I to sign-off acceptance of the tests in violation of procedural requirements. '
7-6 Completed Hot Fuentional Test packages indicated that test objectives has been met, when a review of packages showed all acceptance criteria
- . had not been met. Three packages involved. Isolated documentation deficiencies.
4 7-10 Minor violations of se)aration criteria inside panels CPI-EC PRCB-09 4 and 03. - Barrier had )een removed and redundant field wiring did not meet minimum separation criteria. Isolated instance.
- j. 8-2 Failure to place additional rebar in reactor cavity wall prior to concrete
- pour in 1977. - Gibbs & Hill evaulation GTM-19823 was not totally adequate in addressing concern. NCR CP-77-6 documents applicant identified problem.
l 8-4 NCR not written for misaligned Component Cooling Water Surge Tank anchor bolts. - NCR procedure cited in violation provided by TRT dated 7/ 2/,84. Nonconformance actually documented on TUSI letter CPP-00825 dated 3/2/79. May not be the appropriate requirement.
8-5 Lack of torquing instructions on Construction Traveler No. ME-78-108-111 1 for the anchor bolts on the Component Cooling Water Surge Tank. - Bolts
! were, in fact, torqued. Instructions did not define a specific torquing i requirement.
8-6 Missing concrete test laboratory signatures (7 examples out of 256
- batch tickets reviewed). - Concrete was acceptable. No information provided on tickets outside of specification requirements.
8-10 Repair of concrete adjacent to pipe support CC-1-137-700-E63R in i the Electrical and Control Building following removal of Hilti bolt 1 l did not have OC involvement. - One example only in SSER. Appears to be an isolatet instance.
! 9-3 TUEC's procedures governing the performance and inspection of coating work activities at CPSES were inadequate. - Acceptance criteria was
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l inappropriate and procedure steps were not always correctly followed.
- Basically part of issues 9-2 and 9-5 cited under Criterion III in
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proposed NOV. Proposed procedural violations of little safety significance.
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) 10-5 Lack of accounting for unused weld rods. - Weld rods counted by welder i prior to turn-in. Attendant documented this number, rather than l perfonning a separate counting as required by procedure (interpretation
- as provided in licensing hearings).
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10-8 Failure to deburr and radius drilled holes on the spent fuel pool sparging lines. - Minor procedural violation, if in fact fuel pool sparging lines are safety-related.
10-10 Failure to 3roperly clean expansion joint assemblies of the fuel transfer tu)e. - Housekeeping violation.
10-18 Two instances where drilled holes in supports exceeded the 1/8-inch oversize for bolt holes over 1-inch in diameter. - The bolt holes were in supports MS-1-151-037-C52R and CC-1-233-001-C53R,*and considered to be isolated 1.nstances. ,
10-19 Repair welding was performed on a sway strut assembly while a hold tag was in place. - Repair welds were made, although disposition to NCR M7122 " accept to use as is, a revised drawing to be issued."
Minor violation of procedural requirements.
10-30 Weld Data Card 752483, Operation 4, " Visual Inspection" not signed off by QC. - This reinspection was required to close NCR M-51015. Welds involved anti-vibration straps inside the Containment Spray Heat Exchangers.
Vendor performed inspection on both HXs. Brown & Root QC inspected one HX, no documentation for second HX reinspection, if performed.
11-5 A drawing (FW-I-99-004-C62K, Rev 1, Sh 2 of 2) was voided but still listed in the computer as current and active as required by DCP-3. -
Minor safety significance. Drawing may not be classified for safety-related activities. However, drawing was properly voided as required.
Computer, not really a controlled plant document, was in error.
Isolated instance, one example.
11-11 Contrary to QI-QAP-2.1-5 the TRT identified six instances in the review of ASME and non-ASME QC files where an individual was given the same examination consecutively. - Procedure violation but not FSAR/ ANSI violation, no indication that this would reduce inspectors ability to perform job. Procedural violation with little safety significance.
11-12 Whiteout was used on an exam in violation of CP-QP-2.3. - Two instances only identified by TRT, no evidence of falsification. Minor procedural violation.
11-15 Material Requisitions (MRs) were not completed in accordance with procedure CP-CPM-8.1. - Minor violation, if it is in fact a procedural violation. Basis provided in SSER questionable as the MRs relate to non-Nuclear Safety Seismic Category II hangers, not safety-related ASME Class Hangers.
