Chapter 15
OCCURRENCE REPORTING

Contents

Approved by Andrew Peterson
Revised 10/12


NOTE:
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15.1 Policy

Lawrence Berkeley National Laboratory (Berkeley Lab) strives to prevent all injuries and illnesses; environmental damage; significant business, facility, and community disruptions; and regulatory noncompliance. If these types of occurrences happen, Berkeley Lab will act as needed to identify causes, implement corrective actions to prevent recurrence, and share Lessons Learned.

As part of this process, Berkeley Lab will determine if any occurrences must be reported to the Department of Energy (DOE) per DOE O 232.2, Occurrence Reporting and Processing of Operations Information,and if so, will follow DOE reporting requirements.

15.2 Scope

Chapter 15 documents Berkeley Lab’s program for compliance with DOE O 232.2. The scope of this chapter is limited to occurrences meeting any criteria in DOE O 232.2.

Appendix A provides definitions used in this chapter, including:

15.3 Applicability

All Berkeley Lab divisions and departments, including affiliates and subcontractors performing work for the Laboratory, are subject to the requirements of this chapter. Work covered under a Memorandum of Understanding involving DOE and Berkeley Lab, such as that governing work in some areas of the University of California at Berkeley campus, may be excluded from the requirements of this chapter. 

15.4 Roles and Responsibilities

15.4.1 Employees, Affiliates, and Subcontractors

Employees, affiliates, and subcontractors must report unsafe or abnormal events and conditions (hereafter referred to as “occurrences”) in a timely manner, according to Berkeley Lab policy and the applicable division’s policies and procedures.

Occurrences that cannot be adequately managed internally following existing Laboratory policies and procedures (e.g., the Berkeley Lab Emergency Response Guide) must be reported.

15.4.2 Supervisors and Work Leads

Supervisors and work leads should ensure that employees understand workplace health and safety reporting responsibilities. When a supervisor or work lead learns of an occurrence, he or she must ensure appropriate authorities are notified, including the division safety coordinator and the Environment, Health & Safety (EHSS) Division.

15.4.3 Division Directors

Division directors are ultimately responsible for meeting the requirements of DOE O 232.2 – including categorization, notification, investigation, and reporting – for occurrences at their facilities or operations. They must provide appropriate resources to report events in a timely manner, investigate causes, and institute corrective actions to prevent recurrence.

Where occurrence categorization is not clear, or for management concerns and issues, the division director must decide or agree that the occurrence is DOE reportable. EHSS can assist with this determination. Division directors must approve Final Reports before EHSS submits them to DOE.

Note: A division director is sometimes referred to as a facility manager for purposes of the DOE Occurrence Reporting Program.

15.4.4 Division Designees

Division directors may assign designees from their organizations to help implement these procedures. Division designees assist line managers and staff in meeting occurrence-reporting requirements, including communicating with EHSS to ensure proper DOE notifications are completed. Division designees must be familiar with the procedures described in this chapter.

Appropriate candidates for division designees include deputy division directors, division safety managers, or division safety coordinators. These individuals may be listed as points of contact for DOE-reportable occurrences within divisions (see http://www.lbl.gov/ehs/orps/pdf/divisionORPS.pdf for a list of points of contact).

If no division designee is chosen, the division director is responsible for implementing these procedures.

15.4.5 Environment, Health, Safety, and Security (EHSS) Division

EHSS oversees the occurrence-reporting process to ensure it is properly managed. EHSS assists divisions as needed to respond to, mitigate, categorize, and investigate occurrences, and to support division directors and their designees with DOE occurrence reporting. EHSS completes the required DOE notifications and submits the required DOE reports into the online DOE Occurrence Reporting database.

For events that are ORPS Significance Category 2 and 3 Reportable, EHSS will complete a quality-assurance review of the causal analysis, including the corrective actions, as part of the occurrence-reporting process.

Any EHSS staff member who learns of an occurrence must report this to the appropriate person within the EHSS Division.

Note: Divisions should notify EHSS of an occurrence as soon as possible to get guidance through the occurrence-reporting process.

15.4.6 Office of Contractor Assurance

The Office of Contractor Assurance (OCA) provides oversight for the Issues Management Program; maintains the Corrective Action Tracking System (CATS); and reviews Root Cause Analysis reports, Extent of Condition Review reports, Corrective Action Plans (CAPs), and Effectiveness Review Reports for high-risk issues prior to issuance and approval. OCA also oversees the Causal Analysis Program. The products of these programs are used, when applicable, in the preparation of Final Reports.

15.5 Process Overview

The flowchart below gives a general overview of the DOE occurrence-reporting process. Detailed explanations of each process step are provided in Section 15.6, Required Work Processes. Additional information is available at the EHSS Occurrence Reporting Web site.

Berkeley Lab Occurrence Reporting Process Flow

15.6 Required Work Processes

Work Process A. Discovery, Reporting, and Preliminary Review

Occurrences — both actual and near-miss events — are discovered in a variety of ways, such as observations by workers, notifications from external agencies, internal assessments, etc. A worker must promptly report unsafe or abnormal events and conditions according to division policies and procedures. Occurrences that cannot be adequately managed within the division following existing Laboratory policies and procedures (e.g., following the Berkeley Lab Emergency Response Guide) must be reported, either directly or indirectly, to the EHSS Division.

If a division has no internal reporting policies or procedures, a worker must report occurrences to the appropriate supervisor/work lead and division safety coordinator. Supervisors/work leads report the occurrence to the EHSS Division or to the division’s safety coordinator, who reports occurrences to EHSS.

A worker at any level and at any time may directly report an occurrence to the EHSS Division. When EHSS receives a report, it contacts appropriate personnel within a division to ensure each occurrence is reviewed for DOE reportability.

Regardless of how an occurrence is reported to EHSS, it must be reviewed to determine if it meets a DOE reporting criterion. Divisions may work collaboratively with EHSS to make this determination (as described in Work Process B), or they can make an initial assessment of reportability. In the latter case, EHSS will either validate this assessment or discuss the assessment with the division until consensus is reached.

Work Process B. Categorization

To categorize an occurrence, compare it against the criteria established in DOE O 232.2 (documented in Appendix B). If the occurrence meets any of the criteria, it is reportable to DOE.

DOE criteria are primarily thresholds organized in one of 10 groups (and possibly a subgroup). Significance categories associated with the criteria determine notification, analysis, and reporting requirements (see Appendix C). In most cases, the significance category is pre-assigned by DOE to the specific criterion.

Most DOE criteria are triggered by exceeding a specific threshold documented in a criterion that has a set significance category, making categorization straightforward. Group 10, Management Concerns and Issues, is more subjective, particularly Criterion 2 for Management Concern, which historically accounts for approximately 30% of Berkeley Lab’s reportable occurrences. In addition, Group 10, Criterion 2 (Management Concern) and Group 10, Criterion 3 (Near Misses) do not have pre-assigned significance categories.

In instances where the criterion is questionable or the significance category is variable, division directors or their designees must make the final decision on categorization, although EHSS may provide input into the decision-making process. EHSS staff — which has knowledge of hazards, awareness of DOE criterion thresholds, and response roles — may initially categorize occurrences in the absence of division directors or designees, and later confirm the categorization with division management.

If an occurrence meets more than one reporting criterion, the criterion with the highest significance category determines the notification, analysis, and reporting requirements. As new information becomes available, the occurrence must be re-evaluated and the occurrence criterion and significance category changed if needed.

If the event or condition is not reportable to DOE, it is considered a “site-reportable” event or condition and will be recorded as appropriate by EHSS for tracking and trending purposes.
Given the subjective nature of some occurrences, EHSS should be contacted to assist with categorization.

Categorization Time Frame

DOE has established time frames for categorization.

