ML24331A219

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ASME C and Connect Response Letter
ML24331A219
Person / Time
Issue date: 12/19/2024
From: Christian Araguas
NRC/RES/DE
To: Finney N
ASME Board on Nuclear Codes and Standards
Shared Package
ML24331A217 List:
References
Download: ML24331A219 (1)


Text

Mr. Ned Finney, Chair ASME Board on Nuclear, Clean Energy, Power, and Facilities Codes and Standards Two Park Avenue New York, NY 10016-5990

SUBJECT:

USE OF ASME C&S CONNECT BACKGROUND INFORMATION IN THE RULEMAKING PROCESS

REFERENCE:

ASME letter dated August 27, 2024, Use of ASME C&S Connect Background Information in the Rulemaking Process (ML24296A005)

Dear Mr. Finney,

The purpose of this letter is to respond to the referenced American Society of Mechanical Engineers (ASME) letter requesting that in the future the U.S. Nuclear Regulatory Commission (NRC) use content contained in the C&S Connect record background files as information only and not reference or cite such information as basis for any decisions and any rulemaking regarding ASME Section III or Section XI Code changes or Code Cases.

In response to your request, the NRC staff recognizes the value of your concern. However, the staff is not aware of any circumstance where information solely residing in the C&S Connect record background files has been cited in any agency decision or rulemaking concerning any ASME Section III, Section XI Codes, or Code Cases. The NRC staff decision-making process relies on, and may reference, non-proprietary information that has been made available during the ASME Code meetings that are open to be attended by interested members of the public.

Further, regarding information obtained from the C&S Connect records, all data used has been part of the meeting minutes. The NRC considers information openly discussed in ASME Code meetings and/or included in ASME Code meeting minutes to be publicly available. Going forward, NRC staff will advocate for any information tied or pertaining to potential regulatory disapproval to be made publicly available.

In conclusion, I thank you for your expressed concern. The NRC appreciates the open dialogue with ASME and welcomes future correspondence as the NRC continues to support the December 19, 2024

N. Finney development, revision, and use of ASME Codes and Standards. If you have questions or concerns, please contact me at Christian.Araguas@nrc.gov or 301-415-7210.

Sincerely, Christian J. Araguas, Director Division of Engineering Office of Nuclear Regulatory Research NRC Standard Executive cc:

Kathryn Hyam, ASME Director Clean Energy and Standardization Code and Standard Adam Maslowski, Staff Secretary Signed by Araguas, Christian on 12/19/24

N. Finney

SUBJECT:

USE OF ASME C&S CONNECT BACKGROUND INFORMATION IN THE RULEMAKING PROCESS DATED: DECEMBER 19, 2024 DISTRIBUTION:

D. Rudland, NRR M. Mitchell, NRR M. Benson, NRR K. Manoly, NRR A. Bufford, NRR M. Rahimi, RES ADAMS Package Accession No.: ML24331A217 *via e-mail OFFICE RES/DE/RGPMB RES/DE/RGPMB NRR/DEX NRR/DNRL NRR/DNRL NAME R. Gascot H. Karagiannis K. Manoly D. Rudland M. Mitchell DATE 11/27/2024 11/27/2024 12/09/2024 12/05/2024 12/04/2024 OFFICE NRR/DNRL NRR/DNRL NRR/DEX RES/DE NAME A. Buford M. Sampson T. Martinez (E. Benner for)

C. Araguas DATE 12/06/2024 12/18/2024 12/11/2024 12/19/2024 OFFICIAL RECORD COPY