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Doc No.

:
Title:

PMP-2220-001-001
FOREIGN MATERIAL EXCLUSION (FME)

Alteration Cat.:
CDI/50.59:

Minor Revision
N/A

PORC Mtg. No.:


CARB Mtg. No.:
Admin Hold AR No.:
Superceding Proc(s):

N/A
N/A
N/A
N/A

Rev No.: 025

Temp Proc Exp Date: N/A


Temp Change Exp Date: N/A
Temp Proc/Change End: N/A
Effective Date:
7/29/2013 4:00:00 AM

Approvals
Name

Review/Approval Type/Capacity

Date

Wendzel, Regan
Hicks, Roger
Ball, Vince R
Wygant, Richard
Oneal, Gary
Main, Troy
Rumpf, David
Krycka, Joseph A
Thompson, Steven N
Valadez, Roberto

7 Approval Authority
3 Technical Review
1 Cross-Discipline Review
1 Cross-Discipline Review
1 Validation Review
1 Cross-Discipline Review
1 Cross-Discipline Review
1 Cross-Discipline Review
1 Cross-Discipline Review
1 Cross-Discipline Review

06/20/2013 07:16
06/14/2013 15:17
06/14/2013 08:23
06/10/2013 07:31
06/07/2013 07:29
06/04/2013 13:46
05/31/2013 09:28
05/30/2013 15:26
05/30/2013 06:57
05/30/2013 06:14

Signature Comments
Approved per Acting Plant Manager Toby Woods.
Approved as written.
None
Approved with comments addressed
Change to figure2 - ? Adding "system" to pressurizer. The pressurizer IS part of the Reactor
Coolant System. Its a component NOT a system by itself.

PMP-2220-001-001

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Foreign Material Exclusion (FME)


Information
G Peterson
Writer

SPG

Maintenance

Document Owner

Cognizant Organization

TABLE OF CONTENTS
1

PURPOSE AND SCOPE ............................................................................. 3

DEFINITIONS AND ABBREVIATIONS ........................................................ 4

DETAILS................................................................................................. 8
3.1

Site Ownership of the FME Program ..................................................... 8

3.2

FME Critical Behaviors ...................................................................... 8

3.3

Discussion and General Instructions ...................................................... 9

3.4

FME Boundaries and Barriers.............................................................17

3.5

Determination of Work Area...............................................................18

3.6

Creating FME Area Requirements and Use of Guidelines..........................19

3.7

Job Planning with FME Requirements or Guidelines................................21

3.8

Work Performance with FME Program.................................................21

3.9

Prohibited or Restricted Items and Activities ..........................................23

3.10 FME Inspections ..............................................................................24


3.11 Special Considerations Working Inside Containment................................27
3.12 Special Considerations Working around the Spent Fuel Pool (SFP) .............28
3.13 Reports on Unexpected Intrusion of Foreign Materials .............................28
3.14 Recovery from Unexpected Foreign Material Intrusion Event.....................29
3.15 Special Laydown/Staging Areas ...........................................................31
3.16 Personnel/Material Accountability, Control Points...................................31
3.17 Training Requirements ......................................................................39
3.18 Procedure Implementation Plan...........................................................39
4

FINAL CONDITIONS ...............................................................................40

REFERENCES.........................................................................................40

PMP-2220-001-001

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Foreign Material Exclusion (FME)


Information
G Peterson
Writer

SPG

Maintenance

Document Owner

Cognizant Organization

Attachment 1:

Work Practices .......................................................................44

Attachment 2:

Work Instructions ...................................................................61

Attachment 3:

Material Storage .....................................................................66

Data Sheet 1:

Standard Risk FME Area Requirements.......................................69

Data Sheet 2:

High Risk FME Area Requirements ............................................70

Data Sheet 3:

Request for Transfer or Storage of Foreign Material to SFP or


Transfer Canal .......................................................................71

Data Sheet 4:

Personnel Tool and Material Accountability Log (PMAL) ................72

Data Sheet 5:

FME Area Inspections ..............................................................73

Data Sheet 6:

FME Project Plan....................................................................74

Data Sheet 7:

Authorization for Waiver of Foreign Material Exclusion (FME)


Qualification...........................................................................79

Figure 1:

FME Risk Assessment Chart......................................................80

Figure 2:

List of Area Levels...................................................................81

Figure 3:

Duties and Responsibilities ........................................................84

Figure 4:

The FME Ready Worker...........................................................90

Information

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Foreign Material Exclusion (FME)

PURPOSE AND SCOPE

1.1

The purpose of this procedure is to establish guidance for:

1.2

Determining if assigned area of work is covered by the Foreign Material


Exclusion (FME) Program

Creating, Foreign Material Exclusion Area (FME Area) Requirements.

Planning jobs, making use of FME Requirements and Guidelines

Performing work in accordance with the FME Program

Special consideration while working inside of Containment

Reporting unexpected intrusions of foreign materials (FM)

Recovering from an unexpected foreign material intrusion event

Incorporating Lessons Learned into the FME Program from on-site and
off-site sources

This procedure applies to activities, performed by personnel that may introduce


foreign material into plant equipment causing degraded performance.
1.2.1

Contractor FME Program procedures, when approved by AEP, may be


used in lieu of this procedure.