Work Process C. Notification

After an occurrence has been discovered, found to be DOE reportable, and properly categorized, the EHSS Division must notify DOE. For this to happen, divisions must provide EHSS with preliminary details of the occurrence.

Prompt Notification

The first notification to DOE, providing initial details on the occurrence, is called Prompt Notification, and can be completed by a phone call and/or e-mail to the DOE Berkeley Site Office (BSO). This notification includes a brief summary of the occurrence and the reporting group, subgroup (when applicable), criterion number, and significance category.

Prompt Notification must be completed within the following time frames:

Occurrences meeting specific DOE criteria (noted by the Appendix B criteria marked with an asterisk) must also be reported to DOE Headquarters Operations Center (HQ OC) via e-mail, and receipt must be confirmed. For occurrences that require Prompt Notification of DOE HQ OC, the following details must also be included:

If the occurrence is re-categorized based on new or changing information, it must be reconsidered for Prompt Notification and, as appropriate, the same Prompt Notification process must be followed.
Follow-up notification is required if there is further degradation in the level of safety or impact on the environment, health, or operations of the facility, or other worsening conditions subsequent to the initial notification.

Notification Report

Following initial Prompt Notification, EHSS must submit a written report (the Notification Report) into the online DOE Occurrence Reporting database. The Notification Report contains all relevant detail known at the time and must be submitted within the timeline provide in Appendix C or as soon as reasonably possible.

Work Process D. Occurrence Investigation and Causal Analysis

DOE-reportable occurrences require some degree of investigation and analysis to ensure the cause is understood so that effective corrective actions can be identified and implemented. Guidance and training requirements for conducting causal analysis is provided in PUB-5519(1), Issues Management Program Manual; and PUB-5519(2), Causal Analysis Program Manual.

The rigor and scope of the investigation and analysis are based on the significance category of the event, as summarized in Appendix C (for which PUB-5519 is the “locally approved procedure”). Certain events may result in a federal Accident Investigation Board review. Berkeley Lab is not required to conduct an identical investigation under this circumstance.

All causes, once identified, are classified by specific cause codes described in the DOE O 232.2 Causal Analysis Tree (provided as a link in Appendix D). EHSS, with the assistance of the affected division, determines the appropriate cause codes.

Work Process E. Corrective Actions and Lessons Learned

After a causal analysis is completed, corrective actions to prevent recurrence must be identified. Requirements for developing and managing corrective actions are documented in PUB-5519(1), Issues Management Program Manual;andPUB-5519(2), Causal Analysis Program Manual.

The Berkeley Lab Corrective Action Tracking System (CATS) must be used to document and track corrective actions identified for each DOE-reportable occurrence in accordance with OIA-OCA-0001, CATS Database User Manual. With the exception of Significance Category 4 occurrences, corrective actions must also be entered into the DOE Occurrence Reporting database, with reference to the respective CATS identification numbers.

Divisions must ensure all Significance Category 1 and R Corrective Action Plans (CAPs) are reviewed by the Office of Contractor Assurance (OCA) before final submission, which includes CAPs documented via ORPS and/or Price Anderson Amendment Act Non-compliance Tracking System (PAAA-NTS) Reports. EHSS will review all Significance Category 2 and 3 corrective actions before final submission. In addition, any text changes to corrective actions in CATS must be transmitted to EHSS for updating in the DOE Occurrence Reporting database and for possible review and approval by BSO.

Lessons Learned must be considered in accordance with PUB-5519(4), Lessons Learned and Best Practices Program Manual. Any lessons learned that result from the event must be entered into the Lessons Learned field of the DOE Occurrence Reporting database.

Depending on the significance category, Berkeley Lab or BSO may conduct independent verification, sampling, and effectiveness evaluation of the corrective actions.

Work Process F. Final and Update Reports

A written Final Report is required for all Operational Emergencies and Significance Category 1, 2, 3, and R occurrences. The Final Report is due 45 calendar days from the date of occurrence categorization (for Significance Category 4, the Notification Report is the Final Report). The Final Report must contain the following:

Additional information may be included in the Final Report as appropriate. Examples include:

If the Final Report will not be completed within 45 days, divisions must communicate this to EHSS, which will request a DOE extension in an Update Report filed within the original 45 days. The Update Report must include a detailed explanation of the delay in the Facility Manager’s Evaluation field and provide an estimated completion date.

Update Reports are also required in other circumstances:

The Update Report eventually becomes the Final Report when all pertinent information on the investigation and analysis — including significance, nature, and extent of the occurrence; causes; corrective actions; and lessons learned — is entered into the DOE Occurrence Reporting database and required approvals have been obtained as described below.

Report Approval

Regardless of the significance category of the occurrence, the responsible division director must approve the Final Report (which includes an OCA quality-assurance [QA] review of the Corrective Action Plan for Significance Category 1 or R events) prior to submission to external organizations such as BSO or DOE HQ. Additional DOE approval is required for Operational Emergency Significance Category 1, 2, and R occurrence reports, as documented in Appendix C.

Report Closure

For Operational Emergency and Significance Category 1, 2, and R Final Reports, BSO must review, approve or reject, and add any comments within 14 calendar days of receipt of the report. If approved by BSO, Operational Emergency and Significance Category 1 Final Reports must be submitted to the DOE HQ Program Office, which has 14 days to review, approve or reject, and add comments.

If the Final Report is not approved by BSO or DOE HQ, the DOE employee who rejected the report must provide the reason for disapproval in the report’s DOE comment section. The Berkeley Lab division, with assistance from EHSS, must prepare a revised Final Report and resubmit it to BSO within 21 calendar days of the disapproval. If the revised Final Report cannot be resubmitted within this time, an Update Report must be submitted within 21 calendar days, explaining the delay and estimating a resubmission date. This information must be reported in the Field Manager’s Evaluation field of the DOE Occurrence Reporting database.

Work Process G. Performance Trends and Recurring Occurrences

Berkeley Lab periodically reviews reportable and non-DOE reportable (also known as site-reportable) occurrences and events to look for trends, determine if events are recurring, determine if recurring events meet the criteria for ORPS or PAAA-NTS reporting, and evaluate mitigation strategies. Formal reviews are performed quarterly and include data from the previous 12 months at a minimum.

EHSS analyzes non-DOE reportable events to identify trends. EHSS uses the following data sources in this analysis:

  1. Safety Concerns/Suggestion Log
  2. Operations Incident Log
  3. DBO2 Database
  4. CATS Database
  5. Injury and Illness Database (CAIRS)
  6. Lessons Learned/Best Practices Database
  7. Laboratory-wide One Call (beginning second quarter, FY 2013)

Input into these databases happens through various mechanisms as briefly summarized below:

  1. Safety Concerns/Suggestion Log: Employees are able to submit both safety concerns and safety suggestions to EHSS through the online database.Submissions are entered into a running log of issues, assigned to appropriate EHSS personnel, and tracked.
  2. Operations Incident Log: Facilities personnel enter events and conditions that have been reviewed but do not meet DOE reporting criteria. EHSS SMEs may also enter events and conditions into this log. 
  3. DBO2 Database: Facilities and EHSS personnel conduct construction site and shop walk-throughs, observe behaviors, and enter observations into the DBO2 database.
  4. CATS Database: Employees can enter findings, issues, and associated corrective actions in the CATS Database.
  5. Injury and Illness Database (CAIRS): EHSS enters first aid and OSHA-recordable injuries and illnesses into the Injury and Illness Database (CAIRS). 
  6. Lessons Learned/Best Practices Database: Employees can enter Lessons Learned from specific events and conditions into the database to share information 
  7. Laboratory-wide One Call: Beginning second quarter, FY 2013, calls to ext. 6999 (Laboratory-wide One Call) will be logged by the dispatcher. 

