1. Conduct of the Review May 2005 Revision
6T6L

2. Upon successful completion of this topic, the student should be able to:
Describe the Functional Area concept including:
Team Member responsibility
Finding issues vice solutions
Performance IAW Requirements concept
ORR/RA scope
Basic report administration
Requirements determination and considerations
Programs understanding
Personnel aspects
Equipment aspects
Findings- categorization
6T6L May 2005 Revision

3. Team Member Tasks Assist in preparation of Implementation Plan:
Develop acceptance criteria / performance objectives;
Develop lines of inquiry for each review objective;
Complete individual team member readiness preparations.
Conduct Review:
Reviewing documents, procedures, drawings;
Compile support documentation;
Provide compliance review;
Execute ORR as defined in Implementation Plan;
Develop issues and findings
Assist, as needed, to Complete the Review and Final Report.
6T6L May 2005 Revision

4. Team Member Tasks (continued)
Work with other ORR/RA members:
to resolve and communicate issues;
to prepare the review documentation and report;
to eliminate redundant reviews.
Submit completed review documents for review and approval.
Concur with determination of operational readiness and conclusions of ORR/RA report (in their area of assessment).
6T6L May 2005 Revision

5. An Effective ORR/RA Schedule driven; Requires Effective Coordination
Avoid duplication of:
Interviews, procedure reviews;
Drills, exercise observations . . .
Know time line of the review
Schedule driven;
Defined sequences;
Stay on point, avoid distractions;
Preparation of report forms critical and critical path . . .
6T6L May 2005 Revision

6. Team Communications
Team evaluators must stay within their scope of review.
However, team leader should be made aware of problems that may have broader impact *:
Don't assume other review teams are aware of problems;
Don't assume informal one-on-one discussions adequately relay the problem. Bring to attention of team leadership.
i.e., generic problems that may affect other areas . . .
An effective Team maintains effective communications!
6T6L May 2005 Revision

7. Expanding the Review
The review criteria may define parameters by which the review may be expanded.
For example:
Initially, the review may specify interviews with ten randomly selected operators.
A deficiency of one more operators may result in expanding the review approach to 25 operators. Or,
The review may specify a walk-down of the most crucial safety systems.
At a pre-determined number of deficiencies, the review may be expanded to the entire configuration control system.
6T6L May 2005 Revision

8. Pulling the String
A team member determines that personnel are not familiar with an important procedure…
There is a problem with:
the procedure?
training / identification of those needing training?
supervision?
6T6L May 2005 Revision

9. Sustainable Infrastructure is Implemented and “in place”!
One View of Readiness
Sustainable Infrastructure is Implemented and “in place”!
6T6L May 2005 Revision

10. Important Inter-relationships
6T6L May 2005 Revision

11. Documenting Review Methods Assessment Form (Form 1)
Use a Form 1 to document methods and actions taken by team members in evaluation process . . .
Each Form 1:
Covers specific objective;
Documents team members review methodology and results;
Enough detail to allow a reviewer of form to follow evaluation logic;
Follows approach detailed by CRA (document differences, if any, and reasons for change);
Discuss and defend any aspect of review approach not accomplished;
States whether criteria met or not.
Lists issues associated with that objective:
Discuss issue and details in both the Form 1 and on the Form 2.
6T6L May 2005 Revision

12. Documentation of Deficiencies Deficiency Form (Form 2)
Used to document findings identified during criteria evaluation process . . .
Requirement based = clear and specific description of the requirement and the condition which is deficient . . .
Primary objective = clear communication . . .
6T6L May 2005 Revision

13. Review and Approval of Your Work
¬ Completed by team member;
­ Approved by Team Leader;
® Senior Advisor involved;
¯ Often an iterative process;
° Team Leader and Senior Advisor sign entire report;
± Team Member signs for Functional Area only;
² Dissenting opinion path available if no resolution.
6T6L May 2005 Revision

14. Pre-Start / Post-start
Prior to being published, each finding should be identified as to whether or not, in the opinion of the ORR/RA team leadership, it must be resolved as a prerequisite to start of operations. This determines if it is a Pre-Start or Post-Start.
Guidance is in the DOE/NNSA Order and Standards and Handbook and may also be included in the POA and IP.
The contractor/DOE may be required by the Authorization Authority to resolve all Pre-Start findings of the DOE ORR/RA prior to startup or restart of a facility.
6T6L May 2005 Revision

