The 45-year-old from Helensburgh, who dropped off the main tour at the end of this season having finished down in 159th on the money list, stayed on track for a swift return with a two-under-par 68 over the Tour course for an eight-under total of 204.
Orr, aiming for one of the 25 tour cards on offer, shares eighth place at the halfway stage of the six-round shoot-out, five shots behind the Argentinian frontrunner Tano Goya, boyfriend of Carly Booth, the young Scot who made her presence felt on the Ladies European Tour.
The weather in north-east Spain is expected to deteriorate over the next couple of days and, while Orr is not overjoyed at that prospect, the Scot is more than content with the steady progress he is making so far.
"I am happy enough with my game, but the weather is to change and, when it's cold and wet, you just have to battle away as well as you can as everything plays that bit longer," said Orr, who had six birdies but was hindered by four bogeys. "It was a decent-enough score but I could've done with cutting out a few of the bogeys. It was just a couple of daft mistakes. I'm in decent shape, though, and hopefully it's a case of more of the same over the next couple of days."
George Murray, who also lost his card this year, had a 70 to share 17th spot on 207 while Callum Macaulay bolstered his challenge with a 66 that was aided by an eagle 2 on the 13th. The former Scottish Amateur champion finished in a tie for 26th on 208 alongside Alastair Forsyth, who added a 68 to his tally.
Jamie McLeary remains in sight of the top 25 on 210 after a 68 but Scott Drummond, the former PGA champion, is battling to make the cut on 214 while Andrew McArthur (218), Raymond Russell (220) and Wallace Booth (221) will need to conjure something special to qualify for the closing two rounds.