ML20040G358
| ML20040G358 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1982 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20040G347 | List: |
| References | |
| NUDOCS 8202120207 | |
| Download: ML20040G358 (1) | |
Text
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FEB 101982 MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM:
Victor Stello, Jr., Chairman Committee to Review Generic Requirements
SUBJECT:
CRGR REVIEW 0F PROPOSED RULE ON ACCREDITATION OF TESTING LABORATORIES FOR EQUIPMENT QUALIFICATION At the fifth meeting on January 13 and continuing on January 21 and 22 due to inclement weather, the CRGR was briefed on the Equipment Qualification Program statu:.
During the briefing, the Committee was given the subject rule for consideration.
In this regard, the Committee agreed in general with the concept embodied in the rule, as reflected in subparagraph (a) of proposed 50.49a. However, the Committee has comments on certain details:
(a) Subparagraph (b) seems unnecessary and undesirable. If the accreditation process is taken as described in subparagraph (a), there appears little need for further reference to a particular document in subparagraph (b). Moreover, reference to the particular document in this fashion may restrict the use of future document modifications.
(b) More work is needed on providing for a proper implementation period in subparagraph (c).
It is essential to assure that the rule does not disrupt, or impose backfit requirements on, (1) the use of equipment qualified before the rule, or (2) the qualification testing on going at the time the rule is adopted.
Similarily it is also important to assure that there is a sufficient period before its mandatory implementation to assure that there will be sufficient numbers of accredited laboratories to do the work under the rule.
The Committee recommends that the proposed rule be forwarded for Commission consideration after it has been rewritten to accommodate the comments
- above, A/7 Vic or Stello, cJr., Chfirman Committee to Review Generic Requirements 8202120207 820204 PDR REVGP NRCCRGR PDR
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