ML19261C414
| ML19261C414 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/1978 |
| From: | Halman E NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML19261C376 | List: |
| References | |
| FRN-43FR3288, REF-10CFR9.7, RULE-PR-41-20 NUDOCS 7903220399 | |
| Download: ML19261C414 (2) | |
Text
f UNITED STATES 4
NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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e' February 8,1978
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MEMCRANDUM FOR:
File
SUBJECT:
COMMENTS ON NRC'S PROPOSED NEW RULE RE ORGANIZATIONAL CONFLICT OF INTEREST UNION CARBIDE C. E. Winters, Attorney for UC's Washington office, inquired as to whether the proposed rule would change NRC's way of doing business with the Oak Ridge National Labs.
I responded that as presently drafted, the rule would apply to other Federal agencies, including 00E.
This would mean that rather than following DOE OCI rules, Oak Ridge would be governed by NRC policy in any work it undertakes for the NRC.
I explained to Mr. Winters that this aspect of the rule is currently under consideration within the NRC and'what the final regulation will stipulate with respect to whose rule, DOE or NRC, is applicable to 00E Labs, will be resolved during the coment period. Mr. Winters expressed satisfaction with the reply and stated UC would probably make its views known during the coment period.
AMERICAN INSTITUTE OF ARCHITECTS Mr. Biegel of AIA inquired as to whether the proposed rule deliberately singled out architect engineers for applicability.
I stated that our current conflict language applies to architect engineers in the same manner as the proposed rule, but that there was no intention to deliberately focus upon AE's in this rule. Mr. Siegel stated that he considers it unfair to restrict AE's who perform design work from competing in the follow-on procurement.
He said that has been consistently AIA's position with respect to 0FPP and ERDA OCI rules and that he would so coment to us formally.
HARTFORD STEAM BOILER INSPECTION AND INSURANCE CCMPANY Mr. Earl Kemmler, Vice-President of Hartford, inquired as to whether it was the intent of our OCI rule to include the NRC's licensing procedures for nuclear power plants. He stated that our definition of " contract" in 20-1.5402(e) stipulates any arrangement with the NRC which could be interpreted to mean our licensing arrangements with utilities and others.
I stated that this was not our intent, we only are concerned about procurement arrangements, and that we wnuld look at our definition to perhaps make it more precise with respect to our intended meaning.
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February 8,1978 THE GOVERNMENT CONTRACTOR At his request, I gave Marion Freedman, Editor of the Government Contractor, background information on the development of our CCI rule.
He was concerned about possible conflict betweer qur rule and the upcoming 0FFF Regulation.
I stated that in the development of our rule, we attempted to be consistent with the 0FPP draft and also with the published ERDA Regulation.
I explained to Mr. Freedman that had we not been required by statute to develop the rule by December 31, 1977, we would probably have awaited the 0FPP Regulation prior to establishing our own.
Mr. Freedman complimented the NRC on a well-written regulation and said that the next issue of the Government Contractor would sumnarize its major provisions.
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J. Maynard, ELD H. Coleman, DC
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