ML20206M668

Documents Observations Made During Science Applications Intl Corp QA Audit of Nnwsi Activities at USGS in Denver,Co on 860310-14.Supporting Documentation Encl

ML20206M668
Person / Time
Issue date:	06/02/1986
From:	Bilhorn S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Linehan J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20206M614	List: ML20206M608 ML20206M668
References
REF-WM-1 NUDOCS 8607010252
Download: ML20206M668 (86)

Text

. . Kne.t;esure t 8 '% UNITED STATES 8 i NUCLEAR REGULATORY COMMISSION g j WASHINGTON, O. C. 20555

%, ,d' JUN L 2 1966 MEMORANDUM FOR: John J. Linehan, Acting Chief Repository Projects Branch, DWM THRU: James E. Kennedy, Section Leader Repository Projects Branch, DWM FROM: Susan G. Bilhorn Repository Projects Branch, DWM

SUBJECT:

REPORT OF OBSERVATIONS MADE DURING SAIC QA AUDIT OF NNWSI ACTIVITIES AT USGS, DENVER MARCH 10-14, 1986 The purpose of this note is to document my observations regarding the subject audit. The audit plan, including scope, schedule and audit team, are attached as Enclosure 1.

~, The USGS is the NNWSI Project participant responsible for most of the geology.

and hydrology site investigations. SAIC is the contractor for NNWSI providing QA support to the project. The audit team conducting this audit was comprised of SAIC personnel and one participant from DOE headquarters.

Summary:

1. The audit team recommended USGS stop work on NNWSI activities because of significant problems,found in numerous areas of the USGS QA program.

- The SAIC/NNWSI audit team recommended a stop work order on NNWSI activities at USGS due to the number of significant problems found in the USGS QA program. USGS issued its own stopwork order at the conclusion of the audit, 3/14/86 (Enclosure 2). This order stops essentially all NNWSI technical activities performed by the USGS except: SCP and Exploratory Shaft Test Plan development; work, the suspension of which would cause unrecoverable loss of information; and research and testing to develop and/or evaluate techniques or procedures to be applied later under appropriate QA. USGS committed to making the necessary' improvements to the QA. program concentrating first on upgrading the QA plans for those activities which had net been stopped.

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- NNWSI followed-up with an additional stopwork order which also required USGS to submit a plan of action, including milestones and schedules, for upgrading the QA program (see Enclosure 3).

2. This SAIC audit was an improvement over those previously observed, particularly with regard to preparation and conduct, however there still appears to be too much emphasis on compliance versus technical adequacy and better preaudit planning is necessary (see discussion under "The Audit").

The Audit:

1. Preparation -

A. The SAIC audit team was better prepared for this audit than for those audits I observed in 1985. Most team members were aware of USGS QA program and ongoing technical activities. Most were also familiar with the checklist covering their areas of responsibility. In addition, the checklist was tailored to the USGS program, with emphasis on problem areas that had been identified during SAIC's prior review.

B. Two checklists were prepared for this audit; a programmatic and a technical checklist. The programmatic checklist focused on the 18

. criteria of hQA-1, while the technical checklist focused on site investigation plans, peer / technical reviews, and technical procedures.

$ C. Coordination between SAIC and USGS prior to the audit was lacking.

Audit interviews had not been arranged (schedules and individuals)

. prior to the preaudit meeting therefore last minute arrar.gements and l adjustments were necessary. l O. USGS had verbally requested this audit be postponed. The audit schedule conflicted with a perfcrmance allocation meeting and '

development of work plans, While the availability of USGS people

(i.e., Principal Investigators) was not a difficulty, the potential )

problem did exist and such potential conflicts would best be resolved  ;

. prior to start cf the audit. In addition, based on SAIC review of the QA manual, the USGS QA program had alret.dy been fcund sericusly deficient. SAIC had cited many of these ceficiencies in a meeting with USGS in January, 1986.

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2. USGS Involvement -

J. Wilmon, the USGS/NNWSI QA manager was the prime USGS interface. Others involved in QA activities for USGS/NNWSI who participated in the audit were: Susan Shipley (USGS, Menlo Park QA lead); Darrell Porter (SAIC, Golden-QA contract support); Gene Rush (USGS); Paul Carrera (USGS geologist temporarily assigned as QA support); and a representative from-Los Alamos QA support. In addition, Robert Peterson frem.the Bureau of Reclamation (BOM) participated as an observer. Mr. Peterson is the QA -

lead for the NNWSI work recently delegated to BOM.

In the entrance meeting J. Wilmon presented a summary of the areas he dCknowledged as deficient (Enclosure 4). Though unusual this did indicate an understanaing of the problems involved.

3. Conclusion -

A. The audit was highly compliance-oriented in spite of the inclusion of technical team members and reviews of technical activities (see Enclosure 5 as illustration). This differs from the NRC approach to inspections and audits (such as IDI's) which focus more on the cuality of technical work than on compliance with QA procedures.

B. In Wednesday's close-out session, during which that day's observations and findings were discussed, the team unanimously concluded that there were enough significant findings to merit a stopwork order. The audit continued until protocol for the stopwork order was decided and initiated by the appropriate individuals.

Thursday evening the audit was ended prior to completion of the checklist. The Menlo Park extension of the audit was also canceled at this time.

J. Blaylock, the WMPO QA manager, and E. Cocorus, SAIC QA lead, flew in for consultatien and to attend the exit interview.

C. The audit report contains 23 findings (Enclosure 5). The primary problem areas associated with these findings are summarized below.

1. Control of purchased materials and services Procurerrent documents Contractor QA rec,uirements

g 2. Control of test samples

3. Audits Qualification of auditors Corduct and planning of external aucits Resolution of internal audit results 4 Calibration of measuring and test equipment

5. Indoctrination, training and certification of persons involved in technical ana QA activities

6. Stopwork provisions and precedures '

7. Respcosibility and authority of USGS organizations involved in NNWSI, including QA department

8. Core library and core sample procedures

9. Peer review records

10. Planning of site investigations

11. Assignment and approval of QA levels D. 0GR issued a report regarding the subject audit on April 4, 1986 (Enclosure 6). To clarify a comment documented in this report (page 2, paragraph 7), I stated at the exit meeting that this represented the best prepared audit that I had observed SAIC conduct for NNWSI to date.

Concerns:

1. USGS admitted that staff size of the QA organization was not adequate.

This has apparently been due to administrative difficulties and has not received the necessary management attention. Management support was committed by USGS and NNWSI during the close-out meeting. As follow-up, NNWSI has temporarily assigned one SAIC person (N. Voltura) to USGS to support their current efforts.

2. The recommendation for stopwork was anticipated by USGS to the point that a partial order had been previously drafted. If USGS was aware that problems in the QA program were bad enough to merit a stopwork order, it seems an audit should not have been necessary to cause its issuance.

3. The conditions which merit issuance of a stopwork order en repository activities during prelicensing have not been defined. Also the method, authority and responsibility for recommending a stopwork order based on audit findirgs are not in place, especially for audits conducted by a contractor, such es SA;C.

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{ L t 4. A potential problem with independence from cost and scheduling was apparent regarding audits conducted by contractors such as SAIC. In spite of the uncertainty associated with a first time recommendation of a stopwork order, I believe that the SAIC audit team gave undue attention to what they thought SAIC management and NNWSI would want to hear. In adcition, the lead auditor was concerned about contacting the NLiSI QA manager to discuss the situaticn. I consider that if contracting organizations such as SAIC are to function as " extensions of project staff" in the area of 0A, that they should feel free to act with project authority and exhibit the necessary indeper.dence from cost and scheduling.

5. Core handling and storage problems continue to exist. NhWSI has classified core handling (especially waxing) as a special process as defined in 10 CFR 50 Appendix B which requires application of extra QA measures, but USGS insists core handling can be adequately performed under a nomally controllad technical procedure. In addition, NNWSI insists that USGS manage the core library though USGS has requested NNWSI make alternate arrangements. ,

6. One reason USGS issued an internal stopwork order was to control what activities could continue. Continuation of SCP activities is of concern since perscns needed in the QA improvement efforts will be largely unavailable if working on the SCP and the SCP is a critical piece of work

, that needs adequate QA. It appears the schedule for issuance of the SCP is still a number one priority for NNWSI.

Observations:

1. NNWSI and 00E HQ attribute the term " technical audit" to NRC (initiated by NRC at the site visit, December 1984). NNWSI has been pushed, therefore, to conduct such audits but has been given little direction as to the definition or intent of the term. This has generated numerous interpretations and much confusion. NRC's intent should be clarified.

2. NRC staff have noted that the scope of the audits conducted by DOE /00E projects have been tco optimistic in that they attempt to cover all 18 criteria in less than 4 days. NNWSI has apparently interpreted this to

mean that they need only evaluate the criteria which most directly affect the quality of work performed by each contracter ar.d not audit against all 18 criteria stated in the rcquirements. The intent was, however, that the F

t adequacy of QA be evaluated as necessary to determine compliance with the requirements. In order to ccnduct an adequate evaluation audits may need to be longer or divided into parts. In addition, regular surveillance and

, review should indicate areas which need greater or lesser attention during audits.

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Susan G. Bilhorn Repository Projects Branch Division of Waste Management

Enclosures:

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1. Audit Plan

2. USGS Stopwork Order

3. NNWSI stopwork order on USGS

4. USGS Summary of Deficient QA Program Areas -

5. Audit Report

6. Report of OGR Participation in WMPO QA Audit of USGS Denver cc:0. Hedges 6

u. uinanon M. Bell R. Browning P. Prestholt B. Grimes H. Miller T. Ankrum

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NNWSI AUDIT PLAN 86-2A - DENVER 1

Audit No. 86-2a Date 2/18/86 1.0 SCOPE The purpose of this audit is to evaluate the effectiveness of the (USGS)

Denver, CO Quality Assurance Program Plan and its procedures with respect to the requirements of NNWSI NVO-196-17 (Rev. 3) and to verify the effect_ivengg,s and isolementation of (USGS) technical procedures associated with NNWSI activities. /

2.0 ORGANIZATION TO BE AUDITED United States Geological Survey (USGS) Denver, CO 3.0 AUDIT SCHEDULE o Pre-Audit Team Meeting, 1:30 p.m., March 10, 1986 at USGS o Opening Meeting, 9:00 a.m., March 11, 1986 at USGS o Audit Activities, March 11-14, 1986 o' Closing Meeting, Af ternoon of March 14, 1986 or before 4.0 REOUIREMENTS TO BE AUDITED The requir'ements to be audited are stated in 86-1-1 check list which was generated from the following documents:

o NNWSI-NVO-196-17-Rev. 3 o USGS QA Manual and implementing quality and technical procedures  ;

o Previous Audie 85-12 .-

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'5 . 0 ACTIVITIES TO BE AUDITED o Programmatic QA areas o Technical detailed procedures o Previous audit findings 6.0 AUDIT TEAM MEMBERS S. Singer, SAIC/QASC Lead Auditor

• N. Voltura, SAIC/QASC Auditor J. W. Estella, SAIC/QASC Auditor R. F. Cote, SAIC/QASC Auditor in Training F. D. Peters, SAIC/QASC Auditor in Training E. R. Oakes, SAIC/QASC Technical Advisor D. C. Newton, DOE /HQ Auditor in Training Paul Prescholt, NRC/HQ Observer Susan Bilhorn, NRC/HO Observer i

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I WMP0 AUDIT PLAN NO. 86-2A USGS DENVER COLORADO

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PREPARED BY M SAIC/QASC DATE o7[/F//d APPROVED BY

_ bb)= d WMPO PQMG DATE 2- //T/r4 DISTRIBUTION:

All Team Members -

S. B. Singer, SAIC/QASC, Las Vegas, NV N. A. Voltura, SAIC/QASC, Las Vegas, NV

- J. W. Estella, SAIC/QASC, Las Vegas,flV R. F. Cote, SAIC/QASC, Las Vegas, NV F. D. Peters, SAIC/QASC, Las Vegas, NV E. H. Oakes, SAIC, Oak Ridge, TN

0. C. Newton, 00E/HQ Paul Prestholt, NRC/HQ Susan Bilhorn, NRC/HQ Project File

Record Center L

NNWSI AUDIT PLAN 86 MENL0 PARK Audit No.96-11s Date 1/r e/ T6 1.0 SCOPE The purpose of this Audit is to verify by review of objective evidence the effective impl ementation of the Quality Assurance Program Plan as implemented by USGS at the Menlo Park, California facility.

The USGS QA program will be reviewed to assure that the requirements of NV0-196-17 (Rev. 3) and selected USGS technical procedures are being implemented in accordance with the provisions of the NNWSI Project.

2.0 ORGANIZATION TO BE AUDITED United States Geological Survey (USGS) Menlo Park, California 3.0 AUDIT SCHEDULE o Pre-Audit Team Meeting,1:30 p.m., March 17, 1986 at USGS .

o Opening Meeting, 9:30 a.m., March 18, 1986 o Audit Activities, March 18-21, l986 o Closing Me'eting, Afternoon of March 21, 1986 or before 4.0 REQUIREMENTS TO BE AUDITED -

The requirements to be audited are stated in 86-28-1 checklist wnich was generated from the following documents: -

o NNWSI-NV0-196-17-REV. 3 o USGS QA Manual and implementing quality and technical procedures 5.0 ACTIVITIES TO BE AUDITED o Technical detailed procedures o Previous audit findings 6.0 AUDIT TEAM MEMBERS A. E. Cocoros SAIC/QASC Lead Auditor F. O. Peters, SAIC/QASC Auditor in Training / Technical Advisor E. A. Oakes, SAIC Auditor / Technical Advisor s

A. J.'Rhodrick, 00E/HQ AIT/ Technical Advisor Paul Prestholt, NRC/HQ Observer J. R. Rinaldi. QAD, 00E/NV Auditor 7.0 AUDIT CHECX LIST NUMBERS 86-28-1

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WMP0 AUDIT PLAN NO: 86-28 USGS MENLO PARK, CALIFORNIA PREPARED BY / o DATE Jlt /f/f4 SAIC/Q#5C APPROVED BY hWMP0/PQM 3b 0 DATE 2.// t /%

, DISTRIBUTION:

All Team Members A. E. Cocoros, SAIC, QASC, Las Vegas, NV F. D. Peters, SAIC, QASC, Las Vegas, NV E. H. Oakes, SAIC, Oak Ridge, TN A. J. Rhodrick, 00E/HQ Paul Prestholt, NRC/HQ J. R. Rinaldi, QAD, 00E/NV Project File Record Center O

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United States Department of the Interior

_. j GEOLOGICAL SURVEY v.s. m Box 25w.

