E-1 EPA Audit of WIPP QA Program: CBFO QA 7-12-2014 DOCKET NO: A-98-49; II-A1-117; EPA Air eDocket # EPA-HQ-OAR-2001-0012-0446

ATTACHMENT E: ASME NQA-1-1989 CHECKLIST

NQA-1 ELEMENT: No. 1 with Supplement 1S-1, Organization EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Basic Requirements

1. Are the organizational structure, functional responsibilities, levels of 

authority and lines of communication documented for activities 

affecting quality?

Y QAPD, Revision 11, section 1.1, Organization and Quality Assurance Program; 

section 1.1.1.4, Communication and Interface Responsibilities, paragraph A; 

Appendix C, CBFO Organization, Responsibilities, and Interfaces; Appendix D, 

CBFO Quality Assurance Manager Responsibilities; Appendix E, TRU Waste 

Characterization and Certification Organizational and Individual Responsibilities 

Safety Management FRAM, Revision 2, section 4.0

CBFO CAR No. 14-054

CBFO Organization Chart, dated 7/14/2014

Organization Chart approval letter, dated 6/9/2014

Audit Report of SNL-CO Quality Assurance Program, Audit Number A-14-08, dated 

2/25–27/2014, performed by CTAC

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013

Listing of CBFO CAR Trend Codes

CBFO Monthly Assessment Schedule, dated 7/8/2014

2. Do persons or organizations responsible for performing quality 

assurance functions have sufficient authority, access to work areas 

and organizational freedom to:

 Identify quality problems?

 Initiate, recommend, or provide solutions to quality problems 

through designated channels?

 Verify implementation of solutions?

 Assure that further processing, delivery, installation or use is 

controlled until proper disposition of a nonconformance, 

deficiency or unsatisfactory condition has occurred?

Y QAPD, Revision 11, section 1.1.1.3, QA Management, paragraphs A and B; 

Appendix D, CBFO Quality Assurance Manager Responsibilities

Audit Report of Sandia National Laboratories Carlsbad Programs Group Quality 

Assurance Program, Audit Number A-14-08, dated 2/25–27/2014, performed by 

CTAC

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013

Listing of CBFO CAR Trend Codes

CBFO Monthly Assessment Schedule, dated 7/8/2014
E-2 EPA Audit of WIPP QA Program: CBFO QA 7-12-2014 DOCKET NO: A-98-49; II-A1-117; EPA Air eDocket # EPA-HQ-OAR-2001-0012-0446

NQA-1 ELEMENT: No. 1 with Supplement 1S-1, Organization EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

CBFO Organization Chart, dated 7/14/2014

3. Do persons or organizations responsible for performing quality 

assurance functions have direct access to responsible management at 

a level where appropriate action can be effected?

Y QAPD, Revision 11, section 1.1.1.3, QA Management, paragraphs A and B; 

Appendix D, CBFO Quality Assurance Manager Responsibilities

Safety Management FRAM, Revision 2, section 4.0

CBFO Organization Chart, dated 7/14/2014.

Memorandum dated 7/15/2014, Full Time Equivalent CBFO Positions

Organization Chart approval letter, dated 6/9/2014

4. Do persons or organizations responsible for performing quality 

assurance functions report to a management level that provides the 

required authority and organizational freedom, including sufficient 

independence from cost and schedule considerations?

Y QAPD, Revision 11, section 1.1.1.3, QA Management, paragraphs A.7–10 and B

Safety Management Functions, Responsibilities and Authorities Manual (FRAM), 

Revision 2, section 4.0

CBFO Organization Chart, dated 7/14/2014

Supplementary Requirements (1S-1)

1. Are the organizational structure and the responsibility assignments 

such that:

 Quality is achieved and maintained by those who have been 

assigned responsibility for performing work?

 Quality achievement is verified by persons or organizations not 

directly responsible for performing the work?

