Appendix I: Application of the Graded Approach in Orr Planning - Continued

DOE-STD-3006-95

Appendix 1

- Confidence in site-wide issues: Even if the proposed startup or restart does not directly involve

changes to site issues (e.g., emergency preparedness, site fire response, environmental monitoring), it

may be prudent to evaluate these in an ORR unless recent reviews have shown them to be acceptable.

Startup or restart of a facility will be problematic within a significantly flawed site infrastructure.

Conversely, a strong record of implementing DOE requirements, e.g., Conduct of Operations, would

allow for a justifiable reduction in depth in that area in the ORR.

- Issues raised through other internal or external reviews: The ORR may need to verify that

previously raised issues have been adequately addressed. These issues may be facility-specific or may

relate to the site infrastructure within which the facility operates. Technical Safety Appraisals and

Tiger Team reports are important sources of these issues. The facility's experiences in implementing

the corrective actions and lessons learned may also provide a valuable perspective for determining the

depth of the ORR. Caution must be exercised in utilizing previous inspections as justification for

eliminating a topic or limiting the breadth of review. The adequacy of any previous review to be used

in this manner should be equivalent in all respects to the review that would have been conducted

during the ORR.

- DOE 0 425.1 requires that ORRs document lessons learned. Such lessons may assist in determining

the depth of the ORR. Previous reviews may highlight issues to be considered or may provide the

justification for doing a less detailed review if recent reviews and restart experience can be cited.

- Extent to which the facility/process has been evaluated or operated using the standards and level of

excellence being used in the ORR: In applying the graded approach, the extent to which the facility

has utilized or been evaluated against the current nuclear safety standards should be considered. A

facility that has operated successfully using the DOE nuclear safety standards may require a less

extensive ORR depth.

Appendix 1-4