ML20247C425
| ML20247C425 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1989 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 8905240465 | |
| Download: ML20247C425 (6) | |
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,5 LTR.UMTRA'QA REVIEW /DG 1-l RAY 10 1999
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Mr. Mark L.' Matthews, Acting Project Manager Uranium Mill, Tailings Project Office Albuquerque Operations Office U.S. Department of Energy.
'l P. O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Matthe'ws':
i'e have completed our review of the draft Revision 2 of the Uranium Mill Tailings Remedial Action (UMTRA) Project Quality Assurance Plan (QAP). Once you have had some time to consider the enclosed comments, we recommend that a meeting be set up'to discuss and agree on their resolution.
If you have any questions regarding this review or if you wish to arrange for the recommended meeting, please contact Dan Gillen of my staff at FTS 492 0517.
Sincerely, (SIGNED) PAULH.LOHAUS Paul H. Lohaus, Chief l
Operations Branch Division of Low-level Waste Management and Decommissioning, NMSS
Enclosure:
As stated j
I cc:' C. Cormier, DOE Alb.
Distribution:
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REVIEW 0F UMTRA PROJECT QUALITY ASSURANCE PLAN REV. 2 Basis of Review:
The UMTRA Project Quality Assurance Plan (QAP) was reviewed against the requirements of 10 CFR Part 50, Appendix B and ANSI /ASME NQA-1, as referenced in DOE's QAP. The primary focus of the review was on what is being done to meet the requirements and who has the responsibility.
In cases where DOE is delegating functions to be performed to the contractors, the review focused on a commitment by DOE to retain responsibility for the quality of the delegated work and a statement as to how DOE would determine if the contractor work was acceptable. As discussed at the February 8, 1989 meeting with DOE, the responsibility for the overall program is to be retained and exercised by DOE.
This is the same approach NRC presented and discussed at the earlier meeting.
General Comments:
The revised QAP is very descriptive regarding what is to be done to meet the requirements but is lacking in the assignment of responsibilities to D0E. Our review of Section 1 " Organization" and Section 2 " Quality Assurance Plan" resulted in many questions which are primarily related to a need to clarify the role of DOE. Sections 3 through 18 of the QAP assigns responsibility to the UMTRA-P0, but Sections 1 and 2 did not clearly define the UMTRA-P0 organization and the DOE responsibilities.
It is not clear what DOE is responsible for.
In other cases, responsibility assignments are reflected in Sections 3 through 18 but are not defined in Section 1.
Specific Comments:
1.
Page VIII, Reference Documents The QAP references DOE Order 5700.6A, August 13, 1981, Quality Assurance.
What is the rationale for not referencing the latest DOE Order.
2.
Page VIII, Reference Documents The QAP references ANSI /ASME NQA-1-1979 with 1981 Addendum. Since there is a 1986 version of ANSI /ASME HQA-1, DOE should consider using the current version as the basis for the QAP.
3.
Page 2, Section 1, Organization, Figure 1.1; UMTRA Project QA Interface /Adm.
The function of the Technical Support Group shown on the organization chart needs to be defined.
r I 4.
Page 2, Section 1, Organization, Figure 1.1; UMTRA Project QA' Interface /Adm.
As currently defined on the organization chart, the DOE UMTRA Project Office does not have an interface with the quality assurance organization.
There should be an interface between the:,e organizations, and the QAP should be revised to reflect this.
5.
Page 4, Section 1.2.2; The DOE /AL Assistant Manager for OPEP This section lists two responsibilities for the Assistant Manager for Projects and Energy. Programs on the UMTRA project.
His responsibilities do not include being responsible for the quality of work performed. Who is responsible?
6.
Page 4, Section 1.2.3; The DOE /AL UMTRA Project Manager This section defines the responsibilities for the DOE /AL UMTRI, Project Manager. His responsibilities do not include responsibility for the quality of work being performed. Who is responsible for the quality of work?
7.
Page 5, Section 1.2.5; The DOE /AL UMTRA Project Quality Assurance Manager (QAM)
A.
This section defines the responsibilities of the DOE /AL UMTRA l
Project Quality Assurance Manager. The QAM's responsibilities:
do not include responsibility for approval of the Project (DOE)
Quality Assurance Procedures. Who_is responsible for approval of these procedures?
I B.
This section states the QAM is responsible for reviewing stop l
work recommendations; however, the plan does not clearly state who has the authority to'stop work. This authority needs to be defined.
C.
This section also states the QAM reports directly u the UMTRA Project Manager through the Technical Support Group Leader. However, the plan does not define the responsibilities of the Technical Support Group Leader. The QAP needs to be revised to define the responsibilities of this individual.
l D.
