ML20244B256

Forwards Corrections to Nupac PAS-1 Packaging Sar,Section 9.0 Re QA

ML20244B256
Person / Time
Site:	07109184
Issue date:	04/07/1989
From:	Porter S PACIFIC NUCLEAR SYSTEMS, INC.
To:	Lee H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
25406, L-9746, NUDOCS 8904190093
Download: ML20244B256 (18)

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O#3229 April 7, 1989 IL3. NUCLEAR REGULATORY Goguiss!0ri 8/

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Mr. Henry Ice d

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SUBJECT:

Replacement Pages for Section 9.0, Qua

surance, Certificate of Compliance No.

9184, NuPac PAS-1 Packaging

Dear Mr. Lee:

Please find enclosed Section 9.0 of the NuPac PAS-1 Packaging Safety Analysis Report (SAR) as replacement for the previously submitted copy.

If you have any questions, please contact us at (206) 874-2235.

Sincerely, NUCLEAR PACKAGING, INC.

4.

/

n:1 Steven A.

Porter Engineering Specialist

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SAP / man 3

Enclosures:

As stated a

FEE NOT REQUIRED

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'8904190093 890407 j

- DR ADOCK 0710 4

k N uclear Packaging,Inc. 1010 South 336th Street FederalWay. Washington 98003 (206)874-2235 Fax (206)874 2401 Telex:152667 PNSI UD 1

NuPsc PAS-1 Consolidated SAR, Rev. 0-March 31, 1989 9.0 QUALITT ASSURANCE The' NuPac PAS-1 Packaging has been designed and will be f abricated by Nuclear Packa ging, Inc., (NuPac) Federal Way, Washington.

The Quality Assurance Pro-gram used for the design, f abr ica t ion, assembly, t esting, use and maintenance of the NuPac PAS-1 satisfies. the eighteen (18) criteria of 10.CFR 71, Subpart H in its entirity. NuPac's Quality Assurance Program meeting the se criteria has been submitted to the United States Nuclear Regulatory Commission and has been awarded Approval Naaber 0192, Revision 1.

A synopsis of the Pacific Nuclear Systems, Inc. / Nucle ar Pa cka ging, Inc.

Quality Assurance Program follows:

9.1 Introduction l

Pacific Nuclear Systems, Inc. (PNSI) has developed a quality program to (1)

(

assure traceability, and (2) control the quality of all materials and proces-ses utilized in the production of radioactive shielding, casks, containers, and other equipment pertaining to shipping packages for irradiated fuel, high level waste, and plutonium.

A Quality Manual delineates requirements and procedures necessary to exercise control over design, doc umenta t io n, p roc ur e me n t, material, f abrica tion, inspection, operational testing, equipment ope ra tion and use, ma int enance, repair, modification, invent ory, shipment and quality data retention.

The PNSI Quality Program is implemented by Quality Procedures which are de-signed and administered to meet the 18 criteria of 10 CFR 71, Subpar t H.

The Quality Program is implemented throughout the company and its sub sidi arie s.

The Sub sidia ries include : Pacific Nu cle a r Systems, Inc.,

Nu cle a r Packaging, Inc., NuPac Leasing, Inc., and Pacific Nuclear Systems and Services, Inc.

O 9-1

NuPac. PAS-1 Consolidstad SAR, Rev. ' 0 March 31,1989 9.2 Description of the PNSI.10 CFR 71. Suboart H Quality Proaram 9.2.1 Or naniza t ion Full responsibility for the Quality Assurar.co (QA) Program adherence to 10 CFR-71, Subpart H criteria rest s with PNSI. Quality Program. activities include calibration of measuring equipment, non-destructive examination (NDE), and materials testing.

PNSI surveys and qualifles all organizations performing these services to assure. adherence to the 18 criteria prior to their use.

All other quality activities are performed by PNSI quality personnel.

However, the responsibility of the control of quality in the other organizations con-tinues to rest with PNSI.

PNSI's President has full authority over all func tions of the company, and del e gat e s authority and responsibility f or selected f unc t ion s to o the r personnel within the company.

The a dm inis tra tive function includes financial, legal, and marketing a c tiv it ie s.

Procurement depa rtme nt personnel perform purcha sing activitie s and maintain supplier performance records.

The Engineering Department is responsible for research and development of shipping container technology, design of casks for licensing and fabrication, and design documentation.

l The PNSI Quality Department has suf ficient authority and organizational free-I dom to identify quality programs, implement corrective a c t io n, and verify q

l corrective action ef festiveness.

