DOE Standards/Requirements Implementation Assessment Instruction

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DEPARTMENT OF ENERGY

Standards/Requirements

Implementation Assessment Instruction

September 1994

TABLE OF CONTENTS

LIST OF ACRONYMS

1.0  INTRODUCTION

The Department of Energy (DOE) has established the Standards/Requirements (S/R) Program to identify appropriate environmental, safety, and health protection standards and requirements for selected sites, facilities, and activities, and to assess the status of implementation of those standards/requirements. Additional information and background on this program can be found in the Implementation Plan in response to the Defense Nuclear Facilities Safety Board (DNFSB) Recommendation 90-2.

The environmental, safety, and health requirements for DOE sites, facilities, and activities will be documented in Standards/Requirements Identification Documents (S/RIDs), in accordance with the "Standards/Requirements Identification Document Development and Approval Instruction." The S/RIDs will identify the standards/requirements that are necessary and sufficient to provide an adequate level of protection to workers, the public, and the environment. The S/RIDs will be developed and proposed by the organizations responsible for implementation of the requirements, and will be reviewed and approved by DOE. Approval of the S/RID by DOE constitutes a determination of adequacy. The status of compliance with each of the requirements included in a S/RID will be determined by performing standards/requirements implementation assessments.

The implementation of requirements involves two phases: first, the requirements must be fully applied in the implementing documents of the site, facility, or activity (e.g., policies, procedures, engineering drawings, training materials, safety analysis reports, etc.); second, the actions and conditions at the site, facility, or activity must be consistent with the specifications in the implementing documents. The assessment activities related to the two phases are very different, and, therefore, separate approaches are required for their performance. Phase I assessments involve the review and evaluation of the implementing documents to determine whether they specify the actions and conditions necessary for compliance with each requirement. Phase 2 assessments involve the review of activities and conditions to determine whether they adhere to the implementing documents. Assessments must include both phases to ensure compliance.

2.0 PURPOSE

The purpose of this Standards/Requirements Implementation Assessment Instruction (Instruction) is to provide criteria for planning and performing Phase 1 and 2 assessments, and resolving noncompliances. This Instruction describes the process to assess the status of the implementation of the standards/requirements (requirements) identified in S/RIDs.

3.0 SCOPE

This Instruction applies to standards/requirements implementation assessments performed by Defense Programs (DP) and Environmental Management (EM) Headquarters (HQ) Offices, Operations Offices, Field Offices, Area Offices and contractor organizations, with regard to requirements in the S/RIDs for DOE sites, facilities and activities.

4.0 DEFINITIONS

These definitions are provided for specific application to the S/R Program and may not be identical to similar terms defined in other documents.

4.1 Adherence: Adherence exists when the conditions, activities and physical configuration of a site, facility, or activity conform to the actions and conditions specified in the documentation established to implement the requirements in an S/RID.

4.2 Compensatory Measures: A Compensatory Measure is an interim action taken, when needed, in response to a noncompliance to a requirement in an S/RID to reduce the environmental, safety, or health risk to an acceptable level until the noncompliance is resolved.

4.3 Compliance: Compliance exists when: (1) requirements in an S/RID and the actions and conditions necessary for compliance with these requirements are specified in implementing documents (Phase I compliance); and (2) facilities and personnel adhere to these implementing documents (Phase 2 compliance).

4.4 Compliance Schedule Approval (CSA): A CSA is a documented request I that specifies a schedule for achieving compliance by the implementation of corrective actions and provides appropriate information to support the request for approval.

4.5 Exemption (EX): An Exemption is a relief, waiver, or release, either temporary or permanent, from a requirement contained in an S/RID.

4.6 Implementing Documents: Implementing documents include but are not limited to: policies, procedures, engineering drawings, training materials; and safety analysis reports, which specify the actions and conditions necessary to operate in accordance with the requirements in the S/RID.

4.7 Request for DOE Approval (RFA): A Request for DOE Approval (RFA) is a documented process for requesting DOE approval of a schedule for corrective actions, or an exemption. The two types of Request for DOE Approval are: Compliance Schedule Approval (CSA) and Exemption (EX).

4.8 Standards and Requirements Information Database (STRIDE): The Standards and Requirements Information Database (STRIDE) is a database that includes a list of requirements and status information relating to implementation of the S/R Program.

