COMMON MISUNDERSTANDINGS NOTED IN 10CFR PART 71 QUALITY ASSURANCE PROGRAM SUBMITTALS

The Nuclear Regulatory Commission’s (NRC’s) regulations impose quality assurance (QA) program requirements on entities that use or design Type B and fissile material packages for the transportation of radioactive materials. Prior to commencing activities subject to the QA requirements, a QA program description must be submitted to the NRC for review and approval. The NRC has noted recurring misunderstandings on the part of applicants for, and users of, these NRC-approved 10 CFR Part 71 QA programs in the areas of 1) level of detail required in QA program descriptions, 2) submittal of programs based on other standards, and 3) when approval of changes to NRC-approved QA programs is required.