LANL's Approach to Meeting Rad-NESHAP External Audit Requirements
D.P. Fuehne1 and E.J. Hamilton2 (1Los Alamos National Laboratory, Meteorology & Air Quality Group; 2Hamilton Quality Consulting, Los Alamos, New Mexico)
Los Alamos National Laboratory (LANL) sponsored an external assessment of the Rad-NESHAP compliance program in December 2004 and January 2005, including a weeklong site visit. Regulations in 40 CFR 61, Appendix B, Method 114 require such external assessments. The external assessor, certified by the American Society for Quality, teamed with Rad-NESHAP subject matter experts from other sites in the DOE complex. The assessment scope included Rad-NESHAP Quality Assurance Project Plan (QAPP) compliance, general project management, new inspection and maintenance requirements' compliance, sample-data management and calculation processes, and completeness of incorporating previous-audit observations. Findings from this assessment included issues with keeping procedures up-to-date, methods of stack, sample-system inspections in order to meet fully the intent of the regulation, and meeting commitments stated in the Rad-NESHAP QAPP. The audit proved very worthwhile for LANL personnel, and provided a forum for sharing ideas and solutions across the DOE complex. Long term, LANL will continue sponsoring such assessments on a biannual basis, with varying focus areas to cover the complete scope of the Rad-NESHAP project. The assessment participants hope that other DOE sites incorporate this approach to meet external-audit requirements with full endorsement by both DOE and EPA.