MEMORANDUM FOR THE RECORD FROM(Sanitized)

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP86-00895R000100110001-1
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 10
• Document Creation Date: December 12, 2016
• Document Release Date: January 28, 2002
• Sequence Number: 1
• Publication Date: November 1, 1977
• Content Type: MFR

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MEMORANDUM FOR THE RECORD
FROM : RNP , ords Administration Branch
On 31 October, the undersigned was advised that
on 25 October, Mr. Shaw, Senate Select Committee on
Intelligence, visited with Mr. Thomas Wadlow, NARS,
seeking advice concerning the review of Intelligence
agencies' records withheld for destruction pending the
approval of the SSCI. According to the source, this
meeting was the subject of a memo, dated 26 October,
to the Archivist of the United States from Mr. Wadlow.
It is to be noted here that since the information was
presented to the undersigned in a rapid fire verbal
fashion, the undersigned could only note a few of the
points of the meeting. According to the source,
Mr. Shaw indicated that he plans to review Agency
requests for disposition, and demonstrated a mistaken
impression that NARS supervises all such dispositions.
He further indicated that he plans to have the 17
Committee Senators review pending Agency requests to
vote on individual dispositions. Mr. Shaw is scheduled
to meet again with Mr. Wadlow upon the latters return
to duty on or about the first week in November.
Attached is a xerox copy of an article that
appeared in the October 27, 1977 edition of "The
Nation." The source indicated that this article
would be of interest to us since it could present
problems. The actual xerox copy was obtained by RAB
from the library.
Attachment
As stated
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 barrage," as it was called inr Cuba, TT aiaOdo+R2/19
to clear the way for a telephone rate increase in 1957-
an increase for which Batista was later awarded a gold
telephone, now on view in Havana's Museum of the
Revolution. And there are the requests for compensation
by various American hotels, some of which the Cubans
believe to be properties of the Mafia. The Cubans are
going to be understandably reluctant to compensate such
claimants.
Even if Cuba wanted to satisfy American claims, could
it pay anything? Certainly it cannot pay much. The Cuban
economy is just stumbling ahead; the island's GNP, per
capita is as stagnant now as it was in the 1950s. Cuba has
a debt of almost $6 billion to the USSR; virtually every-
thing on the island is rationed. The mainstay of Castro's.
economy-still the sugar industry-is currently produc-
ing, thanks to droughts, spare parts shortages and mis-
management, at levels established a half-century ago,
during the salad days of American capitalism. There is
not much fat to share out.
Moreover, the Cubans have declared of late that they
intend to maintain the current nature of their trading
patterns. Thus, the American traders will have to strug-
gle for their share of the 35 percent which is allocated
to Western Europe and Japan. This determination to
maintain- two-thirds of its trading relations with the So-
cialist bloc would seem not only to limit the possibility
of compensation through trade, but also limit the broader
BUREAUCRATS ABOVE THE LAW
;krpapPo%Q'Qc11AQ0'h-measure of in-
fluence in Cuba in order to moderate its policies on hu-
man rights and aid to African revolutionaries.
If Cuba will not or cannot pay, there remain several
possibilities. The Carter administration might decide it
was in the broader national interest to favor the traders
and outflank the claimsmen by ending the embargo and
opening trade without preconditions. But if it did so,
Cuban goods would likely be attached by angry claims-
men as soon as they reached America. It has happened
in the past when Cuban sugar, ships and aircraft were
impounded by local court orders.
The real hope of the claimsmen seems to be that, in
one way or the other, the Congress can be persuaded to
compensate them in order to assure normalization of re-
lations with Cuba. The chief counsel for the JCCCC,
Samuel Mcllwain, has suggested that. if Congress agrees
to pay Castro any counterclaims for the Bay of Pigs or
CIA-sponsored raids, these sums should be set aside to
pay U.S. claimants. Or perhaps Congress might agree to
pay back rent on the Guantanamo base, on the under-
standing that this money would go, via some equitable
formula, to the claimsmen.
But one senses that the Congressmen, their hackles
raised by the proposed Panama settlement, will not be
quick to do anything that might be interpreted as sur-
rendering, even indirectly, to Fidel. The likelihood is
that the competing demands of the claimsmen and the
traders will contribute powerfully to a paralysis of U.S.-
Cuban relations that may last for another decade. ^
Double-Entry Intelligence Files
ATHAN THEOHARIS
Historians and archivists will welcome the Final Report
of the National Study Commission on Records and
Documents of Federal Officials (really two reports, one
from the majority and one an alternate). Both versions
affirm what has been in some question-not least because
of Richard Nixon's acquisitive instincts-that the papers
of all federal officials (not only Presidents but bureau-
crats, members of Congress and judges) are public prop-
erty and must be held available for scrutiny by the pub-
lic. But having made this vitally important finding, the
Study Commission evidently felt that the bulk of its
task was done. It cites the Federal Records Act of 1950,
Athan Theoharis, professor of American -history at Mar-
quette University, is the author of Seeds of Repression:
Harry S. Truman and the Origins of McCarthyism (Quad-
rangle Books) and The Yalta Myths: An Issue in American
Politics, 1945-55 (University of Missouri Press). He is com-
pleting a study of internal security policy in the years 1936
to 1976, tentatively called On the Road to 1984.
which obliges the head of each federal agency to "make
and preserve records containing adequate and proper
documentation of the organization, functions, policies,
decisions, procedures and essential transactions of the
agency . . . ," and notes that, to insure compliance with
such requirements, the Code of Federal Regulations of
1976 stipulates that "With particular regard to the formu-
lation of basic Government policy, Federal officials are
responsible for incorporating in the records of their agen-
cies all essential information on their major actions."
The two reports agree that these statutes, together with
the Freedom of Information Act, provide sufficient guar-
antees for the preservation of, and access to, such rec-
ords, within reasonable bounds of confidentiality and
the safeguarding of national security.
