ML20198N172
| 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
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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 '
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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 ,
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