A Potentially Inadequate Safety Analysis (PISA) was identified by NWM division personnel at the Alpha Gamma Hot Cell Facility. The facility Basis for Interim Operations (BIO) incorrectly and inconsistently states that the entirety of the facility is maintained in negative pressure with respect to its surroundings. In fact, the PISA identified that certain rooms with minimal to no radioactive material have been found that are not configured to maintain a negative pressure relative to adjacent portions of building 212. Additionally, the BIO and facility Technical Safety Requirements also incorrectly state all facility exhaust is HEPA filtered. Two older exhausts for the facility, also in and serving areas with minimal to no radioactive material, have been identified that have no filtration (a result of their original design).
Lessons Learned: Any time a change adds, deletes, or modifies system document, a full walkdown verification of credited controls are recommended.
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