This optimism I find unwarranted, in view of recently
acquired knowledge about the separate records-keeping
and document-destruction practices of government agen-
cies, and particularly the intelligence agencies. When de-
vising multiple filing systems and document-destruction
procedures, intelligence bureaucrats have in the past
fully recognized that their agencies' reputations and thus
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authority could be damaged should "sensitive" docu-
ments of a certain kind ever be publicly disclosed. De-
spite the assurance of confidentiality provided by "na-
tional security classifications, these officials devised fil-
ing procedures that separated extremely sensitive from
other. "national security" classified documents. This sys-
tem had a double objective: to permit the prompt de-
struction of these sensitive documents without leaving
behind any clue that such documents had ever existed.
Moreover, although some of these record-keeping prac-
tices were established before, and others after, the 1950
Act, the legislative requirements that adequate records
be created and preserved were deliberately ignored.
Apparently, the National Archives personnel respon-
sible for reviewing agency documents before permitting
their destruction had been unaware of these procedures
intended to avoid public knowledge of illegal activities.
For, on March 26, 1976, the appraiser in the Records
Disposition Division of the National Archives' Office of
Federal Records Centers who had responsibility for FBI
documents authorized (and the archivist subsequently
signed) the destruction of "Closed files of the Federal
Bureau of Investigation containing investigative reports,
inter- and intro-office communications, related evidence
. . . collected or received during the course of public
business in accordance with the FBI investigative man-
date." (Emphasis added.) Thus, extensive files were de-
stroyed without the responsible Archives personnel as-
certaining their historical and public importance. The
limited number of personnel (ten) in this Archives Divi-
sion explains why such voluminous files could not be re-
viewed. Yet the National Archives has not requested
money to hire additional staff for the purpose.
In memorandums of April 11, 1940, November 15,
1941, March 1, 1942, January 16, 1943, March 9, 1943
anti November 9, 1944, FBI Director J. Edgar Hoover
advised bureau officials (both those in Washington and
Special Agents in Charge of field offices) how to pre-
pare for submission to headquarters memorandums that
were not to be retained and filed in the FBI's general
files. These communications were to be typed on pink
paper (later blue) the better to. keep them separate
from white-paper memorandums which, on receipt by
Washington, would be given a serial number for filing
purposes. In part, Hoover's reason for setting up this
color code had been to reduce paper work. A deeper
purpose, however, was to enable FBI field offices to con-
vey sensitive information in writing to the FBI Director
or Washington headquarters without running the danger
that a retrievable record would thereby be created. His
April 11, 1940 memorandum identified documents to be
destroyed as including those "written merely for informa-
tive purposes, which need not be retained for permanent
filing." The March 1, 1942 instruction more specifically
identified these as including memorandums "prepared
solely for the benefit of the Director and other officials
and eventually to be returned to the dictator [of the
memorandum] to be destroyed, or retained in the Direc-
tor's office."
In 1942 the bureau instituted a "Do Not File" pro-
cedure for all field-office requests for authorization to
conduct break-ins, along with the documents that formally
approved these requests. Such papers were not to be
given serial numbers, nor to be filed under the appropri-
ate case or caption category. Whenever Hoover or his
headquarters staff deemed it advisable to destroy them,
they could vanish without a trace. An internal bureau
memorandum of. July 19, 1966, from William- Sullivan
to Cartha De Loach (both men at the time were as-
sistants to the Director) describes in detail the Do Not
File procedure. To prevent excessive recourse to break-
ins-which Sullivan characterized as "clearly illegal"-
and to make sure that sufficient care was taken to pre-
vent their discovery, prior written authorization from the
Director or assistant director was required for all such
crimes. Under normal procedures, of course, this would
create a retrievable record, and the Do Not File device
was invented to avoid that hazard. In September 1975
Congressional testimony, former FBI Assistant Director
Charles Brennan conceded that this was indeed one pur-
pose of the Do Not File procedure. It would also en-
able the bureau to comply with court disclosure orders,
since witnesses could affirm that a search of FBI records
had been made and no evidence uncovered of illegal
government activities.
The recent discovery of this separate file keeping raises
additional questions about the FBI's way with its records.
In the course of reviewing the "Official-Confidential"
files formerly retained by Hoover in his personal office.
the staff of the Senate Select Committee on Intelligence
Activities came across the Sullivan-to-De Loach memo-
randum mentioned above. Mark Gitenstein, the staff
counsel who made this find, then noticed that a caption,
"PF," had been crossed out in the upper-right-hand corner
and the notation added that, in November 1971, the
document had been transferred to Hoover's Official-Con-
fidential files. Further investigation established, first, that
"PF" stood for Hoover's "Personal Files"; second, that
this document, along with seven other documents, had
been transferred from the "B" entry in the Personal Files
("B" for "Black Bag" jobs or break-ins) to Hoover's
Official-Confidential files and, third, that shortly after
his death in May 1972, Hoover's Personal Files had
been sent to his home. There, following Hoover's instruc-
tions but allegedly after first reviewing the voluminous
Personal Files to insure that they contained no official
documents, the FBI Director's personal secretary, Helen
Gandy, destroyed them. In her December 1975 testi-
mony, Ms. Gandy maintained that she had found no
other official documents.
Given the decidedly official character of the Do Not
File memorandum (the seven other items remain classi-
fied, but assuredly Hoover in 1971 considered them of-
ficial), we confront the not very credible possibility that
the only alphabetical entry in Hoover's Personal Files
to contain official documents had been the letter "B."
The process by which documents were selected for trans-
fer and destruction prevents us from knowing whether
the requirements of the 1950 Act and the 1976 Code
were actually met.
394 THE NATION/October 22, 1977
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Obviously, a Do Not File procedure allows those-con-
cerned to deny knowledge of the extent and nature of
recognizably illegal or "sensitive" activities, and other
recent disclosures suggest that such separate filing pro-,
cedures were not confined to break-ins. Thus, Sullivan's
1969 reports from Paris to Washington headquarters on
his surveillance of nationally syndicated columnist Joseph
Kraft were sent under the Do Not File procedure. In
addition, despite Atty. Gen. Nicholas Katzenbach's 1966
requirement that all requests for authority to wiretap be
submitted in writing and the names of those subject to
such surveillances be included in a special file (an ELSUR
Index), the wiretap records of the seventeen individuals
(White House and National Security Council aides and
reporters) tapped between 1969 and 1971, allegedly to
uncover the source or sources of national security leaks,
were not? placed in this Index or filed with other FBI
"national security" wiretap records. (Nor were the 1972
wiretap records on Charles Radford, a lower-level mili-
tary aide suspected of having leaked National Security
Council documents to the Joint Chiefs of Staff, included
in the ELSUR Index or filed with other FBI "national
security" taps. And FBI reports on its surveillance of
Anna Chennault in October/November 1968 were "pro-
tected and secured" to insure that they would not be
discovered and thereby affect that year's Presidential
race.) Accordingly, when Sullivan told Asst. Atty. Gen.
