**LBID-2488**

![](media/image1.wmf){width="1.125in" height="0.7in"}

**Environment, Health, and Safety Division**

**OCCURRENCE REPORTING**

**AND**

**PROCESSING SYSTEM**

**(ORPS)**

**Revision 1**

**Effective Date: March 2007**

**Ernest Orlando Lawrence**

**Berkeley National Laboratory**

**University of California**

**Berkeley, CA 94720**

This work was supported by the U.S. Department of Energy under Contract
No. DE-AC02-05CH11231.

Table of Contents

1\. PURPOSE [1](#__RefHeading___Toc162777651)

2\. RESPONSIBILITIES [1](#__RefHeading___Toc162777652)

2.1. Division Directors [1](#__RefHeading___Toc162777653)

2.2. Division ORPS Designees [1](#__RefHeading___Toc162777654)

2.3. Environment, Health, and Safety Division.
[2](#__RefHeading___Toc162777655)

2.4. Employees, Supervisors, and Subcontractors.
[2](#__RefHeading___Toc162777656)

3\. OCCURRENCE REPORTING PROCESS [2](#__RefHeading___Toc162777657)

3.1 Discovery of Abnormal Occurrence [2](#__RefHeading___Toc162777660)

3.2 Reportability of Occurrence [4](#__RefHeading___Toc162777663)

3.3 Significance of Occurrence [6](#__RefHeading___Toc162777664)

3.4 Prompt Notification of DOE [7](#__RefHeading___Toc162777665)

3.5 Written Notification Report [8](#__RefHeading___Toc162777699)

3.6 Occurrence Investigation and Causal Analysis
[9](#__RefHeading___Toc162777712)

3.7 Update and Final Occurrence Reports
[11](#__RefHeading___Toc162777738)

3.8 Performance Analysis and Identification of Recurring Occurrences
[13](#__RefHeading___Toc162777758)

3.9 Training [13](#__RefHeading___Toc162777759)

APPENDIX A. Reportable Occurrences and Significance Categories
[15](#__RefHeading___Toc162777761)

Group 1 --- Operational Emergencies [17](#__RefHeading___Toc162777762)

Group 2 --- Personnel Safety and Health
[18](#__RefHeading___Toc162777763)

Group 3 --- Nuclear Safety Basis [21](#__RefHeading___Toc162777764)

Group 4 --- Facility Status [22](#__RefHeading___Toc162777765)

Group 5 --- Environmental [24](#__RefHeading___Toc162777766)

Group 6 --- Contamination/Radiation Control
[25](#__RefHeading___Toc162777767)

Group 7 --- Nuclear Explosive Safety [30](#__RefHeading___Toc162777768)

Group 8 --- Transportation [31](#__RefHeading___Toc162777769)

Group 9 --- Noncompliance Notifications
[33](#__RefHeading___Toc162777770)

Group 10 --- Management Concerns/Issues
[34](#__RefHeading___Toc162777771)

APPENDIX B. ORPS Report Worksheet [35](#__RefHeading___Toc162777773)

APPENDIX C. Short Form Worksheet [41](#__RefHeading___Toc162777775)

APPENDIX D. Surface Contamination Values
[45](#__RefHeading___Toc162777777)

APPENDIX E. Causal Analysis Tree [49](#__RefHeading___Toc162777779)

**Procedures for**

**LBNL Occurrence Reporting and Processing System (ORPS)**

[]{#__RefHeading___Toc162777651 .anchor}1. PURPOSE

The Occurrence Reporting and Processing System (ORPS) at Lawrence
Berkeley National Laboratory (LBNL) notifies and keeps Laboratory
management and applicable elements of the Department of Energy (DOE)
informed of abnormal occurrences that could adversely affect:

a.  the health and safety of employees, guests, visitors, and the
    general public;

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a.  the environment;

b.  the intended purpose of LBNL facilities; or

c.  the credibility of the DOE and/or LBNL.

The ORPS procedures described herein provide the criteria for reporting
occurrences and the timely processing of occurrence information to
Laboratory and DOE management. All LBNL divisions and departments,
including subcontractors performing work at Berkeley Lab, are
responsible for following ORPS procedures. Reportable occurrences
require that the description, significance, causal factors, and
corrective actions of the occurrence are fully documented and
transmitted to the DOE ORPS Database. Processing the reportable
occurrences includes categorization of occurrences, timely DOE
notification, and submittals of updated and final ORPS reports. The
completed ORPS reports are used to analyze environment, safety, and
health (ES&H) performance, to develop lessons learned, and to prevent
recurrence of undesirable occurrences at LBNL and other DOE facilities.
The LBNL ORPS procedures meet the requirements of DOE Order 231.1A,
*Environment, Safety and Health Reporting*, and DOE Manual 231.1--2,
*Occurrence Reporting and Processing of Operations Information*.

[]{#__RefHeading___Toc162777652 .anchor}2. RESPONSIBILITIES

[]{#__RefHeading___Toc162777653 .anchor}**2.1. Division Directors:**
LBNL divisions are responsible for the timely reporting of adverse
and/or abnormal occurrences, as described herein, that occur at
facilities or operations within their organizational purview. Division
directors have overall responsibility for implementing these procedures,
ensuring that the division has the appropriate resources to monitor
day-to-day activities, reporting on abnormal occurrences, investigating
the causes of such occurrences, and instituting corrective actions to
prevent recurrence of the occurrences. Division directors must concur
that occurrences are ORPS reportable; and, if reportable, they must
approve the final ORPS reports before submission to the DOE ORPS
database. Note: For the purposes of the DOE ORPS Program, division
directors are sometimes referred to as the "Facility Manager."

[]{#__RefHeading___Toc162777654 .anchor}**2.2. Division ORPS
Designees:** Division directors are to assign individual(s) from their
organizations to assist in the implementation of these procedures.
Assigned designees should have positions and work responsibilities that
allow them to actively monitor day-to-day operations of division
facilities. They should assist division line managers and staff in the
notification, categorization, investigation, mitigation, and report
preparation of all reportable occurrences within the division. Because
of the importance of timely notification and reporting, designees must
be familiar with the ORPS procedures described herein. Appropriate
designees are deputy division directors, division safety managers, or
division safety coordinators.

[]{#__RefHeading___Toc162777655 .anchor}2.3. Environment, Health, and
Safety Division: **EH&S technical staff are to assist divisions as
necessary to respond to, mitigate, categorize, and investigate
occurrences, and are responsible for administering the LBNL Occurrence
Reporting Program and for supporting division directors and their
designees in ORPS report processing. EH&S is the primary point of
contact when reporting and tracking LBNL occurrences to the DOE Berkeley
Site Office (BSO) and other DOE program elements, as appropriate. EH&S
also provides the occurrence data and information input to the DOE
online ORPS database. Note: Due to their knowledge of hazards, awareness
of ORPS criteria thresholds, and response roles, EH&S staff may
initially categorize occurrences in the absence of division directors or
designees and confirm the categorization later with division
management.**

[]{#__RefHeading___Toc162777656 .anchor}2.4. Employees, Supervisors, and
Subcontractors **are responsible for reporting abnormal incidents,
unsafe conditions, and violations to their LBNL line management,
appropriate EH&S staff, and/or emergency responders. Supervisors must
ensure that employees are made aware of workplace health and safety
reporting responsibilities. Supervisors and employees must perform
immediate actions to mitigate unsafe conditions, secure occurrence
scenes as necessary for investigations, and provide information to
assist investigations.**

[]{#__RefHeading___Toc162777657 .anchor}3. OCCURRENCE REPORTING PROCESS

> An overview of the occurrence report process is presented as a flow
> diagram in Figure 3.1.
>
> Additional information is also available at the LBNL ORPS Web site,
> [**http://www.lbl.gov/ehs/orps/index.shtml.**](http://www.lbl.gov/ehs/orps/index.shtml.)

1.  []{#__RefHeading___Toc162777660 .anchor}Discovery of Abnormal
    Occurrence

Employees, supervisors, and subcontractors are required to perform their
job duties and responsibilities in a safe and environmentally
responsible manner; however, if they create or witness an adverse ES&H
occurrence or condition in the course of performing work, they must
immediately report the occurrence or condition to their division
management, safety coordinator, EH&S staff, or any other technical or
management individual who has responsibility and/or technical knowledge
to stabilize the occurrence or condition.

