            2014 Compliance Recertification Application (CRA-2014)
       Compliance Application Review Document (CARD for Section 194.22)
                              Quality Assurance 
	
22.0   Background  

      Quality Assurance (QA) provides for preliminary assessments of the quality/reliability of items and activities that are important to the long-term isolation of transuranic wastes inside the Waste Isolation Pilot Plant (WIPP). The purpose of these QA assessments is to identify   problems with the reliability of any item or activity that is important to isolation. These QA assessments are conducted under the authority of QA Organizations from the U.S. Department of Energy (DOE). The assessments are in the form of reviews, inspections, tests, audits, surveillances and formal peer reviews. DOE's QA Organizations are separate from DOE's operational organizations that directly produce the items or perform the activities that are important to long-term isolation of TRU waste. The items and activities include the technical data and analysis underlying the DOE's Compliance Certification Application (CCA), the 2004 Compliance Recertification Application (2004 CRA or CRA04), the 2009 Compliance Recertification Application (2009 CRA or CRA09), and the 2014 Compliance Recertification Application (2014 CRA or CRA14). DOE's QA assessments "qualify" WIPP's items and activities before final assessments that are conducted by the Environmental Protection Agency (EPA or the Agency). Quality Assurance is a process to enhance the quality/reliability of the WIPP's items and activities prior to the EPA's assessments. 
      
      Section 194.22, titled "Quality Assurance", invokes three specific Nuclear Quality Assurance (NQA) standards for WIPP's QA program. Paragraph (a)(1) of Section 194.22 requires DOE to establish and implement a QA program that complies with the following NQA standards of the American Society of Mechanical Engineers (ASME):
 "Quality Assurance Program Requirements for Nuclear Facilities" (NQA-1-1989).
 "Quality Assurance Requirements of Computer Software for Nuclear Facility Applications" (part 2.7 of NQA-2a-1990, addendum to ASME NQA-2-1989). 
 "Quality Assurance Requirements for the Collection of Scientific and Technical Information on Site Characterization of High-Level Nuclear Waste Repositories" (NQA-3-1989), excluding sections 2.1(b), 2.1(c) and 17.1.

	The main functions for QA Programs are found in NQA-1-1989, Basic Requirement 1, titled "Organization", as follows:

Persons or organizations responsible for ...verifying that activities affecting quality have been correctly performed shall have sufficient authority, access to work areas, and organizational freedom to:
 identify quality problems;
 initiate, recommend or provide solutions to quality problems through designated channels;
   
   
 verify implementation of solutions; and 
 assure that further processing, delivery, installation, or use is controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.

	For EPA's oversight of the WIPP, "quality" is defined as the reliability of an item or activity that is important to the long-term isolation of transuranic waste.  Therefore, a "quality problem" is a problem with the reliability of any item or activity that is important to isolation.   Thus, the main function of WIPP's QA Organizations is to identify problems with the reliability of any such item or activity.  
	
	A copy of the NQA standards can be obtained from:

	The American Society of Mechanical Engineers
	Three Park Avenue, New York, NY 10016-5990

22.1 Requirements  

	(a)(1) "As soon as practicable after April 9, 1996, the Department [Department of Energy] shall adhere to a quality assurance program that implements the requirements of ASME NQA-1-1989 edition, ASME NQA-2a-1990 addenda, part 2.7, to ASME NQA-2-1989 edition, and ASME NQA-3-1989 edition (excluding Section 2.1 (b) and (c)), and Section 17.1). (Incorporation by reference as specified in Sec. 194.5.) 

(2) Any compliance application shall include information which demonstrates 		that the quality assurance program required pursuant to paragraph (a)(1) of this 		section has been established and executed for: 

	(i) Waste characterization activities and assumptions; 

	(ii) Environmental monitoring, monitoring of the performance of the 			disposal system, and sampling and analysis activities; 

	(iii) Field measurements of geologic factors, ground water, meteorologic, 			and topographic characteristics; 

	(iv) Computations, computer codes, models and methods used to 				demonstrate compliance with the disposal regulations in accordance with 			the provisions of this part; 

	(v) Procedures for implementation of expert 	judgment elicitation used to 			support applications for certification or recertification of compliance; 

	(vi) Design of the disposal system and actions taken to ensure compliance 			with design specifications; 

	(vii) The collection of data and information used to support compliance 			application(s); and 

	(viii) Other systems, structures, components, and activities important to 			the containment of waste in the disposal system." 

