DOE Nuclear Regulatory Framework and Comparisons of Nuclear & Aerospace Quality Requirements

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1 DOE Nuclear Regulatory Framework and Comparisons of Nuclear & Aerospace Quality Requirements NASA Quality Leadership Forum March 20, 2013 Gustave (Bud) Danielson Duli C. Agarwal U.S. Department of Energy

2 Purpose Describe DOE Nuclear Regulatory Framework DOE and SAE Counterfeit Prevention Requirements ASME NQA Committee s Current Projects Discuss Nuclear and Aerospace Quality Assurance 2

U.S Department of Energy Organizational Chart DEPARTMENT OF ENERGY Office of the Secretary Dr. Steven Chu, Secretary Daniel B. Poneman Deputy Secretary Melvin G. Williams Jr.

3 U.S Department of Energy Organizational Chart DEPARTMENT OF ENERGY Office of the Secretary Dr. Steven Chu, Secretary Daniel B. Poneman Deputy Secretary Melvin G. Williams Jr. Associate Deputy Secretary Office of the Under Secretary for Nuclear Security Thomas P.D Agostino Under Secretary for Nuclear Security Health, Safety and Security July

DOE Mission ENERGY Catalyze the timely, material, and efficient

leadership in clean energy technologies.

engineering as a cornerstone of our economic prosperity with clear leadership

NUCLEAR SAFETY AND SECURITY MANAGEMENT AND OPERATIONAL EXCELLENCE Enhance

4 DOE Mission ENERGY Catalyze the timely, material, and efficient transformation of the nation s energy system and secure U.S. leadership in clean energy technologies. SCIENCE & INNOVATION Maintain a vibrant U.S. effort in science and engineering as a cornerstone of our economic prosperity with clear leadership in strategic areas. NUCLEAR SAFETY AND SECURITY MANAGEMENT AND OPERATIONAL EXCELLENCE Enhance nuclear security through defense, nonproliferation, and environmental efforts. Establish an operational and adaptable framework that combines the best wisdom of all Department stakeholders to maximize mission success. 4

5 DOE Quality Assurance Framework 10 CFR Part 830, Nuclear Safety Management (QA & Safety Basis) DOE Order 414.1D, Quality Assurance (Nuclear and nonnuclear Facilities) 10 QA Criteria Suspect/Counterfeit Items (SC/I) Nuclear Safety Software National & International Standards DOE G B, Quality Assurance Program Guide 5

6 DOE S/CI Prevention DOE Order 414.1D, Attachment 3, Suspect/Counterfeit Items Prevention Program, responsibilities, inspection, control Once adopted, civil/criminal/contract penalties for non compliance DOE O 232.2, Occurrence Reporting and Processing of Operations Information International Atomic Energy Agency IAEA-TECDOC-1169 DOE Awareness Training Manual, 2007 DOE Order 221.1A,Reporting Fraud Waste & Abuse to the Office of the Inspector General 6

7 Why is SC/I Prevention Important to DOE? Low-Activity Waste Facility Balance of Facilities Analytical Laboratory High-Level Waste Pretreatment Facility 7

8 Low-Activity Waste Vitrification Facility Mixes low-activity rad-waste in glass 70% Construction Complete Overhead pipe racks for steam and glass formers Low-Activity Waste Facility Exterior Low-Activity Waste transfer tunnel Low-Activity Waste carbon bed adsorber 200-ton Low-Activity Waste melter 8

9 DOE Issues and Challenges DOE has a mature program (2004). S/CI Focus Group formed to avoid complacency and address new S/CI risks, tactics, sources Existing programs may need to adapt Expand focus: mechanical & hardware to electronics New Government wide initiatives Federal Acquisition Regulations changes NDAA 2012/13 Common reporting system Update training New standards and technologies 9

10 Suspect/Counterfeit and Defective Items 10

11 Similarities DOE & SAE AS5553A S/CI Requirements Formal planning, implementation and documentation DOE Quality Assurance Program includes S/CI process AS5553A Fraudulent/Counterfeit EEE Parts Control Plan under an SAE AS9100C Quality Management System. Tailored approach to S/CI prevention DOE graded approach AS5553A risk assessment 11

