%i CENTER FOR h UCLEAR WASTE REGULA'I'ORY ANALYSES ,\-v> NONCONFORMANCE REPORT $? q// L roject No. 20-1402-461, -471. -861 NCRNO. 99-02 PART 1: DESCRIPTION OF NONCONFORMANCE Contrary to the requirements in TOP-018, Development and Control of Scientific and Engineering Software, paragraphs 5.3.1 through 5.10.5, several geophysical software codes were developed without a Software Requirements Description, Software Development Plan, documented acceptance testing, CNWRA configuration control, design verification, and formal CNWRA software release. This condition was described in CNWRA surveillance report 99-04, dated 4/16/99, and there have been additional management discussions on this subject necessitating the issuance of this nonconformance report. Initiated by: Bruce Mabrito Date: May 10, 1999 PART 2: PROPOSED DISPOSITION AND CORRECTIVE ACTION (Assigned to: L. McKague) Disposition: The seven codes will be placed under configuration control (TOP-018). Basis of Disposition: Codes could be used in regulatory analysis. Action to correct nonconformance: See attached. 07/30/99 Target date for completion: 1 Proposedbyw R. Date: G/./)q4 PART 3: APPROVAL Element Manager Date: &/4/5 7 Original to QA Records M. Ehnstrom 4 a&& CNWRA FORM QAP 9-1
Transcript
%i CENTER FOR h UCLEAR WASTE REGULA'I'ORY ANALYSES ,\-v>
NONCONFORMANCE REPORT $? q// L
roject No. 20-1402-461, -471. -861 NCRNO. 99-02
PART 1: DESCRIPTION OF NONCONFORMANCE
Contrary to the requirements in TOP-018, Development and Control of Scientific and Engineering Software, paragraphs 5.3.1 through 5.10.5, several geophysical software codes were developed without a Software Requirements Description, Software Development Plan, documented acceptance testing, CNWRA configuration control, design verification, and formal CNWRA software release. This condition was described in CNWRA surveillance report 99-04, dated 4/16/99, and there have been additional management discussions on this subject necessitating the issuance of this nonconformance report.
Initiated by: Bruce Mabrito Date: May 10, 1999
PART 2: PROPOSED DISPOSITION AND CORRECTIVE ACTION (Assigned to: L. McKague)
Disposition: The seven codes will be placed under configuration control (TOP-018).
Basis of Disposition: Codes could be used in regulatory analysis.
Action to correct nonconformance:
See attached. 07/30/99
Target date for completion:
1
P r o p o s e d b y w R. Date: G/./)q4 PART 3: APPROVAL
06. Software Title: Geomagnetic Post Processing Software Version 1
I 04. Software Date: 01/01/98 05. Short Title: Post Processing Software
07. Internal Software ID: none
15. Computer Operating
Windows NT or IRIX 6.2 System:
08. Software Type:
0 Automated Data System
X Computer Program
0 Subroutine/Module
16. Programming Language(s): C
09. Processing Mode:
0 Interactive
X Batch
0 Combination
~ 10. Application Area
' a. General: X ScientificEngineering Auxiliary Analyses 0 Total System PA 0 Subsystem PA Other
b. Specific: Software is intended for use in geologic surveys dealing with magnetometer readings.
11. Submitting Organization and Address: I 12. Technical Contact(s) and Phone: /I CNWRNSwRI 6220 Culebra Road I/ San Antonio, TX 78228
Charles Connor, Programmer SWRI Div 20 (201) 522-6649
Laura Connor, Programmer SWRI-Div 09 (201) 522-4667
13. Software Application: Associates location data, gathered with a GPS unit, and magnetometer readings.
Determines magnetometer base station drift relative to the first day, first base station reading, and adjusts measured magnetometer readings to remove this drift effect.
Determines the heading at each magnetometer reading and adjusts the reading to eliminate directional variations caused by the magnetic field of a bicycle (if used) while surveying.
Filters a data file by eliminating data lines containing readings above and below specified min and max values.
Performs an IGRF (International Geomagnetic Reference Field) correction on a data set of magnetometer readings using geodetic coordinates.
Converts 1atitudeIlongitude coordinates into UTM coordinates using the NAD83 ellipsoid (State Plane Coordinate Systems, North American Datum 1983).
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14. Computer Platform PC or SGI
17. Number of Source Program Statements: 1433 lines
I I I I I I
18. Computer Memory 19. Tape Drives: 20. Disk Units: 21. Graphics: Requirements: 640K I NIA 1 NIA 1 none
23. Software Availability: 0 Available 0 Limited X In-House ONLY
Date:
25.