Robert Mardian in July 1971 that Hoover might use these
taps to blackmail the President, Mardian, after consulting
with Nixon, transferred the tap records from the FBI
to the safe of White House aide John Ehrlichman. Be-
cause they were not listed originally in the ELSUR In-
dex, there was no record either that these files had been
transferred or that the wiretaps had been carried out.
In another area, when Congress in September 1971,
repealed the emergency detention title of the McCarran
Internal Security Act of 1950, Hoover asked Atty. Gen.
John Mitchell how to handle the policy documents of
the Justice Department's independently established,
broader-and illegal-detention program. On February
19, 1972, Mardian advised Hoover to destroy these ma- .
terials. Furthermore, upon concluding the study that re-
THE NATION/Oclober 22, 1977
cedure (known as the Huston Plan), - Hoover in June
1970 advised other intelligence officials who had partici-
pated to destroy this plan's working copies.
During the pretrial hearings in the Judith Coplon case,
the FBI's extensive and illegal use of wiretapping 'was
revealed because Federal District Judge Albert Reeves
ruled that certain FBI reports be submitted as evidence.
Hoover then devised yet another filing procedure. In
Bureau Bulletin No. 34 of July 8, 1949, he ordered that
"facts and information which are considered of a nature
not expedient to disseminate or would cause embarrass-
ment to the bureau, if distributed" were henceforth to be
omitted from agent reports, but detailed in the administra-
tive pages that accompanied these reports. Normally,
agents employed administrative pages to highlight inves-
tigative findings or to outline future investigative efforts.
Because those pages could be kept separate from the re-
ports, Hoover's order would allow the FBI to conduct
questionable or illegal activities, and profit from their
findings without risking disclosure during trial proceed-
ings or even without responsible Justice Department of-
ficials ever learning of them.
This need to prevent discovery of illegal FBI investi-
gative activities had also led Hoover on October 19,
1949 to advise all Special Agents in Charge how to hide
the fact that the bureau was conducting an extensive
"security, index" program. It predated passage of the
McCarran Internal Security Act and was partially based
on a secret directive of August 3, 1948 from Atty. Gen.
Tom Clark. The FBI, however, began to compile addi-
tional indexes---a Communist Index, a "Detcom (Com-
munist Detention) program" and a "Comsab (Commu-
nist Saboteurs) program"-without the Attorney Gen-
eral's direction or knowledge. To guard against discovery
of this program by the press and the Congress-as well
as to prevent the Attorney General from discovering the
bureau's independent extension of his authorization-
Hoover advised SACs: "No mention must be made in
any investigative report relating to the classifications of
top functionaries and key figures, nor to the Detcom or
Comsab programs, nor to the security index or the Com-
munist Index. These investigative procedures and ad-
ministrative aids are confidential and should not be known
to any outside agency."
Then, when the FBI after February 1958, began to
receive copies of letters illegally obtained through the
agency's closely guarded mail cover/intercept program
in New York City, similar filing .procedures were set
down, as described in a November 26, 1962 memoran-
dum. Copies of intercepted mail were to be destroyed
(if of no value) or filed in a secure area, separate from
other FBI files.- Such copies were also not to be included
in the subject's case file, although a cross-reference would
permit retrieval. When significant information found in
this intercepted mail was sent on to FBI field offices or
other divisions, it was to be paraphrased to disguise the
source. Agents in Charge of this project in New York
were specifically warned not to disseminate the obtained
information outside the bureau and not to cite it in any
investigative report.
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Are there other FBI files? Obviously, this question can-
not,be answered definitively. When interviewed by David
Wise, author of The Police State, William Sullivan
claimed that John Mohr (then an FBI assistant direc-
tor) had removed "very mysterious files" from Hoover's
office after the FBI Director's death. These were "very
sensitive and explosive files," Sullivan maintained, and
not all of them were located by Atty. Gen. Edward Levi
when he found "164 such files in the Justice Depart-
ment."
Nor were these separate filing procedures and the at-
tendant document destruction confined to the FBI. The
CIA's drug program documents were destroyed in Jan-
uary 1973. Also, during the September 1975 Congres-
sional testimony, CIA Director William Colby affirmed
that the agency's record-keeping practices made it
impossible to reconstruct past CIA activities involving
the production and retention of highly poisonous toxins:
"Only a very limited documentation of activities took
place"; the desire for compartmentation involving sensi-
tive matters "reduced the amount of record keeping."
In 1969, the National Security Agency devised similar
filing and destruction procedures. In 1967, the NSA had
begun to intercept the international electronic communi-
cations of targeted American citizens and organizations.
The NSA bad the equipment necessary to intercept all
electronic messages, and could isolate particularly desired
messages according to pre-selected names or code words.
To exploit this capability, the CIA and the FBI provided
the NSA with a so-called Watch List of individuals or
organizations whose messages were to be intercepted. In-
formal document transmittal and separate filing methods
were then devised. Being perfectly aware that such inter-
ception was illegal, NSA officials in 1969 worked out
procedures to hide the existence of the activity and their
involvement in it. Reports produced through this eaves-
dropping were given no serial numbers, were not filed
with other NSA reports, were hand-delivered only to
those officials having knowledge of the program, and
were distributed "For Background Use Only." Agencies
receiving the material were directed either to destroy it
or return it to the NSA within two weeks.
Are these separate file-keeping and destruction proce-
dures merely aberrational practices that have now been
abandoned? Unfortunately, in the absence of proof to
the contrary we must assume that they may be continuing
or might be resumed. It is unlikely that before 1975
responsible, informed citizens would have accused the
intelligence agencies of such practices, and if they had,
few Americans would have taken them seriously. Further-
more, recent testimony under oath by intelligence officers
and their responses to document requests during the first
intensive Congressional inquiry into the practices of the
intelligence community have raised additional questions
about. the intelligence agencies' file-keeping practices.