11-16 Lack of segregation of material in laydown area as required by CP-CPM-8.1. - Housekeeping violation. No other problems identified
- as a result of the lack of segregation.
11-17 Lack of QC surveillance of storage and control of materials in the structural / miscellaneous steel shop as required by QI-QP-11.14-1. -
Housekeeping violation. No other problems identified as a result of the lack of QC surveillance.
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. Snubbers in the vicinity of welding were not protected as required by CP-CPM-14.1. - Housekeeping violation. No other problems identified as a result of the lack of procedures.
11-22 One example of a minimum edge distance violation from the anchor bolt hole center to the edge of the baseplate contrary to the requirements of QI-QAP-ll.1-28. - Isolated instance, 1/4-inen'in violation. Only example identified. .
11-23 Two pipe supports with no clearance provided in violation of QI-QAP-11.1 Isolated cases, 1/16-inch required clearance. Two of 42 reviewed in field.
11-24 Four examples of deficiencies on cable tray hangers, nonconforming conditions not noted per QI-QP-11.10-1. - Minor, isolated instances of improper Hilti bolt torque verifications, skewed Hilti bolt angles, and bolt hole to edge distances.
11-25 Lack of sight hole verification of threaded rod on a sway strut in violation of QI-QAP-11.1-28. - Sight hole provided in sway strut.
However, threaded rod cannot be identified.
11-28 Several dimensional and fastener problems on eight pipe supports. -
Minor deviations from procedure Q1-QAP-ll.1-28 involving sway struts, fasteners, and alignment.
11-29 Cable tray hanger had standard (non-heavy) hex nuts in violation of ASTM A-325 requirements. - Drawing specified heavy hex nuts, cable tray hanger fastened with each. Only cable tray identified with this fastener problem.
11-39 Procedural inconsistency for initial transmission of NCRs by site personnel. - Minor procedural violation. No instances identified where NCRs were not transmitted properly.
,/p urg"*g UNITED STATES 3 a NUCLEAR REGULATORY COMMISSION 5 j WASHINGTON, D. C. 20556 k...../ SEP 2 61996 billie Pirner Garde, Esquire Government Accountability Project Midwest Office IN RESPONSE REFER 3424 Marcos Lane TO F0IA-86-386 AND Appleton, WI 54911 86-A-120
Dear Ms. Garde:
This is in response to your letter dated May 22, 1986, in which you requested, pursuant to the Freedom of Information Act (F0IA), records regarding Enforcement Action 86-09 dated May 3, 1986, on the Comanche Peak nuclear power plant.
The four records described on the enclosed Appendix A are subject to your request and are already available for public inspection and copying at the NRC's Public Document. Room (PDR) under the accession number listed with each record.
The one record described on the enclosed Appendix B is now available for public inspection and copying at the PDR in file F01A-86-386 under your name.
The two records described on the enclosed Appendix C are withheld in their entirety pursuant to Exemption (5) of the F0IA (5 U.S.C. 552(b)(5)) and 10CFR9.5(a)(5)oftheCommission'sregulations. These records contain drafts of the enforcement action and related correspondence the release of which would tbnd to inhibit the open and frank exchange of ideas essential to the deliberative process. In addition, record number two on Appendix C is also withheld pursuant to Exemption (7)(A) of the F0IA (5 U.S.C. 552(b)(7)(A)) and 10 CFR 9.5(a)(7)(1) of the Commission's regulations. The release of this record would interfere with an ongoing enforcement proceeding.
Pursuant to 10 CFR 9.9 of the Commission's regulations, it has been detennined that the information withheld is exempt from production or disclosure and that its pr9 duction or disclosure is contrary to the public interest. The persons responsible for this denial are the undersigned and Mr. James M. Taylor, Director, Office of Inspection and Enforcement.
This denial may be appealed to the NRC's Executive Director for Operations within 30 days from the receipt of this letter. As provided in 10 CFR 9.11, any such appeal must be in writing, addressed to the Executive Director for Operations, U. S. Nuclear Regulatory Connission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an
" Appeal from an Initial F0IA Decision."
$??k?W S ff .