This analysis may also include data from other sources, including issues discovered during assurance assessments (both independent assessment and program self-assessments) and division self-assessments; data collected informally, such as feedback from subject matter experts, division safety coordinators, and Associate Lab Director (ALD) liaisons; and issues identified during stand-downs. An ongoing effort will be made to standardize the trending code of events so that EHSS can effectively trend across multiple data sources. A quarterly report will be generated by EHSS and submitted to the Office of Contractor Assurance (OCA).
OCA analyzes DOE-reported events (i.e., ORPS and PAAA-NTS) to determine if recurring issues exist. Any issue that warrants reporting in ORPS and/or NTS as determined by an EHSS analysis of lower-level events is included in an OCA analysis to determine if a recurring issue exists (refer to PUB-5519[3], Data Monitoring and Analysis Program Manual). Results of this analysis are documented in a written report and provided to BSO and line management.

Recurring Occurrences

Trends will be reviewed to determine if they meet the criteria of ORPS and PAAA-NTS reporting. If so, the trend will be reported as a recurring occurrence (Significance Category R) if deemed appropriate to resolve the trend.  In this case, previous individual occurrence report numbers associated with the recurring issue (if applicable) will be provided in the “similar occurrence report numbers” field. The new occurrence report must  meet all reporting and processing requirements for Significance Category R.

Occurrences meeting NTS requirements will be managed per institutional policy for PAAA-NTS issues.

Work Process H. Training

As part of their Berkeley Lab orientation, employees, supervisors, affiliates, and subcontractors receive basic instructions for reporting unsafe conditions and abnormal events. Division directors and deputy directors receive a brief orientation to the DOE Occurrence Reporting process (via EHS 804). Division designees and others likely to be involved in the occurrence-reporting process will receive more detailed training (via EHS 802).

Appendix A. Definitions

1. APPARENT CAUSE. The most probable cause(s) that explains why the event happened, that can reasonably be identified, that local or facility management has the control to fix, and for which effective recommendations for corrective action can be generated, if necessary

2. BUSINESS DAY. The normal administrative day of the reporting organization (e.g., Monday through Friday, 0800 to 1700 local time) during which normal work activities are conducted. It is not meant to encompass the 24 hours in a day, even if the facility is operated or maintained on a 24-hour basis.

3. CONDITION. Any as-found state, whether or not resulting from an event, that may have adverse safety, health, quality-assurance, operational, or environmental implications. A condition is usually programmatic in nature. The following are examples of conditions: errors in analysis or calculation, anomalies associated with design or performance, or items indicating a weakness in the management process.

4. DEFECTIVE ITEM. Any item or material that does not meet the commercial standard or procurement requirements as defined by catalogs, proposals, procurement specifications, design specifications, testing requirements, contracts, or the like. This does not include parts or services found to be inadequate because of random failures or errors within the accepted reliability level.

5. DISCHARGE. Includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil, but excludes discharges in compliance with a permit under Chapter 402 of the Clean Water Act (CWA); discharges resulting from circumstances identified and reviewed and made a part of the public record with respect to a permit issued or modified under Chapter 402 of the CWA and subject to a condition in such permit; or continuous or anticipated intermittent discharges from a point source, identified in a permit or permit application under Chapter 402 of the CWA, that are caused by events occurring within the scope of relevant operating or treatment systems

6. DISCOVERY DATE AND TIME. The point at which facility staff discovered or became aware of the event or condition. Discovery date is NOT the date and time the event or condition is determined to be reportable. Facility staff are those personnel assigned to the facility and cognizant of the area in which the event or condition is identified.

7. ELECRICALLY SAFE WORK CONDITION. A state in which the conductor or circuit part to be worked on or near has been disconnected from energized parts; locked/tagged in accordance with established standards; tested to ensure the absence of voltage; and grounded, if determined necessary

8. EQUIVALENT DOSE

  1. Committed Effective Dose (E50). Refer to 10 CFR 835.2 or to DOE O 458.1 Chg 2, Radiation Protection of the Public and the Environment, dated 6-6-11, Attachment 2 (Definitions)
  2. Committed Equivalent Dose (HT,50). Refer to 10 CFR 835.2 or to DOE O 458.1 Chg 2, Radiation Protection of the Public and the Environment, dated 6-6-11, Attachment 2 (Definitions)
  3. Effective Dose (E). Refer to 10 CFR 835.2 or to DOE O 458.1 Chg 2, Radiation Protection of the Public and the Environment, dated 6-6-11, Attachment 2 (Definitions)
  4. Total Effective Dose (TED). Refer to 10 CFR 835.2 or to DOE O 458.1 Chg 2, Radiation Protection of the Public and the Environment, dated 6-6-11, Attachment 2 (Definitions)

9. EVENT. A significant incident that takes place in real time (e.g., pipe break, valve failure, loss of power, environmental spill, earthquake, tornado, flood, injury)

10. FACILITY. Any equipment, structure, system, process, or activity that fulfills a specific purpose. Examples include accelerators, storage areas, fusion research devices, nuclear reactors, production or processing plants, coal-conversion plants, magnetohydrodynamic experiments, windmills, radioactive waste-disposal systems and burial grounds, environmental-restoration activities, testing laboratories, research laboratories, transportation activities, and accommodations for analytical examinations of irradiated and un-irradiated components.

11. FACILITY MANAGER. Division director

12. FACILITY REPRESENTATIVE. Berkeley Site Office

13. HAZARDOUUS ELECTRICAL ENERGY EXPOSURE. Within the limited approach boundary (LAB) of an energized part not suitably guarded, isolated, or insulated. This includes de-energized parts for which a safe work condition has not been established, e.g., lockout/tagout.

14. HAZARDOUS SUBSTANCE OR MATERIAL

  1. Department of Energy - Hazardous Material. Any solid, liquid, or gaseous material that is chemically toxic, flammable, radioactive, or unstable upon prolonged storage and that exists in quantities that could pose a threat to life, property, or the environment
  2. Department of Transportation - Hazardous Materials (see 49 CFR 171.8 and 172.101). A substance or material, including a hazardous substance, that has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce and that has been so designated
  3. Comprehensive Environmental Response, Compensation, and Liability Act Hazardous Substances (see 40 CFR Part 302)
  4. Occupational Safety and Health Administration (OSHA) Hazardous Chemical (see 29 CFR 1910.1000 and 29 CFR 1910.1200). Any chemical that is a physical or health hazard
  5. Superfund Amendments and Reauthorization Act Title 3, Extremely Hazardous Substances (see 40 CFR 355). These are not defined but appear on lists in Appendix A and Appendix B of 40 CFR 355.

15. IN-PATIENT HOSPITALIZATION. Admission to a hospital requiring at least one overnight stay. This would include admission for purposes of observation only.

16. ITEM

  1. An all-inclusive term used to denote the following: appurtenance, sample, assembly, component, equipment, material, module, part, structure, subassembly, subsystem, system, unit, support systems, documented concepts, or data
  2. When used in reference to nuclear material, a visible, single piece or container of nuclear material with a unique identification and known nuclear material mass

17. LESSONS LEARNED. A good work practice or innovative approach that is identified and shared, or an adverse work practice or experience that is captured and shared to prevent recurrence

18. NONREPORTABLE EVENT. An event that falls within the Occurrence Reporting and Processing System (ORPS) Reporting Groups, does not meet any of the specific ORPS Reporting Criteria, and that the reporting organization has determined to include in the required ORPS Performance Analysis activity

19. NOTIFICATION REPORT. The initial documented report to DOE of an event or condition that meets the reporting criteria defined in DOE O 232.2

20. NUCLEAR FACILITY. A reactor or nonreactor nuclear facility in which an activity is conducted for or on behalf of DOE and that includes any related area, structure, facility, or activity to the extent necessary to ensure proper implementation of the requirements of 10 CFR 830

21. OCCURRENCE. One or more events or conditions that adversely affect, or may adversely affect, DOE (including the National Nuclear Safety Administration [NNSA]) or contractor personnel, the public, property, the environment, or the DOE mission. Occurrences are events or conditions meeting the criteria thresholds identified in DOE O 232.2 or determined to be recurring through performance analysis.