**Figure 3.1.** LBNL Occurrence Reporting Process Flow

Part of the responsibility of division management, division safety
coordinators, and EH&S staff is to monitor day-to-day operations in
division facilities and workspaces for adverse ES&H occurrences or
conditions. Once an occurrence or condition is discovered or reported to
this group of personnel, they will take the following actions:

a.  Take appropriate action to stabilize and/or place the
    facility/operation in a safe condition, and ensure any potential
    environmental effects are stabilized and workers are treated for
    injuries.

b.  Preserve conditions for continued investigation; however, these
    actions are not to interfere with establishing a safe condition.

c.  Concurrently with the above actions, personnel must inform the
    appropriate line management and the EH&S Division of the occurrence
    and its status so that prompt occurrence categorization and DOE
    notification can begin.

d.  As necessary, personnel should record all pertinent occurrence
    information and be available to investigators.

The discovery date and time will be established when adequate
information is available, but this information should be sought as soon
as possible and with urgency at all hours to ensure prompt DOE
notification of occurrences. In some circumstances, discovery may await
confirmation of an occurrence, or a condition that requires time and
resources to complete. Examples are as follows:

a.  For radioactive or hazardous contaminations and exposures, where
    initial monitoring cannot produce reliable results, discovery will
    occur when analytical or lab results confirm results are above
    threshold levels. (Note: Analytical work will be prioritized ahead
    of scheduled, routine analysis where reasonable.)

b.  For injuries, discovery will occur when the nature of a
    hospitalization or lost workday is received from appropriate medical
    or healthcare personnel.

c.  For certain complex hazardous conditions or occurrences, discovery
    will occur when technically proficient staff have completed the
    initial evaluation.

    []{#__RefHeading___Toc162777663 .anchor}3.2 Reportability of
    Occurrence

After discovery of the abnormal occurrence is completed, the affected
division with support from the EH&S Division must determine, within two
hours, if the occurrence is reportable to DOE under ORPS. The reportable
occurrences and the significance of the occurrences are established in
*DOE M 231.1--2, Occurrence Reporting and Processing of Operations
Information*. Appendix A, *Reportable Occurrences and Significance
Categories*, of this procedure also provides a complete description of
reportable occurrences and applicability to LBNL operations and
activities. Reportable occurrences are organized into the following
topical groups and subgroups:

> Group 1: Operational Emergencies
>
> Group 2: Personnel Safety
>
> Subgroup 2A: Occupational Illnesses/Injuries
>
> Subgroup 2B: Fires/Explosions
>
> Subgroup 2C: Hazardous Energy Control
>
> Group 3: *Nuclear Safety Basis*
>
> Group 4: Facility Status
>
> Subgroup 4A: *Safety Structure/System/Component Degradation*
>
> Subgroup 4B: Operations
>
> Subgroup 4C: Suspect/Counterfeit and Defective Items or Material
>
> Group 5: Environmental
>
> Subgroup 5A: Releases
>
> Subgroup 5B: Ecological and Cultural Resources
>
> Group 6: Contamination/Radiation Control
>
> Subgroup 6A: Loss of Control of Radioactive Materials
>
> Subgroup 6B: Spread of Radioactive Contamination
>
> Subgroup 6C: Radiation Exposure
>
> Subgroup 6D: Personnel Contamination
>
> Group 7: *Nuclear Explosive Safety*
>
> Group 8: Transportation
>
> Group 9: Noncompliance Notifications
>
> Group 10: Management Concerns/Issues

Each group has from two to 13 reportable occurrences. Occurrences under
Group 3, *Nuclear Safety Basis*; Group 7, *Nuclear Explosive Safety*;
and Subgroup 4A, *Safety Structure/System/Component Degradation*, are
not applicable to LBNL, because the Laboratory does not operate any
nuclear facilities or Class I, II, or III radiological facilities, and
does not have operations involving Technical Safety Requirements;
Unreviewed Safety Questions; or Safety Class Structure, System, or
Component (SSC). There are several other types of specific occurrences
that are identified as not applicable in Appendix A. A total of 55 types
of occurrences in the remaining groups are applicable to LBNL operations
and require reporting to DOE. If an abnormal occurrence does not
correspond to any of the described occurrences, the incident is not
reportable under these procedures.

[]{#__RefHeading___Toc162777664 .anchor}3.3 Significance of Occurrence

In *DOE M 231.1--2, Occurrence Reporting and Processing of Operations
Information,* DOE has designated a significance category for each of the
described reportable occurrences. Categorization by significance
provides a graded approach in processing the occurrences. The most
significant occurrences require rigorous and in-depth reporting,
investigation, causal analysis, and corrective actions, whereas the
least significant occurrences require only a short report and remedy for
the problem. The reportability and significance of the occurrence are
collectively called the categorization of the occurrence and must be
reported no later than two hours after discovery. The significance
categories in the ORPS program are as follows:

a.  [Significance Category 1]{.underline}: Occurrences that have a
    *significant impact* on safe facility operations, work or public
    safety and health, regulatory compliance, or public/business
    interests.

b.  [Significance Category 2]{.underline}: Occurrences that have a
    *moderate impact* on safe facility operations, work or public safety
    and health, regulatory compliance, or public/business interests.

c.  [Significance Category 3]{.underline}: Occurrences that have a
    *minor impact* on safe facility operations, work or public safety
    and health, regulatory compliance, or public/business interests.

d.  [Significance Category 4]{.underline}: Occurrences that have *some
    impact* on safe facility operations, work or public safety and
    health, regulatory compliance, or public/business interests.

In addition to the above four significance categories, there are two
special categories:

a.  [Operational Emergencies (OE)]{.underline}: Occurrences that are
    unplanned; significant occurrences or conditions that require
    time-urgent response from outside the immediate affected site or
    facility. LBNL emergency-management personnel provide for the prompt
    notification and follow-up actions as required by DOE O 151.1A,
    *Comprehensive Emergency Management System*. LBNL staff who create
    or witness an operational emergency need only call ext. 7-911 for
    emergency response and report coordination.

b.  [Significance Category R]{.underline}: Occurrences that are
    identified as recurring occurrences, as determined by periodic
    analyses of past occurrences at LBNL. The Office of Contract
    Assurance conducts such periodic analyses and reports results to
    LBNL management and DOE.

    []{#__RefHeading___Toc162777665 .anchor}3.4 Prompt Notification of
    DOE

> After categorizing the occurrence as reportable, LBNL must promptly,
> usually within two hours, notify DOE of the occurrence. The division
> that has responsibility for the occurrence will contact the EH&S
> Division to coordinate the notification with various elements of DOE.
> Prompt notification of DOE is based on the significance of the
> occurrence, and must meet the following notification requirements:

  -------------- ------------------- ------------------- -------------------
  Significance   Timeline            Notification To     Notification Mode
  Category                                               

  Category 1     No later than two   Berkeley Site       E-mail and
                 hours after         Office (BSO) and    follow-up phone
                 categorization      DOE Headquarters    call
                                     Operations Center   
                                     (DOE HQ OC)         

  Category 2     No later than two   BSO, and, as        E-mail and/or phone
                 hours after         directed by BSO,    call
                 categorization      DOE HQ OC           

  Category 3     No later than two   BSO                 E-mail and/or phone
                 hours after                             call
                 categorization                          

  Category 4     No prompt                               
                 notification                            
                 required                                
  -------------- ------------------- ------------------- -------------------

For special categories, the prompt notification requirements are the
following:

  -------------- ------------------- ------------------- -------------------
  Special        Timeline            Notification To     Notification Mode
  Category                                               

  Operational    No later than 15    BSO and DOE HQ OC   Per site emergency
  Emergencies    minutes if                              response plan
                 classified; no                          
                 later than 30                           
                 minutes if not                          
                 classified                              

  Category R     No prompt                               
  (Recurring     notification                            
  Occurrences)   required                                

  Specific Cat   No later than two   BSO and DOE HQ OC   E-mail and
  2, 3, & 4      hours after                             follow-up phone
  Occurrences    categorization                          call
  Identified                                             
  with (\*)                                              
  Asterisks (see                                         
  Appendix A)                                            
  -------------- ------------------- ------------------- -------------------

DOE HQ OC e-mail address is <doehqeoc@oem.doe.gov> and phone numbers are
(202) 586-8100 (voice) and (202) 586-8485 (facsimile). Prompt
notification of DOE HQ OC should include as much information as
possible, including the following details:

a.  Occurrence significance category

b.  Location and description of the occurrence

c.  Date and time of discovery

d.  Damage and casualties

e.  Impact of occurrence on other activities and operations

f.  Protective actions taken or recommended

g.  Weather conditions at the scene

h.  Level of media interest at scene/facility/site

i.  Other notifications made

All information should be clear and succinct, avoiding any jargon.
Uncommon or site- or facility-specific abbreviations and acronyms should
be fully described. If the occurrence is recategorized, prompt
notification should be done under the requirements of the new category.
Follow-up notification is required if there is further degradation of
the occurrence or other worsening conditions subsequent to the previous
notification.