(b) "Any compliance application shall include information which demonstrates that data and information collected prior to the implementation of the quality assurance program required pursuant to paragraph (a)(1) of this section have been qualified in accordance with an alternate methodology, approved by the Administrator or the Administrator's authorized representative, that employs one or more of the following methods:  Peer review, conducted in a manner that is compatible with NUREG-1297, "Peer Review for High-Level Nuclear Waste Repositories," published February 1988 (incorporation by reference as specified in Sec. 194.5); corroborating data; confirmatory testing; or a quality assurance program that is equivalent in effect to ASME NQA-1- 1989 edition, ASME NQA-2a-1990 addenda, part 2.7, to ASME NQA-2-1989 edition, and ASME NQA-3-1989 edition (excluding Section 2.1 (b) and (c)) and Section 17.1). (Incorporation by reference as specified in Sec. 194.5.)" 

(c) "Any compliance application shall provide, to the extent practicable, information which describes how all data used to support the compliance application have been assessed for their quality characteristics, including: 

	(1) Data accuracy, i.e., the degree to which data agree with an accepted reference 		or true value; 

	(2) Data precision, i.e., a measure of the mutual agreement between comparable 		data gathered or developed under similar conditions expressed in terms of a 		standard deviation; 	

	(3) Data representativeness, i.e., the degree to which data accurately and 			precisely represent a characteristic of a population, a parameter, variations at a 		sampling point, or environmental conditions; 

	(4) Data completeness, i.e., a measure of the amount of valid data obtained 		compared to the amount that was expected; and 

	(5) Data comparability, i.e., a measure of the confidence with which one data set 		can be compared to another."

(d) "Any compliance application shall provide information which demonstrates how all data are qualified for use in the demonstration of compliance."

(e) "The Administrator will verify appropriate execution of quality assurance programs through inspections, record reviews and record keeping requirements, which may include, but may not be limited to, surveillance, audits and management systems reviews." 
DOE Establishment of the Applicable QA Requirements for Each NQA-1 Element
   
