Resource Assessment.

DOE-STD-1082-94

safety or implementation guide to help the implementing organization in

grading. In general, however, the implementing organization is empowered,

because of its detailed knowledge of the specific features and operation of

their facilities and activities, to use its best judgement in the determination of

the appropriate activities for full implementation of a requirement. The

implementing organization shall propose the method for applying a graded

approach to the particular facilities or activities in the proposed programs or

plans submitted to DOE. When approved, those activities become the basis

for assessment and enforcement.

Following the identification of the appropriate activities to meet the

requirements, the implementing organization may determine that on the

basis of limited resources or other considerations that it is not in DOE's best

interest to implement the requirement. In such cases, the implementing

organization shall request an exemption (see Section 3.11 of this technical

standard). It is important to not confuse the graded approach with the

exemption process. The graded approach is to be used to determine the

appropriate manner to comply with a requirement; it is not to be used to

provide relief from meeting the requirement. Exemptions are used to provide

relief.

The implementation plan shall document the basis for selecting the action

pursuant to the graded approach whenever a graded approach is used.

3.8 Resource Assessment. The implementation plan shall provide an

estimate of the additional life cycle costs to implement the nuclear safety

requirements. The goals of this element of the implementation plan are as

follows: (1) to communicate the expected new costs of implementation to DOE

management for the purposes of budget planning and prioritization; (2) to

identify the need to explore more cost effective means of achieving

compliance; and (3) to identify cases where exemptions should be requested

on the basis of insufficient benefit versus the expected implementation costs.

Identification of required resources should also serve to open a dialogue

between DOE and the implementing organization on adjusting costs and

activities to the available resources.