ML20136G282
| ML20136G282 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/1985 |
| From: | Ankrum G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20136G286 | List: |
| References | |
| REF-PROJ-M-38 NUDOCS 8508120654 | |
| Download: ML20136G282 (5) | |
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["g UNITED STATES 8
g NUCLEAR REGULATORY COMMISSION
- j WASHINGTON, D. C. 20555 g *... *,o AUG o5 %5 MEMORANDUM FOR:
Leland C. Rouse, Chief Advance Fuel and Spent Fuel Licensing Branch Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards FROM:
G. Ted Ankrum, Chief Quality Assurance Branch Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement
SUBJECT:
IE COMMENTS ON 00E'S AUDIT OF R. M. PARSONS COMPANY In accordance with our discussions we are transmitting the comments noted during the observation of the Department of Energy audit of the Monitored Retrievable Storage (MRS) installation's advanced conceptual design by the R.
M. Parsons Company of Delaware.
Contacts for this report 're W. D. Altman, FTS 492-8490, and C. G. Walenga, FTS 492-7846.
G. Ted Ankrum, Chief Quality Assurance Branch livision of Quality Assurance, Vendor, and Technical Training Center Programs Of ' ice of Inspection and Enforcement
Enclosure:
IE's Observations on DOE's Audit of R. M. Parsons Company of Delaware's Design of the MRS, March 1985 Se#6tzp654(A t
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SOE Aud't of R. M. Parsons, Company, Pasadena, CA DOE Task -- Advanced Conceptual Design of MR5
SUBJECT:
IE'S OBSERVATIONS ON DOE'S AUDIT OF R. M. PARSONS COMPANY'S DESIGN OF THE MRS The Nuclear Waste Policy Act of 1982 (NWPA) provides for the Department of Energy (DOE) to develop a proposal for a design of a monitored retrievable storage facility for high level waste which, if authorized, would be constructed and operated by the DOE. The Nuclear Regulatory Commission (NRC), specifically the Office of Nuclear Materials Safety and Safeguards (NMSS), is tasked with the eventual licensing of such a monitored retrievable storage (MRS) facility, if it is authorized. Prior to Congressional authorization for an MRS and the MRS license submittal, the NWPA authorizes DOE to consult with the NRC on safety matters and licensing procedures.
With the eventual licensing of the MRS in mind, DOE invited NMSS to observe DOE's conduct of an audit on the R. M. Parsons Company (Parsons) activities related to the advanced conceptual design of the MRS.
NMSS, in turn, requested the Office of Inspection and Enforcement (IE), specifically the Quality Assurance Branch (QAB), to assist NMSS in the performance of the audit observation. This audit was to be the s~econd DOE audit of Parsons' ctivities related to the MRS. QAB provided an experienced QA staff member to accompany NMSS while observing DOE's conduct of the audit.
The role of the NRC observation team was limited.to observation of the' DOE, auditors during their conduct of the audit of MRS design activities and to provide comments from an NRC regulatory and policy perspective based on the observers' NRC auditing experience.
The comments were to be used by DOE as data for DOE's future use in their audit function. NRC's rele in DOE's conduct of the Parsons audit was strictly consultation.
The NRC and DOE individuals at Parsons' Pasadena site were as follows:
NRC Observers A. Tom Clark, NMSS Craig Walenga, IE DOE Participants John Rast, Safety and QA Division, RL (Lead)
Ron Graham, Commercial Spent Fuel Management Program, RL Gene Koschik, Westinghouse Hanford Company Bruce Nicoll, Basalt Waste Isolation Project, RL George Rokkan, Commercial Spent Fuel Management Program, RL (Coordinator) ap
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The scope of DOE's audit as taken from DOE's audit plan was:
...to cover the
'(Parsons) implementation of QA program requirements for selected activities associated with the MRS.
The audit will focus on completed design documents and supporting design packages with respect to requirements imposed by DOE-RL Order 5700.1 and ANSI /ASME NQA-1..." this audit was to ensure that the design process was properly followed and that an adequate audit trail existed from the initial dc. sign bases to final design products. A previous programmatic audit had Nen conducted on Parsons by DOE in December,1984. Thus, a secondary objective of.this audit was to follow-up on the corrective actions Parsons committed to during the-last DOE audit.
Prior to the conduct of the audit, the NRC personnel provided the DOE audit team with several comments on the current NRC policy towards QA and the auditing function. These comments were to give the auditors, and eventually DOE, a perspective about NRC's quality program objectives. The following general comments were provided:'
a)
NUREG-1055 contains informative material that would be helpful for DOE to use in analyzing and formulating a QA program for the MRS.