Y QAPD, Revision 11, section 1.1.1.3, QA Management, paragraphs A and B; 

Appendix D, CBFO Quality Assurance Manager Responsibilities

CBFO Monthly Assessment Schedule, dated July 8, 2014

Safety Management FRAM, Revision 2, section 4.0

Audit Report of SNL-CO Quality Assurance Program, Audit Number A-14-08, dated 

2/25–27/2014, performed by CTAC

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013

Listing of CBFO CAR Trend Codes

CBFO Monthly Assessment Schedule, dated 7/8/2014

CBFO Organization Chart, dated 7/14/2014

2. Do the individuals or organizations responsible for establishing and 

executing a quality assurance program delegate any or all of the 

work to others, and, if so, do the individuals or organizations retain 

responsibility for the quality assurance program?

Y QAPD, Revision 11, section 1.1, Organization and Quality Assurance Program; 

section 1.1.1.4, Communication and Interface Responsibilities, paragraph A; section 

1.1.1.5, Delegation of Work; Appendix C, CBFO Organization, Responsibilities, and 

Interfaces; Appendix D, CBFO Quality Assurance Manager Responsibilities; 

Appendix E, TRU Waste Characterization and Certification Organizational and 
E-3 EPA Audit of WIPP QA Program: CBFO QA 7-12-2014 DOCKET NO: A-98-49; II-A1-117; EPA Air eDocket # EPA-HQ-OAR-2001-0012-0446

NQA-1 ELEMENT: No. 1 with Supplement 1S-1, Organization EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Individual Responsibilities

Safety Management FRAM, Revision 2, section 4.0

CBFO TP 10.2, Revision 5, Qualification of Audit Personnel and Certification of 

Lead Auditors

CBFO Organization Chart, dated 7/14/2014

Organization Chart approval letter, dated 6/9/2014

Audit Report of SNL-CO Quality Assurance Program, Audit Number A-14-08, dated 

2/25–27/2014, performed by CTAC

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013

Listing of CBFO CAR Trend Codes

CBFO Monthly Assessment Schedule, dated 7/8/2014

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

3. Is responsibility for the control of further processing, delivery, 

installation or operation of nonconforming items designated in 

writing?

Y QAPD, Revision 11, section 1.1, Organization and Quality Assurance Program; 

section 1.1.1.4, Communication and Interface Responsibilities, paragraph A; section 

1.1.1.5, Delegation of Work; Appendix C, CBFO Organization, Responsibilities, and 

Interfaces; Appendix D, CBFO Quality Assurance Manager Responsibilities; 

Appendix E, TRU Waste Characterization and Certification Organizational and 

Individual Responsibilities

Safety Management FRAM, Revision 2, section 4.0

CBFO MP 3.1, Interim Change Notices No.1 &2

CBFO TP 10.2, Revision 5, Qualification of Audit Personnel and Certification of 

Lead Auditors

CBFO Organization Chart, dated 7/14/2014

Organization Chart approval letter, dated 6/9/2014

Audit Report of SNL-CO Quality Assurance Program, Audit Number A-14-08, dated 

2/25–27/2014, performed by CTAC

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)
E-4 EPA Audit of WIPP QA Program: CBFO QA 7-12-2014 DOCKET NO: A-98-49; II-A1-117; EPA Air eDocket # EPA-HQ-OAR-2001-0012-0446

NQA-1 ELEMENT: No. 1 with Supplement 1S-1, Organization EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013

Listing of CBFO CAR Trend Codes

CBFO Monthly Assessment Schedule, dated 7/8/2014

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

4. Where more than one organization is involved in the execution of 

quality assurance activities, is the responsibility and authority of 

each organization clearly established and documented?

Y QAPD, Revision 11, section 1.1.1.4, Communication and Interface Responsibilities, 

paragraph B; Appendix C, CBFO Organization, Responsibilities, and Interfaces

CBFO Organization Chart, dated 7/14/2014

5. Are the external interfaces between organizations, as well as the 

internal interfaces between organizational units, documented? Are 

interface responsibilities defined and documented?