22. OCCURRENCE INVESTIGATION. An investigation conducted according to site-specific procedures and/or when determined by DOE procedures that an investigation by a federal Accident Investigation Board is required

23. OCCURRENCE REPORT. A documented evaluation of a reportable occurrence that is prepared in sufficient detail to enable the reader to assess its significance, consequences, or implications and to evaluate the actions being proposed or employed to correct the condition or to avoid recurrence

24. OFF SITE. Property or location that is not DOE/NNSA or DOE/NNSA contractor owned, leased, or directly controlled

25. OFF-SITE TRANSPORTATION EVENT. Involves movement of materials considered to be in commerce, thus requiring compliance with Department of Transportation Hazardous Materials Regulations (49 CFR Sections 171 – 180)

Transportation events with injuries or fatalities may also require reporting in accordance with Group 2 criteria.

26. OIL. Oil of any kind or in any form, including but not limited to petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil

27. ON SITE. Property or location that is DOE/NNSA or DOE/NNSA contractor owned, leased, or directly controlled

28. ON-SITE TRANSFER EVENT. Involves movement of material not in commerce and subject to regulations in 10 CFR Section 830 or DOE on-site procedures and safety requirements. On-site transfer events with injuries or fatalities may also require reporting in accordance with Group 2 criteria.

29. OPERATIONS. The act, process, or method of operating. This can apply to facilities regardless of mode (shutdown, standby, operational) or state (construction, operational, deactivated, decommissioning).

30. PACKAGING AND TRANSPORTATION. Packaging and Transportation activities/functions include: (1) Packaging - activities related to the design, manufacture, and qualification of packaging represented as qualified for use in the transportation of hazardous materials; (2) pre-transportation functions; (3) transportation functions - movement of hazardous materials and loading, unloading, and storage incidental to the movement; and (4) shipping in accordance with applicable international, federal, state, local, and tribal laws, rules, and regulations governing materials transportation that are consistent with federal regulations (e.g., 10 CFR and 49 CFR) and DOE Packaging and Transportation Directives (e.g., DOE Order 460.1C, DOE Order 460.2A, DOE Manual 460.2-1A, DOE Order 461.1B, and 10 CFR Section 830, Nuclear Safety Management)

31. PERFORMANCE DEGRADATION. Failure or degradation of a facility, process, system, or component that reduces the reliability of critical components of the facility and prevents the system from performing its intended function. Performance degradation does not include: (1) a burned-out power indicator light on a piece of radiation-monitoring equipment that does not prevent the equipment from detecting elevated radiation levels and alarming as designed; (2) a piece of equipment determined to be out of calibration on the conservative side (such as a low-level alarm that is triggered at a higher value than it should); or (3) the temporary loss of a component where redundant components are maintained operable or in operation and the authorization basis is not compromised.

32. PERSONNEL EXPOSURE. An incident of contact or encounter with a hazardous chemical or radiological, physical, biological, or energetic agent at one of the exchange boundaries of the organism (e.g., skin, respiratory system, eyes, ears, or digestive system). Exposure does not refer to a situation where personnel, protected by appropriate personal protective equipment, are subjected to an environment whose ambient conditions present a harmful level of any one, or combination of, the hazards.

33. POLLUTANT. Any material requiring a permit for release into the environment

34. PRE-TRANSPORTATION FUNCTION. A function specified in the Hazardous Materials Regulations (HMR) that is required to assure the safe transportation of a hazardous material in commerce, including: materials classification, packaging, marking, labeling, shipping paper preparation, loading, blocking, bracing, segregating, securing, and placarding (49 CFR 171.8)

35. PRIMARY CONFINEMENT. Provides confinement of hazardous material to the vicinity of its processing. This confinement is typically provided by piping, tanks, glove boxes, encapsulating material, and the like, along with any off-gas systems that control effluent from within the primary confinement.

36. PROGRAM MANAGER. Berkeley Site Office or DOE representative

37. PROMPT NOTIFICATION. Timely reporting of the occurrence to the DOE Field Office and the DOE Headquarters Operations Center, as required by the significance category and the reporting criteria of the occurrence

38. RELEASE. Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or otherwise disposing of substances into the environment. This includes abandoning/discarding any type of receptacle containing substances in an unenclosed containment structure, but does not include permitted containment structures.

39. REPORTABLE OCCURRENCE. Occurrence to be reported in accordance with the criteria defined in DOE O 232.2.

40. ROOT CAUSE. The causal factor that, if corrected, would prevent recurrence of the occurrence. It is the most basic cause that explains why the event happened; that can reasonably be identified; that senior management has the control to fix; and for which effective recommendations for corrective actions to remedy the problem, prevent specific recurrence of the problem, and preclude occurrence of similar problems can be generated, if necessary. This is typically one level further in analysis beyond the apparent cause(s).

41. SAFETY CLASS STRUCTURES, SYSTEMS, OR COMPONENTS (SAFETY CLASS SSCs). The structures, systems, or components, including portions of process systems, whose preventive or mitigative function is necessary to limit radioactive hazardous material exposure to the public, as determined from safety analyses (10 CFR 830.3)

42. SAFETY SIGNIFICANT STRUCTURES, SYSTEMS, OR COMPONENTS (SAFETY SIGNIFICANT SSCs). The structures, systems, or components that are not designated as safety class structures, systems, or components, but whose preventive or mitigative function is a major contributor to defense in depth and/or worker safety as determined from safety analyses (10 CFR 830.3)

43. SECRETARIAL OFFICER. The Secretary, Deputy Secretary, undersecretaries, and the assistant secretaries and staff office directors reporting to the Secretary either directly or through the Deputy Secretary or undersecretary. The following designations are also used to identify secretarial officers with specific responsibilities in various areas: (1) A program secretarial officer (PSO) is an assistant secretary, office director, or NNSA deputy administrator. In the context of field operations, a PSO funds work at a particular site, facility, or laboratory and is a customer of the field office. (2) A lead program secretarial officer (LPSO) is a PSO to whom designated field offices directly report and who has overall landlord responsibilities for the assigned direct-reporting elements. (3) A cognizant secretarial officer (CSO) is a term used in the context of field operations to designate a PSO, not the LPSO, who is responsible for a laboratory or bounded set of facilities within a field office's jurisdiction.

44. SIGNIFICANCE CATEGORIES. Significance categories provide a means to reflect the perceived risk associated with a given occurrence. The significance categories are:

Operational Emergencies (OE): These are defined in DOE O 151.1C and include major unplanned or abnormal events or conditions that involve or affect DOE facilities and activities by causing, or having the potential to cause, serious health and safety or environmental impacts; require resources from outside the immediate/affected area or local event scene to supplement the initial response; and require time-urgent notifications to initiate response activities at locations beyond the event scene.

