The effectiveness of the work performed was presented from two perspectives: First - the technical specialist concluded the conduct of a metallic resources assessment of the conceptual controlled area by methods such as remote sensing interpretation, conservative (biased) sampling, sample analysis, and comparison to other mining districts, had been effectively completed, reflecting industry standards. However, UNR did not implement many of the objectives of the study plan; Second - the quality assurance auditors concluded the QA program implementation was not effective. Little or no implementation of the QA procedures had been performed.

There were no stop work orders, immediate corrective actions or related additional items resulting from this audit.

A summary table of audit results is provided in Attachment 2. The details of the audit evaluation, along with the objective evidence reviewed, are contained within the audit checklists. The checklists are kept and maintained as QA Records.

The focus of the technical audit activities at the NBMG was to evaluate the effectiveness of the critical process steps that lead to the completion of the report on the metallic resource potential of the conceptual controlled area at Yucca Mountain. The critical process steps leading to the completion of the product (report) are listed in section 2.0. The following discussion provides an evaluation of each of the six critical process steps in terms of contributing to a technically adequate report on metallic resources that meets project quality requirements.

Planning - A study plan had been developed and approved for the metallic resources work as well as the assessment of other natural resources at Yucca Mountain. The study plan was approved on November 6, 1992. However, by 1994 a decision was apparently made within the project to conduct resource assessments in a more commercial manner than was described in the study plan and the NBMG was asked to submit a proposal on the metallic resources work. The short proposal that NBMG developed, which was accepted and funded by the project, guided the metallic resources work. The study plan was not revised and the NBMG proposal does not meet QARD planning requirements as specified in section 2.2.5. As a result of the above actions, there are numerous deviations from the approved study plan in terms of the technical work that was preformed. For example, no systematic sampling was performed, no surface sediment samples were collected, and no plant or water samples were collected. No new geophysical data was acquired and the geophysical interpretation that was performed did not guide the sampling program. Isotopic studies were not conducted, no anomaly maps were made, and there was no rigorous comparison of elemental values in the samples collected to average crustal abundances or average elemental abundances for rock types in the area. In addition to not performing work that was specified in the study plan, some studies were undertaken that had not previously been planned, such as the remote sensing investigation and the evaluation of mined energy resources. As far as NBMG personnel were aware, no downstream users of the metallic resources report were involved in the planning process. In summary, decisions to deviate from the approved study plan are not documented and no alternate plan, meeting QARD requirements, was developed so the work performed by NBMG was not controlled by approved plans.

Sample Collection - The sample collection philosophy adopted by the NBMG was to do conservative biased sampling of both surface and subsurface rock units. In other words, only those samples that showed some indication of mineralization were collected for analysis. The concept being that, if only the most promising samples (from an exploration/prospecting for metallic resources point of view) are collected, and they do not indicate the presence of any metallic resources, then the project can reach the conservative judgement that metallic resources are not present at the site. Several hundred samples were collected from surface outcrops and numerous additional subsurface samples were collected from project boreholes and the ESF. Surface samples were numbered and described in field notebooks and the locations were numbered and plotted on topo maps or on orthophoto base maps. Subsurface samples are located by hole number and depth or by location in the ESF and are described in notebooks. It is therefore possible to determine the original locations of all samples collected and analyzed. However, written sample selection criteria were never developed nor were written sample description guidelines developed. In lieu of any written guidance, a training session was conducted at the start of field work. The Principal Investigator (PI) and all of the geologists who were collecting samples worked together for five days. The verbally transmitted criteria for sample selection included the presence of limonitic or hematitic alteration, brecciation, veining, and clay alteration. Given the training exercise, it appears likely that the same types of samples were selected by the individual investigators when they were collecting independently over the next year or so. However, this training was not documented. Unfortunately, without written checklists, guidelines or procedures, it would be difficult to retrace the investigation without recourse to the original investigators. It was also noted that contrary to project policy, none of the outcrop samples were processed through the Sample Management Facility, though the samples were adequately controlled at the NBMG facility. In summary, it appears that an industry standard, conservative biased sampling program was implemented by the NBMG, sample locations can be recovered from the notebooks and maps, and (with access to the original investigators) the sampling criteria can be discovered. The only potential weakness of the sampling program is that, since no unaltered samples were collected, normal or background elemental values for the rocks present will not be analyzed.

