Contents

Approved by Andrew Peterson
Revised 5/24

15.1 Policy
15.2 Scope
15.3 Applicability
15.4 Definitions, Roles and Responsibilities 

• 15.4.1 Definitions
• 15.4.2 Employees, Affiliates, and Subcontractors
• 15.4.3 Supervisors and Activity Leads
• 15.4.4 Division Directors
• 15.4.5 Environment, Health and Safety (EHS) Division
• 15.4.6 Office of the Chief Operating Officer
• 15.4.7 Office of Institutional Assurance and Integrity

15.5 Process Overview
15.6 Required Work Processes

• 15.6.1 Work Process A. Discovery, Reporting, and Preliminary Review
• 15.6.2 Work Process B. Categorization
• 15.6.3 Work Process C. Notification
• 15.6.4 Work Process D. Occurrence Investigation and Analysis
• 15.6.5 Work Process E. Final and Update Reports
• 15.6.6 Work Process F. Training

Appendices 

• Appendix A. DOE ORPS Reporting Criteria
• Appendix B. Notification and Reporting Matrix
• Appendix C. Causal Analysis Tree

Note:
🚩🚩    Denotes a new section

🚩    Denotes the beginning of changed text within a section

🛑    Denotes the end of changed text within a section

____________________

15.1 Policy

Lawrence Berkeley National Laboratory (Berkeley Lab) strives to prevent injuries and illnesses; environmental damage; significant business, facility, and community disruptions; and regulatory noncompliance. If these types of occurrences happen, Berkeley Lab will determine if they meet Department of Energy (DOE) O 232.2A, Chg 1 (MinChg), Occurrence Reporting and Processing of Operations Information, criteria and if so, notify DOE and prepare and submit occurrence reports as documented in this Environment, Safety and Health (ES&H) Manual Chapter.

15.2 Scope

This Chapter documents Berkeley Lab’s process for implementing DOE O 232.2A, Chg 1 (MinChg). The scope of this chapter is limited to occurrences meeting applicable criteria defined in DOE O 232.2A, Chg 1 (MinChg). Safeguard and security events are not reported into ORPS unless they involve other consequences that meet a DOE O 232.2A, Chg 1 (MinChg) criterion.

15.3 Applicability

Per DOE O 232.2A, Chg 1 (MinChg), occurrence reporting requirements apply to the contractor (Berkeley Lab) and Berkeley Lab subcontractors at any tier.  All Berkeley Lab divisions and departments, including affiliates and subcontractors performing work for the Laboratory, are subject to the requirements of this chapter with the following exceptions:

1. Visitors, UC students and other personnel who are onsite but are not engaged in work subcontracted by Berkeley Lab.
2. Other DOE contractors (e.g., LLNL, SLAC, etc.) experiencing an ORPS reportable event while performing work at a Berkeley Lab facility.  Those will be reported through the DOE contractor’s home institution.  
3. UC staff in situations covered by an active Memorandum of Understanding between DOE, University of California and Berkeley Lab which explicitly excludes the work from the requirements of this chapter.

The requirements in DOE O 232.2A, Chg 1 (MinChg), Attachment 1 – 5 have been reviewed and found to be applicable, with the exception of the following criteria:

• Attachment 1, Section 2, Security Requirements
• Attachment 2, Group 2, Subgroup B, Criteria 1 and 3
• Attachment 2, Group 3, Nuclear Safety Basis
• Attachment 2, Group 4, Subgroup A
• Attachment 2, Group 4, Subgroup B, Criteria 2 and 3
• Attachment 2, Group 4, Subgroup C, Criterion 1
• Attachment 2, Group 7, Nuclear Explosive Safety

The above listed criteria are not applicable to LBNL because LBNL is not a nuclear facility and does not have Classified or Controlled Unclassified Information.