4.9 Standards/Requirements Identification Document (S/RID): A Standards/Requirements Identification Document (S/RID) lists the ES&H requirements to be implemented by a site, facility, or activity to achieve an adequate level of protection of worker and public health and safety, and of the environment during the life cycle phases of design, construction, operation, decontamination and decommissioning, and environmental restoration. The S/RIDs are living documents, to be revised appropriately based on a change in the site's or facility's mission or configuration, a change in the facility's life cycle phase, or a change to the applicable standards/requirements.

4.10 Standards/Requirements Implementation Assessment: Standards/requirements implementation assessment is the systematic process for identifying and resolving noncompliances with the standards/requirements specified in an S/RID.

4.11 Validation: Validation is a confirmation of documented information relating to standards/requirements implementation assessment data, results, and closure statements. Validation consists of reviewing records or independently observing actions and conditions to a degree and in a manner that is consistent with the nature and significance of the information and the level of confidence needed.

5.0 RESPONSIBILITIES

This section of the Instruction describes specific DOE and contractor responsibilities related to assessment activities. Phase I and 2 assessments should be performed by the organizations responsible for implementing the requirements included in S/RIDs.

The responsibilities defined for Operations Office Managers shall apply also to the DOE Field Office and Area Office Managers who report directly to DOE HQ.

5.1 Secretarial Officers. Secretarial Officers shall be responsible for the following:

a. assigning the responsibility for HQ assessments to appropriate HQ staff, which includes:

i. planning and conducting HQ assessments and analyzing assessment results;

ii. reviewing proposed corrective actions;

iii. preparing CSAs and EXs; and

iv. implementing corrective actions.

b. validating the Operations Office Phase 1 and Phase 2 assessment and noncompliance resolution processes;

c. monitoring the Operations Offices' validation activities of contractor Phase 1 and Phase 2 assessment processes;

d. approving exemptions and HQ CSAs;

e. tracking assessments and noncompliance resolutions; and

f. ensuring funds have been obligated for assessments and corrective actions.

The Secretarial Officer may delegate any of the above responsibilities, except approval of exemptions.

5.2 Operations Office Managers. Operations Office Managers shall be responsible for the following:

a. assigning the responsibility for Operations Office assessments to appropriate staff, which includes:

i. planning and conducting Operations Office assessments and analyzing assessment results;

ii. reviewing proposed corrective actions;

iii. preparing EXs and CSAs; and

iv. implementing approved corrective actions.

b. validating the contractor Phase 1 and Phase 2 assessment and noncompliance resolution processes;

c. providing formal communication among the contractors, Operations Office, and HQ Offices;

d. approving contractor and Operations Office CSAs;

e. forwarding contractor and Operations Office exemptions to HQ for approval;

f. tracking assessments and noncompliance resolutions;

g. ensuring funds have been obligated for assessments and corrective actions; and

h. reviewing and commenting on contractor assessment plans for Phase I and Phase 2.

The Operations Office Managers may delegate some or all of the responsibilities in this section, except CSA approval, to Operations Office staff or Area Office Managers as applicable.

5.3 Contractors. Contractors shall be responsible for the following:

a. preparing plans for performing Phase I and Phase 2 assessments, including schedules;

b. conducting contractor assessments and analyzing assessment results;

c. notifying the appropriate DOE Operations Office of noncompliances that can be resolved within 120 days, with proposed corrective actions;

d. preparing CSAs and EXs for noncompliances that cannot be resolved within 120 days, and submitting them to the appropriate Operations Office;

e. implementing approved corrective actions;

f. tracking assessments and noncompliance resolutions; and

g. budgeting for assessments and corrective actions.

6.0 ASSESSMENT OBJECTIVES

The objectives of standards/requirements implementation assessments are to:

a. assess whether requirements have been appropriately characterized and corresponding actions and conditions necessary for compliance are specified in implementing documents (Phase 1 Assessments);

b. assess whether the facility and personnel are adhering to the applicable actions and conditions specified in the implementing documents (Phase 2 Assessments); and

c. document the results of assessments and the status of corrective actions using STRIDE or other suitable databases.

It is imperative to recognize that conduct of both phases of assessment is necessary for establishing the status of compliance with the requirements. In addition, S/RID approval is not a prerequisite to the initiation of assessments. Accordingly, assessment schedules shall not be based on projected approval dates, but rather scheduled to immediately follow S/RID development completion dates. The performance of the two phases shall be scheduled to ensure a timely transition from Phase I to Phase 2 and avoid undue delay. Phase 2 Assessments should be initiated upon the establishment of Phase I compliance for, a given functional area, group of tasks, or process activities, as appropriate.

