ML20129C609
| ML20129C609 | |
| Person / Time | |
|---|---|
| Issue date: | 10/21/1996 |
| From: | Miraglia F NRC (Affiliation Not Assigned) |
| To: | Reedy R AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20129C612 | List: |
| References | |
| NUDOCS 9610240069 | |
| Download: ML20129C609 (9) | |
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t UNITED STATES g
g NUCLEAR REGULATORY COMMISSION R
WASHINGTON, D.C. 20066-0001 o
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- s October 21, 1996 Mr. Roger F. Reedy Reedy Engineering, Inc.
Engineering Management Consultants 3425 S. Bascom Avenue, Suite 210 Campbell, California 95008
SUBJECT:
AUGUST 20 AND SEPTEMBER 23, 1996 LETTERS TO DR. SHIRLEY ANN JACKSON, CHAIRMAN
Dear Mr. Reedy:
Chairman Jackson has requested that I respond to your letters of August 20 and September 23, 1996.
I have reviewed your letters and find no new information that would cause a change in the positions previously sent to you in the letter from William T. Russell, dated July 30, 1996.
It is clear that our view with regard to these issues continues to differ from yours..However, I have reconsidered this matter and find our position remains unchanged.
You said on the last page of your August 20, 1996, letter that you know of a provision in the ASME code that has never been met for any code stamped component.
You described it as an administrative " Catch 22."
You should identify the provision and the instances of non-compliance you know of to the NRC.
In addition, you noted a concern about the manner in which a utility had been cited for an ASME code violation. You should identify the utility and the violation to the NRC.
Please respond at your earliest convenience.
Experience shows that NRC's interaction with the ASME and NRC's implementation of the ASME Code have contributed substantially to ensuring safe operation of nuclear plants.
In order to ensure effective cooperation between the two organizations, senior NRC and ASME representatives meet periodically to discuss issues of mutual interest. To this effect, we have scheduled a meeting with senior ASME officials to discuss the requirements of the Code of Federal Regulations and NRC's implementation of the ASME Code including the use of engineering judgement, ASME Code interpretations and other issues you have raised. We believe this discussion is appropriate in order to ensure a continued clear understanding of the relationship between th.! two organizations and their respective authorities and responsib!11 ties. We will inform you of the results of that discussion.
Your September 23, 1996, letter stated'that the new inspection guidance contained in Part 9900 of the NRC Inspection Manual could be misleading.
In response to this concern, we reviewed the guidaace and agree that it could be misleading.
It was not our intent to suggest that IWB-3500 and IWB-3600 are applicable to class 2 and 3 components.
However, because the discussion of the three. subjects of the guidance, code interpretations, engineering judgement, and timeliness of flaw evaluations, were not clearly delineated, this point could be confusing.
Therefore, we intend to provide clarification 9610240069 961021 PDR ORC NRRA fd13/
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1 Mr. Roger F. Reedy to the guidance by providing headings that clearly separate the discussion of the three topics. We believe that these changes, along with some editorial changes, will clarify the guidance.
l Sincerely, Frank J. Miraglia, Acting Director Office of Nuclear Reactor Regulation Distribution:
NRC PDR/ Central Files EMCB RF GMillman, RES JStrosnider MMayfield, RES RHermann JCraig, RES FMiraglia KWichman l
RZimmerman DE RF l
BGrimes SBozin 96-12 l
KBohrer GT96671 &
CECarpenter 96742 i
DOCUMENT NAME: A:\\ REEDY.2
- See previous concurrence ** concur w/ edits I
To receive a copy of this document, indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachnent/ enclosure N =
W3 copy I
OCM OCM I' 9 l
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/24/96 10/21/96 DE:EMCB*
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- WRussehh, SBurns JT.a 9/06/96 9/06/96 9/06/96 9/11/9hfM/[ [S/ /96 9/h[96 0FFICLAL RECORD ' COPY t g
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i October 21,1996 i
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l EDO-j The Commissioners have reviewed and concurred in the proposed j
response to Roger Reedy's August 20,1996 letter. Commissioner Diaz's i
office believes the_ letter would benefit from syntax / editing.
l Doris Mossburg, SECY 415-1964 l
.--~.- --.---
1 1
Mr. Roger F. Reedy
/
l Reedy Engineering, Inc.
