ML20206H753
| ML20206H753 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/1986 |
| From: | Kennedy J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20206H509 | List: |
| References | |
| IAEA-SM-289-9, NUDOCS 8606260284 | |
| Download: ML20206H753 (24) | |
Text
__
1 INTERNATIONAL ATOMIC ENERGY AGENCY (i
INTERNATIONAL SYMPOSIUM ON THE SITING, DESIGN
- AND CONSTRUCTION OF UNDERGROUND REPOSITORIES FOR RADIOACTIVE WASTES Hanover, Federal Republic of Germany,3-7 March 1986 1AEA-SM-289/ 9 U.S. NUCLEAR REGULATORY COMMISSION PROGRAM FOR LICENSING OF A HIGH-LEVEL WASTE GEOLOGIC REPOSITORY James E. Kennedy Division of Waste Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C.
l h
8606260284 PDR 860619 MISC 8606260147 PDR !
a This is e preprint of a paper intended for presentation et e scientific meeting. Secoues of the provisional nature of its content and since changes of substance or detail may hows to be enade before publication, the proprint is made smilable on the l
l understanding that it will not be ched in the literature or in any way be reproduced in its present form. The views expressed and the statements made remain the responalidlity of the named author (s); the viene do not necessarily reflect thoes of the govem.
f ment of the designeting Member State (s) or of the designating organiastion(s). In pertkuder,os/ther the IAEA nor any other f
orpenisesion orbeeV sponeering thk meeting tan be h%i rensenannte for arry metenlal.e ' -!In thle pmprint.
l l
INTERNATIONAL ATOMIC ENERGY AGENCY INTERNATIONAL SYMPOSIUM ON THE SITING, DESIGN
-- AND CONSTRUCTION OF UNDERGROUND REPOSITORIES FOR RADIOACTIVE WASTES Hanover. Federal Republic of Germany,3-7 March 1986 l
lAEA-SM-289/ 9 i
U.S. NUCLEAR REGULATORY COMMISSION PROGRAM FOR LICENSING OF A HIGH-LEVEL WASTE GE0 LOGIC REFOSITORY ABSTRACT The U.S. Nuclear Regulatory Commission is responsible for licensing a high level nuclear waste repository under a rigorous technical and legal process. In the last de~cade, a number of nuclear power plants have been unable to be licensed through this process due to breakdowns in the quality assurance programs that are needed to demonstrate that facilities have been designed and constructed safely. A number of the causes of these breakdowns apply as well to the geologic repository. DOE is faced with a large, complex, first-of-a-kind program with tight schedules and participants who are inexperienced with the rigor required for nuclear facility licensing. The NRC needs to develop a compre-hensive oversight program for quality assurance programs to help assure that problems are identified and corrective action obtained early in the process, not at the time of licensing when years of data collection activities could be found to be inadequate.
This le a preprint of a paper intended for presentation at a scientific meeting. Secoues of the provisional nature of its content and since changes of subetence or detail moy have to be rnede before publication, the proprint le made anilable on the understanding that it will not be cited in the literature or in any way be reproduced in its present form. The views expressed and the statemente made remain the responsibility of the named author (el; the views do not necessarily reflect those of the gowrn-ment of the designeting Member State (s) or of the designeting orgenlastion(s). In particuler, neither the IA(A nor any other oogenisation or body Jponsoring this meeUng can be heed renponsble for any meterial reproduced in this proprint.
1 INTRODUCTION The consequences of failing"to adequately design, construct, operate and license a high level nuclear waste repository in the U.S. are enormous. Costs for the overall program are estimated to exceed 20' billion dollars over the next few decades, and close to 3 billion dollars will be spent during the next five years of characterizing potential sites for a repository. The future of nuclear power as a source of electricity is to some extent tied to the ability of the nation to find a method for_ safely disposing of high level waste. The protection of the health and safety of the public and workers, and the environment is tied to the quality of the work performed in implementing the program.
And finally, the credibility of the involved Federal agencies, the U.S. Department of Energy (DOE) and the U.S.