[]{#__RefHeading___Toc162777699 .anchor}3.5 Written Notification Report

A follow-up written notification report to DOE is required for all
reportable occurrences. Responsible divisions, with assistance from the
EH&S Division, should use the ORPS Report Worksheet (Appendix B) to
prepare the written notification. The notification report should provide
as much information as known, or at least the information required, by
the prompt notification (see Section 3.4). The report serves as the
basis for the subsequent update and final occurrence reports associated
with the occurrence. EH&S enters the information from the worksheet into
the DOE ORPS database. Written notification is deemed complete once the
information of the occurrence is entered into the DOE ORPS database.
Timeline requirements for the written notification are based on the
appropriate significance category, as described below:

+----------------------+-----------------------------------------------+
| Significance         | Timeline                                      |
| Category             |                                               |
+----------------------+-----------------------------------------------+
| Operational          | Before the close of the next business day     |
| Emergencies          | from categorization, but not to exceed 80     |
|                      | hours.                                        |
| Category 1           |                                               |
+----------------------+-----------------------------------------------+
| Categories 2 & R     | Before the close of the next business day     |
|                      | from categorization.                          |
+----------------------+-----------------------------------------------+
| Category 3           | Before the close of business on the second    |
|                      | business day from categorization.             |
+----------------------+-----------------------------------------------+
| Category 4           | Short Form Report before the close of         |
|                      | business on the second business day from      |
|                      | categorization                                |
|                      |                                               |
|                      | (satisfies all written reporting requirements |
|                      | for Category 4 occurrences).                  |
+----------------------+-----------------------------------------------+

Any changes in categorization will be documented in an Update Report and
submitted within the timeline required under the new category. A
justification for the new categorization should be included in the
report.

[]{#__RefHeading___Toc162777712 .anchor}3.6 Occurrence Investigation and
Causal Analysis

The investigation and analysis process is used to gain an understanding
of the occurrence, its causes, and the corrective actions necessary to
remedy the problem and to prevent recurrence. The rigor and scope of any
occurrence investigation and causal analysis are based on the
significance category of the occurrence. EH&S must be contacted to
provide assistance and/or coordination for all investigations and causal
analyses. EH&S subject matter experts may also be involved to provide
technical analysis. EH&S has trained and experienced investigators and
analysts to fully participate in higher-category occurrences that
require trained personnel.

+------------+------------------+------------------+------------------+
| Si         | Occurrence       | Causal Analysis  | Corrective       |
| gnificance | Investigation    |                  | Actions          |
| Category   |                  |                  |                  |
+------------+------------------+------------------+------------------+
| O          | Team of trained  | Root cause       | Remedy problem;  |
| perational | investigators;   | determined       | prevent          |
| E          | DOE accident     |                  | recurrence;      |
| mergencies | investigation as |                  | assess           |
|            | appropriate      |                  | effectiveness    |
| Category 1 |                  |                  |                  |
+------------+------------------+------------------+------------------+
| Category R | Trained          | Root cause       | Remedy problem;  |
|            | investigators    | determined       | prevent          |
|            |                  |                  | recurrence;      |
|            |                  |                  | assess           |
|            |                  |                  | effectiveness    |
+------------+------------------+------------------+------------------+
| Category 2 | Trained          | Apparent cause   | Remedy problem;  |
|            | investigators    | determined       | prevent          |
|            |                  |                  | recurrence       |
+------------+------------------+------------------+------------------+
| Category 3 | Critique/fact    | Apparent cause   | Remedy problem   |
|            | finding          | determined       |                  |
+------------+------------------+------------------+------------------+
| Category 4 | Fact finding     | None required    | Remedy problem   |
+------------+------------------+------------------+------------------+

a.  For occurrences that are categorized as operational emergencies or
    Categories 1, R, or 2 occurrences, investigations must be conducted
    with personnel who have had documented training in accident and/or
    problem investigation. EH&S staff are qualified for such
    investigations.

b.  DOE may conduct a Type A or B investigation for accidents
    categorized as operational emergencies or Category 1 occurrences.
    LBNL is not required to conduct an identical investigation under
    this circumstance.

c.  Guidance for causal analysis is provided in DOE Guide 231.1--2*,
    Occurrence Reporting Causal Analysis Guide*. All causes are
    classified by specific cause codes described in DOE G 231.1--2. The
    cause codes are also provided in the guidance document\'s Causal
    Analysis Tree (Appendix E). EH&S staff are trained in the use of the
    Causal Analysis Tree and should be consulted for all causal
    analysis.

d.  Operational emergencies caused by natural phenomena and/or
    originating off site do not require root cause analysis. Examples
    are earthquakes and offsite wildland fires.

e.  EH&S staff are trained to conduct formal root cause analysis using
    TapRoot® analysis, an approved methodology.

f.  Weaknesses in the division's implementation of Integrated Safety
    Management (ISM) are identified as part of the causal analysis.

g.  Depending on the significance of the occurrence, BSO staff (i.e.,
    facility representatives) should be consulted in a timely manner for
    their assessment of the occurrence as appropriate.

h.  Divisions are responsible for tracking all corrective actions
    identified for each occurrence in the LBNL Corrective Action
    Tracking System (CATS). With the exception of Significance Category
    4 occurrences, corrective actions must also be entered into the ORPS
    database with reference to the respective CATS identification
    numbers. For Significance Category 2 or higher reports, text changes
    to corrective actions in CATS must be transmitted to EH&S for update
    in the ORPS database. Depending on the significance category, EH&S
    and BSO may conduct independent verification, sampling, and
    effectiveness evaluation of the corrective actions.

i.  For operational emergencies, Significance Category 1, R, or 2
    occurrences and any text changes made to previously entered
    corrective actions must have prior BSO approval.

    []{#__RefHeading___Toc162777738 .anchor}3.7 Update and Final
    Occurrence Reports

The Notification Report in the DOE ORPS database is updated as necessary
with new and significant information about the occurrence. Responsible
divisions should provide any updated information to EH&S for data entry
into the ORPS database. Updated information includes, but is not limited
to, new data and investigation results, the status of the investigation,
recurring consequences, and identification of additional deficiencies
related to the occurrence. The Update Report (or if there is no Update
Report, the Notification Report) eventually becomes the Final Occurrence
Report when all pertinent information on the investigation and analysis,
including significance, nature, and extent of the occurrence, cause(s),
corrective actions, lessons learned, and other data as required by the
ORPS data fields (see Appendix B, ORPS Report Worksheet), are entered
into the ORPS database. Process requirements for the Final Occurrence
Report are based on the significance category of the occurrence:

+------------+----------------------------+----------------------------+
| Si         | Final Report Due           | Report Approval            |
| gnificance |                            |                            |
| Category   |                            |                            |
+------------+----------------------------+----------------------------+
| O          | Within 45 calendar days    | DOE Berkeley Site Office   |
| perational |                            | and DOE HQ Program Office  |
| E          |                            |                            |
| mergencies |                            |                            |
|            |                            |                            |
| Category 1 |                            |                            |
+------------+----------------------------+----------------------------+
| Category R | Within 45 calendar days    | DOE Berkeley Site Office   |
+------------+----------------------------+----------------------------+
| Category 2 | Within 45 calendar days    | DOE Berkeley Site Office   |
+------------+----------------------------+----------------------------+
| Category 3 | Within 45 calendar days    | Applicable LBNL            |
|            |                            | division/dept.             |
+------------+----------------------------+----------------------------+
| Category 4 | Only Short Form required   | Applicable LBNL            |
|            | within two business days   | division/dept.             |
+------------+----------------------------+----------------------------+

a.  Regardless of the significance category of the occurrence, the
    responsible division director must approve the final ORPS report
    prior to any submission to external organizations such as the
    Berkeley Site Office or DOE Headquarters. LBNL division directors
    should utilize EH&S assistance to process the final ORPS report.

b.  If the final report cannot be completed within 45 calendar days
    after categorization, an Update Report must be submitted prior to
    the deadline, with a detailed explanation of the delay and an
    estimated date for submittal of the final report.

c.  For Operational Emergencies and Significance Category 1, R, and 2
    final reports, BSO must review, approve, and add any comments, as
    necessary, within 14 calendar days after receipt of the report.
    After approval by BSO, Operational Emergencies and Significance
    Category 1 final reports must be submitted to the DOE HQ Program
    Office for its review, approval, and comments within 14 calendar
    days after its receipt of the report.

d.  If the final report is not approved by BSO or DOE HQ, the
    responsible DOE person rejecting the report must provide the reason
    for disapproval in the DOE comment section of the report. The LBNL
    division, with assistance from EH&S, must prepare a revised final
    report and resubmit 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 providing an estimated date
    for resubmittal. This information must be reported in the
    "evaluation" block of the Occurrence Report.

e.  For Significance Category 4 occurrences, only a "Short Form Report"
    is required (see Appendix C for the Short Form Worksheet).
    Responsible divisions should complete the Short Form Worksheet
    within two business days and submit to EH&S for data entry into
    ORPS. Other than completing any CATS-tracked corrective actions, the
    Category 4 occurrence is considered closed when the Short Form
    Report is in the ORPS database.

f.  The responsible division must retain all supporting information
    pertaining to each occurrence or report in accordance with LBNL
    records management policies. **Note:** Informal documents, such as
    e-mail messages and initial drafts, are not necessary for retention.

    []{#__RefHeading___Toc162777758 .anchor}3.8 Performance Analysis and
    Identification of Recurring Occurrences

The Office of Contract Assurance will perform quarterly analyses of
occurrences during a 12-month period to look for trends. This periodic
performance analysis must evaluate occurrences of all significance
categories plus LBNL-determined nonreportable occurrences in order to
prevent serious occurrences. The quarterly performance analysis results
will be made available to LBNL management and BSO, in ES&H quarterly
reports and/or Operational Awareness meetings.

Occurrences identified as recurring require a new occurrence report to
be submitted for notification of the recurring issue, with
investigation, root-cause analysis, and corrective actions subsequently
required. Previous individual occurrence report numbers associated with
the recurring issue must be provided in the "similar occurrence report
numbers" field. The new occurrence report is categorized as a
Significance Category R occurrence and must meet all reporting and
processing requirements for this category.

[]{#__RefHeading___Toc162777759 .anchor}3.9 Training

Training will be provided by EH&S to applicable division personnel who
may be involved with the reporting and processing of reportable
occurrences. The training course will include the objective and process
of occurrence reporting, including occurrence identification,
categorization, notification, report submission, causal analysis, report
closure, corrective action tracking, and utilization of data from the
ORPS database.

Employees and supervisors are to receive basic instructions for
reporting incidents and unsafe conditions to their line managers, and
this will be included in the required training course, *New Employee
Orientation.*

APPENDIX A

[]{#__RefHeading___Toc162777761 .anchor}REPORTABLE OCCURRENCES AND
SIGNIFICANCE CATEGORIES

**Lab Notes and Instructions:**

1.  Reportable occurrences are organized into ten topical groups. Some
    groups may have subgroups. Each type of occurrence is identified by
    its group, subgroup (if applicable), and sequence number. Thus, for
    example, a radiation exposure above threshold levels is denoted as
    Group 6, Subgroup C, Sequence Number 3, or as 6C(3).

2.  Group 3, Nuclear Safety Basis, and Group 7, Nuclear Explosive
    Safety, are for nuclear facilities and therefore are not applicable
    to LBNL operations or activities.

3.  An actual occurrence can be classified into multiple types of
    occurrences. For such situations, all of the applicable occurrence
    types should be identified in the ORPS report.

4.  Each reportable occurrence is assigned a significance category,
    which determines the graded approach for processing the occurrence
    (see Section 3.3).

5.  Reportable occurrences marked with asterisks (\*) require prompt
    notification of DOE (within 15 minutes for operational emergencies,
    and two hours for all others) regardless of the significance
    category (SC). LBNL emergency management personnel provide the
    prompt notification for operational emergencies; for all other
    reportable occurrences marked with asterisks, contact EH&S at ext.
    5514 to initiate the prompt notification.

[]{#__RefHeading___Toc162777762 .anchor}Group 1 --- Operational
Emergencies

> **Lab Notes:** Call 7-911 for all emergency situations. LBNL emergency
> management personnel will assume all responsibilities for contacting
> appropriate individuals and organizations for the purpose of meeting
> ORPS requirements.

+------------+-----+---------------------------------------------------+
| **SC**     | *   | **Occurrence Description**                        |
|            | *No |                                                   |
|            | .** |                                                   |
+------------+-----+---------------------------------------------------+
| > O        | \*1 | An Operational Emergency not needing further      |
| perational |     | classification, as defined in DOE 151.1A, Chapter |
| >          |     | 5, Paragraph 2.                                   |
|  Emergency |     |                                                   |
+------------+-----+---------------------------------------------------+
|            | \*2 | An Alert, as defined in DOE 151.1A, Chapter 5,    |
|            |     | Paragraph 3a.                                     |
+------------+-----+---------------------------------------------------+
|            | \*3 | A Site Area Emergency, as defined in DOE 151.1A,  |
|            |     | Chapter 5, Paragraph 3b.                          |
+------------+-----+---------------------------------------------------+
|            | \*4 | A General Emergency, as defined in DOE 151.1A,    |
|            |     | Chapter 5, Paragraph 3c.                          |
+------------+-----+---------------------------------------------------+

\* Group 1 reportable occurrences (operational emergencies) marked with
asterisks (\*) require within 15 minutes' prompt notification to DOE.
LBNL emergency management personnel provide the prompt notification for
the Laboratory.

[]{#__RefHeading___Toc162777763 .anchor}Group 2 --- Personnel Safety and
Health

> **Lab Notes:**

1.  All occupational injuries and illnesses are reported to LBNL Health
    Services. It is Laboratory policy to medically monitor all
    potentially serious cases.

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.

**Subgroup A Occupational Illnesses/Injuries**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | \ | Any occurrence due to DOE operations resulting in a       |
|  Cat | * | fatality or terminal injury/illness. For fatalities       |
| > 1  | 1 | caused by overexposures, the intent of this criterion is  |
|      |   | to report those caused by acute rather than chronic       |
|      |   | effects.                                                  |
+------+---+-----------------------------------------------------------+
|      | \ | Any single occurrence requiring in-patient                |
|      | * | hospitalization of three or more personnel.               |
|      | 2 |                                                           |
+------+---+-----------------------------------------------------------+
| >    | 3 | Any single occurrence resulting in three or more          |
|  Cat |   | personnel having Days Away, Restricted or Transferred     |
| > 2  |   | (DART) cases per 29 CFR Part 1904.7.                      |
+------+---+-----------------------------------------------------------+
|      | \ | Personnel exposure to chemical, biological, or physical   |
|      | * | hazards above limits established by the Occupational      |
|      | 4 | Safety and Health Administration (refer to 29 CFR Part    |
|      |   | 1910) or American Conference of Governmental Industrial   |
|      |   | Hygienists, whichever is lower, and that requires the     |
|      |   | administration of medical treatment beyond simple first   |
|      |   | aid on the same day as the exposure. \[29 CFR             |
|      |   | 1904.7(b)(5)(i) and (ii) define "medical treatment" and   |
|      |   | "first aid."\]                                            |
+------+---+-----------------------------------------------------------+

\*All reportable occurrences (as described in Groups 2--10 of Appendix
A) marked with asterisks (\*) require within 2 hours' prompt
notification to DOE regardless of the significance category (SC).
Contact EH&S at ext. 5514 to initiate the prompt notification.