15.4 Definitions, Roles and Responsibilities

15.4.1 Definitions

Definitions are included in DOE O 232.2A, Chg 1 (MinChg).  For clarity, the following definitions are provided here:

• Condition: Any as-found state, whether or not resulting from an event, that may have adverse safety, health, quality assurance, operational, or environmental implications. A condition is usually programmatic in nature; for example, errors in analysis or calculation; anomalies associated with design or performance; or items indicating a weakness in the management process.
• Event: Something significant and real-time that happens (e.g., pipe break, valve failure, loss of power, environmental spill, earthquake, tornado, flood, injury).
• Occurrence: Events or conditions that adversely affect, or may adversely affect, DOE (including NNSA) or contractor personnel, the public, property, the environment, or the DOE mission.

15.4.2 Employees, Affiliates, and Subcontractors

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

15.4.3 Supervisors and Activity Leads

Supervisors and activity leads should ensure that employees understand workplace health and safety reporting responsibilities. When a supervisor or activity lead learns of an occurrence, he or she must ensure appropriate authorities are notified.  This typically includes notifying the division safety coordinator and/or the EHS Division.

15.4.4 Division Directors

Division directors must ensure appropriate resources are available to report events in a timely manner, investigate occurrences, and institute corrective actions to prevent recurrence.  This includes overseeing the dissemination of relevant information to appropriate personnel and implementation of lessons learned to improve operations.

Division directors are responsible for approving occurrence categorization and any reports submitted to DOE.  Where occurrence categorization is not clear, or for management concerns and issues, the division director must decide or agree that the occurrence is DOE reportable. EHS can assist with this determination.

Division directors may assign designees from their organizations to help implement these procedures.  (Note: For the purposes of this Chapter, division directors are typically considered the Facility Manager as defined by DOE O 232.2A, Chg 1 (MinChg).)

15.4.5 Environment, Health and Safety (EHS) Division

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

15.4.6 Office of the Chief Operating Officer (OCOO)

The Deputy Laboratory Director for Operations / Chief Operating Officer or designee communicates ORPS reportable occurrences to the DOE site manager.

15.4.7 Office of Institutional Assurance and Integrity

The Office of Institutional Assurance and Integrity (OIAI) maintains and provides oversight for the Issues Management Program.  The products of the program are used, when applicable, in the preparation of Final Reports.

15.5 Process Overview

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

15.6 Required Work Processes

15.6.1 Work Process A. Discovery, Reporting, and Preliminary Review

Occurrences are discovered in a variety of ways, such as observations by workers, notifications from external agencies, internal assessments, etc. A worker must promptly report unsafe or abnormal events and conditions according to division policies and procedures. Divisions must then determine if the occurrence is potentially ORPS reportable, and if so, report this to the EHS Division. If the occurrence is not considered ORPS reportable then consideration should be given to whether or not the event is reportable at the “site” or “subORPS” level. If the occurrence is potentially site or subORPS reportable, report this to the EHS Division.

Each occurrence must then be reviewed to determine if it meets a DOE reporting criterion. Divisions may work collaboratively with EHS to make this determination, or they can make an initial assessment of reportability. In the latter case, the division must notify EHS of their determination and EHS will either validate this assessment or discuss the assessment with the division until consensus is reached.

15.6.2 Work Process B. Categorization

To categorize, an occurrence is compared against the criteria established in DOE O 232.2A, Chg 1 (MinChg) (documented in Appendix A). If the occurrence meets any of the criteria, it is reportable to DOE. Report Levels assigned to each criteria determine notification, analysis, and reporting requirements (see Appendix B).

Most DOE criteria are triggered by exceeding a specific threshold making categorization straightforward. Group 10, Management Concerns and Issues, is more subjective, particularly Criterion 1 for Management Concern, which historically accounts for approximately 30% of Berkeley Lab’s reportable occurrences. In instances where the criterion is questionable, division directors or their designees must make the final decision on categorization, although EHS may provide input into the decision-making process. In time sensitive situations, EHS staff may initially categorize occurrences in the absence of division directors or designees, and later confirm the categorization with division management.