Thus in 1975, FBI Director Clarence Kelley during a
press conference, senior FBI officials testifying . before
Congress, and FBI memorandums responding to specific
inquiries of the Senate Select Committee all affirmed that
FBI break-ins during domestic security investigations had
ceased in 1966, and that the exact number of such past
FBI break-ins could not be provided because, thanks to
the Do Not File procedure, written records did not exist.
In 1976, however, in response to a court order involving
a damage suit brought against the government by the
Socialist Workers Party, the FBI not only produced
break-in documents but these documents disclosed that
FBI domestic security break-ins continued after 1966 and
as late as July 1976.
In addition, William Colby testified in September 1975
that the CIA could not be fully responsive to the Senate
Select Committee's queries concerning the CIA's drug
programs and specifically its toxin program. Not only, had
documents concerning the CIA's general drug programs
been destroyed in January 1973, but the agency's desire
for compartmentation of sensitive materials had "reduced
[the] amount of record keeping" and thus there had been
.,only a very limited documentation of [the] activities
[which] took place." But in July 1977, contradicting
Colby's assertions, CIA 'Director Stansfield Turner ad-
vised the Senate Select Committee that documents per-
taining to the CIA's past drug program had been dis-
covered after "extraordinary and extensive search efforts."
These, Turner reported, had been found in retired archives
filed under financial accounts. The newly discovered
documents showed that CIA drug testing on American
citizens had been more extensive than had been disclosed
in 1975.
The file-keeping procedures, and their underlying intent
to prevent public/Congressional knowledge of question-
able or patently illegal activities, challenge the assump-
tions underlying the National Study Commission recom-
mendations. Existing law and regulations do not appear
adequate to guarantee retention of public papers, thus
assuring that the Freedom of Information Act will give
access to the full record of federal agency practices. The
problem is more complex and thorny than the commis-
sion recognized. Perhaps the preservation and access to
such papers cannot be insured. But the attempt should
nevertheless be made, and a number of additional safe-
guards are required. First, the Congress should enact
legislation specifictilly forbidding the maintenance of
separate files and requiring federal officials to create a
unitary and complete filing system. Heavy fines and
criminal penalties should be provided for noncompliance.
Second, an oversight committee should be created to in-
sure that more dual, triple or even more elaborate sys-
tems do not continue, will not be devised, or if devised
cannot remain undetected. An independent board of
archivists, journalists and historians might well be created
to provide this oversight. It must have subpoena powers
and complete authority to inspect agency filing systems.
Third, and perhaps this would be less a procedural change
than a political awakening, cold-war secrecy and national
security assumptions must be critically reassessed.
The intelligence agencies' record-keeping practices in
the recent past show their bureaucrats to have felt them-
selves above the law. Rather than being bound to respect
legal or constitutional limitations, these officials decided
that the law could be safely circumvented, first by ex-
396 THE N' TroNIOctober 22, 1977
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ular and Can resst to erance or secret , stt i' 1t 1-u to reaffirm the pea
plaiting popular $
h b t national security as
ou
and then by devising elaborate filing procedures to pre- pies right to know as muc a
vent discovery. What is needed for a return to govern- it does about economic policy. Otherwise the recommen-.,
ment by law, and not by men, is to create safeguards dations offered in both National Study Commission re-
against the tendency of intelligence agency officials to ports could prove to be cosmetic, and that is not what
d
Q
i
d
.
nten
e
decide for themselves, and secretly, what national policy their proponents
- BEHIND THE BERLIN WALL
SOCIALISM WITH A GERMAN FACE
Germany-the "other Germany" as it has been patroniz-
ingly called. The hideous Berlin Wall fixed itself deep.
in most people's minds as the symbol of a new German.,
brutalism. More than that, it was taken as a symbol of
illegitimacy. Here was graphic and deadly proof that the
GDR is a bastard state. For two decades the West tried
to wish East Germany away. The attempt failed, and the
Helsinki Conference of 1975-precursor of this month's ,
meeting in Belgrade-became the coming-out party for
the East German leadership. By an accident of the
French diplomatic alphabet, Erich Honecker found' him-
self sitting between Chancellor Helmut Schmidt and Pres- '
ident Ford. Nothing could have been more ironic than
that the East German party leader should be flanked by
the heads of government of the two countries which had
done more than any others to prevent the GDR's coming
into being.
Although the Western boycott was the most aggravat-
ing international issue for the GDR, its relations with
its allies in Eastern Europe were not without problems.
To be sure, it was integrated into the Warsaw Pact and
Comecon, but its companions in those bodies were a
long time getting over the feeling that the GDR was an
artificial state.
JONATHAN STEELE
In short, East Germany had to gain legitimacy in the
eyes of its friends as well as its enemies. During the first
postwar years Stalin saw the country primarily as a
strategic buffer for the Soviet Union and a source of
reparations payments; the interests of the small minority
of Communists in the Soviet Zone of Germany took
second place. Three times, first under Stalin, then under.
Malenkov and Beria, and finally under Khrushchev, the
USSR toyed with the idea of withdrawing from the
country in return for the neutralization of the whole of
Germany. Although the Russians hoped, at least in the
period just after the war, that a neutral Germany would
be leftward-leaning, they were more concerned to insure:
that its foreign policy was safe than that its political
system was Communist. In 1955, to the chagrin of the
East German leadership, the Soviet Union recognized the
,Federal Republic without demanding a diplomatic quid
pro quo for the GDR. It was not until 1974, almost
exactly a year after the GDR's entry into the United.
Nations, that reciprocity came and the United States
recognized East Germany.
East Germany was on the front page of The New York
Times on September 24. It was a rare occurrence, caused
this time by the news that a stream of dissident writers,
musicians and theatre people is flowing out of the country.
The spate of expulsions-some forced, others merely
encouraged began with Wolf Biermann, the unorthodox
Marxist singer-poet who was refused permission to return
from a trip to West Germany last autumn.