7.0 PHASE I ASSESSMENTS

The purpose of the Phase 1 Assessments, sometimes called administrative assessments, is to review and evaluate implementing documents to determine whether they specify the actions and conditions necessary for adherence with each requirement contained in the S/RID. It may be desirable to perform a preliminary assessment to gain a level of confidence of the general condition of compliance prior to performing a comprehensive assessment. After a baseline state of compliance is achieved, Phase 1 assessments may be limited to new or revised requirements provided that implementing documents are subject to an adequate change control program.

7.1 Establishing the Basis for Phase I Assessments. The following factors are integral to Phase I Assessments:

a. Phase I assessments establish the link between S/RID requirements and implementing documents;

b. after the initial Phase I assessment, subsequent Phase 1 assessments are conducted for new or revised requirements incorporated into the S/RID;

c. implementing documents are subject to a change control process;

d. the context and language of source documents (e.g., DOE Rules and Orders, or other standards) are appropriately used to assess compliance with the requirements; and

e. assessors receive appropriate training on effective ways to perform and document these assessments.

7.2 Phase I Assessment Planning. Phase 1 assessment plans shall include the following:

a. identification of the site, facility, or activity to be covered by the assessment;

b. organization and responsibilities for performing the assessment;

c. qualifications and training requirements for personnel performing the assessment;

d. procedures for conducting the assessment and handling noncompliances;

e. assessment schedules; and

f. estimates of personnel and other resources required.

7.3 Conduct of Phase I Assessments. Assessment activities shall be performed by the organization responsible for implementation of the requirements in the S/RID and conducted in accordance with written procedures. A Phase I assessment will be considered to provide objective evidence of Phase I compliance when:

a. the requirement is incorporated in implementing documents by reference, quotation, or correct paraphrase, and the actions or conditions that will result in adherence with the requirement are specified;

Note 1: In some cases, the requirements in the source document are sufficiently specific and detailed to require no additional specification. In such cases, a copy of the requirement as it appears in the source document, and a written statement of organizational responsibility for implementation may be sufficient documentation to support a finding of Phase 1 compliance.

Note 2: For DOE Order 6430.1A, "General Design Criteria," and DOE Order 4700.1, "Project Management System," the existence of policies, programs, or procedures for implementing the Order constitute objective evidence of Phase 1 compliance.

Note 3: The existence of a DOE-approved implementation plan indicating that the requirement will be incorporated in implementing documents may be considered objective evidence of planned compliance as long as the terms of the implementation plan are fulfilled. However, the existence of and compliance with an Implementation Plan does not constitute compliance with the applicable requirement.

b. the implementing documents are subject to a change control process; and

c. assessment results provide traceability of the requirements to the implementing documents.

The results of previous assessments may be used to establish the compliance status for requirements in the S/RID, if (a) the assessments were performed within the past 24 months and demonstrated Phase 1 compliance with a requirement listed in the S/RID, and (b) the implementing documents have been subject to a change control process.

8.0 PHASE 2 ASSESSMENTS

The purpose of Phase 2 assessments is to provide a continuing basis for confidence that conditions and activities at a site, facility, or activity adhere to the documents that implement the requirements in the S/RID. A continuing basis for confidence is provided when properly planned and scheduled Phase 2 assessments result in evidence of adherence and do not result in frequent instances of non-adherence.

Phase 2 assessments are a continuous process accomplished over time that may use existing processes which meet the expectations of this document. Initial Phase 2 assessments should immediately follow the establishment of Phase 1 compliance for each functional area or subset of requirements within an S/RID.

8.1 Establishing the Basis for Phase 2 Assessments. The following factors are integral to Phase 2 assessments:

a. Phase 1 compliance establishes the basis for conducting Phase 2 assessments;

b. Phase 2 assessments measure the degree to which implementing documents are adhered to for the site, facility, or activity;

c. the Phase 2 assessment process is part of the ongoing self assessment process; and

d. assessors receive appropriate training on effective ways to perform and document these assessments.