Software Develo r:
24. Documentation Availability: 0 Available 13 Preliminary X In-House ONLY
a
-1 SOURCE CODES POST PROCESSING SOFTWARE FOR GEOMAGNETIC SURVEYS
VERSION 1
Manuscript Completed: June 23,1999
Center for Nuclear Waste Regulatory Commission (CNWRA) Southwest Research Institute 6220 Culebra Rd, Bldg. 189 San Antonio, TX 78238-5166
POST PROCESSING SOFTWARE (REV 1)
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1. PROGRAM CONSIDERATIONS This program is composed of six ansi C codes. Each code performs a function (which we will call filters from here on) in a sequence of events. The codes may be used individually to obtain a data file of geomagnetic readings that have been processed in a desired manner. More commonly, the codes are executed in a prescribed sequence to obtain a data file that contains post-processed geomagnetic readings suitable for generating a contour map, profile, or geophysical model.
This program uses inputs from GPS receivers and Geometrics magnetometers. The filters in this program include: (i) the removal of temporal geomagnetic drift; (ii) filtering for erroneous data points; (iii) removal of the Earth's magnetic reference field; and (iv) conversion from latitude-longitude to Universal Transverse Mercator (UTM) coordinates. The final data file is used as a source file for mapping geomagnetic anomalies. Post-processing can be done with any combination of these filters. Experience in magnetic surveying is required in order to make appropriate decisions about the filters that will be applied to particular data sets and parameters input during the filtering process. This users manual does not attempt to teach geophysics or explain the range of possible input parameters.
Because the filters are written in ansi C, they can be compiled and run on any standard computer platform that has a C- compiler. The user must compile each fdter before the filter can be executed.
1 .I PROGRAM FILTERS The filters available in this program are stn2xyz, drift, heading, filter, igrf, and nad83. The names are representative of the functions performed by each filter. The function of each filter is summarized in the following:
STN2XYZ converts a .stn data file to a .xyz data file, for the primary purpose of collating GPS and magnetic data streams DRIFT subtracts diurnal variations in the magnetic field from the magnetic reading data streams IGRF subtracts the International Geomagnetic Reference Field from each magnetic reading HEADING performs heading corrections to individual data points FILTER deletes extremely high or extremely low magnetic readings from the data stream NAD83 converts latitude and longitude to UTM coordinates
t
Detailed descriptions of each filter follow.
1.1.1 STN2XYZ This filter associates location data, gathered with a GPS unit, and magnetometer readings. If the magnetometer collects data faster than the GPS units can acquire locations, the extra location data is interpolated using a linear interpolation method.
The Geometrics 858 magnetometer stores magnetic readings and GPS readings (produced by a GPS receiver and read by the 858 magnetometer via a RS232 port) together in the memory of the magnetometer. These GPS and geomagnetic data are stored on the magnetometer sequentially. This data file is binary. The data file is downloaded to a computer and converted to an ascii text file using software provided by Geometrics.
/ * work performed by the Center for Nuclear Waste Regulatory Analyses * /
/ * their sponsors make any warranty, expressed or implied, or assume any * /
/ * "This computer code/material was prepared as an overhead account of * /
/ * (CNWRA) for the CNWRA. Neither the developer(s) of the code nor any of * /
/ * / * / * / * / * / * / * / * / * / *
legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process 1 disclosed, or'represent that its use would not infringe on privately owned rights. 'I
"In no event unless required by applicable law will the sponsors or those who have written or modified this code, be liable for damages, including any lost profits, lost monies, or other special, incidental or consequential damages arising out of the use or inability to use the program (including but not limited to loss of
* / * / * / * / * / * / * / * / * / * /
/ * data or data being rendered inaccurate or losses sustained by third * / * /
/ * even if you have been advised of the possibility of such damages or * / / * parties or a failure of the program to operate with,other programs')
R. Folck (software QA consultant to the CNWRA) and L. McKague, it has been determined that you have met the requirements of QA Procedure-014, Documentation and Verification of Scientific and engineering Calculations. Specifically, you have taken "uncontrolled software" [as described in 3.1.2 (ii) in QAP-0141 and preserved the copy of the software used in your scientific notebook.number 261E. I have verified that the code is in a copy of that scientific notebook in the QA Records Room.
It appears that in the initial response to nonconformance report 99-02, we should have been more specific and noted that one of the seven codes could have been handled in this manner.