The government of the German Democratic Republic
was at first surprised when scores of other intellectuals
protested the exclusion of Biermann. It briefly detained
a few of them, put some under house arrest, but left the
majority alone until it decided that they too would be
better out of the country. In the last ten months- the
cultural migration has included more than twenty intel-
lectuals. The facts reported in the Western media were
true; the events are sad. Western newsmen covering the
Belgrade review conference on European Security and
Cooperation this month (it opened on October 3) now
have a new peg on which to hang legitimate stories about
repression in Eastern Europe.
Yet there is also something sorrowful about the in-
ability or unwillingness of most Westerners writing about
Eastern Europe to go beyond the cliches. How many
reports of the recent exodus from the GDR have con-
trasted the situation with the position of intellectuals in
the Soviet Union or Czechoslovakia? In those countries
expulsion is a mild form of punishment, when compared
with the more usual practice of imprisonment, or in-
ternal exile with no chance to pursue one's work. In
East Germany an exit visa has become the most com-
mon punishment, at least for prominent intellectual dis-
sidents. For those brought up on an ideological diet
in which the GDR was always' described as the most
authoritarian state in Communist Europe this may seem
an aberration. Those who remember that East Germany
was the only East European state in which the Stalinist
purges of the early 1950s produced no executions, may
see it as just a mild case of history repeating itself.
No country has had a poorer image abroad than East
Jonathan Steele, Washington correspondent for the Man-
chester Guardian, was formerly its East European corre-
spondent. His book, Inside East Germany: The State That
Came in from the Cold, was published by Urizen Books on
October 3.
THE NAnoN/October 22, 1977
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397
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depending on the frequency with which
they are performed and the severity of
the infestation present at and around the
plant.
IE Bulletin 81-03 addressed fouling by
Asiatic clams and musseles only.
Therefore, most plants discussed only
these two species in their responses.
Some plants however, mentioned the
presence of other fouling organisms 46ch
as other species of clams, oysters,
name a few. In addition, a numb of
plants reported problems caus by mud
and silt. In some cases, they imed this
to be a bigger problem at th lant than
In July 1981, NRC issue E
Information Notice 81-2 "Potential
Loss of Direct Access t Ultimate Heat
Sink". The Notice des 'bed the loss of
the normal decay he removal system
at Brunswick. It ale emphasized the
need for licensees initiate appropriate
actions, as descri ed in IE Bulletin 81-
03, for any mari organisms that could
cause fouling a their plant.
A case stud entitled "Report on
Service Wate System Flow Blockages
by Bivalve ollusks at Arkansas
Nuclear O and Brunswick", was
. issued by he NRC's Office for Analysis
and Eval ation of Operational Data in
Februar 1982..
The C's Office of Nuclear Reactor
Regula on (NRR) is conducting a
gener' study of service water system
malf ctions. This study is being
assi ed. through the Special Studies
pro am at the Oak Ridge National
La oratory (ORNL). In the program,
O. NL will investigate licensee event
r orts (LERs) from January 1979
t rough June 1981 on the partial or.
and organize these results
systematically. From this. collection of
events, ORNL will evaluate the safety
significance of service water
1 400W, 4- ' - a
2 Notices
off. 4'', o. 97 / Wednesday May 19,198
malfunctions and provide their
recommendations for any corrective
measures that they believe may be
needed. NRR will attempt to correlate
specific plant design features,
surveillance programs and preventative
measures with the magnitude and types
of service water problems re rted in
LERs and the responses to Bulletin
81-03. Based on the result of this study,
corrective actions will b recommended
in order to improve th reliability of
service water syste
In addition to thervice water study,
laces in "U" t e heat exchangers
si ilar to tho a used at Brunswick. This
rev w-is t etermine if a generic
probl fists and if the design is
approp to for the given application.
Fut e orts on the findings and
rove igatio will be made, as
ap opriate, i the quarterly Report to
C gress on Ab rural Occurrences
REG-0900 ser .)
Dated at Washington, C. this 13th day of
May 1982.
Samuel J. Chilk,
Secretary of the Commission.
IFR DOG- 82-13654 Filed 6-18-ea 8:45 an1J
BILLING CODE 7590-01-M
OFFICE OF MANAGEMENT AND
BUDGET
Privacy Act of 1974; Revised
Supplemental Guidance for
Conducting Matching Programs
May 14, 1982.
AGENCY: Office of Management and
Budget.
ACTION: Issuance of Revised Guidance
Efficiency in Government, OMB
concluded that a revision was in order.
Accordingly, the Guidelines were
revised to clarify the language and to
simplify, where possible, the
administrative and procedural
requirements.
The Revised Guidelines were signed
by the Director of OMB on May 11, 1982,
and became effective on that date. Their
text is set forth below.
Brenda A. Mayberry,
Acting Budget and Management Officer.
May 11, 1982.
Memorandum for the Executive Departments
and Establishments
From: David A. Stockman, Director.
Subject: Revised Supplemental Guidance for
Conducting Matching Programs.
I am attaching a copy of our revised
Guidelines on conducting computerized
matching programs. This revision updates
and simplifies earlier guidance issued on
March 30, 1979. It is effective immediately.
The revision is the result of our evaluation
of agencies' operating experiences under the
original Guidelines. The new Guidelines
incorporate many agency recommendations
for clarifications and changes. In addition,
they greatly simplify the notice and reporting
requirements of the earlier version.
Direct comments or questions on these
Guidelines to OMB's Office of Information
and Regulatory Affairs.
Matching Guidelines
1. Purpose--These Guidelines
supplement and should be used in
conjunction with the "OMB Guidelines
on the Administration of the Privacy Act
of 1974," issued on July 1, 1975 and
supplemented on November 21.1975.
They replace earlier guidance on
d
i
uct
ng computerized matching
for Conducting Computerized Matching con
Programs programs issued on March 30, 1979.
They are intended to help agencies
SUMMARY: This document revises and relate the procedural requirements of
updates guidance to the agencies on the Privacy Act to the operational
conducting automated matching requirements of computerized matching.
programs originally issued on March 30, They are designed tc address the
1979. concerns expressed by the Congress in
1 1982 the Privacy Act of 1974 that "the
EFFECTIVE DATE: Ma
y
run run I ncf Inra,mmArIVN CUNTAGT: sophisticated information technology,
Robert N. Veeder, Office of Information while essential to the efficient
and Regulatory Affairs, Office of operations of the Government, has
Management and Budget, Room 3235, greatly magnified the harm to individual
New Executive Office Building, privacy that can occur from any
Washington,. D.C. 20502; telephone (202) collection, maintenance, use, or
395-4814. dissemination of personal information."