This section states the QAM is responsible for participating i
I in and approving results of QA audits. The QAP does not define f
who in DOE is responsible for establishing and approving audits and surveillance schedules. The plan needs to be revised to address this responsibility.
8.
Page 5, Section 1.3; DOE /AL UMTRA Project Organization Management This section should be revised to reflect the organizational structure and the responsibility assignments of the UMTRA Project Office.
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. 9.
Page 5, Section 1.3.1; 00E/AL In section 1.3.1, it states that DOE UMTRA-P0 carries out its responsibilities by 1) participating in design reviews...; 2) reviewing and aporoving test plans and QA procedures; 3) providing... policy guioance; and 4) reviewing and approving of QAPPs. Who has responsibility for final desigr? Who has responsibility for quality of work performed by contractors? WL1 has responsibility for scheduling and conducting audits and surveillance;? These areas of responsibility need to be defined.
- 10. Page 6, 1.3.2; Project Management This section states Project Management involvement is shown elsewhere in the plan. What specifically is Project Management? This term is not used in the organization charts.
- 11. Page 6, Section 1.4.1; General A.
Section 1.4.1 lists five functions (at a minimum) to be performed by contractors' quality assurance personnel. None of those five functions are listed as responsibilities of the Project QAM. What is the rationale for not assigning these same functions (as a minimum) to the Project QAM?
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B.
In the same paragraph, it is stated that the DOE /UMTRA P0 shall direct and control the UMTRA Project QA Program. Why isn't that responsibility assigned to the DOE UMTRA Project Manager under paragraph 1.2.37
- 12. Page 7, Section 1.4.2; TAC Organization A.
This section refers to organization activities. What are the organization activities referred to in this paragraph?
l B.
Section 1.4.2 describes the TAC QA function as having organizational i
autonomy (reports to JEG Corporate QA Director). Since the QAP does j
not describe the function of the Technical Support Group, it is not clear how the TAC QA organization relates to DOE's responsibility for establishing and implementing a quality assurance program.
Is the TAC QA organization an integral part of the DOE organization? Does i
I TAC QA use DOE written and approved procedures or have their own?
Does TAC QA take daily direction from DOE or does it establish its I
own plans and actions based on a contracted statement of work?
i C.
In Section 1.4.2, what is meant by " Program organization responsibilities?"
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. D.
Who is the Program Manager referred to in Section 1.4.2? Is the Technical Assistance Contractor the Program Manager? It is stated that all site, department and task leaders report to the Program Manager. Does this include the TAC QA Manager?
E.
The TAC QAD Manager interfaces with the UMTRA-P0 QAM, TSGL and the TAC Program Manager but reports to the JEG Corporate QA Director. It appears an independent QA organization is established to oversee all i
site work and does not take direction from DOE. Who is responsible for establishing, implementing and maintaining the QA program? DOE appears to have no responsibility for establishing the QA audit program, initiating corrective action or conducting assessments to evaluate the effectiveness of the QA Program.
- 13. Page 15, Section 2.2.2; Quality Assurance Program Description Section 2.2.2 states that the QA Program for the UMTRA Project is approved by the Technical Support Group. Why doesn't the UMTRA Project Manager approve the QA Program?
- 14. Page 16, Section 2.2.5; Delegated Work This section states that portions of the UMTRA QA Program have been delegated to contractors. What part has been delegated?
- 15. Page 20, Section 3.0; Design Control The responsibility for Design Control is not specified. This section states DOE reviews documentation. What is DOE's role in the design? Is the design or any part of the design responsibility delegated? If so, what part and to whom?
- 16. Page 21, Section 3.2.2; Presenting Data In the last sentence of this section, the words "will be" should be changed to "are."
- 17. Page 24, Section 4.3; Procurement Document Review This section states that contractors on behalf of DOE prepare, approve, issue and control purchases. This section should also define DOE's role in this process.
- 18. Page 27, Section 6.0; Document Control Section 6.0 is very descriptive as to what is done to control documents; however, DOE responsibility for document control is not defined for the UMTRA-PO.
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.- 19. Page 34, Section 10.1; General Section 10.1 makes the statement "The UtiTRA Project is essentially an earth moving, stabilization and monitoring project that does not result in a product." The staff does not agree that there is no product. The product is the results of completing the earth moving and stabilization as per approved drawings or plans. The product of monitoring is data or conclusions from analysis of the data.
- 20. Page 40, Section 16.0; Corrective Action A.
Section 16.0 does not address significant conditions adverse to quality as defined in ANSI /ASME NQA-1. This section should be revised to incorporate this requirement.
B.
Define the role of DOE for DOE-identified conditions adverse to quality.
21.- Page 41, Section 17.0; Quality Assurance Records This section needs to define who in 00E approves the Quality Records Program for UMTRA.