With this note and documentation of NCR 99-02, we will close out the nonconformance report. Mabrito
chuck connor wrote:
Based on your message and extensive discussions among you, myself,
> > > > The seventh code (no name) is contained in > > scientific notebook 2673, checked out to > > chuck connor. This notebook is dates April, 1998 > The code will not be used again. > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > >
3 Dr. Chuck Connor Principal Scientist Center for Nuclear Waste Regulatory Analyses Southwest Research Institute 6220 Culebra Rd San Antonio, TX, 78238-5166, USA
It is unclear whether the codes in question, which are used during field work to process geophysical data, are expected to be used in the “regulatory review process” as defined in TOP-018, paragraph 1.0. It was assumed that documenting the codes in a Scientific Notebook in accordance with QAP-014, “Documentation and Verification of Scientific and Engineering Calculations” as “uncontrolled software” was adequate.
Actions Taken Or To Be Taken:
Acceptance testing (TOP-018,5.6) is documented in Scientific Notebook No. 115E. A Software Summary Form (TOP-O18,5.7.2) will be prepared for each of the seven codes.
The Software Summary Forms and codes will be provided to the Software Custodian for design verification (TOP-018, 5.7,5.8).
Upon acceptance, the seven computer codes will be released (TOP-018, 5.9) for use.
A single User’s Manual (TOP-018, 5.5.6) will be developed for the seven codes. This User’s Manual will incorporate the applicable portions of a Software Requirements Description (TOP-018,5.3), e.g., functions of the software, technical basis, intended computer platforms, etc. The User’s Manual will be reviewed in accordance with QAP-002.
Since the codes have already been developed, a Software Development Plan (TOP-018, 5.4) will not be generated. However, future code changes will be documented using a Software Change Report as described in section 5.5.1 of TOP-018. Other applicable controls (TOP-018, 5.5-5.9) will apply to any future modifications.
The seven codes will be subjected to software validation (TOP-018, 5.10) once a determfnation is made as to their use in the reblatory review process.
These actions will be completed on or before July 30, 1999.
Disposition of Data:
The relevant output data from the seven codes in question have been documented in Scientific Notebook No. 115E, in accordance with QAP-014, paragraph 3.1.3. The output data, when used for technical reports was verified in accordance with QAP-014, paragraph 3.2.3(ii).
Action to Prevent Recurrence:
It is proposed that criteria be established to assist CNWRA staff in determining which codes will be used in the regulatory review process and subsequently subject to TOP-018 controls. See attached.
Charles B. Connor Date ‘ ‘
cc:Mail for: Larry McKague
Subject:
From: To:
To:
To:
To:
To:
To:
To:
To:
To:
To: To: To:
TOP - 018 policy
Larry McKague 6/8/1999 10:06 AM
Annette Mandujano (Amandujano)
Charles Connor
David Ferrill
Brittain Hill
Peter LaFemina
Ronald Martin
Larry McKague
Michael Miklas
Darrell Sirns
John Stamatakos
Deborah Waiting
Bruce Mabrito
The Center for Nuclear Waste Regulatory Analyses (CNWRA, Division 20) policy is that all software / codes that will be developed for a client and/or will be used in Regulatory Analysis will fall under TOP-018 procedures. There are no exceptions! It is desirable, but under some circumstances not necessary, to institute the procedures prior to the preliminary development of the code. Preliminary codes that are to be developed as a test of concept or that are developed in the field or under similar circumstances should be placed under TOP-018 when it is determined that one or all of the following take place: (1)they will work, i.e. the test of concept is successful, (2) that additional development or modifications are needed, i.e. more resources required, (3) when more than one user is identified, i.e. the code will be used in ongogng efforts, (4) when more than:one individual becomes involved in the development of the code, i.e. more resources required, and (5) when returning from the field it is determined that the code will be reused in the future, i.e. the test of concept is successful. The placement of all codes under TOP - 018 procedures should take place sooner rather that later. TOP - 018 requirements are passed on to consultants and subcontractors. The above is given as guidance. When in doubt discuss it with your Element manager.
As a separate issue aside from the Top - 018 procedure, codes that are developed under NRC funding must have a separate work order account number if the estimated code development cost is going to be greater than $25,000. This code development cost number MUST be set up to track the code development costs. Again there are no exceptions. This is a requirement the OMB has put on NRC and by contract on us.
1
Date: 6/3/99 Sender: Bruce Mabrito To: Larry McKague
bcc: Priority: Normal Subject: Nonconformance Report 99-02 Status
The purpose of this email message is to update the actions regarding this Nonconformance Report 99-02.
The NCR was written May 10,1999 and was responded to on May 19,1999. I rejected the response and asked for more detailed information on May 21,1999. On May 26,1999, GLGP Element Manager L. McKague provided me with a draft response, giving much greater detail. There have been meetings between the GLGP Element staff and a QA software consultant to determine the exact approach to resolve all aspects of this NCR. A meeting will be held on June 4, 1999 to iron out some points in the formal reply to the NCR.
