Nuclear Waste: Preliminary Observations on the Quality Assurance
Program at the Yucca Mountain Repository (28-MAY-03,
GAO-03-826T).
A quality assurance program is required by the Nuclear Regulatory
Commission (NRC) to ensure that the Department of Energy (DOE)
can safely construct and operate a high-level radioactive waste
repository. DOE is currently preparing an application to NRC for
authorization to construct the repository. The quality assurance
program includes procedures to assure NRC that the information
DOE provides is verifiable and well documented. DOE will use the
results of a computer simulation to demonstrate that the
repository can be safely operated over the 10,000-year period
required by the Environmental Protection Agency's health and
safety standards. This testimony is based on ongoing and
published GAO work. The testimony provides the history of DOE's
actions to correct quality assurance problems, the status of
DOE's efforts to improve the quality assurance program, and
preliminary observations on the effect of quality assurance
problems on DOE's ability to successfully meet its 2004 milestone
for submitting an application to NRC requesting authorization to
construct the repository.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-826T
ACCNO: A07026
TITLE: Nuclear Waste: Preliminary Observations on the Quality
Assurance Program at the Yucca Mountain Repository
DATE: 05/28/2003
SUBJECT: Nuclear waste disposal
Nuclear waste management
Quality assurance
Radioactive wastes
Safety standards
Nuclear facilities
Nuclear facility safety
Nuclear waste storage
Facility construction
Facility management
DOE Yucca Mountain Project
Yucca Mountain (NV)
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GAO-03-826T
Testimony Before the Subcommittee on Energy and Water Development,
Committee on Appropriations, U. S. Senate
United States General Accounting Office
GAO For Release on Delivery Expected at 4: 00 p. m. EDT Wednesday, May 28,
2003 NUCLEAR WASTE
Preliminary Observations on the Quality Assurance Program at the Yucca
Mountain Repository
Statement of Robin M. Nazzaro, Director Natural Resources and Environment
GAO- 03- 826T
DOE*s track record of correcting problems with its quality assurance
program is less than favorable. Recurring problems have persisted in the
program despite DOE*s numerous attempts to correct them. DOE evaluations
and NRC oversight activities have concluded that the program still falls
short of expectations.
DOE*s 2002 quality assurance improvement plan represents the department*s
most recent attempt to correct quality assurance problems, including those
involving the scientific models and software codes in the computer
simulation that DOE will use to demonstrate the safety of the repository.
Because DOE is still in the process of implementing this plan, it is too
early to determine whether changes included in the plan will be effective.
However, notwithstanding these changes, DOE has recently identified
further quality assurance problems, including recurring problems with the
data that will be used to support the NRC*s decision on whether to
authorize DOE to construct the repository.
Based on previously identified weaknesses and recent indications of new
problems, we are concerned that DOE*s current efforts to improve its
quality assurance program may not yield the results it hopes for. Our
observation is further supported by NRC*s recent comment that DOE*s
quality assurance program has yet to produce outcomes necessary to ensure
that this program meets NRC requirements.
Illustration of Yucca Mountain Repository Waste Package Emplacement
Source: DOE. A quality assurance program is required by the Nuclear
Regulatory Commission (NRC) to ensure that the Department of Energy (DOE)
can safely construct and operate a high- level radioactive waste
repository. DOE is currently preparing an application to NRC for
authorization to construct the
repository. The quality assurance program includes procedures to assure
NRC that the information DOE provides is verifiable and well documented.
DOE will use the results of a computer simulation to
demonstrate that the repository can be safely operated over the 10, 000-
year period required by the Environmental Protection Agency*s health and
safety standards. Some of the key elements of this simulation are shown in
the
illustration. This testimony is based on ongoing and published GAO work.
The testimony provides the history of DOE*s actions to correct quality
assurance problems, the status of DOE*s efforts to improve the quality
assurance program, and preliminary observations on the
effect of quality assurance problems on DOE*s ability to successfully meet
its 2004 milestone for submitting an application to NRC requesting
authorization to construct the repository.