Ms. Garde ,
in light of this response, we are taking no further action on your letter dated July 16, 1986, appealing our lack of response to your request.
Sincerely, AmM -
Donnie H. Grimsley, Director '
Division of Rules and Records Office of Administration
Enclosures:
As stated 's i
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5 FOIN 86-386 Documents in PDR
- 1. 3/27/86 Letter and Inspection Report, Dockets 50-445/86-04 Accession No.
and 50-446/86-03, E.H. Johnson, RIV, to Texas 8604040223 Utilities Generating Company (TUCCo), W.G.'Counsil
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- 2. 3/28/86 Letter and Inspection Report, Docket 50-445/85-19, 8604040109 E.H. Johnson, RIV, to Texas Utilities Generating i Cpapany TUGCo), W.G. Counsil ,
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- 3. 4/28/86 Notification of Significant Enforcement Action, 8605080394 I&E, EN 86-27, Proposed Imposition of Civil Penalties - $250,000
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- 4. 5/3/86 Letter and Notices of Violation and Proposed 8605060208 Imposition of Civil Penalties, Appendices A and B, Dockets 50-445/446, I&E to TUGCo, W.G. Counsil
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1 t APPENDIX B FOIA 86-386 Document for Release
- 1. 5/2/86 NRC/RIV News Release, subject: "NRC Staff Proposes
'S370,000 civil Penalties Against Texas Utilities
. Electric Company" (1 page) ,
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, - . . FOIA-86-386 APPENDIX C Records Subject to F0lA-86-386 Withheld in Entirety
- 1. 01/24/86 Ltr, with connents, fr D. Powers, RIV, to J. Axelrad, I&E, (2 pgs.); forwards .
draft ltr. , Docket 50-445/85-19(2pgs.)
yt Appendix A, Notice of Violation and Proposed Imposition of Civil Penalty, (4 pgs.), Appendix B, Special Unit 1 Cable Tray Support "As-Built" Program Inspection Report, NRC/RIV (14 pgs.),
undated
- 2. 02/26/86 Hemo to R. Hartin, H. Denton, and i G. Cunningham fr. R. Vollmer re: " Enforce- .
ment Action Re Technical Review Team Findings at Comanche Peak" (1 pg) with i draft Itr to W. Counsil, TUEC, ytAppendices A & B Notice of Violation and Proposed Imposition of Civil Penalty (31 pgs.)
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. , l GOVERNMENT ACCOUNTABluTY PROJECT l 1555 Connecticur Awnue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 1
May 22, 198 g ggg )
REQUEST l Director Office of Administration M '*"8 b d k h U.S. Nuclear Regulatory Commission Washington, D.C. 20555 hMMYb Re: FOIA Request To whom it may concern:
Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C.
552, as amended, the Government Accountability Project (GAP) requests copies of any and all agency records and information,
, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, j interview reports, procedures, instructions, engineering ,
analyses, drawings, files, graphs, charts, maps, photographs, '
agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer runoffs, any other data compilations, interim and/or final reports, status reports, and any and all other records relevant to and/or generated in connection with the following: j EA 86-09, May 3, 1986, re: Comanche Peak. Specifically, l this FOIA includes but is not limited to all documents which '
explant what "other violations of NRC regulations were identified...and were not included in the package." (p. 2)
This request includes all agency records as defined in 10 1 C.F.R. 9.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved October 8, 1980), whether they currently exist in the NRC official, " working", investigative, or other files, or at any other location, including private residences.
If any records as defined in 10 C.F.R. 9.3a(o) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed, or are destroyed and/or removed after receipt of 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 requests that fees be waived, because " finding the information can be considered as primarily benefitting the gene-ral public." 5 U.S.C. 552(a) (4) (A). GAP is a non-profit, nonpartisan public interest organization concerned with honest and open government. Through its Citizens Clinic, GAP offers bW Nf ._
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FOIA Request May 22, 1986 Page Two assistance to local public interest and citizens groups seeking '
to ensure the health and safety of their communities.
l GAP is requesting the above information as part of an ongoing monitoring project on the adequacy of the NRC's efforts to protect public safety and health at nuclear power plants.
For any documents or portions of documents that you deny due j 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 IIl, 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.
Respectfully, k
Billie Pirner Garde citizens clinic Director 42111 i
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