Nuclear Regulatory Commission (NRC), is also at stake.
At the same time, the process for licensing a repository is a highly rigorous one. Nuclear power reactors such as Midland, Zimmer, Marble Hill, and Diablo Canyon have either experienced long delays and large increases in costs or been cancelled altogether befope being placed in operation, in part due to the requirements of NRC licensing. In this paper, the NRC licensing process for a geologic repository will be discussed. Special emphasis will be given to the quality assurance programs that are needed to provide a demonstration that adequate quality has been achieved. This paper will also address the mistakes that have been made in the past and how it is believed they can be prevented in this program in the future, and the major challenges faced by both DOE and NRC in establishing and reviewing quality assurance programs.
THE LICENSING PROCESS ,
There are two major federal agencies who are participants in the high level waste repository program--DOE and NRC--and each has a clearly separate mission. The DOE is i
4
2 responsible for the overall management of the program for the design, construction, and operation of a repository. The DOE is also responsible for preparing a license application for demonstrating to the NRC that the repository can be operated safely and can isolate waste for the required periods of time. The NRC has the responsibility for regulating the DOE to assure that the requirements for protecting the public, workers, and environment are met. This is the only responsibility of the NRC.
Licensing of a repository by the NRC will proceed in several steps. DOE must provide comprehensive and complete information in an application to the NRC at three different points: prior to the initiation of construction, before the emplacement of waste, and prior to permanent closure of the repository. At each point they must be able to demonstrate the requirements have been fulfilled. It will be illustrative to examine the first major step in licensing, the authorization to begin construction which is similar to licensing steps at the other phases of the program. Prior to receiving approval to begin construction of a repository, DOE must submit a license application to the NRC which provides assessments of the performance of the facility both during
, the operations phase when waste is being emplaced, and after permanent closure. The NRC staff will review the license application, and in addition, will examine the supporting data and details. The NRC staff will conduct independent assessments of repository performance using these data to determine if compliance with the technical criteria in the NRC regulations has been achieved. The staff will make recomendations as to whether and under what conditions a license should be issued. After staff review, a licensing board will conduct independent adjudicatory hearings on issues and concerns brought before it by the states, Indian tribes, and public. Both the NRC staff and the DOE will have to provide evidence to defend their conclusions, and will be cross examined by the parties disagreeing with their findings. Past experience has shown that expert opinion alone, without documentation of the quality of the data and ,
l
- . . - - , ,-, - ;--- - - e - - - , -- -
- e. ._
~
q
_ 3 work performed, will not survive the scrutiny of a licensing proceeding. In order to complete the staff review and licensing proceedings within the schedules specified for the program will require a complete and well documented license application from the D0E.
Within the next year or so it is expected that DOE will begin formal site characterization for three potential repository sites. Although the first formal step in licensing will not occur until 1991, when the license application is submitted, DOE will be collecting large amounts of data over the next five years to support conclusions in the license application. The staff is therefore involved now in assessing the programs of the DOE to determine if they will lead to a high quality license application.
l IMPORTANCE OF QUALITY ASSURANCE PROGRAMS Many tasks will need to be performed in the geologic repository program over the next several decades, but few will be as important as establishing effective quality assurance programs. Quality assurance programs are a vital and integral part of the overall management system needed to achieve quality and to be able to demonstrate in the rigorous licensing process that quality has been achieved. The quality assurance program required by the regulatory process provides a structured system for this demonstration of quality. It is not enough to obtain the necessary quality, but providing proof of the quality that exists is needed to give the NRC, the states, Indian tribes, and the public confidence that a repository will perform as intended.
The formal NRC definition of quality assurance in the applicable regulations is as follows:
" Quality assurance comprises all those planned and systematic actions necessary to provide adequate confidence that the geologic repository and its
4 subsystems or components will perform satisfactorily in service. Quality assurance includes quality centrol, which comprises those quality assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means to control the quality of the material, structure, component, or system to predetermined requirements."