DENVER FEDERAL CENTER DENVER. COLORADO $0225 IN REPLY LIFER TO:

March 14, 1986 Memorandum To: All USGS Participants, Nevada Nuclear Waste Storage Investigations From: Chief, Branch of Nevada Nuclear Waste Storage Investigations

Subject:

STOP-WORK ORDER This orders the inanediate cessation of most USGS work on NNWSI technical activities. The order applies to all work that meets all of the following three criteria:

(1) The work is intended to produce site-characterization information - that is, a description of the geologic, tectonic, or hydrologic conditions or processes of Yucca Mountain and its setting.

(2) The work has no*. previously been approved in writing by this office and by DOE /WMPO as quality-assurance level III.

(3) The work can be suspended without causing an irrecoverable loss cf infor: nation that may later prove to be acceptable in the licensing process.

Work may continue in the following categories:

(1) Administrative work, with the exception of procurement of i equipment, materials, or supplies to be used in site-characteei- l zation activities.

, (2) Planning, both internal and as part of the preparation of DCE documents such as the Site Characterization Plan and the -

Exploratory Shaft Test Plan.

(3) Work for which the suspension would cause an irrecoverable loss of information. Examples are the seismic -monitoring network, monitoring of existing hydrologie networks, logging of neutron holes, monitoring of runoff events, etc.

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s e l (4) Work in progress on degradable samples or features. Examples include mapping of freshly exposed trench walls (but not sampling of materials for analysis), long-term laboratory tests or experi-monts in which substantial time and cost is already invested, and )

laboratory measurements on " natural-state" samples that would degrade if the measurements were interrupted.

(5) Preparation of publications presenting site-characterization information, but o_n.ly nl to the point of readiness for colleague review.

l (6) Preparation and processing of abstracts for meetings if the submission deadline is July, 1986, or earlier.

(7) Prototype testing, experimentation, and other research intended to develop and/or evaluate techniques or procedures to be applied later under quality-assurance requirements.

(8) All work directed at implementing the requirements of the USC3 Quality Assurance Plan (QAP).

Othee activities that must continue will be considered but must be authorized by this office.

Except for those working on the FY 88 budget preparation, the Site Characterization Plan, or the technical requirements for the exploratory-shaft facility, implementing the QAP is the highest priority of the USGS/

NNWSI at this time. Personnel should be redirected to QA implementation to the fullest extent possible. those performing exempted work should also be redirected to the QA effort unless the work is of great urgency.

At this time I am not prepared to give specific instructions concerning contracts in place, as this requires coordination with Administrative Division personnel. Branch Chiefs. District Chiefs, the Regional Research Hydrologist (Central Region) or their administrative officers are requested to notify R. V. Watkins, Associate Chief, Branch of NNWSI, by memorandum of contracts that are supported wholly or in part by NNWSI funds. Please include a sufficient description of the scope of work to allow a preliminary determination of whether the ticek can continue, must be negotiated for temporary redirection, or must be suspended.

I have taken this action in consultation with and upon the recommendation of the USGS/NNWSI QA Manager, Joe Willmon, because of rapidly accumulating evidence that our implementation of our QAP has not been given the priority that it requires. A DCT audit completed today in Denver has confirmed the lack of satisfacecry implementation in the activities directed by my office as well as in the scientific work. We are all at f ault, and we must 411 contribute to the remedy. Identifica-tion of specific areas in which we must change or improve will be provided as soon as possible.

Assistant Director James F. Devine and NNWSI Project Manager Donald L., Vieth have been advised of and concur with the necessity for this order.

o 9 Neither the timing nor the mechanism of release from this order have been identified. However, I anticipate a task-by-task release, probably after special audits of readiness. I also anticipate that the period will range from several weeks to several months.

NNWSI funding will continue for work authorized in this memorandum or subsequently authorized in writing by me or Joe Willmon. Work that is performed in violation of this order will not be reimbursed feca NNWSI funds. Documentation of personnel activities on NNWSI funding is required as of March 17, 1986. More detailed instcuctions will be issued next week.

h Y- h I William W. Dudley Jr.

cc: J. F. Devine, Asst Director, Engineering Geology

• D. L. Vieth, Director, Waste Management Project Office, DOE WD/ pub 0761P O

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Technical Project Officer Apg28lut D. S. Coelegice! Servey 4

P. O. Aos 25044 Mail sees 418

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(U8CS) 14Htt 810RAct INetSTTCAT!cers OFFICE (91050)

(14tPO ACTION ITDI #86-!!6S (NNWSI) 7tOJECT NUCf. EAR WASTR MANACUSNT FROJRC7 ACTITITIES F

Serve 111eeee 14tP0/Wp=eIHed=013 - condotted NWW81 Projoes. e-and QA on the regard to QA et the USCg'.to erte that support the I tese terme 11y espreso ey eseeeree about the ettnet .

It has been reported to se ther the studies USC8 tacheical staff, people she are esenttted"to esecuttaa actestifie , have not eehieved elearly a USGS a tuli appreetettee mesegeneet prehlen.of the taperteese of QA ce thte .

progree. This le espeeditores to oestefy ser stenderde. the pesettee of QA et the USGS bee set reached the lA would sees the F. 3. Inselaer Engolatory Counteatem's especestfees. *

(Nitc) Aloe, l I have teeteved year essersedies euepending eerk audit.

persweet at the USGS to the to i

Tout settese are a peettive semagemeet etee necessary i 1eng=cesading ergesteettesel defietemetes et the USC3 estreet in theth ,

Se believe that year supedittene acties to this ar e preettee of 4A.

es see essential te

• withie the USGS, and a resolve teuerd soottag eestemory to the regolatory armee.

e problem the reget e sets that are folly eederstead the siteetien, esault to meetles the regelrIt te eseeettel to the preemos as defined to year internet operatiam emente, and confers 1eagee est pleee in thte Project for e esteetific sammale. staff There that le ne d

• med perfees le eseerdseee eith the regoiremente eee estestablishedaseept ter QA i ise have opent seee time reetowing the etteettee with l tshile se sto genere11y te agresseet with year athe , step teerk order.

additteest stapelatione need to be added to your directivepproach, we believ '

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(- thte some le to seasseee the telFO euepeestem of ce. t The perpeee of

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• Frejeet Office (lefro) to reviewing the sort .

- _a siteetion bet ere it le resteered.

This enspeestas of seek applies te g U90s mort terrentl she NIust Projeeg eith the felleutes eseopetemes y beleg pertermed for

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'Serectorisation Plan (SCP), the tuploretary Shaf t "Metropeental Assessment (IA), and the S l the Site

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. an (PSTP). the e ente Tectonic Poettien Paper 9 s e :utsent, esteriale, suppliesMaintetretive/seneseeent work, with the exce ocurement of '

d non technitel activittee ellowed to continue.det171 eel to the succese for concorrence prior to proceenfine.:Mc'.edian v edthe quality requ to torpo ,

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AMor*m ution. *or which the suspension would cause en irrecoverable l ess of

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Work to progrees on degradable esmoles or feetweee and l h A suremente tnre interrested.os " natural-etate* semples that woeld destede e eretory if th e messeressets 3.

deed 11ne le July 1946 or earlier. Preparation and processin6 of sket e embeleases filentified and the pertinent information, inclisding mengeweThese ebetr r researcos evaluation of the tapact on resources required the QA Program. for te ach 1 emeetattee of 6

Pfototype testing, esperimentatten develop and/or eveleste techetgeee or p,recedures provided theand othe have been esproved by 14fPO ae Quality Assurance se1.evel estivittee III these settettice uset not prevent adequate seaposer r. Castimonees af applied to the implenestattee of the OA Progree regettementeese=rees free

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All work that te necessary to achieve adequate imelmee t USCS OA Progree, i.e. procedere development, s ationestablishment of the of Q 14 vel assignmeste, correction of QA Progree deffeteestee , etc.

aality Aeoerence This seepeestes of vert else applies to InfWS! Project relat d eerrently sleetly seempted botesasperfassed for USGS described above. by sabeoetreeters e settwities w1ees the eerk een be

• sseetfie estivities in these ceteseriesa orsesothere th t U otroenly be11swee working Inclede the followingt doye after reestys of this letter.should be ellowed witham 10 to es The inteveettom to be provided sees .

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Iterk1pel Sreshdese revoettaater Strettere (WBS) teek etitle and seeser e Jeetitiesties/rettenele of why the work meet proceed

! Coetrels/procedores reqstremente. to be used to essere the date moete QA progree s, .

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'Wesentation Troject at this tise. of OA Prottram requirements eted, echievistto thPreept edeewete 52ementattoo to the fulleet eittent poseih1e. Personnel should M 'evelop a plan for the meetsnament and escrevel of QAccordingly, yev S--5nt:e agreed to duties the ovelity Assurance o e the swpport L "ancop 4711 2, 9meetints and 10,1986, et Science Applications Internettonel cansent Sheet (0A m' Ntified rerme.durir2 USCS Audit 66-2e no thatand a plan forrogram correcting the CA Porp deficionetes MM113h priorities, and provide a schedule omplished, for inplThis n>c21d be pieced on correcting the deficiencies ementation.

in thoseSephaele ste allmd to continue, i.e. establiotetent of Quality Assurance es where workLto qualifitetton and certification of personnel, todoctrinati evel asettnoente, on end treteing, etc.

Muld es seted that WMPO stil perform es of Uscit periodic su. It ce ploted and to evaluete progress relative e actione are to QA P o ementattee.

The cenditions for lifting this suspenelon are se owes foll 1.

inclementation for the reported audit findings. schedules forApproval by 2.

es a result of the medit.Approeel by WMPO of the USGS Quality Aeoorence

• ee (QAPP) reefsed 3.

Ceeplettee of indoctrinetton end traioins for achieving quality with the NNWSI prograret of all USC8 personeel reopensible 4

ectivity for which USC8 is roepenelble.EMP0roject approval itse/ of Qualit WMP0 approval of e USCE plan to provide reso vertous leestfees venere USCS is performing ongoing NNWWI Pr jurces o ect activities.

At the complettee of all of the above conditione ae fore l of the seepsmetes will be 1sseed to CSCS by I4fPO. removal, le writing, 86-2a, it le evident that the USC$ ented eQA uringstaff trith 0908 Aedit euet be o additteest the esperienced pitc3 m Prestras QAProjoet.

fee the NNWE! pereennel to order to eenere promet la l achievieg this geel to clearly required, As esenttigated essettuneet top ementattee of forther tefossettee, please advise. if yee have soy gesettene, or regelre unPoa>#st i. huse1. yhe WN com 14 1 vteen, nareetee Weste " ; ~. Projoet office

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?. C. Newton, DOE /RQ (RW23) FORA Jees In13 t,h DCE/MQ (RW23), FORS t.tlen Jelacic, DOE /MO (RW24) Fests J. R. *>1llroon, (TSC1, Denver 00 P.

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• 1 IMPLEMENTATION OF THE QA MANUAL NNWSI-USGS 0A PROGRAM 1.01 Manual Upgrade / Maintenance: The manual is not yet complete with at least 4 to 6 additional chapters to be added soon. The existing chapters are subject to revision which should occur semi-annually, at least for the first year. The first revision should be planned for the end of the second quarter, FY 86.

2.01 Management Assessment: This takes place once per year, and requires gathering the essential documents to provide for the review. In the view of QA, this is an important step and cannot be taken lightly as it affects the program's credibility. Action on this element should be directed toward the end of the year.

2.02 Indoctrination / Training: This consists of familiarizing the program participants of the QAand ling laws, documents, requirements implementingthrough exposure procedures. to the control A program of , hJ

• required reading, and meeting presentation should be made to all '

participants for ccmpletion within a six-month period.

2.03 Worker Certification: It is required that evidence of a worker's credentials be retained as accredited by a more senior Program participant. This can be accomplished by ecmpleting tne form as presented in procedure NWM-USGS-QMP-2.03. A system for assuring

.ccmpletion of this task and its required updating needs to be put into place. This should begin at once, and six months seems to be a reasonable time to accomplish it.

3.01 Levels Assignment: All activities or items concerning quality 5 3.02 related work are required to have an assigned quality level. By the -

procedure, this level assignment is to be done by the Principal Investigator under the assurance responsibilities of the QA office. ..

Experience has already shown that this element of the PI's work will '

require a significant amount of assistance from the QA office. This is envisioned as being a continuing task with the heaviest QA involvement at the front end, which may strain the manpower resour- ,

ces for a short period. Because of the retrofit necessity, this task must' begin at once.

3.03 software QA: This is another item assigned to the Principal Invest -

igator. However, it will require surveillance and assistance for C ',

implementation. The implementing procedure remains to be written for s this criteria, awaiting the issuance of the Project SOP.

4.01 Procurement Occument Control: All procurement must be done under QA procedures according to the QA Manual. The QA office has responsi 3 bility *.o assure that the PI and the purchasing office have complied. -

3 ~g 5.01 Technical Procedures: This activity is primarily a responsibility of the Principal Investigator. However, experience has shown that a

• large-QA Office connitment is required to keep the generation of the essential procedures up with the work being performed. " Mechanizing" the procedure preparation has been a big help, but it does not complete the requirement. It is a QA office responsibility to perform the procedure distribution and to keep the essential records of the distribution and revisions, which will be further discussed under

" document control". The preparation, approval and control of technical procedures is an on-going activity which requires multiple level involvement.