1.2.2

This procedure does not apply to removing items, such as pipe caps, plugs
or blank flanges, when flushing, filling, draining, sampling, or venting
systems. (If system/component is breached with a foreign object this
procedure shall apply).

Information

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Foreign Material Exclusion (FME)


2

DEFINITIONS AND ABBREVIATIONS


Term

Meaning

Buffer Zone

An area established immediately adjacent to critical or sensitive foreign


material exclusion areas (i.e. Spent Fuel Pool area, Screenhouse east of
the traveling water screens) as appropriate or practical. This zone is
maintained free from material having a potential of being tracked, blown,
or falling into the FMEA. This area shall be monitored and controlled to
prevent foreign material including flying debris (overhead or near area)
and stationary items being tracked, or kicked from entering the FMEA.
Examples include: welding/grinding near barrier, dirt or other debris
carried into area by foot. Debris in the buffer zone is not a FME
violation but must be cleaned/removed immediately upon identification.

Fail Safe

A condition that ensures that items cannot do any of the following:


enter an open system, equipment, or component based on size or
configuration
be easily broken or come apart
sink in a body of water

Foreign Material
(FM)

Any material not part of a system or component per design. This


includes loose items that have the potential to enter into and cause
damage to open systems and components. Examples of foreign material
include dirt, debris, tools, rags, hardware, pens, eyeglasses, paint chips,
machine tailings, tape, grinding particles and so forth.
In addition, Foreign Material includes parts and wear particles from
designed components, which once displaced, may have detrimental
impact to the parent component or other components physically nearby or
downstream in the case of fluid/gas systems. Examples include circuit
breaker springs, valve internal parts, electronic cabinet door latches, and
so forth. This type of foreign material involved event is where plant
FME practices are not contributing to the introduction of foreign
material.

Foreign Material
Exclusion (FME)

Processes and practices designed to prevent the generation or entry of


foreign material. Foreign Material Exclusion also includes reporting of
inadvertent introduction of foreign material into a system or component
and the subsequent retrieval efforts, which returns the system or
component to its as-designed state.

Foreign Material
Exclusion Area
(FME Area)

A three-dimensional area adjacent to and including a system or


component where specific controls are implemented to prevent the
introduction of foreign material entering the system or component during
maintenance, modification, test or inspection activities. Barriers, signs,
markings or other means identify the extent of the FME Area.

Information

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Foreign Material Exclusion (FME)


Term

Meaning

Foreign Material
Exclusion (FME)
Barrier

A retrievable barrier, device, or external cover installed to prevent


foreign material entry. The barrier can range from rigid pipe caps,
inflatable pipe plugs, tarps, screens, and so forth.

Foreign Material
Exclusion (FME)
Boundary

A device to control access to a FME area. A physical boundary around a


work area with a barrier and signage consisting of rope, curtains, tents,
temporary walls, wire fencing, markers, or other similar materials. This
boundary identifies the area as a FME zone.

FME Device

A temporary device such as a cap, plug, or dam used to prevent the


intrusion of foreign material into a system or component.

Foreign Material
Exclusion (FME)
Guideline

A document which describes discretionary good practices for preventing


the introduction of foreign material into a system or component.

Foreign Material
Exclusion Monitor
(FMEM)

A trained individual responsible for controlling the ingress and egress of


personnel, tools and materials in a FME Area. The monitor could be an
Independent Monitor or Self Monitor. Independent Monitors will have
no other responsibilities and are typically used on larger or complex
activities. Self Monitor will monitor their own or a small work groups
tools and material while also working on the task and are typically used
for jobs with limited scope that are not complex. (e.g.: working on a
single valve/component, tours/inspections or small in scope work
activities inside high-risk area around the spent fuel pool).

Foreign Material
Exclusion (FME)
Project Plan

A plan detailing specific FME controls for a major or complex activity. A


FME Project Plan typically contains both engineered and passive FME
controls. The FME Project Plan should be developed as early as possible
to allow for potential changes to the design and planning for the work
activity. The FME Project Plan is not used as a means of deviating from
procedural requirements. The format for developing the FME Project Plan
is contained on Data Sheet 6, FME Project Plan.

Foreign Material
Exclusion (FME)
Requirements

A document which describes the required precautions and expected


behaviors which are designed to prevent the introduction of foreign
material into a system or component. FME Requirements will be either
related to a Physical Area or a Particular Task.

Foreign Material
Intrusion

Foreign material that enters a plant system, equipment, or component.

Information

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Foreign Material Exclusion (FME)


Term

Meaning

High Risk FME


Area

The highest rating for an FME Area. The highest level of foreign
material awareness and control is desired, or a final inspection for FM is
not possible, or removal of foreign material may not be possible or
difficult. This includes the spent fuel pool and immediate adjacent areas,
and the area immediately adjacent to the containment recirculation sump.
FME Area Requirements are classified as high risk. Additionally, highrisk FME controls should be applied based on risk to systems and
components for which the introduction of FM could be irreversible.

Immediately
Retrievable

Foreign Material that can be removed without the need for additional
resources, further equipment disassembly and or use of removal
equipment.

Job Supervisor

Person designated by title (or designee) to assist with FME activities as


described in this document.

Lanyard

A device used to hold or fasten a tool, material, or other item to a person


or a secure attachment point thus preventing its loss. Lanyards are
generally made from rope, cord, or some other suitable restraint and can
be used to attach an item to a secure attachment point.

