September 23, 2002

Mr. Ronald A. Milner, Chief Operating Officer

Office of Civilian Radioactive Waste Management

U. S. Department of Energy

1000 Independence Avenue, SW

Washington, DC 20585

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION’S OBSERVATION AUDIT

REPORT NO. OAR–02–10, “OBSERVATION AUDIT OF THE OFFICE OF

CIVILIAN RADIOACTIVE WASTE MANAGEMENT, OFFICE OF QUALITY

ASSURANCE, AUDIT NO. BSC–ARC–02–15”

Dear Mr. Milner:

I am transmitting the U.S. Nuclear Regulatory Commission’s (NRC’s) Observation Audit Report

No. OAR–02–10. It is of the U.S. Department of Energy’s (DOE’s), Office of Civilian

Radioactive Waste Management (OCRWM), Office of Quality Assurance (OQA) audit of

Bechtel SAIC Company, LLC (BSC), conducted on July 29–August 2, 2002.

The OQA audit team (hereafter, audit team) performed a limited-scope compliance-based

quality assurance (QA) audit to evaluate BSC’s implementation of the applicable provisions of

the OCRWM Quality Assurance Requirements and Description document, DOE/RW–0333P,

Revision 11, and associated implementing procedures relevant to BSC activities supporting the

Yucca Mountain Site Characterization Project Office. The audit focused on design, but other

programmatic elements were also reviewed. 

The NRC observers (hereafter, observers) determined that DOE’s audit of BSC was effective in

identifying potential deficiencies and recommending improvements for the reviewed BSC

activities. During the audit, both the audit team and the observers independently reviewed

applicable BSC documents, QA procedures, and activities within the audit’s scope.

Although the audit team identified potential deficiencies, and made a quality observation and

recommendations, the observers believe that BSC has effectively implemented these areas of

its QA program with the exception of the deficiencies identified in this report. The observers

agreed with the audit team’s conclusions, findings, and recommendations presented at the

audit exit meeting.
R. Milner -2-

The staff will continue to interface with OCRWM and follow the progress that BSC is making to

address the issues identified during this audit. A written response to this letter and the

enclosed report is not required. If you have any questions, please contact Ted Carter of my

staff at (301) 415-6684.

Sincerely,

/RA/

Janet Schlueter, Chief

High-Level Waste Branch

Division of Waste Management

Office of Nuclear Material Safety

 and Safeguards

Enclosure: NRC Observation Audit Report

No. OAR–02–10, “Observation Audit of the

Office of Civilian Radioactive Waste Management,

Office of Quality Assurance, Audit No. BSC–ARC–02–15"

cc: See attached list.
R. Milner -2-

The staff will continue to interface with OCRWM and follow the progress that BSC is making to

address the issues identified during this audit. A written response to this letter and the

enclosed report is not required. If you have any questions, please contact Ted Carter of my

staff at (301) 415-6684.

Sincerely,

/RA/

Janet Schlueter, Chief

High-Level Waste Branch

Division of Waste Management

Office of Nuclear Material Safety

 and Safeguards

Enclosure: NRC Observation Audit Report

No. OAR–02–10, “Observation Audit of the

Office of Civilian Radioactive Waste Management,

Office of Quality Assurance, Audit No. BSC–ARC–02–15"

cc: See attached list.

DISTRIBUTION:

FILE CENTER HLWB r/f DWM r/f ACNW PUBLIC OSRs

LSN CNWRA CWReamer JSchleuter KStablein DBrooks

TEssig SWastler BSpitzberg WMaier, RWeber TCarter

DDambly MYoung DHiggs LCampbell BMabrito DDunavant 

DRom RIV LChandler

DOCUMENT NAME: S:\DWM\HLWB\DSR\BSC-ARC-02-15 Las Vegas Report Rev 8-12.wpd

*see previous concurrence

OFC HLWB HLWB HLWB HLWB

NAME D. Rom* E. Kraus* K. Stablein* J. Schlueter

DATE 09/13/02 09/04/02 09/23/02 09/23/02

OFFICIAL RECORD COPY

ACNW: YES X NO Delete file after distribution: No

1) This document should be made available to the PUBLIC.

2) This document is related to the HLW program. It should be placed in the LSS.