Sample Analysis - All of the samples collected were analyzed for the same suite of elements. This suite of elements included metals that were of interest such as gold, silver, and mercury; plus a number of Apathfinder@ elements such as arsenic that may be indicators of metallic resources. The full suite of metals and pathfinder elements analyzed was intended to cover all of the ore deposit models that were considered possible for the Yucca Mountain area. Commercial labs and industry standard techniques were employed in the analyses. Techniques included Inductive Coupled Plasma (ICP)-Mass Spectroscopy, ICP-Emission Spectroscopy (ES), and graphite furnace Atomic Absorption. Quality checks by NBMG personnel indicated problems with analyses submitted by Activation Laboratories requiring re-running of some samples and the use of an additional lab (USML); however, that lab is not considered a qualified supplier. Some analyses were also performed at the NBMG Analytical Laboratory. This work was controlled by straightforward Acookbook@ type procedures that appear to be adequate though they were never reviewed and approved for use on the study. At the time of the audit, NBMG personnel were satisfied that the final geochemical data set that had been obtained was adequate for subsequent data analysis and interpretation. In addition to quantitative analyses, some of the samples were examined petrographically or by Scanning Electron Microscopy and X-ray Diffraction analysis to aid in mineral identification and provide information relative to probable ore deposit models. In summary, in spite of the significant effort expended on analytical work, there are some uncertainties about the data due to the use of an unqualified supplier (USML) and the use of unapproved procedures at NBMG.

Data Analysis - This critical process step considers analysis of all the different types of data used in the study. The emphasis so far has been on the geochemical data from sample analysis and the sample collection that preceded it. However, previously collected geophysical data were analyzed for the study from the exploration/prospecting perspective, and existing remote sensing data were also analyzed from this perspective. Apparently all of the data analysis activities were separate parallel efforts conducted by different investigators.

Howard Ross at the University of Utah performed the geophysical analysis as a subcontractor to the NBMG. Howard was not available for interview during the audit, but according to the PI (Steve Castor) the existing geophysical data was not reprocessed for this study. Howard used his experience and professional judgement to evaluate the Yucca Mountain area as to its metallic resource potential based on existing gravity, aeromagnetic, seismic, and electrical data. This data set was judged to be adequate for the purpose of the study and no specific exploration targets were identified based on comparisons to known mineralized areas in the region. Apparently the only documentation of the geophysical interpretation is Howard=s report to the NBMG; procedures or scientific notebooks were not used in the study.

The remote sensing interpretation was conducted by Tom Lugaski at UNR. The work was controlled by scientific notebook. While the notebook does a good job of documenting the mechanics of which thematic mapper (TM) data bands were combined and ratioed from which scenes, it provides no objective for the study and no rationale for the selection of bands and ratios. The interview with Tom Lugaski revealed that the objective of the study was to follow standard industry practices as described in text books and journal articles for selecting band combinations and ratios that were known to highlight certain types of alteration and mineralization. After this was performed, areas of known mineralization in the Yucca Mountain region (Bare Mountain, Bullfrog Hills, etc.) were compared to Yucca Mountain itself. The result was that Yucca Mountain appears to be unmineralized relative to known mining districts. It was observed that when the notebook was started in July of 1995 a page of ARemote Sensing Notebook Procedures@ was taped into the front of the notebook. However, they did not meet QARD requirements for scientific notebooks. When the CRWMS M&O procedure on scientific notebooks

(QAP-SIII-3) became available in October of 1996, the remote sensing notebook did not transition to that procedure (this was the case with all of the scientific notebooks examined for the metallic resources study).

Analysis of the geochemical data set was performed by the PI. Data was tabulated and some simple statistics and comparisons applied. With the exception of one sample which indicated very high tin values, the geochemical data indicated that there were no significant metallic resources at Yucca Mountain. The tin rich sample came from a fumarolic altered area of very limited extent and it was concluded that no significant tin resource is present. It is noted, however, that the threshold values for geochemical anomalies are judgmental, and that background values in the area are unknown because no unaltered samples were collected and analyzed, therefore no statistics could be developed relative to average elemental abundances in the Yucca Mountain region.

In summary, it appears that industry standard data analysis techniques were applied to the geochemical, geophysical, and remote sensing data sets for Yucca Mountain and that no anomalies indicative of significant metallic resources were identified. However, this work was not performed in accordance with QARD requirements.

Interpretation/Modeling - One of the goals of the metallic resources investigation was to evaluate the potential for undiscovered resources. There were two approaches to this goal, the first has already been covered in that the Yucca Mountain area was actively explored/prospected by collecting and analyzing samples from the surface and from available deep boreholes and the ESF. This approach is valuable and necessary, but still leaves a significant volume of rock unsampled. To address this situation, the rock types, structure, geophysics, and geochemistry of Yucca Mountain were interpreted in the context of various ore deposit models in an effort to estimate the likelihood of undiscovered metallic resources and mined energy resources. The results of this effort indicated that for the Tertiary sequence, the most likely model was the volcanic hosted low sulfidization gold model and the potential for this model is low. For the Pre-Tertiary sequence, the most likely model was the sediment hosted gold model and the potential for this model is also low. In summary, the interpretation indicated that for every deposit model considered, the potential for Yucca Mountain was low to very low.

