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5. ESTABLISHMENT AND ADMINISTRATION OF FOREIGN MATERIAL

5.5. Establishing and describing administrative controls

5.5.9. Activity planning

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5.5.8.5. Timing and frequency of training

All plant/project personnel need to receive an introduction to the FMM and FMMP, immediately upon initial access to site, typically in conjunction with general employee training (GET). This course would provide the purpose and importance of FMM and FMMP and the general employee’s responsibilities relating to FM awareness and management as discussed in Section 5.5.8.2.

More in-depth, higher level, specialised training may contain one or multiple times of delivery:

— Initial task training needs to be provided to workers and managers relating to their specific areas, disciplines and assigned tasks for being qualified or permitted to perform independent work;

— Just-in-time training may be used prior to a performing a specific task or supporting a project or program, for example, FMM monitor role, outage work, component replacement or modification. This type of training could involve communication of project requirements, DLAs or practice on mock-ups;

— Continuing training is an excellent opportunity to enhance and expand workers’ FMM knowledge and awareness, particularly based on new information and knowledge, including the OPEX. The frequency of the continued training is typically set by the SAT methodology.

The following topics need to be considered for delivery during these sessions:

— Management expectation reinforcement;

— FMM programme, process or procedures changes, such as:

 Restrictions and use of particular FMC devices, e.g. internal FMC devices, lanyard/tether applications and use;

 Restriction and use of particular tools, e.g. wire wheels and brushes;

 Internal FMC devices use;

 Specialised FMC tool availability and use;

— Use of own and others’ OPEX to improve performance:

 FMM trend results and finding by CAP cause investigations;

 Lessons learned relating to encountered FM related events, close calls and near misses during an outage;

 Observation programme results;

 Industry event or trends.

Based on all available general and task specific FM information, knowledge and experience (see Section 4.1.1), the activity planning involves FMM considerations to anticipate, identify and determine all aspects, including:

— Applicability of rules, requirements and expectations for the activity and its management;

— FM paths and FM targets that are (and could be) possible throughout the task performance;

— FM risks and hazards that would/could exist or be created during the task performance;

— Prevention and protection against the FM risk, hazards and their potential impacts and associated FMCs;

— FMM methods, tools, skills;

— Human and material resources that may be needed, support and interface required or needed and their coordination with all the involved individuals and organisations;

— FMM critical points during the activity, including information exchange; hold, review and check points, verifications;

— Job sequence, i.e. the order of task performance steps, that is the safest and most effective from the FMM perspective;

— Changes to plant conditions, area restrictions, process limitations and the course of activity performance;

— Arrangement and schedule of the tasks and task areas, including those of other activities that will surround/interface with the task area;

— Unusual, special and unique elements of the activity, particularly for those that would be performed for the first time;

— Contingency response for situations involving a high probability of loss of FMCs.

As a good practice, the planning also includes the considerations and recommendations for the optimisation of FM prevention, protection and control for, for example:

— Other possible and safe options for the order of activity steps, based on foreseen potential bottlenecks;

— Training and qualification of the activity workers and other personnel in terms of their numbers at a given activity step and time for dispersion of people to the work area (i.e.

right people at the right time);

— Timing for appropriation of tools and facilities for gather/delivery to or storage in FMCA and surrounding areas for optimising inventory and movements of people (i.e. right tool at the right time in the right place);

— Types, scopes and intervals as to accomplish the purpose by self, second party or independent checks/inspections.

Accordingly, the FMMP governing procedures need to define and describe critical FMM and FMC requirements and expectations that are necessary and required to be considered in the planning for the task review, area and support review and schedule and arrangement review, which were defined in Section 4.8. Those definitions and description will establish a minimum common understanding and pre-set arrangements of aspects, particularly those that are discussed in Sections 5.5.15.5.8, to eliminate, minimise and manage FM hazards and risks during the actual performance of the activity.

Additionally, the governance of the FMMP need to define and describe the roles, responsibilities, competencies and skills tools for planning and planners, as applicable, including interfaces, communication methods. Noting that the FMM planning is a part of overall or departmental work planning, e.g. maintenance work planning, and FMM plans are

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typically considered and addressed within the main work package, FMMP needs to set the framework for the integration of FMM plans with overall work planning and work control programmes, processes and procedures of the facility/project.

The governing procedure may also recommend or require specific methods and tools for planning of particular task, its output and communication, as well as the contingency planning, which are discussed in the following sections.

It is also a recommended practice by the industry experts to standardise the FMM considerations in work planning (or the work packages at large) for the repeated and routine tasks. In such practice, the next performance of the task will only evaluate the difference (a.k.a.

deltas) in the activity conditions from the standard plan (e.g. difference in the conditions around the work area) and will only consider new information and knowledge since the previous planning and performance of that specific activity.

Following Sections discuss, in more detail, the key steps in activity planning: preparation, documentation and change management.

5.5.9.1. Understanding the task and its conditions

Understanding the task and its conditions at planning stage can be established by many methods for various aspects of the task performance, for example:

— An initial and follow up joint walkdowns by the planners and performers visually would identify potential FM hazards and risks associated with job conditions, task and area controls;

— Risk and ramification, as well as the proper order of activity steps, may also be better understood by simulated and/or mock-up performances of tasks with the people who will perform the activity or have the same or similar skills, competencies and experience in performing the activity. (Including people with different skills, competencies or experience in the simulation/mock-up could also be beneficial for a better understanding of activity performance by the provision of different perspectives to avoid ‘tunnel vision’

and ‘group think’. It may also help to have more people become familiar with the activity to prepare/plan for potential personnel changes during the actual activity performance);

— Tabletop reviews of previous post job debriefings and gained experience notes, knowledge sheets and discussions from the previous performance of the tasks or interviews with previous task performers are usually a good source for ramifications and potential improvements;

— Reviewing internal and external OPEX helps with the anticipation and understanding of mishaps and failures that could be encountered.