Legacy FME Issue

Foreign material that was introduced before implementation of FME


standards, during construction, or in historical outages.

Loss of FME
integrity

A condition deemed to exist when material enters an open system or


FMEA and is not controlled.

Non-Fail Safe

Any item that does not meet the Fail Safe definition.

Personnel
Tool/Material
Accountability Log
(PMAL)

A log sheet used to track entry and exit of personnel tools and materials
in an FME Area for accountability purposes.

PMAL Review

Consists of verifications that entries on each form are complete and


legible, and items identified on the PMAL are accurately described.

Reconcile PMAL

Verify items in FME area not failsafe are listed on the PMAL. All items
logged on PMAL are actually in the FME Area at completion of job or
as required by Data Sheet 1, Standard Risk FME Area Requirements,
Data Sheet 2, High Risk FME Area Requirements, and Data Sheet 5,
FME Area Inspections.

Information

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Foreign Material Exclusion (FME)


Term

Meaning

Roving Monitor

A monitor that is qualified to GP-L-FMEM and is designated for large


projects to maintain barriers, clean area, observe FME
behaviors/practices, and perform walk downs & sign off on Data Sheet 5
or other duties as necessary related to FME.

Selected Plant
Systems and/or
Components

The equipment which benefits from the protection resulting from this and
sub-tier procedures. In general, this includes all equipment covered by
licensing documents and the equipment important to the operation of the
power plants.

Site FME
Coordinator

An individual designated by the Program Owner to coordinate FME


Program Activities at D. C. Cook.

Standard Risk FME


Area

The minimum rating for an FME Area. A high level of foreign material
awareness and control is desired and an inspection to verify cleanliness
of the protected system or equipment is possible. FME Area
Requirements are classified as standard risk.

System Boundary
Breach

A breach is the opening of and/or the introduction of a foreign material


to a system, equipment, or component.

Un-recovered
Foreign Material
(FM)

Any FM not recovered (removed) from system or component.

Work Order Task/


WO Task/WOT

Indus terminology, replaces legacy terminology Job Order Activity/JOA.

Information

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Foreign Material Exclusion (FME)


3

DETAILS

3.1

Site Ownership of the FME Program


3.1.1

3.2

Station and supplemental personnel involved with the foreign material


exclusion (FME) program must exhibit the highest level of ownership for
their work activities, to enhance the stations equipment reliability and
system integrity. To this end a high degree of awareness to prevent foreign
material intrusion is necessary throughout the station. Strong ownership of
the FME program is exhibited by workers, monitors, supervisors and
managers, who have internalized, advocate and demonstrate job-site
behaviors that promote excellence in FME. The workers, supervisors and
managers seek to identify and correct program deficiencies, facilitate
continuous FME improvement, and hold each other accountable for the
rigorous implementation of FME practices.

FME Critical Behaviors


3.2.1

Proper Foreign Material Exclusion (FME) adherence is demonstrated by the


following critical behaviors:
a.

Establish FME Area by posting signs, installing barriers and


controlling access to rooms or work areas.

b. Inspect:

NOTE:

Tools and equipment to be used in the FME Area for loose,


missing or damaged parts

Parts to ensure shipping plug and packing material have been


removed

Tape is not a means of FME protection, however tape can be used to secure
personal items or FME covers if necessary.

c.

All non fail-safe items to ensure that they are secure prior to
entering an FME Area (i.e. tools tethered, remove jewelry or
secured with tape (if allowed), or empty pockets, etc.)

Implement Personnel Tool/Material Accountability Logs (PMALs) as


appropriate for Standard Risk or High Risk FME Area.

d. Install temporary pipe dams to minimize introduction of Foreign


Material into a system(s) and/or component(s).

Information

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Foreign Material Exclusion (FME)


e.

Install temporary covers on open system when work is not actively in


progress.

f.

Implement Foreign Material controls for work being performed that


may introduce FM (i.e., grinding, welding, etc.).

g. Reconcile and document Log Sheets used as required by Data


Sheet 1, Standard Risk FME Area Requirements; Data Sheet 2, High
Risk FME Area Requirements; and Data Sheet 5, FME Area
Inspections; as required.
3.2.2

The practices and guidelines contained in Attachments 1, 2 and 3 have been


extracted from INPO 07-008, Guidelines for Achieving Excellence in
Foreign Material Exclusion.
a.

Refer to Attachment 1, Work Practices, for ways that the individual


worker can prevent introducing foreign material into components and
systems.

b. Refer to Attachment 2, Work Instructions, for information to assist


Planners, Supervisors and craft in establishing proper controls to
prevent foreign materials from entering plant systems or components.
c.

3.3

Refer to Attachment 3, Material Storage, for information on how to


prevent introducing foreign material into items that are in storage or are
being transported to the work area.

Discussion and General Instructions


3.3.1

Discussion
a.

The FME program minimizes the potential for inadvertent introduction


of foreign material into plant systems or components. An FME
program goal is to provide a FOCUS ON PREVENTION attitude
among workers. This means workers should think through the
activities they will perform in an FME area and take precautions to
prevent the introduction of foreign materials into plant equipment.

b. The level of control necessary to protect an open system or component


should be consistent with the circumstances of the activities being
performed, the system or component involved, and the size and
orientation of the opening. Maintaining radiation exposures, ALARA,
and the impact of adjacent work should also be considered. The intent
of this procedure is to provide the flexibility necessary to implement the
appropriate controls for the job. [NRC Commitment 6661]

Information

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Foreign Material Exclusion (FME)


c.

