Information Notice No. 84-50: Clarification of Scope of Quality Assurance Programs for Transport Packages Pursuant to 10 CFR 50, Appendix B

                                                            SSINS No.: 6835 
                                                            IN 84-50       

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555

                               JUNE 21, 1984 

Information Notice No. 84-50:   CLARIFICATION OF SCOPE OF QUALITY 
                                   ASSURANCE PROGRAMS FOR TRANSPORT PACKAGES
                                   PURSUANT TO 10 CFR 50, APPENDIX B 

Addressees: 

All nuclear power reactor facilities holding an operating license (OL) or 
construction permit (CP). 

Purpose: 

To help eliminate any confusion as to the applicability of the quality 
assurance provisions of Appendix B, 10 CFR 50 to certain transport packages 
for which a quality assurance program is required by the provisions of 10 
CFR 71. It is expected that addressees will review the information provided 
in this notice for applicability to their program. Suggestions contained in 
this information notice do not constitute NRC requirements and therefore, no
specific action or written response is required. 

Background: 

Pursuant to 10 CFR 71.12(b), 71.14(b), and 71.16(c)(2), licensees who 
transport or deliver to a carrier for transport certain transport packages 
are required to have an NRC-approved quality assurance (QA) program. Such a 
program must have been approved as satisfying the applicable provisions of 
10 CFR 71 Subpart H (formerly Appendix E). An applicant's request for such a 
program approval must be in accordance with 10 CFR 71.101(c). Also, pursuant 
to 10 CFR 71.101(b) [formerly 10 CFR 71.51], each licensee must establish, 
maintain, and execute a quality assurance program that satisfies each of the 
applicable criteria of Subpart H. Under the provisions of 10 CFR 71.101(f), 
however, a licensee may utilize a QA program which has already been approved 
pursuant to 10 CFR 50, Appendix B, provided that the QA program is 
established, maintained and executed with regard to transport packages. 
Therefore, an Appendix B program is acceptable in lieu of one approved 
specifically under Subpart H. 

Discussion: 

Past inspections of transportation activities and the associated QA programs
of nuclear utilities have sometimes revealed a generic inadequacy regarding 
implementation by licensees of Commission-approved, 10 CFR 50, Appendix B, 
QA programs for transport packages. Specifically, this inadequacy usually is
evidenced by nonexistent or deficiently written QA audits for transport 
packages. Apparently some licensees have erroneously concluded that the 
previous 

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                                                              IN 84-50     
                                                              June 21, 1984 
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NRC approval of the 10 CFR 50, Appendix B, program implies fulfillment of 
the implementing QA requirements for transport packages, without 
reservation. 

Several of the criteria of 10 CFR 50, Appendix B, or 10 CFR 71, Subpart H, 
are programmatic (e,g., control of measuring and test equipment, document 
control). For these criteria, the associated implementing procedures may 
sometimes be common for both transport packaging and nontransport 
activities. Certain other aspects, however, are distinctly packaging related 
(e.g., procedures controlling procurement of packaging; preparation of 
packaging for use, loading, and unloading the packagings; maintenance of the 
packaging, QA records, audits, checklists). Consequently, the utility QA 
program must include and address all of the applicable elements for 
transport packages to meet the intent of 10 CFR 71.101(f). Licensees should 
not automatically assume that such implementing procedures developed for 
Appendix B are adequate for transport packages unless such procedures do, in 
fact, address transport packages. 

Recipients of this notice should review the information discussed for 
possible applicability to their quality assurance program for transport 
packages. No written response to this information notice is required. If you
desire additional information regarding this matter, contact the Regional 
Administrator of the appropriate NRC regional office or this office. 



                                   Edward L. Jordan Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contact:  A. W. Grella, IE
                    (301) 492-7746

Attachment:
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