12 Similarities (Continued) Training Reference outside guidance DOE references an IAEA standard for implementing DOE S/CIs requirements in nuclear industry SAE references various government and industry standards including military (MIL) standards and ANSI standards. 12

13 Comparison Example DOE O 414.1D Attachment 3 2 c - The QAP requires training and informing managers, supervisors, and workers on S/CI processes and controls (including prevention, detection, and disposition of S/CIs). SAE AS5553A Personnel Training Comment Meets Fully. Both DOE O 414.1D and SAE AS5553A require training on S/CI prevention. Recommendation: None. 13

14 DOE & SAE AS5553A Differences DOE requirements not found in the SAE standard: Engineering involvement in procurement specifications, inspection, testing, maintenance, replacement, equipment modification, and safety/non-safety applications. Trending analysis and review of lessons learned to improve S/CI prevention process. Cost-benefit impact to support engineering evaluations of installed items. 14

15 Differences (Continued) DOE Requirements not found in SAE standard: Report occurrences Prime contractors, via an internal system DOE shares certain reports to GIDEP Research information DOE S/CI website references prior to purchase and installation Evaluate storage areas for legacy and/or installed S/CIs Evaluate safety and non-safety applications 15

16 Differences (Continued) SAE requirements not found in DOE Order: Maximize parts availability Authentic, originally designed and/or qualified parts throughout product s life cycle, including management of parts obsolescence. Detailed purchasing process Including procurement specifications, contract and approach. Supply chain history and traceability Documented evidence of EEE parts 16

17 Differences (Continued) SAE requirements not found in DOE Order: Product assurance of purchased and returned EEE parts Material control of scrap or surplus EEE parts or assemblies Detailed implementation appendices for parts availability, purchasing process, supply chain traceability, examples of procurement contract, product assurance, and material control 17

18 Comparison Example DOE O 414.1D Attachment 3 2 f - The QAP requires engineering evaluations to be used in the disposition of identified S/CIs installed in safety applications/systems or in applications that create potential hazards. Evaluations must consider potential risks to the environment, the public and workers along with a cost/benefit impact, and a schedule for replacement (if required). SAE AS5553A No corresponding requirements in SAE AS5553A. Comment No Similar Requirement. SAE AS5553A does not specify the use of engineering to evaluate the disposition of identified S/CIs installed in safety applications/systems as well as conducting cost/benefit impacts and a schedule of replacement. Recommendation: Include DOE requirements on engineering evaluations, cost/benefit analysis, and replacement schedule for previously installed S/CIs. 18

19 ASME NQA Committee ASME Committee on Nuclear Quality Assurance ASME NQA , Quality Assurance Requirements for Nuclear Facility Applications NQA-1 has comparisons with: DOE 10 CFR 830 & Order ISO IAEA GS-R-3 (in collaboration with IAEA) SAE??? 19

20 NQA S/CI Projects The NQA Committee has approved a project to develop requirements for the prevention of suspect, counterfeit and fraudulent Items. Work is in progress Target publication in the 2014 Edition 20

21 Conclusions Potential outcomes from understanding compatibility of nuclear & aerospace requirements. Provide a basis for evaluating a suppliers and contractors S/CI program that is compliant with DOE or SAE requirements Suppliers and Contractors can use as a tool for self assessment Facilitate expansion of supplier base Increase confidence in transferability of supplier S/CI programs Support upcoming FAR changes for S/CI reporting across agencies Groundwork for NQA + SAE collaborative project 21

22 Thank you for your time and attention!! Questions? 22

23 Contact Information Bud Danielson DOE Chief of Nuclear Safety Staff ASME Committee on Nuclear Quality Assurance, Vice Chair Phone: Duli Agarwal DOE Office of Quality Assurance ASME NQA Subcommittee on Applications, Vice Chair Phone:

to improve their business systems and be better prepared for DOD review and approval as will likely be required per NDAA 2012 Section 818(e).

to improve their business systems and be better prepared for DOD review and approval as will likely be required per NDAA 2012 Section 818(e). 46 Contract Management May 2013 Contract Management May 2013 47 C ounterfeit parts avoidance and detection has emerged as an area of business and legal risk that aerospace and defense (A&D) contractors