1. The EM/HQ Perspective on Readiness Review
Robert Goldsmith, PhD
Director of Operations Oversight
EM-62

2. Office of Operations Oversight
EM-60 - Office of Safety Management and Oversight
EM-62 - Mission: To determine the effectiveness of Federal and contractor safety and health programs and management systems at EM field sites

3. EM-62 Oversight Responsibilities
Day-to-day oversight of operational safety
Line management assessments
Integrated
Targeted
Validation and verification of completed corrective actions
Startup and restart of nuclear facilities
Timely identification and assistance in correction of deficient safety conditions
Line management assessments, consistent with DOE Order 226.1, the DOE Worker Safety and Health Program, and ISMS criteria – targeted is stuff like con ops, work control, radcon, hazardous energy control
Completeness of CAs and effectiveness
Operational Readiness Reviews/Readiness Assessments

4. EM-62 Readiness Review Responsibilities
Startup Authorities ID OR
ORP RL SR
WIPP
P/P
BNL
Cat 3
FOM HQ
Cat 2 restart
Startup authority is Dae
S-1 is the startup authority for new Category 1 and 2 Facilities. (NNSA may have had this delegated to S-2
New Category 2 activities in existing facilities have been treated as Cat 2 Restarts (Historically)

5. EM-62 Readiness Review Responsibilities
Review and recommend approval
Plan of Action
Startup Notification Requests
Declaration of Readiness
ORRs & RAs
Lead, participate or observe
Central Technical Authority
DNFSB
We Review and Recommend where EM has startup authority
The Appropriate Startup Authority approves the SNR
ORRs – both contractor and field office

6. EM Recent Experience Most ORRs and RAs executed properly
Anomalous events
Premature declaration of readiness
Site not following its own procedures
RA begun before DSA approved
Site procedure that almost precluded ORRs
Over Last 18 months
Premature – Oak Ridge MSRE
Not following procedures ID
RA w/o DSA – SRS
Site Procedures the precluded ORRs – RL
“Optics Problem” with GWSB#2 at SRS. This is a new building to hold vitrified waste canisters from the DWPF. Up to 4 of these buildings were analyzed in the DSA. Therefore the site did not consider it a major modification and did not do a PDSA. The regulators saw the situation differently. Both positions can be defended by the Order. The new SRS decision process still does consider this action as requiring a PSA.

7. Recent EM/HQ Actions
Include readiness review process in integrated assessments
Developed a DOE O 425.1C CRAD
Memo from COO reiterating expectations with regard to DOE O 425.1C
Working group with DOE-ID, CWI, EM, HSS, CTA
EM Field
SRS: New Decision Process in Place
RL: Revised Readiness Procedure
Ines memo:
SNRs due 1/31 and quarterly
Approved DSA before ORR/RA
Working group with DOE-ID, CWI, EM, HSS, CTA
To develop comprehensive plan that addreses what facilities are needed to carry out the cleanup mission, what facilities are needed, what is the AB umbrella for these facilities, what exemptions are required, what can we do at HQ to streamline exemption process, and what changes or interpretive guides can we make to minimize the level of subjectivity for 425?

8. Some EM issues with DOE O 425.1C
Readiness Assessments are intended to be highly flexible
What is an initial startup?
What is a new facility?
What is a major/substantial modification?
What should follow a contractor RA?
Need for S-1 approval of new Cat 2 facilities?
Readiness Assessments are intended to be highly flexible, enabling a broad range of scope and depth – this may not be well embraced throughout the complex and regulators. Other processes should not be used to diminish the RAs domain or preclude sound professional judgment. RAs as defined in the Order, and even more so in STD-3006, are intended to be very flexible.  Also, 3006 clearly states in section
.10.1(8), "There is flexibility within the expectations for an RA. Therefore, it should not be necessary for the contractor to define any other readiness review processes." 
Initial startups – new nuclear activity in existing facility; new equipment; existing nuclear process that moves to different locations (burial grounds, waste drums).
S-1 approval carries a high overhead that doe not necessarily improve safety. Incentive to game the system to avoid the overhead.

9. Workshop Should Consider
Recommendations for changes to Order and associated standards and guides
Consensus on key definitions
Template for readiness determination site process, including documentation
Standardized CRAD
DOE library of precedents
Consider not making changes.
The PDSA standard STD-1189 (in draft) has a definition of new facility. This will pre-empt and resolve some of our issues.
Standardized CRAD- so sites know what to expect and reviewers know what to review.