ML20198N172: Difference between revisions
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| number = ML20198N172 | | number = ML20198N172 | ||
| issue date = 01/16/1998 | | issue date = 01/16/1998 | ||
| title = Responds to 970630 Reply to | | title = Responds to 970630 Reply to Which Forwarded Revised Invoice AM2558-97 for FY97 Annual Fee for QAP Approval Number 0227.Addl Payment for Invoice,Due & Payable within 30 Days of Ltr | ||
| author name = Turdici J | | author name = Turdici J | ||
| author affiliation = NRC OFFICE OF THE CONTROLLER | | author affiliation = NRC OFFICE OF THE CONTROLLER | ||
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Tennessee Valley Authority ATTN: Mark J. Burrf:tski, Manager Nuclear Licensing 1 1101 Market Street , | Tennessee Valley Authority ATTN: Mark J. Burrf:tski, Manager Nuclear Licensing 1 1101 Market Street , | ||
Chattanooga, TN 37402-2801 Cear Mr. Burzynski: | Chattanooga, TN 37402-2801 Cear Mr. Burzynski: | ||
- l am responding to your June 30,1997, reply to our April 22,1997, letter which forwarded revised invoice No. AM2558-97 for the FY 97 annual fee for Quality Assurance Program Approval No. 0227 (QA-0227). You state that the revised invoice is in error because TVA filed a request to downgrade QA-0227 from " User / Fabricator" to " User" prior to October 1,1997, (sic) and ceased any and all fabrication acilvities prior to September 30,1997. (sic) As o explained below, revised Invoice AM2558-97 is correct and is due and payable. j 1 | - l am responding to your June 30,1997, reply to our {{letter dated|date=April 22, 1997|text=April 22,1997, letter}} which forwarded revised invoice No. AM2558-97 for the FY 97 annual fee for Quality Assurance Program Approval No. 0227 (QA-0227). You state that the revised invoice is in error because TVA filed a request to downgrade QA-0227 from " User / Fabricator" to " User" prior to October 1,1997, (sic) and ceased any and all fabrication acilvities prior to September 30,1997. (sic) As o explained below, revised Invoice AM2558-97 is correct and is due and payable. j 1 | ||
i As stated in 10 CFR Part 171.5, quality assurance program approvals are divided ime two mtjor groups: (1) those activities including design, fabrication and use of packaging are classified as ' User / Fabricator," fee Category 10B(1) of 1_0 CFR 171.16d, and (2) those activities - | i As stated in 10 CFR Part 171.5, quality assurance program approvals are divided ime two mtjor groups: (1) those activities including design, fabrication and use of packaging are classified as ' User / Fabricator," fee Category 10B(1) of 1_0 CFR 171.16d, and (2) those activities - | ||
for use only.of packaging are classified as " User," fee Category 10B(2). The " User / Fabricator" i is held by the Certificate of Compliance (CoC) holder (usually a packaging owner) and includes the maintenance of all quality assurance-related documents. Fabrication need not be included 1 in a CoC holder's qwlity assurance program provided fabrication activities are not conducted, l | for use only.of packaging are classified as " User," fee Category 10B(2). The " User / Fabricator" i is held by the Certificate of Compliance (CoC) holder (usually a packaging owner) and includes the maintenance of all quality assurance-related documents. Fabrication need not be included 1 in a CoC holder's qwlity assurance program provided fabrication activities are not conducted, l | ||
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In the situation W)ere a CoC is transferrod, the original CoC holder retains the responsibility for all activities associated with that CoC until: (1) the NRC receives confirmation from the accepting organization taat they will accept responsibility for all Coc activities; and (2) the NRC | In the situation W)ere a CoC is transferrod, the original CoC holder retains the responsibility for all activities associated with that CoC until: (1) the NRC receives confirmation from the accepting organization taat they will accept responsibility for all Coc activities; and (2) the NRC | ||
. haues a revised CoC showing the new CoC holder. Although TVA requested the transfer of . | . haues a revised CoC showing the new CoC holder. Although TVA requested the transfer of . | ||
Y _ CoC No. 6568 to Chem-Nuclear on September 30,1996, the CoC could not be trar,sferred until Ch6m-Nuclear accepted the statements and representations for which the certificate was Issued.: Chem-Nuclear did so in their December 20,1996, letter. Therefore, although the authorization for fabrication activities may not have been necessary under QA-0227, other | Y _ CoC No. 6568 to Chem-Nuclear on September 30,1996, the CoC could not be trar,sferred until Ch6m-Nuclear accepted the statements and representations for which the certificate was Issued.: Chem-Nuclear did so in their {{letter dated|date=December 20, 1996|text=December 20,1996, letter}}. Therefore, although the authorization for fabrication activities may not have been necessary under QA-0227, other | ||
