5. ESTABLISHMENT AND ADMINISTRATION OF FOREIGN MATERIAL
5.6. Assigning roles and responsibilities to individual and organizations
5.6.2. Typical organisational roles by functions
As mentioned earlier, the specific organisational structure is not a major factor, provided the FMM practices in plant activities and tasks are correctly recognised and performed in a timely manner by everyone and every part of the organisation. Therefore, it is more important to focus on the core elements of FMM and FMMP and plant/project functions and activities, as well as ownership of other programmes associated with these activities, rather than a rigid organisational structure and assignment.
Saying that, certain organisations perform activities that may have more direct impact on (or impacted by) the FMMP and associated processes and procedures, thus, have more opportunities in/for implementation and improvement, while some others do not. A graded approach to assign organisational roles and responsibilities is primarily based on the nature of activity, such as owner, area, systems and materials involved, impact/value of the activity to/from FMM policy, programme, processes and procedures. These characteristics of the activity need to be considered in the foundation for organising and assigning organisational FMM roles, responsibilities, accountabilities for FMM related activities in the implementation and improvement of the site FMM and FMMP.
For example, during the operation phase, the maintenance organisation would be more often involved with infield activities where FMM practices are frequently and routinely applied and utilised. Typically, it is the maintenance managers and supervisors who would be more likely to be present and conduct scheduled, and unscheduled observation visits of the areas and activities controlled by the department. Therefore, they have more opportunities to observe compliance, effectiveness and awareness of FMMP and providing observations and coaching to area team leaders and workers to improve performance and awareness and to do so more frequently than other organisations. At the same time, the technical support organisation, i.e.
the engineering organisation that is responsible for design, system, fuel/core management, would be more focusing on establishing adequate design and monitoring processes/controls in place for FMM and/or evaluating consequences and resolutions of FMI events on plant design and performance. Also, in some operating organisations where the technical support is decentralised, local engineering groups, such as reactor, maintenance or refuelling engineering, take more diverse responsibility on FMMP under their umbrella organisations.
On the other hand, during the construction phase, construction organisation is the organisation that is in charge of all the activities that are being performed and it performs or oversees tasks, while operation organisation might be in charge of commissioning activities.
Again, in any case, a common FMM commitment and policy is necessary to exist throughout the organisation, with both vertical and horizontal communication and alignment, to ensure that the FMMP is implemented collectively and effectively. In that manner, all organisations equally understand the importance of good FMM practices and the consequence of poor ones, while they are aware of FM and FMMP and uniformly know, understand and interpret FM, FM hazards and targets in their specific activities towards foreign material free operation and no-adverse effect of foreign material.
5.6.2.1. Maintenance organisation
As the organisation that is typically in charge of maintenance activities during the operation phase, it performs tasks which have the most potential for FM hazards and risks. Thus, it may the focal point and the champion of FMMP and, typically, is the FMMP owner organisation during operation phase. Routine maintenance activities include FMMP elements and FMM considerations in every task and the maintenance organisation needs to establish special (and/or standard) FMC mechanisms for unique tasks, in coordination with and support from other organisations. As mentioned earlier, such involvement also provides more opportunities for improvement of the site FMMP, thus the Maintenance Organisation is a major source of feedback to other organisations and the FMM Programme Coordinator (and in cases, such as in a particular phase of NPP lifetime, where the programme ownership lays with another organisation, to the FMM Programme Owner/Manager).
5.6.2.2. Work control organisation
Prime responsibility of ensuring the adequate task performance and the environment, in order to protect against hazards, risks and events, lays with the planning and scheduling of the activity. Work Control Organisation, focusing on knowledge and information about the FMMP in the plant’s/projects tasks, anticipates and conceptualise the activity for FMM and FMCs.
Carefully investigation of activity and work conditions prior to the performance of the task by work control and planning organisation identifies potential FMs, their generation, target SSCs and ingress paths (and, if needed, recovery options from an FMI), and hence, provides first-order protection that would be reflected in the work first-orders, pre-job briefings and FMC tools and devices. The work control organisation is also responsible for ensuring the coordination of activities that would be interfering with each other to protect equipment and environment from cross-contamination by dirt, dust and other foreign material.