8.2 Phase 2 Assessment Planning

8.2.1 General Planning Criteria. There are two types of plans required to conduct Phase 2 assessments: (1) an annual assessment plan, and (2) specific assessment plans for each assessment. Both plans shall take into account the following:

a. assessments shall be planned and carried out to maximize effective use of resources (for example, assessment activities may be grouped by tasks, process activities, functional areas, or implementing documents as appropriate);

b. high risk activities shall be assessed more frequently;

c. areas of weakness (e.g. frequent non-adherence) shall be addressed more frequently to disclose patterns and trends related to root causes; and

d. critical work processes and activities shall receive higher assessment priority.

8.2.2 Annual Phase 2 Assessment Plan. The initial Annual Phase 2 Assessment Plan is due within 60 days of completion of Phase 1 assessment, and shall be developed by DOE and contractors for each site, facility, and activity within the scope of the S/R Program. The Annual Phase 2 Assessment Plan shall identify:

a. the specific assessments to be performed,

b. assessment schedules,

c. the organizations responsible for performing the assessments, and

d. estimates of personnel and other resources required.

8.2.3 Specific Phase 2 Assessment Plans. Specific Phase 2 assessment plans shall be developed and include the following:

a. the scope of the assessment,

b. identification of the assessment team,

c. training and qualification of team members, and

d. assessment methodology including definition of assessment objectives and criteria.and the process for using "smart sampling."

8.3 Conduct of Phase 2 Assessment

The organization responsible for implementation of the requirements in the S/RID shall conduct Phase 2 assessments in accordance with written procedures. Assessment conclusions shall be based on objective evidence.

An acceptable method to develop objective evidence of adherence shall include the following:

a. interviews to demonstrate that personnel know and understand the conditions and actions specified by the implementing documents relevant to their responsibilities;

b. direct observation of the conditions and the performance of actions specified by the implementing documents; and

c. review of records that document prior interviews and direct observations establishing the nature and existence of conditions or activities.

9.0 DOCUMENTATION:

Assessment documentation shall include objective evidence and describe how assessment activities were carried out and the conclusions reached. The documentation shall correlate the conclusions to the implementing documentation. Documentation shall be sufficiently detailed to facilitate management review and analysis for trends and patterns. Documentation shall be retained in accordance with appropriate DOE records requirements.

The following items, as a minimum, shall be tracked:

a. status of Phase 1 compliance,

b. all noncompliances,

c. status of RFAs, and

d. status of corrective actions.

STRIDE or another suitable database should be used for tracking the above items.

10.0 NONCOMPLIANCE RESOLUTION

For noncompliances that present an undue risk to public health and safety, the environment, or workers and are not consistent with safe operation of a DOE facility, immediate action shall be taken to reduce the risk (i.e., compensatory measures or shutdown) with notification to the appropriate DOE officials. Should undue risks remain or the risk be justified due to mission or cost effectiveness, an exemption will need to be processed and approved by DOE prior to restart of operations.

For a noncompliance with a S/RID requirement that is drawn from an applicable Federal, state, or local law or regulation, or a DOE Rule or Order, any explicit provision in the law, regulation, Rule, or Order for the treatment of noncompliances or exemptions shall take precedence over the provisions of this Instruction. However, the provisions of this Instruction shall be implemented to the extent they are not in conflict with, nor duplicative of, the provisions of the law, regulation, Rule, or Order.

10.1 SCHEDULE FOR RESOLVING NONCOMPLIANCES

Noncompliances that do not present an undue risk should be processed as described below. For noncompliances that can be eliminated within 30 days, no specific actions are required by this Instruction. However, a record of the noncompliance should be retained on site and analyzed for patterns and trends. All other noncompliances shall be processed in accordance with the following schedule. The times specified in the schedule are.measured from the time the noncompliance is acknowledged by management.

For noncompliances that can be resolved within 120 days, notify the Operations Office Manager, if a contractor or Operations Office noncompliance, or to the Secretarial Officer, if a DOE HQ noncompliance, of the following within 30 days: (a) noncompliance description and (b) proposed corrective action.

For noncompliances that cannot be resolved within 120 days, a CSA or EX must be prepared and submitted within the 120-day period to the appropriate RFA approval authority in accordance with Appendix A. Within 180 days (60 days from DOE receipt), the approval authority shall approve/disapprove the CSA or EX.

Table I below summarizes the noncompliance resolution process.

Table 1: Noncompliance Resolution Process

Noncompliances that have been identified during the DP Order Compliance Self-Assessment program, and the EM Phase 1 programs prior to the effective date of this Instruction shall be subject to the schedule requirements stated above, except that the starting date for the schedule shall be the effective date of this Instruction.