Significance Category 1: Non-OE events that caused actual harm, posed the potential for immediate harm or mission interruption due to safety system failure and required prompt mitigative action, or constituted an egregious noncompliance with regulatory requirements that created the potential for actual harm or mission interruption

Significance Category 2: Circumstances that reflected degraded safety margins, necessitating prompt management attention, along with modified normal operations to prevent an adverse event on: safe facility operations; worker or public safety and health, including significant personnel injuries; regulatory compliance; or public/business interest

Significance Category 3: Occurrences with localized implications, including personnel injury, environmental releases, equipment damage, or hazardous circumstances that were locally contained and did not immediately suggest broader systemic concerns

Significance Category 4: Events or circumstances that were mitigated or contained by normal operating practices, but where reporting provides potential learning opportunities for others

Significance Category R: Occurrences identified as recurring, either directly or through periodic analysis of occurrences and other nonreportable events

45. SUSPECT/COUNTERFEIT ITEMS (S/CIs). An item that is suspect when inspection or testing indicates that it may not conform to established government or industry-accepted specifications or national consensus standards or whose documentation, appearance, performance, material, or other characteristics may have been misrepresented by the vendor, supplier, distributor, or manufacturer. A counterfeit item is one that has been copied or substituted without legal right or authority or whose material, performance, or characteristics have been misrepresented by the vendor, supplier, distributor, or manufacturer. Items that do not conform to established requirements are not normally considered S/CIs if nonconformity results from one or more of the following conditions (which must be controlled by site procedures as nonconforming items):

  1. Defects resulting from inadequate design or production quality control
  2. Damage during shipping, handling, or storage
  3. Improper installation
  4. Deterioration during service
  5. Degradation during removal
  6. Failure resulting from aging or misapplication
  7. Other controllable causes (IAEA-TECDOC-1169)

Appendix B. DOE Reporting Criteria

Lab Notes:

LBNL does not possess Hazard Category 1, 2 or 3 nuclear facilities - only radiological facilities.  LBNL does not have operations involving Technical Safety Requirements, Unreviewed Safety Questions (USQ), or Safety Class Structure, System, or Component (SSC).  Therefore Group 3, Nuclear Safety Basis and Group 7 Nuclear Explosive Safety are not applicable to the Laboratory.

Group 1 — Operational Emergencies

Lab Notes:

  1. Upon notification, LBNL emergency management personnel will coordinate the response and reporting to all required agencies including the DOE Emergency Operations Center (as documented in LBNL/PUB 533, MEPP).

#

SC

Occurrence Description

*1

OE

An Operational Emergency not requiring classification, as defined in DOE 151.1C, Chapter V, Paragraph 2.

*2

OE

An Alert, as defined in DOE 151.1C, Chapter V, Paragraph 3a.

*3

OE

A Site Area Emergency, as defined in DOE 151.1C, Chapter V, Paragraph 3b.

*4

OE

A General Emergency, as defined in DOE 151.1C, Chapter V, Paragraph 3c.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Group 2 — Personnel Safety and Health

Lab Notes:

  1. All occupational injuries and illnesses are reported to LBNL Health Services (ext. 6266).
  2. Follow-up medical appointments or hospitalization for chronic illnesses and injuries are not reportable. For example, a worker who spends a day or two in a hospital from time to time for asbestosis that originated twenty or thirty years ago, or a worker who has follow-up appointments after undergoing disk surgery months ago for a job-related injury, does not need to report further.
  3. DOE O 225.1B defines when Federal Accident Investigation Boards must be convened.

Subgroup 2A — Occupational Injuries

#

SC

Occurrence Description

*1

1

Any occurrence due to DOE operations resulting in a fatality or terminal injury/illness. Report fatalities or terminal illnesses caused by overexposures under Subgroup B, Occupational Exposures.

*2

1

Any single occurrence requiring in-patient hospitalization of three or more personnel.

3

2

Any single occurrence resulting in an occupational injury that requires in-patient hospitalization for 5 days or more, commencing within 7 days from the date the injury was received.

Note: This criterion is similar to one of the thresholds for initiating a Federal Accident Investigation Board. If such an investigation is begun, the event must be reported under Criterion 10(1), as well as under this criterion if the injury so warrants.

4

2

Any single occurrence resulting in three or more personnel having Days Away, Restricted or Transferred (DART) cases per 29 CFR Part 1904.7.

5

3

Any single occurrence resulting in a serious occupational injury. A serious occupational injury is an occupational injury that:

  1. Requires hospitalization for more than 48 hours, commencing within 7 days from the date the injury was received;
  2. Results in a fracture of any bone (except bone chips, simple fractures of fingers, toes, or nose, or a minor chipped tooth);
  3. Causes severe hemorrhages or severe damage to nerves, muscles, tendons, or ligaments (note: Severe damage is generally considered to have occurred if surgery is required to correct the damage);
  4. Damages any internal organ;
  5. Causes (1) a concussion or (2) loss of consciousness due to an impact to the head; or
  6. Causes second- or third-degree burns, affecting more than five percent of the body surface.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 2B — Occupational Exposure

#

SC

Occurrence Description

*1

1

Any acute exposure from a chemical, biological, or physical hazard due to DOE operations resulting in a fatality or terminal injury/illness or requiring in-patient hospitalization of three or more personnel.

2

2

Any acute exposure resulting in an occupational injury that requires in-patient hospitalization for 5 days or more, commencing within 7 days from the date the exposure was received or any exposure event resulting in three or more personnel having Days Away, Restricted or Transferred (DART) cases per 29 CFR Section 1904.7.

*3

2

Personnel exposure to chemical, biological or physical hazards that exceeds 10 times the limits established in 10 CFR Part 851 (see 10 CFR Section 851.23 Safety and Health Standards) or exceeds levels deemed immediately dangerous to life and health (IDLH).

4

3

Personnel exposure to chemical, biological or physical hazards (e.g. noise, laser, ultraviolet light, heat, etc.) above limits established in 10 CFR Part 851 (see 10 CFR Section 851.23, Safety and Health Standards), but below levels deemed immediately dangerous to life and health (IDLH), and requires the administration of medical treatment beyond first aid on the same day as the exposure.

5

3

Any exposure including chronic resulting in a serious occupational injury. A serious occupational injury is an occupational injury that:

  1. Requires in-patient hospitalization for more than 48 hours, commencing within 7 days from the date the exposure was received;
  2. Damages any internal organ;
  3. Leads to diagnosis of a debilitating disease; or
  4. Causes second- or third-degree burns, affecting more than five percent of the body surface.

6

4

Personnel exposure to chemical, biological or physical hazards (e.g. noise, laser, ultraviolet light, heat, etc.) above limits established in 10 CFR Part 851, but below levels deemed immediately dangerous to life and health (IDLH).

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 2C — Fires

#

SC

Occurrence Description

*1

1

Not applicable to LBNL

*2

2

Not applicable to LBNL

*3

3

Any fire emergency or fire incident in a non-nuclear facility that:

  1. Activates a fixed automatic fire suppression system, or
  2. Takes longer than 10 minutes to extinguish following the arrival of the emergency response organization, or
  3. Disrupts normal operations in the facility for more than eight hours.

4

4

Not applicable to LBNL

*5

4

Any wild land fire (e.g., forest fire, grassland fire) or other fire outside of a DOE facility that has the potential to threaten the facility.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 2D — Explosions

#

SC

Occurrence Description

*1

1

Not applicable to LBNL

*2

2

Not applicable to LBNL

*3

3

Any unplanned explosion in a non-nuclear facility that disrupts normal operations in the facility.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 2E — Hazardous Electrical Energy Control

#

SC

Occurrence Description

1

2

Any unexpected or unintended personal contact (burn, injury, etc.) with an electrical hazardous energy source (e.g., live electrical power circuit, etc.).

2

3

Any unexpected discovery of an uncontrolled electrical hazardous energy source (e.g., live electrical power circuit, etc.). This criterion does not include discoveries made by zero-energy checks and other precautionary investigations made before work is authorized to begin.

3

4

Any failure to follow a prescribed hazardous energy control process (e.g., lockout/tagout, hazardous energy control program).

