ML20137Y859

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Forwards Copy of 10CFR171.17,proration Section of NRC Annual Fee Regulations
ML20137Y859
Person / Time
Site: 07100227
Issue date: 04/22/1997
From: Gerard Jackson
NRC OFFICE OF THE CONTROLLER
To: Baron R
TENNESSEE VALLEY AUTHORITY
References
NUDOCS 9704230259
Download: ML20137Y859 (4)
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/ACtc%*& UNITED STATES l j 3 NUCLEAR REGULATORY COMMISSION

}.,% WASHINGTON, D.C. 30666-0001 l

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% g . . . . ,*' April 22, 1997 Tennessee Valley Authority '

ATTN: Mr. Raul R.' Baron General Manager Nuclear Assurance and Licensing 1 1101 Market Street Chattanooga, TN 37402-2801 l

Dear Mr. Baron:

On September 30. 1996. TVA requested: 1) that tk'ality Assurance Program i Approval G227 (OA 0227) be downgraded from " User / Fabricator" to " User" only:

2) that Certificates of Compliance Nos. 6722 and 9139 be terminated; and
3) that Certificate of Compliance No. 6568 be transferred to Chem-Nuclear Systems, Inc. (Chem-Nuclear). Your letter stated that this would save TVA approximately $72,000 per year.

Invoice AM2558-97 was recently issued for the FY 1997 annual fee for QA 0227 under fee Category 10B(2). In reviewing this matter, we found that the invoice was issued in error, Enclosed is a copy of 10 CFR 171.17. the proration section of the NRC's annual fee regulations. As provided in 10 CFR 171,17(a)(2), annual fees for downgraded licenses are prorated 50 percent on the basis of when the application is received by the NRC, 3rovided the licensee permanently ceased the stated activities during tie specified period.

Although your request for a downgrade of 0A 0227 was filed Se)tember 30, 1996. l the fabricator activities did not cease under 0A 0227 until tie Certificate of  !

Compliance was reissued to Chem-Nuclear on February 4, 1997. The Certificate '

of Compliance was reissued based on your September 30. 1996, request and Chem-  ;

Nuclear's December 20, 1996, request. Concurrent with the reissuance of the  !

Certificate of Compliance, the authority to design, fabricate, or modify the package is now covered by a OA held by Chem-Nuclear.

Based on the above. Invoice AM2558-97 has been revised to reflect a 50 percent proration for fee Category 10B(1) and a 50 percent proration for fee Category 10B(2) as The revised invoice is enclosed. provided in 10your We received CFRpayment 171.17(a)(2)(ii)(A).

for $950 (the original invoiced amount).

Payment of the additional $35.875 is due within 30 days of the invoice date.

If you have any questions concerning this matter, please contact Maurice Messier at 301-415-6087.

Sir)cerely, ph. 4' /w

'GlendaC. Jackson, Chief I License Fee Section License Fee and Accounts Receivable Branch Division of Accounting and Finance Office of the Controller

Enclosures:

1. 10 CFR 171.17 Revised Invoice 2.

9704230259 970422 ll ll***"*

ll lllll lllllll PDR ADOCK 0710 7

.c 4. Letter T6: Tennessee Valley Authority \.! ,* ATTN: Mr. Raul R. Baron Dated: A ril 22, 1997 011trt12.  :

S. Kinoer ey, OC/DAF/LFARB LFS In. voice File AM2558-97 w/cy inc

.NUDOCS (ML-61) w/cy inc I)ocket PDR w/cy inc File L-71-0227 w/% Uc OC/DAF/LFARB RF w/o cy inc OC/DAF RF (DAF-7-000) w/o cy inc OC/DAF SF (LF-3.2.'2) w/ orig inc & encl LTremper, OC/DAF/LFARB/ARS LVenson, OC/DAF/LFARB/ARS

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00c.F 'Jr NAME: G:\BARDN (T4 mr a copy of ilus document, inlicaw in the ten: 'C' = Copy without snachment/enciomre "N" = No copy.

"E" = Copy with anachmenvenjlosse '

0FFICE OC/DAF/LFARB/LFS OC/DAF/LFARBh b NMSS - IE OC/DAF/LFARB IMPO f f GCJackson f PHessier N r C, t/ JJankovich DBDandoisM OATE h /kY97 N/11/97 Nh N/fS/97 N 97 / /97 0FFICIAL RECORD COPY l

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r 8 171.17 10 CFR Ch.1 (1.}q (66 FR 316M. July 10,1991, as amended at 66 FR 67688. Nov.13,1991; 67 FR 32714. July 23 (2) Dotongraded licenses. (1) 1992; 67 FR 39421. Aug. 31,1992; 68 FR 3s006, Dual fee for a materials 11 4 7e July 20,1993; 68 FR 45M3, Aug. 30, H93; 69 FR subject to feet under th " I 18

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! 38099. May 19,1994; 69 FR 38924. July 20,1994; 32245, June 20,1996; 80 FR 3M62, June pro downgraded d n on or after October 1 of a uest by the 13 cation for downgrade is received b

$171.17 Proration. .

NRC provided the licensee permanen

  • Annual fees will be prorated for NRC ceased the stated activities d licensees as follows: specifled period. Requests for '

(a) Reactors. The annual fee for reac- must be flied with the NRC wi "

tors (power or nonpower) that are sub- days from the effective date g ject to fees under this part and are nnal rule establishing t
.e s.nnual f

, granted a license to operate on or after for which a proration is Mught. Abae October 1 of a FY is prorated on the extraordina.ry cir.unstances. any

, basis of the number of days remaining quest for proration of the annual I in the FY. Thereafter, the full fee is for a downgraded license filed beyon due and payable each subsequent FY. that date will not be considered.

Licensees who have requested amend- (11) Annual fees for licenses for which

,,, applications to downgrade are file 4s

$)- ment to withdraw operating authority during the period October 1 through 4: permanently rated based on during the FYofwill the number be dur-days pro- March 31 of the FY will be prorated as

) follows:

ing the FY the license was in effect be- (A) Licenses for which applications

)!I.

f fore the possession only license was is. have been nled to reduce the scope of 1

Q sued or the license was terminated. the license from a higher fee

! (b) Materials licenses (including fuel category (ies) to a lower fee N[h; ' i

~ cycle licenses). (1) Neto licenses and ter. catogory(les) will be assessed minations. The annual fee for a mate. the annual fee for the higher fee one-half

'i. rials license that is subject to fees category (les) and one-half the annual d

h* under this part and issued on or after fee for the lower fee category (les) and, 2: October 1 of the FY is prorated on the if applicable, the full annual fee for fee basis of when the NRC issues the new categories not affected by the down.