6.01 Document Control: This is a QA office assignment requiring consid-erable supervisory and cler.ical help. A tracking system is required to assure that the necessary distribution is realized, and to the record that the distribution was made in a timely manner provide Work on this tracking system should begin at once, but its completion is of lower priority than many other items of implementation. The main *

~ thrust for priority in this section is the potential effectiveness for its use in management of the QA implementation.

7.01 Control of Purchased Material: This criteria pertains to equipment

' and critical purchases that could affect the quality of the work.

The QA office effort is largely one of record keeping, and assurance that the job is getting done. The procurement office is under instruction to enforce the procedures as described in this procedure.

Further details need to be spelled out in this area, which will be included in the next revision of the QA Manual. Responsibilities for the revisions continue with the QA office, while the responsi-bility for vendor certification has been assigned to Los Alamos National Laboratory for the current fiscal year.

10.1 Surveillance: This is the process of policing the activities to see that the QA procedures are being followed. While the QA office does not perform all the surveillances they are responsible for 3

keeping track of what surveillancos were , performed, and to follow up on the appropriate dispositions. Surveillance of the various tasks of the QA Program will begin immediately, and will continue.

11.01 Tentative Technical Procedures: For those work areas where a standard procedure cannot be prepared, provision is made in the QA Manual to document the work method and pertinent descriptions in a tentative format for use until the work has progressed to a state '

where a formal definite procedure can be prepared. This is the assigned responsibility of the Principal Investigator. However, assistance and or advice will be required in the process. This assistance is available from the outset; and the PI's will be encouraged to use this procedure whenever it legitimately can be used.

12.0 Calibrations: All equipment used must be calibrated by the user on a schedule described in the technical procedure. The rules on cali-bration are strict, and complete records are a requirement. The QA

~

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' office is responsible only for the record portion and for providing the regular schedule, but this responsibility extends to routine re-minders of when recalibrations are due, in addition to assuring that 2

the calibrations are being performed according to the procedures.

This task also requires a tracking system to be used as a management tool as well as for providing the record of the calibrations perform-ed. While there already exists a QA calibration file, it requires revision and updating to be effectively used in the management sense. An update of this file will be a mid-level priority, with emphasis en keeping the calibrations up to date.

15.01 Nonconformance/ Corrective Actions: Any nonconformance prepared by 16.01 an audit, surveillance, or other action must be handled according to a rigid procedure, until fully dispositioned. The QA office wi.ll be preparing some of the nonconformances for various reasons, but the bulk of the time will be consumed by resolving the issues, record keeping and paper handling.

i 17.01 Records Management: All documents supp9 ting the data tnat will i

be used in the licensing process must bc:xe part of the official record. 0A records are well defined, and it is the responsibility of the QA office to achieve a complete record. Currently the records program, in complianca with and under training of the Project office in Las Vegas, is performed by the SAIC-Golden office. It is expected .,

• that revisions to the established records procedures will be requir-ed as the overall program evolves and when 50P-17 4

Implementation in this area is already underway and it will continueis issued. pf uninterrupted by other priorities.

13.01 Audits: Auditing is a large part of the policing activity, and it is an important part of the QA program. This activity requires specially cualified participants, especially in the role of the lead auditor. The audits are performed according to a definite procedure, including scheduling and planning. The scheduling, assurance of their completion, and follow up on audit findings is a requirement of 4

the QA office. Performance of the USGS internal audits is currently. ,

contracted to Los Alamos National Laboratory. i QA Administrative Function: The effort of administration is necessary for program planning and implementation, to hold the work effort to-i gether, and to assist with the fire fights as they occur. QA program evaluation, understanding of Project QA requirements and their changes; and directing any resulting corrective actions also is an important part of the administrative function. .

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4 10/86 1*

IMPLEMENTATION OF THE 0A MANUAL NNWSI-USGS QA PROGRAM Man (MONTH)

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EtJCLOSu9C-- 6 Department of Energy Nevada Operations Office P. O. Box 14100 .

6

.;.';? 003 o,,

Las Vegas, NV 89114-4100

'86 AFR 23 P3 45 AFR 1 7 M ,

J. W. Dudley, Jr.

Technical Project Officer for NNWSI U.S. Geological Survey Post Office Box 25046 418 Federal Center Denver, CO 80225 WASTE MANAGEMENT PROJECT OFFICE (WMPO) AUDIT OF U.S. GEOLOGICAL SURVEY (USGS)

QUALITY ASSURANCE PROGRAM (86-2a) DENVER (WMP0 ACTION ITEM *86-1103)

Enclosed is the report of Quality Assurance Audit 86-2a which was conducted for the Waste Management Project Office (WMPO) at the U.S. Geol.ogical Survey (USGS)

Denver on March 11-14, 1986. .

The audit was conducted to verify implementation and evaluate the effectiveness of the USGS/ Denver Quality Assurance Program Plan and its procedures with respect to the requirements of the NNWSI Project NV0-196-17 (Rev. 3) and the l applicable SOPS, and to verify the implementation of the Quality Assurance

! Program as it relates to the USGS Quality Assurance Manual. The audit did not

imply acceptance or non-acceptance of the USGS QAPP and procedures. Emphasis was placed upon the status of the USGS technical areas and the reviews of the USGS published technical reports.

The audit team reviewed sufficient objective evidence related to USGS work activities to deteruine whether the QA program requirements were being satis- ,

factorily implemented per NNWSI-NV0-196-17 (Rev. 3) and its applicable SOPS.

4 i As a result of the evaluation, the audit team identified twenty-two (22) deficient conditions adverse to quality and five (5) significant observations.

4 This large number of significant audit findings indicated an almost total lack ,

of QA program implementation and therefore, the Lead Auditor concluded that he would reconnend WMPO issue a Stop Work Order for USGS/ Denver and Menlo Park

i. facilities. Audit Finding Sheets 862a-1 through 862a-22 are enclosed for your ,

disposition. Please review the findings, complete the response section, and -

return your response within thirty (30) working days after receipt of this report.

i Unless otherwise noted in the audit report, formal response to the observations is optional. All responses to the findings shall be addressed to the Director, WMPO. ,

6 9 m

..,.,.,,,,.,,,.,,,_..,_,-.__-,-,,___,...__.,__--r-..

4 .

l W. W. Oudley, Jr. If you have any questions regarding this audit, please contact James Blaylock at FTS 575-1125.

Yh b f Donald L. Vieth, Director WMP0:JB-1046 1)WasteManagementProjectOffice

Enclosures:

As stated cc w/ encl.:

V. J. Casse11a, DOE /HQ (RW-22), FORS

0. C. Newton, 00E/HQ (RW-23), FORS E. W. Sulek, Weston, Rockville, M0 J. R. Willmon, USGS, Denver, C0

> J. A. Pattillo, Los Alamos, NM S. H. Klein, SAIC, Las Vegas, NY A. E. Cocoros, SAIC, Las Vegas, NV S. B. Singer, SAIC, Las Vegas, NY E. H. Oakes, SAIC, Reno, NV R. W. Gray, MEO, 00E/NV M. B. Blanchard, WMPO, 00E/NV James Blaylock, WMPO, 00E/NY Paul Prestholt, NRC/HQ SusanBilhorn,NRC/HQ ,

O

J WMP0 QUALITY ASSURANCE AUDIT REPORT N

AUDIT NUMBER: 86-2a 0F USGS/ DENVER

. CONOUCTED ON: MARCH 11-14, 1986 PREPARED BY Id [

LEAD AUDif0R SNIC/QASC OATE y'///f(

APPROVED BY -

WMP0 PQM 3kO J DATE 4 //o /74 I

e 9

e s

o .,

1.0 INTRODUCTION

This report contains the results of the Nevada Nuclear Waste Storage Investigations (NNWSI) Project Quality Assurance (QA) Audit Number 86-2a of the U.S. Geological Survey (USGS) conducted on March 11-14, 1986. The audit was conducted in accordance with the requirements of the Waste Management Project Office (WMP0) QA Audit procedure QMP-18-01.

The audit was conducted to veri fy implementation and evaluate. the effectiveness of the USGS/ Denver Quality Assurance Program Plan and its procedures with respect to the requirements of the NNWSI Project NV0-196-17 (Rev. 3) and the applicable SOPS, and to veri fy the implemen.tation of the Quality Assurance Program as it relates to the USGS Quality Assurance Manual. The activities audited were:

o Programmatic Quality Assurance; and

• o Technical Activities. '

Within these activities, the audit team concentrated its efforts in the following areas:

o Guality Assurance operations; o Laborato y test activities; and o Technical activities and documents.

A checklist was used to expedite the review of documents and records in the USGS files and to record information resulting from discussions with USGS personnel . The,ichecklist items were developed using the following documents:

o NNWSI Project NV0-196-17 (Rev. 3) and the applicable SOPS o USGS QAPP and QA Procedures o USGS Technical Procedures.

I d

2.0 AUDIT TEAM PERSONNEL S. B. Singer, SAIC/QASC, Lead Auditor N. A. Voltura, SAIC/QASC, Auditor J. W. Estella, SAIC/QASC, Auditor i

R. F. Cote, SAIC/QASC, Auditor in Training (AIT)

F. D. Peters, SAIC/QASC, Auditor in Training / Technical Advisor D. C. Newton, 00E/HQ, Auditar in Training (AIT) -

E. H. Oakes, SAIC, Auditor / Technical Advisor j- Paul Prsstholt, NRC/HQ, Observer Susan Bilhorn, NRC/HQ, Observer 3.0

SUMMARY

OF RESULTS

'l The audit team agreed that the USGS was, not complying with the require-ments of their Quality Assurance Prog ~ ram Plan and were not adequately ,

implementing the existing supporting procedures.

A total of twenty-two (22) findings of nonconformance and five (5) signif-icant observations were reported representing thirteen (13) of the sixteen (16) elements reviewed. This resulted in a recomendation ey the Lead Auditor to the WMP0 Project Quality Manager (PQM) that a Stop Work Order be issued. The details of the findings and observations are described in Section 5.0 of this report. To the extent auditad, the following elements were found to be either in compliance or are not addressed by the USGS QA Program and are as follows:

i g Element 6. Document Control: Was not audited.

Element 10. Inspect 1'on: USGS does not perform inspection. .

Element 11. Test / Experiment Control: No findings.

Element 14. Inspection. Test, and Operating Status is covered under other procedures at USGS.

Element 15. Nonconformance: None have been written to date.

L 1

2

t The balance of the 18 QA criteria were audited. A fundamental problem in conducting this audit was that procedures required by NNWSI NV0-196-17 Rev. 3 were not implemented or they did not exist. Therefore, due to both of these problems, the USGS was determined to be not in compliance with NNWSI NV0-196-17, Rev. 3. It was also noted that there was a lack of training of personnel in all areas of the USGS Quality Assurance Program.

4.0 AUDIT MEETINGS The audit commenced with an opening meeting on March 11, 1986. The -

purpose, scope, and agenda of the audit were reviewed with the USGS personnel and USGS assigned coordinators for the various elements to be audited. The results of the audit were thorougnly reviewed with USGS personnel at a close-out meeting held on March 14, 1986. At that time, a handwritten rough draf t of the proposed audit findings and observations was given to USGS management.

4.1 OPENING AND CLOSING MEETING ATTENDEES Paul Prestholt, NRC l

• Nancy Voltura, SAIC/QASC Carl Newton, 00E/HQ Forrest Petars, SAIC/QASC Ed Oakes, SAIC, Reno, NV Leonard Wallitz, USGS/ Denver Gene Rush, NHP, Denver Warren Hofstra, NHP, Denver William Dudley, USGS/ Denver a Sam Singer, SAIC/QASC Joe Willmon, USGS/ Denver Susan Bilhorn, NRC/0WM Ron Cote, SAIC/QASC John Estella. SAIC/QASC Paul Carrera, USGS/ Denver.

• • Susan Shipley, USGS/Menlo Park 3

Boo Peterson, BOR/ Denver Art Guthrie, Los Alamos, NM

• James Blaylock, PQM/WMP0

• 0arrell Porter, SAIC/Gciden, CO

• Bob Wise, SAIC/ Golden, C0

• Ricnard Watkins, USGS/ Denver

• William Nilson, USGS/ Denver

• Robert Rauo, USGS/ Denver

• Ed Cocoros, SAIC/QASC

• Exit Meeting only

• • Opening Meeting only 4.2 PERSONS CONTACTED DURING THE AUDIT Paul Carrera, USGS Joe Willmon, USGS Susan Shipley, USGS Arthur Guthrie, Los Alamos -

Joe Rosenbaum, USGS L. A. Anderson, USGS Linda Watson, SAIC M. S. Whitfield, USGS Chuck Freestone, USGS Bob Peterson, USGS Eugene Rush, USGS Darrell Porter, SAIC 5.0 FINDINGS AND OBSERVATIONS The following findings of nonconformance were recorded during the audit.

The requirement, documents, and details of the requirements are presented in the respective attached Audit Finding Sheets Numbers 862a-1 thru 22.

4

a e Finding No. 862a-1 The USGS QA Program does not have a WMP0-approved QA procedure in place to address source evaluation and selection.

Finding No. 862a-2 A J-13 water sample was found in a container which had no identification other than the number J-13. When the engineer was asked for any other documents that were traceable to' the sample, his reply was, "These documents are not availaDie."

Finding No. 862a-3

, A sample review of procurement documents identi fied inconsistent implementation of USGS-QMP-4.01 in the following areas: ,

1. Neither the purchase requisition nor the NNWSI Project QA Procurement Form consistently identify any of the following for QA Level I items or services: technical requirements, QA Program requirements, Rights of access, Documentation requirements, provision for reporting nonconformances. Requisitions # 4810-0116, 1/14/86; 4810-0041-86, 10/1/85; 4810-0109-86, 1/8/86; 4810-33310T, 12/27/85; 4810-0088, 12/17/85.

