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APPROVED INTERPRETATION GUIDANCE FOR DOE M 232.1-1A

"Procedure requires equipment shutdown"

Approved 9/27/99

REQUIREMENT

GROUP 1 - FACILITY CONDITION

H. Operations

Off-Normal

(1) Any unplanned and unexpected change in a process condition or variable adversely affecting safety, security, environment, or health protection performance sufficient to require termination of a procedure in a reactor or nonreactor facility.



INTERPRETATION
Issue:

Do we declare Off-Normal Occurrences every time we use an Emergency Operating Procedure (EOP)/Abnormal Operating Procedure (AOP)/Alarm Response Procedure (ARP) that causes us to shut down equipment as a precautionary measure?

Intent:

The use of an EOP, AOP, or ARP is not in itself reportable; however, the condition requiring the use of the procedure may be.

Additional Information:

It is the change in the process response or condition that should be evaluated for reportability. In other words, if there is an unexpected change in the process response or condition significant enough to require terminating the process, then this change, not the use of the ARP, AOP, or EOP, should be evaluated for reportability. However; it should be noted that the use of an ARP, AOP, or EOP may be indicative of a process condition or variable adversely affecting safety, security, environment, or health protection performance.

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