If license. New licenses issued during the grade;and Y- period October 1 through March 31 of (B) Licenses with multiple fee cat.

. [ the FY will be assessed one-half the an- erories for which applications have

,y j)! 4 ' nual fee for that FY. New licenses 1s- been filed to downgrade by deleting a sued on or after April 1 of the FY will fee category will be assessed one-half not be assessed an annual fee for that the annual fee for the fee category n FY. Thereafter, the full fee is due and being deleted and the full annual fee

,- payable esq subsequent FY. The an- for the remaining categories.

?' nual fee vill be prorated for licenses (111) Licenses for which applications y for whf .a a termination request or a for downgrade are nled on or after

.a requer for a POL has been received on April 1 of the FY are assessed the full

+

U or af'sr October 1 of a FY on the basis fee for that FY.

of f aen the application for termi- (69 FR 38928. July 20,1s94. as amended at 80 natti o or POL is received by the NRC FR 32348, June 20.19961 hb prov1W 4 the licensee pehnanently n? ceased i ensed activities during the 5171.19 Payment-h specifled period. Licenses for which ap- (a) Method of payment. Fee pay-

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,J plications for termination or POL are ments shall be made by check, draft, filed during the period October 1 money order or electronic fund transfer through March 31 of the FY are as- made payable to the U.S. Nuclear Reg.

sessed one-half the annual fee for the ulatory Commission. Federal agencies applicable category (les) for that FY. may also make payment by either Licenses for which applications for ter- Standard Form 8F-1081 (Voucher and mination or POL are nled on or after Schedule of Withdrawals and Credits)

April 1 of the FY are assessed the full or by the On-line Payment and Collec-annual fee for that FY. tion System (OPAC's). Where specific 4

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ENCLOSURE 1

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U. S. NUCLEAR REGULATORY COMMISSION

'"f FY 97 Annual Materials Fee Invoice

~ ' I' Period 10/1/1996 - 9/30/1997 4

j- 10 CFR 171.16 I REVISED j Invoice Date License Anniversary Month Invoice Number

! ======...... ========================= ===.....--====

l 04/16/97 March AM2558-97 i

] TO: TENNESSEE VALLEY AUTHORITY OFFICE OF NUCLEhR POWER j ATTENTION: RADIATION SAFETY OFFICER i 1101 MARKET STREET i CHATTANOOGA, TN 37402-2801 l ,

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j ***** Mark PAYMENT COPY with any billing address changes *****

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l License / Approval /

l Registration / Code Annual Fee Certificate Number AA905 Category (s) Fee Amount

.................. ===== =====--==-- ---............

1 0227 ANN 10B (2) $ 475.00 1

i 0227 ANN 10B(1) $ 36,350.00

TOTAL
$ 36,825.00  !

i TOTAL INVOICE: $ 36,825.00 t

Amount Billed Represents 50% Procation 0

If paid by Fedwire see attached Terms and Conditions. If paid by check,

{ make check payable to the NRC (reference Invoice no.) and mail tot '

, ==========================n==================

U.S. Nuclear Regulatory Commission <=== This PO Box address is License Fee & Accounts Receivable Branch <=== for receipt of payments

! P.O. Box 954514 <=== only.

! St. Louis, MO 63195-4514 i 1

l' Sor terms and conditions see attached.

Payment must be received within 30 days of the

date of this invoice to avoid late charges. -

Questions: call 301/415-7554.

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  • PAYMENT COPY
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ENCLOSURE 2 i

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Tennessee Valley Authonty,1101 Market Street. Chananooga. Tennecsee 37402 2801

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79 ,1  ;

/ .d 2 j' 4 0 V September 30, 1996 f y g j, j

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/;& V pf H j U.S. Nuclear Regulatory Ccamission ;i 1.3[f ATTN: Document Control Desk /

u _ " g. y' *g . , ,,, _ _ ,_ _ al l Pashington, D.C. 20555 ,

1 Gentlemen In the Matter of ) Docket No. 71-0227 Tennessee Valley Authority )

QUALITY ASSURANCE (QA) PROGRAM FOR RADIOACTIVE MATERIAL PACKAGES TVA hereby requests an amendment to the subject QA program. The purpose of this amendment is to remove references to TVA as a " User / Fabricator" and change TVA's status to a " User" only of radioactive material shipping packages. Accordingly, enclosed is Revision 7 to the subject QA program.

TVA is currently listed as the primary certificate holder on NRC l Certificate of Compliance (COC) Nos. USA /6568/A, USA /6722/A, and USA /9139/A. Accordingly, I herebf request that NRC terminate COC Nos. i USA /6722/A and USA /9139/A. I further request that NRC transfer COC No.

USA /6568/A to Chem-Nuclear Systems Inc., 140 Stoneridge Drive, Columbia, South Carolina 29210.

This action has been determined to be a Cost Beneficial Licensee Action and l has been estimated to save TVA approximately S72,000 per year.  !

In accordance with 10 CFR Part 170, an amendment fee of $250 is being sent j separately to the Fee Management Branch.

If you have any questions regarding this matter, please contact Charles' R.

Davis at (423) 751-7509.

Sine a y,

.Raul ll! R.~ Baron deneral Manager Nuclear Assurance and Licensing Enclosure cca See page 2 4- .GiOo 8 0.t9 k

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l U.S. Nuclear Reguletory Commission Page 2 September 30, 1996 Enclosure cc (Enclosure): ,

Mr. John P. Jankovich, Section Leader ]

Quality Assurance Section Source Containment and Devices Branch Division of Industrial and Medical Safety, NMSS U.S. Nuclear Regulatory Commission  !

I Washington,.D.C. 20555 I

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5 i ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY (BFN), SEQUOYAH (SON), WATTS BAR (WBN),

AND BELLEFONTE (BLN) NUCLEAR PLA?tTS i'

QUALITY ASSURANCE PROGRAM FOR RADIOACTIVE MATERIAL PACKAGES 2

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[ TENNESSEE VALLEY AUTHORITY (TVA) i.

! QUALITY ASSURANCE PROGRAM i

f i- DESCRIPTION FOR RADIOACTIVE i

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MATERIAL SHIPPING PACKAGES LICENSED j.