Briefly, the quality assurance program is a management tool for planning, checking, and documenting work that helps in achieving the necessary quality and in being able to demonstrate that quality has been achieved.
LESSONS LEARNED FROM U.S. REACTOR PROGRAM While it is recognized that a geologic repository is not a reactor, there are still many lessons that can be learned from the problems experienced in the reactor program. The programs are similar in that both are large scale, involve high technology, and require large and complex project management organizations to accomplish the necessary results.
Both also require that the projects undergo essentially the 4
same licensing process of the NRC involving the scrutiny of the NRC staff, licensing boards, and interested outside parties such as the states and tribes. And both programs must also establish and implement similar quality assurance programs to provide the demonstration that quality has been achieved.
Based on the civilian reactor program experience, the NRC staff has found characteristics that can increase or decrease the likelihood that a project can be successfully licensed. Listed below are specific challenges that the staff sees for both the DOE and NRC based on these experiences.
I
I 5
i CHALLENGES FOR DOE l Size of the Program One challenge faced by DOE is the overall size of the program and the resultant management challenge it ;
creates. There are well over 100 organizations l participating in the DOE high level waste program, ,
including the various DOE offices, contractors, and !
subcontractors. DOE Headquarters has overall !
responsibility for the. repository program, and four l separate project offices are involved in developing I programs for potential sites. Within each project, the numerous participating organizations are often spread out geographically. The tasks of communicating - 1 requirements for quality assurance programs to all of a the participants, and to overseeing the implementation of the quality assurance programs in all of the various organizations are enormous ones. A problem experienced in the reactor programs was that in some cases owners often delegated most of the responsibility for achieving and assuring quality to the contractors, and did not systematically oversee the results of their work to independently determine if it was demonstrably correct.
Schedules The U.S. Congress has established aggressive schedules for the development of a high level waste repository--by 1998, DOE is required by the Nuclear Waste Policy Act to begin emplacing waste in a repository. 00E has established intermediate milestones and schedules for meeting the 1998 date which are similarly aggressive. Site characterization for three sites is to be completed by about 1991. At that time, DOE must submit a license application to the NRC for one site which demonstrates that the repository can operate safely and isolate waste. Three years are allotted for review by the NRC staff and the NRC licensing hearings, l l
1 4
4 4
6 and five additional years are scheduled for construction of the repository.
It is important that quality not be sacrificed to meet schedules. DOE has committed to placing quality as its first priority, even if schedules must be slipped, but the schedules imposed by the Congress will make the task of completing the necessary work on time with acceptable quality difficult. Some reactor projects in the U.S. had difficulty achieving the proper balance between schedule and quality.
l Inexperience of Project Participants t The DOE and its contractors have many years of experience in designing, constructing, and operating i
nuclear facilities. For the first time in the repository program, however, DOE must have a major project licensed by the NRC. As many nuclear utilities have learned, the successful practices employed for non-licensed facilities are not necessarily sufficient for a licensed facility. The NRC requirements for demonstrable quality subject to lengthy NRC staff and licensing board scrutiny present a test DOE has not faced before. Many of the scientists and engineers working in this program have successfully performed their duties for years and will want to continue with these work practices. In order to meet NRC requirements, some changes to how these practices are i documented may be necessary. They must lead to quality products and fit into an overall quality assurance program which can provide the demonstration of the quality of work performed. To not do so can result in '
l inconsistent methods, inadequate documentation, and ;
questionable results. DOE has a large task in educating i the various elements of their program in the requirements for a licensed facility and for ensuring that they are being properly implemented.
~
__ 7 Uniqueness of the Repository Program Unlike the reactor program, which has numerous industry standards and work practices which have been established over the many years of designing and constructing nuclear power plants, the repository is a first-of-a-kind program. Many of the technical issues that need to be addressed in site characterization, for example, will involve tests that are state-of-the-art and for which there are no well-defined requirements.
As a result, the standard checking of work against well established acceptance criteria as is done for reactors will not often be pcssible for the repository program.
Peer reviews of state-of-the-art tests and data analysis will instead be necessary.