The scope of the FME program has been expanded to include


additional areas identified in INPO SOER 95-1 and the INPO good
practice on Foreign Material Exclusion, MA-320. Additionally, a Root
Cause Evaluation was conducted for CR 98-7571 and 04298002, which
identifies numerous deficiencies in the program.

d. This procedure uses a RISK BASED approach to FME.

3.3.2

FME Area-1 becomes High Risk

FME Area-2 becomes Standard Risk [NRC Commitment 6964]

Identify the Job Supervisor on Data Sheet 1, Standard Risk FME Area
Requirements; or Data Sheet 2, High Risk FME Area Requirements and
ensure that the Supervisor identification is posted at the job site. [Ref 5.2.1hh]
a.

For a small job, an Job Supervisor is identified during pre-job brief.

b. For a large job, in addition to 3.3.2a, a Job Supervisor's identification


shall be posted at the FME barrier.
3.3.3

Implementation
a.

NOTE:

Determination / Planning of FME Area risk levels:

Technical Requirements Manual 8.5.1, TRS 8.5.1.1 & 8.5.1.2 requires a


visual inspection of the affected areas of the containment to verify that no
loose debris is present that could be transported to the containment sump and
cause restriction of the pump suctions during LOCA conditions this
requirement shall be satisfied.
1. Activities other than normal operation (vent, drain, etc) involving
the breach of a system, component or any activity which may
introduce foreign material into a system or component shall be
evaluated using the guidance of Figure 1, FME Risk Assessment
Chart, to identify the appropriate FME Area and work controls.
The intent of this review is to identify when special controls are
required, such as for Standard Risk or High Risk FME Area
Requirements.
2. The Job Supervisor should make a preliminary FME Area
determination of this evaluation for maintenance and other
activities. Work Planning may develop FME Area criteria
specifically for a standardized FME Area.

Information

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Foreign Material Exclusion (FME)


3. IF the evaluation results in an FME Area designation of Standard
Risk or High Risk, THEN complete, Data Sheet 1, Standard
Risk FME Area Requirements or Data Sheet 2, High Risk FME
Area Requirements.

IF a Standard Risk FME control level, THEN a Job


Supervisor or Site FME Coordinator review and approval
signature is required on Data Sheet 1, Standard Risk FME
Area Requirements. [CR 04218086]

IF a High Risk FME control level, THEN an AEP Manager


review and approval signature is required on Data Sheet 2,
High Risk FME Area Requirements. [CR 04218086]

4. The Data Sheet 1, Standard Risk FME Area Requirements or Data


Sheet 2, High Risk FME Area Requirements, shall be included in
the work package and shall be used during the pre-job briefings.
b. Field Work
1. The level of control necessary to protect an open system or
component should be consistent with the circumstances of the
activities being performed, the system or component involved, and
the size and orientation of the opening. Maintaining radiation
exposures, ALARA and the impact of adjacent work should also be
considered. The intent of this procedure is to provide the
flexibility necessary to implement the appropriate controls for the
job.
2. IF working in or near an FME risk zone, system, or component,
THEN evaluate potential for work to impact the FME risk zone,
system, or component and determine the controls necessary to
prevent problems when FME system is opened or conditions
change.
3. IF making a lift in or over a FME Area, THEN contact the FME
Area owner for authorization of this work in the FME Area. IF
stationed, THEN brief the FME Monitor.

Information

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Foreign Material Exclusion (FME)


4. When FME controls are required the following general process is
utilized:
a)

Review Figure 1, FME Risk Assessment Chart, to determine


the FME risk level.

b) IF the evaluation results in a determination of Standard Risk or


High Risk THEN complete Data Sheet 1, Standard Risk FME
Area Requirements or Data Sheet 2, High Risk FME Area
Requirements, to identify the necessary controls for the job.
1) Incorporate the FME requirements of Data Sheet 1,
Standard Risk FME Area Requirements or Data Sheet 2,
High Risk FME Area Requirements, into the job as work
is being performed in the field.
2) The Job Supervisor is to perform a High Risk FME brief
at the work location (to verify understanding and ensure
that FME practices will be implemented as intended by the
Area Requirement). IF work site prohibits conducting
brief on location (e.g. high noise, contaminated area, high
radiation etc.), THEN perform brief in an alternate
location. [CR 04218086]
3) WHEN the work is finished and the FME inspections are
completed, THEN the Job Supervisor shall complete the
Data Sheet 1, Standard Risk FME Area Requirements or
Data Sheet 2, High Risk FME Area Requirements, as
applicable.
3.3.4

Responsibility
a.

Departments and Work Groups are responsible to develop requirements


for the Data Sheet 1, Standard Risk FME Area Requirements or Data
Sheet 2, High Risk FME Area Requirements, as appropriate to support
their work. This responsibility shall include the adjustments to Data
Sheet 1, Standard Risk FME Area Requirements or Data Sheet 2, High
Risk FME Area Requirements, to meet the special requirements of each
job and to incorporate Lessons Learned, which are deemed appropriate.

b. All personnel are responsible for compliance with FME Area


Requirements for their particular job.

Information

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Foreign Material Exclusion (FME)


c.

