Developing the Implementation Plan
Ensure the objectives and criteria clearly encompass all aspects of the Core Requirements defined in the approved Plan of Action. Generally, this will be all core objectives in an ORR and some subset of the total for an RA. The ORR standard breaks the eighteen Core Requirements into 36 objectives, which translate easily into functional areas. Experience has shown this methodology to be successful. Additionally, the "geographic" scope of the ORR/RA must be considered. The POA should specify the bounds of the facility, systems, and personnel involved in the activity under review and the approaches for the objectives and criteria should reflect these boundaries.
Confirm that the CRADs are written with a clear understanding of the facility systems and processes under review. A generic CRAD should be tailored during the pre-visit to successfully complete a thorough and critical review. Without this understanding and modification of the CRADs, the review effort will suffer.
ORR team members need to carefully review their CRADs and the CRADs of other team members and identify areas of potential overlap. Areas of potential overlap should be discussed and resolution reached as to who will investigate and document results in that area. This minimizes duplication of effort on part of the team members and the facility, and minimizes the likelihood of conflicting conclusions in the report.
If there are significant delays in commencing an ORR, the Implementation Plan's CRADs should be reviewed again for adequacy. Specific items that may change include: references, scope, programs added or deleted, and member assignments.
Given the level of effort required to evaluate software control systems, consideration should be given to preparing a separate CRAD to address software quality assurance.
Fully involve the team early in the process for training and Implementation Plan development. Early dialogue with facility personnel to gain understanding of the activity in progress and the contractor activities in progress is particularly useful. The Implementation Plan used by the contractor and DOE should be parallel in numerous respects.
Give the POA and the Implementation Plan to oversight groups (HSS, DNFSB, State Agencies as required) as soon as possible. Early review and input from all stakeholders will reduce last minute perturbations.
Determine the contract requirements for the facility in reference to Standards Requirements Information Documents (S/RIDs), Work Smart Standards, DOE Orders, Policies, Manuals, Notices, etc., and Integrated Safety Management. Conduct the review in a manner consistent with the requirements contractually invoked on the facility. Statements regarding the status of the facility in these areas should be included in the final report in addition to the overall evaluation of the compliance posture required.
For further information or comments on the ORR web site, please contact James M. Heffner.