DOCKET NO: A-98-49; II-A1-118

EPA Air eDocket # EPA-HQ-OAR-2001-0012-0447

EPA AUDIT OF THE NUCLEAR WASTE PARTNERSHIP, LLC QUALITY 

ASSURANCE PROGRAM

JULY 22–24, 2014

U. S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF RADIATION AND INDOOR AIR

CENTER FOR FEDERAL REGULATIONS

WASHINGTON, DC 20460

DECEMBER 2014
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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....................................................................... 4
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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 Protection 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

NWP 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 Isolation Pilot Plant

WJC William Jefferson Clinton West
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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) Nuclear 

Quality Assurance (NQA) Standard NQA-1-1989,1“Quality Assurance Program Requirements 

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 Mexico. 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 Assurance Program.”

 Element 16, “Corrective Action.”

Based on this audit, the EPA audit team determined that the NWP QA program complies with

these NQA-1-1989 elements and continues to have sufficient independence, authority and 

resources to verify the quality of items and activities that are important to long-term isolation of 

TRU waste.

EPA did not identify any nonconformances in NWP’s QA program 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 the 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 section 2.1(b) and (c) and section 17.1).

 

1 40 CFR 194.22(a)(1) states that DOE’s QA program shall comply with the requirements of 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 verify 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 emplacement 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 QAPD),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 elements of ASME NQA-1-1989. 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, may 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 achievement” 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/CBFO94-1012, Revision 11, June 2010

3 Quality Assurance Program Description, Nuclear Waste Partnership LLC, WP 13-1, Revision 34, October 

10, 2013
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“Quality assurance/verification” 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 

project in Carlsbad, New Mexico. For purposes of efficiency, EPA conducted the audits in two 

parallel tracks with one Lead QA Auditor responsible for each track. Track A included limitedscope audits of the CBFO QA program (see Docket No. A-98-49; II-A1-117; or eDocket EPAHQ-OAR-2001-0012-0446) 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 Alamos 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 consisted of one EPA employee and three support contractors. Table 1 

lists all 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 auditors

listed in Table 1. Ms. Bender found that the SC&A auditors were qualified based on their:

 Working knowledge and understanding of the NQA standards.

 Training.

 On-the-job training.

In addition, Ms. Bender evaluated the qualifications of Ms. Gill to be a Lead Auditor in oversight 

of DOE QA audits specific to Element 18 of NQA-1-1989 and found that she 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.
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 Specific understanding of NQA-1, Element 18.

Mr. Lindblad was an auditor-in-training 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 personnel from 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.

Table 2. Personnel Participating in Audit Meetings

6.0 PERFORMANCE OF THE AUDIT

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

evaluate 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/Observer  

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 McVay NWP 

Laurie Smith LANL-CO, QA Manager  

Martin Navarrete CBFO, Senior QA Specialist  

Michael R. Brown CBFO, QA Director  

Ned Z. Elkins LANL-CO, Program Director 

Paul Shoemaker SNL-CO, Senior Manager 

Porf Martinez CTAC, Regulatory Assurance Manager 

Priscilla Y. Martinez CTAC, QA Auditor/Observer  

Regina Sides CBFO, QA Division 

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  
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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.”

 Element 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 the 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 characterization sites.

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 indicating that organization structure will be fluid while the recent 

issues at the WIPP repository are 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 all 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 operations, 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 corrective 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 throughout the audit as time allowed.

As a result of these audit activities, EPA determined that the NWP QA program complies with

these 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 CONCERNS

The EPA audit team did not identify any findings or concerns relative to the NQA-1-1989

elements discussed above.
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8.0 CONCLUSIONS

The EPA audit team reviewed records and documentation and interviewed personnel to 

determine the compliance of the NWP QA program with ASME NQA-1-1989. Based on the 

sample of documentation and elements reviewed during this audit, EPA determines that NWP

complies with the standard.
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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 Nonconforming 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 CCP 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 LLC, 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 Organizational 

Announcements

Inter-Office 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, 2014
8

WIPP Form Committee Attendees, 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 Assurance 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