ML20154N311
| ML20154N311 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1998 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bradshaw L NYE COUNTY, NV |
| References | |
| REF-WM-1 NUDOCS 9810210248 | |
| Download: ML20154N311 (6) | |
Text
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Mr. L s Bradshsw, Manag r
, - Nya County Departm: int of Natural Rcsourcss
- And Federal Facilitirs Nuclear Waste Repository Project Office i
1210 E. Basin Rd. Ste #6 Pahrump, NV 89048
SUBJECT:
EARLY WARNING DRILLING PROGRAM:
FORMAL REVIEW OF QUALITY ASSURANCE PROGRAM PLAN
Dear Mr. Bradshaw:
The purpose of this letter is to provide the U.S. Nuclear Regulatory Commission (NRC) staff's commants on the Nye County Nuclear Waste Repository Project Office Quality Assurance Program Plan (QAPP) dated June 30,1998. The QAPP was transmitted to Mr. John Greeves by your letter of September 8,1998.
The purpose of our review is to determine whether the QAPP contains adequate requirements
' and controls to address the appropriate criteria of Title 10 of the Code of Federal Regulations (10 CFR), Part 60, Subpart G, (which references 10 CFR Part 50, Appendix B) and thus serve as the framework to develop specific policies, plans, and procedures to implement the QAPP.
In addition to the 10 CFR criteria noted above, the NRC Review Plan for High-Level Waste Repository Quality Assurance Descriptions, Revision 2, was used for our review.
As a result of our review, a Request for Additional Information is enclosed. The enclose d subject matter was discussed in a meeting in the NRC On-Site Representative's (OR) o - m on September 22,1998, between the NRC OR, W. Beike, ana Nye County Representatives Mr. N Stellavato and Mr. D. Davidson.
Should you have any questions concerning our review, please contact Bill Belke of my staff at (702) 794-5047.
Sincerely, Michael J. Bell, Chief Performance Assessment and HLW Integration Branch Division of Waste Mangement p%O 981015 Office of Nuclear Material Safety WM-1 and Safeguards pg
Enclosure:
As stated
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Nye County Department of Naturel Resources And F#Wwel Feoilities Nuclear Wges Repository Project Office 1210 E. Basin Rd. Ste e6 Pehrump, NV 89048
SUBJECT:
EARLY WARNING DRILLING PROGRAM:
FORMAL MbVikW OF QUALITT ASSURANCE PROGRAM Pt.AN Dear Mr.Bradshaw; The purpose of this letter is to provide the U.S. Nuclear Regulatory Commission (NRC) staf!'s comments on the Nye County Nuclear Waste Repository Project Office Quality Assurance Program Plan (QAPP) dated June 30.1998. The QAPP was transmitted to Mr. John Greeves by your letter of September 8,1998.
The purpose of our review is to determine whether the QAPP contebs adequate requirements and controls to address the appropriate criteria of Title 10 of the Code of Federal Regulations (10 CFR), Part 60, Subpart G. (whch references 10 CPR Part 50, Appendix B) and thus serve as the framework to develop specific policies, plans, and procedures to implomont the QAPP.
In addition to the 10 CFR cntena noted 3 Dove, the NRC Review Plan for Hign-Level Weste Repository Quality Assurance Descriptions, Revision 2, was used for our review.
As a resutt of our review, a Request for Additional information is enclosed The encioemd subject matter was discussed in a meeting in the NRC On-Site Representattve's (OR) omee on Septernber 22,1998, between the NRC OR, W Reike, and Nye County Representetives Mr. N Stellevato and Mr. D. Davidson.
Should you have any questions conceming our review, please contact Bill Selke of my staff et (702) 794-5047.
Sincerely.