Y QAPD, Revision 11, section 1.1.1.4, Communication and Interface Responsibilities, 

paragraph B; Appendix C, CBFO Organization, Responsibilities, and Interfaces

CBFO Organization Chart, dated 7/14/2014

*Y: The referenced documents adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 N: The referenced documents do not adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 I: EPA requires additional information to determine if the referenced documents adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 N/A: The specific NQA-1-1989 requirement is not applicable to the subject QA program.
EPA Audit of WIPP QA Program: CBFO QA F-1

ATTACHMENT F: ASME NQA-1-1989 CHECKLIST

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Basic Requirements

1. Is a documented quality assurance program planned, implemented 

and maintained in accordance with NQA-1?

Y QAPD, Revision 11, section 1.1.2.1, Quality Assurance Program Documents

2. Does the quality assurance program identify the activities and items 

to which it applies?

Y QAPD, Revision 11, section 1.1.2.2, Applicability of QAPD Requirements

3. Does the quality assurance program provide control over activities 

affecting quality to an extent consistent with their importance?

Y QAPD, Revision 11, section 1.1.2.3, Grading Items and Activities and Applying 

Management Controls

4. Was the quality assurance program established at the earliest time 

consistent with the schedule for accomplishing the activities?

Y QAPD, Revision 11, section 1.1.2.3, Grading Items and Activities and Applying 

Management Controls

5. Does the quality assurance program provide for the planning and 

accomplishment of activities affecting quality under suitably 

controlled conditions, which include the use of appropriate 

equipment, suitable environmental conditions for accomplishing the 

activity and assurance that prerequisites for the given activity have 

been satisfied?

Y QAPD, Revision 11, section 1.1.2.4, Planning Work, paragraphs E and G

CBFO Monthly Assessment Schedule, dated 7/8/2014

6. Does the quality assurance program provide for any special controls, 

processes, test equipment, tools and skills to attain the required 

quality and for verification of quality?

Y QAPD, Revision 11, section 1.1.2.4, Planning Work

7. Does the quality assurance program provide for indoctrination and 

training of personnel performing activities affecting quality?

Y QAPD, Revision 11, section 1.2.2, Training Requirements, paragraph A

TP 10.1, Revision 5, section 5.0, Procedure

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

8. Does the management of the organizations implementing the quality 

assurance program regularly assess the adequacy of that part of the 

program for which they are responsible and assure its effective 

implementation?

Y QAPD, Revision 11, section 1.1.1.3, QA Management

CBFO Monthly Assessment Schedule, dated 7/8/2014

Supplementary Requirements (2S-1)

1. Does the responsible organization designate those activities that 

require qualified inspection and test personnel and minimum 

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph A
EPA Audit of WIPP QA Program: CBFO QA F-2

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

requirements for such personnel? TP 10.1, Revision 5, section 5.0, Procedure

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

2. Has the responsible organization established written procedures for 

the qualification of inspection and test personnel to assure that only 

qualified personnel are permitted to perform inspection and test 

activities?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph A

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

3. Do personnel selected for performing inspection and test activities 

have the experience or training commensurate with the scope, 

complexity or special nature of the activities?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph A

Audit Report of SNL-CO Quality Assurance Program, Audit Number A-14-08, dated 

2/25–27/2014, performed by CTAC

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

4. Have provisions been made for the indoctrination of personnel 

regarding the technical objectives and requirements of the applicable 

codes and standards and the quality assurance program elements that 

are to be employed?