Site FME Program Owner

Maintains ownership of the FME program

Provides oversight, sets expectations, and reinforces accountability


for the FME Coordinator and station personnel

Reviews and approves FME Plans as designated

Authorize changes to Figure 2, List of Area Levels

d. The Site FME Coordinator is responsible to:

Serve as the site FME subject-matter expert, site advocate for


improvement, and providing a single point of contact for the FME
program

Keep the program owner informed of FME program status and


initiatives

Coordinate with all organizations to ensure that work practices and


FME controls incorporate the strong use of FME fundamentals and
FME error reduction techniques

Perform frequent field inspections and observations (including


training and in the warehouse) of jobs that involve FME controls.
This includes providing coaching for ongoing plant activities to
identify and resolve FME issues, to improve personnel and plant
performance

Review and approve Data Sheet 6, FME Project Plan

Approve Data Sheet 1, Standard Risk FME Area Requirements or


changes to Data Sheet 1 (or Job Supervisor)

Periodically evaluate FME program effectiveness. This includes


the following:

Analyzing work observation data from condition reports and


observations

Performing programmatic assessments against industry


documents to ensure that identified gaps are correct

Information

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Foreign Material Exclusion (FME)

e.

Perform benchmarking to identify good practices for site


implementation. Participate in FME industry working groups, and
communicate with industry peers

Coordinate with the site Training Department to ensure that


training encompasses strong FME performance

Participate in training, pre-job and post-job briefings, event review


teams and outage challenge meetings to reinforce FME program
expectations

Assist organizations with implementing the FME program

Order FME devices and supplies

Oversee the FME Cabinets are adequately stocked

Oversee FME cover laundry

Authorize changes to Figure 2, List of Area Levels

Periodically review Data Sheet 4, Personnel Tool and Material


Accountability Log (PMAL), or facsimiles

May approve transit through an FME Area

Approve deviation from training requirements

Managers are responsible for monitoring work and ensuring FME


controls are adequate and being implemented.

Approve Data Sheet 2, High Risk FME Area Requirements, and


changes

Approve Data Sheet 1, Standard Risk FME Area Requirements or


changes to Data Sheet 1 (or Job Supervisor)

Can authorize changes to Figure 2, List of Area Levels

Periodically review Data Sheet 4, Personnel Tool and Material


Accountability Log (PMAL), or facsimiles

Approve transit through an FME Area

Approve deviation from training requirements

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Foreign Material Exclusion (FME)

f.

Coordinate/Assist in loss of FME integrity actions for FME Area


that have lost integrity, with the Responsible Supervisors.
(Including: Refuel/Reactor Cavity, Spent Fuel Pool, etc.)

Evaluate FME program effectiveness

Oversee the activities of the Job Supervisors throughout the plant

Periodically assess the FME program and routinely report the


assessment results to the Maintenance Director

The Job Supervisor or designee

Performs FME brief.

Reports on unexpected intrusion of foreign material, including


initiation of AR as required.

Approves transit through an FME Area.

Establish, maintain and closeout FME Area [NRC Commitment 1222]

Approve Data Sheet 1, Standard Risk FME Area Requirements or


changes to Data Sheet 1 (or Site FME Coordinator)

Approve Data Sheet 4, Personnel Tool and Material Accountability


Log (PMAL)

g. The FME Monitor:

Ensure Data Sheet 4, Personnel Tool and Material Accountability


Log (PMAL), or electronic equivalent are completed

Ensure lanyards, taping, and so forth used to secure items is


adequate to prevent loss in the FME Area

Ensures Data Sheet 4, Personnel Tool and Material


Accountability Log (PMAL),is accurate, legible, detailed and
correct

When possible, equipment should be secured with solid


lanyards to fixed anchor points instead of detachable lanyards
hooked to personnel.

Ensure personnel items and/or materials are acceptable for entry


into the FME Area. See Figure 4, The FME Ready Worker

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Foreign Material Exclusion (FME)

Prohibit worker entry, if the worker(s), tool(s), equipment, and/or


work items are not ready for entry

Stop activities in or around the FME Area that may introduce FM


into the equipment breach

h. Workers in an FME Area or performing FME Area tasks shall be able


to explain the FME Area requirements for their work.

WHEN maintaining an FME Area, THEN the workers shall


minimize the amount of foreign material inside the area. This
includes tools, equipment, consumables and trash. [ Ref 5.2.1hh]

WHEN a Data Sheet 4, Personnel Tool and Material


Accountability Log (PMAL), is used, THEN ensure the Data
Sheet 4, Personnel Tool and Material Accountability Log
(PMAL), accurately indicates their Owner Controlled Area (OCA)
Badge Number, Name, Material Name and Quantity for their entry
into and exit from the FME Area. Peer check the FME Monitor

Ensure you are an FME Ready Worker (See Figure 4, The FME
Ready Worker) prior to entering and FME Area.

Whenever possible, component assembly and disassembly should


be performed outside the FME Area.

i.

IF component assembly and disassembly takes place inside


the FME Area, THEN additional controls such as barriers or
containment catches shall be used. [ Ref 5.2.1hh]

Report dropped, lost or unaccounted for foreign material to the Job


Supervisor.

Training Department

Design, develop, and deliver initial and continuing FME training

Ensure correct FME behaviors are being performed in all aspects


of training

Review and update training based on feedback, internal/external


operating experience, and gaps identified, to improve performance

Information

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Foreign Material Exclusion (FME)


3.4

FME Boundaries and Barriers


3.4.1

Boundaries
a.

