5. ESTABLISHMENT AND ADMINISTRATION OF FOREIGN MATERIAL
5.6. Assigning roles and responsibilities to individual and organizations
5.6.1. Typical individual roles by position in the organisation
Every staff (from the highest ranking officer down to the people conducting the daily activities) in all organisations participating in the FM related activities and tasks need to clearly know and understand what their role in the FMMP is and how their workplace, skills and knowledge are to be used in achieving sound decision making on the issues regarding the FMM. This necessitates the identification of which decision making, on what aspect of FMM, is applicable to who in the organisations. For example, role and responsibility for ‘FM awareness’ is applicable to everyone in every organisation in the plant/project, because everyone needs to be able to recognise FM and interpret it for its potential hazard. On the other hand, some staff will have additional specific role and responsibilities (such as the programme owner who has additional decision making on maintaining and improving the programme).
Following subsections provide a typical list of individuals and their roles and responsibilities starting from the highest-ranking officer down to the people conducting the daily activities. It needs to be emphasised again that, regardless of rank and place in the organisation, every position, role and decision is equally important for implementing, maintaining and improving the FMMP, and therefore, the sample list provided herein is not in a particular order of importance of decision making on FMM15.
5.6.1.1. Plant Manager
The ‘Plant Manager’16 is the ultimate decision-making person with the most authority (i.e.
the decision authority, as described in Section 5.4.1.1) in the plant/site/station. His/her authorisation level decisions include those for setting the plant/project goals, expectations and policies for all programmes, processes and the activities performed by everyone (including contractors), as well as those for creating and maintaining a culture and work environment for safe and efficient nuclear power generation.
The role, responsibilities and accountabilities of ‘Plant Manager’ for FMMP, as the decision authority, involve ensuring establishment, implementation and maintenance of an effective
15 The point of this emphasis is that some cliché slogans, such as ‘frontline workers are responsible for FMM’ or ‘the FMM programme coordinator is responsible for FMMP’, may be detrimental and skew to responsibility to one individual or organisation.
16 The term ‘Plant manager’ can have different titles in different Member States and different NPPs, such as, chief nuclear officer, chief engineer, site manager, executive vice president, executive president, etc. The title used herein indicates the highest level of manager in a nuclear plant/project (e.g. nuclear power plant project company, nuclear power plant operating organisation) who is responsible for overall executive decision making for the site/project which cannot be delegated.
Therefore, hereafter, it will be referred in quotation as a representation of the position, not the title.
FMMP with a strong foundation, framework and an aligned direction for its integrated application in overall facility programmes, processes and activities, including:
— Establishing and communicating FMM policy, expectations and objectives in accordance with the corporate commitment;
— Ensuring that a FMM culture, such as ‘no blame culture’, exists in the organisation for encouraging reporting of FM incidents;
— Fostering awareness, ownership, accountability and communication in the organisation on FMI event prevention objectives (for example, ‘zero FMI event’, ‘foreign material free operation’ goals) as a part of nuclear and radiological safety and performance;
— Communicating site FMM policy, expectations and objectives to the offsite vendors, suppliers, contractors to ensure compliance;
— Ensuring that the site implementation of the FMM policy, programme and plans regularly reviewed against the objectives and the FMM objective reviews and programme status updates are included in periodic senior management meetings;
— Demonstrating personal commitment to the FMM policy and showing personal involvement in the application, understanding, alignment and permeation of good FMM practices throughout the organisation (for example, by conducting frequent informal visits to the activity areas, shop floors and training classrooms, general or organisational FMM review meetings/briefings to observe the conduct, to obtain first level feedback from implementation).
5.6.1.2. Foreign material management programme owner
As defined in Section 5.4.1.2, programme authority for FMMP is the FMM Programme Owner, who is the person with responsibility and accountability for owning and overseeing the programme and with authority for making administration level decisions on the governance of FMMP. The FMM Programme Owner role is assigned by the ‘Plant Manager’ to a senior manager in the next layer of management (typically the highest level manager of the division that is most concerned with FMM, i.e. the head of leading organisation, for example, the vice president of operations of a nuclear power plant organisation as it may be structured for a particular operation phase).
The FMM Programme Owner assumes responsibility for the development, implementation and continuous improvement of the FMMP towards foreign material free operation and no-adverse effect of foreign material goals. As such, the FMM Programme Owner controls the concept, framework and contents of FMMP and makes administrative level decisions on the provision, application and preservation of the FMMP to establish and integrate all FMM principles, requirements and expectations into daily activities at the plant/project/site together with the owners/authorities of other programmes.
