ML20045G877
| ML20045G877 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/07/1993 |
| From: | DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20045G873 | List: |
| References | |
| NSD-704, NUDOCS 9307160097 | |
| Download: ML20045G877 (13) | |
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Attachmant 1-TECHNICAL PROCEDURE USE AND ADHERENCE NSD 704 -
1.0- Purpose 1.1 Provide management expectations for procedure use and adherence. (See Attachment 7.1) 1.2 Provide additional guidance on key management expectations for technical procedure use and
- ~. adherence for Duke Power Company's nuclear stations.
2.0 Scope 2.1 This directive is applicable to all Nuclear Generation Department (NGD) . employees and any other departments that interface with NGD to the extent where Nuclear Plant Safety or Reliability could be affected.
2.2 This directive provides general definitions and specifically defines the different levels of-procedure use and adherence. .
2.3 This directive does not apply to emergency or ==
abnormal procedures.
3.0 References 3.1 INPO Good Practice ' OA-106, " Technical Procedure Use and Adherence" 3.2 ANSI /ANS 3.2-1988 Section 5.2. 2, " Procedure Adherence" 3.3 NSD 703, " Administrative Instructions for Station -
Procedures" 4.0 Definitions Below is an alphabetical listing of terms and. definitions used in this procedure.
4.1 Adherence - Following intent and direction provided in the procedure.
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2 4.2 Conditional Step - A statement within a procedure .
I that allows a step to be skipped or performed out of sequence. Typically "If..., then",
When..., then" statements. Selected option needs to be completed as required. .
4.3 Deviation - A departure from a specified sequence or ,
requirements of given procedure steps.
4.4 Intent -
The overall objective or purpose of a procedure, procedure section, or procedure step.
4 , Levels of Use - A procedure classification that designates the minimum requirements for procedural use during the performance of an activity.
Procedural use levels are as follows: ,
4.5.1 Continuous Use - Procedure shall be ,
performed using step-by-step adherence unless flexibility is allowed by the procedure or this directive. A copy of the procedure shall be in the possession of the performer (s) at the job site. l 4.5.2 Reference Use - May be performed by referring l to the procedure periodically, ensuring that i procedure adherence and appropriate steps are I being performed. Reference Use procedures with.signoff steps will be signed off as frequently as practical. A copy of the ,_
procedure shall be at the job site.
4.5.3 Information Use - Provides general guidance '
for the performance of an activity that.is frequently performed and relatively' simple.
The procedure is not required to be at the job site.
4.5.4 Multiple Use - May incorporate more than one level of use, as described above. An example of this type of use would be " continuous use" for removal of equipment from service. Once the equipment is removed from service,
" reference use" may be used. Restoring the equipment may again require continuous use" of the procedure.
4.6 Not Applicable (MA) - The designation used if a procedure step or group of procedure steps are not appropriate for the task or activity being. performed.
4.7 Out-of-Sequence - Steps in a' procedure that do' not have to be performed in a particular order may be designated as out-of.-sequence.
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3' 4.8 Out of Service - A component or system that is isolated, deenergized, or incapable of performing its intended function.
4.9 Procedure - See Technical Procedure.
4.10 Procedure Change - A change made to a procedure to correct technical information or improve usability.
Appropriate approval authority is required.
4.11 Procedure Step /Section - A statement or group of statements within a procedure that describe the ~
action (s) necessary to complete an individual function constituting only a portion of the overall activity.
4.12 Supervisor - Personnel filling this position includes the following: -
4.12.1 Team supervisor / relief supervisor.
4.12.2 Responsible technical support / engineering >
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4.12.3 Technician temporarily working in a supervisory position.
4.12.4 For self-directed work teams, group management shall designate who performs the ,,
duties of this position.
4.13 Technical Procedure -
Those types of procedures described in NSD 703 (e.g., ops, IPs, MPs, etc.) The term " procedure" will be used in this context throughout this directive.
4.14 Use - The way a procedure is utilized to accomplish a task or activity.
I 5.0 Responsibilities 5.1 Station- Manager / Engineering . Manager -
Overall responsibility for the establishment, implementation, ,
and effectiveness of procedure use and adherence policies.