3) This document is Non-Sensitive.
Letter to R. Milner from J. Schlueter dated September 23, 2002

cc:

R. Loux, State of Nevada R. Massey, Lander County, NV

S. Frishman, State of Nevada L. Stark, Lincoln County, NV

M. Chu, DOE/Washington, DC M. Baughman, Lincoln County, NV

C. Einberg, DOE/Washington, DC A. Funk, Mineral County, NV

S. Gomberg, DOE/Washington, DC L. Bradshaw, Nye County, NV

N. Slater, DOE/Washington, DC M. Murphy, Nye County, NV

C. Newbury, YMPO D. Chavez, Nye County, NV

R. Dyer, YMPO D. Weigel, GAO

J. Ziegler, YMPO W. Barnard, NWTRB

R. Murthy, YMPO R. Holden, NCAI

S. Mellington, YMPO A. Collins, NIEC

C. Hanlon, YMPO R. Arnold, Pahrump Paiute Tribe

T. Gunter, YMPO J. Larson, White Pine County

K. Hess, BSC R. Clark, EPA

D. Krisha, BSC F. Marcinowski, EPA

S. Cereghino, BSC R. Anderson, NEI

N. Williams, BSC R. McCullum, NEI

M. Voegele, BSC/SAIC S. Kraft, NEI

D. Beckman, BSC/B&A J. Kessler, EPRI

B. Price, Nevada Legislative Committee D. Duncan, USGS

J. Meder, Nevada Legislative Counsel Bureau R. Craig, USGS

W. Briggs, Ross, Dixon & Bell W. Booth, Engineering Svcs, LTD

E. von Tiesenhausen, Clark County, NV L. Lehman, T-REG, Inc

A. Kalt, Churchill County, NV S. Echols, ECG

G. McCorkell, Esmeralda County, NV N. Rice, NV Congressional Delegation

L. Fiorenzi, Eureka County, NV T. Story, NV Congressional Delegation

A. Johnson, Eureka County, NV J. Reynoldson, NV Congressional Delegation

A. Remus, Inyo County, CA S. Joya, NV Congressional Delegation

M. Yarbro, Lander County, NV J. Pegues, City of Las Vegas, NV
I. Zabarte, W.S.N.C. R. Bahe, Benton Paiute Indian Tribe

C. Anderson, Las Vegas Paiute Tribe C. Bradley, Kaibab Band of Southern Paiutes

J. Birchim, Yomba Shoshone Tribe R. Joseph, Lone Pine Paiute-Shoshone Tribe

L. Jackson, Timbisha Shoshone Tribe L. Tom, Paiute Indian Tribes of Utah

C. Meyers, Moapa Paiute Indian Tribe E. Smith, Chemehuevi Indian Tribe

V. Miller, Fort Independence Indian Tribe J. Charles, Ely Shoshone Tribe

A. Bacock, Big Pine Paiute Tribe of

 the Owens Valley

D. Crawford, Inter-Tribal Council of Nevada

R. Quintero, Inter-Tribal Council of Nevada

(Chairman, Walker River Paiute Tribe)

H. Blackeye, Jr., Duckwater Shoshone Tribe

M. Bengochia, Bishop Paiute Indian Tribe D. Eddy, Jr. Colorado River Indian Tribes

J. Egan, Egan & Associates, PLLC G. Runkle, DOE, Washington, DC

J. Leeds, Las Vegas Indian Center W. Briggs, Ross, Dixon & Bell

K. Tilges, Citizen Alert H. Jackson, Public Citizen

J. Triechel, Nuclear Waste Task Force M. Smurr, BNFL, Inc.

W. Boyle, YMPO
U.S. NUCLEAR REGULATORY COMMISSION

OBSERVATION AUDIT REPORT NO. OAR–02–10

“OBSERVATION AUDIT OF THE

OFFICE OF CIVILIAN RADIOACTIVE WASTE MANAGEMENT,

OFFICE OF QUALITY ASSURANCE,

AUDIT NO. BSC–ARC–O2–15”

/RA/ 9/23/02 /RA/ 09/18/02

Daniel Rom Donald W. Dunavant

Projects and Engineering Section Center for Nuclear Waste Regulatory Analyses

High-Level Waste Branch 

Division of Waste Management

/RA/ 09/18/02

Rodney M. Weber

Center for Nuclear Waste RegulatoryAnalyses

Reviewed and Approved by:

/RA/ 09/23/02

N. King Stablein, Chief

Projects and Engineering Section

High-Level Waste Branch

Division of Waste Management
1

1.0 INTRODUCTION

Staff from the U.S. Nuclear Regulatory Commission (NRC) Division of Waste Management, and

the Center for Nuclear Waste Regulatory Analyses (CNWRA), observed the U.S. Department

of Energy’s (DOE’s) Office of Civilian Radioactive Waste Management (OCRWM), Office of

Quality Assurance (OQA) audit of Bechtel SAIC Company, LLC (BSC), Las Vegas, NV.