UNDER 10 CFR PART 71  :

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l TVA NUCLEAR I

4 REVISION: 7 ISSUE DATE: 8/30/96 i

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PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96

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Page 1 of 25 l l REVISION LOG REVISION EFFECTIVE PAGES NUMBER DATE DESCRIPTION OF REVISION AFFECTED ,

5* 06/27/91 Reformat and revise to All -

describe new organization l 6 ** 11/28/94 Revise standard number for All l ,

! WAN Radiation Protection l

Plan. Revise organizational references. Differentiate handling of TVAN-owned and ,

vendor packages. Describe use of packages by WAN users ,

not at nuclear plants. 1 7 (See Note) Change program description from All u " User / fabricator" to " User" by l l

l removing design, fabrication, I

assembly, modification, and f.

repair actions. Revise organizational j references.

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NOTE: Effective date to be established after approval by NRC.

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  • Corresponds to NRC approval revision 8 for Docket 71-0227. l

, " Corresponds to NRC approval revision 10 for Docket 71-0227. !i t

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Rovision 7 8/30/96

. - Page 2 of 25 i TABLE OF CONTENTS SECT TITLE PAGE I

REVISION LOG.. . . . . . . . .. .... . . . .1 TABLE OF CONTENTS . . . . . . . . . . . . .... .2 LIST OF ABBREVIATIONS. .. . . ... . . . . . . . . .4 1.0 PURPOSE... . . . . . . . . . . . . . . . . . . . . . . . . . .5 2.0 APPLICABILl'P/ . . . . . . . . . . . .. 5 3.0 GENERAL... . .. . . . . . . . ... . . . . . .. ..5 l

4.0 QUALITY ASSURANCE ORGANIZATION. . . . . . .5 l

4.1 Functions of Organizations . . . .. .. . . .6 5.0 PACKAGE QA PROGRAM. . .. . . .... . . . .... . . ....9 1

6.0 CONTROL OF DOCUMENTS AND RECORDS. . . . . .. .. .10 1  ;

6.1 Procedures and Instructions.. ... . ... . . . . . . . . . . . . . . . . . . . . .. 11 6.2 Document Control.. ... , . . . . . . .. . . . .. ... . ... . . . . 12 6.3 Records . .. ... . . ... . . . . . . . ... . ... . . ...... . . .. ..... 12 7.0 PROCUREMENT AND MATERIAL CONTROL. . . .. . . . . . . . . .12 7.1 Procurement Document Control. . .. .. . 12

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7.2 Control of Purchased Materials, Equipment, and Services. . . .. 13 7.3 Identification and Control of Materials, Parts, and Components . . .16 8.0 CONTROL OF ACTIVITIES . .

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. .. 17 j 8.1 Inspection and Line Verification. . . . . .

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8.2 NA&L Assessments. .

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PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 Page 3 of 25 i l

TABLE OF CONTENTS l 1

SECT TITLE PAGE

...........17 1 l 8.3 Test Control. . . . . . ..... . .... .. . . . . . . . . .

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8,4 Control of Measuring and Test Equipment.. . . . . . . . . . . . . . . . . . . .

i 8.5 Handling, Storage, and Shipping Control...... .. .. .. .......... .. ............ ...19 8.6 Inspection, Test, and Operating Status. ..... ..... . ... .. ................19 9.0 ADVERSE CONDITIONS. . .................................. . . . . . . . 19 9.1 Nonconforming Materials, Parts, or Components. .... ..... . ............19 9.2 Corrective Action. . . . . . . . . . . . . . ... .. .. .. . .. ... , . . . . . . . . . .20 10.0 INDOCTRINATION, TRAINING, QUALIFICATION, AND CERTIFICATION ...... 21 11.0 AUDITING .. ... . . .. ... ..... ..... .......................................22 l 11.1 General.. .... .. .. . . . ..... ..........................................22 11.2 I niernal Au d its . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

..............................22 11.3 Contractor / Supplier Audits .... ..... ...., .....................................22 12.0 COMPUTER SOFTWARE AND DATA... ...................................22

13.0 REFERENCES

.22 l 13.1 Regulations ... . .... .. . . . . . . . . . . . . . . . .. . . . . . . . . .

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Regulatory Guidance... . ... . . . . . . . . . . . . .23 13.2 . . . . . . . . . . . . . . . ..

TVAN Licensing Submittal Documents.. .. . 23 13.3 .. .

.23 13.4 QA Manuals. . .. . . . . . . . . . .. .. .. . . .

- 13.5 Other . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . ... . 23

. . . . . . . .24 14.0 DEFINITIONS.... ... .. . .. . . . ... . ..

Figure 1 - Organization Chart - TVA Nuclear.. . .. ... . ... .. .............25

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 '

Page 4 of 25 LIST OF ABBREVlATIONS The following abbreviations are used in this plan:

ANI/MAELU - American Nuclear Insurers / Mutual Atomic Energy Liability Underwriters CFR - Code of Federal Regulations CNSI - Chem-Nuclear Systems, Inc.

COC - Certificate of Compliance DOT - Department of Transportation M&TE - Measuring and Test Equipment NA&L - Nuclear Assurance and Licensing j NDE . - Non-destructive Examination l

NL&RA - Nuclear Licensing and Regulatory Affairs NOAP - Nuclear Quality Assurance Plan NRC - Nuclear Regulatory Commission PQAP - Package Quality Assurance Program QA - Quality Assurance QC - Quality Control RMSM - Radioactive Material Shipment Manual SAR - Safety Analysis Report TVA -Tennessee Valley Authority TVAN - TVA Nuclear

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 I Page 5 of 25 l 1

I TENNESSEE VALLEY AUTHORITY (TVA) QUALITY ASSURANCE PROGRAM DESCRIPTION FOR RADIOACTIVE MATERIAL SHIPPING PACKAGES LICENSED UNDER 10 CFR PART 71 1

l 1.0 PURPOSE 1 i

TVA Nuclear (TVAN) is the licensee within TVA for radioactive material shipping packages licensed under 10 CFR Part 71. The purpose of this ,

document is to describe the quality assurance (QA) program that satisfies the '

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requirements of subpart H of 10 CFR 71. This program addresses OA for the use, maintenance, and testirig of radioactive material shipping packages licensed by NRC under 10 CFR 71 (herein after referred to as " packages").

