Development and Implementation of DOE QA Requirements for NDA Measurement Programs

As part of the K-25 D&D project, NDA characterization data was generated to support the safe and compliant disposition of gaseous diffusion equipment that had residual uranium deposits (fissile material). The NDA data was generated by the NDA measurement program that had been developed to support safeguards and security programs, and was being used to implement nuclear criticality safety requirements and meet waste disposal criteria. The quality of the data was suspect due to a less than adequate application of quality assurance principles within the NDA measurement programs. Contributing to this is the fact that DOE directives do not invoke standards or quality assurance requirements that are applicable to NDA measurement programs. Corrective actions for the K-25 project included several efforts to validate the NDA measurement methods. The development and implementation of the corrective actions consumed more resources and time than expected and resulted in significant cost increases and schedule delays. PPPO has taken several actions to address the lessons learned at K-25. One of the actions taken to preclude a similar data quality issue on the Portsmouth D&D project, was the development of quality requirements that are to be used when evaluating NDA measurement programs supporting the Portsmouth D&D project. Rather than build a new assessment process, PPPO coordinated its efforts with the DOE Consolidated Audit Program (DOECAP). The DOECAP program is a mature and effective DOE program used across the complex to evaluate the quality assurance practices within the analytical laboratory processes. The quality requirements for NDA developed by PPPO mirror the quality requirements for analytical processes. In particular, the quality requirements include evaluation of NDA measurement programs ability to: perform energy and efficiency calibrations of equipment, generate reproducible data, train and recertify staff, verify modeling procedures, manage records, define limits of detection, and establish deterministic processes for establishing uncertainty. As a result, PPPO has provided a means of evaluating NDA measurement programs and to confirm that they are capable of generating data of known quality. This effort is also being coordinated with the DOE implementation plan associated with the Defense Nuclear Facility Safety Board (DNFSB) recommendation 2007-1.