ML20246D505
| ML20246D505 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/1989 |
| From: | Pittiglio C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Fliegel M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-39 NUDOCS 8908280138 | |
| Download: ML20246D505 (5) | |
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~LP/UMTRA'QA' j
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j Distribution: Central:Fils1W39 NMSS r/f LLRB r/f LPittiglio DMartin M8 ell Ptohaus JSurmeier JGreeves RBangart PDR Yes
/T7 No
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Proprietary or CF Only /
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ACNW Yes /X /
No
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' SUBJECT ABSTRACTi REVIEW 0F URTRA-DOE /AL 185, REVISION 2 UMTRA PROJECT QA PLAN MEMORANDUM FOR: Dr. Nyron H. Fliegel, Section Leader j
Operations Branch Division of Low-Level Waste Management AUG 2 31989 and Decommissioning, NMSS FROM:
Clayton L. Pittiglio, Jr., Project Manager Regulatory Branch Division of Low-Level Waste Management' i
and Decommissioning, NMSS i
SUBJECT:
REVIEW 0F UMTRA. DOE /AL 185, REVISION 2, UMTRA PROJECT QUALITY ASSURANCE PLAN We have completed our review and attached our comments on the UMTRA Project Quality Assurance Plan (QAP), July 1989. The attached comments include comments provided by Dale Hedges.
In addition to' forwarding these questions and comments on this revision of DOE QAP, attached, I also recommend that we request DOE to provide copies of their referenced implementing procedures and provide copies of the table of contents from their contractor's procedures manuals.
In addition, I recommend that you notify DOE that Dale Hedges and I would like to accompany DOE and its' contractors on selected audits to measure the effectiveness of their audits ar,d to assess the overall effectiveness of the DOE Project QA program.
I would like to point out that the intent of our previous review was to provide general direction and comments and to meet with DOE to discuss these comments..Since DOE elected not to meet with us to discuss the comments, the current review not only reflects comments which were not adequately addressed previously, it provides additional comments which were to be discussed at our meeting with DOE.
If you have any questions, please contact me on extension 2 3438.
Original signed by Clayton L. Pittiglio, Jr., Project Manager s90828013e 89082 Regulatory Branch PDR WASTE Division of Low-Level Waste Management M-39 PDC and Decommissioning, NMSS
Enclosure:
As stated cc: DGillen, HMSS OFC :LLR
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i COMMENTS ON UMTRA-DOE /AL 185, REVISION 2 I
UMTRA PROJECT QUALITY ASSURANCE PLAN Basis for Review L"
The UMTRA Project Quality Assurance Plan was reviewed against 10 CFR 50 Appendix B and ANSI /ASME.NQA-1.
General Comments 1.
The UMTRA QA Plan continues to attempt to describe only the responsibilities of organizations in relation to assuring activities.
This was the principal comment addressed in the previous comment package as well as at several prior meetings. An effective quality assurance program can only be described by including the responsibilities for both the acnieving and assuring functions necessary to ensure that project objectives are met.
It is recognized that DOE is delegating part of the functions for which-they are responsible and it appears that they are also using support contractors as an extension of their own staff. These are acceptable practices but the delegations and management controls exercised by DOE must be clearly described in the-UMTRA QA Plan. The plan submitted by DOE for NRC review is incomplete, inconsistent, and inadequate to permit the reviewer to determine if DOE has adequately planned and is effectively managing the Uranium Mill Tailings Remedial Action Project. Detailed comments substantiating this conclusion are listed below.
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2.
In summary, Section 1, " Organization" does not describe the organizational structure of DOE as it relates to the tasks to be performed by DOE to accomplish the Project's objectives.
What is to be performed by DOE organizational elements and what is to be delegated is not described. The TAC and RAC organizations are partially described but the re?ationship to DOE is not clear. The TAC and RAC will have their own QA Prugram Plans and Procedures which are approved by the DOE Project Manager, The QA Plan needs to clarify the relationship between DOE Project Office QA and TAC and RAC QA.
3.
The DOE response to NRC's questions, May 19, 1989, about the DOE QA Plan did not adequately address questions 6, 7c, 9,12b and 14.
Detailed Comments 1
- 1.
Page 6, Subsection 1.3.1; DOE /AL This section states that the DOE /UMTRA-P0 discharges its QA responsibilities with the assistance and advice of the TAC, by such activities as the following:
a.
Participation in design reviews and QA audits.
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.. Reviewing.and approving of test plans and QA procedures.
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Providing QA surveillance.and policy guidance.
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- d.. - Reviewing and approving'of QAPPs. prepared by organizations.
M, (participating in the Project.
