ML20027C013

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Forwards Ofc of Nuclear Regulatory Research Memo Explanining Concerns Re Proposed Rulemaking, Codes & Stds. Section of Rule in Question Not Intended to Upgrade or Downgrade Basic Quality of Product
ML20027C013
Person / Time
Issue date: 03/24/1982
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Roberts T
NRC COMMISSION (OCM)
Shared Package
ML20027A734 List:
References
FOIA-82-205 NUDOCS 8210120176
Download: ML20027C013 (1)


Text

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MAR 141982 l

p MEMORANDUM FORi Comissioner Roberts l

FROM:

William J. Dircks Executive Director for Operations l

SUBJECT:

SECY 82 PROPOSED RULEMAKING, " CODES AND STANDARDS" p

Attached is a memo from RES explaining the statement which concerned you.

It is clear that the facilities / procedures necessary to support an N stamp may cost much more than the ASME approval, but the section of the rule at point here was not intended to upgrade or downgrade the basic quality of the product (i.e., the requirements of the ASME code), but to establish the means of certifying it.

Egns:DWillizm J.Dircks William J. Dirck's Executive Director for Operations

Enclosure:

3/18/82 memo fm Mino'gue to Dircks cc: Chairman Palladino Commissioner Gilinsky Comissioner Ahearne SECY.

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%,.d MAR 181982 MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM:

Robert B. Minogue, Director Office of Nuclear Regulatory Research

SUBJECT:

COMMISSIONER ROBERTS' COMMENTS ON SECY-82-74 A question has been raised as to the correctness of :: statement in SECY-1 82-74 on page 7 of Enclosure 1.

The statement reads, "These applicant companies will incur estimated costs of $15,000 when applying for ASME approval."

The statement applies only to the ASME charges, made to a company applying for an ASME "N" stamp applied to Classes 2 and 3 components, for performing the accreditation survey (i.e., audits. and evaluations) necessary to make a detemination of whether or not an N stamp should be

. issued to the company. The ASME accreditation survey is usually made by a two or three man team over several days. The $15,000 figure used in SECY-82-74 was given to us by Mr. W. J. Woolacott, who is the Assistant Managing Director for Codes and Standards, ASME.

We recognize that in order to obtain an N stamp a company may need to improve the quality of its operation, thereby incurring additional costs. However, we assume that a company manufacturing components for nuclear power plants would be required to maintain a quality comparable.

to the ASME requirements because of the existing general requirements in our regulations. The proposed rule would codify use of the ASME Code including its N stamp as the vehicle for assuring the necessary quality of components.

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f Robert B. Minogue, Director Office of Nuclear Regulatory Research pf'Ib N

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FROM:

ACTION CONTROL DATES CONTROL NO.

C'ommission::r Roberts 3/26/82 11671 C"""'

OATE OF DOCUMENT INTERIM REPLY 3/4/82 TO:

PREPARE FOR SIGNATURE OF:

Chilk OCsAiauAN FILE LOCATION DExtCUTwE DRECTOR OTHER DESC.J PTION OLETTtnputMO O mEpOnT O OTnEn SPECIAL INSTRUCTIONS OR REM ARKS Question re fact in SECY-82-74 PRIORITY ASStGNED TO DATE INFORMATION ROUTING Minogna; DN 3/1R/R2 - Dircks Cornell Rehm Denton Cunningham NRC FORM 232 EXECUTIVE DIRECTOR FOR OPERATIONS Ch l

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