Summary - std_3006

DOE-STD-3006-2000

number of open items at the time the Readiness to Proceed Memorandum is submitted to DOE the initial

conclusion is that the responsible contractor's management and ORR processes were not successful.

The following discussion concerning the acceptability of the open prestart items at the time the

Readiness to Proceed Memorandum is provided:

a. Each open item prerequisite to commencing facility operations must be identified as a part of the

Readiness to Proceed Memorandum.

b. The number of open items must be small. In determining how many open items is acceptable, one

principle should be that every area to be evaluated by the DOE ORR must be sufficiently complete to

permit evaluation. For example, a single finding or multiple findings that in aggregate mean that

some key program has not yet been developed and put in place would not be acceptable since the

DOE ORR would be unable to review the adequacy of the program. Only if that program were to be

in place prior to the end of the ORR would a finding of this sort be acceptable as an open item in the

Readiness to Proceed Memorandum.

c. Each open item must be defined with an explicit corrective action plan. Open items such as "the

required environmental permits have not been requested or approved" would not be acceptable in that

many additional facility procedures and activities are potentially dictated by the corrective actions to

the identified open item.

d. Each open prestart item from the contractor ORR must have a reasonable plan of corrective action in

place. The plan must be included with the identified open items in the Readiness to Proceed

Memorandum. The schedule for completion of the corrective action plan must be consistent with the

timing for the completion of the DOE ORR.

In summary, the open items should be few in number, well defined with a well defined corrective action

plan, able to be completed on a schedule which is consistent with the DOE ORR schedule, and not of

such a nature individually or in aggregate to preclude an adequate review by the DOE ORR of any

specific area.