Another factor that makes the repository program unique is the interest and involvement of the states and affected Indian tribes. Both are concerned that a repository be developed which protects the health and safety of the public and protects the environment.
Under the Nuclear Waste Policy Act, the states and tribes receive funding to oversee the DOE repository program. Their ability to closely monitor the program and raise issues and concerns in the licensing process could cause delays as issues are litigated. The funding available is well in excess of that available to intervenors in nuclear plant licensing proceedings.
Qualifying Existing Data When DOE begins its site characterization program, it expects to have the formal quality assurance programs required by the NRC fully established. Data collected and analyzed after that time should be defensible in a licensing proceeding if the quality assurance programs are satisfactorily implemented. But there will be a large amount of data collected before these quality assurance programs will have been established which DOE
I 8
l l
I will likely use to support its license application. A challenge facing DOE is how to qualify that data, that is to review it and determine if the necessary demonstration of -its quality can be made for licensing.
For example, information collected on hydrology and geology by oil companies in the vicinity of a potential repository site may be relevant in determining the suitability of that site. It is important that DOE establish methods by which these data may be reviewed and begin the task of processing existing data.
Use of the Quality Assurance Program as a Management Tool Previous reactor projects have in some cases viewed the quality assurance programs as simply another regulatory requirement to meet for licensing, with little overall benefit to managing the program. With the large number of participants in this program who are inexperienced with formal quality assurance programs, such an attitude is possible as well for the repository.
DOE must overcome the tendency to view quality assurance programs as only requirements, and to integrate them into their overall management r,ystem. The quality assurance program should be a part of the management system for keeping management apprised of problems and corrective actions.
CHALLENGES FOR NRC Stability in Regulatory Requirements A major part of the site characterization program concerns scientific investigations where it is not always appropriate to apply the exact same quality assurance programs used for reactor plants to these efforts. Conventional features of programs designed for engineered facilities will need to be tailored to the work at hand. Such elements as inspections by quality I
N 4'
l
o ...
9 assurance personnel, use of non-conformance reports for exploratory tests, and reviews of designs and performance assessments will need to be tailored to the work at hand. It is important that acceptable approaches for applying quality assurance to the repository work be agreed upon early between the DOE and NRC. Experience has shown that changing regulatory requirements throughout the development of a program can cause major program perturbations.
NRC Oversight Programs A primary finding from the reactor programs was that NRC was slow to diagnose problems and take actions.
A root cause was the sporadic and non-constant presence of inspectors at reactor sites. In response to this finding, both the DOE and NRC have agreed that NRC audits of the DOE quality assurance programs will be needed before site characterization work begins so that both 00E, NRC, and others have confidence that data collected during site characterization will be defensible in licensing. The staff of the NRC is now in the process of developing a comprehensive audit plan for assessing the overall quality assurance programs for each project. One of the biggest challenges is to determine the health of such a large program when only a portion of the program can be audited. The rationale that the staff develops must withstand the scrutiny of a licensing board in the early 1990's. The staff is planning to focus on those areas of the program which are expected to have problems. For example, the staff is considering the experience of the organizations in the program and will concentrate on those which bne never operated under a formal quality assurance program.
In addition, the staff reviews will give heavy emphasis to the quality of the products through inclusion of technical staff on the audit teams. The quality assurance program is designed to help achieve quality in addition to providing evidence of quality, and the NRC l
l
- 4. .
10 assessment of its effectiveness will include an assessment of the quality produced.
Such early involvement of the NRC may highlight problems during the early phases of the program, but it is far better to uncover these problems early and obtain corrective action now rather than wait until formal 4 licensing begins in 1991.
l
SUMMARY
- The formal licensing process of the NRC for nuclear i
facilities is a highly rigorous one. Quality assurance
! programs play an important part in this process because they provide confidence, through documentation of work, that a repository can safely operate and isolate waste for thousands i
of years. Both the DOE and NRC face difficult challenges in establishing and reviewing quality assurance programs for the 4
repository, based on experiences from the U.S. reactor program. By learning from past mistakes, however, both federal agencies can accomplish their objectives for the permanent disposal of high level nuclear waste.