Engineering Management Consultants 3425 S. Bascom Avenue, Suite 210 j
Campbell, California 95008
SUBJECT:
AUGUST 20, 1996 LETTER TO DR. SHIRLEY ANN JACKSON, CHAI N
Dear Mr. Reedy:
Chairman Jackson has requested that I respond to your letter of August 20, 1996.
I have reviewed your letter and find no new informa on that would cause a change in the positions previously sent to you i my letter dated i
July 30, 1996.
It is clear that our view with regard t these issues j.
continues.to differ from yours. However, I have reco idered this matter and j
find our position remains unchanged.
l You said on the last page of your letter that you now of a provision in the i
ASME code that has never been met for any code amped component.
You described it as an administrative " Catch 22."
ou should identify the provision and the instances of. non-complianc you know of to the NRC.
In i
addition, you noted a. concern about the man er in which a utility had been j
cited for an ASME code violation. You sh Id identify the utility and the violation to the NRC. Please respond at our earliest convenience.
Experience shows that NRC's interacti with the-ASME and NRC's implementation i
of the ASME Code have contributed su stantially to ensuring safe operation of nuclear plants.
In order to ensur effective cooperation between the two organizations, senior NRC and ASM representatives meet periodically to discuss issues of mutual interes. The agenda for the next meeting will include a discussion of the re irements-of the Code of Federal Regulations and NRC's implementation of t ASME Code including the use of engineering judgement, ASME Code interpr ations and other issues you have raised. We believe this discussion is ppropriate in order to ensure a continued clear understanding of the relat onship between the two organizations and their respective authorities a responsibilities. We will inform you of the results of that discuss n.
Sincerely, Frank J. Miraglia, Acting Director Office of Nuclear Reactor Regulation C
lENT NAME: A:\\RE
.2
- See previous concurrence ** concur w/ edits T
'Ive a copy of this unent, Indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment /enetosure N = No c Cj OCM o
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09/24/96 DE:EMCB*
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RHermann:adi BSheron AThadani WRussell SBurns J
lor 9/06/96 9/06/96 9/06/96 9/11/96 9/ /96 9/13/96 0FFICIAL RECORD COPY
September 24,.1996 EDO-Attached is the proposed response to Roger Reedy. I have made the edits suggested by the Chairman and Commissioner McGaffigan.
There is no need for further Commission review.
Doris Mossburg 415-1964 Att.
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SUBJECT:
AUGUST 20, 1996 LETTER TO DR. SH LEY ANN JACKSON, CHAIRMAN s
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Dear Mr. Reedy:
Chairman Jackson has requested that I res and to your letter of August 20, 1996.
I have reviewed your letter and f d no new information that would cause a change in the positions previous y sent to you in my letter dated July 30, 1996.
It is clear that our vi with regard to these issues continues to differ from yours. Howev
, I have reconsidered this matter and find our position remains unchanged.
Experience shows that NRC's interaction with the ASME and NRC's implementation of the ASME Code have contributed substantially to assuring safe operation of In order to assure effective cooperation between the two nuclear plants.
organizations, senior NRC and ASME representatives meet periodically to discuss issues of mutual interest. The agenda for the next meeting will include a discussion of the requirements of the Code of Federal Regulations
.and NRC's implementation of the ASME Code including the use of engineering We judgement, ASME Code interpretations and other issues you have raised.
believe this discussion is appropriate in order to assure a continued clear understanding of the relationship between the two organizations and their respective authorities and responsibilities. We will inform you of the results of that discussion.
Sincerely, William T. Russell, Director Office of Nuclear Reactor Regulation Distribution:
NRC PDR/ Central Files EMCB RF GMillman, RES JStrosreider MMayfield, RES RHermann JCraig, RES FMiraglia KWichman RZimmerman DE RF BGrimes SBozin 96-12 KBohrer GT96671 DOCUMENT NAME: A:\\ REEDY.2
- See previous concurrence To receive a copy of this document, indicate in the box C= Copy w/o attachment / enclosure Escopy with attachment copy 0FFICE DE:EMCB*
E DE:D*
C ADT:NRR E
D:NRR
'0GC ED0p
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\\n Jhlor WE RHermann:adl BSheron AThadani WRussell SBurns DATE 9/06/96 9/06/96 9/06/96 9/11/96 9/
/96 '
9/d96
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Mr. Roger F. Reedy Reedy Associates, Inc.