DOE provided information on the establishment and implementation of QA in the 2014 CRA Section 22. DOE's current QA Plan provided as part of the 2014 CRA, which establishes the NQA standards for the WIPP, is titled "Quality Assurance Program Document" (QAPD). The QAPD was updated several times since the 2009 recertification.  The last revisions in this reporting period was the May 2010 revision which addressed the April 1, 2010, WIPP Hazardous Waste Facility Permit modification for the time allowed for reporting nonconformances to data quality objectives first identified at the Site Project Manager level. The QAPD is referenced as "DOE/CBFO-94-1012, Revision 13" and the document can be found at: http://www.wipp.energy.gov/library/qapd/DOE-CBFO-94-1012_Rev_13_Eff_04-20-17.pdf.
The following paragraphs are general descriptions of the establishment of the applicable requirements of each NQA "Element" or "Basic Requirement" in Section 22 of the 2014 CRA:
NQA-1 Element 1, Organization, is properly established in Section QAPD-2.1.1, titled "Organization", of Appendix QAPD. CBFO's organization is structured so that operational organizations performing the work are responsible for achieving quality. CBFO's QA Organization has the authority and organizational freedom to properly verify the achievement of quality. CBFO's requirement for Organization is established, and the organizational structure is defined. The responsibilities and authority of the CBFO QA Manager are described. The current organizational chart for CBFO is available through its QA records.
NQA-1 Element 2, Quality Assurance Program, is properly established in Table QAPD-1, titled "QA Program Documents", and in Sections QAPD-2.1.2 through QAPD-2.1.2.4. The referenced table lists the source documents used for planning and maintaining the QAPD, and the NQA standards are listed. Section QAPD-2.1.2 identifies items and activities to which the QAPD applies. CBFO is required to plan work, provide for personnel training and qualification.  And, for compliance with NQA-3-1989, CBFO will provide for management assessments. 
QA Grading was used to identify the levels of QA assessments to be applied to items and activities. Grading was based upon an evaluation of the complexity and importance of the item or activity. Based on the results of the evaluation, appropriate QA assessments and controls are identified. The grading process provides the flexibility to optimize QA controls to a specific item or activity. 
NQA-1 Element 3, Design Control, is properly established in Section QAPD-3.2, titled "Design Control." CBFO's QA Organization requires that design work, including changes, incorporates appropriate controls and requirements such as general design criteria, design bases, and control of inputs.  Design interfaces must be identified and controlled. The adequacy of design products must be verified by individuals or groups independent from those who performed the work. Verification must be completed before approval and implementation of the design. The control of design activities also includes design reviews and qualification testing.  
NQA-1 Element 4, Procurement Document Control, is properly established in Section QAPD-3.3.4, titled "Procurement Document Requirements." CBFO's QA Organization requires that procurement documents address the scope of work, technical requirements, design bases, appropriate codes, standards, regulations, procedures, instructions, tests, inspections, hold points, acceptance criteria, and documentation requirements. Procurement documents must be reviewed to verify that the documents include appropriate provisions for ensuring that items and services meet the prescribed requirements. These procurement documents must be reviewed by QA personnel. The reviewers are required to have access to pertinent information and an adequate understanding of the requirements and scope of the procurement.  
NQA-1 Element 5, Instructions, Procedures, and Drawings, is properly established in Section QAPD-3.1.2, titled "Implementing Procedures." CBFO's QA Organization requires that activities affecting quality are prescribed by and performed in accordance with the appropriate established, documented, and approved instructions, procedures, or drawings. Instructions, procedures, and drawings must be developed, reviewed, and approved by technically competent personnel. Each of the program participants must develop implementing documents that address the quality activities applicable to his or her QA program requirements and work scope.  
NQA-1 Element 6, Document Control, is properly established in Section QAPD-2.4, titled "Documents." CBFO's QA Organization requires that documents that specify quality requirements or prescribe activities affecting quality, such as instructions, procedures, drawings, test plans, and management plans, are controlled to assure that the correct documents are being employed. Controlled documents must be reviewed by competent personnel, using specified criteria for adequacy, correctness, and completeness before approval and issuance. Review comment documentation must be maintained by the originating organization. Responsibilities for document preparation must be specified and the documents must be controlled during the preparation, review, approval, issuance, use, and revision processes.
NQA-1 Element 7, Control of Purchased Items and Services, is properly established in Section QAPD Sections 3.3.2, 3.3.6, and 3.3.7. CBFO's QA Organization requires that controls must be established to ensure that procured items and services meet performance specifications. Prospective suppliers must be evaluated and selected on the basis of documented criteria.  Procurement controls must be in place to ensure that approved suppliers continue to provide acceptable items and services.  
NQA-1 Element 8, Identification and Control of Items, is properly established in Section QAPD-3.1.3, titled "Item Identification and Control." CBFO's QA Organization requires that processes must be used to identify, control, and maintain items from receipt through installation and end-use. Item identification must ensure the appropriate traceability as specified in design documents, codes, standards, specifications, and implementing procedures. An identification marking must be placed on the item or in documents traceable to the item. Acceptable methods and materials for characteristics and markings must be prescribed, and the authority for applying and removing status indicators and markings must also be specified.
NQA-1 Element 9, Control of Processes, is properly established in Section QAPD-3.1.4, titled "Special Processes." CBFO's QA Organization requires that work processes must be performed in accordance with established, approved, and documented technical standards and administrative controls. Work must be planned, authorized, and performed under controlled conditions using approved instructions, procedures, drawings, or other appropriate means.  Implementing procedures must be developed, reviewed, and approved by qualified and competent personnel.  Personnel performing work must be responsible for complying with appropriate instructions. 
NQA-1 Element 10, Inspections, is properly established in Section QAPD-3.4.1, QAPD-3.4.3.6, and QAPD-3.4. CBFO's QA Organization requires inspections to determine acceptance or rejection of an item or activity.  Inspection documentation required of program participants includes: 
 approved implementing procedures; 
 identification of the items and processes to be inspected, the parameters or characteristics to be evaluated, the techniques to be used, the acceptance criteria, and any hold points; 
 the acceptance of items and processes by qualified and authorized persons; 
 identification of any measuring and test equipment used, including the equipment. 

NQA-1 Element 11, Test Control, is properly established in Sections QAPD-3.4 and QAPD-7.6.2.4. (Software testing is established in Section 7.0 of the Appendix QAPD and will be addressed below under the establishment of NQA-2a-1990) CBFO's QA Organization requires tests to determine the capability of an item to meet specified requirements by subjecting the item to a set of defined operating conditions. Test planning is required and includes: 
 identification of the procedures and related requirements documents used to control and perform the test (for example, test plans); 
 identification of the item to be tested, test requirements, and acceptance criteria; 
 identification of the measuring and test equipment (M&TE) including the type, range, accuracy, and tolerance; 
 test prerequisites and provisions to ensure that all test requirements and objectives have been met; 
 any designated hold points; and 
 recording methods used to collect and record the data. 
        