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 826T. To view the product, click
on the link above. For more information, contact Robin Nazzaro at (202)
512- 3841 or nazzaror@ gao. gov. Highlights of GAO- 03- 826T, a testimony
before the Subcommittee on Energy and Water Development, Committee on
Appropriations, U. S. Senate
May 28, 2003
NUCLEAR WASTE
Preliminary Observations on the Quality Assurance Program at the Yucca
Mountain Repository
Page 1 GAO- 03- 826T
Senators Ensign and Reid: We are pleased to be here today to discuss the
Department of Energy*s (DOE) quality assurance program for the Yucca
Mountain repository project. As you know, Yucca Mountain is intended to
serve as the nation*s permanent repository for high- level nuclear waste.
DOE is currently in the process of preparing an application to the Nuclear
Regulatory Commission (NRC) for authorization to construct the repository,
which it expects to submit by December 2004. To ensure that DOE can safely
construct and operate the repository, NRC requires DOE to have a quality
assurance program. The quality assurance program is designed to include
procedures to assure NRC that the information submitted to it is
verifiable and well documented. Audits and management reviews are also
built into the program to monitor whether workers follow these procedures.
In cases where they are not followed, DOE must develop and implement
corrective actions and monitor their effectiveness. An ineffective quality
assurance program could potentially impede the application process and
could precipitate potentially adverse health, safety, and environmental
effects.
In this context, you asked us to investigate the effectiveness of DOE*s
efforts to improve its quality assurance program. Although we are still in
the early stages of our investigation, we are prepared today to provide
(1) the history of DOE*s actions to correct quality assurance problems,
(2) the status of DOE*s efforts to improve the quality assurance program,
and (3) preliminary observations on the effect of quality assurance
problems on DOE*s ability to successfully meet its 2004 milestone for
submitting an application to NRC requesting authorization to construct the
repository.
In summary: DOE*s track record of correcting problems with its quality
assurance
program is less than favorable. Recurring problems have persisted in the
program despite DOE*s numerous attempts to correct them. DOE evaluations
and NRC oversight activities have concluded that the program still falls
short of expectations.
DOE*s 2002 quality assurance improvement plan represents the
department*s most recent attempt to correct quality assurance problems,
including those involving scientific models and software codes that DOE
will use to demonstrate the safety of the repository. Because DOE is still
in the process of implementing this plan, it is too early to determine
whether changes included in the plan will be effective. However,
notwithstanding
Page 2 GAO- 03- 826T
these changes, DOE has recently identified further quality assurance
problems, including recurring problems with the data that will be used to
support the NRC*s decision on whether to authorize DOE to construct the
repository.
Based on previously identified weaknesses and recent indications of new
problems, we are concerned that DOE*s current efforts to improve its
quality assurance program may not yield the results it hopes for. Our
observation is further supported by NRC*s recent comment that DOE*s
quality assurance program has yet to produce outcomes necessary to ensure
that this program meets NRC requirements.
The Nuclear Waste Policy Act of 1982 was enacted to establish a
comprehensive policy and program for the safe, permanent disposal of
commercial spent fuel and other high- level radioactive wastes. DOE was
directed in the act to, among other things, investigate potential sites
for locating a repository. Amendments to the Act in 1987 directed DOE to
consider only Yucca Mountain, Nevada, as a potential site for a
repository. In 2002, the Congress approved the President*s recommendation
of Yucca
Mountain as a suitable site for the development of a permanent high- level
waste repository. The next step in the process is for DOE to submit an
application to NRC for an authorization to construct the repository. In
order to ensure that the information submitted to NRC is verifiable and
well documented, NRC requires nuclear facilities to develop a quality
assurance program that includes a process to identify problems, develop
corrective actions, and monitor the effectiveness of these actions. Among
other things, such a quality assurance program is required to (1) train
personnel in quality assurance; (2) inspect activities that affect
quality; (3) establish controls over testing programs and test equipment,
such as
ensuring that this equipment is properly calibrated; (4) establish and
maintain records, including records documenting the qualifications of
personnel performing repository work; and (5) verify compliance with the
rules and procedures of the quality assurance program to determine the
effectiveness of the program. In carrying out its responsibility for the
Yucca Mountain repository to
meet the Environmental Protection Agency*s (EPA) standards for protecting
public health and safety, as well as its standards, NRC provides
consultation and advice to DOE in the project*s pre- application period.