A copy of this message will be filed with NCR No. 99-02 as an update to activities in response to the NCR.
Bruce Mabrito, ext. 5149
/%,P CENTER FOR NULLEAR WASTE REGULAIORY ANALYSES \I?;\
M E M O R A N D U M
TO: Larry McKague, Manager GLGP Element
FROM: Bruce Mabrito, Director of Quality Assurance
SUBJECT: Rejection of Nonconformance Report No. 99-02
DATE: May21, 1999 $I93144
d 2 b- I have reviewed the initial response to Nonconformance Report No. 99-gZ”and am rejecting it as not sufficient to fully address the problem identified in the nonconformance report..
I wrote a Nonconformance Report as opposed to a Corrective Action Request in this case because this was an incident apparently limited to the GLGP Element and did not cross over into other Elements. However, considering the problems we have faced with implementing TOP-0 18, Development and Control of Scientific and Engineering Software, at the CNWRA over the years, I believe we have to more fully and completely respond to this Nonconformance Report.
Specifically, having a person from outside your Element come in and perform the work that should have been accomplished by your staff is one corrective action approach, but it does not satisfy the need for true root cause analysis or actions to prevent recurrence. Since scientific and engineering software are a major portion of our CNWRA program, and there has been reluctance in the past to implement TOP-01 8, I request you provide the ;following information: 3
0 A more fully detailed and complete root cause for this oversight
0 The specific and full actions to be taken
0 The disposition of data until specified actions are completed
0 Actions taken to prevent this from occurring again.
If you have questions regarding this nonconformance rejection memo, please call me at ext. 5149.
Attachment/ cc: B. Sagar
C. Connor R. Folck M. Ehnstrom QA Records Folder 150 - Nonconformance Documentation
CENTER FOR i . JCLEAR WASTE REGULA x ORY ANALYSES
NONCONFORMANCE REPORT
Project No. 20-1402-461. -471, -861 NCR No. 99-02
PART 1: DESCRIPTION OF NONCONFORMANCE
Contrary to the requirements in TOP-018, Development and Control of Scientific and Engineering Software, paragraphs 5.3.1 through 5.10.5, several geophysical software codes were developed without a Software Requirements Description, Software Development Plan, documented acceptance testing, CNWRA configuration control, design verification, and formal CNWRA software release. This condition was described in CNWRA surveillance report 99-04, dated 4/16/99, and there have been additional management discussions on this subject necessitating the issuance of this nonconformance report.
Initiated by: Bruce Mabrito -d Date: May 10, 1999
PART 2: PROPOSED DISPOSITION AND CORRECTIVE ACTION (Assigned to: L. McKague)
Dis sition: The Seven software codes that were initially developed by C. Connor to aid in the transfer of GPS data in the field will be placed under the TOP-018, Development and Control Of Scientific Engineering software Requirement.
Action to correct nonconformance: B. Winfrey has been tasked to perform the work. She has been supplied with a copy of TOP-018. She may require discussions and guidance from QA.
Target date for completion: 08/02/99
Element Manager: Date:
Director of QA: Date: Comments Anstructions:
PART 4: CLOSE OUT
Comments:
Distribution: Element Managers B. Sagar H. Garcia Original to QA Records M. Ehnstrom
Verified by: Date:
CNWRA FORM QAP 9-1 . ,.
M E M O R A N D U M
TO: CNWRA Staff
FROM: English Pearcy
DATE: January 11,2000
,
SUBJECT: Information Items: CNWRA Management staff meeting held January 10,2000
Attached are CNWRA information items which have been prepared to summarize the key points of the Management staff meeting and the status of CNWRA activities.
If you need additional clarification on the attached, please contact your Element Manager.
a ?
cc: Correspondence Control
CENTER FOR NUCLEAR WASTE REGULATORY ANALYSES
INFORMATION ITEMS
SUBJECT: Center for Nuclear Waste Regulatory Analyses (CNWRA) Management Staff Meeting
DATEPLACE: January 10,2000 San Antonio, Texas
PRESENT: CNWRA (SA) W. Patrick (WP) S. Hsiung (SH) L. McKague (LM) E. Pearcy (EP) P. Mackin (PM) N. Sridhar (NS) G. Wittmeyer (GW) B. Mabrito (BM) H. Garcia (HG)
CNWRA (WTSO)" J. Russell (JR)
* via telephone
BACKGROUND:
This meeting is held weekly to review current and future CNWRA activities that need management attention. The meeting also provides a forum for exchanging information and contributing to the integration of CNWRA activities. The meeting began at about 10:30 a.m. and ended at approximately 11:45 a p . (CST).