NQA-1 Element 12, Control of Measuring and Test Equipment, is properly established in Section QAPD-3.4.6. CBFO's QA Organization requires the use of control systems for measuring and test equipment to ensure that suspect and out-of-tolerance equipment are not used.  

NQA-1 Element 13, Handling, Storage, and Shipping, is properly established in Section QAPD-3.1.5. Handling, storage, cleaning, packaging, shipping, and preservation of items must be controlled to prevent damage or loss and to minimize deterioration.  

NQA-1 Element 14, Inspection, Test, and Operating Status, is properly established in Section QAPD-3.1.3. Status indicators must be employed to help prevent inadvertent installation, use, or operation of items that have not passed the required inspections or tests.  Only authorized persons can apply and remove status indicators on items, as appropriate. The specific status indicators, their use, and the authority to apply or remove them are delineated in applicable QA plans or implementing procedures.

NQA-1 Element 15, Control of Nonconforming Items, is properly established in Section QAPD-2.3, titled "Nonconformances", and in Section QAPD-2.3.2.2, titled "Identifying Nonconforming Items and Data." Items that do not conform to specified requirements must be controlled to prevent their installation, use, or operation before correction. Nonconforming items can be identified at any time by anyone.

NQA-1 Element 16, Corrective Action, is properly established in Sections QAPD-2.3.3, 2.3.3.4, 2.3.3.5, and 2.3.3.7. "Corrective actions" are measures that are taken to rectify a condition that is adverse to quality and, where necessary, to preclude recurrence. Conditions adverse to quality must be evaluated, the appropriate corrective actions must be defined and implemented, and the completion and effectiveness of the corrective action must be verified. If the condition adverse to quality is determined to be significant, corrective action is identified, investigative action is taken, the root cause is determined, and appropriate actions are taken to preclude recurrence. A significant condition adverse to quality includes a condition, which if uncorrected, could have a bad effect on waste isolation. When appropriate, further work on the item, activity, or process must be halted until the appropriate actions have been taken and verified.  

NQA-1 Element 17, Quality Assurance Records, is properly established in Section QAPD-2.5, titled "Records." CBFO's QA Organization requires that records must be specified, prepared, reviewed, approved, maintained, and disposed of in accordance with the CBFO QAPD. Records provide evidence of quality achievement and evidence that the QA program has been properly implemented. The records management system is documented in appropriate QA plans and implementing procedures. The generation, classification, indexing, and retention of QA records are controlled in accordance with appropriate plans and records-related procedures.  

NQA-1 Element 18, Audits, is properly established in Section QAPD-4.2.2, titled "Audits."  Audits verify that all of the WIPP's QA programs comply with the requirement of the NQA standards. The management and control of audits are documented in QA plans or implementing procedures. Audits conducted since the 2009 recertification have been rolled up into summary tables in Appendix AUD of the 2014 CRA. These tables reflect the extensive and comprehensive auditing efforts that CBFO's QA organization has implemented. Appendix AUD provides some objective evidence that CBFO's QA Organization has adhered to a periodic schedule of assessments of lower tier programs and suppliers as required by the NQA standards.

The NQA-2, Part 2.7, Software Quality Assurance, is properly established in Section QAPD-7.3, titled "Software Quality Assurance." CBFO's QA Organization requires that software QA controls are employed to ensure that the software meets its intended use and is controlled. These controls apply to software that manipulates or produces data that are, in turn, used to process, gather, or generate information and whose output is relied upon to make design, analytical, operational, or compliance-related decisions affecting the performance of the waste isolation, including waste characterization processes. The application of these requirements must be prescribed in written plans, policies, procedures, or instructions.