2. Lack of documented evidence of USGS' QA Manager's review and approval of the requisition and the QA Procurement form. Requisitions found deficient wero #4810-0317-86, 9/18/85; 44810-0015-86, 8/20/85;

1. 4810-0007-86,8/85. -

3. USGS personnel have approved the USGS NNWSI Project QA Procurement form for the USGS QA Manager without documented authority to do so.

4. Copies of all as-issued QA Level I procurement documents are not being forwarded to WMP0.

5

7'.

Finding No. 862a-4 NNWSI-USGS-QMP-18.01, Rev. O, does not address program provisions for conducting external audits of suppliers / contractors to USGS.

. Finding No. 862a-5 A review of the Rock Properties Measurement Lab revealed lack of compliance / implementation in the following areas:

1. The QA Calibration Form is not being completed for each instrument requiring calibration and is not being sent to the USGS QA Office prior to the instrument's use.

2. The USGS QA Office is not entering this information into a calibration system -- to include all affected instruments.

3. The calibration status of instruments is not being displayed at a readily accessible location. Stickers are. not affixed to each instrument denoting the calibration status.

4. Nanconformance reports have not been written for instruments that display no calibration status sticker.

5. No documented certifications are on file for personnel performirg equipment calibrations.

6. Calibration standards used for calibration of instruments are not traceable to the National Bureau of Standards (NBS) or other Known standards. Where NBS standards do not exist, the reference standard is not supported by certificates, reports or data sheets attesting to the date, accuracy and conditions under which the results were obtained.

6

7.

The method and interval of calibration for each item has not been defined, based on the type of equipment stability, characteristics, required accuracy, intended use, manufacturer's recommendations or other conditions that affect measurement controls.

8. Instruments out of calibration are not tagged or segregated.

9. Calibration forms, which are QA Level I or II documents, . are not processed as NNWSI Project QA records.

~

Finding No. 862a-6 There is no documentation of indoctrination and training of USGS personnel performing quality related activities. It should also be noted that there is no apparent central control or accountability of the USGS personnel

, working on the NNWSI Project to ensure that these personnel are properly indoctrinated, trained, and certi.fied.

Finding No. 862a-7

• There are no certifications of personnel who perform reviews of technical documents. In addition, many of the USGS technical personnel certifi-cations do not define the area of responsibility for which these personnel are certified. Examples of such certifications are those of the following personnel: Edwardo A. Rodriquez, David A. Ponce, Gary D. Hamilton, John H. Healy, Robert J. Munroe, Brennen O'Neill, William H. Prescott, Joann M.

Stock, Joseph F. Svitek, Walter E. Wendt, Robert H. Colburn, Edward E.

Criley, Ronald M. Kaderabek, Jeff Wilson, Dean Whitman. In some instances, the work experience included on the certifications of USGS technical personnel does not support the activities which they are certified to perform. Examples of such certifications are those of the following personnel: Susan Shipley, Paul E. Carrara, Richard Hay, Pamela Jenks, Christine Arthur, Michael Chornak, Ibrahim Palaz. Also, the certifications of Robert 0. Castle and Kenneth A. Sargent were not approved by the next higher supervisory level as required by USGS 7

procedure NNWSI-USGS-QMP-2.03, Rev. 0, paragraph 3.2. Certifications for Castle and Sargent had no approvals. It should be noted that the USGS QA program does not establish certification criteria for the USGS technical '

personnel. The basis for certification as described on the USGS certifi-cation form is subjective in nature. This also applies to the certifi-cation of Fenix and Scisson geologists who implement USGS activities. In addition, there are no provisions in the USGS QA program for USGS to either accept or concur with lab contractor's certifications since these certifications are performed by F3S personnel.

Finding No. 862a-8 The USGS QA program does not adequately address provisions for USGS QA personnel and QA support contractors to stop unsatisfactory work.

Although USGS-NNWSI-QMP-10.01, R0, para. 4.4 does state that the QA manager has authority to stop work during course of a surveillance, it is not documented as to how this activity is implemented. It should be noted that the stop work authority appears to be limited to those activities identified during the surveillance. No apparent , provisions exist to stop unsatisf actory work identified during audits, inspections' or by other means.

Finding No. 862a-9 The USGS QAPP-Rev. O, Sec. OMP-1.0 does not delineate the responsibility and authority of each organization involved in the execution of activities affecting quality, and does not address external and internal interfaces between organizational units. In the case of internal interfaces, the Geological Division QA Soecialist Central and QA Specialist Western Division, and Nuclear Hydrology QA Specialist responsibilities and author-( ities are not defined and documented. The aforementioned QA personnel as depicted in the USGS Organization Chart do not appear to have access to management levels such that they have the required organizational freedom including sufficient independence from cost and schedule wnen opposed to safety considerations. Note: see AFS 862a-1. Additionally, the USGS QA organization does not clearly delineate the authority and responsibility 8

, . l l

1 l

for the external interfaces between organizational units performing activ-ities affecting quality e.g., Los Alamos National Laboratory which is performing internal and external audits for the USGS and the Bureau of ,

Reclamation which is performing site characterization activities includ-ing, but not limited to, surface hydrology.

Finding No. 862a-10 The USGS QAPP, Rev. 2 does not address provisions for the Quality Assurance program to control activities associated with operation of the core library facilities at the NTS for handling, storing, and distributing material samples and core for the commercial nuclear waste management activities at the NTS as required by the NNWSI Quality Assurance Plan.

Note: refer to AFS 862a-11 for additional information.

Finding No. 862a-11 The USGS Quality Assurance program does not maintain WMP0 approved QA administrative procedures for the storage, handling, and shipping of core samples and other materials associated with NNWSI Project activities to preclude damage, loss, or deterioration by environmental conditions. This condition is of particular concern since the USGS is responsible, in part, for the operation of the core library facilities at the NTS including, handling, storing, and distributing material samples and core for the comercial nuclear waste management activities at the NTS. Note: refer to AFS 862a-10 for additional information.

Finding No. 862a-12 The USGS Quality Assurance Plan does not address provisions to be established for the qualification of personnel, equipment, and procedures and for the control of special process verification methods .to be documented for core sample preparation. This condition is of particular 9

t concern since the USGS has and is presently processing core samples for NNWSI Project activities prior to the development, review, and approval by WMP0 of these special process procedures.

Finding No. 862a-13 (Part 1) Many of the publication files requested for review did not contain peer-review comments. In several publication files that did contain peer-review comments, resolution of tne comments by the author (s) was unclear.

(Part 2) WMP0 asked several interviewees to produce the written peer-review procedures in effect prior to NNWSI-USGS-QMP-3.04, R0; evidence that these procedures existed was not produced.

Finding No. 8623-14 The USGS has been and is performing numerous site investigations for the NNWSI Project, as listed in the Work Breakdown Structure Dictionary, without any approved site investigation plans, and therefore, has been and is violating the QA Program requirements (See AFS 862a-14). The referred paragraphs clearly prohibit any site investigations frcm being performed, until and unless, a site investigation plan has been prepared, tecnnically reviewed, and approved by WMPO.

It is true that extensive plans are in existence, or are in preparation, for the Site Charcterization Plan (SCP) and the Exploratory Shaft Test Plan (ESTP), but these plans are not in effect at this time. The USGS has generally failed to provide, or to technically review, site investigation ,

plans for their activities within the site exploration phase of this project.

It is also true that the USGS did prepare a Work Plan for the USGS Participation in the Nevada Nuclear Waste Storage Investigations Project, for the fiscal year 1985 activities, but this was apparently a preliminary draft which was never completed, reviewed, or submitted to WMP0 for 10

approval. A similar document was also prepared for the fiscal year 1986, but again, this was also apparently a preliminary draft which has not yet been compl eted, reviewed, or submitted to WMP0 for approval. These documents do not therefore, fulfill the requirements of NV0-196-17, Para.

3.2.2 and 3.2.3. (See Audit Finding 862a-15.)

Finding No. 862a-15 The USGS QAPP does not provide for the planning of the site invesigation activities affecting quality as required by Para. 2.1 of NV0-196-17. Rev.

3, as further amplified in Para. 2.1.2 of SOP-02-01, Rev. O, and Para.

3.2.2 and 3.2.3 of NV0-196-17, Rev. 3.

Finding No. 862a-16 Certifications of audit personnel who have performed supplier evaluations are not on file at USGS. Therefore, the acceptability of the supplier '

evaluations performed by these individuals cannot be determined.

Finding No. 862a-17 USGS contracts with various support contractors (e.g.) Inst, of Geophysics / Planetary Physics, Petrographic Services, Colorado School of Mines, and others do not specify that these contractors will implement the

, USGS QA Program for their activities nor does objective evidence exist to demonstrate that these contractors have an equivalent program which meets the requirements of the NNWSI Project QA Plan.

',~ Finding No. 862a-18

[, The USGS QA program does not address provisions to control the utilization v of limited calendar life items or samples (e.g., water samples) to assure that these items or samples are not used after such time that ' their chemical and physical properties may change which would affect the

resulting data.

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e Finding No. 862a-19 There is no oojective ev.idence to support performance of the required QA Manager review. In addition there are no provisions in the USGS technical procedures to require that this sample documentation be provided to the USGS QA Manager for review.

Finding No. 862a-20 Copies of some required records, such as audits and reviews of technical publications, are neither identifiable or retrievable. ,

Finding No. 862a-21

1. USGS records are being processed / reviewed using an unapproved QA ,

procedure "QA Records Management Guidelines" dated 1/28/86.

2. Measures have not.been established to identify / document those personnel who are authorized to validate records.

Finding No. 8622-22 No documentation, USGS Corrective. Action Request (CAR), has been generated to identify numerous recurring conditions adverse to quality. There are 29 outstanding /open audit findings identified by Los Alamos for USGS which have not been resolved; many of these identify recurring conditions.

Observation 1 The following observations were noted during the audit:

Observation No. 01 A report prepared by Will Carr (0FR-84-854) met the " Letter" of the requirements described in NNWSI-USGS-QMP-3.04, R0 (Technical Review of NNWSI Publications). This procedure states, in part, that there will be 12

two peer reviewers for each report prepared by the USGS. One of the reviewers of this open-file report, however, recommended (in writing) that another geologist review the report because of his f amiliari ty with certain parts of the subject matter. There is no record of this third review taking place. Therefore, a question arises concerning the adequacy of the technical review of this publication.

Observation No. 02 In NNWSI-USGS-QMP-17.01, RO, Sec. 5, Para. 5.4.4 it states that documents must be sent to the " Record Processing Center" within two weeks of completion. This schedule seems rather unrealistic, and may require a revision of the procedure.

. Observation No. 03 1

The USGS has adopted a procedure (QMP-3.04, Rev. 0) for the technical review of NNWSI-USGS publications, but tnis procedure does not address the problem of data, interpretations, conclusions, recommendations, and/or reports which are not " published" officially by the USGS. The danger exists that some data, interpretations, conclusions, recommendations and/or " reports" could be used for a Quality Level I purpose, without any technical review, because the USGS QAPP does not address this problem. If this did happen, then it would be a violation of the intent of SOP-02-01.

!- The USGS should address this proolem somehow.

!- Observation No. 04 l

i Part 1 - NNWSI-USGS-QMP-2.01, Rev. O, requires that the status, adequacy

'l and effectiveness of the NNWSI-USGS Quality Assurance Program be assassed l, annually. This assessment is required t.o be documented in a Management Assessment Report which is to be issued by October 31 of each year.. This

( procedure carries an effective date of 8/24/85 and was approved by WMP0 on l

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i 9/27/85. No Management Assessment Report has been issued to date, presumably due to the short time the USGS QA Program has been implemented.

Based on discussions with the USGS QA Manager, this assessment is scheduled to be performed in September of 1986.

Part 2 -

Per the USGS procedure, the USGS Assistant Director assigns responsibility for resolving quality-related proolems and conditions adverse to quality which are identi fied in the Management Assessment Report. There is no method described regarding how these quality-related problems and conditions adverse to quality are documented, tracked or verified, for closure and there is no apparent involvement by Quality Assurance in this process. A response to this observation is required.

Observation No. 05 Based on the number and nature of the findings identified as well as the USGS estimatas of manpower necessary to effectively implement the USGS QA Program, it appears evident that the USGS QA organization is inadequately staffed to achieve proper implementation of the QA Program at USGS.

6.0 CORRECTIVE ACTION A written response to Audit Finding Sheets (AFSs) 862a-1 through 862a-22 (enclosed) is required. USGS should review and investigate the findings to determine the cause and schedule appropriate action to prevent recurrence. The response to the findings shall be in writing and included on, or attached, to the AFSs for return to WMP0 within thirty (30) working days after receipt. In the event that the corrective action cannot be completed within thirty (30) days, the response shall indicate a schedule date for completion. A follow-up response by USGS must be sent to WMP0 when the action has been completed. All responses shall be addressed to the Director, WMPO, and a copy shall be sent to the Lead Auditor (S. B. Singer, SAIC). A fonral answer to all observations except observation' No. 4 is optional. Observation No. 4 requires a response.

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l I WMPO AUDIT FINDING SHEET (AFS) y3A42 (To be used for al AFSs wrth added sheets as requre<1)

Audt Fr@ No. 862a-1 Audted Checktst Reference 362a-1-7.1.1-2 Audted Organzation USGS - Denver l

Organzation Urit GA Control of Purcnaseo Materiai, l Actnmy Ecuicment and Services i Response Assgned To W. W. Oudley, Jr. Reported By (Audtor) N. Voltura/S. Sincer Requrernent (Ote) NNWSI-SOP-02-01, Rev. 0 (1) Para. 5.1.1 states in cart: " Activities that affect quality shall be crescribed by documented instructions, orocedures ... of tyoe accrooriate to the circumstances and shall be accomolished in accordance (cont'd.

F4 Contrary to the above, the USGS QA Program does not have a WMPO-accroved QA procedure in olace to address source evaluation and selection.

M Approved By LA / t4/ - A y///#4 30 cays after-Response Due Date Pa-aw a Approved By WhPO/NV  % ib0 /% Date J

Response (To be cerncieted by audted organzation.)