I I
l l
i i
tr l
1 INTERNATIONAL ATOMIC ENERGY AGENCY j INTERNATIONAL SYMPOSIUM ON THE SITING, DESIGN J AND CONSTRUCTION O FOR RADIOACTIVE WASTES Hanover, Federal Republic of Germany,3-7 March 1986 IAEA SM-289/ 9 U.S. NUCLEAR REGULATORY C0:efISSION PROGRAM FOR LICENSING OF A HIGH-LEVEL WASTE GEOLOGIC REPOSITORY l
James E. Kennedy Division of Waste Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C.
This le a preprint of a paper intended for presentetion et a scientific meeting. Sensues of the prov6eionel nature of ite
.' content and eines changes of subetence or detail may howe to be made before publication, the proprint le modo eveilable on the understanding that it will not t:e cited in the literature or in any way be reproduced in its present form. The vieve empreened and
' the statemente modo remain the roeponsibility of the named author (si; the views de not nessenerify reflect thoes of the govern-rnent of the designeting Mondsor StateW or of the designeting orgenlastionie). in partkuder,celcher the IAEA nor any other oopenseealen er bony eponsoring shk meetkw een be hem renneneboe hw any meteriel reprodvene'in thk preprint.
1
. l lNTERNATIONAL ATOMIC ENERGY AGENCY INTERNATIONAL SYMPOSIUM ON THE SITING, DESIGN
- AND CONSTRUCTION OF UNDERGROUND REPOSITORIES FOR RADIOACTIVE WASTES ;
Hanover, Federal Republic of Germany,3-7 March 1986 l l
> i lAEA-SM-289/ g U.S. NUCLEAR REGULATORY COMMISSION PROGRAM FOR LICENSING OF A HIGH-LEVEL WASTE GEOLOGIC REPOSITORY ABSTRACT The U.S. Nuclear Regulatory Comission is responsible for licensing a high level nuclear waste repository under a rigorous technical and legal process. In the last de'cade, a number of nuclear power plants have been unable to be licensed through this process due to breakdowns in the quality assurance programs that are needed to demonstrate that facilities have been designed and constructed safely. A number of the causes of these breakdowns apply as well to the geologic repository. DOE is faced with a large, complex, first-of-a-kind program with tight schedules and -
participants who are inexperienced with the rigor required for
' nuclear facility licensing. The NRC needs to develop a compre-hensive oversight program for quality assurance programs to help t assure that problems are identified and corrective action obtained early in the process, not at the time of licensing when 1
years of data collection activities could be found to be inadequate.
1 t
l l This le a proprint of a peper Intended for presentation et a eclentific meeting. Seesues of the i.ie.':':d noture of its j content and einse changes of substence or detail twy hows to be mode before publication, the preprint le made swi'oble on the underseending that it will not be cited in the literature or in any wey be reproduced in its present form. The views empressed and the statemente made remain the responsibility of the named author (sh the viene do not i ;;p reflect thoes of the gewere ment of the designeting Member State (s) or of the designeting oegenlastion(el. In pertdeuter, poleher she /AEA nor any oener oogenaneelen er % nooneering thee meetine een be how oweneneste for eny meeertet reprodveed in then preprint.
1 INTRODUCTION l
The consequences of failing to adequately design, construct, operate and license a high level nuclear waste repository in the U.S. are enormous. Costs for the overall program are estimated to exceed 20 billion dollars over the next few decades, and close to 3 billion dollars will be ;
spent during the next five years of characterizing potential sites for a repository. The future of nuclear power as a source of electricity is to some extent tied to the ability ,
of the nation to find a method for safely disposing of high level waste. The protection of the health and safety of the public and workers, and the environment is tied to the quality of the work performed in implementing the program.
And finally, the credibility of the involved Federal ,
agencies, the U.S. Department of Energy (DOE) and the U.S.