Specifically, the FMM Programme Owner’s roles and responsibilities include:
— Controlling and managing FMMP and its administration by deciding on the determination, coordination and oversight of programmatic governance, implementation, as well as the associated resources, information and assessments;
— Providing necessary information, tools and financial and human resource allocation to individuals and organisations who perform activities for administration and coordination of FMMP, including the approval of acquisition of FMM information and knowledge means and needs;
— Cultivating FMM culture by supporting and encouraging all organisations to perform their assigned work properly, e.g. by identifying the targets of ownership in order to have
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those individuals and departments to understand and assume the ownership of their part in the FMMP;
— Providing input and advice from the FMM perspective for an executive decision to be made by the ‘plant manager’ and/or by the executive committee(s), i.e. by the decision authority. Here, it should be noted that, in some cases, it may be possible that ultimate decisions are made heavily and/or primarily based on the FMM facts, such as a decision on FM mitigation method or timing following an FMI event. In those special cases, the FMM Programme Owner (or delegated programme coordination authority and decision maker) can have a major role in the final decision making (including vetoing, or requesting change to, the decision solely due to solid FMM concerns). It is important that prerequisites, criteria and steps for such special cases need to be defined in the relevant programmes and procedures of the organization;
— Developing (or reviewing) and approving strategies, plans and processes for FMMP and FMI event prevention in accordance with the corporate strategy and schedule;
— Developing of long-term plans for resource and knowledge management for the continuously effective FMMP administration and implementation for FMI event prevention with quality and longevity;
— Reviewing and assessing the FMMP and making decisions on revisions, when deemed necessary;
— Reviewing key performance indicators for monitoring the health of FMMP and its implementation (lagging), as well as for identification of weakening/degrading areas or potential future issues (leading), and accordingly, establishment/approval of metrics to measure effectiveness against the FMM objectives;
— Presenting programme status and assessment result/conclusions in periodic senior management meetings to provide forward opinions and suggestions, as well as to solicit feedback, regarding the areas for improvement and strength of FMMP;
— Deciding on self-assessments or peer reviews of FMMP with internal/external participants;
— Addressing the FMMP implementation problem areas that are identified by trend analysis and assessments;
— Ensuring that the programme requirements and expectations (and changes to those) are communicated to the entire organisation involved with FMMP and the compliance with unique FMM requirements affecting certain organisations is checked and verified by:
Proposing and designating the preparation of FMM training, including the review and approval of training modules, enabling objectives and curriculum;
Ensuring that all FMMP requirements are being incorporated in departmental training, procedures, work orders, instructions and they are followed by the personnel;
Creating, and overseeing the activities of, FMM review group(s) that consist of representatives from all relevant departments which meet periodically, and when necessary, to communicate and discuss FMM and FMMP issues, ideas, concerns;
Ensuring the assignment of departmental focal points in each department;
Ensuring FMI events are thoroughly investigated and corrective measures for preventing recurrence are identified and implemented;
Ensuring near misses and close calls are being reported and properly investigated and, if any, lessons learned for preventing future occurrences that could lead to an event are developed and incorporated in the FMMP and other programmes, processes and procedures;
Ensuring timely implementation of corrective actions related to FMMP and FMI prevention throughout the organisation;
Requesting evaluations from other internal/external organisations to prevent, detect, monitor and correct potential FMI precursors;
Ensuring the coordination of FMMP requirements, expectations and practices throughout the organisation by:
o Assigning expert(s) and focal point(s) for the coordination of programme administration, implementation, maintenance and improvement;
o Providing such expert(s) and focal point(s) with ownership, authority and organisational freedom to identify and request implementation of FMM measures whenever and wherever required;
o Obtaining an understanding, recognition and agreement from everyone in the organisation(s) on the authority given to such expert(s) and focal point(s);
— Conducting regular scheduled and unscheduled visits to the areas and activities controlled by the FMMP, as well as group staff meetings, training classrooms and shop floors, etc., to:
Share values and vision by sincere and wanted interaction;
Observe implementation of the FMMP, compliance with its requirements and expectations, effectiveness and awareness;
Point out and discuss (good or bad) observations with workers, work area supervisors;
Collect prompt and first-hand feedback.
