Audit Report: DOE-OIG-17-07

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September 14. 2017

Quality Assurance Management at the Waste Isolation Pilot Plant

The Department’s Waste Isolation Pilot Plant (WIPP) in southeastern New Mexico is the nation’s only geologic repository for the disposal of radioactive waste materials generated by atomic energy defense activities.  WIPP is managed and operated by Nuclear Waste Partnership, LLC with oversight by the Department’s Carlsbad Field Office.  Its mission is to protect human health and the environment through safe management and disposal of certain transuranic wastes.  WIPP is categorized as a Hazard Category 2 Nonreactor Nuclear Facility because it has the potential for significant radiological consequences.  To provide protection against such consequences, WIPP utilizes Safety Class/Safety Significant systems and components in its infrastructure and equipment.  These items are designed to provide protection against radioactive exposure to the public and safety to the worker.

WIPP’s management and operating contract requires compliance with the Department Order 414.1D Quality Assurance, and that WIPP develop and conduct work in accordance with a Department approved quality assurance plan.  In addition, WIPP’s contract requires the implementation and maintenance of a quality assurance program in accordance with the provisions of 40 Code of Federal Regulations Part 194.  The Carlsbad Field Office provides oversight to ensure proper implementation of quality assurance at WIPP.  Due to the importance of protecting the public, workers, and environment, we initiated this audit to determine whether WIPP effectively managed quality assurance requirements.

Our review found that WIPP had not always effectively managed quality assurance requirements.  Specifically, we found that WIPP did not always effectively:

• Perform commercial grade dedications  of items relied on for safety.  We found instances where WIPP did not effectively perform technical evaluations and/or the acceptance process, which are both key parts of an effective commercial grade dedication.

• Evaluate suppliers’ abilities to meet quality assurance requirements prior to and after contract award.  One of WIPP’s methods for evaluating suppliers prior to contract award did not effectively evaluate a supplier’s ability to meet quality assurance requirements. 

• Identify the appropriate quality assurance requirements in contract documents.  We found instances where WIPP did not specifically state in procurement documents the quality assurance program or standard that the supplier should adhere to.

• Maintain adequate document control of quality assurance documents.  We found instances where WIPP did not include document revision numbers, dates, and titles in its procurement documents to ensure the appropriate documents were utilized.

We concluded that these weaknesses were attributable to limited oversight by the Carlsbad Field Office.  In particular, although the Carlsbad Field Office provided oversight of quality assurance activities through audits and surveillances, we determined that, since May 2013, its oversight was limited and did not identify these weaknesses until after we brought the issues to the attention of the Carlsbad Field Office.

Ineffective implementation of quality assurance requirements limits WIPP’s ability to provide reasonable assurance of safe future operations.  Furthermore, problems associated with poor quality assurance can result in increased costs and future operational delays.  Given WIPP’s integral role in the Department’s cleanup mission, it is imperative that quality assurance requirements are met in order to help eliminate future delays and additional costs to taxpayers.

Although the Department and WIPP have taken positive steps to address some of the weaknesses identified, we believe that additional steps are needed to ensure that quality assurance requirements are met for all future operations at WIPP.  Accordingly, we made recommendations to ensure effective quality assurance performance at WIPP.  Management concurred with our recommendations and has initiated corrective actions.

Topic: Management & Administration