The FME Area boundary and the equipment breach may be the same.

b. IF the FME Area boundary and equipment breach are not the same,
THEN the FME Area boundary shall be established and posted.
c.

3.4.2

IF boundaries are required in the Screen House THEN barrier tape is


NOT allowed. Temporary stanchions (e.g., Tesabarriers) are used in
the Screen House.

Barriers
a.

An FME barrier shall be installed over the equipment breach whenever


the breach is unattended or is not required to be open.

b. FME barriers placed over equipment breaches shall be appropriately


marked or posted.
c.

External barriers that can not physically enter a High Risk FME Area
opening do not have to be listed on Data Sheet 4, Personnel Tool and
Material Accountability Log (PMAL) (Example: cover over screen
house grating).

d. To prevent introducing foreign material into equipment, use internal


FME barriers as required to isolate equipment internal openings.
[Ref 5.2.1hh]

NOTE:

The use of tape shall not be used as an internal FME barrier.


e.

WHEN using an internal FME barrier, THEN a restraining device


shall be used such as a lanyard or similar attachment to minimize the
possible impact and consequences of retrieving a lost barrier from a
system. [CR 99-03629]
1. Internal FME barriers used in a High Risk FME Area shall be
listed on the Data Sheet 4, Personnel Tool and Material
Accountability Log (PMAL).

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f.

NOTE:

Prior to removing any FME barrier:

Obtain approval from the Job Supervisor

Inspect the area around the barrier

Isolation valve leakage may cause pressure build-up behind the FME barriers.

IF necessary, THEN check system pressure behind the barrier

g. FME barriers shall:

3.5

Not introduce non-retrievable FM into plant equipment during


installation or removal

Prevent dropped material from entering plant equipment

Allow inspection of the barrier for trapped debris prior to removal

Either allow removal of trapped debris from the barrier or allow


removal of the barrier without loss of any trapped debris

Resist tearing and splitting

Meet fire retardant requirements of PMP-2270-CCM-001, Control


of Combustible Materials.

Be chemically and physically compatible with the equipment per


PMP-2160-CHM-001, Control of Chemical Materials

IF required, THEN allow airflow to provide confined space


ventilation or provide a system vent path.

Determination of Work Area


3.5.1

All work shall be evaluated for applicability of the FME Program. The
following statements shall be used in this determination:
a.

Breaching or opening systems or components should be considered


within the scope of this program.

b. Access to the identified work areas listed on Figure 2, List of Area


Levels, has defined FME Area requirements and should be considered
within the scope of the FME program.

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c.

3.5.2

For task specific job activities under a large FME Area project (i.e.
Turbine, Main Condenser, Ice Condenser, etc.) the Project Manager and/or
Site FME Coordinator will ensure development of FME Area Risk Level to
capture all FME requirements for that project. [CR 04298002]
a.

3.5.3

If the project FME Area requirements do not capture the job specific
activities, create a Data Sheet 1, Standard Risk FME Area
Requirements or Data Sheet 2, High Risk FME Area Requirements, for
the specific job/task activities. [CR 04298002]

EDG fuel injection pump, pump supply manifold and duplex filter work
require cleanliness practices approaching clean room techniques in order
to be successful. To prevent particle-initiated fuel pump seizures, EDG fuel
injector pump work requires awareness, special skills and methods above
and beyond the control measures of the basic plant-wide FME Program.
These control measures are best established, enforced and adjusted
appropriately as the work progresses, by the experienced responsible EDG
Maintenance Supervisor and their crew. Based on the scope of the work,
the Job Supervisor may develop a detailed FME Task Plan identifying the
specific FME controls required.
a.

3.6

IF a system interfaces or has the potential to interface with a FME


High Risk System, THEN treat the system as High Risk FME (for
example, Reactor Coolant System and Reactor Coolant Pump
Sealwater).

IF developing a FME Task Plan, THEN use the provided Task Plan
Template of Data Sheet 6, FME Project Plan, or an equivalent
(i.e., covers the same attributes).

Creating FME Area Requirements and Use of Guidelines [NRC Commitment 7164]

NOTE:

3.6.1

Requirements for posting include posting the level of control for the area.
Location of postings include: Listing from Figure 2, List of Area Levels, at
job site and or as directed by the Job Supervisor.
FME Area Requirements
a.

FME Area Requirements shall be prepared by evaluating the work to


be done to establish the FME requirements for the subject system
and/or component.
Once completed, the document shall be:

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Used as part of pre-job briefings

Implemented in the field

Retained as a part of the WOT when completed

b. Data Sheet 1, Standard Risk FME Area Requirements and Data


Sheet 2, High Risk FME Area Requirements, shall be prepared for
physical plant areas where workers who enter shall comply with the
FME precautions. Figure 2, List of Area Levels, is a pre-established
listing of plant areas that have specified FME Area requirements. The
pre-established list in Figure 2, List of Area Levels may be used so
long as it covers applicable work being performed.
c.

Where possible/practical, FME requirements should be structured and


indexed to allow for repetitive use and to incorporate Lessons Learned,
both from on site as well as Industry sources. In some cases, one time
FME Area requirements may be appropriate. [Ref 5.2.1hh]

d. IF an issue arises in an FME Area and the Job Supervisor is not


available, THEN contact the Site FME Coordinator. [Ref 5.2.1hh]
3.6.2

FME Guidelines (See Desk Top Guide High Risk FME guide)
a.