SUPPLEMENTARY INFORMATION: The These Guidelines do not authorize
Guidelines were originally issued on activities which are not permitted by
March 30, 1979 (44 FR 23138). After law; nor do they prohibit activities
evaluating agencies experiences expressly required to be performed by
operating under those Guidelines and law. Complying with these Guidelines,
considering comments from agencies however, does not relieve a Federal
and concerned groups such as the agency of the obligation to comply with
Presidents Council on Integrity and the provisions of the Privacy Act,
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Federal Register Vol. 47, No. 97 ednesday, ay o ices 21655
would be observed even after hours of
running without cooling water; and (2)
generally, surveillance testing is of such
a short duration that no noticeable seal
degradation would occur even if cooling
flow were necessary for sustained
operation. Since pumps.required during
the post-LOCA recirculation, are
generally located outside primary
containment (in the auxiliary building)
degraded pump seals would result in the
leakage of radioactively contaminated
water outside containment.
Similarly, pumps provided with
bearing lube oil coolers could be
susceptible to flow blockages due to
fouling organisms or the accumulation of
corrosion products or silt deposits. Flow
blockages in these coolers could also go
unnoticed during surveillance testing
unless the cooling water flow was
monitored. This could result in
premature bearing failure when the
pumps are needed to run for an
extended period of time, e.g., following a
LOCA.
The safety concern identified by these
events is the possible degradation of the
beat transfer capabilities of redundant
safety systems to the point where
system function is lost. Preventive
measures and methods of detecting
gradual degradation have been
inadequate in certain areas to preclude
the occurence. The above postulated
events involve a common cause failure
mode that can affect redundant systems.
Aquatic organisms, mud silt and
corrosion products have been the main
source of flow blockage in the coolant
piping system and associated heat
exchangers where events have occurred.
Cause or Causes-A variety of causes
lead to the events reported in Table 1.
At Arkansas Nuclear One, the first
event discovered September 3. 1980, the
growth of Asiatic clams was
unanticipated in the design and
appropriate operational control features
were not provided. The design and
operational control features that did
exist were inadequate to prevent the
buildup of mud, silt, and corrosion
products from becoming a major
problem.
The second event at Arkansas
Nuclear One, Unit 2 on January 14, 1982
assumes additional significance as
compared to the other described events
since it indicates that (1) although the
corrective actions taken to prevent
buildup of marine organisms may not be
totally effective, the increased frequency
of surveillance implemented as a result
of the previous event allowed the
licensee to detect the claim intrusion in
its early stages,' and (2) the rate of
accumulation of the organisms can be
rapid. During the surveillance test, the
flow dropped from 1800 gpm to
approximately 800 gpm over a five
minute interval, indicating a sizeable
blockage. About six buckets of clams
were removed. The event remains under
investigation. The. licensee is studying
the service water piping to identify for
inspection any portions of piping that
may be conductive to Asiatic clam
growth, and other long-term
preventative measures; this study is
planned to be complete prior to the
refueling outage scheduled for October
1983.
At Rancho Seco, the corrosion
occurred because the heads were cast
steel. A corrosion resistant coating such
as epoxy or copper/nickel cladding
would have prevented the problem.
Existing surveillance testing procedures,
however, were also deficient in that the
safety-related heat exchanger
performance was not verified under
appropriate accident conditions.
At Brunswick, the chlorination
program, which was part of the program
to control the growth of marine
organisms, was stopped for
approximately 14 months due to
potential operational problems and
environmental effects. Although
operational and administrative controls
were inadequate at Arkansas Nuclear
One and Brunswick to detect early signs
of the problem, the plants were
shutdown when the technical
specification limits could no longer be
met. As previously discussed, the
incident at Brunswick has the most
safety significance of the incidents
described in this report. Unit 1, which
was shutdown on April 17,1981 to begin
a scheduled maintenance outage,
experienced a total loss of the residual
heat removal system on April 25, 1981.
In order to provide residual heat
removal capacity during the plant.
shutdown, an alternate cooling flow
path had to be established. Because of
the problems found on the Unit 1 RHR
heat exchangers, the similar heat
exchangers in the operating Unit 2 were
examined. For RHR heat exchanger 2A,
a higher than normal differential
pressure at design flow was discovered;
however, the baffle plate was not
displaced. The baffle plate was found
displaced for RHR heat exchanger 213.
Therefore, Unit 2 was shutdown using
heat exchanger 2A at reduced capacity.
After the unit was in cold shutdown,
and alternate cooling flow path was
'Inspection of other safety-related coolers
showed only traces of Asiatic clams with no
significant accumulation,
established (as in Unit 1 described
above) and the heat exchangers were
taken out of service of repair.
At San Onofre, the growth of
gooseneck barnacles was attributed to
the termination of a heat treatment
procedure that controls their growth.
The treatment was terminated during a
protracted plant shutdown of 14 months.
The system problems were noted during
routine operational checks.
At Pilgrim, the mussels apparently
grew in the Salt Service Water System
even though a back flusing and cleanout
program was instituted to control their
growth. Routine surveillance indicated a
continuing problem due to decreasing
heat transfer capabilities.
In general, the causes of the incidents
above related to an inadequate
surveillance and monitoring of the heat
exchanger performance characteristics
such as flow rates, fouling factors, heat
transfer coefficients, etc.
Actions Taken To Prevent Recurrence
Licensees-The licensees of Arkansas
Nuclear One, Rancho Seco, Brunswick,
San Onofre Unit 1 and Pilgrim have
cleaned and flushed the affected cooling
water systems. The licensees have also
committed to improving design features
and detection techniques which are
intended to preclude the. development of
significant fouling of safety-related
cooling systems in the future.