5.6.1.3. Foreign material management programme manager
In some operating organisations, due to significant involvement and performance of activities that may have direct impact on FMM and FMMP, certain directors/managers may be delegated to carry the administrative responsibility and the coordination level decision making authority for the programme. In such organisation structure, the FMM Programme Manager is the individual who implements and oversees the FMMP with delegated programmatic and administrative authority and responsibility, assuming all (or some) of the responsibilities of the FMM Program Owner that is listed in Section 5.6.1.2. This delegation is proposed by the FMM Programme Owner and approved by the ‘Plant Manager’ based on premise of certain department or group having more opportunities for implementation, prevention and improvement. For example:
“The construction manager is typically appointed to own, implement and assess the programme as the FMM Programme Manager during the construction phase while operations manager may assume that role during the commissioning phase. Similarly, the maintenance manager assumes responsibility as the FMM Programme Manager of the plant for the ownership, administration, implementation and improvement of the FMMP towards prevention and elimination of FM hazards and events at the facility during a typical operating organisation”.
FMM Program Manager also reviews and manages the assessment of programme implementation, the FMMP status/needs and presents his/her conclusions, opinions and advice on the FMMP and its administration and implementation to FMM Programme Owner and/or
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‘Plant Manager’ as input to executive decision making. He/she could also present, if exist, to the decision-making bodies/groups, such as an executive committee or board.
Again, the boundaries for delegated decision-making responsibility and authority on the programme administration need to be clearly established and communicated to the entire organisation and they are understood and agreed. Also, in cases where the FMM Programme Manager has a major role in the final decision making, prerequisites, criteria and steps for accomplishing that role need to be defined.
5.6.1.4. Foreign material management programme coordinator
All the aspects of FMMP (including associated processes, procedures, requirements, expectations, rules, essential information, knowledge) are obtained, verified, understood, interpreted, communicated and expressed in the daily tasks and practices. These activities that involve FMMP need to be coordinated with a high degree of expertise, applicability, accuracy, completeness and timeliness around facility in order to achieve a safe, sound FMM decisions at every level. This coordination is accomplished by a dedicated group of staff, who have competency, proficiency, expertise, knowledge, experience in FMM and FMMP and hard and soft skills in the organisation, led by the FMM Programme Coordinator.
Appointed by, and reports to, FMM Programme Owner/Manager, the FMM Programme Coordinator is the focal point for FMMP and its implementation and maintenance. He/she is the primary interface between the management and the frontline for the management and improvement of FMMP and FMM practices at the nuclear power plant (or project) to:
— Provide input and advice to both plant personnel and managers typically through FMM Programme Owner/Manager and committees/boards on effective FMM and improvement of FMMP;
— Collect feedback and suggestions from both managers and plant personnel for FMM and FMMP and incorporate those into the programme, as applicable;
— Support determination, acquisition, provision, sitewide coordination and oversight of programmatic information, knowledge, status and assessment.
As the site FMM expert (or the leader of expert group), the FMM Programme Coordinator, assumes the roles and responsibilities for decision making at the coordination level with sufficient authority and organisational freedom to observe, control, identify, report and implement FMM practices and FMC measures.
Therefore, the roles and responsibilities of a typical FMM Programme Coordinator in the industry cover a large spectrum from provision of administrative and procedural perspective of FMMP to practical and technical presence/involvement in the field implementation and performance of tasks. In this large spectrum, his/her specific responsibilities include:
— Maintenance of the FMMP administrative (governing) procedure to ensure its adequacy, correctness, completeness, clarity, applicability and timely use;
— Preparation (or supporting preparation) of FMMP administrative and implementing procedures (including the supporting/supplementing documents, tools and means, such as checklists, logs, report forms, etc.) to establish the standard framework for FMM application throughout the organisation;
— Review and validation of all the aspects of the FMM plans and programmes are being addressed and implemented in the procedures and processes of relevant departments;
— Preparation and communication of FM anticipation, prevention, elimination, exclusion, mitigation and investigation instructions and key knowledge sheets;
— Request and collection of evaluations from other internal/external experts to prevent, detect, monitor and correct potential FMI precursors for reporting to the FMM Programme Owner/Manager and other relevant departmental leadership;
— Conduct of area walkdowns for activities, that are controlled by the FMMP, to:
Observe and collect feedback on compliance, effectiveness and awareness;
Recognise the FMM culture in action (including good and bad cultural traits, e.g.