**Subgroup A Occupational Illnesses/Injuries (continued)**

+------+---+-----------------------------------------------------------+
| >    | 5 | Personnel exposure to chemical, biological or physical    |
|  Cat |   | hazards above limits established by the Occupational      |
| > 3  |   | Safety and Health Administration (refer to 29 CFR Part    |
|      |   | 1910) or American Conference of Governmental Industrial   |
|      |   | Hygienists.                                               |
+------+---+-----------------------------------------------------------+
|      | 6 | Any single occurrence resulting in a serious occupational |
|      |   | injury. A serious occupational injury is an occupational  |
|      |   | injury that:                                              |
|      |   |                                                           |
|      |   | a.  Requires hospitalization for more than 48 hours,      |
|      |   |     commencing within 7 days from the date the injury was |
|      |   |     received;                                             |
|      |   |                                                           |
|      |   | b.  Results in a fracture of any bone (except simple      |
|      |   |     fractures of fingers, toes, or nose, or a minor       |
|      |   |     chipped tooth);                                       |
|      |   |                                                           |
|      |   | c.  Causes severe hemorrhages or severe damage to nerves, |
|      |   |     muscles, or tendons;                                  |
|      |   |                                                           |
|      |   | d.  Damages any internal organ; or                        |
|      |   |                                                           |
|      |   | e.  Causes second- or third-degree burns, affecting more  |
|      |   |     than five percent of the body surface.                |
+------+---+-----------------------------------------------------------+

**Subgroup B Fires/Explosions**

+------+---+----------------------------------------------------------+
| **   | * | **Occurrence Description**                               |
| SC** | * |                                                          |
|      | N |                                                          |
|      | o |                                                          |
|      | . |                                                          |
|      | * |                                                          |
|      | * |                                                          |
+======+===+==========================================================+
| >    | \ | Any unplanned fire or explosion within primary           |
|  Cat | * | confinement/containment boundaries for nuclear or        |
| > 1  | 1 | hazardous material within a facility.                    |
|      |   |                                                          |
|      |   | \[Note: Facility specific documents need to define what  |
|      |   | constitutes the primary confinement/containment          |
|      |   | boundary.\]                                              |
+------+---+----------------------------------------------------------+
| >    | \ | Fire or explosion in a nuclear facility.                 |
|  Cat | * |                                                          |
| > 2  | 2 | Not applicable to LBNL.                                  |
+------+---+----------------------------------------------------------+
| >    | \ | Any unplanned fire or explosion in a non-nuclear         |
|  Cat | * | facility that                                            |
| > 3  | 3 |                                                          |
|      |   | a.  Activates a fire suppression system,                 |
|      |   |                                                          |
|      |   | b.  Takes longer than 10 minutes to extinguish following |
|      |   |     the arrival of fire protection personnel, or         |
|      |   |                                                          |
|      |   | c.  Disrupts normal operations in a high hazard          |
|      |   |     facility.                                            |
+------+---+----------------------------------------------------------+
| >    | \ | Any wildland fire (e.g., forest fire, grassland fire) or |
|  Cat | * | other fire outside of a DOE facility that has the        |
| > 4  | 4 | potential to threaten the facility.                      |
+------+---+----------------------------------------------------------+

**Subgroup C Hazardous Energy Control**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+------+---+-----------------------------------------------------------+
| >    | 1 | Failure to follow a prescribed hazardous energy control   |
|  Cat |   | process (e.g., lockout/tagout) or disturbance of a        |
| > 2  |   | previously unknown or mislocated hazardous energy source  |
|      |   | (e.g., live electrical power circuit, steam line,         |
|      |   | pressurized gas) resulting in a person contacting (burn,  |
|      |   | shock, etc.) hazardous energy.                            |
+------+---+-----------------------------------------------------------+
| >    | 2 | Failure to follow a prescribed hazardous energy control   |
|  Cat |   | process (e.g., lockout/tagout) or a site condition that   |
| > 3  |   | results in the unexpected discovery of an uncontrolled    |
|      |   | hazardous energy source (e.g., live electrical power      |
|      |   | circuit, steam line, pressurized gas). This criterion     |
|      |   | does not include discoveries made by zero-energy checks   |
|      |   | and other precautionary investigations made before work   |
|      |   | is authorized to begin.                                   |
+------+---+-----------------------------------------------------------+

[]{#__RefHeading___Toc162777764 .anchor}Group 3 --- Nuclear Safety Basis

**Lab Notes:** Group 3 is not applicable to LBNL.

[]{#__RefHeading___Toc162777765 .anchor}Group 4 --- Facility Status

**Subgroup A Safety Structure/System/Component Degradation**

Subgroup A of Group 4 is not applicable to LBNL.

**Subgroup B Operations**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+------+---+-----------------------------------------------------------+
| >    | \ | A Stop Work Order issued by a DOE office.                 |
|  Cat | * |                                                           |
| > 2  | 1 |                                                           |
+------+---+-----------------------------------------------------------+
|      | 2 | Actuation of a Safety Class Structure, System, or         |
|      |   | Component.                                                |
|      |   |                                                           |
|      |   | Not applicable to LBNL.                                   |
+------+---+-----------------------------------------------------------+
| >    | 3 | Actuation of a Safety Significant Structure, System, or   |
|  Cat |   | Component.                                                |
| > 3  |   |                                                           |
|      |   | Not applicable to LBNL.                                   |
+------+---+-----------------------------------------------------------+
|      | 4 | Any facility evacuation, not including a precautionary    |
|      |   | evacuation, in response to an actual occurrence. If the   |
|      |   | occurrence fell under another reporting criterion, then   |
|      |   | evacuation should be reported as well by noting multiple  |
|      |   | reporting criteria for the single occurrence.             |
+------+---+-----------------------------------------------------------+
| >    | 5 | A facility operational occurrence caused by deviating     |
|  Cat |   | from a written procedure or using an inadequate procedure |
| > 4  |   | resulting in an adverse effect on safety, such as: an     |
|      |   | inadvertent facility or operations shutdown (i.e., a      |
|      |   | change of operational mode or curtailment of work or      |
|      |   | processes); an inadvertent facility or operations         |
|      |   | shutdown due to alarm response procedures; an inadvertent |
|      |   | process liquid transfer; or an inadvertent release of     |
|      |   | hazardous material from its engineered containment.       |
+------+---+-----------------------------------------------------------+
|      | \ | A facility or operations shutdown (i.e., a change of      |
|      | * | operational mode or curtailment of work or processes)     |
|      | 6 | directed by management for safety reasons.                |
+------+---+-----------------------------------------------------------+
|      | 7 | A facility or site stand-down resulting from safety       |
|      |   | reasons reportable as an occurrence or occurrences.       |
|      |   |                                                           |
|      |   | (Note: This is a secondary reporting criterion and does   |
|      |   | not require a separate occurrence report.)                |
+------+---+-----------------------------------------------------------+
|      | 8 | Any occurrence or condition that would prevent immediate  |
|      |   | facility or offsite emergency response capabilities.      |
+------+---+-----------------------------------------------------------+

#######  

**Subgroup C Suspect/Counterfeit and Defective Items or Material**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+------+---+-----------------------------------------------------------+
| >    | 1 | Discovery of any suspect/counterfeit item or material     |
|  Cat |   | found in a Safety Class or Safety Significant Structure,  |
| > 3  |   | System, or Component (SSC).                               |
|      |   |                                                           |
|      |   | Not applicable to LBNL.                                   |
+------+---+-----------------------------------------------------------+
| >    | 2 | Discovery of any suspect/counterfeit item or material     |
|  Cat |   | other than office supplies, office equipment, or          |
| > 4  |   | household products.                                       |
|      |   |                                                           |
|      |   | A suspect item or material is one whose documentation,    |
|      |   | appearance, performance, material, or other               |
|      |   | characteristics may have been misrepresented by the       |
|      |   | vendor, supplier, distributor, or manufacturer. A         |
|      |   | counterfeit item or material is one for which sufficient  |
|      |   | evidence exists that deliberate misrepresentation has     |
|      |   | occurred.                                                 |
+------+---+-----------------------------------------------------------+
|      | 3 | 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.             |
+------+---+-----------------------------------------------------------+

[]{#__RefHeading___Toc162777766 .anchor}Group 5 --- Environmental

> **Lab Notes:**

1.  Contact the LBNL Environmental Services Group (ext. 7614) for all
    environmental releases, and for assistance in mitigation and in
    reporting to local regulatory agencies. If the release involves
    radioactive material, the Environmental Service Group will contact
    the Radiation Protection Group.

