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1.0              PURPOSE

 

This procedure establishes the processes for conducting Occurrence Notification, Reporting, and Action Tracking within the Occurrence Reporting and Processing System (ORPS) Office.

 

 

2.0              RESPONSIBILITIES

 

2.1                           The ORPS Coordinator (or designee):

 

2.1.1     Assigns Occurrence Categorizers to provide 24-hour coverage for categorization of events or conditions.

 

2.1.2     Maintains call list to include Categorizers, Categorizer's Schedule, Department Chair/Division Managers, Facility Managers, Authorized Derivative Classifiers, and DOE Facility Representatives.

 

2.1.3     Supplies, as needed, updates to call list for distribution.

 

2.1.4     Issues and maintains Occurrence Reporting Program Description, Occurrence Reporting and Processing System subject area, the Quality Programs & Services Office's Occurrence Categorizer's Procedure, and the Quality Programs & Services Office's internal ORPS Office Procedure.

 

2.1.5     Provides instructions/direction and assistance to Facility Managers and Categorizers.

 

2.1.6     Provides for internal distribution of occurrence reports to appropriate Laboratory management and staff.

 

2.1.7     Tracks status of occurrence reports and corrective actions in the BNL Assessment Tracking System (ATS) and DOE ORPS database.

 

2.1.8     Reviews BNL occurrence data and analyzes for trends.  Distributes results to Laboratory management.

 

2.1.9          Coordinates self-assessments of the Occurrence Reporting Program to evaluate the effectiveness of the system and to identify areas for improvement.

 

 

3.0              DEFINITIONS

 

3.1        Assessment Tracking System (ATS) – ATS database tool consisting of three levels of information related to an assessment:

           

3.1.1    Assessments:  Any internal or external assessment, investigation, or event report.

 

3.1.2    Conditions:  Findings, issues, concerns, observations, or recommendations found in the assessment.  There may be one or more conditions required for a single assessment.

 

3.1.3     Actions:  The activities (permanent or interim) taken to prevent recurrence of causes associated with a condition.  There may be one or more actions required for a single condition.

 

3.2        Balance-of-Plant (BOP):  Is one of seven BNL “facility” designations in the ORPS database.  The others are Alternating Gradient Synchrotron (AGS), Brookhaven Medical Research Reactor (BMRR), Cold Neutron Facility (CNF), High Flux Beam Reactor (HFBR), National Synchrotron Light Source (NSLS), and Plant Engineering (PE).

 

3.3        Condition:  Any as-found state, whether or not resulting from an event, which may have adverse safety, health, quality assurance, security, operational or environmental implications.  A condition is more programmatic in nature, for example, an error in analysis or calculation; an anomaly associated with design or performance; or, an item indicating a weakness in the management process are all conditions.

 

3.4        Event:  A real-time occurrence (e.g., pipe break, valve failure, loss of power, environmental spills, earthquake, tornado, flood, etc.).

 

3.5        Facility Manager:  That individual, or his or her designee, usually but not always a contractor, who had direct line responsibility for operation of a facility or group of related facilities, including authority to direct physical changes to the facility.

 

3.6        Facility Representative (DOE):  For each major facility or group of lesser facilities, an individual or his or her designee assigned responsibility by the Head of the Field Organization for monitoring the performance of the facility and its operations.  This individual shall be the primary point of contact with the contractor and will be responsible to the appropriate Cognizant Secretarial Officer (CSO) and Head of Field Organization for implementing the requirements of DOE Order 232.1A, Occurrence Reporting and Processing of Operations Information.

 

3.7        Notification Report:  The initial documented report of an event or condition that meets the reporting criteria defined in the Quality Programs & Services Office's Occurrence Categorizer's Procedure.  The Notification Report shall consist of fields 1 through 19 and 25 of the Occurrence Report. 

 

3.8        Occurrence:  An event or a condition that adversely affects, or may adversely affect, DOE or contractor personnel, the public, property, the environment, or the DOE mission. Events or conditions meeting the criteria threshold are identified in the Quality Programs & Services Office's Occurrence Categorizer's Procedure.

 

3.9        Occurrence Categorizer:  BNL maintains a team of Occurrence Categorizers for categorizing events or conditions. The team is composed of individuals who are knowledgeable, experienced, and trained in categorization criteria and the categorization process. When notified of an event or condition, the Occurrence Categorizer, using input from the Department Chair/Division Manager and Subject Matter Experts if needed, will categorize the event or condition according to the criteria established in the Quality Programs & Services Office's Occurrence Categorizer's Procedure.