Report Development - The report on metallic resources prepared by the NBMG was not developed under any procedure, not all of the authors had an opportunity to see the report as a whole, and it received no review at NBMG prior to being transmitted to the CRWMS M&O in Las Vegas. At the time of the close of the audit (June 4, 1997), a technical reviewer had been selected for the metallic resources report by the CRWMS M&O and the review was in process. A portion of the metallic resources report had already been utilized as input to the overall natural resources report which had been submitted to the DOE on June 2, 1997. The natural resources report, including those portions from the metallic resources report, had been reviewed prior to submittal to DOE but review documentation was not complete. Apparently reviewers had indicated verbally that their concerns had been addressed. In summary, for the metallic resources report, report development was not procedurally controlled, the selection of one reviewer to cover all aspects of the metallic resources report (geophysics, remote sensing, geochemistry, ore deposit modeling) is questionable, and the report review was in process at the close of the audit.

Observations and Recommendations - It is clear (based on interviews with the PI, statements made by the DOE observer during the audit, and examination of the NBMG proposal for the metallic resources work) that it was the intent of the project to abandon the approved study plan. The approved plan is very systematic, very thorough, and follows an academic or research approach to the resource evaluation. It includes a number of items such as isotopic studies of oxygen, hydrogen, and sulfur to evaluate paleomovement of fluids, that have little direct relevance to the existence of metallic resources at Yucca Mountain. Unfortunately, the decision to follow a more industry standard approach to the

metallic resource evaluation is not well documented, the study plan was never revised, and no alternate planning document that meets QARD requirements was developed. If the primary use of the study is as one of several inputs to a probabalistic assessment of the likelihood of future human intrusion, then QA controls may not have been appropriate. Based on the evaluation of the six critical process steps for the metallic resources study and the above discussion of the existing study plan, there are three observations: (1) An industry standard evaluation of the metallic and mined energy resource potential of the Yucca Mountain conceptual controlled area has been effectively completed by the NBMG, with the result that no commercially valuable resources were identified and the potential for undiscovered resources is low to very low. (2) The only potential technical weakness of the study is that no unaltered samples were collected and analyzed so it is not possible to evaluate any anomalies relative to average elemental abundances of rocks in the area. (3) The industry standard resource evaluation completed by the NBMG was not planned, conducted, or documented in accordance with QARD requirements. Relevant to these observations, recommendations number 2 and 3 are offered and presented in Section 6.0

The audit team identified deficient conditions in all QA program elements evaluated except the following:

One condition adverse to quality was identified relative to the lack of CRWMS M&O management direction and control resulting in the UNR performing quality affecting activities with little or no implementation of the OCRWM QA program and the CRWMS M&O implementing procedures. Similar conditions had been identified during previous verification activities of organizations procured by the CRWMS M&O to perform quality affecting activities in accordance with the CRWMS M&O implementing procedures. These conditions are documented on open, existing OCRWM CAR YM-97-C-001. The condition identified during this audit will be incorporated into CAR YM-97-C-001.

As a result of the audit, two DRs were issued. YM-97-D-053 was issued to the CRWMS M&O and UNR for resolution, and was based on the specific areas within the QA program elements that were not adequately implemented at UNR. YM-97-D-058 was issued to the CRWMS M&O for resolution relative to the review process for scientific documents. The final report for Natural Resource Assessment had been reviewed; however, the process described in the implementing procedure, QAP-SIII-2, Review of Scientific Documents and Data, had not been completed.

1. Two procedures exist for activities related to review: QAP-3-1, Document

Review, and QAP-SIII-2, Review of Scientific Documents and Data. These procedures were written to meet the QARD, section 2.2.10. In addition, two procedures exist that can be used for development of technical documents:

QAP-3-5, Development of Technical Documents, and QAP-SIII-1, Scientific Investigation Control. It seems excessive to have two procedures for one activity. The CRWMS M&O needs to consolidate these procedures into one for each activity. In addition, the CRWMS M&O Requirements Matrix does not indicate use of QAP-SIII-1 in section 2.2.10 implementation. This should be added.

2. In view of the current program approach to the assessment of natural resources, and the follow-on activity of estimating the likelihood of future human intrusion, revisit the determination that QA controls were required for these studies. If it is determined that QA controls are still required, then it is recommended an attempt be made to qualify the report for use in accordance with appropriate project procedures.

3. If any additional work on metallic resources is conducted, collect and analyze some unaltered samples so that anomalies can be evaluated in the context of average elemental abundances of rocks in the area.