ML19225D103
| ML19225D103 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/1979 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Matthew Green AMERICAN SOCIETY OF MECHANICAL ENGINEERS |
| References | |
| NUDOCS 7908070222 | |
| Download: ML19225D103 (4) | |
Text
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DISTRIBUTION:
rentral File JUN Z G 1579 TUC PDR LPDR NSIC QAB Projects QAB Chron. File NRR Reading File DJSkovholt, DPM J"praul, QAB lfr. ':civin D.
Green JGilray, QAB l
The Anerican Society of Mechanical FLiederbach, QAB Engineers l
345 E. 47th Street New York, NY 10017
Dear Mr. Green:
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SUBJECT:
ASME "ANAGFJ1E'lT PLAfl l
l Me have revicted your letter of April 2,1979 to !!r. Reinmuth and its enclosed Dra f t 6 of the ASME lunagement Plan.
Draft 6 was orepared in response to our i
rariues t for addi tional informa tion <.'ated November 28, 1978.
'le finJ that l
1raf t 6 addresses our earlier concern rela tive to being core r.early sel f-l i
contained and is responsive to nost of our earlier questions.
i t
l There are still several items requiring further clarification.
These are l
i enclosed. Also, we have nuoerous editorial cn. cents which ue feel can be l
resolved best at a.aeeting betucan a n_.ber of the ASME staff and Jack Snraul n f ny s ta f f.
Please contact Mr. Spraul on (301) 492-7741 to arrange such a neeting.
I I
It should be cle:rly noted, heuever, as indicated in item 3B of the enclosure, tha* 'ic da not "casider the !!anageoent Plan, as presently wr itten, to be j
res;>cnsive to SeG'on IV. A.2 of the Exchange of Correspon#nce.
This section l
gerierally calls for, cdifications "to improve and broaden the requirenents t
and adclinistrative prveiures associated with the Society's Codes and Standards I
i and nuclear cert:fication and inspection sys tem."
At a neeting held on May 24, l
1973 : ith rcpresentatives of the AS':E, Na tional Coard, and NRC attending, Mr. 7 ic':, chaincan of the "ain Comittee of the AS"E Boiler and Pressure j
Vessei Conaittee, sta ted that the first draf t of the "anace: ent Plan would cover the existing program, and that as progress was nade'on the anticipated progran, nodifications wo' Id be 7de to tiie Plan to incorporate the information called "or in Section IV.A.2.
This view was again expressed in the June 6, 1979
.:eeting '. eld at our offices with representatives frno the sa me organizations in attendance. The NRC staf f position, therefore, is that uatil this step ic complete, the NRC cannot arrive at a finding of equivalency in requirements i
and administrative procedures betucea ASME and NRC and, therefore, cannot grant full acceptance status to the Ibnager.cnt Plan.
An example of one area which requires increased attention is the prcarantic review and follow-up irplementation of Society N-type Certifica te Loplicants for their Cod? covered c ' A r gnt r ' r 'nd C r McH _ i n d ' n 'o ri a Pu;'.d;e _cf 4:pc dy4_M '_};alhfad ',y_ ___
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Iir. !!elvin R. Green Quality System Certificate. 'lhen such sources are physically remote from the applicant's place of business, there are generally no confinnatory checks by AS!'E survey teans or by the Certificate applicants at such sites.
Even when distances involved are reasonable, feu, if any, checks are made.
He look #cruard to hearing froa you further on this rutter.
Sincerely.
Odgin3,igned by 5
Walter P. H33SS j
Ualter P. Ibass, Chief Quality Assurance Branch l
Division. of Project !!anagement
Enclosure:
fequest for i
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!!dditional Information i
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4 REQUEST FOR ADDITIONAL INFORMATI0l1 DRAFT 6 0F THE ASME MANAGEMENT PLAN _
2B.
The ASME Management Plan re'ers only to Section III of the Code.
Since the
" Exchange of Correspondence" also refers to Section XI, the ASME's program for Section XI activities should be discussed or specifically excluded from the Management Plan as was the Quality System Certificate Program and the Owner's Certi ficate Pro] ram. Also clarify if the Plan covers Division 1 and/or Division 2 of Section III.
3B.
The ASME response to question 3A regarding Ittm IV.A.2 of the Exchange of Correspondence is unacceptable.
For the NRC to fulfill its comnitment of Item fV.C.3 of the Exchange of Correspondence ("To review and formally endorse the ASME certification orogram; third party ins 'ection under National Bo'rd enforcement; Authorized ;
ection requirements in accordance with ANSI /ASME N626 Standards and the.4ME Coiler and Pressure Vessel Code Section III, and Section XI when equivalency, (i.e., compatibility) with related NRC Regulations and Regulatory Guides has been achieved."), we must be informed how the present ASME certification system will be changed.
Inherent in how the ASME certification system will be changed is how ASME codes and standards will be changed.
Thus a detailed response to our question on the status and pl.:ns of the ASME regarding Item IV.A.2 of the Exchange of Correspondence is required.
(See also discussion in cover letter.)
4B.
The NCSC scope for nuclear work appears virtually identical to the PTCS scope for non-nuclear work.
Thus it appears the presentation beginning at the bottom of page 4 through the bottom of page 7 can be simplified and clarified.
78.
The footnote on page 8 should be moved to page 3.
The expression, " materials design," needs clarification.
Does " construction" include design verification?
The definition is not consistent with definitions listed in footnotes 1 and 2 to NCA-ll10. and we note that the term " construction" is defined differently for Divisicn 1 and Division 2 of Section III of the Code.
118.
The ASME response to question llA refers to a new sentence inserted on page 10.
It appears ASME intended to refer to page 11 vice page 10.
178.
In order for us to assess the " independence" of the ANI, the Plan must provide information relating to the contractual relationship between the certificate holder and its AIA.
In addition, to assure functioning according to the Code in a manner reflecting adequate independence, we recommend audits of ANIS and ANI Supervisors by some " independent" body - such as the ASME or (preferably) the National Board. We consider the " audit" of an ANI by his ANI Supervisor per N626 to be "first-line supervision" as opposed to an independent audit.
397 357
. Also, the role of a state in supplying ANIS is not clear from the Plan.
Does each state decide whether to supply ANIS or use an insurance company?
Can a manufacturer in a state with state-supplied AtlIs use an ANI from an insurance company instead? Do state-supplied ANIS receive the same pre-licensing exams from ne f;ational Board as insurance company supplied ANIS?
These questions typify the information needed in the Plan in this area.
26B. The ASME response to question 26A concerning checks and balances on the actions of an individual SCNC rember to preclude conflict of interest during any ballot action states there are no additional checks or balances other than the professional integrity of the individual.
Explain why additional controls would not be advisable.
298.
Discuss how a minority report from a survey team member af fects the certi-fication process. Are such minority reports maintained as part of the permanent records?
418.
Expand the sentence in Part VIII of the Management Plan concerning withdrawal of a Certifica te for cause.
Provide information on how the ASME is made aware of poor performance by Certificate holders and the actions taken by the ASME.
45.
Under P art II of the Plan, describe the interfaces with the NRL.
Items which should be considered for inclusion are permission of designatec NRC representatives to inspect and audit activities relating to the issue and cuntrol of Nuclear Certificates of Authcrization, a commitment to comply with 10 CFR Part 21, a comitment that the involved organizations will cooperate with the NRC in licensing and unforcement matters, a commitment that Code violations alleged by the NRC will be insestigated by the National Board (cf. page 16),
and a comnitment th;t the SCf" will analyze any NRC complaint against a Survey Team and take appropriate action (cf. page 24).
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