" User / Fabricator" activities were required to be authorized under QA-0227 until February 4, J 1997, when the activities were covered by a quality assurance program approval held by ; ' | " User / Fabricator" activities were required to be authorized under QA-0227 until February 4, J 1997, when the activities were covered by a quality assurance program approval held by ; ' | ||
Chem-Nuclear. Therefore,' QA-0227 was correctly classified as a " User / Fabricator" approval ' | Chem-Nuclear. Therefore,' QA-0227 was correctly classified as a " User / Fabricator" approval ' | ||
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l?' | l?' | ||
M. Burzynski In summary, " User / Fabricator" activities did not cease under QA-0227 until CoC No. 6568 was issued to Chem-Nuclear on February 4,1997. At that time the " User / Fabricator" activities were no longer required under TVA's QA-0227. The revised invoice correctly reflects a 50 percent proration of the FY 1997 annual fee for fee Category 10B(1) (" User / Fabricator") and 50 percent for 10B(2) (" User") as provided in 10 CFR 171.17(b)(2)(ii)A. | M. Burzynski In summary, " User / Fabricator" activities did not cease under QA-0227 until CoC No. 6568 was issued to Chem-Nuclear on February 4,1997. At that time the " User / Fabricator" activities were no longer required under TVA's QA-0227. The revised invoice correctly reflects a 50 percent proration of the FY 1997 annual fee for fee Category 10B(1) (" User / Fabricator") and 50 percent for 10B(2) (" User") as provided in 10 CFR 171.17(b)(2)(ii)A. | ||
For the reasons stated above and ns explained in our April 22,1997, letter, revised invoice AM2558-97 ($36,8M)is correct, and is due and payable. We received your payment of | For the reasons stated above and ns explained in our {{letter dated|date=April 22, 1997|text=April 22,1997, letter}}, revised invoice AM2558-97 ($36,8M)is correct, and is due and payable. We received your payment of | ||
$950 (the original I waiced amount) and we applied a duplicate payment of $1,S00 for AM5127-97 to this invoice. Payment of the additional $34,275 is due within 30 days of this letter. | $950 (the original I waiced amount) and we applied a duplicate payment of $1,S00 for AM5127-97 to this invoice. Payment of the additional $34,275 is due within 30 days of this letter. | ||
Sincerely, Original signed by James Turdici James Turdici, Director Division of Accounting and Finance Office of the Chief Finnncial Officer Distribution: | Sincerely, Original signed by James Turdici James Turdici, Director Division of Accounting and Finance Office of the Chief Finnncial Officer Distribution: |
Latest revision as of 12:25, 8 December 2021
ML20198N172 | |
Person / Time | |
---|---|
Site: | 07100227 |
Issue date: | 01/16/1998 |
From: | Turdici J NRC OFFICE OF THE CONTROLLER |
To: | Burzynski M TENNESSEE VALLEY AUTHORITY |
References | |
NUDOCS 9801200285 | |
Download: ML20198N172 (2) | |
Text
,. . __ __ . _ . . _ .. _ _ . _ _ . _ _ _ __ _ .. __
- , i 1
y[ 1-UNITED STATES NUCLEAR REGULATORY COMMISSION wmmons, p.c. messa
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. January 16.-1998-ig i
Tennessee Valley Authority ATTN: Mark J. Burrf:tski, Manager Nuclear Licensing 1 1101 Market Street ,
Chattanooga, TN 37402-2801 Cear Mr. Burzynski:
- l am responding to your June 30,1997, reply to our April 22,1997, letter which forwarded revised invoice No. AM2558-97 for the FY 97 annual fee for Quality Assurance Program Approval No. 0227 (QA-0227). You state that the revised invoice is in error because TVA filed a request to downgrade QA-0227 from " User / Fabricator" to " User" prior to October 1,1997, (sic) and ceased any and all fabrication acilvities prior to September 30,1997. (sic) As o explained below, revised Invoice AM2558-97 is correct and is due and payable. j 1
i As stated in 10 CFR Part 171.5, quality assurance program approvals are divided ime two mtjor groups: (1) those activities including design, fabrication and use of packaging are classified as ' User / Fabricator," fee Category 10B(1) of 1_0 CFR 171.16d, and (2) those activities -
for use only.of packaging are classified as " User," fee Category 10B(2). The " User / Fabricator" i is held by the Certificate of Compliance (CoC) holder (usually a packaging owner) and includes the maintenance of all quality assurance-related documents. Fabrication need not be included 1 in a CoC holder's qwlity assurance program provided fabrication activities are not conducted, l
4 or are completed and the quality assurance records are maintained for each packaging.