I Additionally, the Quality Department is inde pe nde nt from other organizations within PNSI and reports directly to the President of PNSI.

The Quality De-par tme nt is headed by the Corporate Quality Director who is responsible for the development, implementa t ion, and administration of the entire PNSI Quality Program.

He must have suf ficient expertise in the entire field of Quality to enable him to direct the entire quality function in close adherence to the 18 criteria of 10 CFR 71 and the PNSI Quality Manual.

Responsibility for l

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. NuPsc PAS-1 Consolidated SAR, Rsv. O Ksrch 31,1989 -

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development of quality acceptance requirement s, inspe c t ion s, and NDE activi-ties rests with the Corporate Quality Director.

It is his responsibility to L

delegate - and evaluate the pe rf ormance of ' all quality related tasks f or PNSI through ' the authority of the president.

It is delineated in writing through the Corporate Quality Director that designated QA personnel have the authority to prevent the con t inue d processing, f abr ica tion, installation, or delivery of unsatisf actory work.

This authority also extends to the quality monitoring of special proces ses utilizing PNSI equipment, personnel and procedures such as waste processing, in-se rvice inspections, e tc.

Production responsibilities include scheduling or in-se rv ice inspection and a dminis tra t ion of all f abr ica t ion activities, both within PNSI a nd at qualified suppliers.

The shipping and r e c e iv ing function is al s o the responsibility of the Production Department.

O On-site activities such as waste processing, in-se rv ice inspections, etc. are administered as a. J oint effort of the operations and engineering personnel.

Quality ' suppor t s these activities with written procedures that prov ide sethods, process controls and check points.

Inspec t ion pe rsonnel pe rf orm monitoring activities and verifications of regulatory, contractual, and tech-nical requirement s during these operations.

The Corporate Quality Director and all other quality personnel and/or or ganiza t ion s with in, or utilized by PNSI, are fully qualified for their quality responsibilities.

Qualification records are maintained in the PNSI Quality Record File.

9.2.2

.qgality As surance Pronram

)

i PNSI has established and implemented a QA Program for the control of quality l

in the design, f abrica t io n, opera t ion, and maintenance of shipping containers for nuclear product s.

Training and/or evaluation of personnel qualifications are required for all QA functions in accordance with written proced ur e s and 9-3

.-NuPac PAS-1 Consc11 dated SAR, Rsv. 0:

K:rch 31, 1989 l

- are approved by the Quality Manager.

The QA. Program assures that all quality requirements, engineering specifications, and specific provisions of any pack-age design approval are met.

Tho se characteristics critical to safe ty are emphasized.

~

The President of PNSI regularly evaluates the PNSI QA program-for adherence to the '18 criteria in scope, implement a tion, a'nd ef f ec tive nes s.

Fur the r,'

the President requires that the Quality System, including the QA Manual Policies and Procedure s, be implemented and e nf orced on all applicable programs at PN SI.

A Material Review Board, consisting of Engineering, Procurement - Production,.

and Quality Personnel has been established to res olve all discrepancies or disagreements pertaining to the acceptability of material, hardware, or safety related operations. Their dispositions are final and binding.

9.2.3 Desian Control PNSI Quality Procedures (QP's) have been developed, approved, and - impleme nted to control design review in such a manner to assure that the following occur:

9.2.3.1 Design activity is planned, controlled, and docuented.

9.2.3.2 Re gulat ory and design r equirement s are correctly tr an sla t ed into specification, drawings, and procedures.

9.2.3.3 Design documents contain quality requirement s.

9.2.3.4-Deviations from quality requirements are controlled.

l 9.2.3.5 Design ve rif ica t ion is pe rf ormed by Quality As s urance pe rsonnel independent of the design activity. These verifications may include t oler ance s tu d ie s, alt e rnat e calc ula t ion s or t est s.

Qualifica t ion tests are conducted in accordance with approved test programs and procedur e s l

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NuPao PAS-1 Conselidsted SAR, R v. O K2rch 31, 1989 i

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9.2.3.6 Interface control is established and adequate.

9.2.3.7 Design and specification changes are reviewed and approved by the 1

same organization (s) as the original issue.

9.2.3.8 Design errors and deficiencies are documented and corrective action -

is taken to prevent recurrence.

