The successful completion of any ORR will be strongly influenced by the degree to which readiness to start program work has been achieved prior to the start of the ORR. While it is the responsibility of line management to achieve a condition of readiness, experience indicates that the ORR Team Leader can influence the success of the process to gain readiness during his/her preparations for the ORR. In many cases, the potential for the particular problem to occur will become evident during pre-visits or other ORR preparations. The following lessons learned reflect areas in which the ORR Team Leader and team members may improve the success of the ORR.
Experience shows that prerequisites should provide significant detail and be fully measurable in order to permit line management to track each prerequisite to completion. The ORR/RA standard stresses the fact that the prerequisites should be tied to the Core Requirements, which are what will be evaluated in the readiness determination. So, ensure that the ORR Prerequisites specified in the Plan of Action support achieving readiness.
A thorough Management Self-Assessment (although not required by DOE O 425.1C) to assist line management in verifying that readiness has been achieved is an important final step in preparing for the ORR. The Contractor ORR Implementation Plan should reflect an intention to review the results of the Management Self-Assessment. The DOE ORR will review the results of the Contractor ORR. Sufficient time between the contractor and DOE ORRs should be planned to allow for finalization of documentation related to the closure and verification of the contractor ORR pre-start findings.
Inadequate, incomplete, or undefined incorporation of the safety basis documentation into procedures and policies has frequently resulted in delays in starting an ORR or in significant findings during the ORR. This is frequently caused by late development and approval of the safety basis documentation. Line management may not fully grasp the time and effort necessary to develop and implement all of the "flow down" procedures and surveillances necessary to put the requirements of the approved safety documentation into practice. Ensure full implementation of the safety basis.
Inadequate or incomplete evidence files or other verifiable documentation that demonstrate the prerequisite conditions have been met may result in an inability to verify readiness has been achieved. The Implementation Plan should clearly indicate the intentions to review these evidence files.
A responsible representative of the line management must be prepared to demonstrate to the ORR team that the conditions required to be met as a prerequisite to resumption, have actually been met. In most cases, this individual will be the counterpart who is assigned to work with the individual ORR Team member. The counterparts should be identified and utilized during the pre-visit.
Assigned counterparts must understand their responsibility to support the ORR team member. The counterpart must present the information and documentation requested. The counterparts must accept responsibility for gaining information and resolving questions. The counterparts should be fully dedicated to a single ORR team member for the duration of the ORR field work. This expectation should be clearly defined during the pre-visit.
Lack of experience on the part of line management as to the expectations of the ORR team in the areas of drills and evolutions expected to occur during the ORR will lead to difficulty in completing established objectives. The Team Leader and team member must devote considerable attention to communicating expectations to responsible line management at the facility level.
Inadequate validation and verification of operational or maintenance/surveillance procedures that are newly prepared or recently modified will result in readiness not being achieved when the ORR starts. An experienced ORR team leader or team member may identify concerns with the adequacy and maturity of these procedures during the pre-visit. If problems are apparent, they should be identified to senior management at the end of the pre-visit.
Lack of formal, structured preparation by DOE line management of the personnel, programs, and documentation to be evaluated during the ORR will delay completion of required activities. DOE line management should be encouraged to conduct a Management Self-Assessment to ensure that prerequisite conditions for which they are responsible have been met. Potential problems in this area may be apparent during the pre-visit and, if noted, pointed out to senior DOE management at that time.
When scheduling sequential ORRs at the same site, management should ensure that delays associated with the first ORR do not negatively impact resources and readiness with respect to conducting the second one.
Note: It should be apparent to the observant Team Leader during the pre-visits and other ORR preparations if difficulties with achieving readiness will be problematic. Although the ORR Team Leader will not be able to deal with the problems directly, his identification of the problems to the appropriate DOE or contractor line manager should be considered.
For further information or comments on the ORR web site, please contact James M. Heffner.