5.2 Group Superintendents, Section. Managers, and-General Supervisors -
Responsible for implementation and -j effectiveness of procedure use and adherence. .This includes:
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5.2.1 To ensure personnel are aware of management's expectations concerning procedure use and adherence.
5.2.2 To ensure personnel are properly trained and qualified to accomplish their assigned tasks.
5.2.3 To ensure personnel are meeting management's expectations regarding the use of procedures by monitoring procedural effectiveness.
5.2.4 To hold personnel accountable for proper procedure use and adherence by providing feedback on inappropriate actions at the time observed.
5.2.5 To encourage personnel to provide feedback regarding the adequacy of procedures used.
5.3 Supervisors - In addition to those responsibilities specified in step 5.2, supervisors are also responsible for:
5.3.1 Ensuring appropriate pre-job procedure reviews, periodic procedure briefings, and post-job review of results are conducted to ensure proper compliance and desired results are obtained.
NOTE: Procedures which are complex or ,,
infrequently used may require a more thorough discussion, illustrations, or examples with a crew prior to start of the activity.
5.3.2 Review and approval of all out-of-sequence steps and other deviations as described in this directive.
5.4 Procedure performers - Responsible for:
5.4.1 Following policies on procedure use and adherence during activities in which they are involved.
5.4.2 Verifying the procedure working copy is compared to the control copy before using and at least once every 14 days.
5.4.3 Knowing the procedure. requirements prior to starting the job. This may be accomplished by reviewing the procedure prior to use or by training on the current revision of the procedure.
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9 5.4,4 Understanding' anticipated response from procedure actions prior to. performing the action and the need to verify that a response
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has occurred. .
S.4.5 Initiating action to improve the quality of the procedure or to correct procedure problems found. .
S.4.6 Stopping work, returning the sys,em t to a safe condition if necessary, and notifying supervision in the event of the following: ;
A. The procedure imposes unsafe, unstable, or unreliable conditions on the plant, component, system, or structure.
B. JZ problems are noted while performing a procedure (e.g., equipment malfunction, procedure technical inadequacy, or anticipated results not obtained).
NOTFa. Procedure problems do not relieve the performer of the responsibility for maintaining safe plant operation, while conducting the activity.
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6.0 Procedure Note: Specific instructions may be included in the procedure in use that. allow flexibility or require additional restrictions.'
6.1 Procedures shall be adhered to during the. course of i activities. Performance of an activity from. memory, without referring to the procedure, does not relieve the performer from the responsibility of. conducting the activity in accordance with the latest revision '
of the procedure.
6.2 All procedures shall be' considered as " Continuous Use" procedures unless otherwise designated within l the procedure.
6.3 Continuous Use and Reference Use Procedures ' - A procedure designated as Continuous Use or Reference Use shall be utilized as described in steps 4.5.1 and 4.5 2.
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NOTE: When performed within a contaminated or other remote area, the performer shall have a copy of those applicable pages at the job site, or be in direct communication with someone who does.
In addition, the following guidance shall be used when performing a Continuous Use or Reference Use procedure:
6.3.1 NAing of Procedure Step (s)
A. Conditional procedure steps should be marked NA, when appropriate, by the-performer.
B. Conditional procedure steps in an unused procedure section do not have to.be marked NA if the reason for- being left ]
blank is evident. !
C. Nonconditional procedure steps may be marked "NA" if the performer has determined that the work scope is more limited than the procedure was written to accomplish or plant conditions are such that the step clearly does not apply.
These steps shall be reviewed by the performer and a knowledgeable supervisor _.
before the NA can occur. The performer 1 and supervisor shall perform the l following:
- 1. Initial NAed step. I
- 2. Ensure explanation clarifying the need for NAing the step is documented within the procedure or-work order.
- 3. To NA a consecutive group of steps, place an NA in the first step and last step along with the performer ~
and supervisor's initials and draw a vertical line through the remaining )
steps involved.
D. If a procedure is being performed 'on' a component that. is out of service, the performer ir not required to obtain the supervisor's review - and approval for a nonconditional NAed step or group of steps before proceeding. HOWEVET1, supervisor review and approval shall be obtained for each nonconditional NAed g-- y+ es a. v-
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7 step prior to returning the' component to service.