-b)
In its' inspections and reviews, the NRC is placing increased emphasis on the achievement of quality in the end product. This.is in contrast to many QA audit programs which are largely programmatic in nature, and which place heavy emphasis on paperwork compliance.
c).
Line Management is responsible for the achievement of quality, not the QA organization.
d)
The QA'crganization is part of a closed-loop management control system which checks the work performed by the line and provides feedback to tcp management regarding the quality of the work performed. The QA organization does not " inspect" quality "in" to a project.
e)
The'NRC has implemented a version of the DOE Readiness Review Program and an Integrated Design Inspection program, both of which are' designed to provide the NRC with a timely and objective evaluation of an applicant's achievement of quality in'the design and construction phase of a project.
The'following comments were noted by NRC's observers during the DOE' audit.
Since some aspects of the audit process were performed prior to the actual conduct of the audit at Parsons, some of the observations are inferred from the conduct of the audit.
a)
Audit Scheduling, Audit Notification and Audit Plan The audit scheduling, notification efforts, and the audit plan were acceptable. The scope of the audit for the current conceptual phase of the work completed by Parsons was appropriate. At this early stage of the project when work is beginning and adequacy and completeness of procedures need to be established, the~ audits emphasis was properly on programmatic matters and the QA process. The auditors approach of' selecting systems and/or components'and following these samples through the entire
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. design process was similar to one aspect of NRC's approach in its. Integrated Design Inspections (IDIs).
NRC will look for this activity in future DOE audits.
For future audits of MRS design activities, DOE should ensure that the audits are structured so that a combination of both compliance (process) and performance (end product, technical, and management) objectives are identified for review.. Technical specialists or technical experts in the areas being reviewed should be used when assessing technical performance.
b)
Preaudit Preparation and Planning 1.
Based on the activities of the auditors at the start of the audit, it appeared that there had not been a sufficient amount of preparation time allotted to allow the auditors to familiarize themselves with Parsons' quality program.
It also appeared that the auditors had not been assigned specific review areas in advance so that they could prepare for their audit roles.
The lengthy planning and familiarization period spent at the beginning of this audit was not an effective expenditure of time.
2.
The audit checklists did not contain specific audit objectives or guidance regarding how to select systems for review, nor was there guidance as to the number of systems to be reviewed.
3.
The DOE Records of Auditor Qualifications were reviewed by the NRC and the auditors were evaluated as having sufficient educational back-ground and pertinent general experience for effective participation on the audit team.
c)
Audit Entrance Meeting-The DOE auditors handling of the. entrance meeting was satisfactory.- During the entrance meeting, Parsons exhibited.an extreme willingness to cooperate fully with the auditors and were well prepared to discuss the corrective actions Parsons was taking regarding DOE's prior audit findings.
d)
Conduct of Audit 1.
With the exception of the long auditor familiarization period at the start of the audit, the actual conduct of the audit was acceptable.
2.
As part of the audit, the auditors should assess the completeness and clarity of design specifications, including instructions for manufacturing; inclusion of appropriate dimensional tolerances; upper and lower limits; sampling frequency; confidence levels and measurement techniques.
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3.
The extent and adequacy of the contractor's programs for configuration management and design change control should be one subject considered
~
Control of change was identified in in some depth by the audit.
NUREG-1055 as an important factor in reducing design errors and construction quality problems.
e)
Audit Report The audit report was well written.and the findings were objective and well supported by the evidence.
f) ' Corrective Action No observations were conducted on the follow-up activities of the auditors since Parsons had not completed corrective action to the DOE's previous audit findings.
NRC considers effective corrective action, including thorough root cause analyses for major deficiencies, to be an important factor in the implementation of an effective quality program.
The NRC observers found the format for the information/ consultation exchange with DOE to be beneficial to both groups.
The NRC observers recommend that consultations between NRC and DOE such as this audit observation be continued.
Summary Based on the above NRC observations, the following areas are recommended to be given emphasis by DOE in reviewing their audit program:
a.
Ensuring that audits are not just programmatic and compliance-oriented; ensuring that they strike an appropriate balance between review of process and technical reviews of products.
b.
' Reviewing several examples of the contractor's' identification and resolution of quality problems in order to assess the contractor's program for analysis and identification of root causes of problems, effectiveness of corrective action, and follow up.
c.
Evaluation of the extent to which top management is aware of and acts on critical project information related to quality.
d.
Using technical personnel who have current relevant design experience as part of the audit team.
e.
Ensuring adequate training and preparation by the audit team prior to audit.
f.
Providing guidance on how to select systems for review to ensure that conclusions based on sampling can be justified.,
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