Y QAPD, Revision 11, section 1.2.2, Training Requirements, paragraph A

TP 10.1, Revision 5, section 5.0, Procedure

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

5. Has the need for a formal training program been determined? Are 

training activities, including on-the-job training, conducted to qualify 

personnel who perform inspections and tests?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph E

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

6. Are the capabilities of a candidate for certification initially 

determined by a suitable evaluation of the candidate’s education, 

experience, training and either test results or capability 

demonstration?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph F

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

7. Is the job performance of inspection and test personnel reevaluated 

at periodic intervals not to exceed three years?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph G

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record
EPA Audit of WIPP QA Program: CBFO QA F-3

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

8. If it is determined at any time that the capabilities of an individual 

are not in accordance with the qualification requirements specified 

for the job, is that person removed from that activity until such time 

as the required capability has been demonstrated?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph G

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

9. Is a person reevaluated for a required inspection or test capability if 

activities have not been performed in his or her qualified area for a 

period of one year?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph G

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

10. Is the qualification of personnel certified in writing in an appropriate 

form, including:

 Employer’s name?

 Identification of person being certified?

 Activities certified to perform?

 Basis used for certification, including:

– Education, experience, indoctrination and training?

– Test results, where applicable?

– Results of capability demonstration?

 Results of periodic evaluation?

 Results of physical examinations, when required?

 Signature of employer’s designated representative who is 

responsible for such certification?

 Date of certification and date of certification expiration?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph H

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

11. Has the responsible organization identified any special physical 

characteristics needed in the performance of each activity, including 

the need for initial and subsequent physical examination?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel,

paragraph I

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

12. Does the employer establish and maintain records of personnel 

qualification?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraph J

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record
EPA Audit of WIPP QA Program: CBFO QA F-4

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Supplementary Requirements (2S-2)

1. Does the quality assurance program provide for the qualification of 

nondestructive examination personnel to the American Society of 

Nondestructive Testing Recommended Practice No. SNT-TC-1A, 

issued June 1980?

Y QAPD, Revision 11, section 2.4.2, Qualification of Nondestructive Examination 

Personnel, paragraph A

2. Has the responsible organization established written procedures for 

the control and administration of nondestructive examination 

personnel training, examination and certification?

Y QAPD, Revision 11, section 2.4.2, Qualification of Nondestructive Examination 

Personnel, paragraph B

3. Does the employer establish and maintain records of personnel 

qualification?

Y QAPD, Revision 11, section 2.4.2, Qualification of Nondestructive Examination 

Personnel, paragraph C

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

Supplementary Requirements (2S-3)

1. Has the responsible auditing organization established the 

qualifications for audit personnel and the requirements for the use of 

technical specialists to accomplish the auditing of quality assurance 

programs?

Y QAPD, Revision 11, section 3.2.2.4, Auditor Qualification

TP 10.1, Revision 5, section 5.1, Technical Specialist Qualification; section 5.2,

Auditor Qualification; section 5.3, Lead Auditor Qualification and Certification;

Attachment I, CBFO Guide for Technical Specialists; Attachment III, Auditor 

Qualifications Documentation; Attachment IV, Example of Record of Lead Auditor

Qualification and Certification

CBFO Monthly Assessment Schedule, dated 7/8/2014

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record

2. Is the competence of audit personnel developed by one or more of 

the following methods:

 Orientation to provide a working knowledge and understanding of 

NQA-1 and the auditing organization’s procedures for 

implementing audits and reporting results?

 Training programs to provide general and specialized training in 

audit performance?

 On-the-job training, guidance and counseling under the direct 

supervision of a lead auditor?

Y QAPD, Revision 11, section 3.2.2.4, Auditor Qualification, paragraphs A–C 

TP 10.1, Revision 5, section 5.2, Auditor Qualification, section 5.2.1; Attachment III, 

Auditor Qualifications Documentation; Attachment IV, Example of Record of Lead 

Auditor Qualification and Certification

Technical Specialist Qualification Record

Lead Auditor Maintenance of Proficiency Record
EPA Audit of WIPP QA Program: CBFO QA F-5

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

3. Does a prospective lead auditor have the capability to communicate 

effectively, both in writing and orally? Has the lead auditor’s 

employer attested to these skills in writing?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph B, Lead 

Auditor Communication Skills

TP 10.1, Revision 5, Attachment IV, Example of Record of Lead Auditor 

Qualification and Certification

Lead Auditor Maintenance of Proficiency Record

4. Are prospective lead auditors trained, as necessary, to assure their 

competence in auditing skills, including training in the following 

areas:

 Knowledge and understanding of NQA-1 and other nuclear-related 

codes, standards, regulations and regulatory guides?