Implementation Date Subnitted By Oate To be ecmpieted by lead audtor (LA) and reviewed by WhPG/NV Corrective Actx:n Resocnse Rev;ewed by LA/Date O satisfactory O Unsatisfactory Reviewed by WMPC/NV/Date __

Corrective Acbon :. TAT 6tation Reviewed by LA/Date O Satisfactory O Unsatisfactory Reviewed by WhPO/NV/Date Reaudt Date Remarks Audt Fodng Cosed O LA Concurrence /Date Reference and Phrrt:er(s) for unsatisfactory reaudt _

WMP0 Audit Finding No. 8623-1 cont'd Req. cont'd with these instructions, procedures . . ." (2) Para. 7.1 states in part:

" Measures shall be established to ensure that purchased material. equipment and services conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection . . ."

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8-WMPO AUDIT FINDING SHEET (AFS) $j;w2 (To be' used for ai AFSs wr:h added sneets as recu ed.)  !

Audt Fn:ing No. 862a-2 USGS QMP-8.01 Aucited Check 5st Reference Rev. O Para. 4.1.2 Audted Orgaruzation USGS - Oanve -

Metroloqy Lab Orgatuation Unit Rock Precaration Room Activity Identification & Control of Samoles Rosconse Assigned To W. W. Oudley, Jr. _ Reccried By (Audtcr) S. Sincer Re<;urement (C;te) UNWSI-USGS nMP 9.01 Dav. O Se-tion 1. idanti#im *4nn t ran -1 ne Geologic & Hydrologic Samoles, Para. 1 Purcose, states: "This crocedure defines the method of identification and control of ceologic and hydrolooic samoles to (cont'd)

F4 Contrary to the above J-13 water samole was found in a container which had no identification other than the number J-13. When the engineer was asked for any other documents that were traceable to the samole, nis reoly was, "These documents are not available."

Approved By LA -J v'/f/X Rescense Oue Cate ec o Approved By WMPC/NV ~ b 4 //o /% Date

) .

Rescense (To 'be ccmpleted by audted crgatuatien.)

Irrclementation Date Submrtted By Date To be esTsieted by lead audtor (LA) and reviewed by WMPC/NV Corrective Action Response Reviewed by LA/Date C Satisfactory C Unsatisfactory Reviewed by WMPC/fN/Date Corrective Action Implementation Reviewed by LA/Date i C Satisfactory C Unsatisfactory Reviewed by WMPC/tN/Date Reaudt Date Remarks Audt Feding Cosed C LA Concurrence /Date Reference and Number (s) for unsatisfactcry reaudt

WMP0 Audit Finding No. 862a-2 cont'd Req. cont'd assure their traceability until they are destroyed." Para. 2 Scoce of Como11ance, states in part: "This procedure is apolicable to all geologic and hydrologic samples generated by USGS which support Quality Levels I and II activities for NNWSI Project." Para. 4.1. "Information needed for each samole will include its location, sampling plan, lot or batch, collector, date of collection, stceage location and physical description. This data shall be on documents traceable to the samole throughout the samoles' collection orecaration, analysis and storage."

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WMPO AUDIT FINDING SHEET (AFS) yg^-0 (To be used for al AF5s wrth added sheets as recured.)

Audt Frdg No. 862a-3 Audted Checkist Reference 862a-1-4.2.2 Audted Orgatuatx:n USGS - Denver Orgaruatxm Urst GA Activrty Procurement Doc. Control Response Assuped To W. W. Oudley, Jr. Reported By (Audtor) N. Voltura/S. Sincer Recrement (Cite) NNWSI-USGS-CMP-4.01, Rev. O states: Para. 1: Purcose: "To establish controls for ensuring that reouisition documents include the applicable statements, re ences or clauses to obtain procurement objectives for NNWSI Project related (cont'd)

Fodng Contrary to the above, a samole review of crocurement documents identified ince sistent imolementation of USGS-0MP-4.01 in the following areas: (1) neither the cur-chase recuisition nor the NNWSI OA Procurement Form consistently identify any of the following for QA Level I items or services: technical requirements, OA Program (cont' Approved By LA  ! oA v/f//d Response Due Date Rec Approved By WWO/NV u b a

//o/f6 Date Response (To be completed by audted orgarwaticn.)

Irnpiementation Date Submrtfed By Date i

i To be ccirGted by lead audtor (LA) and reviewed by WWO/NV Corrective Acten Resocnse Reviewed by LA/Date i

O Satisfactory C Unsatisfactory Reviewed by WWO/NV/Date Corrective Action la-A-atation Reviewed by LA/Date O Satisfactory C Unsatisfactory Reviewed by WWO/NV/Date Reaudt Onte Remarks Audt Findng Closed C LA Concurrence /Date Reference and Number (s) for unsatisfactory reaudt 4

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WMP0 Audit Finding No. 862a-3 cont'd Req. cont'd services, activities or

ems." Para. 4.3 states in part: " Level I items / services

-- In addition to 4.1 ano 4.2, requisition documents shall include provisions as

. deemed necessary and applicable by the purchaser for the following: Technical requirements . . . , QA Program requirements . . . , Rights of Access . . . ,

Documentation Requirements . . . , Nonconformance reporting requirements . . ."

Para. 5.3 "QA Manager reviews & approves the requisition & QA Procurement forms . . .

Copies of the requisition documents for Level I items / services are forwarded to . . . WMP0 . . ."

Finding cont'd requirements, Rights of access, Documentation requirements, provisions for reporting nonconformances. Requisition #s - 4810-0116, 1/14/86; 4810-0041-86, 10/1/85; 4810-0109-86, 1/8/86; 4810-33310T, 12/27/85; 4810-0088, 12/17/85. (2) Lack of dccumented evidence of USGS' QA Manager's review and approval of the requisition and the QA Procurement form. Requisition #4810-0017-86, 9/18/85; #4810-0015-86, 8/20/85; #4810-0007-86, 8/85. (3) USGS personnel have aoproved the USGS NNWSI QA Procurement form for the USGS QA Manager without documented authority to do so.

(4) Copies of all as-issued QA Level I procurement documents are not being forwarded to WM90.

WMPO AUDIT FINDING SHEET (AFS) 'Ys^~

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(To be used for al AFSs wrth aoded sheets as recure<1)

Audt Frdng No. 862a-4 Audted Checkist Reference 862a-18.2.1.2 Audted Organzaton USGS - Denver Actvrty Audits Orgaruabon Unrt QA Response Assxped To W. W. Oudley, Jr. Reported By (Audtor) N. Voltura/S. Singer Reosernent (Cite)NNWSI SOP-02-01, Rev.0 Para.18.2.1 states in part: " Internal & externe audits shall be scheduled in a manner that shall provide coverage & coordination with cngoing QA crogram activities. . . " Para.18.2.1.2 External Audits - Elements (cont'd)

Frdng Contrary to the above, NNWSI-USGS-QMP-18.01, Rev. O does not address program orovisions for conductino external audits of sucoliers/ contractors to USGS.

Approved By LA *t M <//M74 Resoonse Due Date cb!

• Approved By WP#0/NV s bb a Uto/N Date Response (To be completed by audted organzaton.)

!.. Arg,ritaten Date Submrtted By -

Date i

l To be completed by lead audtor (LA) and reviewed by WMPO/NV l Correctve Acton Response Reviewed by LA/Date l O satisfactory C Unsansfactory

)

Reviewed by WP&O/NV/Date Corrective Acton trrolementaton Reviewed by LA/Date O satisfactory 0 Unsatisfactory Reviewed by WP&O/NV/Date Reaudt Date Remarks l

Audt Findng Oosed O LA concurrence /Date l Reference and Number (s) for unsatisfactory reaudt l

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WMPO Audit Finding No. 8623-4 cont'd Req. cont'd of a supplier's QA program shall be audited Dy the curchaser . . ,"

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WMPO AUDIT FINDING SHEET (AFS) ' C ^ -C gg3 (To be usec for al AFSs wrth added sheets as rewed QMP-12.01 para 3 862a-5 througn 9 & SOP-0 Audt Fr*g No. Audtec Checkist Referencepage 37 & 38 - of Audted Orgaruata USGS - Denver para 12.1.4 Rocx Properties Orgaruatm W Measurements Lab Acevrty Control of M & TE Resemse Asixped To W. W. Dudlev. dr. Recorted By (Audter)S. Singer Recuirement (C;te) Chacter 12 Control of Measuring and Test Ecuipment Section 1, 2. SCOP OF COMPLIANCE. This procedure apolies to all USGS instruments that require calibration in succort of the NNWSI Project. It acclies to all NNWSI-USGS cersonnel and their (con F4 A review of the Rock Properties Measurement Lab revealed lack of compliance /ime mentation in the following areas: (1) the QA Calibration Form is not being completed f each instrument recuiring calibration and is not being sent to the USGS QA Office oric to the instrument's use. (2) The USGS CA Office is not entering this information (cont Approved By LA -

eh <//r/P4 Response Oue Date ec to

, Approved By W7#0/NV k J 4 ho/95 Cate Response (To be comc.eted by audted orgaraatm.)

imr.4ementate Date Sutmtted By

^

Date ,,,;

To be cca@ted by lead audtor (LA) and reviewed by W@O/NV Correctve Acta Response Reviewed by LA/Cate O satisfactory C Unsansfactory '

Reviewed by WSO#NIOate Correctr.re Acta h-(.4wratatm Revewed by LA/Date O Satisfactory O Unsansfactory Reviewed by WhPO#N/Date

, Reaudt Cate Remartr.s _

Audt Fr*g Closed O LA Concurrence /Date Reference and Nunter(s) for unsatsfactory reaudt 1 i

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WMPO Audit Finding No. 862a-5 cont'd Req. cont'd  ;

contractors. 4. RESPONS:slLITIES. 4.1 The Principal Investigator (PI) is resconsible for ensuring that USGS-controlled instruments requiring calibration meet the requirements of this procedure.

5. PROCEDURE. 5.1 A QA Calibration Form (Attachment 1) shall be completed by the PI or a delegate for each instrument requiring calibration and sent to the USGS QA Office prior to the instrument's use. 5.2 The USGS QA Office shall enter the information into a calibration system, and provide the orginating P! a copy of the information. 5.5 The PI is responsible for ensuring that the calibration status of instruments are displayed at some readily accessible location. Tc comoly, a sticker shall be alfixed to each instrument denoting the calibration status according to one of the following three cataegories:

1. Showing equicment identification, date calibrated, date recalibration is cue, procedure number and calibrator. 2. Indicating the equipment identifictation,

, "0PERATOR TO CALIBRATE", anc the proccoure number. 3. Showing the eouipment -

identification and "N0 CALIBRATION REQUIRED". 5.6 Nanconformance reports shall be prepared in accordance with NNWSI-USGS-QMP-15.01 for instruments that are used after the recalibration due date or displays no calibration status sticker.

6. QA REQUIREMENTS. 5.1 Personnel performing equipment calibration shall be l

certified to have the qualifications necessary to perform the required cali-

bratica. Theta qual 1+!caticas shall ba based en trafning and expertence and  ;

l documented according to procedure NNWSI-USGS-QMP-2.03. 6.2 Calibration standards used for calibration of instruments shall be traceable to the National

. Sureau of Standards (NBS) or other known standards; this includes primary and ,

working standards. If NBS standards do not exist, the reference standard. used shall be supported by certificates, reports, or data sheets attesting to the

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WMPO Audit Finding No. 862a-5 cont'd Req. cont'd l

date, accuracy, and conditions under which the results were obtained. If reference standards are used, they will be stored and handled in such a way as to maintain the required accuracy and characteristics of the standard.

6.3 The method and interval of calibration for each item shall be defined, based on the type of equipment stability, characteristics, required accuracy, intended use, the manufacturer's recommendations, and other conditions that affect measurement control. Instruments that are out of calibration shall be tagged or segregated and shall not be used until they have been recalibrated.

If any instrument is found to be out of calibration consistently, then it shall be repaired or replaced. A calibration shall be performed when the accuracy of the instrument is suspect. 8. RECORDS MANAGEMENT. The calibration forms and any other documents associated with this procedure which are Quality Level I or II docu'ments shall be processed as an official'NNWSI QA record.

i

WMPO Audit Finding No. 862a-5 cont'd

' Finding cont'd into a calibration system -- to include all affected instruments. (3) The calibration status of instruments is not being displayed at a readily accessible location. Stickers are not affixed to each instrument denoting the calibration status in accordance with Para. 5.5 above. (4) Nanconformance reports have not been written for instruments that display no calibration status sticker. (5) No Ocumented certifications are on file for personnel performing equipment calibrations. (6) Calibration standards used for calibration of instruments are not traceable to the NBS or other known standards. Where NBS standards do not exist, the reference standard is not supported by certificates, reports or data sheets attesting to the date, accuracy and conditions under wnich the results were obtained. (7) The method and interval of calibration for each item .

has not been defined, based on the type of equipment stability, characteristics, required accuracy, intended use, manufacturer's recommendations or other conditions that affect measurement controls. (8) Instruments out of calibration are not tagged or segregated. (9) Calibration forms, which are QA Level I or II documents, are not processed as NNWSI QA records.

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WMPO AUDIT FINDING SHEET (AFS) N-?-C (To be used for al AFSs wrth aoded sneets as recured Audt Fndng No_ 862a-6 Audted Checkist Reference _362a-1 Page 7 of Audted Orgaruate USGS Orgaruaton Urvt Various Actmty Indoctrination & Training Response Assgned To W. W. Dudley, Jr. Reoortec By (Audtor)J. W. Estella Reuement (C.te) NNWSI-USGS-QMP-2.02, Rev. O, caragraph 4.1 requires that all personnel cerforming auality related activities receive indoctrination and training to the exten-necessary to perform their specific functions. Paragraph 4.2 states that the (cont'd)

F% Contrary to the above cited requirement, there is no documentation of indoctrint tion and training of USGS personnel performing quality related activities. It snould also be noted that there is no apoarent central control or accountability of the USGS cersonnel working on the NNWSI Project to ensure that these personnel are (cont'd)

Approved By LA MM </d/Y4 Response Due Date C Approved By WPPO/NV c-- 4 4 / f/* Date a

Resoonse (To be corrested by audted orgarnaten.)

