5. ESTABLISHMENT AND ADMINISTRATION OF FOREIGN MATERIAL
5.5. Establishing and describing administrative controls
5.5.6. Storage controls
5.5.6.1. Warehouse storage of components, equipment, parts and materials
Once the component, equipment, material or part is delivered and the receipt inspection verified the FMM requirements being met, it will be stored in an onsite warehouse (which typically consists of a central storage facility for the entire site and several dedicated storage areas nearby the activities or activity groups, e.g. maintenance workshop). In order to ensure that parts and materials provided to the plant/site/station remain free of FM between the performance of receipt inspection and the time when they are prepared for installation, FMC processes and practices need to be applied to protect the stored component, equipment, material or part from FM ingress and to prevent generation of FM in, on or around them.
Considering that the storage period could be long sometimes lasting for decades and the storage conditions may vary during such a long time, sustained and adapting FMM efforts are essential from the asset management point of view. Especially in long-lasting or suspended construction phases, during which the component, equipment, material or part more likely to be stored outdoor facilities for decades, extra efforts to protect assets protection become very important, as it has been shown by one well known industry experience:
“In an Argentinian NPP project, the construction was put on hold for nearly 30 years after most of the plants components and equipment were delivered to the site. This required FM protection and prevention tools, methods and activities to maintain the material FM free for decades. Successful equipment
protection including FMC resulted in only 10 per cent of the material ended up being needed service or disposal”.
Therefore, the FMMP administrative procedure needs to define and clearly describe the FMM requirements and controls for onsite storage, particularly during construction and operation phases. The FMMP procedure may also refer to the administrative (or task specific) procedures and processes of other programmes, such as the procurement programme, for descriptive instructions. In such cases, however, the FMMP administrative procedure still contains the criteria, requirements and responsibilities for designation and interface). Furthermore, FMMP administrators need to ensure that the storage instructions regarding the FMM are correctly and completely incorporated (and maintained/updated) in those processes and procedures.
The key element for FMC during storage, of course, is maintaining cleanliness in the warehouse and all storage facilities by:
— Keeping the areas clean, tidy and free of debris and other FM in accordance with the applicable housekeeping and cleanliness requirements and standards and ‘clean as you go’ practices (for example, by keeping general warehouse floors, aisles free of scrap material, packing wraps, cardboards, wood, straps);
— Routinely inspecting the storage areas/warehouses holding equipment or components to ensure that housekeeping and cleanliness standards are met.
In addition to reiterating or emphasising those general cleanliness requirements, the FMMP governing document needs to identify and describe specific requirements, controls and actions for FMM during storage, which are typically applied during three distinctive stages of storage, such as:
— Controls for accepting the components, equipment, material or parts to the warehouse:
Items are delivered/returned to warehouse with all proper FMC devices in place and intact, with internal and external cleanliness is acceptable for storage;
In the cases of missing FMC devices, the subject material can be accepted for storage only after verifying that no FM in, on or around the item and applying necessary FMC devices for storage;
The items that are received with ‘NOT FM INSPECTED’ tag/label are accepted only if it is logged as ‘not FM inspected’ and they are moved to storage with such tag/label is intact;
— Controls during the time of storage of the components, equipment, material or parts in the warehouse:
All items ready for storage have FMC devices are clearly identified and marked with standard FMM markings/labels/tags, which contain clear, accurate and complete information for FMM aspects and are consistently placed on the outside (or on the outer package), such that they need to be visible without moving the item;
‘NOT FM INSPECTED’ tags/labels remain on the items during the entire time of storage, for those that were not completely and thoroughly inspected for FMM measures and FMC devices;
FMC devices, when they are temporarily removed for internal access for a required service or inspection of a stored item (such as valves that require periodic inspections and cleaning to remove dust, dirt or any other FM, particularly from
114
seat surfaces when in long term storage), are reinstalled immediately after the service is completed;
Movement of items within the warehouse facility is avoided or minimised such that the risk of damage to the equipment, component or parts, as well as to the installed FMC devices, is reduced;
Parts, materials, components or equipment are stored in accordance with the manufacturer’s storage specifications including those for the FMC and such requirements may be specified (or emphasised) in the FMMP governing procedure, particularly those that are related to the SSCs with high FM risk, for example, as noted by an international expert:
