Activity communications and interfaces

— To transition from a High Risk/Level 1 FME AREA/ZONE down to a Standard Risk/Level 2 FME AREA/ZONE (i.e. downgrading the zone) requires to:

 Reconcile all log entries for material, tools, parts, etc.;

 Secure all system openings with approved FMM devices;

 Verify no High Risk FME AREA/ZONE requirements are present in the FMCA;

 Suspend logging requirements if no longer in effect;

 Suspend FM monitoring activities if not required;

 Post area as Standard Risk/Level 2 FME AREA/ZONE.

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“Management expectations have not been formulated or communicated along with the station policy for adherence to foreign material exclusion (FME)” [5].

 Omitted supervisory emphasis on FMM considerations and practices for the upcoming activity:

“Supervisory emphasis on the foreign material control during pre-job briefings and supervision of work activities, has been very limited” [5].

 Missed supervisory assertion of FMM practices during the observation of task performance at the field;

 The worker did not report to his manager and discuss with him the FMI near miss during the post job briefing;

— Lack of communication during the planning of activities:

 The worker did not take part in the preparation or review of the work planning and was not aware of FMM provisions of the work order were for protection of equipment important to safety;

 The planner was not informed about the FM issue that was faced during the last performance of the task;

— Lack of sharing operating experience information;

— Lack of written communication:

 Insufficient information in the user’s manual concerning the FMM requirements relating to the approved work order;

 Missed recording of a deviation in the procedure which adversely affected the FMC set up by the following crew.

Consequently, communication of the activity’s hazards, risks, conditions, prerequisites, work environment, worker qualifications, requirements, procedures and OPEX to every concerned personnel is of an utmost importance, at all levels and all directions. An effective communication and team support will allow individuals to receive the instructions, advice, information and support that they need. Conversely, the communication will allow them to provide the necessary feedback to his/her crew, organisation, others in the internal and external organisations to consider, implement and practice FMM and to improve FMMP in prevention of or protection against FMI events.

Therefore, as a part of the requirements and controls of the FMMP, the administrative procedure needs to identify the interfaces and the types of communication methods, tools and mechanisms (discussed in Section 4.7) needed for the exchange of for necessary or required information from FMM requirements and expectations perspective. As a minimum, the FMMP governing document needs to establish requirements and controls for formal communication methods and tools that include:

— Descriptive activity and work level documents, e.g., FMM packages and plans, including roles and responsibilities of those involved in the implementation, performance and support group interfaces;

— Instructional and prescriptive activity and work level documents, e.g., work orders and instructions, including the activity plan, checklists, flowcharts, that are part of the work orders and instructions;

— Job briefings;

— Signage and marking for FMM, FMMP, FMCA and FMM awareness;

— Programme and plant activity meetings, e.g. coordination, administration, review and committee/panel meetings, including periodic programme and task review sessions;

— Incident reporting;

— Operational experience reporting;

— Procedural review and checks.

The FMMP administrative procedure also needs to clearly define and describe the applicable requirements and expectations for these communication methods, tools, mechanisms and sessions. These requirements/expectations include initiating conditions, content and timing based on the purpose, significance, urgency and nature of the information that is required or necessitated to be exchanged, as well as the relevant participants and interfaces, for activity communication. For example, in some briefings, written forms/reports may be required or expected to be completed or signed to support, document and record the communication or transfer of information. Such requirements or expectations, when exist, also need to be defined and described by the FMMP administrative procedure.

Following Sections describe key communication methods, tools and mechanisms for an activity.

5.5.10.1. Foreign material management plan document

As defined in Section 5.5.9.2, the FMM plan is a cross-organisational written communication method, that notes, discusses and describes the management of FM during an activity, included in the final work order package for implementation.

There is no ‘one size fits all’ form or format for FMM plan and its preparation and distribution process requirements and expectations for communicating FMM specifications and interfaces for the activity (e.g. FMM requirements, expectations, responsibilities, actions, methods, tools) between all organisations involved in the activity. Such process requirements and expectations on how to establish an FMM plan would depend on the vigour and inabilities of an organisation, its culture and character, its strengths and weaknesses of organisational (internal and external) interfaces for communication. For example, the FMMP of an organisation may determine the scope and extent of FMM plans based on the level of activity conditions, communication or work practices that have been observed and are anticipated to still exist, while another owner/operating organisation’s FMMP focuses on the activities on and around high-value SSCs. Some specific examples of the key concerns affecting the scope and extent of a FMM plan, as collected from the industry, include:

— Work/task procedures do not specifically address unique FMCs for the jobs that are assessed as high or standard FMRLs and for the associated FMCAs;

— Work is being performed in a continuously exposed area (e.g. spent fuel pool, refuel pool, steam generator, turbine generator) where the high risk and consequence and strict FMCs are required;

— Work is to be performed on SSCs/equipment that are extremely sensitive to FMI;

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— There will be generation of debris in or near open SSCs;

— Evolutions involve multiple work groups;

— Evolutions involve multiple simultaneous activities;

— Component replacements or modifications, including large and complex activities, such as those conducted during plant construction or refurbishment, are extensive;

— There is long-lead needs and requirements for the activity, including those for procurement, training, etc.