TVAN is a user of numerous vendor packages. l 2.0 APPLICABILITY The Package Quality Assurance Program (POAP) applies to (a) TVAN I

personnel and organizations performing activities that could affect vendor "

shipping packages which are licensed by NRC; (b) non-TVAN TVA organizations as required by intergroup Agreement; and (c) contractor activities that could affect vendor shipping ~ packages which are licensed by NRC, unless TVAN has approved alternate administrative controls for those activities.

3.0 GENERAL This document describes the quality-related functions involved with radioactive material shipping packages. The term " quality-related" encompa.sses those i

activities, items, and equipment associated with the performance and support of activities, measurements, and calculations that are required by Federal regulations and license conditions and commitments.

This POAP description is formatted in such a manner as to describe how ]

procedures and instructions are developed to implement program requirements.

4.0 OUALITY ASSURANCE ORGANIZATION i The organizational structure, functional responsibilities, levels of authority, and f lines of internal and external communication for the management, direction, l and execution of the PQAP are clearly established for all organizational levels.

I The organization chart in Figure 1 shows TVAN which has the responsibility for the PQAP for radioactive material shipping packages and its implementation for l

the use, maintenance, and testing of vendor packages. ,

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I PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 l Revision 7 8/30/96 i i Page 6 of 25 L l

i l 4.1 c unctions of Organizations i 1

WAN management, while carrying out their functions, are required to comply l fully with the aspects of the PQAP applicable to their organization and ensure proper implementation. This subsection identifies specific QA functional

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responsibilities that the identified organizations are to develop through TVAN documents.

4.1.1 President, WAN ,

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The President, WAN ensures that responsibilities for QA are clearly l defined and understood and that each organization is adequate to l

accomplish its task. Significant problems or occurrences relating to a i

QA are brought to his attention, and he participates directly in their l 4

resolution as required. The duties of the President, TVAN are carried i out through the Vice President, Engineering and Technical Services

!. l and the Senior Vice President, Nuclear Operations. )

4.1.2 TVAN Organizations 4

in addition to responsibilities delineated in other parts of this l document, TVAN organizations have the following general functions:

y i A. Invoke appropriate QA requirements on non-WAN TVA  !

organizations that provide services for quality-related programs and features, including the determination of grading indicators with due consideration for importance.

! l B. Develop, control, and maintain procedures and instructions as ap propriate to implement quality-related activities nnd processes I

involving licensed vender shipping packages.

C[ Ensure appropriate controls for documents and records generated within the organization or received from external sources.

D. Identify and issolve adverse. conditions and perform related corrective action activities including assessing trends for internally and externally identified problems.

E. Develop certification programs as appropriate and ensure that trained, qualified, and, where required, certified employees are used in the performance of quality-related activities involving 4 I licensed vendor shipping packages.

F. Initiste stop work within their area of responsibilities when warranted.

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227

. Revision 7 8/30/96 I

Page 7 of 25 G. Ensure personnel performing quality-related activities on licensed vendor packages receive indoctrination and training as necessary l to ensure that adequate proficiency is achieved and maintained.

H. Ensure procedures adequately address interfaces of affected organizations.

4.1.3 Engineering and Technical Services The duties of the Vice President, Engineering and Technical Services are carried out through the General Manager, Nuclear Assurance and Licensing, the General Manager, Technical Services, and the General Manager, Site Support. j 4.1.4 Nuclear Assurance and Licensing (NA&L)

The General Manager, NA&L is responsible for ensuring through use of audits and assessments that activities involving radioactive  ;

material packages are conducted in accordance with the POAP. The duties of the General Manager, NA&L are carried out through the Quality Assurance Manager, the Site Quality Managers, the Site NA&L Managers, and the Manager, Corporate Nuclear Licensing and Regulatory Affairs (NL&RA). The Manager, Corporate NL&RA has the following responsib'ilities:

A. Establishes an interface between TVAN and NRC for nuclear licensing activities.

B. Reviews and approves submittals and correspondence between TVAN and NRC concerning PQAP elements, and C. Ensures that commitments to NRC concerning PQAP elements are documented.

4.1.5 Site Support The General Manager, Site Support ensures control of purchased l material, equipment, and services and identification of materials, parts, and components. He also ensures that QA requirements are included or referenced in related procedure and instructions for document control. He procures contracts for the rental of vendor packages. He is also responsible for ensuring that procedures and activities for renting shipping packages include requirements for .

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procurement document control, l

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96

- - Page 8 of 25 4.1.6 Technical Services l The General Manager, Technical Services ensures that QA records generated during the use of radioactive material packages are safely stored in a retrievable manner in accordance with applicable procedures. He also ensures that QA requirements are included or referenced in related procedure and instructions for d::t. ment control, the Nuclear Procedures System, computer software, and records, i 4.1.7 Inspection Services j The Manager, inspection Services reports to the General Manager, Technical Services. He is a package user during shipments of radiography equipment. The responsibilities described for the plant manager and their staffs concerning use of packages are the same

. for inspection Services personnel.

4.1.8 Nuclear Operations The duties of the Senior Vice President, Nuclear Operations are carried out through the General Manager, Operations Support; the Vice President, Browns Ferry Site; the Vice President, Sequoyah Site; and the Vice President, Watts Bar Site. l The nuclear plant managers report to their respective site vice presidents. Primary responsibility and authority for implementing QA I

requirements for the use, maintenance, and testing of vendor packages are vested in each plant manager. Through assignments to his section supervisors, he ensures that plant-specific instructions pertaining to the use, maintenance, and testing are prepared in I accordance with established QA policies and requirements; that work is performed in accordance with approved documents; and that results are documented and proper records maintained. The plant manager is responsible for the necessary training and qualifications of plant personnel.

4.1.9 Operations Support The duties of the General Manager, Operations Support are carried out through the Manager, Radiological and Chemistry Control, who I has the following responsibilities.

A. Prepares and coordinates the review of procurement g I

specifications for vendor packages used by WAN.

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PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 Page 9 of 25 B. Maintains the PQAP Description and the Radioactive Material l Shipment Manual (RMSM) to ensure that the most current NRC and DOT regulations are incorporated into the shipping (

l procedures and instructions.

C. Analyses reports of abnormal equipment operation or personnel errors to identify and correct problems. g D. Ensures that procedures are developed for the implementation of f commitments to NRC concerning the PQAP.