2.  ORPS reporting is not required for courtesy notices provided to the
    City of Berkeley for releases that are below reporting thresholds.

3.  There are no areas of critical habitat or jurisdictional wetlands,
    and there are no known historical or archeological sites within the
    Berkeley Lab boundary.

**Subgroup A Releases**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | \ | Any release (onsite or offsite) of a hazardous substance, |
|  Cat | * | material, waste, or radionuclide from a DOE facility that |
| > 2  | 1 | is above permitted levels and exceeds the reportable      |
|      |   | quantities specified in 40 CFR 302 or 40 CFR 355.         |
+------+---+-----------------------------------------------------------+
|      | 2 | Any discharge 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 of 100 barrels   |
|      |   | or more is reportable under this criterion.               |
+------+---+-----------------------------------------------------------+
| >    | 3 | Any release (onsite or offsite) of a hazardous substance, |
|  Cat |   | material, waste, or radionuclide from a DOE facility that |
| > 4  |   | is above permitted levels and exceeds 50 percent of the   |
|      |   | reportable quantities specified in 40 CFR 302 or 40 CFR   |
|      |   | 355.                                                      |
+------+---+-----------------------------------------------------------+
|      | 4 | Any release (onsite or offsite) of a hazardous substance, |
|      |   | material, waste, or radionuclide from a DOE facility that |
|      |   | must be reported to outside agencies in a format other    |
|      |   | than routine periodic reports. (However, oil spills of    |
|      |   | less than 10 gallons and with negligible environmental    |
|      |   | impact need not be reported in ORPS.)                     |
+------+---+-----------------------------------------------------------+

**Subgroup B Ecological and Cultural Resources**

Not applicable to LBNL (see Lab Note 3, above).

[]{#__RefHeading___Toc162777767 .anchor}Group 6 ---
Contamination/Radiation Control

> **Lab Notes:**

1.  The LBNL Radiation Protection Group (ext. 6626) must be contacted
    for all adverse or abnormal radiation-related occurrences,
    regardless of thresholds or significance category. The Radiation
    Protection Group provides immediate assistance to mitigate any
    adverse or abnormal radiation-related incident and to determine the
    reportability of the incident.

2.  The Radiation Protection Group must contact the LBNL Price Anderson
    Amendment Act (PAAA) coordinator for all radiation-related
    incidents.

3.  Radioactive material or sources that are discovered on site and that
    have not been previously included in LBNL inventories or
    authorizations are considered to be found, not lost, and are not
    reportable under Subgroup 6A.

4.  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.

5.  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.

6.  Radioactive contamination is reportable under category 6B to the
    extent that the contamination falls outside areas with exit
    requirements comparable to those listed for Contamination Areas in
    Article 338.2 of DOE STD-1098-99. At LBNL, the radiological controls
    and exit requirements implemented at posted radioactive materials
    areas (RMAs) and radioactive materials storage areas (RMSAs)
    generally meet those in the referenced DOE standard.

7.  In Subgroup 6D(3), Personnel Contamination, the term "site-provided
    protective clothing" will include gloves, protective shoes, or other
    personal protective equipment (PPE), even though the purpose of the
    PPE was not specifically for radiological protection.

8.  10 CFR Part 835, Appendix D, values are in Appendix D of this
    document.

**Subgroup A Loss of Control of Radioactive Materials**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | 1 | Identification of radioactive material off site due to    |
|  Cat |   | DOE operations/activities that exceeds applicable         |
| > 2  |   | DOE-approved authorized limits (pursuant to DOE O         |
|      |   | 5400.5). This applies to items/areas consisting of        |
|      |   | radioactive material. This does not apply to items with   |
|      |   | surface radioactive contamination. See Criterion 6B(1)    |
|      |   | below for criteria for identification of items with       |
|      |   | surface radioactive contamination.                        |
+------+---+-----------------------------------------------------------+
|      | 2 | Loss of radioactive material that exceeds 100 times the   |
|      |   | quantities specified in 10 CFR Part 835, Appendix E       |
|      |   | (excluding consumer products such as smoke detectors), 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.                             |
+------+---+-----------------------------------------------------------+
| >    | 3 | Loss of radioactive material which exceeds 1 times and no |
|  Cat |   | greater than 100 times the quantities specified in 10 CFR |
| > 3  |   | Part 835, Appendix E (excluding consumer products such as |
|      |   | smoke detectors) 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.     |
+------+---+-----------------------------------------------------------+

**Subgroup B Spread of Radioactive Contamination**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | 1 | Identification of radioactive contamination offsite due   |
|  Cat |   | to DOE operations/activities that exceeds applicable      |
| > 2  |   | DOE-approved authorized limits (pursuant to DOE 5400.5)   |
|      |   | or, if there are none, the values found in 10 CFR Part    |
|      |   | 835, Appendix D.                                          |
|      |   |                                                           |
|      |   | \[Note: All releases of property containing or            |
|      |   | potentially containing residual radioactivity are subject |
|      |   | to requirements in DOE 5400.5. Compliance with 10 CFR     |
|      |   | Part 835, Appendix D, values does not necessarily satisfy |
|      |   | the requirements in DOE 5400.5.\]                         |
+------+---+-----------------------------------------------------------+
|      | 2 | Identification of onsite radioactive contamination        |
|      |   | greater than 100 times the total contamination values in  |
|      |   | 10 CFR 835, Appendix D, and that is found outside of the  |
|      |   | following locations: Contamination Areas, High            |
|      |   | Contamination Areas, Airborne Radioactivity Areas,        |
|      |   | Radiological Buffer Areas, and areas controlled in        |
|      |   | accordance with 10 CFR 835.1102(c). For tritium, the      |
|      |   | reporting threshold is 100 times the removable            |
|      |   | contamination values in 10 CFR Part 835, Appendix D.      |
|      |   |                                                           |
|      |   | \[Note: (a) This does not apply to contamination from     |
|      |   | residual radioactive material meeting applicable          |
|      |   | DOE-approved authorized limits;                           |
|      |   |                                                           |
|      |   | \(b\) this also does not apply to legacy radioactive      |
|      |   | contamination, which will be reported under a separate    |
|      |   | criterion below;                                          |
|      |   |                                                           |
|      |   | \(c\) the exclusion from reporting contamination in a     |
|      |   | Radiological Buffer Area applies only when the area has   |
|      |   | been established next to a Contamination Area, High       |
|      |   | Contamination Area, or Airborne Radioactivity Area, and   |
|      |   | when its exit requirements have adopted guidance from     |
|      |   | Article 338.2 of DOE-STD-1098-99.\]                       |
+------+---+-----------------------------------------------------------+