Although the scope and extent of FMM plans will vary from one owner/operator organisation or from one activity to another within the same organisation, the contents of an FMM plan that is effectively communicating specification and interfaces of the activity would cover at least the following aspects:

— Identification of FMM plan, e.g. name/number, activity/task(s) to be performed;

— Purpose and scope of the planned activity/task(s) that present all involving/relevant FMM and FMC criteria in details, in a simple but complete manner;

— The expected activity time/schedule, duration and resources necessary, including the identification of plant’s state (e.g. cold or hot shutdown, operation at full power or decreased power, maintenance or refuelling outage);

— References to applicable requirements, standards, and other necessary documents, such as administrative and technical procedures, manuals and drawings;

— Identification of lead person, group and organisation who prepare the plan (this is typically the official owner of the activity), including:

 The names of plan’s originator, preparer, independent reviewers(s), line management (supervisor, manager, director) involved in preparation of document;

 The names of plan preparation team members, if applicable (for example, large and complex activities which involve multiple work groups, major plant equipment, extensive plant modifications, large project resource expenditures or high level of regulatory and/or safety significance may require a team of planners who would participate and coordinate the plan to ensure that FMM, FMC and all other applicable requirements are met in an integrated and aligned manner);

— SSCs and equipment that are involved and relevant, particularly those are important to nuclear, industrial and radiological safety, plant performance and/or extremely sensitive to FM;

— Required reviews and approvals, including their timing and order;

— Specific responsibilities of those involved in the preparation, approval and implementation of the plan, including individuals, organisations and inter-organisational committees/panels/boards and;

— Specific activity details (simple but complete, including the specific emphasis of any new, different, uncommon, unusual, distinctive matters):

 FMRLs and FMCAs to be used, including any risk level and/or zone transitioning;

 Preparation and assistance need from specific organisations (e.g. isolation of the systems, construction of special structures, such as scaffolding, barriers, shielding, insulation);

 General and specific FMM requirements, such as work precautions, inspection and hold points, flushing, etc.;

 Specific training needed to perform the activity in accordance with FMM principles;

 Type and timing of job briefings to focus on specific FMM requirements, controls and responsibilities;

 Any special FMCs to be applied, housekeeping and cleanliness requirements and expectations, use of FMC devices, etc.;

 FMCA access control and any turnover requirements for FMCA owner/controller;

 Controls required to maintain material or tool cleanliness in the FMCAs or buffer zones;

 Requirements for the use of overhead cranes, rigs, hoists, tools to be used, if necessary;

 Activity inspection requirements, including the inspection specifications, performing organisations and inspection stages/times;

— Other work in the area (or in remote areas) of the plant/project that could interfere with the FMM of the activity or may require the activity to be executed in a particular time, period or manner;

— FMM plan deviation requirements;

— FMI event response actions, including any specific immediate or other reporting requirements to ensure that FM and appropriate FMC measures are recovered and restored efficiently and in a timely manner, if applicable (for example, arrangements for mitigation of or recovery from an FMI event need to be specifically included in the FMM Plan if the probability of FMI is high and it is possible that FMC measures cannot be put in place due to certain or unusual circumstances);

— Other topics that need to be emphasised, such as:

 Applicable operational experience or lessons learned from the industry (or other industries);

 Information on the performance of the same and similar activities and plans that were completed previously.

Also, when activities are to be performed adjacent or nearby each other, there could be several FMM options to be considered and optimised. In such cases, it would be a good practice to include a ‘pros and cons’ matrix or impact/value, risk and/or cost/benefit analysis of each option and ranking and recommendation in the FMM Plan.

Again, the FMMP governing document needs to clearly and concisely specify the required/expected scope and content of an FMM Plan to ensure adequate, sufficient and timely communication and understanding of FMM requirements, aspects and interfaces for a specific activity by all who has to input, feedback, select, agree and approve FMM and FMC considerations. By doing so, the FMMP administrative procedure ensures that there is a standard application of a written communication of requirements, expectations, responsibilities, actions, methods, tools, that are necessary from all organisations involved in the activity, regarding the management of foreign material.

5.5.10.2. Job briefings

Job briefings are key communication tool involving the information exchange between an individual and group(s) on a particular task and on the associated requirements and expectations, as well as the potential challenges, including FM hazards and risks. It is essential to hold job briefings as a part of any activity (using a graded approach) where the information exchange would make the at-hand (or next round of) activity safer, more effective, more

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efficient and timelier. As such, the briefings typically take place between the supervisors/team leads and the worker(s), experts and worker(s), worker and group(s), and so forth.