SUMMARY OF PERTINENT POINTS: i
. NRC staff have indicated the potential exists for placing three additional areas of industrial mobilization execption workunder the decommissioning project. The work areas are (i) review ofthe NRC staff assignment of values for the resuspension factor used in models (e.g., D&D and RESRAD) to determine dose for building occupancy scenarios; (ii) review of the Molycorp, Incorporated decommissioning plan, Part I1 for the Washington, PA site (i.e., review licensee submittals for an engineered containment cell for disposal of radiohctively contaminated waste); and (iii) similar review ofusing a disposal cell for decommissioning waste at another site (Fansteel?). The CNWRA has also expressed interest in reviewing the decommissioning plan for the depleted uranium impact area at the Jefferson Proving Ground. That review would use the extensive experience gained from reviewing site characterization information and performing pathway-dose assessments for the site. (JR)
. Participation ofthe CNWRA in the Decommissioning Management Board meeting was initiated by J. Russell last week. The board comprises representatives from the Decommissioning Branch, Ofice of Nuclear Regulatory Research, Nuclear Reactor Regulation, and the Office of General Counsel.
1
One CNWRA Nonconformance Report, 99-02, relating to the seventh of seven scientific and engineering geophysical software codes remains open, awaiting final resolution by putting the code under TOP-0 18 control. (BM)
An organizational and planning meeting for the corrosion and reactive transport bench scale heater test was held on January 7,2000. Sensors have been in testing for the past three months, several 55 gallon drums of Tptll alpine miner muck have arrived, and the previous bench scale heater test apparatus is being modified for the new experiment. (SH)
A telecon was held on January 7,2000 with the Private Fuel Storage (PFS) to discuss the open items in the SER so that PFS can submit additional information to support our SER (Final Version) development by January 24,2000. This telecon was preceded by a discussion with the NRC Program Manager. (SH)
A telecon was held on January 7,2000 with theNRC Program Officer to discuss the major concerns discovered in our review of HOLTEC HI-STAR and HI-STORM casks Topical Safety Analysis Report for high seismic region. These concerns will be included in our round 2 Request for Additional Information (RAI). This RAI will be delivered to NRC on January 31,2000. (SH)
In the Tank Waste Remediation System project, the NUREGKR on vitrification technologies was completed and transmitted to NRC. An annotated outline for evaporator safety issues was e-mailed to NRC for their comments. A similar outline for the ultrafiltration process is being prepared. (NS)
We received comments from Enron on our draft report. Additional analyses are planned. We also plan to submit a pre-proposal to them for additional work.(NS)
We have received another batch of cuttings from the EWDP Phase I wells/drillholes. Cuttings have been received for NC-EWDP-2D, 5 S, and Washburn- 1 X. Cuttings are provided iqindividual sample bags representing 5 ft intervals. About 50-100 g of sample cuttings are provided in each bag. A preliminary inspection indicates that the entire depth of each of these drillholes is represented (i.e., 0-5 ft through total depth). (EP)
The second report for JNOC is being prepared and should go out this week. Four more analog models remain to be run for the final report. David Ferrill is planning a trip to Japan for the week of January 14 to present JNOC with the final report.(LM)
~
We have received the fist check from Midland Valley for licensing of 3DStress. The fee was for the first three licenses sold after we met our commitment to exchange five licenses for a copy of their 3DMove software. (LM)
Business Development Items
. M. Marshall (Div. 01) plans to visit the Air Force Corrosion Office. It appears that they are not pleased with their current contractor and want to consider others. CNWRA staff plans to join her in a meeting at the Air Force Office on February 20th. (NS)
4
. D. Farrell coordinated a telecon with the Barbados Water Authority (B WA) to discuss possible projects. They are interested in a wide range of efforts including effects ofbrackish water extraction (for desalination) on fresh water lenses, evaluation of existing groundwater protection zoning and policy, modeling of saline water intrusion, improved modeling for karst flow, and independent reviews of EIAs. Presently BWA is responsible for both water supply and regulation. In the future the regulatory responsibilities will move to a new organization called the Water Resources Agency. They desire assistance in developing and establishing a regulatory framework for this new organization (EP)
. R. Green and S. Painter made presentations to the Edwards Aquifer Authority “Blue Ribbon Panel” on the proposed parameter estimation and saline water line projects. The Panel will meet through the weekend and on Monday, January 10. We expect feedback shortly after their meeting indicating their level of interest in our proposals. (EP)
PREPARED BY: APPROVED:
English Pearcy Manager, Geohydrology and Geochemistry
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