awareness, housekeeping, cleanliness, application in general plant areas);
Point out and discuss observations (good or bad) with workers, work area supervisors in a constructive manner (i.e. coaching and praising), in the context of FMMP and from the FMM and FMMP expert’s perspective;
Note and report possible areas for programme improvement to the FMM Programme Owner/Manager;
— Participation in special activity coordination meetings, such as daily outage meetings, work planning meetings;
— Following up on FM related events, near misses and close calls to:
Confirm that they are properly reported and investigated ensuring their adequacy and completeness from FMMP perspective;
Provide expertise and input to investigations, when needed;
Incorporate lessons learned, if any, in the FMMP and associated processes, procedures and instructions;
— Coordination of, and participation in, scheduled inspections and audits of the work areas, procedures and processes of related departments with the oversight organisation(s);
— Determination of applicability of external FMM and FMMP implementation issues to the plant organisation(s) by reviewing and analysing OPEX in industry databases and any other relevant sources, such as nuclear and/or non-nuclear industry studies, events, practices;
— Participation in benchmarking activities and industry working groups to follow, observe, learn and share industry good practices and lessons learned;
— Recommendation and/or incorporation of updates to FMMP based on the lessons learned by, for example:
Area and activity walkdowns (his/her own and others’) and collected post job briefing notes and task knowledge sheets;
Following up on FM related events, near misses and close calls;
Reviewing results of investigations, evaluating the adequacy of corrective actions and recommendations for corrective action, if necessary;
Reviewing OPEX from the plant and nuclear or other industries;
— Provision of assistance and FMM expertise in the identification of training needs and target audience, as well as supporting the development of training material, delivery and evaluation of training (initial, periodic and as needed);
— Identification and coordination of procurement and supply of FM prevention and control methods, devices and tools to the requesting/needing departments;
— Maintenance of metrics/performance indicators to monitor and measure health and effectiveness of the FMMP, including:
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Performing trend development, analyses and identification of internal FMMP implementation problem areas by using the results of analyses;
Preparation of technical results and observations to provide them to FMM Programme Owner/Manager and relevant organisations;
Preparation and dissemination (site wide posting) of effectiveness review results, particularly those areas with exemplary improvement or degradation, to the site personnel or relevant specific departments/sections through the appropriate communication media;
— Maintenance of FMM campaigns, such as FM Awareness postings, FM Alerts and other FMM and FMMP related communications to the entire organisation;
— Reporting of all FM related issues (including periodical updates on the programme status) to the FMM Programme Owner/Manager (and, if requested, to ‘Plant Manager’) and providing recommendations for the improvement of FMMP elements.
Although it may be a good practice to have a focal point (i.e. a single point of contact, SPOC) for FMMP coordination and maintenance at a plant/project, as it can be seen above, the FMM Programme Coordinator usually has a large amount of responsibilities and tasks. This has presented an issue, by itself, for effectiveness (or even existence) of FMMP, as it is observed in the OPEX:
“Overloading of FMM Programme Coordinators has been a challenge throughout the world for both the FMM Programme Coordinators and the NPPs, particularly creating problems in maintaining and managing the programme, such as:
— Burning out of FMM Programme Coordinators with overwhelming tasks resulting in frequent turnover of the personnel that has required hiring or developing technical staff, who have competency, proficiency, expertise, knowledge and technical and soft skills, assuming the roles and responsibilities.
— Organisation(s) and/or FMM Programme Coordinators starting to prioritise responsibilities and tasks which results in only the tasks with this ‘perceived and accepted’ high priority getting done completely and comprehensively while the others get done ‘when time is available.
This, in turn, has caused:
— Omissions and deficiencies in those activities owing to cursory work.
— Slowly eliminating tasks, that are under the responsibility of FMM Programme Manager, by inadequate or false justifications/reasons (mostly based on artificial priority criteria and bases) or establishing situational and shortened lists or frequency of tasks in the same manner.
— Increasing costs of FMMP and its maintenance and management, resulting in questioning the cost/benefit of the programme.
These three main problems have resulted in degrading FMM practices and ineffective FMMP, decreasing attentiveness, seriousness and meticulousness
of FMM Programme Coordinators and plant staff or, even worse, slow and eventual elimination or marginalisation of systematic and formal FMMPs.
Consequently, in some Member States, plants are considering the elimination (or they are eliminating) FMM Programme Coordinator position altogether by process changes as a part of change management plans for efficiency increase and cost reduction” [67].