Nuclear Regulatory Comission (NRC), is also at stake. 1 At the'same time, the process for licensing a repository is a highly rigorous one. Nuclear power reactors such as Midland, Zimer, Marble Hill, and Diablo Canyon have either experienced long delays and large increases in costs or been cancelled altogether before being placea in operation, in part due to the requirements of NRC licensing. In this paper, the NRC licensing process for a geologic repository will be discussed. Special emphasis will be given to the quality assurance programs that are needed to provide a demonstration
- hat adequate quality has been achieved. This paper will also address the mistakes that have been made in the past and how it is believed they can be prevented in this !
program in the future, and the major challenges faced by both DOE and NRC in establishing and reviewing quality assurance ,
programs.
THE LICENSING PROCESS There are two major federal agencies who are participants in the high level waste repository program--DOE and NRC--and each has a clearly separate mission. The DOE is i
e
2 responsible for the overall management of the program for the design, construction, and operation of a repository. The 00E is alse responsible for preparing a license application for demonstrating to the NRC that the repository can be operated safely and can isolate waste for the required periods of time. The NRC has the responsibility for regulating the 00E to assure that the requirements for protecting the public, workers, and environment are met. This is the only responsibility of the NRC.
Licensing of a repository by the NRC will proceed in several steps. 00E must provida comprehensive and complete information in an application to the NRC at three different points: prior to the initiation of construction, before the emplacement of waste, and prior to permanent closure of the repository. At each point they must be able to demonstrate the requirements have been fulfilled. It will be illustrative to examine the first raajor step in licensing, the authorization to begin construction which is similar to licensing steps at the other phases of the program. Prior to receiving approval to begin construction of a repository, DOE must submit a license application to the NRC which provides assessments of the performance of the facility both during the operations phase when waste is being emplaced, and after permanent closure. The NRC staff will revied the license application, and in addition, will examine the supporting data and details. The NRC staff will conduct independent assessments of repository performance using these data to determine if compliance with the technical criteria in the NRC regulations has been achieved. The staff will make recomendations as to whether and under what conditions a license should be issued. After staff review, a licensing board will conduct independent adjudicatory hearings on issues and concerns brought before it by the states, Indian tribes, and public. Both the NRC staff and the DOE will have to provide evidence to defend their conclusions, and will be cross examined by the parties disagreeing with their findings. Past experience has shown that expert opinion alone, without documentation of the quality of the data and n
- . l l
__ 3 work performed, will not survive the scrutiny of a licensing proceeding. In order to complete the staff review and licensing proceedings within the schedules specified for the i program will require a complete and well documented license application from the 00E.
Within the next year or so it is expected that DOE will begin formal site characterization for three potential repository sites. Although the first fomal step in i licensing will not occur until 1991, when the license application is submitted, DOE will be collecting large
- amounts of data over the next five years to support i conclusions in the license application. The staff is
- therefore involved now in assessing the programs of the DOE l to determine if they will lead to a high quality license
- application.
1 i IMPORTANCE OF QUALITY ASSURANCE PROGRAMS Many tasks will need to be performed in the geologic repository program over the next several decades, but few will be as important as establishing effective quality assurance programs. Quality assurance programs are a vital and integral part of the overall management system needed to achieve quality and to be able to demonstrate in the rigorous licensing process that quality has been achieved. The quality assurance program required by the regulatory process provides a structured system for this demonstration of quality. It is not enough to obtain the necessary quality, but providing proof of the quality that exists is needed to give the NRC, the states, Indian tribes, and the public confidence that a repository will perfonn as intended.
The formal NRC definition of quality assurance in the applicable regulations is as follows:
" Quality assurance comprises all those planned and systematic actions necessary to provide adequate confidence that the geologic repository and its
4 4
subsystems or components will perform satisfactorily in service. Quality assurance includes quality control, which comprises those quality assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means to control the quality of the material, structure, component, or system to predetermined requirements."
Briefly, the quality assurance program is a management tool for planning, checking, and documenting work that helps in achieving the necessary quality and in being able to demonstrate that quality has been achieved.
