Approved 9/27/99 REQUIREMENT E. Environmental Agreement/Compliance Activities Off-Normal (2) Any occurrence under any agreement or compliance area that will be reported to outside agencies in a format other than routine periodic reports. INTERPRETATION Information on events that are under investigation (not yet known to be a violation) is sometimes provided to the State's oversight group in a non-routine meeting. Does this exchange of information constitute reporting to outside agencies in a format other than routine periodic reports and therefore requires an occurrence report? Intent: The intent is to notify DOE management of occurrences that warrant non-routine reports to outside regulators and make them aware of the existence of the report and concern by an outside agency. Additional Information: It is not the intent to generate an occurrence report for every contact the facility operator has with an outside agency related to an environmental agreement or compliance area. An occurrence report is not required for a meeting to discuss events that are under investigation. Reporting under this section is normally expected to be related to an enforceable agreement or compliance issue that mandates non-routine reporting. However, DOE management needs to be made aware of concerns that are expected to generate significant concern by outside agencies, the press, or general public. If the event warrants an occurrence report because of the potential for public or press interest, it can be reported under Group 10.C - Potential Concerns/Issues. Later if an investigation determines that a non-routine report is required then the nature of occurrence field can be recoded to Group 2.E in an update report. |
| Back to DOE Approved Interpretations |