Exemptions. - std_3006

DOE-STD-3006-2000

assessment expertise in addition to technical expertise. No ORR team member shall review his or

her own work or that for which they are responsible.

d. As a minimum, the DOE and responsible contractor ORR reports shall be maintained in auditable

form. This should include the ORR finding closure records.

e. The contractor and DOE readiness review process must have a provision to record and retain lessons

learned for future use. Lessons learned should be documented in the ORR report.

The process flow diagram in Appendix 5 depicts the sequence of requirements to achieve startup

authorization. The diagram includes a reference to the Section(s) of the ORR standard that describe

the requirements of each step or element.

4.6 Exemptions. DOE O 425.1B specifies that the exemption provisions of DOE O 251.1 and DOE

M 251.1-1 are applicable. Obtaining an exemption to ORR requirements might be appropriate in those

situations when a short duration, one-time activity is to be conducted for which the requirements for an

ORR are not warranted. Examples of this situation include one-time, unique operations to clean out

systems or components incident to deactivation and decommissioning (D&D) or short duration actions

necessary to support national commitments in unusual circumstances. The justification for exemption

should be prepared by the responsible contractor and reviewed or approved on a case-by-case basis in

accordance with DOE M 251.1-1. The exemption request should define the process to confirm readiness

to safely start the operations and to ensure that the operation will be conducted with the degree of safety

warranted by the hazards and risks of the process being conducted. The exemption request should define

compensatory measures such as continual supervisory or DOE presence during operations to be taken to

assure safety. The exemption request should identify the activities to be taken to assure readiness of

personnel, procedures, and structures, systems, and components to safely conduct the operation. The

exemption request should also specify the methods of review to verify readiness has been achieved. The

justification to conduct operations under these specified conditions is provided to EH for their

independent review. When the exemption is to extend beyond the time requirements of DOE O 425.1,

section 4.a (1), the exemption request to authorize an RA in lieu of an ORR should provide justification

for approval and describe the scope of the proposed Readiness Assessment to be conducted.