ML19309B126
| ML19309B126 | |
| Person / Time | |
|---|---|
| Issue date: | 12/23/1976 |
| From: | Huberman B NRC COMMISSION (OCM) |
| To: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19309B125 | List: |
| References | |
| SECY-77-064, SECY-77-64, NUDOCS 8004030168 | |
| Download: ML19309B126 (2) | |
Text
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UNITED STATES 4
NUCLEAR REGULATORY COTATAISSION
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December 23, 1976 MEMORANDUM FOR: Tom Rehm FROM:
Ben Huberman
SUBJECT:
COMMENTS ON VENDOR AND THIRD-PARTY INSPECTION PROGRAM I cannot concur in the draft paper as written because it does not provide the Commission with a complete range of realistic alternatives. My reservations in this regard have been transmitted to IE on several occasions, including the recent Volgenau briefing for the Commission, but I will su=marize them once again below.
One of the major questions addressed by the paper is:
"Given that NRC should have a vendor inspection program, how should the current LCVIP be expanded to provide inspection coverage of all vendors?"
(Issue 2, page 12, underline added).
By the term "all vendors" IE means approximately 1,000 industry vendors. Under the present program about 109 vendors were inspected by NRC last year. The use of ASME inspectors as proposed j
in Alternative 3 would increase this figure to about 386 vendors, but it would do essentially nothing about the 500 or so non-ASME product vendors which the NRC program does not currently inspect.
(Last year only 18 non-ASME product vendors, other than NSSS, AE's and fuel fabricators, were inspected).
In short, alternative 3 does not offer coverage of all vendors.
The only Alternatives in the paper which offer " complete coverage" both involve dropping the idea of third party inspectors and either lowering inspection frequencies (Alternative 1) or dramatically increasing NRC manpower by about 69 persons (Alternative 2).
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The paper completely ignores an additional and realistic alternative:
namely, the use of third party ASME inspectors plus a modest increase in NRC vendor inspection personnel devoted to non-ASME vendors.
From the chart on page 6 of Appendix E it appears that only about seven additional persons would be required to provide adequate inspection coverage in
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those non-ASME product areas not fully covered by NRC today and which would remain uncovered during the proposed two years test of the third party concept.
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CONTACT:
Ken Pedersen (OPE) 634-1548 Pat Comella (OPE)
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Tom Rehm.
To summarize:
Alternative 1:
(page 12)
Provides for inspection of all vendors but lowers frequency to inadequate levels.
Alternative 2:
(page 12)
Provides adequate coverage of all vendors but at a sharp increase in NRC resources.
Alternative 3:
(page 12-13) Holds NRC resources stable but does not provide for adequate coverage of all vendors (i.e., most g
non-ASHE vendors would go uninspected by NRC).
p Alternative 4:
(not Provides for coverage of all vendors at adequate inicuded) levels with a modest increase in NRC resources plus use of third party inspectors.
Alternative 4 is needed to give the paper balance and to provide the Commission with a full range of choices. Accordingly, I urge that such an alternative be incorporated in the paper before it is sent forward td the Commission.
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