BROOKHAVEN NATIONAL LABORATORY

**Issue and Decision Paper**

**[Issue]{.underline}:** Approval and implementation of the SBMS Program
Description "Occurrence Reporting Program Description" and the SBMS
Subject Area "Occurrence Reporting and Processing System (ORPS)."

**[Decision Maker:]{.underline}** John H. Marburger III, Laboratory
Director

**[Originator]{.underline}:** SBMS Steering Committee, T. Sheridan, K.
Brog, and the Program Description/Subject Area Development Team: L.
Kimmel (Facilitator), E. Sierra (SME), J. Maraviglia, N. Gmur, J.
Higgins, R. Kinkead, K. Krasner, E. Lessard, P. Williams, G. Shepherd,
D. Warren, M. Zarcone

**[Background:]{.underline}**

DOE requires the reporting, investigation, and analysis of occurrences
as an important element in mitigating occurrences at DOE facilities. The
primary requirement for DOE contractors to report occurrences is
mandated in DOE Order 232.1A, *Occurrence Reporting and Processing of
Operations Information.* In order to meet the objective of DOE Order
232.1A, the Occurrence Reporting and Processing System (ORPS) subject
area (https://sbms.bnl.gov/standard/20/2000t011.htm) provides procedures
for implementing the Occurrence Reporting Program Description
(https://sbms.bnl.gov/program/pd05/pd05d011.htm) and identifies the
process for staff and management who perform specific duties related to
discovery, response, notification, investigation, and reporting of
occurrences to BNL and DOE management. In accordance with DOE Order
232.1A, all staff are required to appropriately report abnormal events
or conditions that they perceive may

-   endanger the health and safety of staff or the public,

-   have an adverse effect on the environment,

-   seriously impact the operations and intended purpose of BNL
    facilities,

-   result in loss or damage of property, or

-   adversely affect national security or the security interest of DOE
    or BNL.

    As per DOE Order 232.1A, "Implementation procedures shall be
    submitted for approval to the responsible DOE Secretarial Office
    within 4 months of incorporation of the requirements in the
    Contractor Requirements Document into a new or existing contract."
    In addition, "Implementation procedures shall be considered
    automatically approved 2 months after submittal, if they are not
    deliberately approved or rejected by DOE prior to the automatic
    approval."

At this time in order to meet DOE Order 232.1 and DOE Manual 232.1-1,
BNL has in effect Environmental Safety & Health Standard 1.1.0
Occurrence Reporting System, Rev. 5. However, this standard has not been
updated to reflect DOE Order 232.1A, and DOE Manual 232.1-1A,
*Occurrence Reporting and Processing of Operations Information*, dated
July 21, 1997.

**[Discussion]{.underline}:**

The reporting, investigation, and analysis of occurrences is an
important element in mitigating occurrences at DOE facilities. Reporting
of occurrences is a management tool useful in ensuring that
organizations do not repeat the same mistakes. In order to make
effective use of this tool, BNL staff and managers must be aware of the
purpose of occurrence reports and the process for preparing them.

Evaluations of the BNL Occurrence Reporting Program as it exists now
indicate the following problems: There are multiple department specific
occurrence reporting procedures resulting in inconsistencies and lack of
standardization throughout BNL. The DOE ORPS database contains BNL
reports that have been waiting to be finalized since 1997. There are
also BNL corrective actions that have not been implemented going back to
1992. Clearly, the BNL Occurrence Reporting Program has lacked
management attention. No centralized responsibility for the Occurrence
Reporting Program has been defined. Accordingly, DOE and Brookhaven
Science Associates (BSA) both agree that the program requires
improvement

In an effort to improve the Occurrence Reporting Program, an Occurrence
Reporting Program Description and a subject area for Occurrence
Reporting and Processing System (ORPS) have been written. This new
program description defines responsibilities for occurrence reporting.
The ORPS program will be disseminated Lab-Wide under the authority of
the Deputy Director, Operations. Most importantly, an ORPS Office within
the Independent Oversight Office will be charged with the oversight,
evaluation, and maintenance of the reporting program. The ORPS Office
will consist of an ORPS Coordinator and Administrator. The new program
will establish a cadre of qualified BNL Categorizers on a rotating
schedule, available 24 hours a day 7 days a week to make determination
of event reportability. A single lab-wide procedure for event
categorization has been developed. Subject matter experts will assist
line management in causal factor analysis and determination of
appropriate and effective corrective actions. In addition, a new
Laboratory Assessment Tracking System (ATS) will be used to track
update/final reports and corrective actions to completion.

**[Options]{.underline}:**

A.  Do not publish the Program Description and Subject Area as part of
    SBMS.

[NOTE:]{.underline} This option will require Environmental Safety &
Health Standard 1.1.0 Occurrence Reporting System, Rev. 5 to be updated
to reflect DOE Order 232.1A, and DOE Manual 232.1-1A, *Occurrence
Reporting and Processing of Operations Information*, dated July 21, 1997
and will allow department specific procedures to remain in effect.

B.  Publish the Program Description and Subject Area as part of SBMS.

**[Recommendation]{.underline}:**

Adopt Option B. This option will result in a centralized ORPS Office
staffed by an ORPS Coordinator and Administrator. The ORPS Office will
be charged with the oversight, evaluation, and maintenance of the
reporting program. In addition, a cadre of qualified BNL Categorizers
will be available on a rotating schedule, available 24 hours a day, 7
days a week to make a determination of event reportability. There is no
added cost to implement this action.

**[Decision]{.underline}:** Option B approved

**[Proposed Implementation Schedule and/or Milestones]{.underline}:**

-   Post the Program Description and the Subject Area on the SBMS Web
    Site within five days of the Director's approval of the Issue and
    Decision Paper.

-   In addition to utilizing the SBMS subscription service, issue an
    E-mail to all staff informing them that the Program Description and
    Subject Area has been approved.

/s/John Marburger 4/25/00

Signature (Decision-maker Approval) date