5.6.2.3. Outage organisation
The greatest potential for FMI events is during plant outages when refuelling is performed and maintenance on SSCs and equipment is conducted, particularly owing to multiple tasks being simultaneously performed on and around open systems (and the site, at large) which increases the FM hazards and risks. Furthermore, during the outages, there is a higher potential of one-time or infrequent tasks being performed which require unique or particular attention to FMM aspects.
As the organisation that is in charge of all the activities during a plant outage, Outage Organisation can assist in elimination/minimising the risk of FMI events with coordination and sequential execution of work activities (particularly those to be performed nearby each other
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simultaneously or in series) where potential for generation, transport or intrusion of FM on open systems exist.
The OCC and the OCC teams need to be aware and understand the hazards, risks and impacts of FM on the coordination of activities, and therefore, FM, FMM and FMMP requirements and expectations need to be discussed during the daily outage meetings and awareness and anticipation for FM need to be highlighted during outage coordination.
The OCC teams also need to be informed of any FMI events that have occurred and get involved in the recovery of the material. FMI events during the outages are particularly critical since their consequences may not be realised until the consequent unit start up and operation at power when safe and efficient performance could be adversely and significantly impacted.
The outage organisation also may help with establishing KPIs for the FMM and FMMP implementation during the outages and afterwards. As these FMM and FMMP metrics/indicators can be a part of the outage goals that are tied to the overall plant/project KPIs, including those for FMMP.
Moreover, outage organisation typically requires active involvement and presence of FMM programme owner/manager and coordinator(s) in daily outage meetings during which task performances, as well as FM events, close calls, near misses and good practices, need to be discussed.
5.6.2.4. Operations organisation
The Operations Organisation perform various tasks and activities with potential for FM and FMI risks and hazards, such as filling plant systems, draining, flushing, handling and loading fuel, performing work adjacent to and over spent fuel bays, resin routines among other open system or component work, and therefore play an important role in FMM towards foreign material free operation.
In addition to creating potential for FM and FMI, operations also perform routine field inspections of the plant that can identify FM hazards, areas at risk for potential FM and FMI due to housekeeping issues, system deficiencies, missing or deficient FM barriers or other causes.
Operations may also be involved with FM and FMI identification through routine testing of systems and normal surveillance of system operation/performance, and certainly they would be involved with FMI mitigation and evaluation.
5.6.2.5. Construction and commissioning organisations
As discussed in Sections 3.3, Construction Organisation is the organisation that is in charge of all the activities that are being performed and it performs or oversees tasks that are unique, first-time, large and/or complex, and typically, with extensive and numerous FM hazards and FM targets during the construction phase (noting that, as aforementioned, the refurbishment and major modification project organisation could also be considered as construction organisation).
The construction activities are mostly conducted in a widespread area by multiple disciplines, interfacing and interacting with other simultaneous work. Therefore, the construction organisation would be managing and controlling significant amount and variety of FM which
would be associated with more FM hazards and higher FMI incident risks (mostly necessitating special/unique prevention and protection strategies and means).
More importantly, FMI events during the construction are critical since their consequences may not be realised until the commissioning even until the operation where the efficiency and performance, and potentially safe operation, of NPP are adversely and significantly impacted.
For these reasons, generally, the Construction Organisation is the owner of the FMMP during the construction phase and even during commissioning phase since there maybe overlapping activities. As discussed in Sections 3.3. and 3.4, such overlap put the plant and the associated SSCs in a complex situation from the FMM perspective, as final adjustments are made during the construction of some systems while other systems are being tested. In such cases, Commissioning Organisation may become the owner of FMMP.