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 2F — Hazardous Energy Control (Other than electrical)

#

SC

Occurrence Description

1

2

Any unexpected or unintended personal contact (burn, injury, etc.) with a hazardous energy source (e.g., powered mechanical hazards, steam, pressurized gas).

2

3

Any unexpected discovery of an uncontrolled hazardous energy source (e.g., powered mechanical hazards, steam, pressurized gas). This criterion does not include discoveries made by zero-energy checks and other precautionary investigations made before work is authorized to begin.

3

4

Any failure to follow a prescribed hazardous energy control process (e.g., lockout/tagout, hazardous energy control program).

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Group 3 — Nuclear Safety Basis

Group 3 is not applicable to LBNL.

Group 4 — Facility Status

Subgroup 4A — Safety Structure/System/Component Degradation (Nuclear Facilities)

Subgroup 4A is not applicable to LBNL.

Subgroup 4B — Operations

#

SC

Occurrence Description

*1

2

A formal change of operational mode or curtailment of work or process directed by a DOE Field Element Manager or Contracting Officer for safety reasons (e.g., a Stop Work Order).

2

2

Not applicable to LBNL

3

3

Not applicable to LBNL

4

3

Any facility evacuation, other than a precautionary evacuation or an evacuation due to false alarms or spurious alarms (e.g., due to electronic noise, radon/thoron decay). If the event fell under another reporting criterion, then evacuation should be reported as well by noting multiple reporting criteria for the single occurrence.

5

4

A facility operational event which resulted in an adverse event on safety, such as but not limited to:

  1. An inadvertent facility or operations shutdown (i.e., a change of operational mode or curtailment of work or process),
  2. A manual facility or operations shutdown due to alarm response procedures,
  3. An inadvertent process liquid transfer, or
  4. An inadvertent release of hazardous materials form its engineered containment.

6

4

A facility or operations shutdown (i.e., a change of operational mode or curtailment of work or processes) directed by senior contractor or senior DOE management for safety reasons, and requiring a conrrective action(s) prior to continuing operations.

7

4

Any event or condition that would prevent immediate facility or offsite emergency response capabilities.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 4C — Suspect/Counterfeit and Defective Items or Material

#

SC

Occurrence Description

1

3

Not applicable to LBNL

2

4

Discovery of any suspect/counterfeit item or material that is found in any application whose failure could result in a loss of safety function, or present a hazard to public or worker health and safety.

3

4

Discovery of any defective item or material, other than a suspect/counterfeit item or material, in any application whose failure could result in a loss of safety function, or present a hazard to public or worker health and safety.

A defective item or material is any item or material that does not meet the commercial standard or procurement requirements as defined by catalogues, proposals, procurement specifications, design specifications, testing requirements, contracts, or the like. It does not include parts or services that fail or are otherwise found to be inadequate because of random failures or errors within the accepted reliability level.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Group 5 — Environmental

Lab Notes:

  1. For assistance with environmental releases, mitigation, and reporting to local regulatory agencies, contact the LBNL Environmental Services Group (486-7614).  If the release involves radioactive material, the Environmental Service Group will contact the Radiation Protection Group.
  2. DOE reporting is not required for courtesy notices provided to the City of Berkeley for releases that are below reporting thresholds.

Subgroup 5A — Releases

#

SC

Occurrence Description

*1

3

Any release (onsite or offsite) of a hazardous or extremely hazardous substance, including radionuclides from a DOE facility above federally permitted releases in a quantity equal to or exceeding the federal reportable quantities specified (See specifications in 40 CFR 302, 40 CFR 355 and CERCLA Section 101(10)).

[Note: See Group 1, Criterion 1 for situations under which releases of hazardous or extremely hazardous substances would be reported under "Operational Emergencies."]

2

4

Any release (onsite or offsite) of a pollutant from a DOE facility that is above levels or limits specified by outside agencies in a permit, license, or equivalent authorization, when reporting is required in a format other than routine periodic reports.

[Note: See Group 1, Criterion 1 for situations under which releases of hazardous or extremely hazardous substances would be reported under "Operational Emergencies."]

3

4

Any release (onsite or offsite) that exceeds 100 gallons of oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil. For operations involving oil field crude or condensate, any discharge that must be reported to outside agencies in a format other than routine periodic reports is reportable under this criterion.

[Note: See Group 1, Criterion 1 for situations under which releases of hazardous or extremely hazardous substances would be reported under "Operational Emergencies."]

4

4

Any discrete release of sulfur hexafluoride (SF6) due to an event or DOE operation equal to or exceeding 115 pounds (1,247 metric tons of CO2e according to 40 CFR Part 98, Subpart A, Table A-1) or 115 pounds more than the normal release quantity if the SF6 release is a common byproduct of the operation.

[Note: For this criterion, discrete means the event or operation has defined start and stop points less than seven full days apart.]

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 5B — Ecological and Cultural Resources

#

SC

Occurrence Description

1

2

Any occurrence including releases causing significant impact to ecological or cultural resource for which DOE has responsibility under applicable laws, regulations, and Executive Orders.  For example, extensive damage to, or destruction of:

  1. Ecologically preserved areas, or pristine or protected wetlands;
  2. Threatened or protected flora or fauna or critical habitats;
  3. Potable drinking water intake or well usage; or
  4. Historical/archeological sites.

*2

2

Any occurrence, including releases, resulting in extensive environmental degradation (e.g., fish kill, notable loss or relocation of native species, need for interdiction of crop sales, or restriction to human access).

[Note: See Group 1, Criterion 1 for situations under which releases of hazardous or extremely hazardous substances would be reported under "Operational Emergencies."]

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Group 6 — Contamination/Radiation Control

Lab Notes:

  1. All radiological events, regardless of significance, must be reported to the LBNL Radiation Protection Group (486-7652).  The Radiation Protection Group will contact the LBNL Price Anderson Amendment Act (PAAA) coordinator.
  2. Consumer products will be interpreted to mean any radioactive material or product that can be purchased without a Nuclear Regulatory Commission (NRC) license or DOE contract, including NRC-exempt quantities and NRC–generally licensed products.
  3. Radioactive contamination is not interpreted to include objects that are contained such that the radioactivity is not dispersible and cannot be inadvertently touched by people.
  4. Legacy radioactive contamination is contamination resulting from historical operations that are unrelated to current activities.


Subgroup 6A — Loss of Control of Radioactive Materials

 

Lab Notes:

  1. Subgroup 6A criteria apply to bulk radioactive materials, sealed sources, and property containing radioactive materials, including discovered legacy radioactive materials, but do not apply to surface radioactive contamination on property.  Surface radioactive contamination is addressed in Subgroup 6B.

 

#

SC

Occurrence Description

*1

2

Identification of radioactive material offsite due to DOE operations/activities that exceeds applicable DOE limits (pursuant to DOE O 458.1 Chg 2, dated 6-6-11).

2

2

Loss or unexpected discovery of radioactive material that exceeds 100 times the values in 10 CFR Part 835, Appendix E (excluding consumer products such as smoke detectors, if they are handled in accordance with manufacturer's instructions), or loss of accountability of such material for more than 24 hours. The 24-hour time period begins when the loss of accountability is discovered and must include one business day.

3

3

Loss or unexpected discovery of radioactive material which exceeds 1 times and no greater than 100 times the values in 10 CFR Part 835, Appendix E (excluding consumer products such as smoke detectors, if they are handled in accordance with manufacturer's instructions) or loss of accountability of such material for more than 24 hours. The 24-hour time period begins when the loss of accountability is discovered and must include one business day.

