Deficiency Form - Continued

DOE-STD-3006-95

Appendix 4

A sample of five occurrence reports revealed that all but one were on schedule regarding

reporting to DOE Headquarters. Lessons learned training required in three of the five reports

was complete. A spot check of operators during interviews (13 interviews) confirmed the

effectiveness of the lessons learned training.

(b) Not Desirable; no specifics, personalized, irrelevant...

The contractor's ORPS Program was examined. It's one of the best I've seen - almost as good as

XXX in XXXX. A sample of reports were looked at and found to be in excellent condition.

Headquarters likes this program too and was very complimentary about it when I was up there

last month.

Review of SAR/TSR implementation; maintenance of pressure differential in glove boxes for

personnel protection.

(a)

Desirable; objective, analytical, supported by background detail.

Chapter XXX of the SAR requires ". . . absolute pressure in a glovebox in operation with

radioactive material in it shall be maintained below the pressure of the surrounding area such that

any air flow shall be from the surrounding area into the glovebox. This is to prevent the escape of

airborne or potentially airborne radionuclides from the glovebox to the surrounding area." This

requirement has been implemented through Technical Safety Requirement (TSR) xxxx that

requires a differential pressure (DP) of xx in. of water to be maintained between a glovebox and

its surrounding area.

The gauges installed to monitor this DP are not calibrated on a regular basis and have not been

calibrated since installation 5 years ago. These gauges are the principle means of surveillance to

ensure that the TSR is complied with. The DP gauges are not considered safety related

equipment by the contractor and are, therefore, not part of the calibration program. The

contractor's position is that the gauges are informational only and not "safety related equipment."

The ORR team disagrees with this interpretation and asserts that the DP gauges are "safety

related equipment" in that they provide the means to monitor a TSR and need to be reliable and,

therefore, should be part of the M&TE Calibration Program.

(b)

Undesirable; confusing, argumentative, lacking in detail and background, requirement not

established...

The DP gauges installed on the glove boxes are out of calibration. I looked at 13 of them and all

Appendix 4-18