DOCKET NO: A

- 98

- 49 ; II

- A1

- 118 EPA Air eDocket # EPA

- HQ

- OAR

- 2001

- 0012

- 0447

EPA AUDIT OF THE NUCLEAR WASTE PARTNE RSHIP, LLC QUALITY ASSURANCE PROGRAM

JU LY 22

– 2 4 , 201 4

U. S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OF RADIATION AND IND OOR AIR CENTER FOR FEDERAL R EGULATIONS WASHINGTON, DC 20460

DEC EM BER 2014ii TABLE OF CONTENTS

Section Page

Acronyms and Abbreviations

................................ ................................ ................................ ......... iii

1.0 Executive Summary

................................ ................................ ................................ ............. 1

2.0 Background

................................ ................................ ................................ .......................... 1

2.1 Regulatory Background

................................ ................................ ........................... 1

2.2 Organizational Background

................................ ................................ ..................... 2

3.0 Purpose and Scope

................................ ................................ ................................ ............... 2

4.0 Definitions

................................ ................................ ................................ ............................ 2

5.0 EPA Audit Logistics

................................ ................................ ................................ ............ 3

5.1 Audit Schedule

................................ ................................ ................................ ......... 3

5.2 Team Members

................................ ................................ ................................ ........ 3

6.0 Performance of the Audit

................................ ................................ ................................ ..... 4

7.0 Findings and Concerns

................................ ................................ ................................ ......... 5

8.0 Conclusions

................................ ................................ ................................ .......................... 6

9.0 References

................................ ................................ ................................ ............................ 7

TABLES

Table 1 . EPA Quality Assurance Audit Team Members

– Track A

................................ ............... 3 Table 2. Personnel Participating in Audit Meetings

................................ ................................ ....... 4iii ACRONYMS AND ABBREVIATIONS

ASME American Society of Mechanical Engineers CAQ condition adverse to quality

CBFO Carlsbad Field Office CBFO QAPD Carlsbad Field Office Quality Assurance Program Document

CCP Central Characterization Program

CFR Code of Federal Regulations

CTAC Carlsbad Field Office Technical Assistance Contractor

DOE U.S. Department of Energy

EPA U.S. Environmental P rotection Agency

EPA/DC EPA Docket Center

IMPS Issues Management Processing System

LANL

- CO Los Alamos National Laboratory

- Carlsbad Office

M&O management and operations

NCR nonconformance report

NDE nondestructive examination NQA nuclear quality assurance

N WP Nuclear Waste Partnership, LLC

NWP QAPD Nuclear Waste Partnership Quality Assurance Program Description QA quality assurance SCAQ significant condition adverse to quality

SNL

- CO Sandia National Laboratories

- Carlsbad Office

TRU transuranic

WIPP Waste Iso lation Pilot Plant

WJC William Jefferson Clinton West1

1.0 EXECUTIVE SUMMARY

This report presents results of the U.S. Environmental Protection Agency ( EPA ) audit of the Nuclear Waste Partnership, LLC (NWP)

, quality assurance (QA) program . EPA conducted this audit at the Carlsbad Field Office (CBFO) on July 22

– 24, 2014

. The purpose of the audit was to determine NWP ’s compliance with American Society of Mechanical Engineers (ASME) N uclear Quality Assurance (NQA) Standard NQA

- 1

- 1989, 1 “Quality Assurance Program Requ irements for Nuclear Facilities

. ” NWP is the Department of Energy ’s (DOE ’s ) management and operations (M&O) contractor for the Waste Isolation Pilot Plant (WIPP). The Central Characterization Program (CCP), a subset of NWP, is responsible for characterization of transuranic (TRU)
wastes at most of the DOE TRU waste generator sites.

During this audit, the EPA audit team reviewed documents and records provided by NWP and interviewed applicable NWP personnel in Carlsbad, New Me xico. EPA QA auditors evaluated the NWP QA program against the NQA

- 1

- 1989 elements listed below to ensure compliance with EPA regulations at Title 40 of the Code of Federal Regulations (40 CFR ) 194.22 :

 Element 1, “ Organization

. ”

 Element 2, “ Quality Assur ance Program

. ”

 Element 16, “ Corrective Action

. ”

Based on this audit, the EPA audit team determined that the NWP QA p rogram compl ies with the se NQA

- 1

- 1989 e lement s and continue s to have sufficient independence, authority and resources to verify the qualit y of items and activities that are important to long

- term isolation of TRU waste.