[Note: Legacy radioactive material discovered through a routine radiological monitoring program, compliant with 10 CFR 835 may be summarized in a single short form report, for example, on a quarterly basis.  Each instance of legacy radioactive material must be identified in the report and contain the details required for reporting in accordance with this Order.]

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

6B — Spread of Radioactive Contamination

#

SC

Occurrence Description

*1

2

Identification of offsite radioactive contamination due to DOE operations/activities that exceeds applicable DOE-approved authorized limits (pursuant to DOE 458.1 Chg 2, dated 6-6-11) or, if there are none, the values found in 10 CFR Part 835, Appendix D.

[Notes:

  1. Release or clearance of property containing or potentially containing residual radioactive material is subject to requirements in DOE O 458.1.  Compliance with 10 CFR Part 835, Appendix D values does not necessarily satisfy the requirements in DOE O 458.1.
  2. The discovery of radioactive contamination from past DOE/NNSA operations that may have caused, is causing or may reasonably be expected to cause exposures exceeding protective action criteria may be reportable an Operational Emergency under Group 1, Criterion 1.]

2

2

Identification of onsite radioactive contamination greater than 100 times the total contamination values in 10 CFR 835 Appendix D, exclusive of footnote 3 to Appendix D, and that is found outside of the following locations: areas routinely posted, controlled and monitored for contamination, areas controlled in accordance with 10 CFR 835.1102(c), and, per Section 835.604(a), any non-posted area that is under the continual observation and control of an individual knowledgeable of and empowered to implement required access and exposure control measures. For tritium, the reporting threshold is 100 times the removable contamination values in 10 CFR Part 835, Appendix D.

[Notes:

  1. This does not apply to surface contamination from residual radioactive material meeting applicable DOE-approved authorized limits.
  2. This does not apply to legacy radioactive contamination which is to be reported under a separate criterion below.
  3. The exclusion from reporting contamination in a Radiological Buffer Area applies only when the area has been established for a Contamination Area, High Contamination Area, or Airborne Radioactivity Area and its exit requirements have adopted guidance from Article 338.2 of DOE-STD-1098-2008.
  4. The discovery of radioactive contamination from past DOE/NNSA operations that may have caused, is causing, or may reasonably be expected to cause uncontrolled personnel exposures exceeding protective action criteria may be reportable as an Operational Emergency under Group 1, Criterion 1.]

3

3

Identification of onsite radioactive contamination greater than 10 times and no greater than 100 times the total contamination values in 10 CFR 835 Appendix D, exclusive of footnote 3 to Appendix D, and that is found outside of the following locations: areas routinely posted, controlled and monitored for contamination, areas controlled in accordance with 10 CFR 835.1102(c), and, per Section 835.604(a), any non-posted area that is under the continual observation and control of an individual knowledgeable of and empowered to implement required access and exposure control measures. For tritium, the reporting threshold is 10 times the removable contamination values in 10 CFR Part 835, Appendix D.

[Notes:

  1. This does not apply to contamination from residual radioactive material meeting applicable DOE-approved authorized limits.
  2. This also does not apply to legacy radioactive contamination, which is to be reported under a separate criterion below.
  3. The exclusion from reporting contamination in a Radiological Buffer Area applies only when the area has been established for a Contamination Area, High Contamination Area or Airborne Radioactivity Area and its exit requirements have adopted guidance from Article 338.2 of DOE-STD-1098-2008.
  4. This reporting criterion does not apply to packages monitored in accordance with 10 CFR Section 835.405 that meet DOT contamination limits specified in 49 CFR Section 173.443(a).]

4

4

Identification of onsite legacy radioactive contamination greater than 10 times the total contamination values in 10 CFR 835 Appendix D, exclusive to footnote 3 to Appendix D, and that is found outside of the following locations: areas routinely posted, controlled and monitored for contamination, areas controlled in accordance with 10 CFR 835.1102(c), and, per Section 835.604(a), any non-posted area that is under the continual observation and control of an individual knowledgeable of and empowered to implement required access and exposure control measures. For tritium, the reporting threshold is 10 times the removable contamination values in 10 CFR Part 835, Appendix D.

[Notes:

  1. Legacy radioactive contamination is radioactive contamination resulting from historical operations that are unrelated to current activities.
  2. This does not apply to contamination from residual radioactive material meeting applicable DOE-approved authorized limits.
  3. The exclusion from reporting contamination in a Radiological Buffer Area applies only when the area has been established for a Contamination Area, High Contamination Area or Airborne Radioactivity Area and its exit requirements have adopted guidance from Article 338.2 of DOE-STD-1098-2008.
  4. Legacy contamination identified through a routine radiological monitoring program, compliant with 10 CFR 835 may be summarized in a single short form report, for example on a quarterly basis.  Each instance of legacy contamination must be identified in the report and contain the details required for reporting in accordance with this Order.]

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 6C — Radiation Exposure

Lab Notes:

  1. For all of Subgroup C, reportability should be determined promptly following an event, using field indicators when dosimetry results are not available.  Quantitative dose estimates should only be reported using the site's established dosimetry, dose assessment, and modeling processes.  Resulting confirmed dose estimates may overturn initial reportability determinations.

 

#

SC

Occurrence Description

*1

1

Determination of a dose that exceeds the limits specified in 10 CFR Part 835, Subpart C, Occupational Radiation Protection or DOE O 458.1 Chg 2, dated 6-6-11, paragraph 4.b(1)(a) [paragraph 2.b(1)(a) of the CRD]. 

2

2

Failure to provide the required monitoring for an exposure estimated to exceed the values for providing personnel dosimeters and bioassays as stated in 10 CFR 835.402(a) or 10 CFR 835.402(c).

3

3

Determination of a single occupational dose, attributable to an identified event that exceeds an expected dose by: (1) 500 mrem Committed Effective Dose (CED), or (2) the greater of 10 percent or 100-mrem effective dose due to external exposure.

4

3

A radiological release that exceeds any limit contained in paragraphs 4.f.(2), 4.f.(5), 4.g.(4), 4.g.(5)(a), 4.g.(7), 4.g.(8)(a)4 or 4.i.(1) of DOE O 458.1 Chg 2, dated 6-6-11 or exceeds the 40 CFR Section 61.92 requirements.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Subgroup 6D — Personnel Contamination

#

SC

Occurrence Description

*1

2

Any occurrence requiring offsite medical assistance for contaminated personnel, including transporting a person with personnel or clothing contamination due to DOE operations/activities that exceeds 1 times the total contamination values in 10 CFR 835, Appendix D to an offsite medical facility or bringing offsite medical personnel onsite to perform treatment or decontamination.

2

2

Identification of offsite personnel or clothing contamination due to DOE operations/activities that exceeds 1 times the total contamination in 10 CFR Part 835, Appendix D. For tritium, the reporting threshold is 1 times the removable contamination value found in 10 CFR Part 835, Appendix D.

3

4

Identification of onsite personnel or clothing contamination (excluding anti-contamination clothing provided by the site for radiological protection) that exceeds 10 times the total contamination values identified in 10 CFR Part 835, Appendix D. The contamination level must be based on direct measurement and not averaged over any area. This criterion does not apply to tritium contamination.

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

 Group 7 — Nuclear Explosive Safety

Group 7 is not applicable to LBNL.

 Group 8 — Packaging and Transportation

Lab Notes:

  1. Radiological materials transported using the defined route between LBNL and the UC Berkeley Campus are deemed to be on-site transfers.
  2. On-site releases of radioactive materials due to packaging or transportation are reportable under this section if the amount of the release or contamination exceeds applicable thresholds defined in 10 CFR 835.

 

#

SC

Occurrence Description

*1

2

Any offsite transportation incident involving hazardous materials that would require immediate notice pursuant to 49 CFR Section 171.15(b).