The objectives of the OQA audit were to assess the adequacy and effectiveness of BSC’s

implementation of the Quality Assurance Requirements and Description (QARD) and

implementing procedures, and to verify BSC’s compliance with the requirements in the areas

reviewed. The NRC observers’ (hereafter, observers) objective was to assess the effectiveness

of the OQA audit team (hereafter, audit team) and audit process, as well as the BSC

implementation of the provisions in the QARD. This report documents the observers’

determination of the effectiveness of the OQA audit and BSC’s implementation of QARD

provisions.

2.0 MANAGEMENT SUMMARY

The observers determined that OQA Audit BSC–ARC–02–15 was effective in determining the

level of compliance of BSC Quality Assurance (QA) activities with the QARD and with

associated implementing procedures. The observers agreed with the audit team’s conclusions,

findings, and recommendations. The observers determined that the audit team members were

qualified, independent of the activities that they reviewed, and knowledgeable of the QA

requirements. Based on these observations, the OCRWM QA program has been effectively

implemented, except for the items noted in the two potential deficiency reports (DRs), one

quality observation (QO), and two recommendations. The potential DRs, QO, and

recommendations were in the areas of procedural controls, drawing reviews, and specification

review documentation.

3.0 AUDIT PARTICIPANTS

3.1 Observers

Daniel S. Rom Team Leader NRC

Donald W. Dunavant QA Specialist CNWRA

Rodney M. Weber QA Specialist CNWRA

3.2 Audit Team

Marilyn A. Kavchak Audit Team Leader OQA/Navarro Quality Services

(NQS)

F. Harvey Dove Auditor OQA/NQS

James E. Flaherty Auditor OQA/NQS

Donald J. Harris Auditor OQA/NQS

Christian M. Palay Auditor OQA/NQS

4.0 REVIEW OF THE AUDIT AND AUDITED ORGANIZATION

OQA conducted this audit of BSC in accordance with OCRWM Quality Assurance

Administrative Procedures (APs) 18.3Q, “Internal Audit Program,” and 16.1Q, “Management of

Conditions Adverse to Quality.” The NRC staff’s observation was based on NRC Manual
2

Chapter 2410, “Conduct of Observation Audits,” dated July 12, 2000.

4.1 Audit Scope

This was a limited-scope compliance-based audit to evaluate BSC’s implementation of the

OCRWM QA program defined in the QARD, DOE/RW–0333P, Revision 11, and applicable

implementing procedures. The audit team evaluated the implementation, compliance,

adequacy, and effectiveness of the activities of the BSC Repository Design Project’s support of

the Yucca Mountain Site Characterization Project (YMSCP).

4.2 Audit Conduct and Timing

The audit was performed in a professional manner and the audit team demonstrated a sound

knowledge of the applicable BSC and DOE programs and procedures. The audit team

personnel were unified in approach, persistent in their interviews, challenged responses when

appropriate, and followed their checklist questions, deviating when necessary to more fully

understand the BSC process or pursue discrepancies. The audit team performed a thorough

and effective audit.

The audit team and observers caucused at the end of each day to discuss the audit status and

any new and developing issues. The observers were provided with ample opportunity to

participate in the discussions with any comments, concerns, or questions. The audit team

leader met with BSC management each morning, with some of the observers present, to

discuss the current audit status and potential discrepancies. Members of the BSC organization

also participated in the discussions via teleconference. The observers determined that the

timing of the audit was

appropriate for the team to evaluate the BSC QA program. It was also noted that the BSC

personnel had a good understanding of the QA program requirements and accepted ownership

of the products audited.