 General structure of quality assurance programs as a whole and 

applicable elements as defined by NQA-1?

 Auditing techniques of examining, questioning, evaluating and 

reporting; methods of identifying and following up on corrective 

action items; and closing out audit findings?

 Audit planning in the quality-related functions for the following 

activities: design, purchasing, fabrication, handling, shipping, 

storage, cleaning, erection, installation, inspection, testing, 

statistics, nondestructive examination, maintenance, repair, 

operation, modification of nuclear facilities or associated 

components, and safety aspects of the nuclear facility?

 On-the-job training to include applicable elements of the audit 

program?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph C, Lead 

Auditor Training

TP 10.1, Revision 5, section 5.3, Lead Auditor Qualification and Certification; 

section 5.5, External Lead Auditor Certification; Attachment III, Auditor 

Qualifications Documentation; Attachment IV, Example of Record of Lead Auditor

Qualification and Certification

Lead Auditor Maintenance of Proficiency Record

5. Is a prospective lead auditor required to have participated in a 

minimum of five quality assurance audits within a period of time not 

to exceed three years prior to the date of qualification, one audit of 

which shall be a nuclear quality assurance audit within one year prior 

to qualification?

Y QAPD, Revision 11, section 3.2.2.4, Auditor Qualification, section 3.2.2.6, Lead 

Auditor Qualification, paragraph A.2, Experience

TP 10.1, Revision 5, Attachment IV, Example of Record of Lead Auditor 

Qualification and Certification; section 5.3, Lead Auditor Qualification and 

Certification, section 5.3.3

Lead Auditor Maintenance of Proficiency Record

6. Is a prospective lead auditor required to pass an examination that 

evaluates his or her comprehension of and ability to apply the body 

of knowledge identified under the training requirements (listed under 

question 4 above)?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph D, Lead 

Auditor Examination

TP 10.1, Revision 5, Attachment IV, Example of Record of Lead Auditor 

Qualification and Certification; section 5.3, Lead Auditor Qualification and 
EPA Audit of WIPP QA Program: CBFO QA F-6

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Certification, section 5.3.4

Lead Auditor Maintenance of Proficiency Record

7. Do lead auditors maintain their proficiency through one or more of 

the following:

 Regular and active participation in the audit process?

 Review and study of codes, standards, procedures, instructions and 

other documents related to quality assurance program and program 

auditing?

 Participation in training programs?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph F, Lead 

Auditor Proficiency Maintenance

TP 10.1, Revision 5, Attachment V, Lead Auditor Maintenance of Proficiency 

Record

Lead Auditor Maintenance of Proficiency Record

8. Does management conduct documented annual assessments of lead 

auditors to extend their qualification, require retraining or require 

requalification?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph F, Lead 

Auditor Proficiency Maintenance

TP 10.1, Revision 5, section 5.4, Lead Auditor Annual Certification Evaluation, 

section 5.4.1

Lead Auditor Maintenance of Proficiency Record

9. Are lead auditors who fail to maintain their proficiency for a period 

of two years or more required to requalify?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph F, Lead 

Auditor Proficiency Maintenance

TP 10.1, Revision 5, section 5.4, Lead Auditor Annual Certification Evaluation, 

section 5.4.3

Lead Auditor Maintenance of Proficiency Record

10. Is the employer responsible for training auditors? Y QAPD, Revision 11, section 1.1.1.1, Management, paragraph C.1; Appendix D, 

CBFO Quality Assurance Manager Responsibilities

TP 10.1, Revision 5, section 4.2, CBFO QA Manager, section 4.2.1

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

11. Does the responsible auditing organization select and assign 

personnel who are independent of any direct responsibility for 

performance of the activities that they will audit?