**Subgroup B Spread of Radioactive Contamination (continued)**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+------+---+-----------------------------------------------------------+
| >    | 3 | Identification of onsite radioactive contamination        |
|  Cat |   | greater than 10 times the total contamination values in   |
| > 3  |   | 10 CFR 835, Appendix D, and that is found outside of the  |
|      |   | following locations: Contamination Areas, High            |
|      |   | Contamination Areas, Airborne Radioactivity Areas,        |
|      |   | Radiological Buffer Areas, and areas controlled in        |
|      |   | accordance with 10 CFR 835.1102(c). For tritium, the      |
|      |   | reporting threshold is 10 times the removable             |
|      |   | contamination values in 10 CFR Part 835, Appendix D.      |
|      |   |                                                           |
|      |   | \[Note: (a) This does not apply to contamination from     |
|      |   | residual radioactive material meeting applicable          |
|      |   | DOE-approved authorized limits;                           |
|      |   |                                                           |
|      |   | \(b\) this also does not apply to legacy radioactive      |
|      |   | contamination, which will be reported under a separate    |
|      |   | criterion below;                                          |
|      |   |                                                           |
|      |   | \(c\) the exclusion from reporting contamination in a     |
|      |   | Radiological Buffer Area applies only when the area has   |
|      |   | been established next to a Contamination Area, High       |
|      |   | Contamination Area, or Airborne Radioactivity Area, and   |
|      |   | its exit requirements have adopted guidance from Article  |
|      |   | 338.2 of DOE-STD-1098-99.\]                               |
+------+---+-----------------------------------------------------------+
| >    | 4 | Identification of onsite legacy radioactive contamination |
|  Cat |   | greater than 10 times the total contamination values in   |
| > 4  |   | 10 CFR 835, Appendix D, and that is found outside of the  |
|      |   | following locations: Contamination Areas, High            |
|      |   | Contamination Areas, Airborne Radioactivity Areas,        |
|      |   | Radiological Buffer Areas, and areas controlled in        |
|      |   | accordance with 10 CFR 835.1102(c). For tritium, the      |
|      |   | reporting threshold is 10 times the removable             |
|      |   | contamination values in 10 CFR Part 835, Appendix D.      |
|      |   |                                                           |
|      |   | \[Notes: (a) Legacy radioactive contamination is          |
|      |   | radioactive contamination resulting from historical       |
|      |   | operations that are unrelated to current activities;      |
|      |   |                                                           |
|      |   | \(b\) this does not apply to contamination from residual  |
|      |   | radioactive material meeting applicable DOE-approved      |
|      |   | authorized limits;                                        |
|      |   |                                                           |
|      |   | \(c\) the exclusion from reporting contamination in a     |
|      |   | Radiological Buffer Area applies only when the area has   |
|      |   | been established next to a Contamination Area, High       |
|      |   | Contamination Area, or Airborne Radioactivity Area, and   |
|      |   | its exit requirements have adopted guidance from Article  |
|      |   | 338.2 of DOE-STD-1098-99.\]                               |
+------+---+-----------------------------------------------------------+

**Subgroup C Radiation Exposure**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | \ | Determination of a dose that exceeds the limits specified |
|  Cat | * | in 10 CFR Part 835, Subpart C, Occupational Radiation     |
| > 1  | 1 | Protection; or DOE O 5400.5, Chapter II, Item 1 \[i.e.,   |
|      |   | 100 mrem Total Effective Dose Equivalent (TEDE) for       |
|      |   | offsite exposures to a member of the public\].            |
+------+---+-----------------------------------------------------------+
| >    | 2 | Any unmonitored exposure that exceeds the values for      |
|  Cat |   | providing personnel dosimeters and bioassays as stated in |
| > 2  |   | 10 CFR 835.402(a) or 10 CFR 835.402(c).                   |
+------+---+-----------------------------------------------------------+
| >    | 3 | Any single occupational exposure that exceeds an expected |
|  Cat |   | exposure or dosimetry result by: (1) 500 mrem Committed   |
| > 3  |   | Effective Dose Equivalent (CEDE), or (2) the greater of   |
|      |   | 10 percent or 100 mrem effective dose equivalent due to   |
|      |   | external exposure.                                        |
+------+---+-----------------------------------------------------------+
|      | 4 | Determination of an estimated annual dose that exceeds 10 |
|      |   | mrem Total Effective Dose Equivalent (TEDE) for offsite   |
|      |   | exposures to a member of the public from air pathways     |
|      |   | only.                                                     |
+------+---+-----------------------------------------------------------+

**Subgroup D Personnel Contamination**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | \ | Any occurrence requiring offsite medical assistance for   |
|  Cat | * | contaminated personnel, including transporting a person   |
| > 2  | 1 | to an offsite medical facility or bringing offsite        |
|      |   | medical personnel onsite to perform treatment or          |
|      |   | decontamination.                                          |
+------+---+-----------------------------------------------------------+
|      | 2 | Identification of personnel or clothing contamination     |
|      |   | offsite due to DOE operations that exceeds the values for |
|      |   | total contamination found in 10 CFR Part 835, Appendix D. |
|      |   | For tritium, use the values for removable contamination   |
|      |   | found in 10 CFR Part 835, Appendix D.                     |
+------+---+-----------------------------------------------------------+
| >    | 3 | Any onsite contamination of personnel or clothing         |
|  Cat |   | (excluding site-provided protective clothing) that        |
| > 4  |   | exceeds 10 times the values for total contamination       |
|      |   | 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.                           |
+------+---+-----------------------------------------------------------+

[]{#__RefHeading___Toc162777768 .anchor}Group 7 --- Nuclear Explosive
Safety

> **Lab Notes:** Group 7 is not applicable to LBNL.

[]{#__RefHeading___Toc162777769 .anchor}Group 8 --- Transportation

> **Lab Notes:**

1.  Radiological materials transported using the defined route between
    LBNL and the UC Berkeley Campus are deemed to be onsite transfers.

2.  Onsite 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.

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | \ | Any offsite transportation incident involving hazardous   |
|  Cat | * | materials that would require immediate notice pursuant to |
| > 1  | 1 | 49 CFR Part 171.15, namely:                               |
|      |   |                                                           |
|      |   | \(a\) As a direct result of hazardous materials,          |
|      |   |                                                           |
|      |   | > \(i\) A person is killed;                               |
|      |   | >                                                         |
|      |   | > \(ii\) A person receives injuries requiring             |
|      |   | > hospitalization;                                        |
|      |   | >                                                         |
|      |   | > \(iii\) Estimated property damage exceeds \$50,000;     |
|      |   | >                                                         |
|      |   | > \(iv\) An evacuation of the general public occurs,      |
|      |   | > lasting 1 hour or more;                                 |
|      |   | >                                                         |
|      |   | > \(v\) One or more transportation arteries or facilities |
|      |   | > are closed or shut down for 1 hour or more; or          |
|      |   |                                                           |
|      |   | \(b\) Fire, breakage, spillage, or suspected radioactive  |
|      |   | contamination occurs, involving shipment of radioactive   |
|      |   | materials; or                                             |
|      |   |                                                           |
|      |   | \(c\) Fire, breakage, spillage, or suspected              |
|      |   | contamination occurs, involving shipment of infectious    |
|      |   | substances (etiologic agents); or                         |
|      |   |                                                           |
|      |   | \(d\) There has been a release of a marine pollutant in a |
|      |   | quantity exceeding 450 liters (119 gallons) for liquids,  |
|      |   | or 400 kilograms (882 pounds) for solids; or              |
|      |   |                                                           |
|      |   | \(e\) The operational flight pattern or routine of an     |
|      |   | aircraft is altered.                                      |
+------+---+-----------------------------------------------------------+
| >    | 2 | Any offsite transport of hazardous material, including    |
|  Cat |   | radioactive material, whose quantity or nature (e.g.,     |
| > 3  |   | physical or chemical composition) is different than       |
|      |   | intended, such that the receiving organization's          |
|      |   | operations were impacted/disrupted, or the transport      |
|      |   | resulted in the initiation of corrective actions by the   |
|      |   | originating organization.                                 |
+------+---+-----------------------------------------------------------+

**Group 8** --- **Transportation (continued)**

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+------+---+-----------------------------------------------------------+
| >    | 3 | Any onsite transport of hazardous material, including     |
|  Cat |   | radioactive material, whose quantity or nature (e.g.,     |
| > 4  |   | physical or chemical composition) is different than       |
|      |   | intended, such that the receiving organization's          |
|      |   | operations were impacted/disrupted, or the transport      |
|      |   | resulted in the initiation of corrective actions by the   |
|      |   | originating organization.                                 |
+------+---+-----------------------------------------------------------+
|      | 4 | Any packaging or transportation activity involving the    |
|      |   | onsite release of radioactive materials, etiologic        |
|      |   | agents, hazardous substances, hazardous waste, or marine  |
|      |   | pollutants.                                               |
+------+---+-----------------------------------------------------------+

[]{#__RefHeading___Toc162777770 .anchor}Group 9 --- Noncompliance
Notifications

> **Lab Notes:**

1.  Enforcement action is reportable even if the fine is later reduced
    below \$10,000, or the number of violations is reduced below ten.