M In 1.3.la above it is stated that the DOE /UMTRA-PO participates in' design
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. reviews., In 1.3.2 it is stated that the DOE /UMTRA.- Project Manager.
approves' design cisteria, conceptual design,.and final-design.- It:is suggested that the responsibilities for achieving and assuring..the L
quality of the remedial action task activities be clearly stated in Section:1.0 Organization. Those same respruibilities should be consistently. threaded through the rest of the QA plan.
In 1.3.lc above it is stated that the DOE /UMTRA-P0 approves test plans
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and.QA procedures. Who or what aart of:the Project office approves plans-and procedures? Who generates t1e plans and procedures to be approved - DOE
.and/or contractors? In 1.3.1c above it is stated that the DOE /UMTRA-P0
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provides~QA surveillance and policy guidance.. This statement does not idescribe the control that must be exercised by the Project Office and' further is inconsistent with statements later in the document which
~ indicate the Project Office' controls' audits of contractors, 2.
Page 6, Subsection 1.3.2; UMTRA Project Manager.
The responsibilities of the DOE Project Manager and his staff are not described. Subsection 1.3.2, states only that the Project Manager administers the Project and is assisted by Project Engineers.
3.
Page 5, Subsection 1.2.6; The DOE /AL Project Quality Assurance Manager In subsection 1.2.6,.it'is stated that the Project Quality Assurance Manager supervises and directs the QA activities of the TAC and RAC.- In subsection 1.4.3, it is stated that the RAC. Quality manager has authority to stop work. Since the Project QAM does not have authority to stop work and directs the RAC Quality Manager, how does the subordinate gain this authority? How does this authority to stop work vested in the RAC Quality manager relate to the statement in subsection 1.8, that states the overall authority to stop work on
'all levels of the UMTRA Project rests solely with the DOE Contracting
' Officer?
4.
Page 17, Section 2.0; Quality Assurance Program.
Much of Section 2, Quality Assurance Program is written as a restatement of requirements rather than stating what is being done by what part of the DOE Project Organization.
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i Comments UMTRA-DOE /AL... l An example, 2.2.9,. states organizational managers will periodically assess the effectiveness of those portions of the QA program for which they are responsible. The term " organizational manager" is not used in Section 1, to describe the DOE organization nor has the DOE organization been broken down to include manager titles.
S'.
Page 24, Section 3.2.5; Readiness Review for Design Activities Readiness reviews are discussed in 3.2.5, with no indication of what the participation is by the DOE Project Office. The same is true for 3.2.6, Design Verification and 3.2.7, Design Charge Control.
6.
Page 25, Section 3.2.8, Design Error and Design Deficiency Control It is stated in 3.2.8, that errors and deficiencies in approved design documents generated by the DOE /UMTRA Project Office and design information used by the DOE /UMTRA Project Office will be controlled and resolved in accordance with Section 16. Section 16, Corrective Action, states that provisions for reporting conditions adverse to quality are addressed in project' contractor QAPPs. How are Project Office generated deficiencies resolved by contractors?
What is the responsibility of the Project Office for deficiencies generated within DOE 7 7.
Page 26,. Section 4.0; Procurement Document Control.
It is not clear whether DOE will procure materials and services from
-the information provided in Section 4, Procurement Document Control.
DOE responsibilities for contractor procurement are also not addressed.
8.
Page 28, Section 5.0; Instructions, Procedures and Drawing DOE /UMTRA Project Office responsibilities are not defined for the preparation and approval of Project Office procedures. A listing of DOE procedures needs to be provided to further assess the effectiveness of the DOE management systems.
i 9.
Page 29, Section 6.0; Document Control l
DOE /UMTRA Project Office responsibilities are not specified for Project office controlled documents.
- 10. Page 31, Section 7; Control of Purchases Materials, Equipment and Services I
This is adequate providing DOE-AL or DOE /UMTRA Project Office does not purchase any materials or services and does not enter into the contractors process for procurement in any way.
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Comments UMTRA-DOE /AL... '11.
Page 34,. Section 8; Identification and Control of Materials, Parts, and Components I
This section is adequate.
12.
Page 35, Section 9; Control of Special Processes This'section is adequate.
13.
Page 36, Section 10; Inspection This section is adequate.
14.
Page 37,.Section 11; Test Control This section is adequate.
15.
Page 38,. Section 12; Control of Measuring and Test Equipment This section is' adequate.
16.
Page 39, Section 13;' Handling, Storage, and Shipping This section is adequate.
17.
Page 40, Section 14; Inspection, Test, and Operating Status This section is adequate.
- 18. Page 41, Section 15; Control of Nonconforming Items This section is adequate.
19.
Page 42, Section 16; Corrective Action DOE /UMTRA Project Office organization responsibilities are not defined for corrective actions for which the Project Office is responsible.
- 20. Page 43, Section 17; Quality Assurance Records DOE /UMTRA Project Office responsibilities are not defined for retention and retrieval of records produced by the Project office.
- 21. Page 45, Section 18; Audits This section is adequate.
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