7. Evaluating and Conducting Readiness Assessments (RAs)

Management System: Environment, Safety, and Health

Subject Area: Facility Safety Authorization

Procedure 7. Evaluating and Conducting Readiness Assessments (RAs)

Subject Matter Expert: CAROL SOHN
Management System Owner: PATRICK SMITH
Secondary Management System Owner: KARL MORO

| SCMS Home Page | Subject Area | Revision History | Subject Area Definitions

Issue Date:  09/11/2012
SCMS Revision:  4.0

1.0  Applicability

This procedure is to provide the Office of Science (SC) a consistent method to assign responsibilities and accountability, for the evaluation and conduct of Readiness Assessments (RAs) of Hazard Category 1, 2, and 3 nuclear facilities, activities, and operations. This procedure applies to SC Headquarters (HQ) and SC Site Office staff responsible for the verification of readiness of startup and restart of Hazard Category 1, 2, and 3 nuclear facilities, activities, and operations for which SC has environment, safety, and health (ES&H) oversight responsibilities.

2.0  Required Procedure

This procedure correlates with latest version of the U.S. Department of Energy (DOE) O 425.1D, Verification of Readiness to Startup and Restart Nuclear Facilities. Across SC, there are several different types of RAs from lowest to highest grading including:

In addition, the complexity of an RA can vary from the simplicity of a checklist to very complex, extensive reviews that are similar to an Operational Readiness Review (ORR). If there are multiple RAs (Contractor-led followed by DOE-led) these are typically performed in series. An exception would be an activity involving a series of startups (e.g., multiple glove boxes in a glove box line) that dependent upon the Plan of Action (POA) and Implementation Plan (IP), could be conducted in parallel. For these types of special circumstances, Contractor Readiness Reviews of each phase (e.g., glove box) would need to be completed and documented, prior to the initiation of the DOE review (e.g., the Contractor RA Final Report would need to be completed and items in DOE O 425.1D, Paragraph 4e(6) completed).

This procedure describes in detail the roles and responsibilities of the SC Site Office and HQ individuals. The procedure does not describe in detail the roles and responsibilities of the contractor or the DOE RA Team. The DOE RA Team roles and responsibilities are described in the order and DOE‑STD‑3006‑2010, Planning and Conducting Readiness Reviews.

For Contractor-led Readiness Assessments, go to Step 1.

For DOE-led Readiness Assessments, go to Step 19.

Contractor-led Readiness Assessments
Step 1

The SC Site Office Manager or designee oversees the contractor to:

  • Ensure that the contractor uses a graded approach (e.g., ranging from a checklist1 to the rigor of an ORR).

  • Ensure the contractor develops a POA which describes the scope of the RA. The POA must provide a clear discussion of the physical or geographical scope of the RA and a clear description of the Structures, Systems and Components (SSC), individual processes, and program that are within the scope of the RA.

  • Ensure the contractor POA designates the proposed RA Team Leader.

  • Ensure the adequacy of qualification of the contractor RA Team Leader and subsequent selection of any team members (e.g., this can be done by approval of the POA). Note that if the Team Leader is changed, the revised POA or selection of the new team leader must be approved by the SAA.

  • Ensure all core requirements identified in DOE O 425.1D, Attachment 1, Contractor Requirements Document (CRD), Paragraph 2.f., are evaluated for applicability for inclusion in the scope of the RA. Note that core requirements excluded may be marked “Not Applicable” with a brief justification for that marking.

  • Ensure the level of detail provided in the justification should be commensurate with the complexity of the review and of the operation, such that a knowledgeable reader would reasonably be expected to draw the same conclusions.

  • Ensure the Contractor POA scope is appropriate for the circumstances associated with the startup or restart.

  • Ensure the Contractor POA includes the prerequisites for starting the RA. Prerequisites define measurable actions or deliverables that, when completed, provide assurance that readiness has been achieved for each specific core requirement that is to be reviewed in the RA.

  • Ensure the contractor submits the POA to the SC Site Office.

1 - A sample checklist is provided in the Example of Readiness Assessment Checklist.