Some plants/projects chose to solve these problems by systematic and conscience actions to maintain or improve effectiveness of FMMP coordination, maintenance and implementation tasks and activities. Primarily, these plants/projects have driven the programme coordination to ‘shop floors’ and/or ‘expert groups’, for example, by:
— Permeating responsibility in the organisation to perform most of FMMP coordination tasks/activities correctly and effectively after identifying/determining the core responsibilities of an FMM Programme Coordinator and then assigning other responsibilities in one or both of the following manners:
To individuals who are distributed in the departments, where the programmatic responsibilities for field implementation and performance of tasks could be accomplished more effectively, providing clearly defined interfaces and protocols between them and the site FMM Programme Coordinator, who remains as a focal point;
To committees of representatives from departmental levels and layers that can perform review and assessments and can provide consensus recommendations to the FMM Programme Coordinator and/or to the FMM Programme Owner/Manager;
— Centralising responsibilities in a group of staff, who have competency, proficiency, expertise, knowledge and technical and soft skills, in a dedicated FMM Programme Coordination Group, under the leadership of FMM Programme Coordinator, as the FMM and FMMP conscience of the plant/project (see Section 5.6.2.13).
Sections 5.6.1.5 and 5.6.1.6 discuss these permeated and centralised FMMP administration arrangements that are implemented by the management of various owner/operating organisations, respectively.
5.6.1.5. Foreign material management department coordinator
In order to resolve the challenges with the large number of responsibilities and tasks assigned to the FMM Programme Coordinator, several plant/project organisations have chosen to permeate some roles and responsibilities of the FMM Programme Coordinator specifically those which had less to do with the programme management and had more involvement with the field implementation of tasks/activities and created FMM Department Coordinator positions.
The FMM Department Coordinators are local (e.g. in/of a department or a line of work) FMM experts with competency, knowledge and technical and soft skills for FMMP and its coordination and execution, in addition to their core work proficiency and skills. They are delegated to carry FMMP coordination responsibilities in/for their department and are the primary interface between the FMM Programme Coordinator and the frontline (i.e. as a bridge integrating the FMMP administration and execution for the management and improvement of
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FMMP and FMM practices). Furthermore, they are given sufficient authority and organisational freedom to observe, control, identify, report and implement FMMP activities and measures at the department level. Therefore:
— An FMM Department Coordinator is appointed by his/her departmental manager with a request and approval by the FMM Programme Owner/Manager and the FMM Programme Coordinator;
— The responsibilities and accountabilities of an FMM Department Coordinator, as well as his/her authority to locally coordinate and/or implement FMMP activities and measures, need to be clearly defined and described the FMM Programme Owner/Manager and the FMM Programme Coordinator (and agreed by the departmental manager and the employee).
Possessing the awareness, ownership and the channels of communication on both FMM/FMMP aspects and the tasks of his/her department, with their FMM and FMMP expertise, information and knowledge in both areas, they would be able to:
— Coordinate specific FMM tasks/activities, that are related to their own profession and departmental task performance, more closely and specifically;
— Provide expert opinion, input, feedback, suggestions and recommendations on FMM and FMMP related issues and areas for improvement (or overall programme improvement) to FMM Programme Coordinator and their line manager from task performance perspective;
— Identify and evaluate FMI precursors, hazards and risky conditions for prevention, detection, monitoring or elimination/minimisation in departmental activities;
— Provide input and suggestions to the workplace frontline personnel on awareness, recognition and solution of FMM challenges and on the effectiveness of FMM and FMMP implementation in their activity execution;
— Collect feedback and suggestions from line manager and workplace colleagues for FMM and FMMP and communicate those the FMM Programme Coordinator, as applicable for the FMMP improvement.
The specific responsibilities of FMM Department Coordinator, which are a set of the responsibilities of the FMM Programme Coordinator at the departmental level, typically include:
— Ensuring the FMMP administrative (governing) procedure and departmental implementing procedure are adequately, correctly and timely aligned and harmonised;
— Supporting development of departmental implementing procedures (including the reflection of supporting/supplementing documents, tools and means, such as checklists, logs, report forms) to comply with and reflect the standard framework for FMMP implementation and application in own organisation;
— Following up on all the aspects of the departmental input and feedback on FMM plans and programmes are addressed and implemented, as applicable, in the procedures and processes of own departments;
— Conducting walkdowns of the areas and activities of own department to observe and coach programme and implementation effectiveness and culture in action (also observing good and bad cultural traits, e.g. awareness, housekeeping, cleanliness in general plant areas);
— Discussing (coaching and praising) observations (good or bad) with workers, work area supervisors from a local FMM and FMMP expert perspective, as well as reporting the