10.2 ELIMINATION OF NONCOMPLIANCES

A noncompliance can be eliminated by either implementing appropriate corrective actions or by obtaining an exemption from DOE. When an exemption is granted, the applicable S/RID shall be modified accordingly.

Implementation assessments for EM facilities/activities are based entirely on DOE approved S/RIDs. Accordingly, the exemption alternative for resolution of a noncompliance is neither appropriate nor authorized.

When corrective actions described in a CSA (whether approved or not) are completed and compliance is achieved, the organization that submitted the CSA shall submit a written closure statement to the Operations Office, if a contractor, or to an Operations Office or the Secretarial Officer, if a DOE HQ organization. The closure statement shall state that corrective actions have been completed and compliance has been achieved, and describe any substantive changes from the information provided in the CSA.

Closure statements shall be in the form of a letter or memorandum signed by the highest level of management required to sign and submit the related CSA. Compliance status shall be updated upon closure statement submittal.

11.0 QUALITY ASSURANCE

Implementation of the S/R Program by DOE and contractor personnel will comply with the applicable DOE Quality Assurance requirements, particularly training and qualification of involved personnel. This will ensure that properly qualified and trained personnel are used in assessing S/RID requirements and handling noncompliances.

APPENDIX A

PREPARATION AND.PROCESSING OF REQUESTS FOR DOE APPROVAL

1.0 PURPOSE

This Appendix establishes the information requirements for preparing the two types of Requests for DOE Approval (RFAs): Compliance Schedule Approvals (CSAs) and Exemptions (EXs); and describes the process for submitting, reviewing, approving, and revising RFAs.

2.0 SCOPE

This Appendix is applicable to RFAs submitted by DOE HQ offices, Operations Offices and contractors.

3.0 PREPARATION OF REQUESTS FOR DOE APPROVAL (RFAs)

RFAs shall be prepared to contain, as appropriate, the general and technical information described in Sections 3.1 and 3.2 below. Each request shall have the following characteristics:

a. Each RFA shall be clear, concise, and complete.

b. RFAs and/or revisions shall contain all necessary information, and not rely for content on references to prior RFAs.

c. Acronyms shall be spelled out when first used since reviewers may not be familiar with local terminology or operations. The use of unfamiliar acronyms should be minimized.

An RFA may cover more than one noncompliance. For administrative convenience, CSAs should not include noncompliances with widely separated dates for completion of corrective actions.

Before processing any RFA (draft or otherwise), ensure that:

a. If it contains or concerns classified information or potentially classified information, it it reviewed by an Authorized Classifier in accordance with DOE Order 5650.2B, "Classification of Information;" or

b. If it potentially contains Unclassified Controlled Nuclear Information, it is reviewed by a Reviewing Official in accordance with DOE Order 5650.3A, "Identification of Unclassified Controlled Nuclear Information."

3.1 General Information

The following identifying information shall be provided in the RFA:

a. Organization preparing RFA - e.g., Allied Signal, Pinellas Area Office, etc.

b. Type of RFA - spelled out as, Compliance Schedule Approval Request or Exemption Request.

c. Date of RFA submission.

d. Request Number (e.g., RFP-XXX-CSA-10) - assigned by the responsible individual for each organization using the STRIDE database shall be as follows:

RFP Organization code from the list published by DOE HQ,

XXX Code identifying the S/RID (if the RFA results from a DOE Order compliance self-assessment conducted before completion of the S/RID, the DOE Order number should be used in place of the S/RID code),

CSA Type of request (CSA or EX),

10 Sequential number for that type of request by the organization (this is the tenth CSA submitted by RFP). RFA revisions are indicated by alphabetical series, e.g., 10A, 10B, etc.

Acronyms shall be spelled out when first used since reviewers may not be familiar with local terminology or operations. The use of unfamiliar acronyms should be minimized.

3.2 Technical Information

The level of detail and rigor in the technical information should be commensurate with the nature of the noncompliance(s) to the health and safety of the worker, the public, and the environment. Relatively minor issues should result in relatively simple RFAs.

Technical information must be presented in the sequence and under the headings used below. In many cases, one or more headings will not apply to a specific noncompliance. In these cases, enter "Not Applicable" or "None." For a RFA that covers more than one noncompliance, appropriate information must be provided for each noncompliance.

REQUIREMENT

Provide a specific reference to the S/RID (or DOE Order if the RFA results from a DOE Order compliance self-assessment conducted prior to completion of the S/RID); in addition, the requirement must be quoted or paraphrased.