Step 2
  1. The SC Site Office Manager or designee reviews the POA for adequacy and provides any comments to the contractor for resolution (see NOTE 2).

  2. If the Startup Authorization Authority (SAA) is the SC Site Office Manager, the SC Site Office Manager approves the POA. This step is not applicable to Contractor approved RAs.

  3. The SC Site Office Manager or designee:

    • If the SAA is a HQ individual, forwards the contractor POA and a recommendation for disposition to SC Deputy Director for Field Operations (SC‑3).

    • Forwards the contractor POA to SC‑3, SAA (if the SAA is not the contractor or the SC Site Office Manager), DOE HQ Office of Health, Safety and Security (HS‑1) and the SC Central Technical Authority (CTA).

    • Provides any comments from HQ entities to the contractor for disposition (see NOTE 2).

NOTE 1:  The RA may not commence until the POA has been approved by the SAA.

NOTE 2:  For contractor approved RAs, the degree of review by DOE may be limited and should follow a graded approach.

Step 3

The Senior Nuclear Safety Advisor:

  • Reviews the Contractor submitted POA and provides any comments to the SAA.*

  • Coordinates any comments from HQ entities on the Contractor POA to the SC Site Office for resolution.

* Applies to DOE approved Readiness reviews.

Step 4

If an HQ official is the SAA, the HQ official:

  • Reviews the POA.

  • Approves or disapproves the POA

  • Provides the approved POA or comments (if not approved) to the SC Site Office Manager or designee (as applicable)

Return to Step 1 of this procedure if the POA was not approved.

NOTE: The RA may not commence until the POA has been approved by the SAA.

Step 5

The SC Site Office Manager or designee oversees the contractor to:

  1. Ensure that the Contractor RA Team Leader selects team members (as applicable) meeting the following training and qualification requirements*:
    1. Technical knowledge of the area assigned for evaluation including experience working in the technical area;

    2. Knowledge of performance based assessment processes and methods; and

    3. Knowledge of the facility, activity or operation-specific information.

  1. Ensure that RA team members do not review work for which he or she is directly responsible.

  2. Ensure the Contractor RA Team Leader determines and documents the team’s qualification and training and freedom from conflict of interest. Adequacy of the qualifications of Contractor Readiness Review Team Members may be based on DOE concurrence with contractor procedures if the procedures specify that team members must meet the minimum qualification and training requirements specified in DOE O 425.1D, Attachment 1, CRD, Section 2.e.(3).

* Typically done based upon review of the IP (no documentation required).

Step 6

The SC Site Office Manager or designee oversees the contractor to ensure:

  • The Contractor RA team develops an IP.*

  • The Contractor IP documents the evaluation criteria and the review approaches based on the scope given in the POA.*

  • The Contractor Team Leader approves the Contractor IP.*

  • The Contractor IP includes the full RA scope defined in the POA.*

  • The Contractor submits the Contractor IP to the SC Site Office.*

  • The Contractor RA is conducted to the Contractor IP.*

* - These items may be excluded per approval of this procedure by the Program Secretarial Officer (PSO) with SC CTA concurrence for RAs of a simpler nature (e.g., checklist type RAs) .

Step 7

The SC Site Office Manager or designee:

  • Reviews the Contractor IP for adequacy and provides any comments to the contractor for resolution.*

  • Forwards the Contractor IP to SC‑3, HS‑1, the SC CTA, and the SAA (IP only goes to SAA if the SAA is not the contractor or the SC Site Office Manager).*

NOTE: The RA may not commence until the IP has been approved by the RA Team Leader.*

* - These items may be excluded per approval of this procedure by the PSO with SC CTA concurrence for RAs of a simpler nature (e.g., checklist type RAs).

Step 8

The Senior Nuclear Safety Advisor:

  • Reviews the Contractor IP and provides any comments to the SAA.*

  • Coordinates any comments from HQ entities on the Contractor IP to the SC Site Office for resolution.*

* - These items may be excluded per approval of this procedure by the PSO with SC CTA concurrence for RAs of a simpler nature (e.g., checklist type RAs).

