ML20211E401
| ML20211E401 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/1986 |
| From: | Kennedy J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Browning R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-1 NUDOCS 8610220438 | |
| Download: ML20211E401 (15) | |
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JTGreeves JJLinehan MEMORANDUM FOR:
Robert E. Browning, Director RBoyle Division of Waste Management JKennedy & r/f SCoplan THROUGH:
John J. Linehan, Acting Chief RJohnson Repository Projects Branch KStablein Division of Waste Management PHildenbrand RCook FROM:
James E. Kennedy, Section Leader PPrestholt Repository Projects Branch Tverma Division of Waste Management JGiarratana
SUBJECT:
SUMMARY
OF MANAGEMENT MEETING WITH DOE HEADQUARTERS, JUNE 5, 1986
Background:
NRC staff met with DOE Headquarters personnel on Thursday, June 5,1986 to discuss staff concerns with the DOE repository QA program. The meeting was held in room 7F-059 of the Forrestal Building from 3:00 p.m. to 5:00 p.m.
In attendance were:
NRC DOE M. Bell, DWM W. Purcell H. Miller, IE J. Knight J. Linehan, DWM M. Langston T. Ankrum, IE C. Newton J. Kennedy, DWM S. Bilhorn, DWM Summary:
The NRC staff made a presentation on concerns it has with the DOE repository program (a staff handout from the meeting is attached as enclosure 1).
Specific problems observed by the staff in the last 11 years were reviewed.
While the presentation and concerns focused on QA, they generally apply equally as well to DOE's technical program as well. NRC staff believes that three management issues are in part responsible for these specific problems: DOE's need to rely heavily on contractors, a lack of centralized management within the DOE repository program, and the lack of an effective QA program. Although the staff has had only limited review of the DOE program, a significant number of problems have been identified. The staff therefore believes that the extent of problems may be much larger. These problems will need to be addressed and WM Rec rd file WM Prciect __./
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, 1 resolved before submission of the SCP's for review and comment, if DOE is to meet its commitment to have a fully qualified program in place prior to submittal of the SCP's.
Regarding DOE's reliance on contractors, DOE has a small staff relative to those of their contractors. While the staff believes this practice can work, DOE cannot abrogate responsibility to contractors and must have sufficient numbers of qualified staff to oversee the work of contractors.
The staff indicated that given the need to rely on contractors, the other two issues become.even more important.- Past experience has shown that a lack of centralized management makes project success more difficult to achieve. The findings of the Ford Study (NUREG-1055) and an EPRI study (see page 3-18 of the Ford study for the correct reference) on construction lead times for nuclear power plants, and the DOE experience with the FFTF project support this conclusion. The NRC staff believes that centralized management in which OCRWM has direct control over the project offices and the project offices have direct control over their contractors, or some other organizational arrangement that would provide similar control, would increase the likelihood of success for the project. The staff discussed specific evidence of the lack of centralized control making management of the program more difficult. For example, the NNWSI project cannot directly issue stop work orders to certain contractors, but must coordinate them with the contracting officer who is an employee of the i
field office. Such an arrangement has been a factor in the long time needed for NNWSI to issue stop work orders to site contractors in the last several months. 00E indicated that they believe the present organizational arrangement is working adequately.
The staff also discussed how an effective QA program can help to minimize the impact of reliance on contractors and reduce the number of quality problems in the program, it provides a means to assess the performance of contractors and 1
a basis for taking corrective action. Along with the additional control mentioned above, it is a part of a closed loop management system in which problems are identified and the authority to correct them givensto the responsible managers.
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The staff indicated that it was raising management concerns with the DOE now before major problems had occurred so that appropriate action can be taken by i
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The staff proposed several NRC actions that would allow the NRC to provide additional feeaback to DOE on their QA program and provide DOE with a better understanding of what NRC expects at the time NRC audits D0E's program. First.