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5.0 PACKAGE OA PROGRAM l

The PQAP is directed at providing the appropriate control of quality in relation to the importance of the activity or item to radiological safety and provides for ,

the graded application and verification of QA requirements to quality-related items and activities involving licensed shipping packages.

The following criteria are to be considered when applying QA requirements:

. The impact on safety on a shipping package malfunction or failure.

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. The specification, design, or uniqueness of the package.

. The need for special controls and assessment of shipping packages, l processes, and operational activities.

. The degree to which functional compliance can be demonstrated by an inspection or test.

. The quality history of a shipping package or shipping activity and the degree of standardization. l

. Requirements of applicable codes and ctandards.

The following factors are to be considered in the degree of QA verification required to ensure implementation of QA requirements:

. New activities not previously performed or implemented.

. Trend or previous histories of quality problems.

. Activities critical to package safety or having the most potential to impact safety.

. Revisions to procedures which have recently been implemented.

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 Page 10 of 25 Activities that have not been assessed in the recent past or are performed l l infrequently.

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. Activities that are performed by new personnel, contractors, or technicians.

. The requirements of applicable codes and standards that are mandated l for the shipping package or shipping activity. l l

The POAP includes procedural controls for ensuring that the use of packages l does not result in undue risk to the health and safety of the public or l l

employees. These procedural controls are established in the RMSM, implementing facility instructions, and vendor cask handling procedures. The requirements of the certificate of compliance for each package are included in these procedural controls. Revisions to PQAP documents are made in accordance with established procedures and instructions.

Work affecting the characteristics of the package which are important to quality is controlled by properly approved procedures and instructions. Maintenance work on vendor packages by TVAN personnel is also performed in accordance )

with approved procedures and instructions.

  • TVAN personnel who are involved in the use, maintenance, and testing of vendor packages are trained as specified in the RMSM and facility instructions.

This training includes familiarization with the PQAP. Non-TVA personnel who transport or use licensed shipping packages at TVAN facility sites receive training and/or orientation from TVAN as specified in the RMSM.

PQAP Description revisions are reviewed and concurred in by the General I

Manager, Nuclear Assurance and Licensing or his designate. He provides independent audits of the effectiveness of implementation of the PQAP.

Contractors providing equipment or services under the PQAP are required to have a QA program that meets the requirements of subpart H of 10 CFR 71.

The adequacy of the contractor's program is evaluated by the General Manager, Nuclear Assurance and Licensing.

6.0 CONTROL OF DOCUMENTS AND RECORDS

l PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 L l Page 11 of 25 1 6.1 Procedures and Instructions Instructions, procedures, and drawings are developed using a graded I

approach to prescribe those activities that affect the quality-related functions of I

shipping packages. Compliance with these documents is mandatory.

Requirements for suppliers and contractors to develop and implement l

procedures, instructions, and drawings to meet the pertinent requirements of I l the PQAP are included under the section entitled " Procurement Document Control." Vendor packages are controlled by vendor procedures, which may be ]

contained in controlled vendor manuals or referenced or contained in TVAN l 4

site instructions. TVAN users ensure that they have the most recent revision of  ;

vendor procedures before package use.

Procedures are written to provide a controlled method for preparing, reviewing, changing, and approving procedures and instructions. Procedures and I

instructions prescribing operational activities that affect the quality-related l

functions of shipping containers identify special equipment and environmental conditions required to perform the activity, provide applicable quantitative and 4

qualitative acceptance criteria, and include provisions for documenting that activities were accomplished in accordance with these documents.

Site instructions for administration, operation, and maintenance of shipping packages at each facility are issued, aporoved, and controlled by site-level standard practices or procedures. Site .nstructions for the use of vendor l packages may reference or contain vendor package instructions, which can also be implemented directly from the controlled vendor manual. (

TVAN site instructions that implement QA requirements are reviewed and/or assessed by the Site Quality Manager's/ Nuclear Assurance and Licensing Manager's organization using a graded approach to verify that such QA requirements are adequately defined.

TVAN procedures or instructions are prepared, reviewed, and approved within the organization responsible for the activities involved. Whenever the procedure or instruction specifies actions for another organization, the affected organization concurs with the proposed procedure or instruction before approval, unless concurrence has been made in a higher level document.

Procedures, instructions, and drawings that affect the quality-related functions of shipping packages are centrolled in sccordance with following section. t

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96

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l 6.2 Document Control l Activities such as the use, maintenance, and testing of vendor packages are i performed using approved procedures ' prepared in accordance with the TVAN Nuclear Procedures System and the RMSM. PQAP implementing procedures and associated revisions are prepared, reviewed by qualified individuals, and approved for issuance by authorized personnel before release or issuance in accordance with approved written procedures. These procedures identify the organization responsible for these actions and ensure that changes to these documents are reviewed and approved by the originating group. Manuals, procedures, and drawings for vendor packages are controlled by the vendor through his document control system. TVAN users ensure that they have the Idest revision of vendor documents before package use.

6.3 Records The RMSM establishes the requirements for preparation and storage of '

records generated during the use, maintenance, and testing of vendor-owned shipping packages used by TVAN. These records are maintained and retained as specified in the RMSM. Records are identifiable and retrievable and maintained in designated stcrage locations in accordance with established procedures. (

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7.0 PROCUREMENT AND MATERIAL CONTROL l

7.1 Procurement Document Control Procurement document control applies to documents used to obtain packages,  ;

parts, and services required to maintain, test, inspect, or use vendor {

radioactive material chipping packages. The quality of purchased replacement materials, components, and spare parts is required to be equal to or better than the original item.

Control of package procurements is accomplished primarily through procurement documents. The originating organization is responsible for '

including or referencing regulations, codes, standards, design bases, or other provisions necessary to assure adequate QA requirements in the documents I for procurement of packages, spare parts, and services. Procurement documents include the following as applicable:

A. Basic technical requirements, including drawings, test and specification requirements, special instructions, applicable regulations, codes, and industrial standards.

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 Page 13 of 25

8. QA program requirements including requirements for supplier audits, surveillance, and inspection, and provisions for TVAN's access to the I supplier's facility and records.

C. Requirements that the cask supplier provide a description of his QA program which meets the requirements of subpart H of 10 CFR 71.

D. Documentation requirements, including records to be prepared, maintained, submitted, or made available for review, such as drawings, specifications, i procedures, procurement documents, inspection and test records, l qualifications, chemical and physical test results, and instructions for ultimate disposition of the records.