Step 9

The SC Site Office Manager or designee oversees the contractor to ensure that prior to starting the Contractor RA:

  • Contractor line management has issued a Readiness to Proceed Memorandum certifying that the facility, activity, or operation is ready for startup or restart.*

  • The Contractor Readiness to Proceed Memorandum is accurate.*

  • Contractor line management verifies that preparations for startup or restart have been completed with the exception of a manageable list of open prestart issues with a well-defined schedule for closure.

  • Contractor line management verifies that the contractor RA POA prerequisites have been met.

* - These items may be excluded per approval of this procedure by the PSO with CTA concurrence for RAs of a simpler nature (e.g., checklist type RAs).

Step 10

The SC Site Office Manager or designee ensures that prior to starting the Contractor RA:

  • Any comments on the Readiness to Proceed Memorandum have been forwarded to the SAA.*

  • If the SAA is a DOE HQ individual, the SC Site Office Manager or designee provides a recommendation to the SAA if the contractor is ready (can be completed via email).

* - These items may be excluded per approval of this procedure by the PSO with SC CTA concurrence for RAs of a simpler nature (e.g., checklist type RAs).

Step 11
  1. If DOE is the SAA for a Contractor-led RA, the HQ or SC Site Office Manager SAA approves commencement of the Contractor RA (via written documentation or email) and the contractor performs the RA

  2. If the contractor is the SAA, the contractor line management approves commencement of the Contractor RA.

NOTE: The RA may not commence until the SAA has approved the RA to commence.

Step 12

The contractor (including the Contractor RA Team):

  • Performs the RA using the IP.

  • Approves and issues a final report.

  • Provides the final report to the SC Site Office and to the SAA (as applicable).

Step 13

The SC Site Office Manager or designee oversees the contractor to ensure:

  1. The adequacy of the Contractor-led RA.

  2. The adequacy of the final report that is prepared by the Contractor RA Team.

  3. The final report includes:

    1. A conclusion as to whether startup or restart can proceed safely;

    2. Adequate detail to support the conclusion; and

    3. A lessons learned section to assist future readiness review efforts.

  1. That the Contractor RA Team Leader approves the final report.

  2. That the Contractor RA Team Leader provides a copy of the final report to the SC Site Office.

NOTE: If a checklist is used for the RA, the checklist may serve as the POA, IP, and final report but must also meet the basic content requirements of a final report as described in Step 13.

Step 14

The SC Site Office Manager or designee:

  • Provides a copy of the RA report to SC‑3, HS‑1, the SC CTA, and the SAA (only goes to SAA if DOE is the SAA).

  • Provides any comments from HQ entities on the final report to the contractor.

Step 15

The Senior Nuclear Safety Advisor:

  • Reviews the final report and provides any comments to the SAA

  • Coordinates any comments from HQ entities on the final report to the SC Site Office.

Step 16

The SC Site Office Manager or designee oversees contractor activities to:

  • Ensure that corrective action plans are developed by the contractor to correct findings from the final report. Action plans must provide an evaluation of, an address any overall programmatic deficiencies and causes.

  • Ensure that corrective action plans for post-start items have been developed, implemented, and approved.

  • Ensure that a finding closure package has been created that includes a brief description of actual corrective actions taken, evidence of completion, and reasons for concluding that closure has been achieved.

  • Ensure that contractor pre-starts have been satisfactorily resolved prior to startup or restart.

Step 17
  1. If the SAA is a DOE individual:

    • When there is no subsequent DOE RA, the SC Site Office Manager or designee ensures that all pre-starts findings are closed.

    • When there is a subsequent DOE RA, the SC Site Office Manager or designee ensures that any open pre-start findings have a well-defined schedule for closure.

  1. The SC Site Office Manager or designee provides a recommendation to the SAA to approve/disapprove startup via email or formal documentation.

Step 18

If DOE is the SAA, the DOE SAA approves the startup or disapproves the startup and identifies issues to the contractor through the SC Site Office Manager or designee.

This completes this procedure.

DOE-led Readiness Assessments

Step 19

The SC Site Office Manager or designee oversees activities to:

  • Ensure that DOE line management and the DOE Team Leader use a graded approach for the RA (e.g., ranging from a checklist1 to the rigor of an ORR).