22.2   Evaluation of Compliance for 2014 Recertification  
The EPA evaluation process to recertify the WIPP's QA Programs in 2014 was similar to the prior EPA evaluation processes (e.g., 1998 CCA, 2004 CRA, and 2009 CRA). The EPA reviewed documents provided by DOE for the 2014 Recertification Decision and conducted inspections and formal audits at DOE facilities.
The QA Program of CBFO audits all other WIPP-related organizations to verify that they also properly establish and implement the QA requirements. Appendix AUD of the 2014 CRA contains summaries of the CBFO QA audits of WIPP organizations. Tables AUD-1 through AUD-15 of Appendix AUD summarize CBFO's QA Organization audits performed between January 20, 2009 and January 9, 2013 of transuranic (TRU) waste sites, Sandia National Laboratories (SNL), Washington TRU Solutions (WTS), suppliers performing quality-affecting work, the Carlsbad Field Office (CBFO), and Los Alamos National Laboratory  -  Carlsbad Operations (LANL-CO). It is possible that some of DOE's audits were performed prior to the end of the reporting date for the 2014 CRA; however, audits are not considered complete until the final report and associated regulatory approvals have been documented.
EPA Oversight Activities

Section 194.22(e) provides the EPA with the authority to conduct audits to verify the proper execution of QA Programs. Table 1 provides a list of the EPA inspections and audits conducted during the 2014 CRA compliance period. 
During this current recertification period, the EPA increased its surveillance of the WIPP QA Programs' performance to strengthen the quality of work that supports the isolation of the TRU waste in the WIPP repository.
EPA auditors witnessed the performance of many of the audits conducted by CBFO's QA Organization that are listed in Appendix AUD.  In all the witnessed cases, the EPA determined that the CBFO QA audits were performed properly in accordance with Element 18, titled "Audits", of NQA-1. The EPA reports of CBFO QA audits are also available to the public through the Agency's public dockets. Based on a large sample of CBFO QA audits witnessed by EPA, the EPA has the following general conclusions regarding the audits listed in Appendix AUD of the 2014 CRA:
 The CBFO QA audits were properly planned and scheduled,
 The audits were properly performed in accordance with written procedures or checklists by qualified personnel who did not have direct responsibility for performing the activities being audited.
 The audit results were properly documented and reported to and reviewed by responsible DOE management and the EPA, and
 Follow-up actions were taken by DOE where indicated in the CBFO QA audit reports. 
      The EPA directly audited the lower-tier WIPP organizations that report to CBFO.   In most of these cases, the EPA QA auditors took direct audit samples while witnessing CBFO QA audits. The EPA conducted many EPA-only audits of the QA programs of lower-tier organizations, focusing on SNL, WTS and LANL-CO. The QA organization of WTS was the most audited lower-tier organization because WTS operates both the WIPP site and the Central Characterization Project at most of the waste generator sites. The EPA reports documenting EPA-only audits of lower-tier organizations are also available to the public through the Agency's public dockets.
      The contact-handled TRU waste generators with EPA-approved QA programs include:
   LANL/Central Characterization Project (CCP)  
   Hanford 
   Idaho National Laboratory (INL)/Central Characterization Project
   Savannah River Site (SRS)/CCP
   Advanced Mixed Waste Treatment Project
   Oak Ridge National Laboratory (ORNL)/Central Characterization Project

Public Comments
	The EPA did not receive any public comments on DOE's continued compliance with the quality assurance requirements of Section 194.22 or Section 194.8(a).