EPA did no t identify any nonconformances in NWP ’ s QA p rogram relative to the requirements of ASME NQA

- 1

- 1989

. This report documents these audit activities. This information will be provided through EPA’s Electronic Docket (via regulations.gov) and the official Air Docket, in accordance with Title 40 of the Code of Federal Regulation 40 CFR 194.22 (a)(1). EPA’s Air Docket A

- 98

- 49 is located at the Air and Radiation Docket in t he EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Avenue, NW, Washington, DC, 20004.

2.0 BACKGROUND

2.1 Regulatory Background

In accordance with 40 CFR 194.22(a)(1), EPA requires DOE to implement a QA plan that establishes the following NQA standards developed by ASME:

1. ASME NQA

- 1

- 1989

. 2. ASME NQA

- 2a

- 1990 Addenda, Part 2.7, to ASME NQA

- 2

- 1989

. 3. ASME NQA

- 3

- 1989 (excluding s ection 2.1(b) and (c) and s ection 17.1).

1 40 CFR 194.22(a)(1) states that DOE’s QA program shall comply with the requirements o f the 1989 version of the ASME NQA

- 1 standard.2

The regulation at 40 CFR 194.22(a)(2) requires DOE to implement its QA plan for all items and activities that are important to the long

- term isolation of TRU waste within the WIPP. The regulation at 40 CFR 194.22(e) provides EPA with the authority to conduct audits to veri fy the proper establishment and implementation of QA programs for the WIPP.

2.2 Organizational Background

CBFO is responsible for management of the WIPP. This responsibility includes oversight of the characterization of TRU waste bound for the WIPP and emplace ment of the waste at the disposal site near Carlsbad, New Mexico. As stated in the CBFO Quality Assurance Program Document ( CBFO QAPD )

, 2 “The mission of the CBFO is to protect human health and the environment by operating the WIPP for safe disposal of TRU waste and by establishing an effective system for management of TRU waste from generation to disposal.”

NWP is DOE’s contractor that manages and operates the WIPP. NWP’s CCP contracts with most of the generator sites to perform TRU waste characterization activities at the sites. The NWP QA
program supports all NWP activities, including WIPP site operations and CCP waste characterization activities

. NWP performs all activities supporting the WIPP under the NWP Quality Assurance Program Description (NWP QAP D), 3 which incorporates the requirements of NQA

- 1

- 1989 and the CBFO QAPD.

3.0 PURPOSE AND SCOPE

The purpose of this EPA audit was to verify that the NWP QA program continues to properly implement selected e lement s of ASME NQA

- 1

- 1 989. The scope of this EPA audit was limited to QA oversight of activities that are important to the long

- term isolation of TRU waste as represented by documentation provided by NWP

.
4.0 DEFINITIONS

Finding: A determination that a requirement of the NQA standards has not been properly

established or implemented. A finding requires a response.

Concern: A judgment that a finding may occur in the future and

, depending on the magnitude

of the issue, ma y or may not require a response

. Quality : The reliability of a specific item or activity that is important to the long

- term

isolation of TRU waste in the WIPP. “ Quality a chievement ” is the responsibility of operational groups that directly produce such an item or perform such an activity

.

2 Quality Assurance Program Document, U.S. Department of Energy Carlsbad Field Office, DOE/CBFO

94

- 1012, Revision 11, June 2010

3 Quality Assurance Program Description, Nuclear Waste Partnership LLC, WP 13

- 1, Revision 34, October 10, 20133 “ Quality a ssurance/ v erification ” is the responsibility of QA groups that do not produce such an item or perform such an activity.

5.0 EPA AUDIT LOGISTICS

5.1 Audit Schedule

On July 22

– 24, 2014, EPA conducted QA audits of four DOE programs working on the WIPP
pro ject in Carlsbad, New Mexico

. For purposes of efficiency, EPA conducted the audit s in two parallel tracks with one Lead QA Auditor responsible for each track. Track A included limited

scope audits of the CBFO QA program (see Docket No. A

- 98

- 49; II

- A1

- 117 ; or eDocket EPA

HQ

- OAR

- 2001

- 0012

- 044 6 ) and the NWP QA program (this report). Track B completed audits of the Sandia National Laboratory

- Carlsbad Office (SNL

- CO) QA program (see Docket No. A

- 98

- 49; II

- A1

- 115 ; or eDocket EPA

- HQ

- OAR

- 2001

- 0012

- 0444 ) and Los Ala mos National Laboratory

- Carlsbad Office (LANL

- CO) QA program (see Docket No. A

- 98

- 49; II

- A1

- 116 ; or eDocket EPA

- HQ

- OAR

- 2001

- 0012

- 0445 ) , both of which had been evaluated previously with remote audits. The other members of the EPA audit team participated in all four audits. This report addresses only the results of EPA’s audit of the NWP QA program; the docket numbers cited above provide results of the other three EPA QA audits.

