ML19324C349
| ML19324C349 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1989 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 8911160157 | |
| Download: ML19324C349 (5) | |
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DG/M.MTTHEWS/11/9
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Mr. Mark' Matthews Acting Project Manager l
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< Uranium Mill Tai 1Ings Project Office i
Albuquerque Operations Off1ce U.S. Dep:rtment of Energy l
P.O. Box 5400 j
j Albuquerque, EM 87115 j
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Dear Mr. Matthews:
' Enclosed are our remaining comments pertinent to your Revision 2 of the UMTRA Project Quality Assurance Plan, July 1989.
An advance copy of these comments was provided to you during our recent meeting on November 1,1989. As discussed during that meeting, once you have had a chance to look over this enclosure, we will set up a meeting to discuss the connents and plans for l
NRC's accompaniment on future audits.
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.If you have any questior.s regarding this review, please feel free to contact me or Dan Gillen of my staff (FTS 492 0517).
I Sincerely, j
(SIGNED) PAULH.LOHAUS l
L I
Paul H. Lohaus, Chief Operations Branch j
Division of Low-Level Weste Management j
and Decommissioning, NMSS I
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Enclosure:
As stated Sally MannChuck Cormler,E Hg.
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l COMMENTS ON UMTRA-DOE /AL 185, REVISION 2 f
UMTRA PROJECT QUALITY ASSURANCE PLAN l
Basis for Review The UMTRA Project Quality Assurance Plan was reviewed against 10 CFR 50 Appendix 0 and ANSI /ASME NQA-1.
Coments 1.
DOE has not adequately responded to the General Comment addressed on May 15, 1989.
In sumary, it is still not clear what DOE is responsible for. Questions 3 thru 23 provide some additional detailed coments i
expanding on the May 15, 1989 Gtneral Coment.
2.
The DOE response to NRC's questions, May 19, 1989, about the DOE QA Plan
- l did not adequately address questions 6, 7c, 9, 12b and 14 l
3.
Page 6. Subsection 1.3.1; DOE /AL This section states that the DOE /UNTRA-P0 discharges its QA responsibilities with the assistance and advice of the TAC, by such activities as the following:
a.
Partir.jpation in design revtews and QA audits, b.
Reviewing and approving of test plans and QA procedures, c.
Providing QA surveillance and policy guidance.
I d.
Reviewing and approving of QAPP's prepared by organizations t
participating in the Project.
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In 1.3.la above it is stated that the DOE /lNTRA-P0 participates in design reviews.
In 1.3.2 it is stated that the DOE /UMTRA Project Manager i
approves design criteria, conceptual design, and final design.
It is 1
suggested that the responsibilities for achieving and assuring the quality of the remedial action task activities be clearly stated in Section 1.0 Organization.
Those same responsibilities should be consistently threaded through the rest of the QA plan.
In 1.3 lb above it is stated that the DOE /UMTRA-P0 approves test plans and QA procedures.
Who or what aart of the Project office approves plans
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and procedures? Who generates tae plans and procedures to be approved -
l DOE and/or contractors? In 1.3.1c above it is stated that the
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Comments UMTRA-00E/AL... l l
DOE /UMTRA-P0 provides QA surveillance and policy guidance, This statement does not describe the control that must be exercised by the Project Office and further is inconsistent with statements later in the j
document which indicate the Project Office controls audits of contractors, j
i 4.
Page 6, Subsection 1.3.2;,UMTRA project Manager
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The responsibilities of the DOE Project Manager and his staff are not described.
Subsection 1.3.2 states only that the Project Manager administers the Project and Is assisted by Project Engineers.
5.
Page 5, Subsection 1.2.6; The DOE /AL Project Quality Assurance Manager In subsection 1.2.6; it is stated that the Project Quality Assurance i
Manager supervises and directs the QA activities of the TAC and RAC.
In i
subsection 1.4.3, it is stated that the RAC Quality manager has authority to stop work.
Since the Project QAM does not have authority to stop work l
and directs the RAC Quality manager, how does the subordinate gain this i
authority? How does this authority to stop work yested in the RAC l
l Quality manager relate to the statement in subsection 1.8, that states the overall authority to stop work on all levels of the UMTRA Project rests solely with the DOE Contracting Officer?
6.
Page 17. Section 2.0; Quality Assurance Program
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Much of Section 2, Quality Assurance Program is written as a restatement l
l of requirements rather than stating what is being done by what part of l
the DOE Project Organization.
L An example, 2.2.9, states orgenizational managers will periodically l
assess the effectiveness of those portions of the QA program for which they are responsible.
The term ' organizational manager is not used in Section 1 to describe the DOE organization nor has the DOE organization been broken down to include manager titles.
7.
Page 24 Section 3.2.5; _ Readiness Review for Design Activities Readiness reviews are discussed in 3.2.5, with no indication of what the I
participation is by the DOE Project office.
The same is true for 3.2.6, Design Verification and 3.2.7 Design Charge Control.
8.
Page 25, Section 3.2.8, Design Error end Design Deficiency Control It is stated in 3.2.8, that errors and deficiencies in ap) roved design documents generated by the DOE /UMTRA Project Office will
>e controlled and resolved in accordance with Section 16.
Section 16, Corrective Action, 1
Coments UNTRA DOE /AL...
3-l states that provisions for reporting conditions adverse to quality are I
addressed in project contractor QAPP's.
How are project Office generated i
deficiencies resolved by contractors? What is the respoasibility of the Project office for deficiencies generated within DOE?
9.
Page 26, Section 4.0; Procurement Docyent Control i
It is not clear whether DOE will procure materials and services form the information provided )n Section 4, frocurement Document Control.
Doe responsibilities for contractor procurements are also not addresses.
10.
Page 28, Section 5.0; Instructions. Procedures and Drawing DOE /UMTRA Project Office rassonsibilities are not defined for the preparation and approvai of Project Office procedures.
A listing of DOE procedures needs to be provided to further assess the effectiveness of the DOE management systems.
11.
Page 29, Section 6.0; Document Control DOE /UMTRA Project office responsibilities are not specified for Project i
Office controlled documents, t
12.
Page 31, Section 7; Control of Purchases Materials. Equipment and Services This is adequate providing DOE-AL or DOE /VMTRA Project Office does not purchase any materials or services and does not enter into the contractors process for procurements in any way.
13.
Page 34, Section 8; Identification and Control of Materials. Parth and Components l
This section is adequate.
l 14 Page 35, Section 9; Centrol of Special Processej This section is adequate, h
a 15.
Page 36, Section 10; Inspection This section is adequate.
16.
Page 37, Section 11;. Test Contro1 This section is adequate.
17.
Page 38, Section 12; Control of Measuring and Test Equipment This section is adequate.
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Comments UMTRA-DOE /AL...
4-l 18.
Page 39, Section 12; Control of Measuring and Test Equipnent This section is adequate.
19.
Page 40, Section 14; Inspection, Test, and Operating Status f
This section is adequate.
20.
Page 41, Section 15; Control of_ Nonconforming items This section is adequate.
21.
Page 42, Section 16; Corrective Action i
DOE /UNTRA Project Office organization responsibilities are r.ot defined for corrective actions for which the Project Office is responsible.
22, Page 43. Section 17; Quality Assurance Records DOE /UMTRA Project Office responsibilities are not defined for retention and retrieval of records produced by the Project Office.
23.
Page 45, Section 18; Audits i
This section is adequate.
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