The briefings may be conducted prior to beginning a task, during a certain stage of task and after the job is completed, formally or informally. If and when possible, these job briefings need to be conducted face to face and verbally (it is highly encouraged to use ‘three-way communication’ to ensure correct transfer and understanding), as well as written and visual materials (e.g. drawings, plans, maps, photos) that are necessary or helpful to elucidate the information being exchanged.

Typical job briefings and their purpose, content and timing include:

— Pre job briefings: These are the information exchange and communication sessions in advance of the tasks (typically close to the start of the work). which addresses all or most of the following using a graded approach:

 Confirming each person is FMM trained and qualified to perform the assigned task;

 Clarifying FMRLs, FMCAs and any other specific FMCs;

 Discussing the known and anticipated environmental condition, e.g. heat, humidity, lighting, workspace type, size and obstacles, that may affect the safety of worker(s);

 Reminding the roles of individuals in the execution and support of the job for critical aspects of task;

 Noting FMM as-found and close-out inspections, and required check and hold points;

 Discussing any anticipated challenging, special attention and care areas, potential error-prone situations and identifying required and expected responses;

 Noting past internal and external OPEX (challenges, issues, errors, lessons learned) in the same or similar tasks;

 Highlighting turnover requirements, including the stages of holding other job briefings;

 Emphasising the self and peer checks, observation and their retainment for subsequent job briefings;

 Reminding actions in case of an FMI event, unanticipated FM hazard and risk recognition;

— Post job briefings: These are the information exchange and communication sessions that are held after the completion of the tasks (as soon as practical) which communicate the FMM information that had been observed on:

 Events, challenges, issues, errors that were encountered during the performance of activities;

 Their impact on the task and worker(s),

 Resolutions of challenges, issues, errors that were encountered;

 Good practices in the performance of activities, that helped safety, performance and timing of activities;

 Personal, team and programmatic lessons learned and ‘good to know’ key points.

 These debriefings aim primarily collecting and disseminating such information, typically from the workers and job leaders about the work. This information also needs to be collected, reviewed, analysed and used to improve planning, preparation and performance of later same or similar activities. It is a good practice

that all identified experiences and lessons learned are formally documented so that it can be retrieved;

— Scheduled mid-job briefings: These are the information exchange and communication sessions that are held periodically, and/or when the special conditions make them necessary, as the activity/task/job is being performed and in progresses. Particularly,

‘transitional’ information exchange, i.e. mid-job briefings conducted when there is a transition from one phase of the activity, is essential to ensure the continuity and transition, which are very important elements/expectations of an ongoing task. Such phase transitions primarily occur due to, and be marked by, the planned/known changes that transform (or interrupt) the course and nature of the activity performance due to shifts in tasks, people and area.

An effective transitional information exchange by the planned and scheduled mid-job briefings accomplish the continuity in two-folds:

 Adequately and sufficiently capturing and transferring the information on the current status of the work, including the FM and FMC conditions, hazards, risks, type and results of completed inspections, areas of special attention, etc.;

 Communicating the current and upcoming status.

Accordingly, timings and scope of these transitional briefings correspond to certain milestones that are known/planned/scheduled to be changing the task phase, task performer and/or task area conditions, such as changing the task crew (shift turnover briefings), start of a critical phase of the task or an adjacent activity that has special impact (phased job briefings).

The continuity of activity and information, including the FMM and FMC aspects, during these transitions are very critical for safe and ‘FM free’ completion of the activity, for example:

“At a plant, FMC plugs (which had not been previously used for application for the task at hand) were inadvertently left in internal vent holes in a primary heat transport pump. The large pump was disassembled by one task crew (who installed the FMC plugs) and reassembled by another one. As mentioned earlier, these plugs were being applied to the pump vent holes for the first time, and moreover, they were not documented and were not included in the discussions during the briefing by the first set of crews to communicate and turn over the task to the incoming crew. This omitted information of such unusual part/process resulted in a failed communication that was to ensure that the new crew knows and understands this new application, i.e. installation of FMC plugs.

In addition, the closeout inspection (potentially due to the first time application and awareness of plugs) failed to find the plugs. After the inspection, still unknowing the plugs were applied; the second crew assembled the pump. After the system was returned to service, the pump was started and the normal running temperatures were quickly exceeded. Owing to the prompt recognition and reaction by the operation crew, the pump was immediately shut down prior to harming the pump and a significant damage was averted”.