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

If the event or condition is not reportable under DOE O 232.2A, Chg 1 (MinChg), it is typically considered a site or subORPS reportable event or condition and will be recorded as appropriate for tracking and trending purposes.

15.6.3 Work Process C. Notification

After an occurrence is determined to be DOE reportable and properly categorized, the Department of Energy will be notified. Internal notification to the Berkeley Site Office (BSO) will be managed as discussed below. The EHS Division will notify DOE through the ORPS process. EHS will also prompt divisions to consider the funding structure as well as the line management structure so all DOE points of contact are notified and can respond accordingly.

For this to happen, divisions must provide EHS with preliminary details of the occurrence.

Initial Notification

LBNL will first notify BSO using one or more of the following methods:

• An automated email from the “Alert from the Lab’s Institutional Notification System”
• Phone call and/or e-mail 

This notification will include a brief summary of the occurrence and the reporting group, subgroup (when applicable), criterion number, and report level. For high and low report level occurrences, LBNL must report within 2 hours of categorization.  Informational report level occurrences must be reported by the close of business on the business day after categorization.

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

Written Notification/Final Report

Following Initial Notification, EHS must submit a Written Notification into the online DOE Occurrence Reporting database. The Written Notification contains all relevant details known at the time and must be submitted within the timeline provided in Appendix B or as soon as reasonably possible.  For informational and low report level occurrences, the Written Notification is the Final Report.  For high report level occurrences, additional investigation is required and a final report due within 60 days.  For informational report level occurrences that are unlikely to provide any lesson learned or value to the DOE complex, LBNL with concurrence from the Berkeley Site Office, may choose not to enter the occurrence into the ORPS database.  In these cases, the occurrence will be added to the site reportable database. 

15.6.4 Work Process D. Occurrence Investigation and Analysis

Occurrences must be investigated and analyzed following a graded approach in accordance with LBNL’s Issue Management Program. Staff charged with leading an investigation must consider the significance or potential significance of the event when choosing the scope and tools to use in the investigation.

For high report level occurrences, identified causes, corrective actions, and any extent of condition (if performed) must be included in the Final Report.  Lessons learned must be considered in accordance with LBNL’s Issues Management Program. Any lessons learned developed from the event must be included or summarized in the Final Report.

15.6.5. Work Process E. Report Preparation

Occurrence reports must be written clearly and concisely so the general reader can understand the basic “who, what, when, where, how” of the event and safety issues involved. Reports must quantify the level of contamination, dose, exposure, release, and damage (e.g., estimate the acres of wild land burned) when possible, instead of merely stating a reportable limit was exceeded.

Final high report level occurrences must contain the following information:

1. A description of occurrence that contains the background and description of the event at a sufficient level of detail for the reader to understand what happened and the resulting consequences and actions.
2. Identified causes and corrective actions.
3. Applicable causal codes (see Appendix C).
4. Any extent of condition (if performed).

Reports on suspect/counterfeit and defective items or material, must provide the manufacturer/supplier/vendor (including a contact, phone number, and website); the model and part numbers; the quantity found; why the item/material is suspect/counterfeit or defective; and how the item/material is being used. Reports must also include the method of detection (i.e., craft inspection prior to installation, in-service inspection, or failure) and identify any resulting consequences, along with any photos via attachments, as appropriate. In some instances, the information may be considered sensitive (such as contact names and phone numbers). In those instances, the information need not be included in the occurrence report but may be obtained by contacting the Originator of the occurrence report.

If the Final Report will not be completed within 60 days, divisions must communicate this to EHS.  EHS will request a DOE extension in an Update Report filed within the original 60 days. The Update Report must include a detailed explanation of the delay in the “Facility Manager’s Evaluation” field and provide an estimated completion date.