' However, each CoC holder's quality assurance program must address design. Since TVA held .
.CoC No. 6568 for the Model LL-60-150 packaging, TVA's quality assurance program approval - ,
(QA-0227) had to address design until February 4,1997, the date the CoC was transferred to Chem-Nuclear.
In the situation W)ere a CoC is transferrod, the original CoC holder retains the responsibility for all activities associated with that CoC until: (1) the NRC receives confirmation from the accepting organization taat they will accept responsibility for all Coc activities; and (2) the NRC
. haues a revised CoC showing the new CoC holder. Although TVA requested the transfer of .
Y _ CoC No. 6568 to Chem-Nuclear on September 30,1996, the CoC could not be trar,sferred until Ch6m-Nuclear accepted the statements and representations for which the certificate was Issued.: Chem-Nuclear did so in their December 20,1996, letter. Therefore, although the authorization for fabrication activities may not have been necessary under QA-0227, other
" User / Fabricator" activities were required to be authorized under QA-0227 until February 4, J 1997, when the activities were covered by a quality assurance program approval held by ; '
Chem-Nuclear. Therefore,' QA-0227 was correctly classified as a " User / Fabricator" approval '
^
D' . (fee Category 10B(1)) until February 4,1997. -l D
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M. Burzynski In summary, " User / Fabricator" activities did not cease under QA-0227 until CoC No. 6568 was issued to Chem-Nuclear on February 4,1997. At that time the " User / Fabricator" activities were no longer required under TVA's QA-0227. The revised invoice correctly reflects a 50 percent proration of the FY 1997 annual fee for fee Category 10B(1) (" User / Fabricator") and 50 percent for 10B(2) (" User") as provided in 10 CFR 171.17(b)(2)(ii)A.
For the reasons stated above and ns explained in our April 22,1997, letter, revised invoice AM2558-97 ($36,8M)is correct, and is due and payable. We received your payment of
$950 (the original I waiced amount) and we applied a duplicate payment of $1,S00 for AM5127-97 to this invoice. Payment of the additional $34,275 is due within 30 days of this letter.
Sincerely, Original signed by James Turdici James Turdici, Director Division of Accounting and Finance Office of the Chief Finnncial Officer Distribution:
L. Tremper, OCFO l L. Venson, QCFO S. Kimberley, OCFO D. Weiss, OCFO Invoice File AM2558-97 w/cy inc NUDOCG (ML-69 w/cy inc Docket File L-71-0227 w/cy inc PDR w/cy inc ,
OC/DAF/LFARB RF w/o ey inc OC/DAF RF (DAF-7-215) w/o cy inc -
OC/DAF SF (LF-3.2.2) w/ orig inc & enci LF97-111 w/o cy inc DOCLMENT NAME: C:\TVA n* =me a cor r et mis exumum. tidwam te e, ter ac - cap, =tecu, am,ctmanswckmov "r - cc wen awknavenciamme "N" - No copv.
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