LESSONS LEARNED FROM U.S. REACTOR PROGRAM While it is recognized that a geologic repository is not a reactor, there are still many lessons that can be learned from the problems experienced in the reactor program. The programs are similar in that both are large scale, involve
, high technology, and require large and complex project management organizations to accomplish the necessary results.
Both also require that the projects undergo essentially the same licensing process of the NRC involving the scrutiny of the NRC staff, licensing boards, and interested outside parties such as the states and tribes. And both programs must also establish and implement similar quality assurance programs to provide the demonstration that quality has Leen achieved.
Based on the civilian reactor program experience, the NRC staff has found characteristics that can increase or decrease the likelihood that a project can be successfully licensed. Listed below are specific challenges that the staff sees for both the DOE and NRC based on these experiences.
5 CHALLENGES FOR DOE
~
Size of the Program One challenge faced by DOE is the overall size of the program and the resultant management challenge it creates. There are well over 100 organizations participating in the DOE high level waste program, including the various DOE offices, contractors, and subcontractors. 00E Headquarters has overall responsibility for the. repository program, and four separate project offices are involved in developing 1
. programs for potential sites. Within each project, the numerous participating organizations are often spread out geographically. The tasks of consnunicating
, requirements for quality assurance programs to all of i '
the participants, and to overseeing the implementation of the quality assurance programs in all of the various organizations are enormous ones. A problem experienced in the reactor programs was that in some cases owners often delegated most of the responsibility for achieving and assuring quality to the contractors, and did not systematically oversee the results of their work to independently determine if it was demonstrably correct.
Schedules The U.S. Congress has established aggressive schedules for the development of a high level waste repository--by 1998 DOE is required by the Nuclear Waste Policy Act to begin emplacing waste in a repository. DOE has established intermediate milestones and schedules for meeting the 1998 date which are similarly aggressive. Site characterization for three sites is to be completed by about 1991. At that time, DOE mJst submit a license application to the NRC for one site which demonstrates that the repository can operate
- safely and isolate waste. Three years are allotted for review by the NRC staff and the NRC licensing hearings, i
- --.,.,_ - ,. - - - - - - - - . , . - ~ --.?- ,
6 and five additional years are scheduled for construction of the repository.
It is important that quality not be sacrificed to meet schedules. 00E has committed to placing quality as its first priority, even if schedules must be slipped, but the schedules imposed by the Congress will make the task of completing the necessary work on time with acceptable quality difficult. Some reactor projects in the U.S. had difficulty achieving the proper balance between schedule and quality.
Inexperience of Project Participants The DOE and its contractors have many years of experience in designing, constructing, and operating nuclear facilities. For the first time in the repository program, however, DOE must have a major project licensed by the NRC. As many nuclear utilities have learned, the successful practices employed for non-licensed facilities are not necessarily sufficient for a licensed facility. The NRC requirements for demonstrable quality subject to lengthy NRC staff and licensing board scrutiny present a test DOE has not faced before. Many of the scientists and engineers working in this program have successfully performed their duties for years and will want to continue with these work practices. In order to meet NRC requirements, some changes to how these practices are documented may be necessary. They must lead to quality products and fit into an overall quality assurance program which can provide the demonstration of the
quality of work performed. To not do so can result in inconsistent methods, inadequate documentation, and questionable results. DOE has a large task in educating the various elements of their program in the requirements for a licensed facility and for ensuring that they are being properly implemented.
l l
l l
l .
2
7 Uniqueness of the Repository Program l Unlike the reactor program, which has numerous
! industry standards and work practices which have been established over the many years of designing and constructing nuclear power plants, the repository is a first-of-a-kind program. Many of the technical issues
! that need to be addressed in site characterization, for i example, will involve tests that are state-of-the-art and for which there are no well-defined requirements.
As a result, the standard checking of work against well established acceptance criteria as is done for reactors will not often be possible for the repository program.
Peer reviews of state-of-the-art tests and data analysis will instead be necessary.
l Another factor that makes the repository program unique is the interest and involvement of the states and affectsJ Indian tribes. Both are concerned that a i repository be developed which protects the health and j safety of the public and protects the environment.