 

3.10      Occurrence Report:  A documented evaluation of an event or condition that is prepared in sufficient detail to enable the reader to assess its significance, consequences, or implications and to evaluate the actions being proposed or employed to correct the condition or to avoid recurrence.

 

3.11      ORPS:  Occurrence Reporting and Processing System

 

3.12      Program Manager:  The Headquarters individual or designee, designated by and under the direction of a Secretarial Officer, who is directly involved in the operation of facilities under his or her cognizance, and holds signature authority to provide technical direction through Field Element/Operations Office Organizations to contractors for these facilities.

 

3.13      Reportable Occurrence:  Events or conditions to be reported in accordance with the criteria defined in the Quality Programs & Services Office's Occurrence Categorizer's Procedure.

3.1.4          Update Report:  Prepared and issued when intermediate reporting is required:  (1) to supply additional information as it becomes available prior to issuance of the Final Report; (2) when an additional item is added to a Roll-Up Report; (3) any change in categorization is documented in an Update Report which is to be submitted before the close of the next business day from the time of recategorization (not to exceed 80 hours); (4) upon request of DOE; (5) and when the Final Report can not be completed within 45 calendar days, an Update Report is submitted giving a detailed explanation for the delay and the estimated date for submittal of the Final Report.  All fields with an asterisk (*) preceding them are required in the Update Report.  If the required information is not yet available, this fact is so noted.

 

4.0              PREREQUISITES

None

 

 

5.0              PRECAUTIONS

 

None

 

 

6.0              PROCEDURE

 

6.1        Occurrence Notifications:         

 

6.1.1          The ORPS Coordinator receives an initial notification of an ORPS reportable event/condition from the on-shift Occurrence Categorizer.

 

6.1.2          The ORPS Coordinator e-mails a “heads-up” to the Deputy Director for Operations, Quality Programs & Services Office Manager, Price Anderson Amendments Act (PAAA) Coordinator, Public Affairs Office, and the Occurrence Categorizers.

 

6.1.3          The ORPS Coordinator works with the responsible Facility Manager to ensure that a Notification Report is submitted to DOE by close of business on the following business day, but not to exceed 80 hours.

 

6.1.4          The ORPS Coordinator notifies the Deputy Director for Operations when a Balance of Plant Notification Report is ready for submission.  Upon approval the Deputy Director for Operations submits the Balance of Plant Notification Report.  Non-Balance of Plant Notification Reports are submitted by their respective Facility Managers.

 

6.1.5     The ORPS Coordinator receives notice that a Notification Report was submitted.

The ORPS Coordinator e-mails the Notification Report to the Deputy Director for Operations, Quality Programs & Services Office Manager, Public Affairs Office, Price Anderson Amendments Act (PAAA) Coordinator, Lessons Learned Coordinator, and the Occurrence Categorizers.

 

6.1.6     The Assessment Tracking System (ATS) Administrator, upon notification by the ORPS Coordinator, enters the assessment/condition/action per exhibits B, C, and D into ATS assigning an Update/Final Report due date 40 days from the time of initial Categorization.

 

6.2        Occurrence Investigation and Reporting:

 

6.2.1     The Quality Programs & Services Office (QP&SO) will assist in identifying similar recent BNL occurrences to determine if programmatic issues exist and make known that a Laboratory-Level corrective action is warranted.  Programmatic findings will be reported to the QP&SO Office Manager and the Price Anderson Amendments Act (PAAA) Coordinator.  The QP&SO Manager will communicate programmatic findings to the Assistant Laboratory Director for Environment, Safety Health & Quality and the Deputy Director for Operations.

 

6.2.2          The Facility Manager notifies the ORPS Coordinator that a draft Update/Final Report is in ORPS for review.

 

6.2.3     Upon request, the ORPS Coordinator reviews the Update/Final Report and makes recommendations for revision as required.

 

6.2.4     The ORPS Coordinator notifies the Deputy Director for Operations when a draft Update/Final Report is ready for review and submission into ORPS.

 

6.2.5          If the Deputy Director for Operations deems the draft Update/Final Report not satisfactory, the Facility Manager must revise it.

