Clarification of some of the Core Requirements contained in Appendix 2

DOE-STD-3006-2000

Clarification of some of the Core Requirements contained in Appendix 2

Since the formal inception of the Operational Readiness Review (ORR) program, lessons learned have

been generated. Through review of these lessons learned is has been noted that some of the Core

Requirements need further explanation to properly communicate the expectations contained therein.

Specifically Core Requirement 7 regarding implementation of established requirements has generated

confusion from both a preparation and an evaluation perspective. Core Requirement 10 has generated

confusion from a preparation standpoint. Further details regarding these core requirements are provided

below.

Core Requirements 7 states, "Formal agreements establishing requirements are in place between the

operating contractor and DOE, via the contract or other enforceable mechanism, which govern the safe

operations of the facility. A systematic review of the facility's conformance to these requirements has

been performed. These requirements have been implemented in the facility, or compensatory measures

are in place, and formally agreed to during the period of implementation. The compensatory measures

and the implementation period are approved by DOE." This requirement was established to drive

implementation of various initiatives including S/RIDs and Work-Smart Standards. The requirement

however, includes implementation of the established requirements at the facility. Organizations have

misinterpreted this requirement to be fulfilled through the completion of the S/RID or Work-Smart

Standards program. While the completion of the program elements is certainly prerequisite to the proper

controls being established in the facility, the facility level implementation of the requirements is the issue

of primary concern. The procedures and direction for "floor level" operations must implement the

established requirements agreed to by DOE and the operating contractor through the S/RID, Work-Smart

Standard, or other acceptable program. The existence and adequacy of these procedures and direction at

the floor level must be verified by line management prior to startup/restart, and confirmed by the ORR or

RA team during the startup/restart review.

Core Requirement 10 States, "An adequate startup or restart program has been developed that includes

plans for graded operations and testing after startup or resumption to simultaneously confirm operability

of equipment, the viability of procedures, and the performance and knowledge of the operators. The

plans should indicate validation processes for equipment, procedures, and operators after startup or

resumption of operations including any required restrictions and additional oversight." This requirement

was established to provide direction for the period following the ORR or RA and the startup/restart of the

facility. It is recognized here that, since operations are not authorized prior to and during the ORR or

Appendix 3-3