Report Approval

The responsible division director must approve the Final Report prior to submission to DOE.

Report Closure

Within 14 calendar days after finalizing a high report level occurrence, the Facility Representative or Designated DOE Representative must review the report with regard to the requirements of this Order and approve, reject, and add comments, as necessary. If the Final Report is rejected by the applicable Facility Representative or Designated DOE Representative, the Representative must provide the reason for rejection. A revised Final Report must be resubmitted within 21 calendar days of the rejection. If the revised report cannot be resubmitted within this time, an update to the Occurrence Report must be submitted explaining the delay and providing an estimated date for resubmittal.

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

15.6.6 Work Process F. Training

As part of their Berkeley Lab orientation, employees, supervisors, affiliates, and subcontractors receive basic instructions for reporting unsafe conditions and abnormal events. ORPS-specific training will be provided as needed. 

Appendices

Appendix A. DOE ORPS Reporting Criteria

Group 1 – Operational Emergencies

High	1. An Operational Emergency, Alert, Site Area Emergency, or General Emergency as defined in DOE O 151.1D

Group 2 – Personnel Safety and Health

Subgroup A – Occupational Injuries and Exposures
High	1. Any occurrence due to DOE operations resulting in a fatality or terminal injury/illness.
High	2. Any single occurrence, injury, or exposure requiring in-patient hospitalization of three or more personnel.
High	3. Any single occurrence, injury, or exposure resulting in an occupational injury that requires in-patient hospitalization for five or more days, commencing within seven days from the date the injury.
Low	4. Any single occurrence, injury, or exposure resulting in three or more personnel having Days Away, Restricted or Transferred (DART) cases per 29 CFR Section 1904.7, Recordkeeping Forms and Recording Criteria.
Low	5. Any single occurrence resulting in an occupational injury or exposure that*: (a) Requires in-patient hospitalization for more than 48 hours, commencing within seven days from the date the injury or exposure was received; (b) Results in a fracture of any bone (except bone chips; simple fractures of fingers, toes, or nose; or a minor chipped tooth); (c) Causes severe hemorrhages or severe damage to nerves, muscles, tendons, or ligaments (Note: Severe damage is generally considered to have occurred if surgery is required to correct the damage.); (d) Damages any internal organ; (e) Causes 1) a concussion, or 2) loss of consciousness due to an impact to the head, or (f) Causes second or third-degree burns, affecting more than five percent of the body surface.
High	6. Personnel exposure to chemical, biological, or physical hazards that exceed 10 times the limits established in 10 CFR Part 851, Worker Safety and Health Program (see 10 CFR Section 851.23 Safety and Health Standards) or exceed levels deemed Immediately Dangerous to Life and Health (IDLH).
Low	7. Personnel exposure to chemical, biological or physical hazards above limits established in 10 CFR Part 851, Worker Safety and Health Program (see 10 CFR Section 851.23, Safety and Health Standards), but below levels deemed IDLH.

Subgroup B – Fires
High	1. Not applicable to LBNL
High	2. Any fire that: (a) Activates a fixed automatic fire suppression system (e.g., clean agent or wet-pipe automatic sprinkler protection), (b) Takes longer than ten minutes to extinguish following the initiation of firefighting efforts by the emergency response organization, or (c) Disrupts normal operations in the facility for more than four hours.
Info	3. Not applicable to LBNL
Info	4. Any wild land fire (e.g., forest fire, grassland fire) or other fire outside a DOE facility that has the potential to threaten the facility.

Subgroup C – Explosion
High	1. Any unplanned explosion that disrupts normal operations.