5.6.2.6. Training organisation
As discussed in Section 4.6, training is an essential part of the FMMP implementation to ensure the understanding of FM, FMM and the relevant planning and performance of tasks accordingly. Training Organisation is, therefore, one of the core entities for establishing and maintaining the information for, and knowledge of, workers, managers or contractors on the elements of FMM and the requirements and expectations of FMMP implementation.
As such, the Training Organisation is responsible for educating the relevant personnel on the awareness of FM, FM hazards, risks and the causes and consequences FMI event, individually and collectively. The training organisation fundamentally contributes to the recognition of FM, prevention of FM generation and FMI events by the provision of initial, continuing and special training. In coordination with the FMMP owner organisation and applying SAT and training techniques, the Training Organisation identify the training needs and associated type, material and environment, ranging from a general FMM awareness and expectations training to all site personnel, to detailed and in-depth training modules for particular disciplines. Using a graded approach, the organisation will set training sessions on particular applications of FMM elements, methods and tools to their specific tasks (e.g. maintenance activities, fuel handling evolutions, chemistry sampling) and will evaluate the results for the continuous improvement of the training.
5.6.2.7. Technical support organisation
The Technical Support (e.g. Engineering) Organisation carries direct and indirect responsibilities for FMM and FMMP in every stage of the lifecycle of an NPP (see Section 3.2 and Section 3.5.2). The proactive and direct organisational responsibilities include designing and engineering FMM features that are built (or to be built) into the SSCs, such as devices, materials, chemicals, etc., as well as the considering concepts, designs and arrangements of some temporary protective/preventive devices and tools.
The system cleanliness, material compatibility criteria and requirements and associated verifications, as well as the predictive models for ingress and transportation paths to prevent FMI events during activities, also require engineering organisation input and review.
In reactive (mitigation) manner, i.e. in case of an FMI event, the engineering organisation may carry responsibilities for:
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— Supporting search, detection and removal of FM by designing, proposing or assessing methods, tools and techniques that are discussed in Section 6;
— Performing evaluations and assessments to support the decision to accept/reject the intruding FM as part of a system or component, i.e. redefining the material as ‘non-foreign’ and ‘a new part of the SSC’ in integrated design and overall operation of the SSCs, as discussed in Section 7.
Consequently, they may be responsible for tracking the type, amount and location of FM detected, recovered or left in the SSCs, as well as their impacts on overall plant SSCs. Also, similar to the good practice discussed in Section 3.2.1, the design engineering organisation would establish and update FMT&PDs taking into account the operability and maintainability experience to maintain the mapping of FMs that are evaluated and left in the SSCs, as well as in other design output diagrams and schematics, e.g. process flow, P&ID, maintenance and repair, pneumatic and hydraulic system diagrams, which are discussed in Section 7.
5.6.2.8. Radiation protection organisation
This organisation frequently enters FMCAs to perform surveys or contamination control activities, and therefore, has to follow and adhere to FMM requirements relating to that work area. Radiation Protection Organisation would also assist with ALARA assessments in task planning of a performance, as well as with FM mitigation and recovery assessment and planning relating to intrusions in or around radioactive systems.
5.6.2.9. Chemistry organisation
Routine chemical sampling supports the detection of FM in the SSCs, such as fuel and core, in a timely manner. Therefore, Chemistry Organisation carries responsibilities for FMM in plant systems. The organisation may be directly responsible for control and assessment of any soluble FM and FMI in the plant fluid system. Furthermore, reviews and approvals of chemicals for compatibility with SSCs also reside with Chemistry Organisation, and hence, they are requested to review and approve proposed FMC devices for system compatibility issues, as well.
5.6.2.10. Quality assurance/quality control organisation
In every stage of the lifecycle of an NPP, the QA/QC Organisation carries responsibility for overseeing and inspecting the quality of work, SSCs and materials to ensure adherence to quality standards as well as the expectations of owner/operating organisation. As the QA/QC requirements are (can be) part of the activities by all organisations, the QA/QC Organisation provides support to the activity specific organisations, including the FMMP owner organisation, on the determination and communication of requirements and compliance.
