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 Org anization, 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, date d 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 7/8/2014E

- 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 Q uality 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 Month ly 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 indivi duals 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; Ap pendix D, CBFO Quality Assurance Manager Responsibilities; Appendix E, TRU Waste Characterization and Certification Organizational andE

- 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 Respo nsibilities Safety Management FRAM, Revision 2, section 4.0 CBFO TP 10.2, Revision 5, Qualification of Au dit 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 As sessment 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 Int erfaces; 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 Notice s 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 De cember 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, Responsibilit ies, 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, Rev ision 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 d efine, 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 Assess ment 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 AEPA 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? T P 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 a ssure 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 Ins pection 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 Require ments, 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 Pro ficiency 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 RecordEPA 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 certificat ion 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 RecordEPA 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 writt en 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
, Rev ision 5
, s ection 5.1

, Technical Specialist Qualification; s ection 5.2

, Auditor Qualification; s ection 5.3

, Lead Auditor Qualification and Certification ; Attachment I

, CBFO Guide for Technical Specialists ; Attachment III

, Auditor Qualifications Documentation ; Attachment IV

, E xample of R ecord of L ead A uditor Q ualification and C ertification 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 Qua lification, 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 RecordEPA 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 guide s?

 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 clos ing 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 examinatio n, 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, Rev ision 11, section 3.2.2.6, Lead Auditor Qualification , paragraph C
, Lead Auditor Training TP 10.1, Rev ision 5, section 5.3, Lead Auditor Qualification and Certification;

s ection 5.5

, External Lead Auditor Certification; Attachment III

, Auditor Qualifications Documentation ; Attachment IV

, E xample of R ecord of L ead A uditor Q ualification and C ertification 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 exce ed 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, se ction 3.2.2.6, Lead Auditor Qualification, paragr aph 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 andEPA 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 oth er 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 Rec ord

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 Rec ord

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 Ma intenance of Proficiency Record Technical Specialist Qualification Record

11. Does the responsible auditing organization select and assi gn personnel who are independent of any direct responsibility for performance of the activities that they will audit? Y QAPD, Rev ision 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 Ma intenance of Proficiency Record Technical Specialist Qualification RecordEPA 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, Au dit Team Selection, paragraph C MP 10.3, Revision 7, section 4.5, Audit Team Leader, section 4.5.2
Lead Auditor Ma intenance 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 respo nsibility 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, paragr aph D, Lead Auditor Examination TP 10.1, Revision 5, section 4.0, Responsibility; se ction 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 Ma intenance 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, ex perience, 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, paragrap h 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 Reco rd

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 CEPA 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 Rec ord 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, Rev ision 12, Corrective Action Reports
Memora ndum dated 9 /4/2013, Interim Change Notice No. 2 to CBFO Management Procedure 3.1, Rev ision 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 P l an 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 t hru 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 Impa ct 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 2013EPA 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, R evision 11
, s ection 1.3.3.7

, Corrective Action Follow

- up MP 3.1, Rev ision 12, Corrective Action Repo rts, 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 requirem ent is not applicable to the subject QA program.