Deficiency Form - Continued

DOE-STD-3006-95

Appendix 4

Implementation of the Required Reading Program was examined. Twenty-five items in the

program were tracked to determine if the 16 qualified Stationary Operating Engineers (SOEs)

have signed-off as having read the required documents. Over half the required reading checked

was found deficient. That is, over half of the 400 (16 x 25) items checked were not documented

as complete. In addition, some significant items from the required reading items were provided to

ORR interviewers to sample SOE retention of the material covered in the readings. The retention

of the key points in these required reading items was poor. Of eight SOEs interviewed on three

items, over half produced unsatisfactory responses.

(b) Not Desirable; extreme, speculative, too general, inappropriate...

The Required Reading Program was examined. It was determined to be one of the worst

programs this reviewer has encountered. Many of the operators had not done the reading and

their attitude was unacceptable. Management said they had a procedure for the program, but I

couldn't locate it. The ORR interviewers asked some of the SOEs about items in their required

reading. Their responses were unsatisfactory. This area needs work.

Review of Operational Experience Review Program; Occurrence Reporting and Processing System

(ORPS) Program

(a)

Desirable; specific, objective, descriptive...

The Occurrence Reporting and Processing System was examined. Requirements from DOE

Order 5000.3 are programmatically implemented at the XXXX facility by the contractor through

XXXX 5000.3. The contractor's procedure is judged to be satisfactory in that it requires

occurrence reports to be generated and reported to the Department as required by the DOE

Order. All specifications in the DOE Order are adequately implemented by the contractor's

procedure.

Some observations were noted. A significant one is that the threshold for an unusual occurrence

regarding the release of "hazardous materials above limits. . ." is unclear. The descriptive

guidance given in the contractor procedure is too general and leads to inconsistency and

confusion. Seven managers of organizations within the facility that dealt with hazardous

materials were interviewed regarding the threshold for reporting under this Order. All were

interpreting the guidance differently and required different responses for similar occurrences

involving hazardous material.

Appendix 4-17