Yucca Mountain QA 101

by Kristi Hodges

August 01, 2005

When it comes to what quality assurance (QA) is and/or isn't, the experts are the last ones consulted. So it's been left to well-meaning laymen to interpret the subtleties of a seemingly complex profession - it's no surprise that most get it wrong. To read that Yucca's QA organization has failed to improve quality is like screeching fingernails across a chalk board to those in the QA profession. Someone needs to give QA 101 training; someone needs to set the record straight. Considering the silence of the current leaders of my profession, I'll give it my best shot - it's certainly not rocket science.

When a building fails an inspection, it's because a building code violation has occurred. It's not a building code problem, as the building code is not the problem. The problem is that someone failed to perform work to requirements of the city building code. Therefore, work must be redone in order for the building to pass inspection.

Likewise, when a work activity fails a QA audit, it's because one or more QA requirements were violated. It's not a QA problem, as QA is not the problem. The problem is that someone failed to perform work to the requirements established in the QA Program. Therefore, work must be corrected in order to close the deficiency documents and pass the next audit.

In early 2001, when significant QA deficiencies recurred, new terminology slipped into the Yucca Mountain dialogue. For dubious reasons, violations of QA requirements were restated as QA problems. Although resisted by the QA organization, the mere repetition of the fallacy created a perception that couldn't be shaken. It wasn't long before failures in QA implementation were being attributed to the QA organization. And not long after that the DOE QA Director was removed, which is another story altogether.

To attribute QA violations to the QA organization would be the same as attributing building code violations to building inspectors. We've all heard of shooting the messenger, but rarely has the messenger been blamed for the shooting.

Welcome to our world.

Upon the news that Yucca Mountain had QA problems, those on the Yucca reporting beat took the "QA is the problem" bait and ran with it. With the heat placed on the QA overseers, QA circumventors appeared to be home free. But soon the project became embroiled in controversy over QA whistleblowers - every problem became a QA problem, every report a QA document, and every worker a QA worker. "It's the QA stupid!"

So what did DOE do?

To fix the alleged QA problems, a new QA Director was appointed to "get QA out of the spotlight." Subsequent changes to reduce the QA organization's oversight role were referred to as "QA improvements." But three years down the road and another QA Director has tried and failed to fix QA.

As Bill Belke, the former NRC on-site representative, once said in regard to the QA organization, "Why fix what's not broken?" That since has been updated to there's no fixing what's been broken.

But if the experts had been consulted, they would have explained that QA auditors, like inspectors, don't do the work; they make sure work is done correctly. And QA Directors don't direct the work; they direct the oversight of the work. One can change the composition and leadership of the QA organization, and identify deficiencies all day long, but only those responsible for doing the work can improve the quality of the work. This simple concept has somehow eluded comprehension of even the best of reporters (and DOE managers).

But I digress.

The QA 101 student must first learn the basics:

-   There are workers and overseers of work;
-   Scientists and engineers are workers;
-   QA auditors are overseers;
-   Workers implement QA requirements;
-   QA auditors assess implementation of QA requirements;
-   Workers prepare technical reports; and
-   QA auditors prepare audit reports.

To get right what most get wrong, next learn the lingo:

Quality Assurance vs. Quality Control (QC):

Although often used interchangeably, there are differences between QA and QC. QA aims to assure that quality is built into work; QC aims to confirm that quality was built into work. QA has auditors; QC has inspectors. QA auditors evaluate implementation and effectiveness of processes used to complete work; QC inspectors evaluate completed work for conformance to specifications & drawings. Hint: The QA Director at Yucca Mountain is not a QC Manager.

QA Organization vs. QA Implementation:

Like all organizations, QA organizations have problems, but QA problems are not necessarily QA organization problems. Most QA problems are in implementation of QA requirements. Therefore, it's important, when writing an article or speaking as a member of Congress, to articulate whether the perceived problem is with the QA organization or those responsible for quality, which would be the workers and their management.

QA Document vs. Technical Document:

QA organizations prepare lots of documents, e.g., audit reports, deficiency documents, procedures, and requirement interpretations. However, QA organizations don't produce technical documents; those are prepared by scientists and engineers. Note that the infiltration studies at the center of the USGS e-mail kerfuffle were not conducted by QA workers. Also note that QA workers conducted an audit in January 2000, which is why most of the substantive issues related to the USGS e-mails were previously identified and corrected. Hint: There still is "no technical smoking gun." Sorry Jon.

QA Independence vs. Organizational Conflict of Interest:

Beware of those that tout their independence, as they are only as independent as the ones signing their paychecks. For instance, most "independent" investigators are hired by those with an agenda; therefore, most "independent" investigation reports are written before the investigation has started - the only independence being from reality as they think we're actually buying their baloney.

But QA auditors are required to be independent. In other words, they can have no personal involvement in producing the work subject to audit - that would be a conflict of interest. However, there are conflicts of interest and there are organizational conflicts of interest (OCI). One can be independent of the work and still violate federal OCI regulations, which preclude personnel, including QA auditors, from overseeing their company's work on behalf of the government. Hint: DOE cannot take credit for its prime contractor, BSC's, internal QA audits. What were they thinking?

QA Auditor vs. QA Whistleblower:

When auditors identify deficiencies they are not whistleblowing; they are doing their jobs. When auditors are retaliated against and removed from their positions for identifying deficiencies there is a good chance that they will become whistleblowers. There are plenty of faux whistleblowers with slick attorneys extorting money from vulnerable nuclear projects, but there are also legitimate whistleblowers that never in a million years wanted to be in their situations. Note: Bogus whistleblowers have been hitting Las Vegas jackpots off Yucca Mountain at the expense of the American taxpayer - details to come.