TVAN utilizes recognized standards or internal specifications for the purchase of standardized items. Other items are purchased by part number or recommendations supplied by the vendor. k NA&L reviews and/or assesses procurement documents for shipping packages, spare parts, and services to assure they have been prepared, reviewed, and approved in accordance with applicable QA requirements. Procurement  ;

documents for licensed packages are reviewed and approved by individuals having responsibility to ensure that appropriate QA and technical requirements have been included.

For "off-the-shelf" items where it is impractical to impose appropriate QA l controls on the supplier, NA&L specifies quality verification requirements sufficient to ensure the adequacy of such items for use.

Package procurement documents include quality-related requirements which are not changed without the review and approval of the organizations responsible for originally reviewing the procurement document. Changes to procurement documents such as typos, changes in quantities, and monetary changes need not be routed to the originating organization or the appropriate NA&L organization provided that the procurement document change does not affect QA requirements and a copy of the change is sent to affected organizations.

7.2 Control of Purchased Materials, Equipment, and Services l

PACKAGE QA PROGRAM DESCRIPTION NRC Dockat 71'-0227 Revision 7 8/30/96 l

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7.2.1 General I l

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Vendor shipping packages, spare parts, and servicas, whether l l- purchased directly or through others, conform to procurement .

document specifications which are controlled as described in i " Procurement Document Control". Provisions are made, as .I

appropriate, for source evaluation and selection, review for objective

[

i evidence of quality, inspection at source, and examination upon delivery.

Quality control measures of package suppliers are assessed by NA&L i at periodic intervals commensurate with the importance, quantity, and l complexity of the packages or services being procured. This I

assessment verifies that documentation such as certificates of '

, conformance are valid. Proposals (bids or quotations) by suppliers l i are reviewed to ensure that no exceptions are taken which would j

{

violate quality requirements. .j 1

j 7.2.2 Source Evaluation and Selection l i The evaluation of package suppliers is based on one or more of the following:

b A. An assessment of the supplier's QA program to verify the

! supplier's capability to comply with the required elements of l

subpart H of 10 CFR 71, and/or other specific codes or standards  ;

which are applicable to the package, type of material, equipment, 1 5-3 or service being procured.

i B. A review of previous records and performance of suppliers who i have provided packages similar to the type being procured.  ;

C. A survey of the supplier's facilities and QA program to determine j his capability to supply packages which meet the design, manufacturing, and quality requirements.

Suppliers who meet these requirements are added to an " Approved ,

Suppliers List" which is maintained by the Manager, Corporate Quality Assurance. Suppliers on this list are periodically reevaluated '

and requalified or purged from the list based on results of these reevaluations.

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,', PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96

> Page 15 of 25 NA&L determines the type and extent of supplier evaluation required.

They also provide evaluation of suppliers of licensed shipping l packages. A determination is made to assure the supplier is qualified l by performing an evaluation as described above or by determining  !

from the " Approved Suppliers List" that the supplier is qualified to supply the package, spare parts, or services being procured. l NA&L maintains files of supplier evaluations. These files contain bid and contract information, QA programs, results of supplier surveys conducted by TVAN, correspondence on contract performance, reports of inspections, and QA document information. These files are maintained for the use of requisitioning organizations. NA&L also I performs supplier surveys. Supplier evaluation files may be utilized in determining the acceptability of supplier QA programs. If inadequate supplier information is available from the above source, NA&L uses other techniques in evaluating the supplier. The results of such QA program evaluations are maintained by NA&L.

7.2.3 Surveillance at Supplier Facilities l Surveillance of suppliers of licensed shipping packages is accomplished consistent with the importance to quality in accordance with written instructions. The originating organizations for each purchase request are responsible for delineating QA requirements.

7.2.4 Receiving Inspection l Examination of shipping packages upon delivery is performed in accordance with general written instructions which contain measures to assure:

A. The shipping package or related item is properly identified and corresponds with the receiving documentation.

B. Incpection of the shipping packages and acceptance records is performed and judged acceptable in accordance with predetermined inspection instructions, before the first use of the shipping package.

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 i Page 16 of 25 I C. Documentation, such as the package certificate of compliance, required drawings, operating procedures, and other items required for use of the package, is available before package use. In special circumstances, and with appropriate management

' approval, packages may be used before receipt of associated documentation, in these cases, the shipping packages are tagged as nonconforming, and additional administrative controls are used

- to provide assurance that the package is not used for radioactive material shipment before disposition of a nonconformance.

I D. Nonconforming items are segregated where practical, controlled, and clearly identified until proper disposition is made.

The site radwaste manager at each nuclear power plant (or equivalent at other TVAN faciliSes) is responsible for the receipt inspection of licensed shipping packages. The Power Stores Supervisor at each nuclear power plant (or equivalent at other facilities) is responsible for the receipt of spare parts in accordance with applicable procedures and instructions. Each item is receipt-inspected by appropriately trained and qualified personnel.

Personnel performing receipt inspections utilize written instructions to verify conformance to procurement documents. Each item is stored in accordance with its related technical and/or QA requirements.

Deficiencies, such as damage, shortage, or missing items, are

< resolved before packages or spare parts are released for use or installation and before declaring shipping packages to be ready for use. Resolution is achieved according to the requirements of

" Nonconforming Materials, Parts, or Components." l Identification and Control of Materials, Parts, and Components (

7.3 As required, materials, parts, and components are identified by heat number, tot number, unique serial number, or other means appropriate to their application. Item identification is used to maintain traceability between items in storage and the documentation which attests to the acceptability of these items, as applicable. When required by applicable codes and standards, traceability is maintained to the point of installation.

Where size and accessibility permit, the identification is on the item but such as not to interfere with the performance characteristics of the item. In other cases the identification is maintained on records traceable to the item. Regardless of the extent of traceability required, the acceptability of parts installed on a shipping package is ensured by control systems which permit only acceptable items to be released from storage.

