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APPROVED INTERPRETATION GUIDANCE FOR DOE M 232.1-1A

"Discovery date and time"

Approved 9/27/99

REQUIREMENT

10.2.B. Specific Report Items.

(10) Date and Time Occurrence Was Discovered. Enter the date and time when the facility staff discovered the event or condition being reported.



INTERPRETATION
Issue:

Define when a reportable event or condition is discovered (date and time).

Intent:

The discovery date and time is when the facility staff discovered or became aware of the event or condition. The facility staff are those personnel assigned to the facility and cognizant of the area in which the event or condition is identified. This is not the time the Facility Manager (FM) or designee (FMD) becomes aware of the occurrence.

Additional Information:

Even though the FM or FMD is responsible for categorizing the event or condition, they are also responsible for training cognizant personnel to report all upset conditions in a timely fashion to the FM or FMD (usually a Shift Manager or equivalent) for information on facility condition and reportability consideration. The concern is that there are special groups tracking dates and times of events when this data is not being accurately identified. Example: How many events happen on Friday afternoon, or backshifts?

Examples are as follows:
  1. A facility operator is responsible for identification of all events or conditions within the facility in which they are trained or qualified. This is to include process, radiological, environmental, safety, security, or other events or conditions.

  2. A Radiological Control Technician (RCT) is responsible for identifying events or conditions in which they are trained or qualified. The RCT would be responsible for the radiological control aspects of the facility as well as other areas in which they have received training, such as safety hazards, fires, or personnel injuries. They may not be held accountable for operational areas of the facility unless training in that area has been provided.

  3. A facility mechanic is responsible for the identification of maintenance related events or conditions such as an improper lockout/tagout; improper maintenance of Safety Class or Safety Significant Systems, Structures, or Components (SSCs); or other specific application to operations under their cognizance. Some pieces of equipment are specifically operated and maintained by the maintenance organization, such as some electrical and instrumentation (E&I) pieces of equipment. The identification of an event or condition applicable to that piece of equipment would fall under the responsibility of maintenance personnel.

  4. Laboratory Technicians are responsible for the identification of conditions associated with their area of cognizance. The identification of an out-of-specification sample analysis by the technician is the time of discovery. The technician does not need to be physically stationed in the affected facility, but is trained in the techniques and expected results of the analysis being performed.

  5. Subcontractors or other non-facility personnel are responsible for the identification of a condition or event for which they have been trained, such as witnessing a person falling from a roof or receiving an electrical shock. When a subcontractor identifies a reportable process related condition for which he is not trained, the time of discovery is the time the cognizant facility person was made aware of the condition.
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