Specifically, the understanding of activity includes, as a minimum:

— Activity area and surrounding areas;

— Need, purpose, type and timing of FMC during the activity performance;

— Prerequisites for, and challenges of, executing tasks;

— Special competencies, skills, methods, tools needed and their timing;

— Possibilities/obstacles of information exchange mechanisms;

— Necessities/hinderances of inspections and verification that are required or could be needed.

Additionally, the management and mitigation of a high possibility FMI that may occur may also be considered.

The governing FMMP procedure instructions particularly need to ensure that workers and planners verify that correct FMCA boundaries and FMCs are specified in the work instructions during walkdowns of job sites/areas and review of work packages. The procedure also covers the actions to take when FMM instructions in the work plan are incorrect, unclear or omitted and the subsequent provision of feedback to the plan, in accordance with existing work management feedback processes, ensuring that the conditions and instructions are corrected for the current activity and recorded for future activities.

Process and methods for determination and verification of the list of FMM materials, tools and equipment that may be needed for the job (e.g. plugs, covers and caps) and their inclusion in the work package also need to be defined and described. Again, feedback mechanisms and the process of correcting work packages for missing FMM materials, tools or equipment together need to be identified in the FMMP governing procedure (or refer to existing work control and management procedures/processes) for the current and future activities.

5.5.9.2. Foreign material management plan

Output of the activity planning is typically a FMM plan document (or a set of documents) that describes the elements, aspects, interfaces and well-thought implementation scheme and strategy of FMM and FMC for/of a particular activity. Overall, the FMM plan is a communication method (see Section 5.5.10.1) as it contains a formulated written cross-organisational communication of the requirements, expectations, responsibilities, actions, methods, tools, that are necessary from all organisations involved in the activity, regarding the management of FM. This is typically a living document that is drafted, published, reviewed and revised for FMM considerations of an activity from the preliminary FMM plan to baseline FMM plan for final approval and implementation. As a usually practice the FMM plan is included in the work order package.

The scope and extent of the FMM plan, per the scaling in graded approach, depends on the risk and complexity of the job, as well as the involvement of multiple organisations and activities.

FMM plans for activities with a high probability or consequence of FMI may be much more detailed to ensure organisations are adequately prepared and interfaces are strongly established that those of simple or routine activities with low FM hazards and risks. Regardless, FMM plans need to define and describe the FMM specifications and interfaces for the activity:

— In enough detail to establish and communicate a baseline plan that is capable of meeting FMM needs and means by all relevant and involved organisations;

— As far in advance as possible to facilitate appropriate reviews and approvals as well as completion of any preparation, e.g. procurement and training requirements/needs as part of the activity.

The FMMP document needs to provide clear guidance and criteria on the graded approach on the scope and extent of the FMM plan, that would include the following considerations and their weighting, for example (see also Section 4.5):

— Nuclear, industrial and radiological safety impacts;

— Plant performance goals and expectations;

— Degree of probability/risk of FMI event based on the existing/generated FMs, created FM paths and FM targets during the entire activity;

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— Severity of consequences of FMI regarding safety, health, economic and financial aspects;

— Rarity/frequency/specialty of the activity;

— Complexity of the activity;

— Evolutions and interfaces involving multiple work groups;

— Level of interaction with parallel activities of the same or different scale.

Section 5.5.10.1 provides further details on the content of a typical FMM plan document that communicates FMM specifications and interfaces for the activity (e.g. FMM requirements, expectations, responsibilities, actions, methods, tools) between all organisations involved in the activity for the understanding and agreement of a common strategy and implementation.

5.5.9.3. Management of unplanned field changes

As aforementioned in Section 4.8, an activity planning cannot itemise any unplanned or unexpected profound conditions and needs that may arise during the course of activity (e.g. changes in plant conditions during operation and maintenance phase, field changes during construction, equipment failures). However, it may anticipate and provide contingency and allowance for rearrangement of FMCs for recovery of schedule and coordination of resources.

The contingencies could be made a part of the main activity plan or may be a supplement to it as ‘contingency planning’.

Circumstances will inevitably arise where unexpected conditions are encountered which may affect or compromise the original FMM plan. Workers are expected to stop work and consult the supervisor in the event unforeseen situations for which they do not have sufficient training or adequate procedures or if a new FMM issue is discovered, which was not anticipated when planning the work. Any ‘at risk’ activity has to be acted upon immediately and actions to reduce any foreseen potential FMI risk are to be taken. The supervisor ought to be able to advise workers of proper FMM techniques at any point or be able to seek assistance from more knowledgeable individuals in the organisation.

In cases of changes to the FMM plan, existing FMRL particularly has to be reviewed and, if a higher risk is determined, then FMCA and all applicable requirements and expectations have to be transitioned. For example, one owner operating organisation, which is using a three zone, no risk, standard (or Level 1) risk and high (or Level 2) risk, has established the following requirements for FMCA transition up and transition down:

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

 Erect boundary perimeter, if not previously established;

 Remove unnecessary and unessential materials, parts, tools, personnel, etc, from area;

 Perform upgraded housekeeping activities inside new High Risk FME AREA/ZONE and adjacent area;

 Assign FMCA Monitor and inventory and log all remaining items inside FMCA;

 Post area as High Risk/Level 1 FME AREA/ZONE;

 Maintain the area as per High Risk/Level 1 FME AREA/ZONE requirements;

— 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.