15. Compliance Issues
A non-compliance issue does not necessarily mean a Pre-Start finding!
Does the non-compliance represent:
significant risk?
significant mission impact?
significant political impact?
significant lack of control?
6T6L May 2005 Revision

16. So, the question is.....
Does this finding represent a deficiency of such magnitude as to prevent startup until resolved?
Clear failure to implement commitment or assumption of TSR or DSA
OR:
Is it related to sustainability?
Not a significant safety Issue?
Limited impact to Activity within review scope?
6T6L May 2005 Revision

17. Determining Pre- or Post Start
Pre-Start
Unacceptable Risk
Acceptable Risk
Probability
Post start
6T6L May 2005 Revision

18. Don't just identify the finding. . .
Understand the potential impact of the finding!
The possible consequences of not resolving it . . .
The potential that those consequences will be realized and impact:
- personnel; environment;
- facility; mission;
- public . . .
6T6L May 2005 Revision

19. Determine the possible consequences if Finding is
Consider program
elements that
FINDING
limit
consequences
Determine the possible
consequences if Finding is
Consider confidence in
not corrected
Management System
Determine the potential(s)
Consider program
of those consequences
elements that limit
being realized
potential of unwanted
occurrences
TL Handbook Appendix 11
6T6L May 2005 Revision

20. Some Obvious Prestart Criteria
Causes a loss of operability that prevents safe shutdown or loss of monitoring ability of safety related systems (i.e. important to safety) . . .
Indicates a lack of control that can have near term impact on operability or functionality of safety related systems . . .
Requires operator action in short period of time to prevent or mitigate consequences . . .
Violates assumption or controls by which DOE/NNSA accepts risk of operations . . .
6T6L May 2005 Revision

21. Some More Obvious Prestart Criteria
Results in operation outside of limits of TSRs, OSRs, etc
Results in an Unreviewed Safety Question:
Increase in the probability or consequence of accident or failure mode described in SAR?
Introduction of a new accident or failure mode not described in SAR?
Reduction in the margin of safety as described in SAR?
Results in failure to comply with Authorization Bases commitments (TSR, LCOs, Surveillances etc.) . . .
6T6L May 2005 Revision

22. Some More Obvious Prestart Criteria
Operations/Activities that can lead to:
Environmental release of hazardous material in excess of reporting guidelines, permit limits, etc.
Exposure of off-site personnel in excess of radiological guidelines for off-site exposure or chemical exposure in excess of minimum reportable amounts.
Worker / on-site exposures in excess of guidelines or requirements.
6T6L May 2005 Revision

23. Finding - example
Two LCOs ( and ) specified in the activity SAR are not covered by approved surveillance procedures.
6T6L May 2005 Revision

24. Finding - example
Emergency exits from this facility do not meet the requirements of NFPA 101 (Life Safety Code). The exits are required to have quick- open "crash bar" hardware.
6T6L May 2005 Revision

25. Finding - example
Posting of Radiological areas and entry control programs for these areas per the requirements of 10 CFR 835 were inadequate.
No control device was used as required on each entrance to the hot cell 2 area (high radiation area).
6T6L May 2005 Revision

26. Finding - example
Although an adequate energy isolation procedure has been developed for this activity, maintenance personnel that service equipment in the area were not familiar with the procedure.
No program has been established for root cause determination of maintenance failures, as required by DOE O B
6T6L May 2005 Revision

27. Finding - example
No valve identification was provided for the line emergency shutdown system. Although operators questioned were well aware of the shutdown procedure, new personnel may not be aware of these valves.
6T6L May 2005 Revision

28. Finding - example
The pipe content and direction flow labeling for this process has been limited to those lines with hazardous materials.
Non-hazardous material lines have not yet been labeled.
6T6L May 2005 Revision

29. If the Results of the Review are not Successful
Significant Team Decision; Facts must support . . .
Discuss situation and options with Authorization Authority . . .
Two Options:
Suspend the Review. Interim Report including what was done and areas not done.
Final report for completed Functional Areas (FA) . . .
High level discussion and findings for incomplete FAs . . .
Terminate the Review. Report results with basis for repeat of entire ORR/RA.
6T6L May 2005 Revision