NONCOMPLIANCE

Describe the noncompliance in the context of the requirement. If partial compliance exists, put into perspective the portion of the requirement for which compliance exists and the portion for which noncompliance exists. Also identify the major systems or activities affected.

RISK

Describe the risk to the health and safety of the worker, the public, or the environment that is created by the noncompliance. Take into account any pre-existing actions or conditions that mitigate the effects of the noncompliance.

COMPENSATORY MEASURES

If compensatory measures are necessary as an interim measure until the required corrective action is completed, describe the compensatory measures and either state whether the compensatory measures have been fully implemented or include the schedule for their implementation.

CORRECTIVE ACTIONS (Applicable to CSAs only)

1. Description of Corrective Actions. Summarize the actions proposed to achieve compliance.

2. Schedule for Corrective Actions. For each corrective action, provide in tabular form: a brief description of the corrective action milestones; the person or specific organization responsible for each milestone, and the estimated start and completion dates for each milestone. The milestones should be described in terms that define the end result (i.e., "New procedure issued and personnel training completed").

Clearly identify any corrective actions that will not be initiated until after DOE approval of the CSA.

If the action is not funded, these dates may be shown as duration milestones (for example, the action will begin "Six months after receipt of funding," or will be completed "Within three months of receipt of funding").

If applicable, describe sequential relationships that define the critical path and identify potential obstacles, such as conflicting priorities.

JUSTIFICATION FOR APPROVAL

Explain, with reference to specific activities, why it's acceptable to remain in noncompliance during the period proposed by the RFA. Describe the nature and results of any tests or analyses used to support these conclusions. If appropriate, discuss how plant conditions or compensatory measures contribute to this conclusion. The justification for approval may refer to any type of net benefit arising from the approval, including avoidance or reduction of costs and impact to workers and the public, improved operational efficiency, etc. Other factors associated with approval or disapproval also should be discussed.

For exemptions, describe how the following criteria for seeking an exemption are met:

(a) Would be authorized by law;

(b) Would not present an undue risk to the public health and safety, the environment, or facility workers;

(c) Would be consistent with the safe operation of a DOE nuclear facility;

(d) Involves special circumstances, including the following:

(1) Application of the requirement in the particular circumstances conflicts with other requirements; or

(2) Application of the requirement in the particular circumstances would not serve or is not necessary to achieve its underlying purpose, or would result in resource impacts which are not justified by the safety improvements; or

(3) Application of the requirement would result in a situation significantly different than that contemplated when the requirement was adopted, or that is significantly different from that encountered by others similarly situated; or

(4) The exemption would result in benefit to human health and safety that compensates for any detriment that may result from the grant of the exemption; or

(5) Circumstances exist which would justify temporary relief from application of the requirement while taking good faith action to achieve compliance; or,

(6) There is present any other material circumstance not considered when the requirement was adopted for which it would be in the public interest to grant an exemption.

RESOURCE IMPACTS

Describe any resources and funding required to implement the actions described in the RFA. The description should separate personnel and other costs.

If corrective actions are to be completed by reallocating amounts already funded, describe what other scheduled activities will not be completed because of the reallocation.

If corrective actions cannot be completed within amounts already funded, describe supplemental funding needed and plans for obtaining the funding. If budget requests have not already been made, so state and indicate the timing for requesting additional funds.

LIST OF ATTACHMENTS

If applicable, list all documents attached to the RFA. If excerpts are attached, they must identify the source document and provide sufficient content to perform a review.

4.0 SUBMISSION OF RFAs

RFAs submitted to DOE for approval shall be signed by a manager at an ,appropriate level within the submitting organization, who is accountable for schedules. Each organization shall monitor the status of its RFA submittals, including comments received, approvals granted, and corrective actions completed, including the appropriate dates.

5.0 CHANGES TO RFAs

Any required change to a RFA must be submitted in writing as soon as possible to the appropriate DOE office for approval. Revisions to RFAs shall follow the provisions provided in Section 4.0. The letter or memorandum transmitting the revision shall provide a brief statement of the reason for the revision.

In the case of changes to a single element of information (e.g., a date), the proposed revision may be submitted in the form of a letter or memorandum in lieu of the revised RFA. The letter or memorandum proposing the revision must include the following information:

a. Originating organization and original request number,

b. Justification for the change,

c. The proposed change, and

d. Signature approvals from the responsible managers.

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