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— Unscheduled mid-job briefings: Similar to the scheduled mid-job briefings, these impromptu briefings are the new information communication sessions that are held, when necessary, as the activity/task/job is being performed and in progresses. The difference is that unscheduled mid-job briefings are held when an unexpected/unplanned/unknown occurrence, or appearance of new critical/important information, that impacts/changes the task performance and conditions (as to, for example, the activity people, plan, area, instructions). Thus, the timings and scope of these ‘new information communication’

briefings are solely driven by the occurrence (e.g. stand down meetings), or the new information (e.g. update meetings), and their significance of impact on the task (i.e. on the task performer, purpose, schedule, steps or area conditions). These briefings are to adequately, comprehensively and completely communicate the change as to:

 What the change is;

 Why and where the information is originated;

 Impact (or potential impact) on the ongoing task, including, among others, the FM and FMC conditions, hazards, risks, type and results of completed inspections, areas of special attention;

 Specific impact on the previously known and communicated information of the work (i.e. that were covered during the pre-job and earlier scheduled mid-job briefings).

5.5.10.3. Activity area awareness

As discussed in Section 5.5.2, activity areas have to be established and controlled in accordance with the FMRL at or around the work being performed. This information on the work area identification and controls are to be communicated to all involved in the activity and all project/plant personnel who may be in the area or the vicinity.

For the people involved with the activity, the activity plan and job briefings communicate all the requirements and expectations in and around the activity area while they are performing or supporting the activity, including the awareness of FMCA boundaries, barriers and signs.

On the other hand, for the plant (or project) personnel, who are not part of the activity but need to be in the vicinity or general areas nearby, the FMM identification, restriction and applicable controls are necessary to be clearly communicated in order to have their awareness and not to interfere with the activity or violate the FMCA boundaries. Therefore, messages for general personnel awareness need to be communicated, for example, by the following methods, tools or mechanisms:

— FMCA identifications, such as signs, barriers and boundaries are posted with sufficient visibility and information (restrictions and cautions);

— FMC devices are clear for recognition, marked by wording and/or colour consistent with the site specific FMMP colour and wording (for example, as mentioned in Section 5.5.4, brightly coloured FMC devices to promote recognition);

— When changes to the activity areas occur, all signs, barriers and boundaries for general plant personnel are updated;

— Training covering activity area and controls are provided to all personnel to identify, recognise, interpret FMM devices, signs and associated reactions and requirements, including those for housekeeping, cleanliness, observation and reporting when around FMCA.

FMMP governing procedure needs to clearly specify the types, characteristics and placement manners of FMM signs, wordings, barriers, boundaries, etc., for the identification, recognition, interpretation of FMCs by all plant personnel. The administrative procedure also sets the general FMM training scope and topics for FMCA awareness, to maintain the integrity of activity areas, to understand and meet FMM requirements/expectations and to prevent and protect the health and safety of both activity workers and other plant staff.

5.5.10.4. Event, near-miss and close call notifications

When an FMI incident occurs, there are at least two stages of communication of the information about the event based on the purpose and timeliness: Immediate communication for notification and, subsequent, systematic communication for reporting the event and communicating detailed information:

— Immediate communication: This is the notification to all involved or relevant plant personnel of the FMI event for their prompt knowledge, review and assessment of the incident and existing and potential impact on the people and the SSCs being worked on and other SSCs in and around the plant/site. The prompt and preliminary review and assessment of FMI will determine the adversity and or urgency of the situation and its consequences based on what is communicated. Particularly, the immediate communication will be the basis for immediate actions to be taken at the work area (and plant/site, at large, if deemed necessary) to prevent further incidents and impacts as a result of the event that just occurred, such as:

 Stoppage and assessment of additional activities in the activity area and surrounding areas;

 Stoppage of running SSCs that may be impacted by the FM;

 Prompt operability determination, declaration of any plant SSCs being inoperable or unavailable and due to the FMI or its impact;

 Determination of needs or requirements for addition or relocation of FMC barriers to prevent additional events and personnel;

 Mitigation and recovery assessments.

Therefore, each immediate communication/notification ought to provide information correctly and completely to all involved or relevant plant personnel incident, which may have a different set of contacts for each incident. For example, if the event could affect in-service components or fuelling activities, immediate notification to operations is typically required. Subsequently, the event needs to be immediately communicated according to its nature, e.g. known or possible mechanical impact on the specific system or equipment and adjacent or downstream components, water chemistry, instrumentation, the electrical systems and equipment, radiological conditions.

The communication method of this immediate information exchange is typically verbal which may include, for example, the notification of responsible FMCA personnel, activity supervisor/lead, control room, construction coordination centre (CCC), outage control centre (OCC), in person or by phone or radio;

— Systematic communication: After the immediate communication and prompt actions, the FMI ‘incidents’ (at this communication phase, not only the events, but also the near misses and close calls) are communicated to report and provide detailed information on the incident for further investigation and mitigative actions, and if identified, any corrective actions. Incident reporting is a written communication that could be followed

In document Foreign Material Management in Nuclear Power Plants and Projects (Page 135-147)