[Note: Any occurrence involving an offsite DOE/NNSA shipment containing hazardous materials that causes the initial responders to initiate protective actions at locations beyond the immediate/affected area should also be reported as an Operational Emergency under Group 1, Criterion 1; Group 8 will be a secondary reporting criterion.]

2

3

Not applicable to LBNL

*3

3

Any offsite "accident" (per 49 CFR Section 390.5) involving a motor vehicle carrying DOE hazardous materials operating on a highway in interstate or intrastate commerce.

[Note: Prompt notification is not required if the accident does not involve personnel injuries.]

4

3

Any offsite transportation incident involving DOE hazardous materials that requires submission of a Hazardous Materials Incident Report on DOT Form F 5800.1 pursuant to 49 CFR Section 171.16.

5

3

Any offsite transportation of hazardous material, including radioactive material, whose quantity or nature (e.g., physical or chemical composition) is such that it is noncompliant with the receiving facilities Waste Acceptance Criteria (WAC) or other receipt requirements and the receiving organization's operations were significantly impacted or disrupted (e.g., material cannot be accepted, possessed, or stored at that facility; must be treated or repackaged to be accepted; or exceeds a license or permit limit).

6

3

Any transportation activity for onsite transfer resulting in onsite release of radioactive materials, hazardous materials, hazardous substances, hazardous waste, or marine pollutants that is above permitted levels and exceeds the reportable quantities (RQ) specified in 40 CFR Section 302 or 40 CFR Section 355.

[Note:

  1. This occurrence may be reportable under Group 1, Criteria 2, 3, or 4.
  2. Any release of a quantity of hazardous materials greater than five (5) times the Reportable Quantity (RQ) specified for such material in 40 CFR § 302; of greater than 1,000 gallons (24 barrels) of oil to inland waters; or greater than 10,000 gallons (238 barrels) of oil to coastal waters should also be reported as an Operational Emergency under Group 1, Criterion 1; Group 8 will be a secondary reporting criteria.]

7

4

Violation of applicable Hazardous Materials Regulations requirements for activities listed in 49 CFR Section 171.1(b) performed during the preparation of offsite hazardous materials shipments and discovered during shipment in commerce or at the receiving site.

8

4

Any onsite transfer of hazardous material, including radioactive material, whose quantity or nature (e.g., physical or chemical composition) is such that it is noncompliant with the receiving facilities Waste Acceptance Criteria (WAC) or other receipt requirements and the receiving organization's operations were significantly impacted or disrupted (e.g., material cannot be accepted, possessed, or stored at that facility; must be treated or repackaged to be accepted; or exceeds a license or permit limit).

9

4

Unauthorized deviation from DOE instructions to commercial motor carriers for DOE hazardous materials shipments (e.g., designated route, prohibited route, designated time of the day).

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Group 9 — Noncompliance Notifications

Lab Notes:

  1. Notices of deficiencies related to permit modifications, renewals, or reports are not DOE Reportable.

 

#

SC

Occurrence Description

1

4

Any written notification from an outside regulatory agency that a site/facility is considered to be in noncompliance with a schedule or requirement (e.g., Notice of Violation, Notice of Intent to Sue, Notice of Noncompliance, Warning Letter, Finding of Violation, Finding of Alleged Violation, Administrative Order, or equivalent notification or enforcement action).

[Note: This criterion is not applicable to DOE Office of Enforcement actions.]

2

4

Any packaging or transportation violation of regulations discovered by DOT during onsite inspections or Compliance Reviews resulting in fines greater than $5,000 or Unsatisfactory/Conditional Satisfactory ratings.

[Note: Noncompliance occurrence reports are to be updated to reflect fines or penalties levied or corrective actions imposed by the outside regulatory agency upon final settlement of any enforcement action undertaken.]

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Group 10 — Management Concerns and Issues

Lab Notes:

  1. For an event to be considered a DOE reportable near miss under #3, 1) something must have physically happen, and 2) the consequences of the near miss would have resulted in a DOE reportable occurrence should it have been an actual event.  For example, a person working near the edge of a roof without adequate fall protection would not be a near miss.  If the same person tripped and fell near the edge of the roof, this would be a DOE reportable near miss because an event physically happened (i.e., the tripping) and the worker would have likely sustained serious injuries from falling off the roof.

 

#

SC.

Occurrence Description

1

4

Any event resulting in the initiation of a Federal Accident Investigation Board, as categorized by DOE O 225.1B, Accident Investigation.

[Note: This reporting criterion may raise the significance category of an occurrence already reported under separate criteria. Multiple reporting criteria should be noted when appropriate.]

2

1-4

An event, condition, or series of events that does not meet any of the other reporting criteria, but is determined by the Division Director (a.k.a. Facility Manager) or line management to be of safety significance or of concern to other facilities or activities in the DOE complex.

The SC assigned to the management concern should be based on an evaluation of the potential risks and impact on safe operations.

3

1-3

A near miss to an otherwise DOE reportable incident, where something physically happened that was unexpected or unintended, or where no barrier or only one barrier prevented an event from having a reportable consequence.

The SC assigned to the near miss must be based on an evaluation of the potential risks and extent of personnel exposure to the hazard.

*4

4

Any occurrence that may result in a significant concern by affected state, tribal, or local officials, press, or general population; that could damage the credibility of the Department; or that may result in inquiries to Headquarters.

*5

4

Any occurrence of such significant immediate interest to offsite personnel and organizations that it warrants prompt notification to the DOE Headquarters Operations Center (DOE HQ OC), and which is not already designated elsewhere in this set of reporting criteria to have prompt notification [denoted by having an asterisk (*) next to the occurrence sequence number].

# = Criterion Number
SC = Significance Category
* = Prompt notification to DOE Headquarters required

Appendix C. Notification and Reporting Matrix

 

Prompt Notification

Notification Report

Final Report

Significance Category

Due

Notification To

Notification Mode

Due

Causal Analysis

Due

Report Approval

Operational Emergency

15 minutes if classified (per DOE O 151.1c), otherwise 30 minutes

  • BSO
  • DOE HQ Operations Center (OC)

Per LBNL/PUB 533, MEPP

Close of business (COB) next business day, not to exceed 90 hrs

Root cause or locally approved procedure

Within 45 calendar days

  • BSO
  • DOE HQ
  • Division Director

1

Within 2 hours of categorization

  • BSO
  • DOE HQ OC

E-mail and follow-up phone call

COB next business day, not to exceed 90 hrs

Root cause or locally approved procedure

Within 45 calendar days

  • BSO
  • DOE HQ
  • Division Director

Recurring

Not Required

Not Required

Not Required

COB on the second business day

Root cause or locally approved procedure

Within 45 calendar days

  • BSO
  • Division Director

2

Within 2 hours of categorization

  • BSO
  • DOE HQ OC (as required)

E-mail and/or phone call

COB next business day

Apparent cause or locally approved procedure

Within 45 calendar days

  • BSO
  • Division Director

3

Within 2 hours of categorization

  • BSO
  • DOE HQ OC (as required)

E-mail and/or phone call

COB on the second business day

Apparent cause or locally approved procedure

Within 45 calendar days

  • Division Director

4

Within 2 hours of categorization (as required)

  • BSO
  • DOE HQ OC (as required)

E-mail and/or phone call

COB on the second business day

Optional or locally approved procedure

Within 2 business days

  • Division Director
  1. Categorization Time is from Discovery Date and Time. Prompt Notification is from Categorization Date and Time. Written Notification is from Categorization Date and Time.
  2. Specific Significance Category 2, 3 and 4 occurrences (identified with an asterisk in Appendix B) also require prompt notification to DOE HQ OC.

Appendix D. Causal Analysis Tree

Go here to download an electronic copy of the Causal Analysis Tree.

 

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