9.2.3.9 Design organization (s) and their responsibilities and authorities are delineated and controlled via written procedure.

9.2.4 Procurement Document Control The PNSI QA Program assures that all purchased material, components, equipment, and services adhere to design specifications.

Iv Supplier evaluation and selection, obj e ctive ev idence of supplier quality, as signment of quality requirement s to procurement documents and related design docume nt s, and ' source, in process, and receiving inspections are all adminis-tered and controlled in accordance. with approved PNSI QA procedures.

All procurement activity is performed in accordance with written procedures deline a ting r equir ement s for prepa ra t ion, r ev iew, approval, and control of pr ocur eme nt documentation.

Pa r ticul ar emphasis is placed on a s sur ing that I

revisions to procurement documentation are reviewed and approved by the same cognizant groups as the original.

Quality Assurance clause sheets are included with all request for quotes and p urch a se orde rs.

Quality Assurance pe rsonnel as sign clauses from the she e t s to the procur eme nt doctane nt referencing 10 CFR 71, Subpart H r equirement s appropria t e to the con tr a c t.

In ad d it ion, material information including grade, type, size, and special physical or chemical data requirements is included on the proc ur eme nt d oc ument s.

Othe r d oc ume nta t ion and inf orma t ion such as drawings, proce dur e s, inspection and test requirements, hold points, welding and o ther process qualification r equirement s are delineated on the 9-5

NuP'ac PAS-1 Consolidated SAR, Rsv. O March 31,1989

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b) procurement document s by the Quality Assurance personnel as appropriate to the i

contract.

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Quality Assurance personnel as sure that requirements for acceptance of hard-ware and documentation appropriate to the contract are included in procurement docume ntation.

PNSI Quality Assurance personnel maintain the right of access to all supplier facilities and documentation for source inspection and/or audit activities. A statement to this effect is included on procurement documentation 'when it is appropriate to the contract.

9.2.5 Instruction, Procedures and Drawings Quality planning is developed by qualified Quality Engineers (QE's) for all '

activities requiring quality participation in accordance with approved PNSI QA

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procedures and is approved by the Corporate Quality Director.

All design documents (i.e., drawings, s pe cif ica tion s, special processes, etc.)

af fecting quality are reviewed by the Quality Depa r tme nt and referenced in quality planning as necessary to assure adherence to package design approvals and the applicable criteria of 10 CFR 71, Subpart H.

All instruct ions, proced ur e s, and drawings are developed, r ev iewed, approved, utilized, and controlled in accordance with the requirements of written quality assurance procedures.

9.2.6 Document Control Policy and procedure for review, approval, relcase and change control of all controlled, quality related doc une nt s are delineated in approve d PNSI QA Proc e dur e s.

Provisions are provided in the QA Procedures for identification

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of individuals / organizations responsible for review, approval, and issuance of doc ume nt s.

Document control responsibilities, facilities, and distribution j

requirements are also addressed.

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NuPac PAS-1 Consolidated SAR,- Rev. O March 31,1989 -

Controlled documents include, but are not ' limited to:

(a) ' Design specifications

'4' (b) Design manufacturing drawings

'(c)

Special process specifications and procedures

'(d)- Procurement document s (e) - QA Procedures and manuals (f)' Quality Planning f or receiving, in process, source and in-

. service inspections (g)

Source surveillance and evaluation reports (h) Test procedures (i) ~ Audit reports (j). ' Operational test procedures and data.

When revised documents - appear in other documents as references, suppl ement s, or exhibit s, appropriate revisions are made to those documents - prior to the release of the-- basic approved change.

Documentation listings are maintained' delineating the title, numbe r and'

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. c urrent revision for all drawings, proced ur e s, specifications, and purchase r

orde rs.

The Quality Personnel assure that all required support documentation is available at the work area prior to the initiation of the work effort.

1 i

i 9.2.7 Control of Purchased Material s. Parts and Components l

k Procurement document s are reviewed for acce ptability of sug ge s t ed supplie rs

.f based on the PNSI approved supplier list s.

In addition, and as required, supplier surveys are conducted by qualified PNSI

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pe rsonnel to f ur the r as s ure supplier ac c ept ability.

These eval ua t ion s are based on one or all of the following criteria:

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- NuPac PAS-l' Consolidated SARI' Rev. O March 31, 1989 -

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(a) The supplier's capability to comply with' the requirements of 10 1

CFR 71, Subpart H, that are applicable ~ to the contract.