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I PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227

- - Revision 7 8/30/96 i .

j Page 17 of 25 I G

1 f 8.0 - CONTROL OF ACTIVITIES 8.1 Inspection and Line Verification i

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' Inspection is performed using a graded approach during maintenance, material  ;

l receiving, and storage activities affecting the quality of vendor shipping l packages and related items at TVAN facilities to verify conformance with applicable requirements. Instructions covering these activities contain appropriate inspection requirements, including mandatory holdpoints, which are in accordance with the original package design and inspection source requirements or acceptable alternatives. Alternatives to originalinspection requirements are in accordance with the requirements of applicable codes, standards, and regulations. l I

8.2 NA&L Assessments ,

I NA&L performs assessment activities in accordance with section 9.2 of the I

Nuclear Quality Assurance Plan. I 1

8.3 Test Control Testing is performed to demonstrate that vendor shipping packages perform l satisfactorily in service and to ensure that malfunctions are identified in a timely manner, Tests required by the NRC Certificate of Compliance and other tests l I

required to ensure the qualification of the vendor shipping package for use are conducted by the responsible onsite organization in accordance with the controls of the PQAP.

Testing is accomplished in accordance with written and approved procedures or instructions which include the requirements of NRC Certificate of-Compliance, drawings, specifications, codes, standards, and regulatory I requirements.

Written test instructions and/or checklists include as necessary: test l equipment and calibration requirements, material requirements, prerequisite conditions, environmental conditions, limiting conditions, precautions, detailed performance instructions for the testing, inspection holdpoints, acceptance or rejection criteria, and data collection, reporting, and approval requirements.

The facility managers implement the test programs. Results of tests performed on vendor shipping packages are documented, evaluated, and their acceptability determined by qualified individuals.

i PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 {

Revision 7 8/30/96  !

j Page 18 of 25  !

f - The' Site Quality Manager / Site NA&L Manager ensures by assessment and/or review of test results that required tests of vendor shipping packages at the - l l .

4 TVAN facility are performed in accordance with approved procedures or instructions.

8.4 Control of Measuring and Test Equipment . ( l l

1 i  :

4 M&TE utilized in or related to the use, maintenance, or testing of vendor shipping packages is contro!!ed in accordance with written procedures or

[ instructions. Procedures or instructions for calibrating and controlling M&TE j '

4 , include identification of the test equipment, calibration techniques, calibration frequencies, maintenance control, and storage requirements.

Control of M&TE requires:  ;

1 A. That each item of M&TE be assigned a specific interval for recalibration. ,

B. Unique identification of each item of test equipment. .

1

! ' C. Traceability to calibration test data and tagging (when practical) to show j due_date of calibration.

! D. Traceability of reference standards to national standards and periodic I- revalidation of reference standards.

E. Records to be maintained which indicate the complete status of each item l' ~

of test equipment, including its maintenance history, calibration results, i abnormalities, and last and future calibration dates.

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F. Control of the purchase requirements and acceptance tests for new or i

replacement test equipment, t

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G. M&TE are calibrated against a working standard having tolerances within i- appropriate limits for the type of measurement being taken or test being i performed. ,

i H. The reference standards used to calibrate the working standards have a l closer tolerance than that of the working standard and are calibrated  ;

i against higher level reference standards of closer tolerance.

l M&TE found out of calibration is conspicuously tagged, segregated, and an f investigation is initiated to determine the validity of previous measurements 1

i and the corrective action to be taken. ,

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PACKAGE QA PROGRAM DESCRIPTION NRC Docket 7'i-0227 Revision 7 8/30/96 t Page 19 0f 25 i

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Tools, gauges, and instruments necessary for maintenance, inspections, and tests are calibrated and controlled in accordance with written instructions.

Test instrumentation is maintained by various organizations within TVAN and is used at the nuclear facilities as required to perform shipping package tests or i other special operations. Each organization is responsible for assuring that I test equipment used by that organization has been properly calibrated and l documented.

8.5 Handling, Storage, and Shipping Control l The RMSM requires approved procedures for handling, storing, and shipping i operations; establishes safety restrictions concerning handling, storage, and l shipping of packages; and ensures that tests, certifications, acceptances, and finalinspections have been completed before shipment. Packages are handled, stored, cleaned, and shipped in a manner to minimize deterioration, contamination, or damage.

Package-handling equipment such as cranes, forklifts, and cables which are used on radioactive material packages are tested in accordance with established procedures before use.

The facility manager desig' nates those persons responsible for handling, storage, and shipping operations that are quality-related.

8.6 Inspection, Test, and Operating Status l The RMSM establishes procedures for determining inspection, test, and '

operating status of vendor packages. Certificate of compliance test and inspection results are recorded using site or vendor instructions or procedures.

A " hold" on package use is established when inspection or test criteria are not satisfied. Only authorized personnel are allowed to remove a " hold." The facility manager designates those persons responsible for implementing the requirements of this section.

9.0 ADVERSE CONDITIONS l 9.1 Nonconforming Materials, Parts, or Components 1 Nonconforming materials, parts, or components discovered during receipt inspection or package maintenance are controlled to prevent their inadvertent l use or installation. Control of nonconforming items include:

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 4 -

Revision 7 8/30/96 i Page 20 of 25  !

A. ' Conspicuous markings to identify the item as nonconforming. l B. Reporting of nonconformance to responsible supervision and the package '

vendor, as appropriate.

C. Segregation of nonconforming items from acceptable material, when

. practical.  !

D. Review and disposition of nonconforming items by designated supervision.

Disposition action for nonconforming materials, spare parts, and components is taken by designated personnel in accordance with applicable procedures.  !

i The package vendor independently reviews and approves any nonconforming 1 items before package use. Decisions to reduce engineering requirements to permit the use of nonconforming parts, materials, or components for vendor shipping packages are also made by the package vendor with concurrence by '

appropriate site management.

9.2 Corrective Action l

. TVAN organizations and onsite non-TVAN service organizations performing -)

quality-related activities promptly identify and resolve adverse conditions.

Minor deficiencies identified during the course of QA verifications which may j be brought into compliance within an acceptable time frame are corrected on the spot in accordance with established instructions. Adverse conditions are dispositioned by organizations with defined responsibility and authority and are corrected in accordance with documented plans.

The cause of significant adverse conditions is determined, and corrective i action is taken to preclude recurrence. Significant adverse conditions are l I reported to appropriate levels of management. The satisfactory completion of  !

corrective actions is verified and documented by the appropriate organization. l Independent verification of corrective action implementation is performed by ,

NA&L as specified within the TVAN Corrective Action Program. ,

Commensurate with their impodance to quality and safety, adverse conditions i which are not being effectively or timely resolved are escalated to appropriate levels of management in a timely manner. Procedures describing the corrective action program establish the requirements for those adverse conditions which are tracked.