E. Supervisor arproval for nonconditional NAs may be given via telephone if the j supervisor clearly understands why the NA is necessary.
F. For nonconditional NAed steps, supervisor i determination should take into account l the necessity for a procedure change. 1 6.3.2 Out-of-Sequencing of Procedure Steps A. Procedure steps, identified by the :{
performer as needing to be performed out-l of-sequence, shall be reviewed by a j knowledgeable supervisor.
B. Steps needing to be performed out-of- -
sequence shall be reviewed and initialed by the performer making the determination
.and a knowledgeable supervisor prior to performing the out-of-sequence steps.
C. The supervisor shall ensure that a clarifying explanation of why the step {
was performed out-of-sequence is documented within the procedure or work order.
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D. For out-of-sequence steps, supervisor determination should take into account the necessity for a procedure change.
6.3.3 Deviating from Procedure Steps Due- to Changing Plant Conditions A. JZ changing plant conditions make it impossible to complete a procedure as written, supervisory evaluation and approval shall' be granted prior- to continuation.
B. Evaluations should include, but not be limited to, taking into account viable alternatives '(e.g.,- submitting a procedure ' change, job priorities, ' risks involved, etc.).
C. It deviation can ONLY be approved for instances in which the overall intent of s the procedure is not affected.
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D. The' reason for the deviation shall be documented in the procedure or work order and initialed by the performer and a knowledgeable supervisor.
6.4 Information Use Procedures - A procedure designated as Information Use shall be utilized as described in step 4.5.3. The procedure is not required to be at '
the job site if the procedure is frequently performed and relatively simple, such that the procedure requirements have been committed to memory.
6.5 Multiple Use Procedures - A procedure designated as Multiple Use shall be utilized as described in step 4.5.4. The level of procedure use shall be indicated within the procedure.
7.0 Attachments .
7.1 Management Expectations for Procedure Use and Adherence 7.2 Procedure Use and Adherence Matrix i l
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9 r Attachment 7.1 Management Expectations for Procedure Use and Adherence 3
Procedure Use If at any time during the performance of a procedure',
the anticipated results are not, or will not be obtained, the performer should immediately stop, and if necessary, return the system to a safe condition.
This condition should be immediately reported to supervision.
Continuous Use or Reference Use procedures shall be at the job site.
When a procedure is performed within a contaminated or other remote area, the performer shall have a copy of those applicable pages at the job site, or be in direct communication with someone who does.
Information Use procedures are not required to be at the job site IE the procedure is frequently performed and relatively simple, such that the procedure requirements have been committed to memory.
1 For Continuous Use procedures, each step shall be ;
read, understood, and performed as written, then signed off when completed, if signoff is required.
For Reference Use procedures, steps shall be read, understood and performed as written. Signoff steps will be signed off as frequently as practical.
l Transfer of signoffs or data from contaminated 1 procedures to a clean copy shall be step-by-step. l Photocopy, facsimile, electronic message recorder, or direct co' ~nication to another individual are !
acceptable lethods to accomplish this.
Any working copy shall be compared to the control copy before using and at least once every 14 days. ;
At least one person performing the task described. by !
the procedure shall be qualified to the procedure / task, or the task shull be directly supervised.
Direct supervision of a task includes, as a minimum, a pre-job briefing, a post-job. review of results, and any in-process observation of actions the supervisor deems necessary to ensure proper compliance and the desired results are obtained.
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10 Procedure Adherence Procedures shall only be used for the intent and purpose for which they were written.
For Continuous Use or Reference Use procedures, the procedure shall be performed as written, with deviations only permitted as described below.
If changing plant conditions make it impossible to complete a procedure as written, supervisory evaluation and approval shall be granted prior to continuation.
When the action / condition called for by a step is found to already exist, the step may be signed off as completed. Any unexpected actions or conditions shall be evaluated.
Conditional procedure steps or blocks of steps may be marked N/A by the performer, if the specified conditions do not apply.
Nonconditional. steps may be marked N/A if the performer has determined that.the work scope is more limited than the procedure was. written to accomplish or plant conditions are such that the step clearly does not apply. The steps'shall be reviewed and initialed by both the performer and a knowledgeable supervisor prior to going to the next step. For __
components which have been removed from service, the supervisor review and initial may be performed prior to returning the component to service. An explanation and justification for this action shall be documented within the procedure or work order.
