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 68 over the Tour course for an eight-under 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 Argentinian front-runner Tano Goya.
The weather in north-east Spain is set 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 everything plays that bit longer," said Orr.
George Murray, who also lost his card this year, had a 70 for a 207 to share 17th on 207, while Callum Macaulay bolstered his challenge with a 66 that was aided by an eagle-two 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 card-winning top 25 on 210 after a 68, but Scott Drummond – the former PGA champion – is battling to make the 72-hole cut on 214, while Andrew McArthur (218), Raymond Russell (220) and Wallace Booth (221), will need to conjure something spectacular to qualify for the closing two rounds.