!' t. TAT + taten Date Sutetted By -

I Date To be competed by lead audtor (LA) and reviewed by WWC/NV Correctue Acton Response Reviewed by LA/Date O satisfactc,ry G Unsat'sfactory Reviewed by WWO/NV/Date Ccere.:twe Acton 1..-A+7taten Revwwed by LA/Date O satisfactory O thsatsfictory Reviewed by WWO/NV/Date Reaudt Date Remarks Audt Finch; Cosed O LA concurrence /cate Reference and Nurnberis) for unsatsfactory reaudt

WMPO Audit Finding No. 862a-6 cont'd Req. cont'd I' ' indoctrination and training' activities shall be documented and retained as .

a QA' record.

Finding cont'd t

}- properly indoctrinated, trained, and certified.

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WMPO AUDIT FINDING SHEET (AFS) Iss^~

(To be used for al AF5s wrth added sheets as recured Audt Fridng No. 862a-7 Audted Checkist Reference _362a-1 og 10 of :

Audted Organzaton USGS Orpaten Urst Various Actvrty Personnel Certifications Response Assgned To W. W. Oudlev, Jr. Reported By (Audtor)J. W. Estella Recurernent (C.te) NNWSI-SOP-02-01, Rev. O reouires that personnel cerforming Quality Lev i activities be certified to show comoetence to cerform their soecific duties, e.c. ,

design verification, document review, surveillance, etc.

p4 Contrary to the above cited recuirement, there are no certifications of personne wno perform reviews of technical documents. In addition, many of the USGS technical cersonnel certifications do not define the area of resconsibility for which these cersonnel are certified. Examoles are: Edwardo A. RodriQuez, David A. Ponce, (cont'd)

Approved By LA L AA Y #4 Response Due Date Rec r Approved By WhPC/NV e a

bA i//o /% Date Response (To be cornoieted by'audted organzaten.)

I Li,2+T+ taten Date submrtted By -

Date To be completed by lead audtor (LA) and reviewed by WhPO/NV Correctve Acton Response Reviewed by LA/Date i O satisfactory G Unsattsfactory i

Reviewed by WhPC/NV/Date ia 1

Correctve Acton L4+T=6taten Reviewed by LA/Date O satisfactory 0 Unsatsfactory Reviewec by WhPO/NV/Date Reaudt Date Remarks Audt Fr&g Closed C LA Concurrence /Date Reference and Number (s) for unsatsfactory reaudt I

WMP0 Audit Finding No. 8623-7 cont'd Finding cont'd Gary D. Hamilton, John H. Healy, Robert J. Munroe, Brennen O'Neill, William H.

Prescott, Joann M. Stock, Joseph F. Svitek, Walter E. Wendt, Robert H. Colburn, Eaward E. Criley, Ronald M. Xaderabek, Jeff Wilson, Dean Whitman.

, In some instances, the work experience included on tne certifications of USGS technical personnel does not suoport the activities which they are certified to perform.

Examples are: Susan Shipley, Paul E. Carrara, Richard Hay, Pamela Jenks, Christine Arthur, Michael Chornak, Ibrahim Palaz. Also, the certifications of Robert O. Castle and Xenneth A. Sargent were not approved by the next higher supervisory level as required by USGS procedure NNWSI-USGS-QMP-2.03, Rev. O, paragraph 3.2; these certifications had no approvals at all. It should be noted that all the personnel certifications available for USGS technical personnel were completed within the 2 weeks prior to this audit. It should also be noted that the USGS QA program does not establish certification criteria for the USGS technical personnel. The basis for certification as de cribed on the USGS certification form is subjective in nature. This also applies to the certi-fication of Fenix and Scissen geologists who implement USGS activities. In addition, there are no provisions in the USGS QA program for USGS to either accept or concur with these certifications since these certifications are performed by F&S personrel.

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$ WMPO AUDIT FINDING SHEET (AFS) cA-E

~

735 (To be used for al AFSs wrtn added sneets as recured) 862a-1, og 1 of 1C 3-0 Audt F@ No. Audted Checust Reference Ques. (1)

Audted Orgarizaton USGS Orgarazaton Urvt GA Actrvny I Organization Response Assged To W. W. Oudley, Jr. Reported By (Audtor) R.F. Cote /J.W. Estella Roosement (Cae) NV0-196-17-Rev. 3, cc. 3 cara. 1.8, states in cart: cuality assurance personnel shall recort to management levels such that they have sufficient authority a organizational indeoendence to identify cuality orablems; to initiate, recommend (con p4 Contrary to the above recuirements the USGS OA program does not adecuately address orovisions for USGS OA cersonnel and 0A succort contractors to staa unsatisfac tory work. Although USGS-NNWSI-0MP-10.01,RO, cara. 4.4 does address that the OA managi has authority to stoo work during course of a surveillance, it is not documented (cont Approved By LA "h dMMI

// d Response Due Date cNo! N" Keoort Approved By WhPO/NV ---

- 4ho/% Date J

Response (To be comoieted by audted organzaton.)

l..GT,66taten Date Submrtted By -

Date To be completed by lead audtor (LA) and reviewed by WhPO/NV Correctve Acaon Response Reviewed by LA/Date O satisfactory 0 Unsatsfactory Reviewed by WhPO/NV/Date Corrective Action inwiementation Reviewed by LA/Date O satisfactory 0 Unsatsfactory Reviewed by WhPO/NV/Date Reaudt Date Remarks Audt Findng Cosed O LA Concurrence /Date Reference and Number (s) for unsatisfactory reaudt

D p WMPO Audit Finding No. 862a-8 cont'd Reg. cont'd or provide solutions; to verify implementation of solutions; and to s:co unsatisfactory work.

Finding cont'd as to how this activity is implemented. It should be noted that the stop work authority appears to be limited to those activities identified during the.

surveillance. No apparent provisions exist to stop unsatisfactory work identified during audits, inspections or by other means.

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(To be used for aA AFSs wrth added sheets as reared.) 862a, og 2 of 102 Audit Frdng No 062a-9 Audted CheckLst ReferenceQues. 2 3 ta-o f 102,,Oue,s. f.oc5 Audted Orgaruaten USGS Orgaruabon Urvt GA Actvrty Organization (I)

Response Assgned To W. W. Dudley, Jr. Reported By (Audtor)R.F. Cote /J.W. Estella Reo.urernent (C4te)NNWSI-50P-02-01-Rev. O, Sec.1.0, cara.1.2.t organization states: "it more than one organization is involved in the execution of activities affecting qualit:

then the responsibility & authority of each organization shall be established (cont'd)

Frdng Contrary to the above recuirements, the USGS CAPP-Rev. O, Sec. OMP-1.0 does not delineate in writing the resoonsibility & authority of each organization involved in tr execution of activities affecting quality, and does not address external and internal interfaces between organizational units. In the case of internal interfaces, (cont'd)

Approved By LA A &'/f/Af Response Due Date c Approved By WWO/NV 4//o R6

]

Date Response (To be ecmckteo by audted organzaten.)

I,w;e,T+,taten Date Subentted By -

Date r

l t

To be cc.w>eted by lead audtcr (LA) and reviewed by WWO/NV Correctve Acton Response Reviewed by LA/Date O satafactory 0 Unsatsfactory Reviewed by WWO/NWDate Corrective Acton I.T06T-ataten Reviewed by LA/Date O satisfactory 0 Unsatisfactory Reviewed by WWO/NV/Date t:

Reaudt Date

, Remarks Audt Frdrg Cosed O LA Concurrence /Date Reference and Nrnber(s) for unsatsfactory reaudt

WMPO Audit Finding No. 362a-9 cont'd Reg. cont'd clearly and documented. The external interfaces between organizations and the internal interfaces between organizational units and changes thereto shall be documented. Interface responsibilities shall be defined and documented."

NNWSI-SOP-02-01-Rev. O, Par. 1.1.1; Organization, states in part . . the authority and duties of persons and organzations performing activities affecting quality shall be clearly established and delineated in writing.

Finding cont'd the Geological Division QA Specialist Central & QA Specialist Western Division, and Nuclear Hydrology QA Specialist responsibflities and authorities are not defined and documented. The aforementioned QA personnel as depicted in the USGS Organization Chart do not appear to ha've access to management levels such that they have the required organizational freedom including sufficient independence '

from cost and schedule when opposed to safety considerations. Note: see AFS-86-2A-1.

Additionally, the USGS QA organization does not clearly' delineate in writing the authority and responsibility for the external interfaces between organizational units performing activities affecting quality e.g. Los Alamos National Laboratory '

who is performing internal and external audits for the USGS and the Bureau of Reclamation who is performing site characterization activities including, but not limited to, surface hydrology.

a p , - , ,n< .- .--- -

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. 733 (To be used for al AFSs wr:n adoed sheets as recased) 862a-1, pg a. of h_.

Audt Frdg No. 862a-10 Audted Checust Reference 0ues. 5.

Audted Orgaruata USGS Orgaruaten Urvt GA Actmty II Procram Response Assxpied To W. W. Oudley, Jr. Reported By (Audtor) R.F. Cote /J.W. Estella Rossement (Ote) NNWSI-50P-02-01-Rev. O. Sec. 2.0, Par. 2.1.1: Program: states in cart.

the orogram shall identify the systems, structures, comconents, and activities to be covered by the QA Program Plan.

pm Contrary to the above recuirement; the USGS OAPP, Rev. 2 does not address cro-

visions for the Ouality Assurance crocram to control activities associated with coer3-tion of the core library facilities at the NTS for handlino, storine, and distributinc material samoles and core for the commercial nuclear waste manacement activities (cont Approved By LA L A My/M Response Due Date chN!

Approved 8y WWO/NV w 4//o /f' Date i

Response (To be corroieted by audted orgatua, tert)

I

,,,.,:emer,taten Date Subtrutted By -

Date 1

To be completed by lead audtor (LA) arid revowed by WWO/NV Corrective Acton Response Reviewed by LA/Date O satisfactory C Unsat= factory Revewed by WWO/NV/Date

' Corrective Acton implementaten Reviewed by LA/Date O satisfactory 0 Unsatsfactory Reviewed by WWO/NV/Date Reaudt Date Remarks Audt Fridng Cosed O LA concurrence /Date Reference and Nunter(s) for unsatsfactory reaudt 4

i

. o WMP0 Audit Finding No. 362a-10 cont'd Finding cont'd at the NTS as required by the NNWS! Quality Assurance Plan. Ncte: refer to AFS-86-2A-11 for additional information. '

IO

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$C/~2 (To be used for al AFSs wrth added sheets as recured) 862a-1, pg 45 of Audt FW No. 862a-11 102 Ques. (3 a Audted Checkist Reference 60 or 102 (Q Audted Orgarizate USGS Organzaton Uret GA Actvrty (13) Storice Handlino & Shiocine Resocnse Asscred To W. W. Oudley, Jr. Reported By (Audtor)R.F. Cote /J.W. Estella Requrement (Cae) Rec. No. 1 NV0-196-17-Rev. 3,Sec. 5.0, car. 5.1. states in cart all activities affecting quality on the NNWSI project will be performed utilizing aaprove instructions, orocedures, drawings, or other documents. (cont'd)

F4 Contrary to th'e above reouirement; the USGS Quality Assurance crocram does not maintain WMP0 acoroved 0A administrative oracedures for the storace handlina & sh of core samoles and other materials associated with NNWSI activities to creclude damag+

loss, or deterioration by environmental conditions. This condition is of (cont'd)

Approved By LA $J V//[fd Response Due Date C  !

Approved By WWO/NV h -

4 //o / 6 Date J

Resoonse (To be comc4ted by audted organzatx:n)

.. ATor,taten Date Submrttec By ~

Date To be completed by lead audtor (LA) and reviewed by WWO/NV i

Correctve Acton Response Reviewed by LA/Date O Satisfactory 0 Unsatsfactory pevew ,y w,g,yy,g,,,

Correctve Acton implementaten Reviewed by LA/ Data O Satisfactory 0 Unsatsfactory Reviewed by WWO/NV/Date Resudt Date Remarst.s L

Audt Fodng Cosed O LA Concurrence /Date Reference and Nunter(s) for unsatsfactory reaudt

. o WMP0 Audit Finding No. 8623-11 cont'd Req. cont'd Reg. No. 2 NV0-196-17-Rev. 3, Sec. 5.0, Par. 5.1, states: QA administrative procedures or documents provide instructions for implementation and application of NV0-19.6-17 and the participating organizations' . . QAPPs. Req. No. 3 NV0-196-17-Rev. 3, Sec. 5.0, Par. 5.3, states in part: the administrative QA procedures will require WMP0 review and approval prior to use.

Finding cont'd particular concern since the USGS is responsible in part for the operation of the core library facilities at the NTS including, handling, storing, and distributing material samples and core for the commercial nuclear waste man-agement activities at the NTS.

Note: refer to AFS 86-2A-10 for additional information.

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862a-12 3623-1, oc 44 of Aus Fm No- Audted Checkist Reference 102 Ques.(1) and Audted Orgaruaton USGS Ormaton Unt GA Activity (9) Control of Processes Response Assged To W. W. Dudley, Jr. Reported By (Audtor) R.F. Cote /J.W. Estella Requrement (Cete) Rec. No. 1 NV0-196-17-Rev. 3, Sec. 9.0, Par. 9.2; states; wnen scecia processes are recuired to control cuality, the use of qualified personnel, equipment, c procedures is necessary, the criteria for cualification of personnel, equipment , (con-Frdng Contrary to the above reouirement(s), the USGS Quality Assurance Plan does not address orovisions to be established for the cualification of personnel, equioment, anc.

orocedures and for the control of scecial oracess verification methods to be documentet for core samole oreparation. This condition is of carticular concern since the (cont'd.