Subgroup D – Hazardous Energy
High	1. Any unexpected or unintended personal contact (e.g., burn, shock, injury, etc.) with a hazardous energy source (e.g., live electrical power circuit, mechanical hazards, steam, pressurized gas, etc.).
Low	2. Any failure to follow a prescribed hazardous energy control process that results in potential worker exposure to uncontrolled hazardous energy (e.g., live electrical power circuit, powered mechanical hazards, steam, pressurized gas, etc.); OR any discovery of an uncontrolled hazardous energy source (e.g., live electrical power circuit, powered mechanical hazards, steam, pressurized gas, etc.). This criterion does not include discoveries made by zero-energy checks and other precautionary investigations made before work is authorized to begin.

Group 3 – Nuclear Safety Basis (Not applicable to LBNL)

Group 4 – Facility Status

Subgroup A – Safety Structure/System/Component Degradation (Nuclear Facilities) (Not applicable to LBNL)

Subgroup B – Operations
High	1. A formal shutdown of an activity or operation for safety reasons, directed by the DOE Field Element Manager, Contracting Officer or senior contractor management requiring corrective actions prior to continuing operations (e.g., a Stop Work Order).
High	2. Not applicable to LBNL
Low	3. Not applicable to LBNL
Low	4. A facility operational event which resulted in an adverse effect on safety, such as, but not limited to: (a) an inadvertent facility or operations shutdown (i.e., a change of operational mode or curtailment of work or processes); (b) a manual facility or operations shutdown due to alarm response procedures; (c) an inadvertent process liquid transfer; or (d) an inadvertent release of hazardous material from its engineered containment.
Info	5. Any event or condition that would prevent immediate facility or offsite emergency response capabilities.

Subgroup C – Suspect/Counterfeit and Defective Items or Material
Low	1. Not applicable to LBNL
Info	2. Discovery of any other suspect or counterfeit item or material [i.e., not found in a SC or SS SSC] that is found in any application whose failure could result in a loss of safety function, or present a hazard to public or worker health and safety.
Info	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.

Group 5 – Environmental

Subgroup A – Releases
Low	1. Any release (onsite or offsite) of a hazardous or extremely hazardous substance, including radionuclides from a DOE facility above federally permitted releases in a quantity equal to or exceeding the federal reportable quantities specified (See specifications in 40 CFR Part 302, Designation, Reportable Quantities, and Notification; 40 CFR Part 355, Emergency Planning and Notification; and CERCLA Section 101(10), Federally Permitted Releases.)
Info	2. Any release (onsite or offsite) of a pollutant from a DOE facility that is above levels or limits specified by outside agencies in a permit, license, or equivalent authorization, when reporting is required in a format other than routine periodic reports. [Note: This criterion does not apply to the following: * Discharges (including potable water) that do not result in leaching or erosion of contaminated material from a known or suspected boundary of a Potential Release Site. * Discharges (including potable water) capable of reaching surface or groundwater that do not require remediation/repair. (The contractor’s environmental subject matter experts make the determination of environmental impact and the need for remediation/repair activities.)]
Info	3. Any release (onsite or offsite) that exceeds 100 gallons of oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil. For operations involving oil field crude or condensate, any discharge that must be reported to outside agencies in a format other than routine periodic reports is reportable under this criterion.
Info	4. Any discrete release of sulfur hexafluoride (SF6) due to an event or DOE operation equal to or exceeding 115 pounds (1,247 metric tons of CO2e according to 40 CFR Part 98, Subpart A, Table A-1, Global Warming Potentials) or 115 pounds more than the normal release quantity if the SF6 release is a common byproduct of the operation.
Low	5. Any release or spill (onsite or offsite) of per-and polyfluoroalkyl substances (PFAS)-containing Aqueous Film Forming Foam (AFFF).

Subgroup B – Ecological and Cultural Resources
High	1. Any occurrence including releases causing significant impact to ecological or cultural resource for which DOE has responsibility under applicable laws, regulations, and Executive Orders. For example, extensive damage to, or destruction of: (a) Ecologically preserved areas, or pristine or protected wetlands; (b) Threatened or protected flora or fauna or critical habitats; (c) Potable drinking water intake or well usage; or (d) Historical/archeological sites.
High	2. Any occurrence, including releases, resulting in extensive environmental degradation (e.g., fish kill; notable loss or relocation of native species; need for interdiction of crop sales; or restriction to human access).