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(b)- A review of previous records and performance. of the supplier.

. c).A snrvey-of the supplier's facilities and QA program to deter-(

1 mine his capability to supply a product which meets the design,-

manuf acturing, and quality requirements.

Results of all supplier'. evaluations are recorded on Supplier Evaluation f orms and are retained in the Quality Data File.

Quality requirement s. and standard clauses are added to procurement document s to require suppliers to identify material, provide test reports, control-special proces ses,. certify equipment and personnel, etc.

As a minimum, requirements are imposed on' suppliers to identify materials, specific, codes, specifications and/or design not adhered to during fabrication.

Justifica-tions for ' accept-as is' or ' repa ir' dispositions are also required tobe sumitted to the Material Review Board for review and acceptance.

Quality planning is prepared and approved by the Quality Department for per-formance of all source, test, shipping and/or. receiving inspections in accor-dance with approved design requirements, applicable 10 CFR 71 criteria, pro-.

I curement document requirement s, and contract specifications.

Receiving inspection is performed to determine that the f ol low ing, as appropriate to the contract, are assured:

(a) The material, component, or equipment is properly identified and corresponds with the identification on receiving documenta-tion.

j (b) Material, components, equipment, and acceptance records are inspected and are acceptable in accordance with inspection instructions, prior to installation or use.

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• . Napas PAS-1 Censc11dsted SAR, Rev. 0 March 31, 1989

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-(c)

Inspection records and/or ' certificates of conformance attesting L

to the acceptance ' of material and components are. available prior to installation or use.

(d) Items accepted and released are; identified as to their inspec-tion. sta tu s prior to forwarding them to.a controlled storage area or releasing them for further work.

All described activities are delineated in' approved PNSI QA' procedures.

9.2.8 Identification and Control of Materials. Parts. and Connonente The identification and control of materials, parts, components, and completed and in process as.somblies is administered by the Quality Department in accor-dance with approved PNSI QA Procedures.

These procedures _ address quality sta tu s tags, mainte nance of material identification and tra ce ability, part identification, and related documentation.

Some of the de tail s of these procedures follow:

(a) Material identification procedures included in inspection plan-ning and fabrication' drawings require tha t identifica tion of material, components, and/or hardware be maintained on-the item-or in traceable records to prevent use of incorrect or defec-tive items.

i (b) When appropriate, due to contractual or safety related concerns requiring specific identification and Material Review Board action, Quality Assurance personnel as sure that identifiestion of materials, components, spe ci f ica t ion s, procurement documen-t a t io ns, manuf actur ing, and inspection records, dis cr epancy r eport s, and material test data is provided and is complete.

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i (c)- Quality Assurance personnel assure, via drawings and-inspection planning requirements, that: identification -locations do not af fect the fit-up, interfacing capability, performance or over-all quality of the finished product.

Ide ntifica tion, in accor-dance with drawings and inspection planning requirement s, is verified prior to. releasing the. item for further proces sing ' or delivery.

9.2.9 Control of Snecial Proces'ses

. PNSI approved QA Procedures delineate the policies and procedures established to control such special processes as: welding, heat treating, lead pouring, non-destructive examination,. waste processing, etc.

in accordance with appli-cable codes, standards, specifications,10 CFR 71 criteria, and other require-monts.

Special' processes developed by PNSI suppliers and by PNSI are 'docu-me nt e d. -.

'All procedures for special processes and the pe rsonnel required to perform them are qualified - under the cognizance of the Quality Department in accor-dance with applicable codes, standards, specifications, and contract requi re-ments.

All qualification records and support data are retained in the Quality Data file, and are maintained in a current status by Quality Assurance personnel.

These documents are controlled as delineated in Section 9.2.6 of this Quality System description.

9,2.10 In soe ct ipn All rece iv ing, source, in process, and in-se rv ic e inspection activities are pe rf ormed in accordance with approved PNSI QA procedures.

All inspection personnel and/or organization qualifications are reviewed and accepted by the Quality Manager pr ior to inspec t ion activity.

The inspection activity is 1

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i Nalan PAS-1 Consolidated SAR, Rev. O Ma rch 31, 1989 performed 'in strict accordance - with approved quality pis.nning prepared ' by qualified QA personnel (See also Section 9 2.5 discust son).

