May 8, 2019

Department of Energy’s Quality Assurance: Commercial Grade Dedication of Items Relied on for Safety

The Department of Energy is responsible for the construction and operation of nuclear facilities across its complex.  To ensure these facilities operate safely, the Department and many of its contractors are required to develop and implement a quality assurance program in accordance with the American Society of Mechanical Engineers’ Quality Assurance Requirements for Nuclear Facility Applications (NQA-1).  However, the Department and its contractors had experienced difficulty finding suppliers that were NQA-1 qualified, which required the Department to increasingly depend on a process known as “commercial grade dedication” (CGD).  CGD is a procurement process performed in accordance with NQA-1, which provides reasonable assurance that a commercial item or service will perform its intended safety function and is equivalent to an item or service provided under a NQA-1 quality assurance program.

In 2009 and in 2015, the Department’s Office of River Protection reported significant issues with the implementation of CGD by Bechtel National, Inc., the contractor responsible for the construction and commissioning of the Waste Treatment and Immobilization Plant (WTP) project, and Parsons Government Services, Inc., the contractor responsible for the construction and commissioning of the Salt Waste Processing Facility (SWPF) project.  Since both WTP and SWPF are nuclear facilities, the Department required its contractors to apply NQA-1 during construction.  Due to the importance of nuclear safety, we initiated this audit to determine if the implementation of CGD of commercial items and services at the Department’s WTP and SWPF projects was effective.

Our review identified weaknesses in the implementation of CGD procurements at the Department’s WTP and SWPF projects.  Specifically, our review identified weaknesses in the dedication acceptance process performed in accordance with NQA-1 and the Department’s guidance.  We concluded that the issues identified with implementation of CGD at WTP and SWPF were the result of weaknesses in Department oversight to ensure the contractors followed NQA-1 standards.  In particular, the Department did not ensure consistent oversight across its complex.  Additionally, we identified that the contractors did not effectively implement contractor quality assurance programs.  While our findings are specific to the WTP and the SWPF, insufficient oversight may be a problem at other Department sites.  

Weaknesses in the Department’s CGD program limit its ability to provide reasonable assurance that items and services meet the requirements for safe operation.  Therefore, an ineffective CGD program can impact the safety of the facility, the worker, and the public, as well as result in additional costs to resolve issues or concerns.  Although the Department has taken positive steps to address some of the weaknesses identified, we believe that additional steps are needed to ensure that CGD and quality assurance requirements are met for all future Department operations.  Accordingly, we made four recommendations to ensure effective CGD across the Department’s complex.

Topic: Environmental Cleanup