NRC-The NRC conducted special
inspections regarding the events at the
facilities noted above. In addition, on
April 10, 1981 the NRC's Office of
Inspection and Enforcement issued IE
Bulletin 81-03, "Flow Blockage of
Cooling Water to Safety System
Components by Corbicula sp. (Asiatic
Clam) and Mytilus sp. (Mussel)". The
Bulletin requested licensees to
determine whether either species was
present in the vicinity of their station
and the extent of any fouling these
organisms may have caused in fire
protection or safety-related systems.
The responses to the Bulletin have been
received from all of the operating plants.
The responses received represent 48
sites. Of these, 21 sites reported positive
findings either in the plant or in the
source or receiving waterbody. Eight
sites have seen some evidence of
Asiatic Clams in the plant and six sites
have seen evidence of mussels in the
plant. This has ranged from occasional
findings of a few shell fragments in the
main condenser to major infestations.
An additional seven sites have reported
that while Asiatic clams were not yet
present in the plant, they were present
in either source or receiving
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4 , o. iAp
a es ay, ay 19, 1982 / Notices
21657
including any provisions not cited in (4) Matches done to produce aggregate (f) Subsequent actions expected of the
these Guidelines. statistical data without any personal source (e.g., verification of the identity
2. Scope-'t'hese guidelines a 1 t identif'e
i r
pp y o
all agencies subject to the Privacy Act of (5) Matches done to support any
1974 (5 U.S.C. 552a), and to all matching research or statistical project where the
programs: specific data are not to be used to make
a. Performed by a Federal agency, decisions about the rights, benefits, or
whether the personal records used in the privileges of specific individuals.
match are Federal or non-Federal. (6) Matches done by an agency using
b. For which a Federal agency its own records.
discloses any personal records for use in d. A "matching agency" is the Federal
a matching program performed by any agency which actually performs the
other Federal agency or any non-Federal match.
organization. e. A "source agency" is the Federal
are effective on their date of issuance-
May 11, 1982.
4. Definitions-For the purposes of
these Guidelines:
a,ya.- VL L- vL-u~ w ae uses in me
match. Note that in some circumstances,
a source agency may be the instigator
and ultimate beneficiary of the matching
pro
ram
as wh
l
k
g
,
en an agency
ac
ing
a. All the terms defined in the Privacy computer resources uses another agency
Act of 1974 apply. to perform the match. The disclosure of
b. A "personal record" means any records to the matching agency and any
information pertaining to an individual subsequent disclosure of "hit
"
b
s
(
y
that is stored in an automated system of either the matching or the source
records, e.g., a data base which contains agencies) must be done in accordance
information about individuals that is with the provisions of paragraph (b) of
retrieved by name or some other, the'Privacy Act.
personal identifier. f. A "hit" Is the identification, through
c. A "matching program" is a a matching program, of a specific
procedure in which a computer is used . individual.
to compare two or more automated 5. Guidelines for Agencies
systems of records or a system of
records with a set of non-Federal
records to find individuals who are
common to more than one system or set.
The procedure includes all of the steps
associated with the match, including
obtaining the records to be matched,
actual use of the computer,
administrative and investigative action
on the hits, and disposition of the
personal records maintained in
connection with the match. It should be
noted that a single matching program
may involve several matches among a
number of participants.
Matching Programs do not include the
following:
(1) Matches which do not compare a
substantial number of records, e.g.,
comparison of the Department of
Education's Defaulted Student Loan
data base with the Office of Personnel
Management's Federal Employee data
base would be covered; comparison of
six individual student loan defaultees
with the OPM file would not be covered.
(2) Checks on specific individuals to
verify data in an application for benefits
done reasonably soon after the
application is received.
(3) Checks on specific individuals
based on information which raises
questions about an individual's
eligibility for benefits or payments done
reasonably soon after the information is
received.
Participating in Matching Programs-
Agencies should acquire and disclose
matching records and conduct matching
programs in accordance with the
provisions of this section and the
Privacy Act.
a. Disclosing Personal Records for
Matching Programs
(1) To Another Federal Agency-
source agencies are responsible for
determining whether or not to disclose
personal records from their systems and
for making sure they meet the necessary
Privacy Act disclosure provisions when
they do. Among the factors source
agencies should consider are:
(a) Legal authority for the match;
(b) Purpose and description of the
match;
(c) Description of the records to be
matched;
(d) Whether the record subjects have
consented to the match; or whether
disclosure of records for the match
would be compatible with'the purpose
for which the records were originally
collected, i.e., whether disclosure under
a "routine use" would be appropriate;
whether the soliciting agency is seeking
the records for a legitimate law
enforcement activity-whichever is
appropriate; or any other provision of
the Privacy Act under which disclosure
may be made;
(e) Description of additional
information which may be subsequently
disclosed in relation to "hits"
of the "hits" or follow-up with
individuals who are "hits").
(g) Safeguards to be afforded the
records involved, including disposition.
If the agency is satisfied that
disclosure of the records would not
violate its responsibilities under the
Privacy Act, it may proceed to make the
disclosure to the matching agency. It
should ensure that only the minimum
information necessary to conduct the
match is provided. If disclosure is to be
made pursuant to a "routine use"
(Section (b)(3) of the Privacy Act), it
should ensure that the system of records
contains such a use, or it should publish
a routine use notice in the Federal
Register. The agency should also be sure
to maintain an accounting of the
disclosures pursuant to section (c) of the
Privacy Act.
(2) To a Non-Federal Entity-Prior to
disclosing records to anon-Federal
entity for a matching program to be
carried out by that entity, a source
agency should, in addition to all of the
considerations in 5a(1) above, also make
reasonable efforts, pursuant to section
(e)(6) of the Privacy Act, to "assure that
such records are accurate, complete,
timely, and relevant for agency
purposes."
b. Written Agreements-Prior to
disclosing to either a Federal or non-
Federal entity, the source agency should
require the matching entity to agree in
writing to certain conditions governing
the use of the matching file, e.g.: That
the matching file will remain the
property of the source agency and be
returned at the end of the matching
program (or destroyed as appropriate);
that the file will be used and accessed
only to match the file(s) previously
agreed to; that it will not be used to
extract information concerning "non,
hit" individuals for any purpose; and
that it will not be duplicated or
disseminated within or outside the-
matching agency unless authorized in
writing by the source agency.
c. Performing Matching Programs-
(1) Matching agencies should maintain
reasonable administrative, technical
and physical security safeguards on all
files involved in the matching program.