 

6.2.6          The Deputy Director for Operations notifies the ORPS Coordinator that an Update/Final ORPS Report was approved and submitted into ORPS. The ATS Administrator upon notification by the ORPS Coordinator will close the “reporting” action and condition.  If there are any open corrective actions, the ATS Administrator will add a condition and enter any open corrective actions into ATS per exhibits E and F.

 

6.3        Report Follow-up and Action Close Out:

 

6.3.1          The ORPS Coordinator will review the status of Occurrence Reports in the ORPS database on a daily basis.

 

6.3.2          In the event that either the DOE Facility Representative or the DOE Program Manager rejects an Update/Final Report, the ATS Administrator will enter a revision due date into ATS via a new condition and action per exhibits G and H.  The revised due date shall be 16 days from the notice of Report rejection. 

 

Complete steps 6.2.2 – 6.2.6 as described under Occurrence Investigation and Reporting.

 

6.3.3     The ATS Administrator receives ORPS action closure forms from respective Owners/Delegates of actions and forwards this closure request to the ORPS Coordinator for ATS closure approval.

 

6.3.4     Upon receiving ORPS Coordinator approval, the ATS Administrator closes ORPS actions in ATS and the ORPS Coordinator does same in the ORPS database.

 

6.3.5     The Facility Manager/Delegate may extend an action due date by filling out the “Create/Update Action” form on ATS.

 

6.3.6     When all corrective actions are closed and concurrence is gained from the Assessment Owner/Delegate, the ATS Administrator will close the “Assessment” in ATS.

 

6.4        Tracking and Trending:

 

6.4.1     On a monthly basis, the ORPS Coordinator will track and graph the following, which is presented to the Deputy Director for Operations:

           

6.4.1.1  ORPS report status to include:

·         Status of DOE review

·         Number of rejected reports

·         Number of overdue reports

·         Number of open reports

·         Number of new reports

 

6.4.1.2  ORPS corrective action status to include:

·         Number of overdue actions

·         Number of open actions

 

6.4.1.3  BNL ORPS by Calendar Year Report Submitted.

 

6.4.1.4  ORPS Reports and Actions (by Directorate) to include:

·         Reports overdue

·         Reports not overdue

·         Actions overdue

·         Actions not overdue

 

6.4.2     On a quarterly basis, the ORPS Coordinator will track and evaluate all ORPS events for trends and potential emerging issues. Evaluation results will be submitted to the Deputy Director for Operations.  Tracking and Trending information is presented at a quarterly workshop for the Occurrence Categorizers.

  

 

7.0              IMPLEMENTATION AND TRAINING

 

7.1        Training and indoctrination of ORPS Office staff, outside technical specialists, consultants, adjunct staff, and other supporting staff to this instruction is satisfied through on-the-job training and required reading.

 

 

8.0              RERERENCES

 

8.1        10 CFR 830, Subpart A - Quality Assurance Requirements.

 

8.2        DOE Order 414.1A, Quality Assurance.

 

8.3        DOE Order 5480.19 Chg. 1, Conduct of Operations Requirements for DOE Facilities.

 

8.4        BNL Management System Description, "Integrated Assessment Program."

 

8.5                BNL Management System Description, “Emergency Preparedness and Off-Normal Event Reporting.”

 

8.6                SBMS Subject Area, “Occurrence Reporting and Processing System (ORPS).”

 

8.7        SBMS Program Description, “Occurrence Reporting Program Description.”

 

8.8        Quality Programs & Services Office Procedure, “Occurrence Categorizer’s Procedure.”

 

8.9        DOE Order 232.1A, Occurrence Reporting and Processing of Operations Information.

 

8.10      DOE Order 151.1A Chg. 2, Comprehensive Emergency Management System.

 

 

9.0       ATTACHMENTS

 

9.1        Exhibit A:  ORPS Office Process Flow.

 

9.2        Exhibit B:  ORPS Assessment Template.

 

9.3        Exhibit C:  ORPS Condition Template.

 

9.4        Exhibit D:  ORPS Action Template.

 

9.5        Exhibit E:  ORPS Condition for Corrective Action Plan Template.

 

9.6               Exhibit F:  ORPS Corrective Action Template.

 

9.7               Exhibit G:  ORPS Condition Rejected Report Template.

 

9.8               Exhibit H:  ORPS Action Rejected Report Template.