5.2 Team Members

The Track A audit team cons isted of one EPA employee and three support contractors. Table 1 lists a ll members of the EPA audit team , along with each person’s affiliation and function during this audit.

Table 1 . EPA Quality Assurance Audit Team Members

– Track A

Prior to this audit, Lindsey Bender (EPA) evaluated the qualifications of the SC&A a uditors listed in Table 1. Ms. Bender found that the SC&A auditors were qualified based on their :

 W orking knowledge and understanding of the NQA standards

.

 Training

.

 On

- the

-

job training

. In addition, M s. Bender evaluated the qualifications of M s

. Gill to be a Lead Auditor in oversight of DOE QA audits specific to Element 18 of NQA

- 1

- 1989 and found that s he is qualified in this capacity based on her :

 Communication skills

.

 Technical qualifications

. Audit Team Member Audit Responsibility Affiliation Lindsey Bender EPA QA Audit Team Leader EPA Patrick Kelly Lead QA Auditor SC&A , Inc. Kira Darlow QA Auditor SC&A, Inc.
Karl Lindblad QA Auditor

- in

- Training SC&A, Inc.4

 Specif

ic understanding of NQA

- 1, Element 18

.

M r

. Lindblad was an a uditor

- i n

- t raining during this audit ; his qualifications as a QA auditor will be addressed in a subsequent EPA QA audit report.

EPA held one Entrance Meeting and one Exit Meeting that included p ersonnel f ro m all four audited organizations, identified in Table 2. Some of these personnel may have been interviewed during one of the other three audits; however, only the personnel interviewed as part of this NWP QA audit are identified in Table 2.

Tab le 2

. Personnel Participating in Audit Meetings

6.0 PERFORMANCE OF THE A UDIT

The EPA audit team reviewed record s provided by NWP and interviewed NWP personnel to

e valuate implementation of the requirements in ASME NQA

- 1

- 1989 for the elements listed below, using NQA

- 1

- 1989 checklists . This information will be provided on line through the EPA’s Electronic Docket (via regulations.gov). Hard copies can also be obtained via the Reading Room/Information Center in the Agency’s Air and Radiation docket (at 1301 Constitution Ave., Name Affiliation and Title/Position Entrance Meeting Interview Exit Meeting Berry Pace CTAC

, QA Programs Manager 
Bill Allen NWP, QA 
Cindi Castillo CTAC, QA Auditor/Observ er   Dana C. Bryson CBFO, Deputy Manager  
Dennis Miehls CBFO, Senior QA Specialist  
Fran Ito NWP  Gene Safley SNL

- CO, QA Lead 
Grace Duran SNL

- CO, Records Lead 
Jeff Neatherlin NWP, Underground Ops Integration Manager 

Jim McV ay NWP 
Laurie Smith LANL

- CO, QA Manager  
Martin Navarrete CBFO

, S enior QA Specialist  
Michael R. Brown CBFO, QA Director  
Ned Z. Elkins LANL

- CO, Program Director 
Paul Shoemaker SNL

- CO, Senior Manager 
Porf Martinez CTAC, Regula tory Assurance Manager 
Priscilla Y. Martinez CTAC, QA Auditor/Observer   Regina Sides CBFO, QA D ivision  Shelly R. Nielsen SNL

- CO, QA  
Steve Davis SNL

- CO, QA Assessment Task Lead  
Steve Kouba URS , Manager EPA Compliance Program  Tammy Reynolds NWP
, Deputy Recovery Manager 
Val Cannon NWP
, QA    Wayne Ledford NWP, QA Specialist  5

NW, Washington, DC, 20004). This in accordance with Title 40 of the Code of Federal Regulation 40 CFR 194.22 (a)(1).

 Element 1, “ Organization. ”

 E lement 2, “ Quality Assurance Program. ”

 Element 16, “ Corrective Action. ”

EPA did not identify any nonconformances in NWP’s QA program relative to the requirements of ASME NQA

- 1

- 1989.

As recovery from the February 2014 events continues , QA oversight of th e operations is especially important. During this audit, EPA evaluated selected aspects of the NWP QA program to ensure that it has the appropriate independence, authority, and resources to oversee NWP operations at the WIPP facility and at CCP waste chara cterization site s

. The organization chart and the organization description included in the NWP QAPD are in flux due to the recent issues identified at the WIPP repository. DOE/CBFO and NWP exchanged a series of communications indicat ing that organization s tructure will be fluid while the recent issues at the WIPP repository a re remediated. EPA finds this explanation reasonable and will monitor the organizational structure of NWP QA at future audits.