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NRC Docket 7'i-0227 PACKAGE OA PROGRAM DESCRIPTION Revision 7 8/30/96 1 Page 21 of 25 Trend analysis is performed on adverse conditions and quality indicators associated with NA&L verification activities. Trend results are u management of the quality status, identify adverse trends that need increas management attention, and compare quality of performance among organizations and, where applicable, with incustry standards. The trend analysis program is described in procedures and instructions.

Work is stopped under any of the following conditions:

A. Work is proceeding in violation of approved and controlling documents.

B. A condition which clearly icdicates that cessation of an activity is the only means available to protect the health and safety of the public and/or TVA personnel.

C. An activity which if continued will require extensive rework or repair for corrective action.

D. An activity which if continued may jeopardize package safety.

E. A condition that represents continual failure to comply with technical or administrative controls.

The Vice President, Engineering and Technical Services, as delegated to the General Manager, NA&L, is responsible for the development of the Corrective Action Program. Line managers are responsible to stop any work within their areas of respontibility when a continuation of activities could meet tro above criteria for work stoppage. NA&L is responsible to issue a formal Stop Work Order, as required, if a line manager fails to act on a stop work condition.

Stop Work Orde.s remain in effect until proper evaluation can be made and adequate corrective action can be applied.

NA&L is responsible to establish and maintain trend analysis procedures for adverse conditions and the quality indicators generated by NA&L verification activities such as audits, assessments, inspections, and vendor audits and surveillances.

j 10.0 INDOCTRINATION. TRAINING QUALIFICATION AND CERTIFICATION j

Personnel involved in the use, maintenance, and testing of licensed vendor shipping packages receive training and periodic retraining of the type applicable to their responsibilities and at the frequency specified in the i

RMSM. The Manager, Radiological and Chemistry Control delineates training requirements in the RMSM. The facility managers develop a program of training and indoctrination for quality-related employees which includes instruction, testing, and documentation of training, as appropriate.

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PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96

[.- Page 22 of 25 l 11.0 AUDITING l 11.1 General j i

. Measures are; established to implement a comprehensive audit program which
consists of internal audits including TVAN and other TVA organizations which j support the radioactive material shipment program and contractor / supplier j audits to determine and assess the adequacy and effectiveness of the QA program.

11.2 Internal Audits (

l The scope of an audit is determined by considering such factors as work areas, activities, processes, or items and the specific organizations involved.

! Auditing organizations ensure that audit procedures and instructions i adequately cover applicable elements of the PQAP. Audits are scheduled in accordance with site license requirements and regulatory requirements and to the extent possible based upon the status and importance to quality of the i activities being performed.

11.3 Contractor / Supplier Audits l i

l Audits of selected suppliers are conducted to verify implementation and 8

adequacy of specified QA requirements. Contractors / suppliers to be audited are selected on the basis of importance of their products to package quality, j status of contract activity, historical performance of the supplier, and potential

QA program problems that may be discovered during source surveillance j inspection activities or earlier audits. Audit schedules are prepared, and ,

audits are conducted in accordance with the schedules. Audit reports are prepared and reviewed by the audit team, approved by management, and transmitted to the supplier and appropriate management within TVAN.

l 12.0 COMPUTER SOFTWARE AND DATA l The development, procurement, maintenance, and use of computer software involved with licensed vendor shipping packages are controlled as a l quality-related activity in accordance with section 10.0 of the TVAN Radiation Protection Plan. f 1

13.0 REFERENCES

l 13.1 Regulations l 10 CFR 20," Standards for Protection Against Radiation" l

PACKAGE OA PROGRAM DESCRIPTION NRC Docket 71-0227

. - Revision 7 8/30/96 Page 23 of 25 10 CFR 21," Reporting of Defects and Noncompliance" l 10 CFR 71," Packaging and Transportation of Radioactive Material" i NRC Certificates of Compliance for vendor packages 49 CFR 171,172,173,175,177, and 178 (DOT regulations) l I

13.2 Regulatori Guidance NRC Regulatory Guide 7.4, " Leakage Tests on Packages for Shipment of Radioactive Materials" NRC Regu'atory Guide 7.10," Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material".

NRC IE Bulletin 79-19, " Packaging of Low-level Radioactive Waste for Transport and Burial" NRC IE Bulletin 79-21, " Transportation and Commercial Burial of Radioactive Material" NRC IE Bulletin 83-10," Clarification of Several Aspects Relating to use of NRC-Certified Trdisport Packages" TVAN Licensing Submittal Documents l 13.3 Browns Ferry Updated Final Safety Analysis Report Sequoyah Updated Final Safety Analysis Report Watts Bar Final Safety Analysis Report I

QA Manuals j i 13.4 TVA Nuclear Quality Assurance Plan (NOAP), TVA-NOA-PLN89-A 13.5 Other \ l TVAN Radiation Protection Plan, TVAN Standard 5.1 South Carolina Radioactive Material License No. 097 (Chem-Nuclear Systems, incorporated (CNSI)]

PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 Page 24 of 25 i

CNSI Disposal Site Criteria ANI/MAELU Engineering Inspection Criteria, Section 4.1, Low-Level Radioactive Waste Packaging and Transportation ANI/MAELU Engineering Inspection Criteria, Section 4.2 Radioactive Waste .

Management 14.0 DEFINITIONS }

Unless redefined in this document, the terms used in this document are those defined in (1) the TVAN Radioactive Material Shipment Manual, (2) the TVAN Radiation Protection Plan (TVAN Standard 5.1), or (3) section 15.0 of the Nuclear Quality Assurance Plan (TVA-NOA-PLN89-A)in order of priority.

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PACKAGE QA PROGRAM DESCRIPTION NRC Docket 71-0227 Revision 7 8/30/96 Page 25 of 25 1

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l Figure 1 Organizational Chart' l TVA Nuclear i

President, j TVA Nuclear l Sr. V.P., Vice President, Nuclear Engrg & Technical l Operations Services l

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Operating Gen Manager, ' Gen Manager, Gen Manager, Gen Manager, Site Vice Operations Nuc Assurance Technical Site Support Presidents Support & Licensing Services Manager, Manager, Manager,

- Radiological - Corp Quality - Inspection '

Operating and Chemistry Assurance Services l 1 -Plant Control '

Managers l Manager, Corp

- Nuc Licensing 4 - Plant & Reg Affairs 4 Staffs i

Site Quality

- Mngrs/Nuc Assur l & Licen Managers i l i

j C:\0RGPLUS\PCAP7.0RG i

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1 1 4

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