ML20137R685

Informs That Staff Has Completed Review of CT low-level Radwaste Program QA Plan.Areas Recommended for Expansion, Listed

ML20137R685
Person / Time
Issue date:	04/03/1997
From:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Gingerich R CONNECTICUT, STATE OF
References
REF-WM-3 NUDOCS 9704140199
Download: ML20137R685 (4)

Text

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Pye . k UNITED STATES j, j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 l

o g ,o April 3, 1997 Ronald Gingerich. Director Low-Level Radioactive Waste Program Connecticut Hazardous Waste Management Service 50 Columbus Boulevard Hartford, CT 06106-1910

SUBJECT:

REVIEW OF THE CONNECTICUT LOW-LEVEL RADI0 ACTIVE WASTE PROGRAM OUALITY ASSURANCE PLAN

Dear Mr. Gingerich:

In response to your March 10. 1997, request the R ff reviewed your submittal entitled " Connecticut Low-Level Radioactive Waste Program Quality Assurance Plan." The staff did not conduct an in-depth review similar to the type of review that we conduct as part of the formal license application review.

Instead the staff initially conducted an " acceptance" review to determine if all the areas required in a Quality Assurance (QA) Plan were addressed. The l acceptance review was based on reviewing and comparing the information in your i Quality Assurance Plan (OAP) against the guidance identified in NUREG-1293 entitled " Quality Assurance Guidance for a Low-Level Radioactive 'aste Disposal facility," and Chapter 9. " Quality Assurance" of NUREG-1199.

" Standard Format and Content of a license application for a Low-Level Radioactive Waste Disposal Facility." The staff concluded that the Connecticut 0AP addressed all of the 0A information recommendations.

Following the acceptance review, the staff reviewed your 0AP to determine if it could identify any significant issues or concerns. This review was based on the guidance in NUREG-1293, and Chapter 9 of NUREG-1200 " Standard Review Plan for the Review of a License Application for a Low-Level Radioactive Waste Disposal Facility." The staff has identified two areas that it recommends be expanded, early on, in the development of your QAP.

First, the staff recommends that detailed implementing procedures be developed to support of each of the 18 criteria identified in your 0AP. The implementing procedures can either be developed by the your staff (CHWMS) or by your selected contractor. However, the group applying the OA criteria should develop the implementing procedures.

The implementing procedures serve four main functions: (1) they focus both your staff and supporting contractors on the necessary training to support the OAP criteria: (2) they provide a simple mechanism for making adjustments / corrective actions in toe program while minimizing schedule and cost impacts: (3) they provide both your staff and supporting contractors a written standard to evaluate their own performance (self-assessment) and take corrective actions when necessary: and (4) they provide CHWMS a mechanism for conducting audits / inspections of the program to determine if the OAP is properly implemented. For example, if the result of an audit / inspection imp,I determines that the proper procedures and supporting revisions are being used 140022 NRC FRE CENTER COPY Io 9704140199 970403 ,

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R. Gingerich and understood by .the staff / contractor applying the procedures. CHWMS will have a high level of confidence in the QA program.

Finally, the staff recommends that CHWMS define early in the 0A process when and where the QA criteria will be applied. Chapter 6. "A)plicability of Quality Assurance" of the OAP recognizes the need to esta]lish a OA program early in the facility development, and to define when and where the OAP should be applied. Considering the fact that work affecting the site characterization, performance, and safety of the facility may be performed prior to selecting the facility developer / operator, the staff cannot overemphasize the importance of defining early in the 0A process when and where the OA criteria will be applied. Because of the way CHWMS responsibilities were established by the General Assembly, this area has the potential to be the biggest single weakness in the process. However, early definition of the application of the OAP will resolve this potential issue.

The review was conducted by Larry Pittiglio who was the author of the guidance documents addressed above. He can be reached (301) 415-6702, should you have any questions concerning these comments.

Sincerely,

[0riginal signed by]

l John W. N. Hickey. Chief Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards TICKLT::LLDP-7070 DISTRIBUTION: Central File LLDP r/f DWM r/f NMSS r/f JGreeves MFederline PSobel PLohaus PUBLIC yJg

• SEE PREVIOUS CONCURRENCE Path & File Name: S:\DWM\LLDP\CLP\0A. CON OFC LLDP* LLDP* Ll{S# h NAME CPittiglio RNelson JNickey DATE 4/02/97 4/02/97 4 / 3 /97 0FFICIAL RECORD COPY ACtM: YES X NO Category: Proprietary or CF Only

! IG . YES NO X l LSS YES NO X Delete file after distribution: Yes No X 1

WMFTM l

i R. Gingerich -

-and understood by the staff / contractor apolying the procedures. CHWMS will have a high level of confidence in the OA program.

Finally, thc staff recommends that CHWMS define early in the OA process when and where the GA criteria will be applied. Chapter 6. " Applicability of Quality Assurance" of the OAP recognizes the need to esta]lish a OA program early in the facility development, and to define when and where the OAP should be applied. Considering the fact that work affecting the site characterization, performance. and safety of the facility may be performed prior to selecting the facility developer / operator, the staff cannot overemphasize the importance of defining early in the OA process when and where the QA criteria will be applied. Because of the way CHWMS responsibilities were established by the General Assembly, this area has the potential to be the biggest single weakness in the process. However early definition of the application of the OAP will resolve this potential issue. l The review was conducted by Larry Pittiglio who was the author of the guidance documents addressed above. He can be reached Gal) 415-6702. should you have any questions concerning these comments.

Sincerely. ,

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John W. N. Hickey. Chief low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards l

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and understood by the staff / contractor applying the procedures. CHWMS ill- i have a high-level of confidence in the OA program. ,

Finally, the staff recommends that CHWMS define early in the OA rocess when and where the OA criteria will be applied. . Chapter 6. "A) li ility of Quality Assurance" of the OAP recognizes.the need to esta) ' a OA program

. early~1n the facility development, and to define when and ere the OAP should {

be applied. Considering the fact that work effecting t site  !

characterization, performance, and . safety of the facil)ty may be performed i prior to selecting the facility developer / operator, fie staff cannot over .

_em hasize the importance of defining early in the process when and where -l th OA criteria will be applied. Because of the ay CHWMS responsibilities  !

j. were established by the General Assembly, this' ea has the potential to be  ;

. the biggest single weakness in the process. ever early definition of the  ;

l application of the OAP. will resolve this p t ntial issue. ]

The review was conducted by Larry Pitti o who was the author of the guidance i documents addressed above. He can be ched (301) 415-6702., should you have >

any questions concerning these commen .

Sincerely. l

. [0riginal signed by]

John W. N. Hickey. Chief Low-Level Waste and Decommissioning l Projects Branch Division of Waste Management Office of Nuclear Material Safety TICKET: LLDP-7070 QLS_TRIBUT10N: Central File LLDP r/f DWM r/f NMSS r/f JGreeves MFederline PSobel PLohaus PUBLIC To receive a copy of this document small box on "0FC:" line enter: "C" = Copy without attachment / enclosure: "E" = ,

Copy trith attachment / enclosure: - No copy.

Path & File Name: S:\DWM\. P\CLP\0A. CON OFC LLDI) [ IIDP/Jd['/ LLDP 1 NAME dPLOiklio [RNeTok JHickey DATE /k/97/' O/S/97 / /97 FFICIAL RECORD COPY ACNW: YES X N Category: Proprietary or CF Only IG : YES 0 X LSS : YES NO X Delete file after distribution: Yes No X w