NRC officials are located onsite at the Yucca Mountain project office
where they conduct daily oversight of project activities, including
Background
Page 3 GAO- 03- 826T
observing and commenting on DOE*s quality assurance audits and preparing
bi- monthly reports on the overall status of the program. Additionally,
DOE and NRC hold quarterly quality assurance meetings and conduct
exchanges between staff on technical issues.
DOE*s quality assurance problems at the Yucca Mountain repository site
date back to the late 1980s. In a 1988 report, we identified significant
problems with the quality assurance program, noting that it failed to meet
NRC standards. 1 We found that NRC had identified many specific concerns
from the oversight activities it had performed at Yucca Mountain. For
example, NRC noted that DOE*s heavy reliance on contractors and its
inadequate oversight of quality assurance activities would increase the
likelihood that DOE might encounter quality- related problems.
Furthermore, NRC said that the likelihood that the state of Nevada and
others would contest the licensing proceedings increased the probability
that DOE would have to defend its quality assurance program and the
quality of the work performed. NRC noted that DOE*s inability to properly
defend its work could result in additional expense and time- consuming
delays as program weaknesses are corrected. NRC also found that DOE staff
and contractors exhibited negative attitudes toward the function of
quality assurance, noting that participants appeared to lack a full
appreciation for what it took to get a facility licensed by NRC.
DOE was put on notice of these shortcomings, but the problems continued.
In its 1989 evaluation of DOE*s Site Characterization Plan, NRC concluded
that DOE and its key contractors had yet to develop and implement an
acceptable quality assurance program. In March 1992, based on progress DOE
had made in improving its quality assurance program, NRC allowed DOE to
proceed with its site characterization work, noting
that DOE had demonstrated its ability to evaluate and correct quality
assurance program deficiencies. A year and a half later, however, NRC
raised concerns with DOE about the acceptability of facility design
activities requiring quality assurance. NRC reported that it had no
confidence that DOE*s management plan for resolving quality assurance
issues related to the design activities would work because of DOE*s and
1 U. S. General Accounting Office, Nuclear Waste: Repository Work Should
Not Proceed Until Quality Assurance Is Adequate, GAO/ RCED- 88- 159
(Washington, D. C.: Sept. 29, 1988). History of Actions
Taken to Correct Quality Assurance Problems
Page 4 GAO- 03- 826T
the site contractors* inability to effectively implement corrective
actions in the past.
DOE renewed its efforts to correct problems with its quality assurance
program starting in the late 1990s when its own audits at Yucca Mountain
identified quality assurance problems in three areas: data sources,
validation of scientific models, and software development. First, DOE
could not ensure that all the data needed to support the scientific models
could be tracked back to original sources or that the data had been
properly collected. Second, DOE had no standardized process to develop the
scientific models needed to simulate geological events. Finally, DOE had
no process for ensuring that the software being developed to support the
models would work. In response to the issues raised in the audits, DOE
issued a management plan in 1999 that prescribed remedies. Following
implementation of this plan, DOE considered the issues resolved.
