Nuclear Waste
Preliminary Observations on the Quality Assurance Program at the Yucca Mountain Repository Gao ID: GAO-03-826T May 28, 2003A 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.
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.
GAO-03-826T, Nuclear Waste: Preliminary Observations on the Quality Assurance Program at the Yucca Mountain Repository
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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:
GAO Highlights:
Highlights of GAO-03-826T, a testimony before the Subcommittee on
Energy and Water Development, Committee on Appropriations, U.S.
Senate
Why GAO Did This Study:
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 a 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.
What GAO Found:
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.
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.
[End of section]
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 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.
Background:
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 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.
History of Actions Taken to Correct Quality Assurance Problems:
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.[Footnote 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
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.
Status of DOE Efforts to Improve Quality Assurance:
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,
* 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.
Preliminary Observations:
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 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.
FOOTNOTES
[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).