Approved By LA h MMW Response Due Date cNN h" Approved By WhPC/NV h k i 4 do /"" Date Response (To be comodeted by audted organzaton.)

' Ai,ei.taten Date Submrtted By -

Date To be cornpieted by lead audtor (LA) and reviewed by WNFO/NV Corrective Acton Response Reviewed by LA/Date O satisfactory G Unsatsfactory Reviewed by WhPC/NV/Date Corrective Acton trmiementaten Reviewed by LA/Date O satisfactory 0 Unsatsfactory Reviewed by WhPO/NV/Date Reaudt Date Remarks Audt FrW Closed C LA Concurrence /Date Reference and Number (s) for unsatsfactory reaudit

' o WMP0 Audit Finding No. 862a-12 cont'd Rea. cont'd and procedures, and the maintenance of the qualification records will be specified in the participating organizations' and NTS suoport contractors' QA programs.

Special process verification methods and criteria will also be documented and retained. Req. No. 2 NV0-196-17-Rev. 3, Sec. 9.0, Par. 9.3; states in part .

examples of special processes include, but are not limited tc . . core sample preparation.

Req. No. 3 NV0-196-17-Rev. 3, Sec. 9.0, Par. 9.4; states; for QA Level I activitics, the participating organizations and NTS support contractors will forward their special process procedures to WMP0 for review and approval prior to use.

Findina con +.'d USGS has and is presently processing core samples for NNWSI activities prior to the development review and approval by WMPO of these scecial process procedures.

9

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C 2 5 M'M WMPO AUDIT FINDING SHEET (AFS) 2 ^ -*

7~ 33 (To be used fer al AFSs wr:n addec sneets as recurec.)

862a-13 86-2a, pages 5, 8 Audt F@ No. Audted Checkist Reference 9, 11, 13-15.

Audted Crgaruation U.S. Geological Survey - Denver l Crgaruation Urrt Geoloaic/ Hydrologic Divs. Activity N$ kdvheU"boS$eN E@[05 Response Assigned To W. W. Oudley, Jr. Reported By (Audtcr) Ed Oakes i Requiernent (Cte) (Part 1) NNWSI 196-17, Rev. 0 (1980), Sec. 17, Para. 17.1 and USGS-0 APP-01 RO, Sec. 17 states that sufficient records, including the results of technical reviews, will be maintained to succort conclusions reached from investigations, (cont'c g 4 (Part 1) Many of the publication files requested for review did not contain peer' review comments. In several oublication files that did contain oeer-review coments, resolution of the comments by the author (s) was unclear. (Part 2) WMP0 asked several interviewees to produce the written oeer-review crocedures in effect orfor to (cont'd)

Accreved By LA (ml MMfd Rescense Cue Cate C Accreved 8y WMPC/NV h bb >

//o /(6 Cate Rescense (To be ccmcleted by audted crgancaticn.)

l 1

'n clementation Date Submtted By Date To be cerrpleted by lead audtor (LA) and reviewed by WMPC/NV Corrective Action Response Reviewed by LA/Date C Satisfactory C Unsatisfactory Reviewed by WMPC/NV/Date Corrective Acticn Implementation Reviewed by LA/Date O Satisfactory C Unsatsfactory Reviewed by WMPC/NV/Date i

l Resudt Date Remarns Audt Fodng Cosed C LA Concurrence /Date Reference and Number (s) for unsatisfactory reaudt

e o a

WMP0 Audit Finding No. 862a-13 cont'd Reg. cont'd 3

and (Part 2) NNWSI 196-17 Rev. 0 (1980), Sec. 6, Para. 6.1. states that each particioating organization have existing written procedures which describe how They control their own quality-related documents.

Finding cont'd NNWSI-USGS-QMP-3.04, Rev. 0; evidence that these procedures existed was not produced.

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. 733 (To be used for al AFSs wrth added sheets as reQured.)

862a-14 262a-2, pg 3 Audt Frn:h3 No. Audted ChecALst Reference #3 & *6 Audted Orgaruatx:m USGS - Denver Orgaruabon Unrt Site Investigation Actmty Documentation l Response Assxped To W. W. Dudley, Jr. Reported By (Audter) Forrest O. Peters Remsement (Ote)NVO 196-17 Rev. 3 Para. 3.2.2 and 3.2.3 3.2.2 Prior to the start of a<

site investigation, the responsible Participating Organization shall develop a clan wh will describe the tests and exceriments which will be utilized to determine the (cont'<

Frdng The USGS has been and is aerforming numerous site investigations for the NNWSI oroject, as listed in The Work Breakdown Structure Dictionary, without any accroved site investigation olans, and therefore, has been and is violating tne reouirements of the referred caragraohs. The referred oaragraohs clearly archibit any site (cont'd)

Approved By LA o A VNhl Respcose Due DatekhcNiN 8b

Approved By WWO/NV d*/M Date Response (To be corroleted by audted organzaton.)

l l

In AT 6tation Date Submtted By Date To be correleted by lead audtor (LA) and reviewed by WWO/NV Correctve Acton Response Reviewed by LA/Date O Satusfactory O Unsatsfactory Reviewed by WWO/NV/Date Corrective Acton .'T&T=ntation Reviewed by LA/Date O satisfactory 0 Unsansfactory Reviewed by WWO/NV/Date Reaudt Date Rernarks Audt Frdng Cosed O LA Concurrence /Date Reference and Pktnber(s) for unsatsfactory reaudt

,1 WMPO Audit Finding No. 862a-14 cont'd Rec. cont'd geologic, hydrologic, geotechnical, or tectonic mean values and range of uncertainties of the natural host formation. The plan shall present sufficient detail. to determine whether or not the activities to be conducted, the methods of analyzing the data to be gathered, and the modeling methods will ensure tnat the end results will provide sufficient information necessary to evaluate the ~

characteristics of the natural barriers against the criteria specified in 10 CFR 191.

3.2.3 The responsible Participating Organization shall conduct a technical review on 4

the plan prior to the start of any' activities associated with the plan.

Finding cont'd investigations from being performed, until and unless, a site investigation plan has been prepared, technically reviewed, and approved by WMPO.

It is true that extensive plans are in existence, or are in preparation, for the site characterization plan (SCP) and the exploratory shaft test plan (ESTP),

but these plans are not in effect at this time. The USGS has generally failed to provide, or to technically review, site investigation plans for their activities within the site exploration phase of this project.

It is also true that the USGS did prepare a Work Plan for the USGS Partici-pation in the Nevada Nuclear Waste Storage Investigation, for the fiscal year 1985 activities, but this was apparently a preliminary draft which was never completed, reviewed, or submitted to WMPO for approval. A similar document was also prepared for the fiscal year 1986, but again, this was also apparently a preliminary draft l which has not yet been completed, reviewed, or submitted to WMPO for approval.

l These documents do not therefore, fulfill the requirements of NVO 196-17 Para 3.2.2 and 3.2.3.

L (See Audit Finding 86 2a-15. )

i

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862a-2 og. 3 Audt Fe&g No. 862a-15 Audted Checkist Reference "4 5 16 Audted Orption USGS - Denver Crgarnaten Urvt GA Actrvrty Precaration of USGS OAPP Response Asagred To W. W. Oudley, Jr. Repor*ed By (Audter)Forrest D. Peters Recurement (Cte) NV3 196-17 Rev. 3 Para. 2.1, 3. 2. 2, and 3.2. 3. 50P 02-01 Para. 2.1.2 The OAPPs shall orovide for the olanning and accomolishment of activities affecting I

ouality under suitable controlled conditions. Controlled conditions include the (cont'e 74 The USGS CAPP does not orovide for the planning of the site investigation activities affecting ouality as recuired by (Para. 2.1) of NVQ 196-17 Rev. 3, as furthe amolified in Para. 2.1.2 of SOP 02-01 Rev. O, and Para. 3.2.2. and 3.2.3 of NVO 196-17

Rev. 3.

Approved By LA _4 MY/s% Response Cue Cate ch!N h*'

Accreved By WPSC/NV w 4//o[(6 Cate J

Response (To be ccmoleted by audted orgaruation.)

freciementation Date Submitted By Cate l To be completed by lead audtor (LA) aM reviewed by WPeO/NV

! Corrective Action Response Revowed by 1.A/Cate C satisfactory O unsatisfactory Reviewed by WP#C/NV/Cate Corrective Action Inwiementation Reviewed by LA/Cate C Satisfactory C Unsansfactory

• Reviewed by WP&O/NV/Cate '

Resudt Date Remarks Audt Fedng Cosed O LA Concurreneescate Reference and Nmber(s) for unsatisfactory reaudt

)

, , _ - - - , - , - - ---,---,,n. _ _ , . - - - . - , - , , - - , - - - . - , , . , - - - - - , . - - - - - . , , ,

• o WMPO Audit Finding No. 86-2a-15 cont'd Reg. cont'd use of acoropriate eouiement, suitable environmental conditions for accomplishing the activity, assurance that prerequisites for the given activity have been satisfied, and control for verification of quality activities. SOP 02-01 2.1.2 Activities that affect quality should be planned and documented to assure a systematic approach, Planning should result in the documented identification of methods and organizational responsibilities. Planning should be performed as early as practical and no later than the start of those activities that are to be controlled to assure interface compatibility and a satisfactory approach to QA. NVO 196-17 3.2.2 Prior to the start of a site investigation, the i

responsible Participating Organization shall develop a plan which will describe the tests and experiments which will be utilized to determine the geologic, hydrologic, geotechnical, or tectonic mean values and range of uncertainties of the natural host formation. The plan shall present su.fficient de, tail to determine whether or not the activities to be conducted, the methods of analyzing the data to be gathered, and the modeling methods will ensuri that the end results will provide sufficient information necessary to evaluate the characteristics of the natural barriers against the criteria specified in 10 CFR 191. 3.2.3 The responsible Participating Organization shall conduct a technical review on the plan prior to the start of any activities associated wit'. the plan.

4 1

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,_ { WMPO AUDIT FINDING SHEET (AFS) Iss^"

(To be used for al AFSs with added sneets as recured)

Audt FrW No. 862a-16 Audrted ChecAist Reference _(See note below)

Audted Orgaruate USGS - Denver Organuata Urvt 0A Sucolier Evaluations / Certification Actrvrty__of Personnel Response Assywd To _ W. W. Dudley Jr.

Reported By (Audtor) N. Voltura/S. Singer Recurernent (Ote) SOP-02-01. Rev. O Para.17.1.1 states:

" Sufficient records shall be maintained to furnish evidence of activities that affect ouality.

The re::ords shall include at least the followino:

. . oualifications of cersonnel . . ."

FM.g Contrary to the above, certifications of audit eersonnel who have cerfor supplier evaluations are not on file at USGS. Therefore, the acceotability of sucolier evaluations cerformed by these individuals cannot be determined.

A'oproved By LA o v/7/pg, N h"'

Response Due Date c Approved By WhPC/NV -

v 4 //o /t' Date Response (To be ecmpleted by audted orgarnata.)

k

. Ar+ > tate Date Submrtted By

_ Date ~

To be corroieted by lead audter (LA) and reviewed by WWO/NV Correctrve Acta Response Reviewed by LA/Date O satisfactory O Unsatsfactory Reviewed by WWO/NV/Date Correctrve Action Implernentata Reviewed by LA/Date O Satisfactory 0 Unsatsfactory .

mm/Date Reaudt Date Remarks i Audt FrW Cosed O LA Concurrence /Date Reference and Nurnber(s) for unsatisfactory reaudt

g .

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862a-1, pg 4 or_

Audt Frdng No. ,3623-17 Audted Checkist Reference 102 Ques. 6.A, 6.

Audted Orgaruaten USOS Orgaruaden Urvt GA Acevrty Orcanization (I)  !

Response Assge:i To W.W. Dudley, Jr. Reported By (Audtor) R.F. Cote /J.W. Estella 1

Reo.sement (C.te) NNWSI-USGS-QMP-1.01, R0. Pg. 5 of 5, Par. 4.10; states: "All succort d other contractors with activities directed at the NNWSI-USGS Project shall either comol with the reouirements of the NNWSI-USGS OA Program Plan as specified by contract (cont'c g4 Contrary to the above reauf rement, USGS contracts with various succort contracti (e.c.) Inst. of Geochvsics/01anetarv Physics. Petrocrachic Services. Colorado Sc5 col of Mires, and others do not soecify that these contractors will imolement the USGS OA Program for their activities nor does objective evidence exist to demonstrate (cont'd).

Approved By LA ,

E'4 8 /74 Resocrise Due Date cbb!$b Approved By WhPO/NV w b 4//o/96 Date

)

Besoonse (To be corrc4eted by audted orgatuaten.)

i irrpiernentaten Date Submrtted By ~

. Date To be corrchted by lead audtor (LA) and reviewed by WhPC/NV Correctve Acton Response Reviewed by LA/Date O satafactory 0 Unsatufactory Reviewed by WhPC/NV/Cate Corrective Acten '. TAT =6taten Reviewed by LA/Date -

O Satafactory 0 Unsansfactory l Reviewed by WhPO/NV/Date Reaudt Date

~

Remarks 1

i Audt FrW Cosed O LA Concurrence /cate Reference and Nrnber(s) for unsatsfactory reaudt l

4- <,

4 WMP0 Audit Finding No. 862a-17 cont'd

- Req. cont'd or they shall have an equivalent program of their own."

Finding cont'd <

that these contractors have an equivalent program which meets the requirements of the NNWSI Project QA Plan.

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(To be used for AA AFSs with added sheets as re% rect) 862a, pg 43 of IC, i Audt F4 No. 362a-18 Audted ChecALst Reference Ques. 7 Audted Orgaruaten USGS Orgarvaton Lbyt GA Actrvity C-He*+ a f 9 i Response Assged To W. W. Oudley, Jr. Reported By (Audtcc) R.F. Cote /J.W. Estella Recurement (C4te) NNWSI-50P-02-01-Rev. O. Sec. 8.0, Dar. 8.2.2.2, states: items or samoles having limited calendar life, or items having limited coerating If fe or cycles.

shall be identified and controlled to preclude use of items or samoles for which (cont' pridng Contrary to the above recuirements, the USGS CA crocram does not address orovi-sions to control the utilization of limited calendar life items or sa cles Ie.c.) at9-samples to assure that these items or samoles are not used after such time that their chemical and physical orocerties may change which would affect the resulting data.