FME Guidelines are intended to be repositories for the details of


techniques that have been found to make the FME Program more
effective and efficient. These Guidelines are intended to be utilized in
the decision process for identifying the requirements of an area. They
may also be structured with any format, indexing, and content,
however, consideration should be given to sharing this information with
others working in the FME Program.

b. Where possible/practical, FME Guidelines should be structured and


indexed to allow for repetitive use and to incorporate Lessons Learned,
both from on site as well as Industry sources.
c.
3.6.3

View the D. C. Cook High Risk FME Guidelines by accessing them


through the FME intranet site on the Maintenance Web Page.

Modifying FME Area Requirements


a.

FME Area requirements may be changed provided the Job Supervisor


annotates such changes on Data Sheet 1, Standard Risk FME Area
Requirements, and/or Data Sheet 2, High Risk FME Area
Requirements, notifies workers and obtains the appropriate approvals.
[Ref 5.2.1hh]

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b. The Job Supervisor or Site FME Coordinator may modify a Standard
Risk FME control level, an AEP Manager review and approval
signature is required to modify a High Risk FME control level.
1. For example, following implementation of FME controls, a High
Risk FME Area may be approved to be downgraded to a Standard
Risk FME Area. [Ref 5.2.1hh]
c.

3.7

3.8

IF a High Risk FME Area has been approved to be downgraded to a


Standard Risk FME Area, THEN post Data Sheet 2, High Risk FME
Area Requirements showing downgrade approval and Data Sheet 1,
Standard Risk FME Area Requirements showing current FME
requirements at the job site. The High Risk FME Area requirements
must be reestablished prior to removing the FME controls. [Ref 5.2.1hh]

Job Planning with FME Requirements or Guidelines


3.7.1

Jobs shall be reviewed to determine if the task is part of the FME Program,
Refer to Figure 1, FME Risk Assessment Chart. For jobs covered by FME
Program, it should be determined if the job will be conducted in an area
covered by the pre-established FME Area Standard (Refer to Figure 2, List
of Area Levels). IF the Figure 2, List of Area Levels, provides the needed
level of control, THEN establish FME Area Requirement using pre-existing
level. [Ref 5.2.1hh]

3.7.2

FME Controls should be identified in the procedure or the Work Order


Task / WO Task /WOT

3.7.3

The completed Data Sheet 1, Standard Risk FME Area Requirements or


Data Sheet 2, High Risk FME Area Requirements, shall be included in the
work package and shall be used during the pre-job briefings.

Work Performance with FME Program


3.8.1

Jobs shall utilize pre-job briefings and include a discussion of applicable


Data Sheet 1, Standard Risk FME Area Requirements or Data Sheet 2,
High Risk FME Area Requirements and review Figure 3, Duties and
Responsibilities.

3.8.2

Workers in an FME Area or performing FME tasks shall be able to explain


the FME requirements for their work. [Ref 5.2.1hh]

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3.8.3

Special considerations are required when removing components and/or


assemblies that are normally part of the closure boundary for a given
system or component. Examples include valve bonnets, circuit breakers,
and electronic drawers.
a.

Appropriate FME measures shall be taken to protect both the removed


component/assembly and the system/component that was breached.

b. Continuing FME controls shall be applied for removed items that are
transported to shops or otherwise removed from normal areas.
c.

Descriptions of precautions and/or behaviors for these removed items


can be accomplished as part of Data Sheet 1, Standard Risk FME Area
Requirements, or Data Sheet 2, High Risk FME Area Requirements
that breached the system/component, (details should be added to the
applicable data sheet in the Additional Requirements/Remarks section.)

3.8.4

Figure 2, List of Area Levels and Data Sheet 1, Standard Risk FME Area
Requirements, or Data Sheet 2, High Risk FME Area Requirements should
be discussed as part of post-job critiques, when applicable. Adjustments to
the Figure 2, List of Area Levels, can be considered for future work.

3.8.5

Only Site FME Coordinator or the FME Program Owner can make changes
to a pre-established listing of Figure 2, List of Area Levels.
[Ref 5.2.1hh]

NOTE:

3.8.6

Only items that are designed for the environment and controlled by an
approved procedure may be stored in the Spent Fuel Pool or Transfer Canal.
Examples of this equipment include Fuel, Fuel Handling Tools, Ultrasonic
Test Equipment, RCA Test Fixtures, tools used for removal of debris and so
forth. Items that degrade or decompose are prohibited from storage in the
Spent Fuel Pool, or Transfer Canal.
Material storage in spent fuel pool or transfer canal is performed as
follows:
a.

Filters and other similar items SHALL not be stored in the Spent Fuel
Pool or Transfer Canal.

b. Objects to be permanently or temporarily stored in the Spent Fuel Pool


or transfer canal shall be approved for storage and evaluated for
chemical and radiological impacts using Data Sheet 3, Request for
Transfer or Storage of Foreign Material to SFP or Transfer Canal.

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c.

Objects that inadvertently fall into the Spent Fuel Pool, transfer canal
or reactor cavity shall be documented in accordance with PMI-7030,
Corrective Action Program.