Group 6 – Contamination/Radiation Control

Subgroup A – Loss of Control of Radioactive Materials
High	1. Identification of radioactive material offsite due to DOE operations/activities that exceeds applicable DOE limits (pursuant to DOE O 458.1 Chg 3, Radiation Protection of the Public and the Environment, dated 1-15-13).
High	2. Loss or unexpected discovery of radioactive material that exceeds 100 times the values in 10 CFR Part 835, Occupational Radiation Protection, Appendix E (excluding consumer products such as smoke detectors, if they are handled in accordance with manufacturer’s instructions), or loss of accountability of such material for more than 24 hours. The 24 hour time period begins when the loss of accountability is discovered and must include one business day.
Low	3. Loss or unexpected discovery of radioactive material which exceeds one times and no greater than 100 times the values in 10 CFR Part 835, Appendix E (excluding consumer products such as smoke detectors, if they are handled in accordance with manufacturer’s instructions) or loss of accountability of such material for more than 24 hours. The 24 hour time period begins when the loss of accountability is discovered and must include one business day. Note: Legacy radioactive material discovered through a routine radiological monitoring program, compliant with 10 CFR Part 835 may be summarized in a single occurrence report, for example, on a quarterly basis. Each instance of legacy radioactive material must be identified in the report and contain the details required for reporting in accordance with this Order.

Subgroup B – Spread of Radioactive Contamination
High	1. Identification of offsite radioactive contamination due to DOE operations/activities that exceeds applicable DOE approved authorized limits (pursuant to DOE O 458.1 Chg 3, Radiation Protection of the Public and the Environment, dated 1-15-13) or, if there are none, the total contamination values in 10 CFR Part 835, Appendix D.  [Note: Release or clearance of property containing or potentially containing residual radioactive material is subject to requirements in DOE O 458.1 Chg 3. Compliance with 10 CFR Part 835, Appendix D values does not necessarily satisfy the requirements in DOE O 458.1 Chg 3.]
High	2. Identification of onsite radioactive contamination greater than 100 times the total contamination value in 10 CFR Part 835 Appendix D, exclusive of footnote 3 to Appendix D, and that is found outside of the following locations: areas routinely posted controlled, and monitored for contamination; areas controlled in accordance with 10 CFR Section 835.1102(c); and, per 10 CFR Section 835.604(a), any non-posted area that is under the continual observation and control of an individual knowledgeable of and empowered to implement required access and exposure control measures. For tritium, the reporting threshold is 100 times the removable contamination values in 10 CFR Part 835, Appendix D.  Notes: * This does not apply to surface contamination from residual radioactive material meeting applicable DOE approved authorized limits. * This does not apply to legacy contamination that is to be reported under a separate criterion below. * The discovery of radioactive contamination from a past DOE/NNSA operation that may have caused, is causing, or may reasonably be expected to cause an uncontrolled personnel exposure exceeding protective action criteria may be reportable as an Operational Emergency under Group 1, Criterion 1.
Low	3. Identification of onsite radioactive contamination greater than 10 times and no greater than 100 times the total contamination values in 10 CFR Part 835, Appendix D, exclusive of footnote 3 to Appendix D, and that is found outside of the following locations: areas routinely posted, controlled, and monitored for contamination; areas controlled in accordance with 10 CFR Section 835.1102(c); and, per 10 CFR Section 835.604(a), any non-posted area that is under the continual observation and control of an individual knowledgeable of and empowered to implement required access and exposure control measures. For tritium, the reporting threshold is 10 times the removable contamination values in 10 CFR Part 835, Appendix D. Notes: * This does not apply to surface contamination from residual radioactive material meeting applicable DOE approved authorized limits. * This does not apply to legacy contamination that is to be reported under a separate criterion below. * This reporting criterion does not apply to packages monitored in accordance with 10 CFR Section 835.405 that meet DOT contamination limits specified in 49 CFR Section 173.443(a).
Info	4. Identification of onsite legacy radioactive contamination greater than 10 times the total contamination values in 10 CFR Part 835 Appendix D, exclusive of footnote 3 to Appendix D, and that is found outside of the following locations: areas routinely posted, controlled, and monitored for contamination; and areas controlled in accordance with 10 CFR Section 835.1102(c); and, per 10 CFR Section 835.604(a), any non-posted area that is under the continual observation and control of an individual empowered to implement access and exposure control measures. For tritium, the reporting threshold is 10 times the removable contamination values in 10 CFR Part 835, Appendix D. Notes: * Legacy radioactive contamination is radioactive contamination resulting from historical operations that are unrelated to current activities. * This does not apply to contamination from residual radioactive material meeting applicable DOE approved authorized limits. * Legacy contamination identified through a routine radiological monitoring program, compliant with 10 CFR 835 may be summarized in a single occurrence report, for example, on a quarterly basis. Each instance of legacy contamination must be identified in the report and contain the details required for reporting in accordance with this Order.