Table 1 - List of EPA's Audits and Inspections of DOE's QA Programs that Support the 2014 CRA  
Sites
     Activity
Report Date[a]
                             Description 
AMWTP
Inspection 
October 2009
II-A1-107
EPA inspected an audit conducted by the Quality Assurance Organization of the Department of Energy Carlsbad Field Office.  This audit (A-09-19) evaluated the QA program and waste characterization processes at the Advanced Mixed Waste Treatment Project.
AMWTP
Inspection
October 15, 2009
II-A1-107
Inspection of CBFO QA audit (A-09- 19) that evaluated the quality assurance program and waste characterization processes at the Advanced Mixed Waste Treatment Project (AMWTP). Dates of inspection:  August 19-20, 2009.  EPA evaluated NQA-1 requirements, specifically Element 18.
CBFO
Audits
November 2011
II-A1-109
EPA conducted three audits of the Carlsbad Field Office QA program during 2011 on the following dates: January 25-27; March 14-17; July 19-21.
CCP
Audit
November 2008
II-A1-103
EPA audit of the Central Characterization Program. The EPA audit team reviewed documents and interviewed personnel to determine CCP's QA
Program's compliance with the Nuclear Quality Assurance (NQA) standard of the American Society of Mechanical Engineers (ASME), Element 1, Organization. No non-conformances were identified. Based on this audit, EPA determined that CCP's QA program is compliant with the Organization element of the NQA standard.
DOE
Audits
September 2010
II-A1-108
EPA audits of DOE peer review of historical information.  On June 29 through July 1, 2010, EPA conducted an audit of a Department of Energy peer review used to qualify historical information for transuranic (TRU) waste streams SR-BCLDP-004.002 and SR-BCLDP-004.003.  This DOE Peer Review was conducted from May 4, 2010 through June 2, 2010.  EPA performed a follow-up audit on August 3-4, 2010 to further evaluate the Peer Review.  The investigation of activities selected for the EPA audit samples showed that the Peer Review was conducted properly in accordance with the EPA-invoked standard NUREG-1297, "Peer Review for High-Level Nuclear Waste Repositories."
Hanford 
Inspection
April 28, 2010
II-A1-108
Inspection of DOE Audit (A-10-07) at the Hanford Site's QA Programs.  Dates of inspection: April 7-8, 2010. EPA evaluated NQA-1 requirements, specifically Element 18.  
Hanford
Inspection 
October 2008
II-A1-102
Inspection of DOE Audit (A-08-18) performed at the Hanford Site's Quality QA Program. Dates of inspection: June 17-19, 2008.  EPA evaluated NQA-1 requirements, specifically Element 18. EPA reviewed DOE's interim audit report.
Hanford
Inspection 
September, 2009
II-A1-105
Inspection of DOE Audit of Hanford Site's QA Program.
Dates of inspection: June 9-11, 2009).  EPA evaluated NQA-1 requirements, specifically Element 18.
Oak Ridge
Audit
March 31, 2008
II-A1-99

EPA Audit of the quality assurance program at the Oak Ridge National Laboratory. During the audit, EPA determined that the DOE Audit (A-08-06) was conducted properly in accordance with the NQA standards.  Dates of the audit:  November 13-15, 2007 
Sandia
Inspection
April 2012
II-A1-110

EPA observed an audit conducted by the Carlsbad Field Office. Dates of audit: December 7-8, 2011.  This audit (A-12-05) evaluated the quality assurance program of the Sandia National Laboratories Nuclear Waste Management Program.
Sandia
Audit
May 2008
II-A1-98
EPA conducted an audit, of the Sandia National Laboratories (SNL) Quality Assurance (QA) Program for software used for the Waste Isolation Pilot Plant (WIPP) Performance Assessment (PA). The EPA audit team reviewed SNL's software documentation to determine compliance with the requirements of Nuclear Quality Assurance (NQA) standard titled "Quality Assurance Requirements for Computer Software for Nuclear Facility Applications."

Vallecitos
Telephone Audit
May 2009
II-A1-104
On December 4, 2008, EPA conducted a brief audit via phone of the QA Analyst on-site at the Vallecitos waste-generator site. This EPA audit was done to supplement face-to-face interviews conducted during an EPA audit of October 21-23, 2008, of the CCP QA Program. 
WIPP
Audit
January 2010
II-A1-106
EPA conducted an audit of the QA program of CCP at WIPP. In addition, EPA evaluated the performance of the CBFO's audit (A-09-010) of CCP. Dates of the audit and inspection: February 23-26, 2009.
CBFO, CBFO TA Contractor, Washington TRU Solutions, LANL-Carlsbad Office, Sandia-Carlsbad Office, CCP of WIPP
Audit
April 2010
II-A1-109

EPA conducted an audit of six organizations (CBFO, CBFO TA Contractor, Washington TRU Solutions, LANL-Carlsbad Office, Sandia-Carlsbad Office, CCP. of the Waste Isolation Pilot Plant. The EPA audit team reviewed documents and records and interviewed personnel to determine continued compliance with the Nuclear Quality Assurance (NQA) standard of the American Society of Mechanical Engineers (ASME), Element 1, titled Organization.
a  All reports may be found by the listed item number in Docket ID No. A-98-49

22.3  2014 Recertification Decision 

	The EPA finds that DOE's QA Programs continue to be effective at identifying problems with the reliability of items and activities that are important to the long-term isolation of transuranic waste. Based on the EPA's review of the effectiveness of the WIPP related QA Organizations, the results of EPA audits, inspections, and the review of the 2014 CRA information, the EPA determines that DOE continues to comply with the Quality Assurance requirements of Section 194.22 and Section 194.8(a).

