Approved 9/27/99 REQUIREMENT b. The Facility Manager shall submit and distribute an Update Report if there is any significant and new information about the occurrence. The status of the investigation, recurring consequences, or the identification of additional component defects are activities associated with the occurrence and shall be included in Update Reports. When additional occurrences are to be included in a Roll-Up Report, an update shall be submitted, in accordance with Section 5.7, by the close of the next business day from the time of categorization (not to exceed 80 hours). INTERPRETATION Clarify when an event is a continuation of an identified occurrence or a new event is happening. Explain the differences, and when a Roll-Up Report should be considered. Intent: Update reports should be used to document when multiple consequences related to a single event appear over a period of time. Roll-Up reports should be used to document additional occurrences with the same root cause and the same or similar direct and contributing causes and corrective actions. Additional Information: Example 1: Consider a chemical spill that results in an immediate fish kill. It is discovered several weeks later that many birds have died from eating fish killed by the spill. An update report should be submitted to document the additional consequences of the chemical spill. If a second chemical spill occurs and results in another fish kill, it should be considered a separate occurrence. The second occurrence can be rolled-up into the first occurrence if the criteria of DOE M 232.1-1A, Section 5.7 for Roll-Up reports are met. Field #4 is used to indicate that the one report includes two occurrences. Example 2: An inventory of hazardous waste drums reveals that some of them are not labeled correctly. Due to the number of drums, several days are required to finish the inventory. However, each day several violations are found. Each drum does not require the categorization of a new occurrence. This is all part of one occurrence and should be considered a continuation of an existing occurrence. The increased consequence warrants issuing an Update Report to identify the new information. Example 3: A fire protection water line into a facility has frozen and cracked, rendering the fire control system inoperable. Two days later, it is discovered that water from the broken line spread contamination outside a controlled area. This is an additional consequence from the original occurrence, not a new occurrence. The increased consequence warrants issuing an Update Report to identify the new information. Example 4: This is an example of a roll-up event. A safety significant component degrades when it is required to be in operation. Long term corrective actions will replace the specific component, but continued operation is allowed until replacement occurs. Another identical safety significant component fails, but it serves a different location or different function from the first component. The root cause code for the second failure is considered to be the same design problem. The second event should be considered to be a candidate for inclusion into the initial report creating a Roll-Up Report based on a non-finalized report, even though the direct and contributing causes are not identical. Corrective actions should identify and address all causes identified in all occurrences. |
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