<snip>
First of my Assembler code is RMODE31 
So I anyway have to call something below the line to open to read to close
</snip>

It is not true that you have to call something below the line. Code doing 
OPEN and CLOSE can be RMODE 31, quite possibly needing to specify MODE=31.
The DCB itself needs to be below 16M. Even exits via the DCBE can be above 
16M.

Peter Relson
z/OS Core Technology Design

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