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-the staff will carry out its existing plans for observing how well and quickly i
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- DATE
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MINUTES 2 the DOE program is developing. These plans were discussed in detail during the December 4-5, 1985 meeting with DOE and are described in the minutes for that meeting. Second, the staff proposed that it conduct mini-audits of discrete program areas as soon as possible. This would also give DOE an understanding of the expectations of the NRC in its audits. DOE staff indicated that no other NRC audits, other than those currently planned at the time of SCP issuance, would be requested or pennitted. The staff also proposed observing the lifting of stop work orders that have recently been imposed on several contractors. DOE indicated that staff observations would not be practical.
Stop work orders will be lifted when work is ready to proceed, and DOE does not plan to audit readiness to lift the stop work orders. The NRC staff pointed out that DOE was at risk with such an approach in that later staff audits could find quality assurance and/or technical programs to be unacceptable.
The NRC staff again highlighted the need for the DOE to establish detailed schedules and milestones so that the NRC and DOE can determine when and where specific interactions are needed. DOE indicated that they are working on this in response to several other NRC letters on this topic but that it would be some time before a meeting to lay out milestones and schedules and agree on consultation points could take place.
Follow-up Actions The NRC staff committed to documenting the concerns identified in the meeting.
This memorandum, and the letter forwarding it to DOE, constitute the necessary documentation.
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James E. Kennedy, Section Leader Repository Projects Branch Division of Waste Management Record note: This memorandum was reviewed by Ted Ankrum of IE who concurred that it was a acebrate account of the discussions during the meeting.
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l BRIEFING OF OGil m STAFF VIDlS OF 1)OE 1
QA PROGRAM AND PROPOSED 3
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0 DESCRIBE SPl:CIFIC 115ELUIS SlAFF HAS OBSERVED 10 DATE o
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l'WIP Miiill:6 txt liyttt> LOGIC IESTING, DECLMBER 3 ll, }985 "A Sa:ND lEriti! CAL RATIGMLE FOR TIE PURPOSE AND 11MillG OF TIE PROPOSED TESTING WAS NOT j
PRESETHED..."
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"...)LS11iJG PROCEDURES AND QUAL 1TY ASSURANCE PLANS HAD NOT BEEN FINALIZED."
"...lMIP COULD NOT DEMONSTRATE tl0W TtE TESTING STRATEGY WAS BElllG INTEGRATED WITH OllER Si1E (linRAClER17ATION ACTIVITIES."
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TIE STAf F LLLIEVES ItESE SikJRTCtMINGS NE DUE IN PART TO AN INEFFECTIVE 0A PROGiwi i
i ts Cl>li LibHARY Al Ni&di "bF bliAlEST CCKERN WAS TIE UNAVAILABILITY OF PROCEDURES...FOR COLLECTl!1G MlD HANDLING CORE i
MARCil28,1985 LETIER 10 D0il VIETH (GIVES RESULTS OF 9/84 DATA REVIEW)
"... CORE CllSTODY IS SUPPOfdED BY DOClifNTATION OF QUESTIONABLE ADEQUACY..." (NtwomER 13,1985 i
LETTER TO DON VIETH BASED ON 9/85 SITE VISIT)
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"...GESTIG10 CUK.ERNING HANDLING AND DUCtfENTATION OF CORE S#FLES MAY ULTIMATELY AFILCl
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LICENSABILITY OF fl&JSI SITE.