Model validation and software development problems, however, resurfaced in
2001. New quality assurance audits found that project personnel had not
followed the required procedures for model development and validation or
established a timeline for completing the models. In addition, these
audits identified that project personnel had not followed the software
development process, prompting a prohibition on
further software development without prior management approval. According
to DOE, the significance of these new observations was compounded by their
similarity to those problems previously identified. In July 2002, DOE
provided NRC with a revised plan to correct its quality
assurance problems at Yucca Mountain, including the problems with
scientific models and software codes. In constructing the plan, DOE
conducted an in- depth study of Yucca Mountain*s management and work
environment. The plan outlined five key areas needing improvement.
Specifically, it noted the need for
clarifying roles, responsibilities, accountability, and authority for
DOE and contractor personnel,
improving quality assurance processes and clarifying line management*s
quality responsibilities,
improving DOE and contractor written procedures, Status of DOE Efforts
to Improve Quality Assurance
Page 5 GAO- 03- 826T
implementing more effective and consistent corrective action plans to
preclude recurring quality problems, and
improving the work environment where employees can raise program
concerns without fear of reprisal. To fully address issues raised in the
plan, DOE identified a total of 72 actions needed to correct the quality
assurance program* 35 to address the five key areas, 12 to address model
development issues, and 25 to address software development issues. DOE
recently reported that it had completed 41 of the 72 actions. The
management plan also included
performance measures to assess the effectiveness of the actions. DOE
recently reported, however, that the Yucca Mountain project still lacks
complete and useful performance measures and stated its intention to have
the appropriate performance measures in place by September 2003.
Since DOE began to implement its latest improvement plan, new quality
issues have emerged. In March 2003, DOE issued a *stop- work* order
preventing further use of a procedure intended to help improve DOE and
contractor quality assurance procedures. According to DOE, they cancelled
the use of the procedure and reverted back to the existing procedure. In
April 2003, DOE again found data- related problems similar to the data
verification problems identified in 1998. For example, DOE found that,
instead of verifying data back to appropriate sources, project scientists
had been directed to reclassify the unverified data as *assumptions* which
do not require verification.
At the April 2003 quality assurance meeting with NRC, DOE highlighted
several recent improvements to the quality assurance program. These
improvements included (1) management changes with DOE*s primary contractor
at the site, including a new president and a new director of quality
assurance, (2) increased line management involvement in quality assurance,
and (3) the integration of quality engineers with DOE line employees.
Despite this reported progress, an NRC official at the same meeting
commented that the quality assurance program had still not
produced the outcomes necessary to ensure the program is compliant with
NRC requirements.
Whether DOE can correct its quality assurance problems in time to meet its
milestone for submitting an application that is acceptable to NRC is not
clear. DOE*s unsuccessful efforts to address recurring quality assurance
problems, the identification of new problems since the issuance of its
2002 Preliminary
Observations
Page 6 GAO- 03- 826T
improvement plan, and NRC*s recent comment that DOE*s quality assurance
program has yet to produce outcomes necessary to ensure that this program
meets NRC requirements do not instill much confidence that
the quality assurance problems will soon be resolved. An ineffective
quality assurance program could impede the application process, leading to
time- consuming and expensive delays as weaknesses are corrected, or
ultimately prevent DOE from receiving authorization to construct a
repository. Moreover, continued reliance on data that are unverifiable and
thus could be inaccurate could lead to adverse effects in the course of
the 10,000- year period required by EPA*s health and safety standards. At
the same time, now that the project has shifted from scientific
investigation to preparing an application, DOE may now have the proper
motivation and focus to correct recurring quality assurance problems given
the integral role that quality assurance plays in the application process.
As we continue our investigation, we will work to validate our
observations and further assess the effectiveness of DOE*s efforts to
improve its quality assurance program. Thank you, Senators Reid and
Ensign. That concludes my testimony. I
would be pleased to respond to any questions that you may have.
Contacts and Acknowledgments
For further information on this testimony, please contact Ms. Robin
Nazzaro at (202) 512- 3841. Individuals making key contributions to this
testimony included Lee Carroll, Daniel Feehan, Thomas Kingham, Thomas
Laetz, Chalane Lechuga, and Jonathan McMurray.
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