Michael J. Bell, Chief Performance Assessment and HLW Integration Branch Onnaion of Weste ManGement Office of Nuclear Material Safety and Safeguards I
i Enclosure As stated cc: See attached distnbution list DISTRIBUTION File Center PAHLr/f D W M r#
On-site Raps NMSSr#
PUBLIC LSS CWNRA JGreeves K8tablein DOC. NAME: S;/DWM/PAHUSLW/BRADSHAW.WPO ENC S/DWM/PAHUSLW/NYECTY.QS l
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Letter to L. Bradshaw from M. Bell dated: October 15, 1998 cc:
R. Loux, State of Nevada S. Frishman, State of Nevada L. Barrett, DOE / Wash, DC A. Brownstein, DOE / Wash, DC S. Hanauer, DOE / Wash, DC C. Einberg, DOE / Wash, DC S. Rousso, DOE / Wash, DC N. Slater, DOE / Wash, DC R. Dyer, YMPO
)
S. Brocoum, YMPO R. Clark, YMPO A. Gil, YMPO B. Price, Nevada Legislative Committee J. Meder, Nevada Legislative Counsel Bureau D. Bechtel, Clark County, NV E. von Tiesenhousen, Clark County, NV J. Regan, Churchill County, NV S. Dudley, Esmeralda County, NV L. Fiorenzi, Eureka County, NV B. Mettam, Inyo County, CA T. Manzini, Lander County, NV i
E. Culverwell, Lincoln County, NV J. Wallis, Mineral County, NV M. Murphy, Nye County, NV N. Stellavato, Nye County, NV
. W. Cameron, White Pine County, NV D. Weigel, GAO W. Barnard, NWTRB i
R. Holden, NCAI A. Mitre, NIEC R. Amold, Pahrump County, NV J. Lyznicky, AMA R. Clark, EPA F. Marcinowski, EPA R. Anderson, NEl S. Kraft,' NEl J. Kessler, EPRI
- = -
o NYE CDUNTY NUCLEAR WASTE REPOSITORY PROJECT OFFICE QUALITY ASSURANCE PROGRAM REVIEW REQUESTS FOR ADDITIONAL INFORMATION
GENERAL COMMENT
S 1.
Much of the information needed to respond to the acceptance criteria contained in the U.S. Nuclear Regulatory Commission's (NRC) Review Plan for High-Level Waste Repository Quality Assurance Program Descriptions (RP), is located in the Nye County 1
Quality Administration Procedures (QAPs) and not the Nye County Quality Assurance Program Plan (QAPP). The QAPs are actually the implementing procedures used to l
implement the requirements and commitments delineated in the QAPP. Consequently, the QAPs, conceivably face the potential of being revised more frequently to accommodate various minor changes that surface as the program develops. Also, the QAPs are the actual vehicles from which users conduct their various functions to implement the QAPP requirements and commitments. Therefore the NRC staff i
recommends that the QAPP include the necessary infc* ltion to satisfy the NRC RP acceptance criteria and become a " stand alone" docum.
In this way, the QAPs will have the necessary flexibility to accommodate minor changes and ravisions.
2.
Throughout the QAPP, references are made to ANSI /ASME NQA-1 without referring to the actual date of this document. The QAPP should specify which edition (date) of the ANSI /ASME NOA-1 document is being used as the bass for the commitment. (The NRC RP endorses the 1986 edition of ANSI /ASME NOA-1.)
SPECIFIC COMMENTS 1.
It is not clear what quality-affecting functions (if any), the Regulatory Licensing Contractor identified in Figure 1-1 performs. (NRC Review Plan (RP) Section 1,1.2) 2.
Paragraph 1.3.1 in the QAPP indicates that the Project Quality Assurance Officer reports directly to the On-Site Geotechnical Representative when not involved in quality-affecting work. This is not clearly identified in Figure 1-1, Nye County Waste Repository Project Office Organizational Chart. (RP Section 1,1.10) 3.
Clarify how criteria is established and documented for determining and identifying structures, systems, and components, software, and activities, which are to be covered by the QA program. Describe how the intent or equivalent of NUREG-1318 is met.