The NWP WIPP Form process enables NWP to track and trend a ll issues, nonconformances, concerns and problems, including, but not limited to

, those that are identifiable as conditions adverse to quality (CAQs) and significant conditions adverse to quality (SCAQs). A group of individuals from all areas of NWP’s oper ations , including NWP QA get together about once a week to discuss the submitted WIPP Forms. The WIPP Form Committee determines which trend codes to apply and whether the issue is a CAQ. The committee then assigns development and implementation of the corr ective action plan to an appropriate manager. During the meeting, the QA representative also makes an initial assessment regarding whether the issue is an SCAQ; however, the final SCAQ determination is made by the NWP QA Manager. EPA observed the WIPP Form Committee meeting held on July 24, 2014.

The EPA audit team performed a document and record review for the requirements of NQA

- 1

- 1989 Elements 1, 2 and 16 and gathered objective evidence to support the proper implementation of these requirements throughou t the audit as time allowed.

As a result of these audit activities, EPA determined that the NWP QA program compl ies with the se NQA

- 1

- 1989 elements and has sufficient independence, authority and resources to verify the quality of items and activities that are important to long

- term isolation of TRU waste.

7.0 FINDINGS AND CONCERN S

The EPA audit team did not identify any findings or concern s relative to the NQA

- 1

- 1989 elements discussed above.6

8.0 CONCLUSIONS

The EPA audit team reviewed records and document ation an d interviewed personnel to determine the compliance of the NWP QA p rogram with ASME NQA

- 1

- 1989

. Based on the sample of documentation and elements reviewed during this audit, EPA determine s that NWP complies with the standard.7

9.0 REFERENCES

CCP Calendar Year 2014 Surveillance/Assessment Schedule CCP NDE Operator Training Records

CCP

- PO

- 002, CCP Transuranic Waste Certification Plan, Revision 27, May 31, 2013

CCP

- QP

- 002, CCP Training and Qualification Plan, Revision 37, May 12, 2014

CCP

- QP

- 005, CCP TRU Nonconfor ming Item Reporting and Control, Revision 24 , April 29, 2014

CCP

- QP

- 030, Revision 9, CCP Written Practice for the Qualification of CCP Helium Leak Detection Personnel, August 12, 2013

CCP

- QP

- 032, Revision 2, CCP Written Practice for the Qualification of CC P Pressure Change Leak Testing Personnel, August 12, 2013 Compensatory Measures Matrix for Phase III Mine Entry Compensatory Measures Matrix for Phase III Mine Manned Entry Copies of WIPP Form Nos. 14

- 111, 14

- 019, 14

- 133 and 14

- 200

DOE CBFO letter to NWP L LC, dated 4/11/2014, Subject: Required Compensatory Measures Plan for Phase II Mine Planned Entry

DOE Order O 232.2 IMPS report for WIPP Forms, January 1, 2010

, to July 10, 2013

Inter

- Office Correspondence, dated March 31, 2014 with regard to NWP Organizat ional Announcements

Inter

- O ffice Correspondence, dated April 4, 2014 with regard to Contractor Assurance System Compensatory Measures

Inter

- office Correspondence, WIPP Form 14

- 169

– Review for SCAQ Lead Auditor Qualification Record (NQA

- 1

- 1989) Management Assessment Report, MA

- QA

- 2013

- 02 MC 1.7, WIPP Form Screening Committee , Revision 6 NWP Management Position description for Assurance Programs Manager NWP Organization Chart, provided July 23, 2014 NWP QA Audit Plan, Audit E14

- 03 NWP QA Organization Chart, provided July 23, 2014 NWP QA Rolling 2

- Year Independent Assessment Schedule Fiscal Year 2014/2015 Partial list of 2014 NCR Nos. and corresponding WIPP Form Nos. Report for WIPP Forms Entered between January 1, 2014 and July 23, 20148

WIPP Form Committee At tendees, July 24, 2014 WIPP Form Meeting agenda, July 24, 2014 at 9 A.M. WIPP QA Surveillor Authorization Card WIPP QA Surveillor Authorization Card

WP 13

- 1, Quality Assurance Program Description, Revision 34, October 10, 2013

WP 13

- QA.03, Quality Assuranc e Independent Assessment Program

, Revision 22

WP 13

- QA.04, Quality Assurance Department Administrative Program, Revision 21, January 30, 2014

WP 13

- QA.06, Quality Assurance Department Qualification and Certification of Nondestructive Examination Personnel

, Revision 9

WP 13

- QA3007, External Oversight Activities, Revision 11, June 28, 2013

WP 15

- GM1002, Revision 2, Issues Management, Processing of WIPP Forms , April 3, 2014