2.  Notices of deficiencies related to permit modifications, renewals,
    or reports are not ORPS reportable.

+-----+----+-----------------------------------------------------------+
| **S | *  | **Occurrence Description**                                |
| C** | *N |                                                           |
|     | o. |                                                           |
|     | ** |                                                           |
+=====+====+===========================================================+
| >   | 1  | Any enforcement action (other than associated with the    |
| Cat |    | Price Anderson Amendment Act) involving 10 or more cited  |
| > 3 |    | violations, and/or an assessed fine of \$10,000 or more.  |
|     |    |                                                           |
|     |    | \[Note: This criterion applies to the enforcement action  |
|     |    | as initially received from the regulator. Thus the        |
|     |    | enforcement action would still be reportable even if the  |
|     |    | fine is later reduced below \$10,000 or the number of     |
|     |    | violations reduced below 10.\]                            |
+-----+----+-----------------------------------------------------------+
| >   | 2  | Any written notification from an outside regulatory       |
| Cat |    | agency that a site/facility is considered to be in        |
| > 4 |    | 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 a  |
|     |    | similar type of notification or enforcement action).      |
+-----+----+-----------------------------------------------------------+

#######  

[]{#__RefHeading___Toc162777771 .anchor}Group 10 --- Management
Concerns/Issues

+------+---+-----------------------------------------------------------+
| **   | * | **Occurrence Description**                                |
| SC** | * |                                                           |
|      | N |                                                           |
|      | o |                                                           |
|      | . |                                                           |
|      | * |                                                           |
|      | * |                                                           |
+======+===+===========================================================+
| >    | 1 | Any occurrence resulting in the initiation of a Type A or |
|  Cat |   | B accident investigation as categorized by DOE O 225.1A,  |
| > 2  |   | *Accident Investigation*.                                 |
|      |   |                                                           |
|      |   | \[Note: This reporting criterion may raise the            |
|      |   | significance category of an occurrence already reported   |
|      |   | under separate criteria. Multiple reporting criteria      |
|      |   | should be noted when appropriate.\]                       |
+------+---+-----------------------------------------------------------+
| >    | ^ | An occurrence, condition, or series of occurrences that   |
|  Cat | † | does not meet any of the other reporting criteria, but is |
| >    | ^ | determined by the Facility Manager or line management to  |
| 1--4 | 2 | be of safety significance or of concern to other          |
|      |   | facilities or activities in the DOE complex. One of the   |
|      |   | four significance categories should be assigned to the    |
|      |   | occurrence, based on an evaluation of the potential risks |
|      |   | and the corrective actions taken.                         |
|      |   |                                                           |
|      |   | \[^†^ Note: An SC 1 occurrence report requires Prompt     |
|      |   | Notification.\]                                           |
+------+---+-----------------------------------------------------------+
|      | ^ | A near miss, where no barrier or only one barrier         |
|      | † | prevented an occurrence from having a reportable          |
|      | ^ | consequence. One of the four significance categories      |
|      | 3 | should be assigned to the near miss, based on an          |
|      |   | evaluation of the potential risks and the corrective      |
|      |   | actions taken.                                            |
|      |   |                                                           |
|      |   | \[^†^ Note: An SC 1 occurrence report requires Prompt     |
|      |   | Notification.\]                                           |
+------+---+-----------------------------------------------------------+
| >    | \ | Any occurrence that may result in a significant concern   |
|  Cat | * | by affected state, tribal, or local officials, press, or  |
| > 4  | 4 | general population; that could damage the credibility of  |
|      |   | the Department; or that may result in inquiries to        |
|      |   | Headquarters.                                             |
+------+---+-----------------------------------------------------------+
|      | \ | Any occurrence of such significant immediate interest to  |
|      | * | offsite personnel and organizations that it warrants      |
|      | 5 | 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 \[denoted by having an asterisk (\*)  |
|      |   | next to the occurrence sequence number\].                 |
+------+---+-----------------------------------------------------------+

APPENDIX B

[]{#__RefHeading___Toc162777773 .anchor}ORPS REPORT WORKSHEET

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APPENDIX C

[]{#__RefHeading___Toc162777775 .anchor}SHORT FORM WORKSHEET

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APPENDIX D

[]{#__RefHeading___Toc162777777 .anchor}Surface Contamination Values (10
CFR Part 835, Appendix D)

**This page is intentionally blank.**

**Surface Contamination Values**^1^ **in dpm/100 cm**^2^

  ---------------------------------------------- ---------------------- ---------------------
  **Radionuclide**                               **Removable**^2,\ 4^   **Total (Fixed +
                                                                        Removable)**^2,\ 3^

  U-nat, U-235, U-238, and associated decay      ^7^1,000               ^7^5,000
  products                                                              

  Transuranics, Ra-226, Ra-228, Th-230, Th-228,  20                     500
  Pa-231, Ac-227, I-125, I-129                                          

  Th-nat, Th-232, Sr-90, Ra-223, Ra-224, U-232,  200                    1,000
  I-126, I-131, I-133                                                   

  Beta-gamma emitters (nuclides with decay modes 1,000                  5,000
  other than alpha emission or spontaneous                              
  fission) except Sr-90 and others noted                                
  above^5^                                                              

  Tritium and tritiated compounds^6^             10,000                 N/A
  ---------------------------------------------- ---------------------- ---------------------

^1^ The values in this appendix, with the exception noted in footnote 5,
apply to radioactive contamination deposited on, but not incorporated
into, the interior or matrix of the contaminated item. Where surface
contamination by both alpha- and beta-gamma-emitting nuclides exists,
the limits established for alpha-and beta-gamma-emitting nuclides apply
independently.

^2^ As used in this table, disintegrations per minute (dpm) means the
rate of emission by radioactive material as determined by correcting the
counts per minute observed by an appropriate detector for background,
efficiency, and geometric factors associated with the instrumentation.

^3^ The levels may be averaged over one square meter, provided the
maximum surface activity in any area of 100 cm^2^ is less than three
times the value specified. For purposes of averaging, any square meter
of surface will be considered to be above the surface contamination
value if (1) it is determined from measurements of a representative
number of sections that the average contamination level exceeds the
applicable value, or (2) it is determined that the sum of the activity
of all isolated spots or particles in any 100 cm^2^ area exceeds three
times the applicable value.

^4^ The amount of removable radioactive material per 100 cm^2^ of
surface area should be determined by swiping the area with dry filter or
soft absorbent paper, applying moderate pressure, and then assessing the
amount of radioactive material on the swipe with an appropriate
instrument of known efficiency. (Note: The use of dry material may not
be appropriate for tritium.) When removable contamination on objects of
surface area less than 100 cm^2^ is determined, the activity per unit
area will be based on the actual area, and the entire surface will be
wiped. It is not necessary to use swiping techniques to measure
removable contamination levels if direct scan surveys indicate that the
total residual surface contamination levels are within the limits for
removable contamination.

^5^ This category of radionuclides includes mixed fission products,
including the Sr-90 that is present in them; it does not apply to Sr-90
that has been separated from the other fission products or mixtures
where the Sr-90 has been enriched.

^6^ Tritium contamination may diffuse into the volume or matrix of
materials. Surface contamination evaluations will consider the extent to
which such contamination may migrate to the surface in order to ensure
the surface contamination value provided in this appendix is not
exceeded. Once this contamination migrates to the surface, it may be
removable, not fixed; therefore, a \`\`total\'\' value does not apply.

^7^ (alpha)

APPENDIX E

[]{#__RefHeading___Toc162777779 .anchor}CAUSAL ANALYSIS TREE

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![](media/image2.wmf)