Quality Inspection personnel are independe nt from all other organizations within _ PNSI and r epor t direc tly to the Corporate _ Quality Director or the Subsidiary Quality Manager.

' Inspection personnel qualifications are based on their capability to perform the required inspection functions in accordance. with applicable codes, stan-dards, professional society progress such as the ASQC quality technician certification, and PNSI training programs.

Qualification r ev iew s are pe r-formed _ periodically to maintain personnel proficiency and assure current qualification.

Mandatory hold points, inspection equipment requirement s, accept - rej ect criteria, personnel requirement s, characteristics to. inspect, va riable /a t tr i-butes recording instructions, reference documentation, and other requirements are included in the inspection planning.

The Quality Assurance department assures that any replacements, modifiestions, or. repairs performed after final acceptance of material, components or hardwars are inspected in accordance with the original inspection planning or new planning prepared as appropriate.

9.2.11 Test Control A test control program, as it applies to quality, is addr es sed in approved PNSI QA Procedures and assures, wie required pl anning, tha t all required tecting, such as proof and acceptance tests, are identified and performed in accordance with test procedures, design requirements, and lim it a t ion s.

Prerequisites, accept /rej ect criteria, data recording criteria, in s trument a t ion calibra t ion, e nvironment al conditions, doc ument a t ion and evaluation requirement s, etc. are $clineated in the test procedures.

Changes to the test procedures are required to be reviewed / approved by the same organization (s) as the original issue.

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g NnPac PAS-1'Consc11 dated SAR, Rsv. O Ma rch 31,1989 i

. Whenever equipment, components, and/or assemblies require modification, ' re-pairs, or replacement which could result in requirements for re-test or addi-tional testing, Quality As surance personne1' as sure, as appropriat e, that original or new test inspection planning is prepared and adhered to.

In any case, test results are documented, evaluated, and scoepted by qualified personnel as required by the test inspectica plan prepared for the test under the cognizance of Quality Assurance personnel.

9.2.12 Control' of Measurina and Testina Faulement Administration of ' the calibration of me asuring equipment and ine trumenta tion is performed by the Quality Department in accordance with appro7ed PNSI QA -

Procedures..The calibration system assures that all et andard me asuring instruments (SMI) used in the acceptance of' material, equipment, and assemblies are calibrated and properly adj u sted at specified' intervale to maintain ' accuracy within pr e-de termined limit s.

Calibration ' is pe rf ormed using equipment traceable to national standards.

All calibrated equipment. is identified and is traceable to the calibration test data.

Whenever EB(I are found to be out of calibration during or imme dia t ely after use, all items inspected during that period are rej ected by inspection and are submit t ed to r eview ac t ion for possible re-inspec t ion or o ther appropriat e corrective action.

9.2.13 Espdl in a.

Storane, and Shinoina a

PNSI approved QA Procedures require that handling, storage, and shipping requirements adherence verification criteria be included in quality plarning.

These requirements are designed to prevent damage or deterioration of material and equipment.

I.4 formation pertaining to shelf life, environment, packaging, temperature,. cleaning, handling, pr e se rva tion, etc.,

is included as required t o me e t design, NRC package approval and/or U.S. Department of Transportation shipping requirement s.

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i NuPhs PAS-1' Consolidated SAR, Esv. O March 31,1989 O

Shipping documentation preparation - departure and arrival time,' and destina-tion ~ data. recording are also addressed in the planningi when applicable.

Shipping requirements in quality planning must be met prior to release for-shipment.

9.2'.141 Insnection. Test and Oneratina Status The use of inspection status tags, quality inspection stamps, and-other means~-

'to indicate : inspection and test sta tu s at, or for, PNSI are delineated in approved PNSI QA Procedures.

The i clarity of the status indication, prevention of inspection, and/or test step by passing, and prohibition of removal or modification of status indica-tions, except with Quality Department approval / Material Revlow disposition, is assured vis these procedure s.

The Quality Assurance Department assures via Quality, Procedure, - interof fice ' memoranda, training sessions, and audit that all PNSI personnel are aware of and understand the meaning. and uses of status togs on all hardware, material, and test set-ups (see.also Section ' 9.2;15 discus s ion).

9.2.15 Non-conf ormina Material. Part s.

or Connonents PNSI approved QA Procedures - require that material, components, and equipment that do not conform to requirements are controlled to prevent their inadve r-tent use.