4.3 Audit Team Qualification and Independence

The observers determined that the qualifications of the audit team lead (ATL) and the OQA

audit team members met the requirements of AP–18.1Q, “Audit Personnel Qualification.” The

ATL provided the qualification records of the audit team. The observers concluded that the

audit team members had the necessary expertise to perform the audit and had sufficient

authority and organizational freedom to make the audit process meaningful and effective.

4.4 Examination of the QA Elements

The NRC staff observed the audit team conducting detailed checks of the adequacy of

BSC QA activities related to the YMSCP. The audit team effectively used its prepared

checklist identifying the QA program implementing procedures. Interviews were held with

BSC personnel, as well as appropriate management personnel, who had performed or

are currently performing activities required by the implementing procedures. Record

packages were also reviewed to assure documentation was in compliance with procedural

requirements. The audit team effectively shared information among team members and

assisted one another to assure each area was adequately covered and completed.

4.4.1 Organization—[LP–1.0Q–BSC, Revision 1, Interim Change Notice (ICN) 1]

The audit team reviewed several organization charts of various BSC groups. Administrative

and functional reporting structures of the matrixed organizations (i.e., direct reporting of a staff

member to an administrative and a technical manager) were identified in the previous audit of
3

the BSC activity as not being completely clear. The charts have been revised since the last

audit and were found to be acceptable. 

The observers agreed with the findings in this area.

4.4.2 QA Program 

Review of Technical Documents and Data—(AP–2.14Q, Revision 2)

The audit team reviewed two technical documents and four drawing packages. Technical

review of these documents was conducted to verify reviewer qualifications, extent of review,

and objective evidence of procedural compliance. It was determined that the drawing packages

reviewed did not receive an impact review and that there was no justification for not completing

this review, as required by AP–3.24Q, “Drawings.” The audit team identified a potential DR for

this condition. 

The observers agreed with the finding in this area.

4.4.3 Design Control—(AP–3.13Q, Revision 3)

The audit team reviewed available reports, calculations, specifications, and other documents to

determine compliance with the applicable design process implementing procedures. These

procedures included:

• “Technical Reports”—AP–3.11Q, Revision 3, ICN 2

• “Design Calculations and Analyses”—AP–3.12Q, Revision 1, ICN 2

• “Managing Technical Products”—AP–3.15Q, Revision 3, ICN 2

• “Specifications”—AP–3.19Q, Revision 2

• “Technical Design Verifications”—AP–3.20, Revision 1

• “Technical Review and Approval Construction Submittals”—LP–3.22Q–BSC, 

Revision 0, ICN 3

Three of seven available System Design Documents (SDDs) were reviewed. The review of

draft SDD, “Surface HVAC System,” dated July 23, 2002, revealed that the technical reviewer

did not verify that meteorological data used to support the system design were placed under

control (assigned a data tracking number). Although the applicable procedures were followed

(LP–3.25Q–BSC, Revision 1, “Design Criteria,” and LP–3.26Q–BSC, Revision 0, “System

Description Document,”), the auditors identified this as a risk area since the procedure(s) did

not clearly define a method of referencing data. The auditors noted that terminology has

changed from data to design input and from generation and use of data in science to design

and design input. This has left a gap in procedures related to engineering use and control of

data as required by the QARD in Supplement III. A recommendation was proposed to revise

procedures to require the use of the technical data management system for control of

Supplement III data, for the engineering processes.

The auditors also examined specification review packages to determine compliance with

procedural requirements for technical reviews. During this review, it was noted that a reviewer

had not indicated an organizational affiliation. This isolated incident was documented in a

proposed observation. 

The observers agreed with the findings in this area.
4

4.4.4 Implementing Documents

Plan and Procedure Preparation, Review, and Approval—(AP–5.1Q, Revision 3, ICN 1)

In addition to the review of in-process and completed design documents, design team

personnel responsible for the various documents were interviewed and asked to describe their

processes for design approach. In the course of these discussions, it became clear that the

requirements of the QARD, Section 2.2.5 were not followed by BSC and the applicability of

these planning requirements was questioned as they applied to the construction engineering

activities. Additional discussions were held with design management and a recommendation

made to seek clarification about the application of the QARD requirements in this area. The

audit team leader contacted OQA management personnel who had been involved in the QARD

development and evolution in previous years. This discussion resulted in a recommendation to

draft a proposed position statement that would relieve the design engineering process from

certain QARD planning requirements. The draft proposal will be submitted to current

DOE/OQA and DOE/YMSCO management.