Y QAPD, Revision 11, section 3.2.2.3, Audit Team Selection, paragraph A

MP 10.3, Revision 7, section 4.5, Audit Team Leader, section 4.5.2

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record
EPA Audit of WIPP QA Program: CBFO QA F-7

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

12. Does the lead auditor, prior to commencing the audit, concur that 

assigned audit personnel collectively have experience or training 

commensurate with the scope, complexity or special nature of the 

activities to be audited?

Y QAPD, Revision 11, section 3.2.2.3, Audit Team Selection, paragraph C

MP 10.3, Revision 7, section 4.5, Audit Team Leader, section 4.5.2

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

13. Is the employer responsible for the development and administration 

of the examination for a lead auditor? If the employer delegates this 

activity to an independent certifying agency, does the employer 

retain responsibility for the conformance of the examination and its 

administration to the NQA-1-1989 standard?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph D, Lead 

Auditor Examination

TP 10.1, Revision 5, section 4.0, Responsibility; section 4.2, CBFO QA Manager, 

section 4.2.3; section 5.3, Lead Auditor Qualification and Certification, section 5.3.4

Lead Auditor Maintenance of Proficiency Record

14. Does the employer establish and maintain records of personnel 

qualifications for auditors and lead auditors performing audits?

Y TP 10.1, Revision 5, section 4.0, Responsibility; section 4.2, CBFO QA Manager, 

section 4.2.4; section 6.0, Records

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

15. Does the employer certify each lead auditor as being qualified to 

lead audits, including documentation of the following by the 

certification:

 Employer’s name?

 Lead auditor’s name?

 Date of certification or recertification?

 Basis of qualification (i.e., education, experience, communication 

skills, training, examination, etc.)?

 Signature of employer’s designated representative who is 

responsible for such certification?

Y QAPD, Revision 11, section 3.2.2.6, Lead Auditor Qualification, paragraph E, Lead 

Auditor Certification

TP 10.1, Revision 5, Attachment IV, Example of Record of Lead Auditor 

Qualification and Certification; Attachment III, Auditor Qualifications 

Documentation

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

16. Are the records for each lead auditor maintained and updated 

annually?

Y TP 10.1, Revision 5, section 5.4, Lead Auditor Annual Certification Evaluation, 

section 5.4.2

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

Supplementary Requirements (2S-4)

1. Are personnel identified for indoctrination or training? Y QAPD, Revision 11, section 1.2.2, Training Requirements, paragraph A; section 

2.4.1, Qualification of Inspection and Test Personnel, paragraph C
EPA Audit of WIPP QA Program: CBFO QA F-8

NQA-1 ELEMENT: No. 2 with Supplements 2S-1, 2S-2, 2S-3 and EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

2S-4, Quality Assurance Program

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

2. Is the extent of indoctrination and training commensurate with the 

following:

 The scope, complexity and nature of the activity?

 The education, experience and proficiency of the person?

Y QAPD, Revision 11, section 2.4.1, Qualification of Inspection and Test Personnel, 

paragraphs C and F

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

3. Are personnel indoctrinated in the following subjects as they relate 

to a particular function:

 General criteria, including applicable codes, standards and 

company procedures?

 Applicable quality assurance program elements?

 Job responsibilities and authority?

Y QAPD, Revision 11, section 1.2.2, Training Requirements, paragraphs A and B; 

section 2.4.1, Qualification of Inspection and Test Personnel, paragraph C 

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

4. Is training provided, if needed, to:

 Achieve initial proficiency?

 Maintain proficiency?

 Adapt to changes in technology, methods or job responsibilities?

Y QAPD, Revision 11, section 1.2.2, Training Requirements, paragraph A 

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

5. Do records of the implementation of indoctrination and training take 

the form of:

 Attendance sheets?

