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Assessment and improvement of foreign material management (‘Act’) 56

4. FUNDAMENTAL ASPECTS OF FOREIGN MATERIAL MANAGEMENT

4.4. Proactive programme

4.4.5. Assessment and improvement of foreign material management (‘Act’) 56

The ‘Act’ activity aims at the timely mitigation and correction of deficiencies and weaknesses identified in the FMMP by a thorough and appropriate assessment, audit (including

self-assessments) and implementation of the requirements and areas for improvement identified by oversight during the ‘Do’ and ‘Check’ activities (Fig. 13).

FIG. 13. Assessing and correcting/adjusting the programme: ‘Act’, FM foreign material, FOSAR

foreign object search and retrieval, FORAA foreign object review and assessment.

A variety of preventive and corrective actions are available to mitigate issues by the assessment and evaluation of detected issues, challenges and pitfalls during the inspection and monitoring of foreign material and associated processes and tasks by, for example, self-checks (during

‘Do’) and oversight (during ‘Check’). Decisions on the type and timing of the corrective and improvement actions are based on assessments of the observed events, near misses and close calls, understanding of the applicable FM prevention, protection and control, predictability of future potential for FMI events, available decision criteria and the effectiveness of available technologies and training.

Additionally, benchmarking of other nuclear or non-nuclear FMMPs can be beneficial in identifying opportunities to improve. A set of performance indicators (metrics) are to be developed to assess the effectiveness and health of the implementation of the FMM programme.

4.5. GRADED APPROACH TO IMPLEMENTATION

In an effective and efficient FMMP, all activities around the SSCs are reviewed for potential threat for an FMI and further planning and guidance are established to control or manage FM or to eliminate or minimise the risk of FMI during performance of these activities, using a graded approach. This graded approach will determine the necessity, type and extent of the application of FMM administrative controls, checks and requirements (e.g. for methods, tools,

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people6) that are to be applied to arrangements and activities in their planning, development, implementation and execution. In turn, the use of the graded approach, which is also discussed in the IAEA publication TECDOC-1740 [46], will help to optimise resources (human, equipment and financial) and costs of preventive, protective and mitigative controls.

In establishing graded control of the activities, there are some common characteristics, based on the existing IAEA industry practices and lessons learned, including:

— Regardless of the organisational and corporate driving factors, selected graded process and its graded approach cannot, in any manner, compromise safety and has to be consistent and compliant with the applicable regulations, codes and standards;

— There is no ‘one size fits all’ grading process as it would vary depending on an organisation’s strengths and weaknesses and corporate philosophy driving the corporate policy, strategy, goals, finances and character and culture of the organization;

— Scaling of graded approach, similarly, will be driven by the same corporate and organisational characteristics that will assign and apply a value, importance and significance to a particular arrangement and activity. However, it is prudent and sensible to apply tighter controls to more significant activities based on their cause and effect aspects. Such aspects that need to be considered and weighed include:

 Nuclear, industrial and radiological safety impacts and importance;

 Quality and reliability designations, requirements, expectations and effects;

 Plant performance goals and expectations;

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

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

 Rarity/frequency/specialty of the activity;

 Complexity of the activity;

 Level of interaction with parallel activities of the same or different scale;

— Administrative framework and associated documents (i.e. administrative procedure) need to provide clear definitions for grading method, criteria, metrics, such that all activities are graded consistently, without complexity, ambiguity or subjectivity;

— Considering the large volume of activities in a plant/project, grading process will demand time and resources. However, based on OPEX:

 Challenge with the demand for time and resources can be eased by pre-grading standard, frequent and routine activities that are performed under same conditions (people, environment, work area, task sequence, nearby SSCs and parallel activities, etc.) without a need for grading every time activity is performed unless there is a change from the standard implementation.

It should be noted that, for such pre-grading processes, the conditions considered in the grading process need to be clearly defined and recorded in tasks instructions, as any deviation from those conditions would necessitate review and control, and if necessary, regrading. The extent of review and control would be dependent on the amount and magnitude of changes to standard task performance and area;

6 As noted in Ref. [45]: “Controls and checks that could be graded include, for example, aspects such as qualification and training for individuals, type and format of procedures, and requirements on verification, inspection, testing, material, records and the performance of suppliers” [45].

 Graded application of the FMMP requirements and controls, on the other hand, minimises the costs while improving the safety and quality of the performance of tasks by enabling the management to allocate and prioritise resources and attention focusing on activities of greater significance and utilise them to a lesser degree in less critical activities. This prioritisation and focus would achieve minimising FMI events that would have more adverse consequences for nuclear safety, personnel and equipment health, plant performance and economics (since a significant FMI event could result in the allocation of much more resources and more costs and more loss of revenues;

 Graded approach will  in a one-time effort also identify products and activities of lesser (or no) importance and significance among all activities which, then, will enable to determine the minimum amount and extent of controls to be applied going forward;

— It is possible to assign different grading for different stages of the activity evolution.

However, in such cases, entry and exit conditions from one grade to next need to be well defined, documented, validated and verified. Additionally, the changes to the administrative and physical FMCs, from one grade to the next, need to be identified and clear instructions need to be provided for the change management.