Acceptable Procedural Exceptions to ORRs for Conduct of RAs

DOE-STD-3006-2000

(1) In the case of routine restarts when little maintenance and few minor modifications have occurred,

but an RA is required, it may be appropriate for the responsible contractor to use a pre-approved

checklist and have the results monitored or reviewed by a member of the Operations Office. In these

cases, a separate DOE RA might not be required; the responsible contractor could be the restart authority.

However, any Operations Office review of the RA that is deemed necessary should be performed prior to

resumption of operations.

(2) The sequence of the contractor and DOE RAs could be more flexible when authorized by the restart

authority. Similarly, the contractor RA might be sequenced in parallel with final actions to gain

readiness to resume operations. The principle that the RA verifies areas in which readiness has been

gained remains critical to the process. Therefore, the relevant prerequisites must be met prior to start of

individual parts of the RA.

(3) The independence of the team members from management could be less rigorous for the RA. The

principle that no RA team member review his/her own work shall be retained.

(4) The requirement for formal, written notification of readiness to resume operations provided to the

Operations Office could be modified. Notifications in accordance with DOE O 232.1A could be used if

specified in Operations Office procedures.

(5) The formal RA record must be adequate to identify what was done, the results, and the

recommendation concerning resumption of operations by the individual(s) who conducted the RA.

Contractor and Operations Office procedures should specify the minimum record for various categories

of RAs discussed in the procedure. For example, those RAs which use pre-approved checklists would

have a less complex report than those RAs following an extended shutdown of a Hazard Category 3

facility with significant modifications.

(6) The RA plan or checklist may or may not contain all elements of an ORR Implementation plan.

Many of the policies and procedures described in this standard are relevant and appropriate for inclusion

in procedures for Readiness Assessments. For example, the discussions concerning breadth and depth

decisions are equally appropriate to RAs as well as ORRs. In situations where an ORR would be

required except that the Hazard Categorization is 3 vice 2, ORR procedures from the standard would be