Subgroup C – Radiation Exposure
High	1. Determination of a dose that exceeds the limits specified in 10 CFR Part 835, “Occupational Radiation Protection,” Subpart C, “Standards for Internal and External Exposure,” or in DOE O 458.1 Chg 3, Radiation Protection of the Public and the Environment, dated 1-15-13, paragraph 4.b(1)(a) [paragraph 2.b(1)(a) of the CRD], “Public Dose Limit.”
High	2. Failure to provide the required monitoring for an exposure estimated to exceed the values for providing personnel dosimeters and bioassays as stated in 10 CFR Section 835.402(a) or 10 CFR Section 835.402(c).
Low	3. Determination of a single occupational dose, attributable to an identified event that exceeds an expected dose by: (1) 500 mrem Committed Effective Dose (CED), or (2) 100-mrem effective dose due to external exposure.
Low	4. A radiological release that exceeds any limit contained in paragraphs 4.f.(2), 4.f.(5), 4.g.(4), 4.g.(5)(a), 4.g.(7), 4.g.(8)(a)4 or 4.i.(1) [and paragraphs 2.f.(2), 2.f.(5), 2.g.(4), 2.g.(5)(a), 2.g.(7), 2.g.(8)(a)(4) or 2.i.(1) of the CRD] of DOE O 458.1 Chg 3, Radiation Protection of the Public and the Environment, dated 1-15-13 or exceeds the 40 CFR Section 61.92 requirements.

Subgroup D – Personnel Contamination
High	1. Any occurrence requiring offsite medical assistance for contaminated personnel, including transporting a person with personnel or clothing contamination due to DOE operations/activities that exceeds 1 times the total contamination values in 10 CFR Part 835, Appendix D to an offsite medical facility or bringing offsite medical personnel onsite to perform treatment or decontamination.
High	2. Identification of offsite personnel or clothing contamination due to DOE operations/activities that exceeds 1 times the total contamination values in 10 CFR Part 835, Appendix D. For tritium, the reporting threshold is 1 times the removable contamination value found in 10 CFR Part 835, Appendix D.
Low	3. Identification of onsite personnel or clothing contamination (excluding anti-contamination clothing provided by the site for radiological protection) that exceeds 10 times the total contamination values identified in 10 CFR Part 835, Appendix D. The contamination level must be based on direct measurement and not averaged over any area. This criterion does not apply to tritium contamination.