“One FMMP procedure specifically mentioned the manufacturers specification for the storage of safety-related check valves to emphasise and increase awareness of storage conditions which were specified by the manufacturer as: “in an area with minimal dust and dirt; on a flat service; in an indoor dry warehouse where the item is not exposed to sunlight and the temperature and humidity are kept constant; and away from flammable or explosive materials and preferably in a ventilated room”
In case of absence of specific conditions, the storage area is selected by using a graded approach to minimise or eliminate conditions for:
o FM existence and generation around the items while in storage (for example, by selecting appropriate storage place for FMM, i.e. indoor or outside, aisle or wall, segregated or together with cardboard crates/boxes, to protect from dust and dirt);
o Degradation, deterioration or erosion/corrosion of parts, materials, components or equipment, including the FMC devices, due to the environmental conditions, such as heat, cold, sunlight, dryness, moisture, corrosive material nearby (for example, storing indoors or covering while outdoors for minimising sunlight impact), or physical factors (for example, vertical or horizontal orientation of valves, stacking of bendable items);
o Restrictions/obstacles for serviceability and movement (for example, storing on aisle versus wall side, shelving high or low) that may impact FMCs;
— Controls during the discharge, transfer and preparation of items, by the warehouse staff, to the activity area for the installation:
Ensuring that FMC devices and covers remain in place during the delivery;
Preparing/staging in a location where there is none or minimum possibility of FM ingress, i.e. not opening and staging the component where dust or debris from nearby activity could be blown, scatter or fall inside the component/equipment when the packing is opened and FMC covers are removed;
Unpacking the items before bringing into the FMCA or, if it is impossible to do so (such as in cases when the packaging needs to remain on the material until use, for example, due to fragile or sensitive content), unpacking them cautiously possibly under the observation of a second bystander and removing the packaging material from the FMCA as soon as the packing material is no longer protecting the material.
It is also important to be understood by the workers, who will receive and install/use the item, that storage, delivery and staging requirements do not ensure that items are cleaned to a level that is acceptable for installation into the plant when prepared for use/installation by the warehouse staff. Therefore, the activity workers are still responsible for checking, confirming and/or establishing cleanliness of items prior to installation in accordance with system cleanliness and FMM requirements.
5.5.6.2. Storage of tools and FMC devices
In addition to warehouse storage of equipment, material, parts and components, a unique process of FMM is the storage of tools and FMC devices in small and local facilities around the site for nearby availability, easy access or radiological considerations.
In most plants, there are implementing procedures, as well as assigned ‘tool rooms’, for maintaining and controlling tool inventory and tool conditions, including those for FMM.
Otherwise, the FMMP administrative procedure establishes and describes a FMM process to store, maintain, account for and control tools (including personally owned tools, if permitted) to prevent and protect the SSCs from FMI caused by inappropriate or faulty tools. Additionally, the governing programme document needs to establish requirements and controls for FMC devices and FMM materials (which may be stored in FMM cabinets, bins, shops around the common activity areas (as discussed in Section 5.5.4)) for their integrity, availability, accountability and maintenance.
Regardless of where it is described and instructed, in an effective FMMP:
— Tool and FMC device/material storage, maintenance, accounting and reconciliation controls include the requirements and expectations for identification, inventory, location and condition tracking of tools and devices, recordkeeping methods;
— Governing FMMP procedure (or implementing procedures) addresses the requirements for servicing and preservation of good FMM conditions for tools (e.g. tool integrity, cleanliness) and FMC/FMM materials, including those for their requests, procurement and delivery to the activity areas;
— Inspection of tools for moving, loose and missing items prior to and after use (see Section 5.5.3) is a required process (or a high priority expectation, as a minimum);
— Process for inspecting returned tools and, if identified, reporting lost, damaged, broken, incomplete, dismantled, fragmentary and defective tools is clearly described with the requirement that the tools to be collected and returned to the staging area as soon as practical.
Also, typically, there are strategically placed permanent or mobile cabinets and cribs for in general areas or activity specific locations to store other FMM materials, such as stickers/signage/boundary markers, tool controls, clear and coloured plastics, nylon panels, magnetic and Velcro straps, loops and hooks to attach and secure nylon or cloth panels to each other and to anchoring structures (e.g. handrails or guardrails, bottom to kickplates) to secure nylon or cloth panel skirting to floor structures.
It is a good practice to establish catalogues of available tools (including special tools, such as inspection, cleaning, search, recovery and retrieval tools), FMC devices (see Section 5.5.4) and FMM material, as well as their storage locations, i.e. tool and material rooms, tool cribs, material cabinets, bins, boxes, etc. This catalogue needs to be made easily available to site personnel, preferably electronically, and as applicable, in hardcopies.
116