(2) Matching agencies should insure
that they have appropriate systems of
records including those containing
"hits," and that such systems and any
routine uses have been appropriately
noticed in the Federal Register and
reported to OMB and the Congress as
appropriate.
d. Disposition of Records-
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F dera Register
(1) Matching agencies .will return or
destroy source matching files (by mutual
agreement) immediately after the match,
(21 Records relating to hits will be
kept only so long as an investigation,
either criminal or administrative, is
active and will be disposed of in
accordance with the requirements of the
Privacy Act and the Federal Records
Schedule.
e. Publication Requirements?
(1) Agencies, prior to disclosing
records outside the agency, will publish
appropriate "routine use' notices in the
Federal Register, if necessary. -
(2) If the matching program, will result
in the creation of a new or the
substantial alteration of an existing
system of records, the agency involved
should publish the appropriate Federal
Register notice and submit the requisite
report to OMB and the.Congress
pursuant to OMB Circular No. A-108.
f. Reporting Requirements?
(1) As close to the initiation of the
matching program as possible, matching
agencies shall publish in the Federal
Register a brief public notice describing
the matching program. The notice should
include:
(a) The legal authority under which
the match is being conducted;
(b) A description of the matching
program including whether the program
is one time or continuing, the
organizations involved, the purpose(s)
for which the program is being
conducted, and the procedures to be
used in matching and following up on
the "hits";
(c) A complete description of the
personal records to be matched,
including the source(s), system of
records identifying data, date(s) and
page number(s) of the most recent
Federal Register full text publication
where appropriate;
(d) The projected start and ending
dates of the program;
(e) The security safeguards to be used
to protect against unauthorized access
or disclosure.of the personal records;
and
(f) Plans for disposition of the source
records and "hits."
Agencies should send a copy of this
notice to the Congress and to the Office
of Management and Budget at the same
time it is sent to the Federal Register.
(2) Agencies should report new or
altered systems of records as described
in e (2) above as necessary.
(3) Agencies should also be prepared
to report on matching programs
pursuant to the reporting requirements
of either the Privacy Act or the .
Paperwork Reduction Act. Reports will
be solicited by the Office of Information
and Regulatory Affairs and will focus on
both the protection of individual privacy
and the government's effective use of
information technology. Reporting
instructions will be disseminated to the
agencies 'as part of either the reports
required by section (p) of the Privacy
Act or section 3514 of Pub. L. 96-511.
g. Use of Contractors-Matching
programs should, as far. as practicable,
be conducted "in-house" by Federal
agencies using agency personnel, rather
than by contract. When contractors are
used, however,
(1) The matching agency should,
consistent with subsection (m) of the
Privacy Act, cause the requirements of
that Act to be applied to the contractor's
performance of the matching program.
The contract should include the Privacy
Act clause required by FPR Amdt. 155,
41 CFR 1-1.337-5;
(2) The terms of the contract should
include appropriate privacy and security
provisions consistent with policies,
regulations, standards and guidelines
issued by OMB, GSA, and the
Department of Commerce;
(3) The terms of the contrct should
preclude the contractor from using,
disclosing, copying, or retaining records
associated with the matching program
for the contractor's own use;
(4) Contractor personnel involved in
the matching program should be made
explicitly aware of their obligations
under the Act, and of these guidelines,
agency rules and any special safeguards
in relation to each specific match
performed.
(5) Any disclosures of records by the
agency to the contractor should be made
pursuant to a "routine use" (Section
(b)(3) of 5 U.S.C. 552a).
6. Implementation and oversight- the
Office of Management and Budget will
oversee the implementation of these
Guidelines and shall interpret and
advise upon agency proposals and
actions within their scope, consistent
with section 6 of the Privacy Act.
IFR Doc. 82.13563 Filed 8-18-02; 8:45 am]
BILLING CODE 3110-01-M
SECURITIES AND
COMMISSION
Midwest Sto E hange, Inc,;
Applications to nlisted Trading
Privileges and of pportunity for
Hearing
May 12, 1982.
exchange has fired applicaons with the
Securities and 1):xchange Co mission
Securities Exchange Act of 1934\and
Rule 12f-1 thereunder, for unlisted
tra ing privileges in the following
sto ks:
Ana omp Incorporated
Co coon Stock, $1 Par Value (File No. 7-
Cullii e Database Systems Incorporated .
Com on Stock, $.10 Par Value (File No. 7-
Hil.achi Amited
6217).
Common Sock, $.50 Par Value)(File No.. 7-
6219).
Southmark Co
ration (Geor
$1 Par Valit
Common Stoc
622)
These securiti
securities exchan
t
the consolidated
system.
Interested person
submit on or before
data, views and ar
s are Ii
or mo
es a
ns
ted and
are reported in
re invited to
Persons desiring to
comments should fi
thereof with the 5
Se
Ex
Securities and
C.
Washington, D.
h
opportunity for
based upon all t
trading privileg
applications ar,
maintenance
and the prote
Market-Regula
authority.
George A. Fit
Secretary.
IrR Doc. 82-13
BILLING COD
eats concerning
pplications..
ret
y of
ang Con
oll
0549.
aring, t
ns
pplicati
io
e inform
fens ions of
.s pursuant
consistent
C
fair and orde
on of investo
th the .
ly markets
fission, by the Div]
on,.pursuant to de
Filed 5-18-82; 8:45 am]
8010-01-M
gated
[Release o. 34-18722; File No. SR-P RB-
Munici I Securities Rulemaking
Board; elf-Regulatory Organizations;
Propo ed Rule Change
Pro osed Rule changes by Municipal
Securities Rulemaking Board, relatln$ to
calcu ations. Comments requested on or
befo e June 9, 1982.
I? rsuan.t to Section 19(b)(1) of the .
Sec rities Exchange Act of 1934, 15
U. U.C. 78s(b)(1), notice is hereby given
th t Qn April 27, 1982, the Municipal
Se unties Rulemaking Board filed with
e written
the
owing this
if it finds,
n available
nlisted.
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