 Training logs?

 Personnel training records?

Y QAPD, Revision 11, section 1.2.2, Training Requirements, paragraph C

Lead Auditor Maintenance of Proficiency Record

Technical Specialist Qualification Record

*Y: The referenced documents adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 N: The referenced documents do not adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 I: EPA requires additional information to determine if the referenced documents adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 N/A: The specific NQA-1-1989 requirement is not applicable to the subject QA program.
EPA Audit of WIPP QA Program: CBFO QA G-1

ATTACHMENT G: ASME NQA-1-1989 CHECKLIST

NQA-1 ELEMENT: No. 16, Corrective Action EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Basic Requirements

1. Are conditions adverse to quality identified promptly and corrected 

as soon as practical?

Y QAPD, Revision 11, section 1.3.3.3, Conditions Adverse to Quality, paragraph B; 

section 1.3.3.7, Corrective Action Follow-up; section 1.3.3.9, Quality Trending, 

paragraph B

MP 3.1, Revision 12, Corrective Action Reports, Attachments I–IV.

EPA Concern No. CBFO-QA-2013-03C

Memorandum dated 8/7/2012, Interim Change Notice No. 1 to CBFO Management 

Procedure 3.1, Revision 12, Corrective Action Reports

Memorandum dated 9/4/2013, Interim Change Notice No. 2 to CBFO Management 

Procedure 3.1, Revision 12, Corrective Action Reports

2. In the case of a significant condition adverse to quality, is the cause 

of the condition determined and corrective action taken to preclude 

recurrence?

Y QAPD, Revision 11, section 1.3.3.4, Significant Conditions Adverse to Quality; 

section 1.3.3.5, Corrective Action Planning, paragraphs C and D

MP 3.1, Revision 12, section 5.3, Corrective Action Plan; section 5.4, Corrective 

Action Plan Evaluation; Attachments I–IV

CAR Nos. 13-042 and 14-009

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013

Listing of CBFO CAR Trend Codes

3. Are the identification, cause and corrective action for significant 

conditions adverse to quality documented and reported to 

appropriate levels of management?

Y QAPD, Revision 11, section 1.3.3.4, Significant Conditions Adverse to Quality, 

paragraph B

MP 3.1, Revision 12, section 5.1, Corrective Action Report Initiation: CBFO QA 

Director; section 5.2, CAR Issuance: CBFO QA Director; section 5.9, Evaluation of 

Impact for CARS Requiring Accelerated Corrective Action

CAR Nos. 13-042 and 14-009

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013
EPA Audit of WIPP QA Program: CBFO QA G-2

NQA-1 ELEMENT: No. 16, Corrective Action EPA AUDITORS: L. Bender, D Gill, K. Darlow, K, Lindblad DATE: July 2014

Does the reference document adequately define, describe, address or 

satisfy the following:

Y, N, I, 

N/A* Applicable Procedure and Paragraph; Additional Objective Evidence

Listing of CBFO CAR Trend Codes

4. Is follow-up action taken to verify implementation of corrective 

action?

Y QAPD, Revision 11, section 1.3.3.7, Corrective Action Follow-up

MP 3.1, Revision 12, Corrective Action Reports, section 5.6.1, paragraph A

CAR Nos. 13-042 and 14-009

CBFO Semi-Annual CAR Trend Report, dated 3/5/2014

Listing of CBFO CARs issued in the past 12 months (since June 2013)

Listing of CARs still open as of 7/18/2014

6 month CAR Trend Report for July thru December 2013

Listing of CBFO CAR Trend Codes

Supplementary Requirement – None 

*Y: The referenced documents adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 N: The referenced documents do not adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 I: EPA requires additional information to determine if the referenced documents adequately define, describe, address or satisfy the NQA-1-1989 requirement.

 N/A: The specific NQA-1-1989 requirement is not applicable to the subject QA program.