Group 7 – Nuclear Explosive Safety (Not applicable to LBNL)

Group 8 – Packaging and Transportation

High	1. Any offsite transportation incident involving hazardous materials that would require immediate notice pursuant to 49 CFR Section 171.15(b). Note: Any occurrence involving an offsite DOE/NNSA shipment containing hazardous materials that causes the initial responders to initiate protective actions at locations beyond the immediate/affected area should also be reported as an Operational Emergency under Group 1. Group 8 will be a secondary reporting criterion.
Low	2. Not applicable to LBNL
Low	3. Any offsite “accident” (per 49 CFR Section 390.5) involving a motor vehicle carrying DOE hazardous materials operating on a highway in interstate or intrastate commerce.
Low	4. Any transportation activity for onsite transfer resulting in onsite release of radioactive materials, hazardous materials, hazardous substances, hazardous waste, or marine pollutants that is above permitted levels and exceeds the Reportable Quantities (RQ) specified in 40 CFR Part 302 or 40 CFR Part 355.
Info	5. Any offsite transportation incident involving DOE hazardous materials that requires submission of a Hazardous Materials Incident Report on DOT Form F 5800.1 pursuant to 49 CFR Section 171.16. Note: For reporting under this criterion, the occurrence report belongs to the party that initiated the shipment (i.e., the occurrence report belongs to the shipper of record). Exemption from this criterion applies when the shipper is external to DOE.
Info	6. Any offsite transportation of hazardous material, including radioactive material, whose quantity or nature (e.g., physical or chemical composition) is such that it is noncompliant with the receiving facilities Waste Acceptance Criteria (WAC) or other receipt requirements and the receiving organization’s operations were significantly impacted or disrupted (e.g., material cannot be accepted, possessed, or stored at that facility; must be treated or repackaged to be accepted; or exceeds a license or permit limit).
Info	7. Violation of applicable Hazardous Materials Regulations requirements for activities listed in 49 CFR Section 171.1(b) performed during the preparation of offsite hazardous materials shipments and discovered during shipment in commerce or at the receiving site.
Info	8. Any onsite transfer of hazardous material, including radioactive material, whose quantity or nature (e.g., physical or chemical composition) is such that it is noncompliant with the receiving facilities Waste Acceptance Criteria (WAC) or other receipt requirements and the receiving organization’s operations were significantly impacted or disrupted (e.g., material cannot be accepted, possessed, or stored at that facility; must be treated or repackaged to be accepted; or exceeds a license or permit limit).
Info	9. Unauthorized deviation from DOE instructions to commercial motor carriers for DOE hazardous materials shipments (e.g., designated route, prohibited route, designated time of the day).

Group 9 – Noncompliance Notifications

Info	1. Any written notification from an outside regulatory agency that a site/facility is considered to be in noncompliance with a schedule or requirement.

Group 10 – Management Concerns and Issues

Info	1. An event, condition, or series of events that does not meet any of the other reporting criteria, but is determined by the Facility Manager or line management to be of safety significance or of concern for that facility or other facilities or activities in the DOE complex.
Info	2. A near miss to an injury, where something physically happened that was unexpected or unintended AND where no barrier prevented an event from having a reportable consequence (i.e., happenstance was the main reason the event did not result in a reportable injury).
Info	3. Any occurrence that may result in a significant concern by affected state, tribal, or local officials, press, or general population; that could damage the credibility of the Department; or that may result in inquiries to Headquarters.

Appendix B. Notification and Reporting Matrix

Report Level	Categorization	Initial Notification	Written Notification	Causal Analysis	Final Report	Final Report Approval
High (H)	2 hours	2 hours	Close of business, 2 business days	Per local procedures	Close of business, 60 calendar days	Facility Representative of Designated DOE Representative
Low (L)	2 hours	2 hours	10 business days	Per local procedures	None required	Per local procedures
Informational (I)	2 hours	Close of business, next business day	10 business days	Per local procedures	None required	Per local procedures

Note: Categorization time is from discovery date and time. Initial notification is from categorization date and time. Written notification is from categorization date and time.

Appendix C. Causal Analysis Tree

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

_____________________