  • Ensure that DOE line management develops a POA which describes the scope of the RA. The POA must provide a clear discussion of the physical or geographical scope of the RA and a clear description of the SSCs, individual processes, and program that are within the scope of the RA.

  • Ensure the DOE POA designates the proposed RA Team Leader.

  • Ensure the adequate qualification of the DOE RA Team Leader and subsequent selection of any team members.

  • Ensure all core requirements identified in DOE O 425.1D, Paragraph 4.f., are evaluated for applicability for inclusion in the scope of the RA.

  • Ensure the DOE POA provides a basis for justifying the exclusion of any core requirement that will not be assessed during the RA. The level of detail provided in the justification should be commensurate with the complexity of the review and of the operation, such that a knowledgeable reader would reasonably be expected to draw the same conclusions. Note that core requirements excluded may be marked “Not Applicable” with a brief justification for that marking.

  • Ensure the DOE POA scope is appropriate for the circumstances associated with the startup or restart.

  • Ensure the DOE POA includes the prerequisites for starting the RA. Prerequisites define measurable actions or deliverables that, when completed, provide assurance that readiness has been achieved for each specific core requirement that is to be reviewed in the RA. Prerequisites should also address DOE oversight of contractor preparations and DOE’s readiness to oversee contractor operations within the scope of the RA.

  • Ensure the DOE POA is submitted to the SC Site Office Manager.

1 - A sample checklist is provided in the Example of Readiness Assessment Checklist.

Step 20
  1. The SC Site Office Manager or designee reviews the POA for adequacy and resolves any comments with SC Site Office Line Management.

  2. If the SAA is the SC Site Office Manager, the SC Site Office Manager approves the POA.

  3. The SC Site Office Manager or designee forwards the POA with recommendation (for disposition) to SC‑3, HS‑1, the SC CTA and the SAA (only goes to SAA if the SAA is an HQ individual).

NOTE: The RA may not commence until the POA has been approved by the SAA.

Step 21

The Senior Nuclear Safety Advisor:

  • Reviews the DOE POA and provides any comments to the SAA.

  • Coordinates comments from HQ entities on the DOE POA to the SC Site Office for resolution.

Step 22

If the SAA is an HQ official, the HQ official:

  • Reviews the POA.

  • Approves or disapproves the POA.

  • Provides the approved POA or comments (if not approved) to the SC Site Office Manager or designee (as applicable).

Return to Step 19 of this procedure if the POA was not approved.

NOTE: The DOE RA may not commence until the POA has been approved by the SAA.

Step 23

The Site Office Manager or designee oversees activities to ensure:

  1. That the DOE RA Team Leader selects team members (as applicable) meeting the following training and qualification requirements:

    1. Technical knowledge of the area assigned for evaluation including experience working in the technical area;

    2. Knowledge of performance based assessment processes and methods; and

    3. Knowledge of the facility, activity or operation-specific information.

  1. That the DOE RA team does not include as senior members individuals from offices that are assigned direct line management responsibility for the work being reviewed. Any exceptions require SAA approval.

  2. That DOE RA Team Members do not review work for which he or she is directly responsible.

  3. The DOE RA Team Leader determines and documents the team’s qualification and training and freedom from conflict of interest in the areas they are assigned.

Step 24

The Site Office Manager or designee oversees activities to ensure:

  • The DOE RA team develops an IP.

  • The IP documents the evaluation criteria and the review approaches based on the scope given in the POA.

  • The DOE RA Team Leader approves the DOE IP.

  • The DOE IP includes the full RA scope defined in the DOE RA POA.

  • The DOE RA Team Leader submits the DOE IP to the SC Site Office.

  • The DOE RA is conducted to the DOE IP.

Step 25

The SC Site Office Manager or designee:

  • Reviews the DOE IP for adequacy and provides any comments to the DOE RA Team Leader for resolution.

  • Forwards the DOE IP to SC‑3, HS‑1, the SC CTA and the SAA (only goes to SAA if not SC‑3)

NOTE: The RA may not commence until the DOE IP has been approved by the DOE RA Team leader.