! Under the Nuclear Waste Policy Act, the states and 1 tribes receive funding to oversee the DOE repository program. Their ability to closely monitor the program and raise issues and concerns in the licensing process could cause delays as issues are litigated. The funding
- available is well in excess of that available to
- intervenors in nuclear plant licensing proceedings.
Qualifying Existing Data
- When DOE begins its site characterization program, it expects to have the formal quality assurance programs I required by the NRC fully established. Data collected and analyzed after that time should be defensible in a licensing proceeding if the quality assurance programs are satisfactorily implemented. But there will be a large amount of data collected before these quality assurance programs will have been established which DOE i
I A
I 8
will likely use to support its license application. A challenge facing DOE is how to qualify that data, that is to review it and determine if the necessary demonstration of its quality can be made for licenshg.
For example, information collected on hydrology and geology by oil companies in the vicinity of a potential repository site may be relevant in determining the suitability of that site. It is important the.t DOE establish methods by which these data may be reviewed and begin the task of processing existing data.
Use of the Quality Assurance Program as a Management Tool Previous reactor projects have in some cases viewed the quality assurance programs as simply another regulatory requirement to meet for licensing, with little overall benefit to managing the program. V'th the large number of participants in this program who are
, inexperienced with fomal quality assurance programs, such an attitude is possible as well for the repository.
- DOE must overcome the tendency to view ouality assurance programs as only requirements, and to integrate them into their overall management system. The quality assurance program should te a part of the management syste.m for keeping management apprised of problems and corrective actions.
CHALLENGES FOR NRC Stability in Regulatory Requirements
- A major part of the site characterization program concerns scientific investigations where it is not always appropriate to apply the exact same quality assurance programs used for reactor plants to these efforts. Conventional features of programs d? signed for engineered facilities will need to be tailored to the work at hand. Such elements as inspections by quality l
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9 assurance personnel, use of non-conformance reports for exploratory tests, and reviews of designs and performance assessments will need to be tailored to the work at hand. It is important that acceptable approaches for applying quality assurance to the repository work be agreed upon early between the DOE and
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NRC. Experience has shown that changing regulatory requirements throughout the development of a program can cause major program perturbations.
NRC Oversight Programs A primary finding from the reactor programs was
- that NRC was slow to diagnose problems and take actions.
A root cause was the sporadic and non-constant presence of inspectors at reactor sites. In response to this finding, both the DOE and NRC have agreed that NRC audits of the DOE quality assurance programs will be needed before site characterization work begins so that both DOE, NRC, and others have confidence that data collected during site characterization will be defensible in licensing. The staff of the NRC is now in the process of developing a comprehensive audit plan for l assessing the overall quality assurance programs for each project. One of the biggest challenges is to determine the health of such a large program when only a portion of the program can be audited. The rationale that the staff develops must withstand the scrutiny of a licensing board in the early 1990's. The staff is planning to focus on those areas of the program which are expected to have problems. For example, the staff is considering the experience of the organizations in the program and will concentrate on those which have never operated under a fonnal quality assurance program.
In addition, the staff reviews will give heavy emphasis to the quality of the products through inclusion of technical staff on the audit teams. The quality assurance program is designed to help achieve quality in addition to providing evidence of quality, and the NRC t
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10 assessment of its effectiveness will include an assessment of the quality produced.
Such early involvement of the NRC may highlight problems during the early phases of the program, but it is far better to uncover these problems early and obtain corrective action now rather than wait until formal licensing begins in 1991.
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SUMMARY
The formal licensing process of the NRC for nuclear facilities is a highly rigorous one. Quality assurance programs play an important part in this process because they provide confidence, through documentation of work, that a repository can safely operate and isolate waste for thousands of years. Both the DOE and NRC face difficult challenges in establishing and reviewing quality assurance programs for the repository, based on experiences from the U.S. reactor program. By learning from past mistakes, however, both federal agencies can accomplish their objectives for the permanent disposal of high level nuclear waste.
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