ML22154A453
| ML22154A453 | |
| Person / Time | |
|---|---|
| Site: | 07100968 |
| Issue date: | 06/03/2022 |
| From: | Hipolito Gonzalez NRC/NMSS/DFM/IOB |
| To: | Boyd R Secured Transportation Services |
| A THOMLINSON NMSS/DFM/IOB 3014157000 | |
| References | |
| Download: ML22154A453 (3) | |
Text
June 3, 2022 Mr. Roy A. Boyd, II President Secured Transportation Services, LLC 90 West Moreno Street Buford, GA 30518
SUBJECT:
SECURED TRANSPORTATION SERVICES QUALITY ASSURANCE PROGRAM REQUEST
Dear Roy Boyd:
By letter dated July 13, 2021 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML21201A320), Secured Transportation Services, LLC (STS) requested U.S. Nuclear Regulatory Commission (NRC) approval of STS-QAM-QP1, Revision 0, Quality Assurance Program (ADAMS Accession No. ML21201A321) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 71 subpart H.
Following staff engagement with STS personnel concerning the eligibility of STS to receive NRC approval of its Quality Assurance Program (QAP), STS sent a separate letter dated November 19, 2021 (ADAMS Accession No. ML21327A031), and made the following request:
STS formally requests an interpretation of whether a quality assurance program should be approved by the NRC prior to engaging in Type B package design activities as indicated in NUREG 7.10, or whether quality assurance programs may only be submitted after the package design has been completed and submitted to the NRC.
As a response to these questions, the NRC staff reviewed the following 10 CFR Part 71 requirements.
10 CFR 71.31(a), requires, in part that:
An application for an approval under this part must include, for each proposed packaging design, the following information:
R. Boyd 2
A quality assurance program description, as required by § 71.37, or a reference to a previously approved quality assurance program.
Establishment of program. Each licensee, certificate holder, and applicant for a CoC
[Certificate of Compliance] shall establish, maintain, and execute a quality assurance program satisfying each of the applicable criteria of §§ 71.101 through 71.137 and satisfying any specific provisions that are applicable to the licensee's activities including procurement of packaging. The licensee, certificate holder, and applicant for a CoC shall execute the applicable criteria in a graded approach to an extent that is commensurate with the quality assurance requirement's importance to safety.
Before the fabrication, testing, or modification of any package for the shipment of licensed material subject to this subpart, each certificate holder, or applicant for a Certificate of Compliance shall obtain Commission approval of its quality assurance program.
10 CFR 71.105(a), in relevant part:
The licensee, certificate holder, and applicant for a CoC shall identify the material and components to be covered by the quality assurance program In summary:
- 1) It is not necessary to have an NRC-approved QAP prior to beginning package design activities. It is only required prior to beginning fabrication.
- 2) Prior to applying for a CoC, the design must be complete to the point that the materials and components of the design are identified, and the designs importance to safety is delineated using a graded approach.
- 3) Only licensees, certificate holders, and applicants for a CoC are eligible to have a QAP approved by the NRC. See 10 CFR 71.105(a).1 A thorough review of NRC records has confirmed that STS is not a current NRC licensee, certificate holder, or CoC applicant. Until such time that STS applies for a CoC, the NRC cannot review an STS QAP. Once STS applies for a CoC, the NRC will review (and, if found sufficient under 10 CFR Part 71, approve) the QAP as early in the application process as possible. This can be discussed in more detail during pre-application meetings.
1 In addition, the NRC staffs position with regards to QAP approvals for those that are not licensees, certificate holders, or applicants is stated in a publicly available letter entitled Request for NRC Position on Controls of Type B Package Fabrication, dated June 13, 2012 (ADAMS Accession No. ML12165A157).
R. Boyd 3
If you have any questions or additional concerns regarding this communication, please contact Aaron Thomlinson at (301) 415-7000.
Sincerely, Hipolito Gonzalez, Acting Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-0968 Hipolito J.
Gonzalez Digitally signed by Hipolito J. Gonzalez Date: 2022.06.03 14:23:55 -04'00'
ML22154A453*E-mail OFC:
NMSS/DFM OGC NLO NMSS/DFM NMSS/DFM NAME:
AThomlinson JMcManus*
SFigueroa*
HGonzalez*
DATE:
5/5/2022 5/5/2022 5/6/2022 6/3/2022