Step 26

The Senior Nuclear Safety Advisor:

  • Reviews the DOE IP and provides any comments to the SAA.

  • Coordinates any comments from HQ entities on the DOE IP to the SC Site Office for resolution.

Step 27

The SC Site Office Manager or designee ensures that prior to starting the DOE RA:

  • DOE line management has received formal written Readiness to Proceed Memorandum from the contractor certifying that the facility is ready for startup or restart.

  • The Contractor’s Readiness to Proceed Memorandum is accurate.

  • Any comments on the Readiness to Proceed Memorandum have been forwarded to the SAA.

  • DOE Line Management verifies that preparations for startup or restart have been completed with the exception of a manageable list of open prestart issues with a well-defined schedule for closure to allow the DOE RA Team to review the closure process.

  • DOE line management verifies that the DOE RA POA prerequisites have been met.

  • The SC Site Office Manager or designee provides a recommendation to the SAA if the contractor and DOE are ready (can be completed via email).

Step 29

The SAA (either the SC Site Office Manager or HQ individual) approves commencement of the DOE RA (via written documentation or email).

NOTE: The RA may not commence until the SAA has approved the RA to commence.

Step 30

The DOE RA Team conducts the RA to the IP and prepares a final report.

Step 31

The DOE RA Team Leader:

  • Approves the final report and each team member approves the section of the final report for which he/she was responsible. There will be a provision for dissenting professional opinions if agreement cannot be achieved.

  • Provides a copy of the final report to the SC Site Office and SAA.

Step 32

The SC Site Office Manager or designee oversees activities to:

  1. Ensure the DOE RA Team prepares a final report and provides a copy of the report to the SC Site Office Manager and SAA

  2. Ensure the final report is adequate and includes:

    1. A conclusion as to whether startup or restart can proceed safely,

    2. Adequate detail to support the conclusion, and

    3. A lessons learned section to assist future readiness review efforts.

Step 33

The SC Site Office Manager or designee:

  • Provides a copy of the RA report to SC‑3, HS‑1, and the SC CTA.

  • Provides any comments from HQ entities on the final report to the DOE RA Team Leader.

Step 34

The Senior Nuclear Safety Advisor:

  • Reviews the final report and provides any comments to the SAA.

  • Coordinates any comments from HQ entities on the final report to the SC Site Office.

Step 35

The SC Site Office Manager or designee oversees contractor and DOE activities to:

  • Ensure that corrective action plans are developed by the contractor and DOE to correct findings from the final DOE RA report. Action plans must provide an evaluation of, an address any overall programmatic deficiencies and causes.

  • Ensure that contractor and DOE corrective action plans for post-start items have been developed, implemented, and approved.

  • Ensure that a finding closure package has been created that includes a brief description of actual corrective actions taken, evidence of completion, and reasons for concluding that closure has been achieved.

  • Ensure that contractor and DOE pre-starts have been satisfactorily resolved prior to startup or restart.

Step 36

The SC Site Office Manager or designee oversees activities to ensure all pre-starts (contractor and DOE) are closed.

Step 37

The SC Site Office Manager:

  • If the SC Site Office Manager is the SAA, approves or disapproves the startup or restart via email or formal documentation

  • If the SAA is an HQ individual, provides a recommendation to the SAA to approve/disapprove startup/restart via email or formal documentation.

Step 38

The DOE HQ SAA:

  • Approves or disapproves the startup or restart and identifies related issues associated with disapproval (this is typically done with a formal memorandum)

  • Forwards the startup decision to the SC Site Office Manager.

This completes this procedure.

3.0  References


This is the online OFFICIAL SCMS COPY of this file. Before using a printed copy, verify that it is the most current version by checking the Last Major Revision and Last Minor Revision dates (at the bottom of each document) on the SCMS Web site.


| SCMS Home Page | Subject Area | Revision History |

Send a question or comment to the SCMS Help Desk.
Disclaimer

Filename: \ORBIT\OrbitSearch\SubjArea\FSA\FSA_Pro7.cfm
Last Major SCMS Revision: 09/11/2012