ML20237B926
| ML20237B926 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1987 |
| From: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kay C ENERGY, DEPT. OF |
| References | |
| REF-WM-1 NUDOCS 8712170242 | |
| Download: ML20237B926 (4) | |
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- JKENNEDY/KAY/VG 10 '9 NOV 2 7 W 1
'1 Mr.-Charles E. Kay, Acting Director Office of Civilian Radioactive Waste Management
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Dear Mr. Kay:
IEEtVC tD M, 023-E5) j On July 14, 1987, your office issued Director's Statementn entitled " Managing
'for Quality" and " Quality Assurance" which give policy guidance to your line managers on these two important. topics. The Director's Statements apply'to the repository, storage and transportation programs, and their support functions.
The Managing for Quality Statement prescribes that line managers perform.
c certain actions at least annually to evaluate the effectiveness and adequacy of their programs. The Statement on Quality Assurance (QA) defines the purpose of
.QA and establishes a three 1cvel system for applying quality assurance measures. The highest level, Quality. Level 1 (QL1), is for activities that are important to radiological health and safety and waste isolation (i.e.
"Q-listed". activities).
The. requirements imposed by DOE are NRC regulations, NRC review plans, generic technical positions, and other staff guidance.
Quality Level'2 (QL2) is for assignment to those " activities that'are related' to radiological safety and waste isolation," but which are not Q-listed.. QL2 also includes activities "which have a strong potential for being added to the
.Q-List and whose failure or degradation could. adversely' affect the performance of structures, systems, and components important to safety or waste isolation."
The requirements which apply to QL2 are internal DOE requirements which are not aus comprehensive as those of QL1. Quality Level 3 (QL3) is for assignment to CCRWM activities selectively chosen because of special programmatic importance other than radiological safety and waste isolation. Greater than normal controls are to be applied.
We are pleased to note that managing for quality and quality assurance are receiving attention by top management in the OCRUM program. The NRC's Ford Study.(" Improving Quality and the Assurance of Quality in the Design and Construction of Nuclear Power Plants", NUREG-1055, May 1984) found that top management attention and commitment are essential for achieving and assuring quality results in a program. The Ford Study also found that QA programs cannot be used as a substitute for management's responsibility in achieving and assuring quality. The Director's Statements incorporate both of these findings. However, our review of the Director's Statements has identified several concerns. The purpose of this letter is to bring these concerns to your attention for appropriate action in your continuing effort to achieve an effective QA program.
After reviewing these documents, we are concerned with certain features of the L
'QL2 designation. First, QL2 activities which have a " strong potential" for being added to.the Q-List will have lesser QA measures applied than QL1 and therefore will be difficult or impossible to upgrade to QL1 at a later date.
The definition strongly implies that some of these activities will become QL1 8712170242 871127 PDR WASTE WM-1 PDR
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l later in the program.
In addition to the lesser QA measures, it is not clear if the design requirements in 10 CFR Part 60, Sections 60.130-60,135, for QL1 items will be applied to QL2 items. Thus, it appears that upgrading QL2 items at a later date may also require DOE to backfit not only QA measures, but design measures as well. A niunber of plants in the power rear: tor program faced similar upgrading and either cancelled their projects due to the difficulty of upgrading, or incurred long delays and large cost increases attempting to upgrade the QA and design measures.
It is also unclear in the Statement if QL2 items will be included in the relicensing consultation program with the NRC.
I suggest that items and activities with the potential for being added to the Q-List be included in QL1 and that the Statement be revised.
Our second concern is with the inclusion within QL2 activities "whose failure or degradation could adversely affect the performance of structures, systems, and components important to safety or waste isolation." It is appropriate for certain activitiec which could affect the performance of Q-listed items to not be QL1 if, for example, it can be shown that they do not affect the safety functions of Q-listed items at the time they are needed to prevent or mitigate accidents. As worded, however, the definition of QL2 may also include activities which could affect needed safety functions. The interpretation of this phrase needs additional explanation so there will be confidence that all necessary activities affecting the radiological health and safety of the public receive appropriate QA measures. We suggest that our ongoing discussions on the staff's Q-List Generic Technical Position (GTP) and the DOE implementation of the GTP in its program documents be one appropriate way of resolving our concerns.
If you or your staff have any questions on these items, please contact R.E. Browning (301-427-4069) or D. J. Youngblood (301-427-4177).
Sincerely, (Signed) Robert E Bemp i
fIughL. Thompson,Jr., Director p Office of Nuclear !!aterial Safety and Safeguards y
cct J. Knight, DOE S. Kale, DOE K. Klein, DOE i
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- ii JKENNEDY/KAY/VG 10/8..
OFFICIAL CONCURRENCE AND DISTRIBUTION RECORD LETTER FOR:
Mr. Charles E. Kay, Acting Director Office of Civilian' Radioactive Waste Management U.S. Department'of Energy Mail Stop RW-1 Washington, DC 20585 FROM:
Hugh L. Thompson,' Jr., Director NMSS SUBJECT.:
DOE'S JULY 13, 1987 DIRECTOR'S STATEMENTS ENTITLED " MANAGING ~
FOR QUALITY" AND QUALITY ASSURANCE" DOCUMENTING DOE'S POSITIONS ON ACHIEVING'AND ASSURING QUALITY IN ALL PHASES OF THE OCRWM PROGRAM II E DATE:
DISTRIBUTION WM87368
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