(S#E AS ABOVE) l 86/06/0l1 i
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3gV IIAGI DATA REVIEW OF ROCK ffolMilCS/DESIG4 TESTING PROCEDURES o
llbARDING ItE DATA, OllE l'ulflT RECif S It! A titt4BER OF TIE ATTAGED CatolTS: NNELY, INADEQUATE IUCitif1TATICt: Of VN:100S ITLMS, INCLUDING CAllBRAllul DATA, ACCEPTANCE / REJECTION CRITERIAi Af4D DAIA REIUCIlull AllD 'lLS1 Pl<0CEDURES." LETILk lo VIElli 0F hARO128,1985 o
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...Sttf Ph1ULCl P/JillCIPANTS [VIZ., US6S1 HOLD A VIEW OF GA AS UNNECESSARY, BURDEllSOFE, AND AN IMPOSITION." MitMTES OF ftMSI QA MEETING,12/8f1 "lR li.DICAlLD lHAT llS68 HAS NOT ACCEPTED llE PRCUECT OA REQUIREMENTS. FOM OW-UP G4 THIS ITEM IS t!EEDED BY ICE." MitUTES OF INIP OA MEETING,12/811 Itini W,1%5 LETTERS ON NRC DATA REVIDJS (SEE ABOVE AND PREVIOUS SLIDE) RE LIS6S SAIC AUDil, SistrU 1986 - STOP WORK ORDER REQUIRED DIE 10 PROBLEMS IDENTIFIED AT (J$6S O
LFFEcllVEfLSS Of AUDITS "If1 StftiARY,1 DO 10T BELIEVE llE AUDIT (BY IMC) 0F 140CKKLL'S AUDIT AND SURVEILLANCE PROGRfN WAS LffECTIVE... hY C0NCLU51dlS AS TO TIE EFFECTIVENESS OF TIE PDCIMELL MIDIT #4D SURVEILLANCE PROGRAM ARE Dl#ElRICALLY OPPOSED TO TiOSE REfflED BY IMC." INTERNAL REPORT (lli PREPAPATION) BY PRC us IMC AUDIT OF ROCIMELL,' fi/Roi 25-28,1986
"...THE GESERVED AUDIT (BY PMC ON BEHALF OF DOE /ld.) WAS NOT CAPABLE OF DETECT!?lG WlETHER OR NOT THE PJE/PB MAY BE ABLE TO EtiSURE THAT ITS ENGINEERING PRODUCTS CAN BE DENUf4STRATED TO IIAVE TIE hEOUlkED QUALITY." FROM lEC SitFF EV/1UATION OF i AC AUDIT OF KAISER [lElt4EERS, APRIL 15-17,1986.
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STAFF llAS IIAD LIMITED REVIEW OF PROGRAM - lW4DFUL OF AREAS / ORGANIZATIONS. YET, SIGilFICANT CONCERNS o
litf(I IFIED. AClUAL EX1ENT IS LIKELY PUCH LARGER ST/.ff t.CitWLEDGES ACTIONS TAKEN BY Il0E RECENTLY (GTOP WORK ORDERS), BUT IS CONCFRNED ABOUT TIMING OF O
4 CORRECTIVE ACllGis N1D OVERALL EFFECTIVENESS OF PROGRM1.
o STAFF CONCERNED Ill\\i TitESE SPECIFIC PROBLEMS ARE CAUSED IN PART BY MANAGEfENT ISSUES WillCH IEED EXAM fb/l6/IMI
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Pn.T r>:PERilliCES WITil SIMILAR ARRANGENENTS FFTF - DIRECT CONTROL GIVEll TO ll0 PROGRAM OFFICE IN 1975 FROM FIELD OFFICE AFTER PROBLEMS OCCURRED Foku STUDY - SUCCESSFUL PHOJECTS CREATED SEPARATE DIVISION WITH BOTll AMilNISTRATIVE AND FUNCTIONAL CONTROL. UNSUCCESSFUL UTILITIES SPLIT ADMINISTRATIVE AND FUNCTIONAL RESPONSIBILITIES EPRI STUDY,1983 - HOST UTILITIES EVENTUALLY ADOPTED INDEPENDENT PROJECT FORM OF ORGANIZATION E6/06/0!!
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FOR REACTORS, NRC itAS BEEN FORCED TO DEAL WITH MANAGEENT ISSUES AFTER MAJOR @ PROBLEMS UNCOVERED O
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