15951 Los Gatos Blvd., Suite 1 Los Gatos, California 95032 i
SUBJECT:
AUG T 20, 1996 LETTER TO DR. SHIRLEY ANN JACKSON, CHAIRMAN i
Dear Mr. Reedy:
l Chairman Jackson ha g(requested that I respond to your letter of August 20 1996.
I.have reviewe your letter and find no new information that would cause a change in the positions previously sent to you in my letter dated July 30, 1996.
It is clear t at our view with regard to these issues continues to j
differ from yours. Howe r, I have reconsidered this matter and find our l
position remains unchange Experience shows that NRC's *nteraction with the ASME'and NRC's implementation of the ASME Code have contrib ted substantially to assuring safe operation of i
nuclear plants.
In order to a sure effective cooperation between the two organizations, senior NRC and A E representatives meet periodically to discuss issues of mutual interes The agenda for the next meeting will include a discussion of the requi ments of the Code of Federal Regulations and NRC's implementation of the ASM judgement,ASMECodeinterpretation(Codeincludingtheuseofengineering s nd other issues you have raised.
We i
believe this discussion is appropria in order to assure a continued clear understanding of the relationship bet en the two organizations and their i
l respective authorities and responsibilih es. We will inform you of the results of that discussion.
l l
Sincerel 1
i William T. Rus ell, Director Office of Nucle r Reactor Regulation Distribution:
NRC PDR/ Central Files EMCB RF GMillman, RES j
JStrosnider MMayfield, RES RHermann JCraig, RES FMiraglia KWichman i
RZimr..erman DE RF 4
BGrimes SBozin 96-12 j
KBohrer GT96671 DOCUMENT NAME: A:\\HERMAWi\\AGAIN2
/
To recalve a c of thls document, Indicate in th CPEopy tta t enclosure E= Copy with at achment/ enclosure N a No OFFICE EMCB E
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AbT ([ h D:NRR OGC EDO\\
Rhermann:adl Bhon AThYani WRussell SBurns JTayl'or WE 9/b/96 9/ (, /96 9/h/96 9/ /96 9/ /96 9/ /96 DATE 0FFICIAL RECORD COPY
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FROM DUE: 10/10/96 EDO CONTROL: GT96742 DOC DT: 09/23/96 FINAL REPLY:
Roger F.
Reedy Ready Engineering, Inc.
TO:
Chairman Jackson FOR SIGNATURE OF :
i Miraglia DESC:
ROUTING:
ASME CODE INTERPRETATION tTavinr Milhoan Thompson l
Blaha i
1 DATE: 09/30/96 ASSIGNED TO:
CONTACT:
NRR Miraglia SPECIAL INSTRUCTIONS OR REMARKS:
Put EDO and Chairman on for concurrence.
I Chairman's Office to review response prior to disptach.
Ref.- GT96671.
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OFFICE OF THE SECRETARY l
CORRESPONDENCE CONTROL TICKET PAPER NUMBER:
CRC-96-1030 LOGGING DATE: Sep 27 96 i
ACTION OFFICE:
EDO 1
i AUTHOR:
ROGER REEDY 4
AFFILIATION:
CALIFORNIA ADDRESSEE:
CHAIRMAN JACKSON LETTER DATE:
Sep 23 96 FILE CODE:
SUBJECT:
ASME CODE INTERPRETATION 4
ACTION:
Direct Reply DISTRIBUTION:
CHAIRMAN, COMRS SPECIAL HANDLING: SECY TO ACK 4
CONSTITUENT:
1 NOTES:
CHAIRMAN SHOULD REVIEW RESPONSE PRIOR TO DISPATCH "REF CRC 96-0932" DATE DUE:
Oct 11 96 SIGNATURE:
DATE SIGNED:
AFFILIATION:
i EDO -- GT96742 j