The observers agreed with this determination and the proposed action to be taken.

4.4.5 Software Management—(AP–SI.1Q, Rev. 3, ICN 4)

The audit team reviewed the software verification process and records for GTSTRUDL 25 and

FLAC3D 2.1. The records were found to be complete and demonstrated compliance with the

requirements of AP–SIQ, Revision 3, ICN4, “Software Management.” Auditor interviews with

the affected personnel indicated that the personnel were familiar with the procedural

requirements. Configuration control of the verified software was through the software library,

which issued software items to individual computers on an as-requested basis. 

The auditor team followed up on a previously identified finding, DR–99, on submitting review

documents for maintenance as quality records. Of the three software packages reviewed

during this audit, the reviewer had maintained copies of review records, but had not submitted

them to the Records Processing Center. The auditors determined that the recent approval of

DR–99 had not allowed sufficient time to implement its stated corrective action. The

responsible software manager agreed to expedite corrective action and the auditor saw no

value added in reporting this as a finding. It was determined that no further action would be

taken at this time.

The observers agreed with this determination.

4.4.6 Control of the Electronic Management of Data—(AP–SV.1Q, Rev. 0, ICN 2)

The audit team reviewed AP–3.13Q, R3, “Design Control,” as it affected the implementation of

Supplement V. It was determined that AP–3.13Q did not address all the requirements of

Supplement V and contained references to processes such as “BSC Policies”, which are not

controlled documents, to describe client design reviews (Section 5.11) and configuration audits

(Section 5.1.9). The audit team identified a potential DR for this condition. 

The observers agreed with the finding in this area.

4.4.7 Potential Audit Findings, Recommendations, and Action Items

The audit team identified three conditions adverse to quality during its review. These conditions

were identified as DRs and Qos. In addition, two recommendations were made and one
5

additional related action item resulted from this audit. The following is a short description of

each. 

Two Potential Deficiency Reports

(1) Procedure AP–3.24Q, “Drawings,” requires that impact reviews be conducted or that

justification be given if they are not. There were no justifications provided for the lack of

impact review of drawings sampled during the audit. 

(2) The QARD requires work to be performed in accordance with controlled procedures. 

Procedure AP–3.13Q, “Design Control,” does not implement Supplement V

requirements and contains references to processes that do not have controlled

procedures, specifically client design reviews in Section 5.1.1, and configuration audits,

Section 5.1.9.

One Potential QO

(1) One specification review did not identify the organizational affiliation of the reviewer, as

required by procedure. 

Audit Team Recommendations

The audit team made two recommendations. They were:

(1) Clarification is needed to better define requirements for design calculation checking, 

specifically “mathematical checking.” 

(2) Control of scientific data should be strengthened by requiring the use of the Technical Data

Management System for control of Supplement III data for the engineering processes.

Additional Action Item

After an in-depth discussion with BSC and OQA management on implementation of QARD

design planning requirements and the intent of these requirements, a recommendation will be

drafted regarding clarifying the applicability of QARD, Section 2.2.5, requirements to

engineering functions will be drafted. This recommendation will be presented to OQA

management, for possible issue of written clarification to BSC, concerning the applicability of

these requirements. 

5.0 NRC STAFF FINDINGS

The observers determined that Audit No. BSC–ARC–02–15 was effective in determining the

level of compliance of the BSC activities associated with the programmatic implementation of

QARD design requirements, with the exception of QARD planning requirements (see the action

item above) and the identified potential deficiencies and observation. 

5.1 NRC Audit Exit Summary

During the audit exit meeting, the observers expressed their appreciation for the cooperation

and responsiveness given them during their observation activities. In addition, the observers

stated that they agreed with the audit team’s findings and recommendations, as presented at

the audit exit meeting.
6

5.2 NRC Audit Observer Inquiries

During this audit, the observers followed up on the status of the Observer Inquiry from

LLNL–ARC–02–07. The Navarro audit supervisor indicated that a response to the inquiry had

been forwarded to NRC, and he produced a copy of the transmittal letter dated July 2, 2002. 

The observers verified that NRC had received the response and that the response was under

review. No other inquiries were investigated and no new inquiries were written during this audit.