(RP Section 2,2.4) 4.
Describe provisions which assure that the QAPP includes measures which assure that the development, control, and/or use of computer programs will be conducted in accordance with the guidance of NUREG-0856 and NUREG/CR-4640.
(RP Section 2,2.9) 5.
Clarify the extent of design that the Nye County QA drilling program is applicable to. It is the NRC's understanding, that the Nye County drilling program does not apply to Enclosure
design as opposed to scientific investigation. Should this be the case, the description in a
S,ection 3.0 of the QAPP should be clarified accordingly. (RP Section 3) 6.
Describe how errors and deficiencies in technical reviews are documented and corrected. (RP Section 3,3.7) 7.
Describe provisions to assure that plans for data collection are completeC before performing data collection and analysis activities. (RP Section 3,3.11) 8.
Clarify whether peer reviews are conducted in accordance with or the equivalent of NUREG-1297, " Generic Technical Position on Peer Review for High-Levd Waste Repositories." (RP Section 3,3.16) 9.
Describe measures which assure changes to Scientific Investigation Technical Reports, Scientific Notebooks, Work Plans, Technical Procedures, Test Plans and Procedures, and QAPs are subject to the same controls that were originally applied. (RP Sections 3, 3.17; 6,6.4; and 11,11.4) 10.
Clarify whether measures are established to assure that verified computer codes are certified for use and their uses are specified. (RP Section 3,3.18) 11.
Identify whether there are plans for Nye County to qualify any data which was collected without a fully implemented 10 CFR Part 60 Quality Assurance Program, if so, measures should be described to meet the criteria provided in NUREG-1298, " Generic Technical Position on Qualification of Existing Data for High-Level Nuclear Waste Repositories." (RP Section 3,3.19) 12.
Describe measures to assure that inputs for scieritific investigation are specified and approved on a timely basis and to the level of detail necessary to permit the activity to be carried out in a timely manner and to provide a consistent basis for making decisions, accomplishing verification measures, and evaluating changes.
(RP Section 3,3. 20) 13.
Clarify whether procedures are established to assure that applicable regulatory requirements, design bases, and other requirements are referenced or stated in procurement documents; there are adequate acceptance and rejection criteria, and that procurement documents have been prepared, and approved, to confirm that these requirements have been correctly c arried out. (RP 4,4.1) 14.
Describe measures to assure that changes to field and laboratory procedures are documented and verified in a timely manner by authorized personnel. (RP Section 5, 5.4) 15.
Describe provisions which assure that when documents which require verification are released before verification, they are identified, controlled, and authorized for release through signature approval, with the described bases for release. (RP Section 6,6.7) 2
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16.
Measures should be described whereby the organization providing items, materials, equipment, services, or software furnishes documentation identifying any procurement requirements that have not been met, and a description of nonconformances from the procurement requirements that have not been met. (RP Section 7,7.4) 17.
Describe measure which assure that supplier's certificates of conformance for items, services, and software are periodically evaluated by audits, independent inspections, or tests to assure they are valid and the results are documented. (RP Section 7,7.7) 18.
Clarify whether correct identification of samples is verified and documented prior to release or use or analysis. (RP Section,8,8.4) 19.
Describe measures to assure that potential sources of uncertainty and error in test plans, procedures, and parameters which must be controlled and measured to assure that tests are well controlled are identified. (RP Section 11,11.5) 20.
Clarify whether provisions are established to indicate by mariings, the status and operating status of software. (RP Section 14,14.1) 2 Describe whether measures are established to control altering the sequence of required tests, inspections, and other operations important to safety. (RP Section 14,14.5) 22.
Describe measures which assure that procedures are established for
- documenting / recording, reviewing, and confirming accuracy of scientific notebooks.
(RP Section 17,17.6) 23.
. Clarify whether audits include technical evaluations of software. (RP Section 18,18.3) 3