Identification, segregation, discrepancy reporting, disposition of

'non-conformances by authorized individuals, and re-inspection activities are performed and controlled in strict accordance with these procedures.

Quality Discrepancy Reports (QDR) are utilized by the PNSI quality department to identify discrepant items, de s cribe the discrepancy, and provide disposi-tion and re-inspection requirement s.

'Ih e si gna tur e s of authorized cognizant personnel are placed on the QDR to signify approval of the disposition. These personnel must be approved by the Corporate Quality Director and President and must be from the same groups approving the original 'esign.

In conjunction 9-13

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NuPho PAS-1 Ccnselidstad SAR, Rsv. O March 31, 1989 l

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with repair or re-work dispo sit ion s, quality as sur ance pe rsonnel provide s uppl eme ntal inspection planning to verify proper implementation of the QDR 1

dispo s it ion.

This assures that the item is re-tested and/or re-inspected to a I

degree at least equal to the original acceptance activity.

1 9.2.16 Corrective Action Failures, malfunctions, and deficiencies in material, components, equipment, and services are identifisd and reported to the Corporate Quality Director and the President. The c.tuse of the condition and corrective action necessary to prevent r ec urre nce is iden tified, implemented and then followed up to verify corrective action ef fe ctiv ene s s.

All reporting r equireme nt s of applicable contrac tual and regulatory spe cif ica t ion s and regulations are adhered to as part of any corrective action activity.

Detail requirements for this activity are delineated in approved PNSI QA Procedures.

O 9.2.17 Quality Assurance Records A quality records system is in effect at PNSI and is adminis t ered in accor-dance with approved PNSI QA procedures.

The purpo se of the quality record system is to assure that docue nted ev ide nce pertaining to quality related activities is maintained and available for use by PNSI, it s customers, and/or I

regulatory age ncie s as ' applicable.

Quality Records include, but are not limit ed to, inspe c t ion and test records, audit r ep ort s, quality pe rsonnel qualifications, design rev iew s, quality related procur eme nt data, supplier evaluation report s, etc.

All records are iden tified by work orde r number, part number, contract numbe r, or drawing neber as appropriate to the record type. A complete list of all quality records is maintained and provides cross reference between the different identity methods described above and pinpoints the record location.

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Design related records such as cal cul a t ions, drawings, research and develop-J ment t est report s, etc., are retained in the Quality Assurance records system for the life of the shipping package.

All other quality related records are retained for the life of the shipping pac ka ge in accordance with 10 CFR 9-14

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, NuP:s PAS-1 Cozsc11 dated SAR, Rsv. O March 31,1989 7.s (J) 71.91(c) unle s s o therwise specified in related contractual or regulatory r equir ement s.

Inspection records rstained in the Quality Assurance records system prov ide the following data when applicable:

(a)

Inspection type, i.e.,

in process, in-se rv ic e, testing, receiv-ing, and shipping.

(b) Evide nce of completion and verification of manuf acturing, in-spection, or test operation.

(c) The date and results of the inspection or test.

(d) Information related to noted discrepancies.

(e)

Inspector or data recorder identification.

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(f) Evidence of acceptance.

9.2.18 And it :

Quality program audits are performed on a periodic, scheduled ba sis by personnel without direct responsibilities in the areas being audited.

Audit pe rs onnel are certified quality assurance lead auditors who have met all requirements of ANSI N 45.2.23.

Written planning she e t s and check lists are utilized.

Audit results and corrective action activity are reported to

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mana gement, in writing, and are retained in the quality assurance record file.

Responsible management personnel are required to respond to audit findings with the neces sary action to c orre c t the noted def ic ie nc ie s.

Current PNSI practice is to audit all quality functions on an annual basis.

Areas found deficient during audit s are reaudited on a first priori ty basis to verify corrective action implementation and ef festiveness.

Details of the PNSI Audit System are delineated in approved PNSI QA Procedures.

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., NuPs.o PAS-1 Consolidated SAR, Rsv. 0

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9.3 References 9.3.1

' Title 10, Code of Federal Regulations, Part 71-(10 CFR 71),

Packarina and ' Transportation of Radioactive Mat e ri al s, August, 24, 19 83.

9.3.2 PNSI Corporate Quality Manual, Revision 15, dated February 1,1988.

9.3.3 NRC Approval No. 0192 pertaining to the Pacific Nuclea r Syst' ens /

Nuclear Packaging,10 CPR 71, Subpart H, QA System.

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