Steps may be performed out of the listed sequence IE-the performer has reviewed'all intermediate steps and confirmed that this action will not adversely' impact the outcome of the procedure. The steps-shall be reviewed and initialed by both the performer and a knowledgeable supervisor prior to performing the steps out of sequence. An explanation and justification for this action shal'1 be documented within the procedure or work order.
Procedure changes to improve quality, or to' reduce or eliminate the need to apply the above deviation rules, shall be evaluated.
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ATTACllMENT 7.1 Management Expectations for Procedure Use and Adherence if at any time during the perfonnance of a procedure, the anticipated results are not, or will not be obtamed, the _Q C-perfonner should immediately stop, and if necessary, return the system to a safe condition. This condition should I be immediately reported to supervision..
Continuous Use or Reference Use
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procedures shall be at the job site.
When a procedure is performed within a contaminated or other remote area, the perfonner shall have a copy of those applicable pages at the job site, or be in direct communication with someone who does.
Infonnation Use procedures are not required to be at the job site .If the procedure is frequently perfonned and relatively simple, such that the procedure requirements have been committed to memory.
For Continuous Use procedures, each step shall be read, understood, and perfmmed as written, then signed off when completed, if signoff is required.
For Reference Use procedure, steps shall be read, understood and perfonned as written. Signoff steps will be signed off as frequently as practical, Transfer of signoffs or data from contaminated procedures to a clean copy shall be step-by-step. Photocopy, facsimile, electronic message recorder, or direct communication to another individual are acceptable methods to accomplish this.
Any working copy shall be compared to the control copy before using and at least once every 14 days.
At least one person perfonning the task described by the procedure shall be qualified to the procedure / task, or the task shall be directly supervised.
Direct supervision of a task includes, as a minimum, a pre-job briefm' g, a post-job revitw of results, and any in-process observation of actions the supervisor deems necessary to ensure proper compliance and the desired results are obtained.
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Proendure y i the intent and pmpose for which they were wntten.
Adh_ereae.e 1 ,
For Continuous Use or Reference h !
Use procedures, the procedure d shall be perfonned as written, j L' with deviations only pennitted as S y described below. hygggggggmj If changing plant conditions make it impossible to complete a procedure as written, supervisory evaluation and approval shall be granted prior to continuation.
When the action / condition called for by a step is found to already exist, the step may be signed off as completed. Any unexpected actions or conditions shall be evaluated.
Conditional procedure steps or blocks of steps may be marked N/A by the perfonner, if the specified conditions do not apply.
Non-conditiona' teps may be marked N/A if the perfonner has detennined that .he work scope is more limited than the procedure was --
written to accomplish or plant conditions are such that the step clearly does not apply. The steps shall be reviewed and initialed by both the perfonner and a knowledgeable supervisor prior to going to the next step.
For components which have been removed from service, the supervisor review and initial may be performed prior to returning the component to service. An explanation and justification for this action shall be documented within the prmedure or work order.
Steps may be perfonned out of the listed sequence .IF the performer has reviewed all intennediate steps and confinned that this action will not adversely impact the outcome of the procedure. The steps shall be i reviewed and initialed by both the performer and a knowledgeable I supeivisor prior to performing the steps out of sequence. An explanation and justification for this action shall be documented within the procedure or work order.
Procedure changes to improve quality, or to reduce or eliminate the need to apply the above deviation rules, shall be evaluated.
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11 Attachment 7.2 <
Proceduro Use and Adherence Matrix f USE/ ADHERENCE REQUIREMENTS CONTINUOUS REFERENCE INFORMATION i User Refoins Accountability X X X l
l Stop Work for Problems /Sofety X X X l l
Aware of Procedure Requirements Prior to Use X X X j Ensure AllSteps are Performed X X X Step By Step Adherence X X l Procedure at Job Sito X X l Signoff offer each Step If Signoff is Required X Signoff as often as Practicalif Signoffis Required X 1
Steps may be Performed from Memory X X Refer to Procedure Periodically During Use X j i
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