Specifically, in the FMMP implementation and compliance, the QA/QC organisation provides regular inspections of activities, areas and stored equipment and material and reports the non-compliance. In the task level, depending on the nature of the task, the organisation may also have inspections and monitoring roles in area/activity QC checkpoints, close out inspections, among other QA/QC aspects.
Additionally. in following up on FMI event evaluation, root cause determination and corrective action implementation, QA/QC organisation carry responsibilities.
The organisation may also oversee onsite or offsite manufacturing and installation controls and acceptance inspections and conduct independent audits/assessments to ensure the compliance with FMMP requirements and FMM practices, as applicable.
5.6.2.11. Procurement and warehouse organisations
Procurement and Warehouse Organisations are responsible for ensuring the supplies are manufactured, acquired, transported, received and stored free of foreign material.
Procurement personnel ensures this through identifying, describing and communicating specifications, requirements, expectations through purchase order and contract clauses for FMCs (and FMI terms and conditions for contract services) for the activities, components and services (such as for manufacturing, transport, factory and receipt inspections, storage). They also communicate with the FMM Programme Coordinator for FMC tools specifications, selections, stocks and availabilities.
The warehouse personnel ensure that the supplies are delivered free of FM and remain so during the storage (i.e. from the time when items are delivered to the warehouse to the time they are prepared for use in the installation). As such, they perform FM receipt inspections, described in Section 5.5.5.6, when the supplies are received for acceptance and storage. They move the items to storage and ensure the prevention and protection of components, equipment, materials or parts that are in the warehouse inventory from the FM ingress and generation in or on them during the storage. They also deliver and stage equipment, parts and material to the activity areas and ensure that the activity receives (and when applicable, unpacks) them free of foreign material.
5.6.2.12. Security organisation
Security Organisation is a very important contributor to FMMP implementation and improvement due to their proximity to the plant SSCs, as aforementioned several times in this publication. Their direct interference with the plant facility, equipment and material, such as the security inspections of equipment and materials entering and exiting the NPP site which makes them responsible for FMM and, in some cases, FMI. For example, based on the cases from industry experience:
“FMC devices that were removed to facilitate security inspection were not restored to their pre-inspection or they were damaged during the inspection and left at those conditions after the inspection, resulting in FM incident”.
Thus, security personnel need to know that their inspections may potentially result in an FMM issue, and therefore, gaining and maintaining FMM information and knowledge is essential.
Also, owing to their direct interface with the plant as a part of their core security roles and responsibilities, such as their routine patrols of plant facilities, security personnel can participate in the awareness and recognition FM and FM hazards. As long as it does not interfere with their primary responsibilities, Security Organisation, therefore, can support and enhance the FMMP with their observations and reporting of FM and FMM issues/challenges during their routine patrols of plant facilities and report any FMM observations and concerns.
Therefore, for Security Organisation need to know and protect integrity of FMM, for example protection of FMC barriers, during their routine and frequent security inspections.
Consequently, the plant owner/operating organisation provides the security personnel with
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targeted FM training to allow them to recognise, observe and report issues and challenges, particularly on:
— Overall housekeeping conditions;
— Physical FMM controls, such as physical barriers, devices, postings/signs;
— Potential FM, such as dirt or debris near sensitive areas and components.
5.6.2.13. External organisations
There are many various entities that are external to owner/operating organisation and have roles and responsibilities for establishment, coordination and implementation of plant’s/project’s FMM and FMMPs. These organisations include: technology and equipment vendors;
designers; manufacturers; regulatory bodies; and industry associations, such as WANO, INPO, EPRI; technology owner groups and nongovernmental agencies like IAEA, OECD/NEA.