Approved By LA  ! -M <//y/F[ Response Due Date c $

Approved By WhPO/NV ri- 4 //o/% Date J

Resoonse (To be ccateted i by audted orgarnaton.)

Irnoiementaten Date Submrtted By ~

Date l

To be completed by lead audtor (LA) and reviewed by WhPC/?N Corrective Acton Response Reviewed by LA/Cate O satisfactory 0 Unsatisfactory l Reviewed by WWOMV/Da:e Corrective Action 'cwiementaten Reviewed by LA/Date i O satisfactory C Unsatisfactory i Reviewed by WWOM//Date l Resudt Date Remarks

Audt Fridng Closed O LA Concurrence /Date l Reference and Numcer(s) for unsatisfactory reaudt

- , - . ~ - - ,,an -- ...._-n.,., .,_,,.,,,-----_.e _ , -__. _,.,., _,, .,_

e n .

WMP0 Audit Finatng No. 862a-18 cont'd Req. cont'd the shelf 11fe or operating life has expired.

o-d ,,i WMPO AUDIT FINDING SHEET (AFS) pf<2

. mh s (Tc be used for al AFS4 wrth aoded sneets as rec. rec.)

Audt Fn&g No. 862a-19 Auctec Chec.sist Reference 962a-1 aq.43 of 1 Audted Crgarnation USGS Crgarwaten Urvt Quality Assurance icentificacion ano controi of Activrty Materials. Parts a cenoonents Rescense Assigned To Recerted By (Audter) J. W. Estella Rec.drernent (Cte) NNWSI-USGS-CMP-8.01, Rev. O, paragraph 3 requires the f centification geologic and hydrologic samoles to be controlled from initial collection tnrougn discosal and that this identification be correlated from the samole to (cont'd)

Fodng Contrarv to the above cited reouirement. there is no obiective evidence to succort that the reouired QA Manager review is being cerformed. In addition there are no orovisions in the USGS technical procedures to reouire tnat this samole documentati be orovided to the USGS OA Manager for review.

Approved By LA wa1 r/A/74 Rescense Cue Cate c Accreved Sy WWO/NV M Q )

4 //o /(6 Cate Rescense (To be ccrreleted by audted crgaruation.)

lrrperrentation Date Subrntted By Cate To be cerrpieted by fead audtor (LA) and reviewed by WMPC/NV Corrective Action Resoonse Reviewed by LA/Cate O Sa acwy O WWam Reviewed by WMPC/NV/Cate Corrective Acticn kMintation Reviewed by LA/Cate

• O Satisfactory C Unsatisfactory Reviewed by WMPC/NV/Date Reaudt Date Reenarks I Audt Focog Cosed O LA Concurrecce/Date Reference and Nurnber(s) for un:atsfactcry reaudt _,

. WMPO Audit Finding No. 862a-19 cont'd Rec. cont'd pertinent documents. Paragraon 5 of thf s procedure recuires that once the sample has undergone all tests and analyses, the samole documents must be reviewed for completeness and adequacy by the QA Manager. This revien must be documented by signature of the QA Manager.

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' 73 3 (To be used for aJ AFSs wrm acceo sneets as rect. rec.)

862a-20 86h, @ %

Audt Frsg No.

Audted C.hecxist Reference Ques. (1)

Audted Crgaruation U.S. Geological Survey - Denver Orgaruation Urrt Record Processing Center Activity Quality Assurance Records Resconse Assxped To W. W. Oudley, Jr. Reported By (Audter) Ed Oakes Recurerrent (Cte) NNWSI-SOP-02-01 (RO), Sec.17 Para.17.1.1 recuires that saecific records be maintained in the USGS's " Record Processing Center."

1 F4 Cooies of some required records, such as audits and reviews of technical publications, are neither identifiable or retrievable, au cays arcar Accreved By LA - A f/9Z Resconse Oue Cate Receiet of Accreved Sy WMPC/NV h b >

4 o / (6 Cate Resocnse (To be ccrreleted by audted crgatuation.)

terciementation Cate Subrretted By Da'te To be ccmpleted by lead audter (LA) and reviewed by WWO/NV Corrective Action Response Reviewed by LA/Cate C Satisfactory C UnsatLsfactory Reviewed by WMPC/NV/Cate .

Corrective Acticn lenplernentation Reviewed by LA/Date C Satisfactory C Unsansfactory Reviewed by WWO/NV/Cate -

i Reaudt Date Remarks .

Audt Frds Cosed C LA Concurrence /Date Reference and Nurnber(s) for unsatisfactory reaudt

• 9 I WMPO AUDIT FINDING SHEET (AFS) ^-02

1. 75 g

(To be used for al AFSs wrth aoded sneets as recurec.)

Audt Frdng No, 862a-21 Audted Checkist Reference Page 82 of 102 Audted Orgaruation USGS - Denver Crgaruation Urvt Records Processino Center Activity OA Records Rosconse Assigned To W. W. Oudley, Jr. Peocrted Sy (Audter) Ed Oakes Recurernent (Cite) SOP-02-01, Rev. 0 (1) Para. 5.1.1 states in part: " Activities that affect quality shall be prescribed in documented instructions, procedures . . . of a type acorooriate to the circumstances . . ." Para. 5.3.1 states in cart: (cont'd)

Fedng (1) Contrary to requirements 1 & 2 above USGS records are being processed /re-viewed using an unacoroved 0A orocedure "0A Records Management Guidelines" cated 1/28/86. (2) Contrary to reautrement 3 above, measures have not been established to identify / document those oersonnel who are authorized to validate records.

Apcreved By LA i

$n % c//p/fd CNN oper Resocnse Oue Cate Accrevec Sy WMPC/NVdh h- 4 //o / r(* Cate Re rt Resocnse (To be ccrreleted by audted crgaruaocn.)

i trrelementation Date Subrntted By Cate i

To be completed by lead audtor (LA) and reviewed by WP&O/NV Corrective Action Response Reviewed by LA/Cate

, O Satisfactory C Unsansfactory l

Reviewed by WMPC/NV/Cate l Corrective Action ferpiementation Reviewed by LA/Cate l

C Satisfactory C Unsatisfactory Reviewed by WP#0/NV/Cate Reaudt Date Remarks Audt Fedng C;osed O LA Concurrence /Cate Refererce and Nurnber(s) for unsatisfactcry reaudt '

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'NM90 Audit Finding No. 862a-21 cont'd Reg. cont'd

". . . QA administrative documents for Level I shall be approved by WMPO before they can be used." (2) USGS-QMP-17.01, Para. 4.3 states in part: "The Records Administrator is responsible for management and implementation of the USGS records management system. This includes instituting a program to review potential QA records to ensure their completeness, suitability and legibility, and for retention processing. The Administrator will also be responsible for receipt control, indexing and submittal to the PRC." (3) USGS-QMP-17.01, Para.

5.5 states in cart: "All documents, including controlled documents, are to be stamped, initialed, or signed and dated by authorized personnel, or otherwise authenticated, appropriate to the class of the documents . . ."

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Q8 WMPO AUDIT FINDING SHEET (AFS)

(To be used Ice al AFSs wrth added sraets as recure<1)

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78s Audt Fn: fog No. 862a-22 Audted Checkist Reference 962a-16.5.1 Audted Orgaruatien USGS - Denver Orgaruation Lht GA Activ ty NCR, CAR and Audit Procedures Response Assigned To W. W. Dudley, Jr. Reocrted By (Audtcc) N. '/citura/S. Sincer i Recurement (Cite) NNWSI-USGS-0MP-16.01, Rev. O Para. 5.1 states in cart: " . . . Periodic examination of Nonconformance Recorts, Audit Recorts, or other documents often reveal the need for a CAR, but a CAR also may be issued as a result of any observation (con't '

g4 Contrary to the above, no documentation, USGS CAR, has been generated to identi, numerous recurring conditions adverse to quality. There are 29 outstanding /coen audit findings identified by LANL for USGS wnich have not been resolved; many of these identify recurring conditions.

Approved By LA N[ A v/Y/Yd Response Oue Date cb!

Approved By WMPC/NV e , 4 //o/f6 Cate _

Resecnse (To be cerrckted by audted crgatuation.)

Irrelementation Cate Subrrrtted By Cate To be cornpleted by lead audtor (LA) and reviewed by WMPC/NV Corrective Aeson Response Reviewed by LA/Date O Satisfactory C Unsatisfactory Reviewed by WMPC/NV/Cate Corrective Acticn LTAT ntaben Reviewed by LA/Date O Satisfactory O Unsansfactory Reviewed by WMPC/NV/Date Resudt Cate Remarks Audt Fodng C:osed O LA Cencurrence/Date Reference and Nurnber(s) for unsatisfactory reaudt

s o.

a WMPO Audit Finding No. 8621-22 cont'd Req. cont'd which discloses a ". . . recurring adverse situation or condition.

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t k h CLOS'JE b A

i Report of CGR Participation in WMPO QA Audit of USGS - Denver Auditing Organization:

Waste Management Project Office, Nevada operations office Audited Organization:

United States Geological Survey, Denver Dates of Audit: March 11 - 14, 1986 Audit Scope:

(1) Programmatic (all 18 criteria)

(2) Technical supporting EA)

(Selected technical reports Audit Team Members:

Sam Singer, SAIC (Lead ~ Auditor)

- Nancy Voltura, SAIC (Auditor) -

John Estella, SAIC (Auditor) .

Ren Cote, SAIC (Auditor in Training) '

Forest Peters, SAIC (Auditor in Training) -

Ed Oakes, SAIC (Technical Advisor)

Carl Newton, DOE-HQ (Auditor in Training) ,

Paul Prestholt, NRC-HQ (Observer Susan Billhorn, NRC-HQ (observer))

, Summary of Audit:

i The audit was divided into three teams.

Sam15, 12, Singer, 16 andconducted

18. a programmatic audit cf criteria 4The ,6 first" team, 7

led by "

matic audit of criteria John1,Estella led a seco.nd team in a prog, ram,-

2, 8, 9, 10, 13 and 14.

The second taken in' response to the findings from the previous aud l ,

A third team led by Ed oakes conducted a technical audit in(#8S-12).

which selected reports reviewed for adequacy.referenced in the Environmental Assessment were ^

,5, 11, and 17 and some selected test procedures.The third team also exam

, s. . .

At the and of the second day of the audit it wa~s apparent to all 2 l audit team members that the USGS work was not being controlled by.-

the QA were program and that significant problems adverse to quality prevelant. ~

The team unasiously voted to recommend to the j

\

cant problems were corrected.,WMPO project manager that he stop ,

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At the exit findings meeting from the Audit Team Leader reviewed the 25 expected the audit.  :

The most serious, in my opinion, are:

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The lack of an indoctrination and training program which has led to an ignorance among USGS personnel of quality requirements, such as instrument calibration and the conduct of peer reviews, and an apathy by management and_ workers toward documentation of quality achievement.

2. .

The lack of detailed site investigation plans describ-ing the the nextwork year. that USGS preposes to do for WMPO over .

4 3.

The failure to clearly delinate authority and respon- -

sibility within the USGS organization and between Reclamation. other participants, such as the Bureau of USGS~.and 4.

The activition lacle beingof assigned performed. quality levels to the work -

~ Eval'uation of Conduct of Audit:

The audit checklist was excellent. The questions were well thought out and thorough.

been overlooked.and the questions were phased in such aNo important a manner and auditse that they: were readily understandable by both auditor i . .

, The pre-audit and well handled. meeting for the audit team was a very good idea -

of the checklist was explained v.11 -The conduct and scope of the -

audit, and use team um.*4ng after-each Tay's activities were invaluablaI also thi_nk the daily their conduct of the audit.e audit team leader ando members were very pr'fess t-At the exit meeting one of the y NRC observers:

I concur. . g 5; - said. she had never seen a team so well prepared.-  ;

' Scae are: areas % .

iliInW 31 offer a potential for improvement in the future t

'pr- - .

1) Art advance copy of the checklist to all team l members would have been useful, 2) some time set aside each day to discuss questions of the checklist would be useful - perhaps at the beginning of each day.

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3)

.I was sorry to see only SAIC people - no DOE-WMPO representatives exit meeting). were on the audit (except at the.

4) I was stunned by the " lack of respect" exhibited by the USGY management for the QA Audit - the team was told at,the entrance meeting they would be prohibited from interviewing principal investiga-tors because they w'ere working on more important matters.

This situation would'probably been turned around except for the presen.not~have ca of DOE-f HQ on the audit and some aggressive intervention.-

5)

The either role theofpre-audit USGS observers was notordiscussed team meeting the at entrance meeting and probably should have been.

6)

There wasbynoWMPO personnel schedule auditfor interviews of USGS teams.

7)

There was no briefing by USGS on the.ir srgani-zation at the entrance meeting.

would be helping in determining the responsibi-Such a briefing lities of those being interviewed in the audit and in how they relate to other departments in USGS.

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OR CCRWM DISTRIBUTION

SUBJECT:

Report of WMPO Audit of USGS ADDRESSIE: J. Knight CCRWM Distribution: BCC:

W. Purcell, RW-20 -

T. Isaacs, RW-22 , D. Siefken, Weston L. Skoblar, Weston M. E. Langston, RW-40 H. Steinberg, RW-33 E. Sulek, Weston Originator's Chron: Newton # Kennedy, NRC ~

OCRWMe CCRU, RW-13 (5)

OGR Reading File L&R Div. Chron L&R Div.' File # 6510.903.9.2 .

RW-24:CNewton:KMA:252-5625: typed 4/1/86 PC Code: WMPO Mach C .

CONCURRENCES:

N/ 2 /fl C. Newton, RW-24 f 8 e.

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