In addition to their contributions to OPEX collection and dissemination, which were discussed in Section 5.5.10.5, they carry (or could be assigned to) other plant/project specific roles and responsibilities, some of which can be as follows:
— Vendors/Contractors/Suppliers: Each onsite or offsite entity involved in the activities in support of the owner/operating organisation, such as those design, manufacture, ship, construct, conduct refurbishment and maintenance activities, is to be aware, responsible and accountable of the potential consequences of its activity with respect to FMM, as well as the possible cross effects from other interfacing organisations. This can be accomplished by:
Agreeing and adhering to the FMM policy, requirements, expectations, controls and goals anchored and communicated by the owner/operating organisation, as well as activity planning, supervision and oversight by the work control organisation(s);
If superior to that of owner/operating organisation (based on their better understanding and experience of the activity), establishing and utilising own FMM programme policy, requirements, expectations, controls and goals after aligning, agreeing and confirming with the owner/operating organisation;
Continuously maintaining communication of changes and issues (both in policy and infield activities) by open and prompt exchange of information with the operating organisation and other interfacing organisations and by maintaining and providing records;
Contributing to owner/operating organisation continuous improvement of the FMMP based on own experience, information and knowledge of FMM elements and aspects;
Committing to exceptional FMM performance in all activities, overriding, if necessary, the demands of production or project schedules.
Contracts and applications for approved vendor status are some of the most effective instruments for articulating and agreeing upon the obligations of a plant operator, of a plant supplier and of their subcontractors. It is useful to include FMM requirements and expectations in each bidding, tendering and contract document with a vendor or supplier. In the own or common management system documents, each involved entity needs to describe the ways it contributes to FMC and FMM, towards the owner/operating organisation’s foreign material free operation and
no-adverse effect of foreign material, including how those are to be reviewed, agreed and accepted by own and the owner/operating organisation;
— Regulatory body: Regulatory body is involved with the FMMP with respect to establishing, and overseeing compliance with, the requirements that ensure the safety related SSCs are, and remain, capable of performing their intended safety functions. They are aware of the fact that when FM is not properly managed, FMI to safety related SSCs (or non-safety related SSCs supporting those) may negatively impact the safe operation by potentially degrading the safety margin. Thus, the rulemaking, oversight and verification of compliance by the regulatory body related to FMM is identified as a role of regulatory bodies. The responsibilities of a regulatory body in terms of FMM and FMMPs may include:
Establishing requirements and guidance that can be explicitly FMM specific, such as housekeeping, shipping, storage, cleanliness, or that are implicit or incorporated in other requirements, such as QA/QC requirements in construction, commissioning, operation, maintenance, equipment reliability;
Assuring that the owner/operating organisation establishes, maintains and follows adequate programmes, processes and procedures to ensure that the safety related SSCs and/or the SSCs supporting safety related SSCs are free of FM that could damage or adversely affect intended safety function or significantly degrade safety margins;
Observing that the owner/operating organisation has an anchored a safety culture that demonstrates awareness, responsibility and behaviour of no tolerance for events challenging nuclear safety, including FMI events, with potential safety consequences in mind;
Observing that the organisation has an effective condition recognition, identification, reporting and resolution processes that ensure anticipation, prevention, protection, detection and, if necessary, mitigation of FM that could damage, or adversely affect function, integrity and reliability of safety related SSCs, or SSCs supporting them;
Verifying the effectiveness of corrective action process in preventing recurrence of significant conditions adverse to quality that is caused by FMI;
— Industry associations: Aspects of FMM/FME17 have been a focus area of the industry associations and several organisations involved in the nuclear power industry, including IAEA, WANO, INPO, EPRI (see Section 1.1), FME Industry Working Group (FME IWG), among others. These organisations, associations and groups contribute to the improvement of FMM practices and FMMPs in NPPs in various manners, including the activities of:
Publishing skilful industry guideline documents to assist sites with FMMP development, implementation and improvement [911];
Distributing FMM related OPEX routinely, as well as promptly, to share learnings;
Organising/participating joint meetings, workshops of national, regional and international industry working groups, to establish consensus on assistance to the industry focusing on continuous improvement of FMM and FMMP by
17 Industry initiated standards, guidance and expectations refer to Foreign Material Exclusion (FME) Programme, which is similar to FMMP, mention herein.