IF the object can not be retrieved, THEN initiate an Action and


Data Sheet 3, Request for Transfer or Storage of Foreign Material
to SFP or Transfer Canal.

d. Material stored in the Spent Fuel pool SHALL be stored away from the
suction and discharge line openings for Spent Fuel Pool Cooling. The
method of attachment SHALL be annotated on Data Sheet 3, Request
for Transfer or Storage of Foreign Material to SFP or Transfer Canal,
for review and approval.
3.9

Prohibited or Restricted Items and Activities


3.9.1

Items PROHIBITED from entering any High Risk FME Area including the
Reactor Cavity, Containment and the Spent Fuel Pool FME Areas.

Tie-wraps with metal clips

Clear plastic sheeting, sleeving, or bags unless adequately marked for


visibility purposes. Safety PPE is exempt.

Items with visible foreign material

Items with loose parts or fasteners

Easily breakable items. Glass light bulbs are exempt

Paper clips

Fabric with cut edges that may be susceptible to unraveling [Ref. 5.2.1nn]

All personal items, (i.e. jewelry, change, wallets, etc.) must be


REMOVED (or restrained/controlled as noted below) from person and
pockets.

IF item cannot be removed, THEN the item must be contained


(worn under a glove, taped, etc.) and logged into the area.

Any required medications must be contained, secured to the person


(per Job Supervisor and in a manner that does not restrict use) and
logged into the area.

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All tool cards (i.e., Human performance , Safety, etc.) must be


REMOVED (or restrained/controlled as noted below) from person.

IF the tool card(s) cannot be removed, THEN the tool card shall
be attached to a lanyard and clipped or taped to the workers outer
garments and each card logged on the PMAL.

3.9.2

The use of wire or steel brush devices for work in High Risk FME Areas
requires the approval of the AEP Mechanical Maintenance Manager.
Barriers SHALL be used to contain or prevent bristles from entering uninspectable areas of a component or system.

3.9.3

Work activities that generate loose debris such as wire brushing, grinding,
cutting, etc., are restricted near High Risk FME Areas. Establish a buffer
zone between the debris generating activity and the High Risk FME Area or
erect a barrier or tent to capture the material.

3.9.4

Exceptions are allowed for items or activities that do not pose a threat to the
breached system.
a.

The exception shall be evaluated and approved on a case-by-case basis


by the Job Supervisor or Site FME Coordinator.

b. The exception shall be evaluated and approval is documented on an


Action Evaluation of FME integrity actions.
3.10

FME Inspections

NOTE:

3.10.1

The following guidance is for FME inspections as noted on Data Sheet 1,


Standard Risk FME Area Requirements, or Data Sheet 2, High Risk FME
Area Requirements.
Inspection Performance
a.

Inspections may be performed using an inspection mirror, fiberscope,


camera or other visual aid if needed.

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b. Unless otherwise specified, inspection results shall be documented via
the Data Sheet 1, Standard Risk FME Area Requirements, or Data
Sheet 2, High Risk FME Area Requirements, WOT or Procedure.
1. Inspection results are documented in the procedure (if used) or
WOT (if used) as either:

A note in comments.

A recorded step.

2. Unacceptable results shall be resolved by either:

3.10.2

Correcting the problem, re-inspecting and/or accepting the


item. Generate an Action to identify problem and actions
taken.

Documenting and resolving the problem by implementing loss


of FME integrity actions and initiating an Action. Refer to
step 3.13.

AS Found Breach and Final Closeout


a.

Immediately following initial equipment breach, accessible internal


portions of the equipment shall be inspected for foreign material.
1. The equipment shall be free of foreign material.

NOTE:

Tightly adhering corrosion film is not foreign material.


2. IF foreign material is found, THEN implement loss of FME
integrity actions. Refer to step 3.13.

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b. Prior to installing components that may prevent final closeout
inspection, inspect affected areas for foreign material and record in the
Data Sheet 1, Standard Risk FME Area Requirements, or Data Sheet 2,
High Risk FME Area Requirements.
1. The equipment internals AND the components being installed shall
be free of foreign material. For example:

A pump rotating element.

A check valve disc.

2. The Job Supervisor may waive this Internal Parts Inspection (step
3.10.2b) IF no components have been introduced. Document on
Data Sheet 1, Standard Risk FME Area Requirements, or Data
Sheet 2, High Risk FME Area Requirements.

NOTE:

The use of tape shall not be used as an internal FME barrier.


c.

IF applicable, THEN immediately prior to closing the equipment


breach, remove the internal FME barriers.

d. Immediately prior to closing the equipment breach, the accessible


internal portions of the equipment shall be inspected for foreign
material and recorded on the Data Sheet 1, Standard Risk FME Area
Requirements, or Data Sheet 2, High Risk FME Area Requirements.
1. The equipment shall be free of foreign material.
3.10.3

Entering or Leaving an FME Area


a.

Inspect items entering the FME area, items shall:


1. Be free of foreign material.
2. Have no loose parts or fasteners.
3. Have no missing parts or fasteners, except items may enter the
FME area if the location of the missing parts or fasteners is
identified and documented.

b. Inspect items leaving the FME area, items shall have no missing parts
or fasteners, except for missing parts or fasteners that were identified
and documented upon entry.

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3.10.4

Barrier Installation and Removal


a.

Prior to installing any FME barrier, the FME barrier shall be


inspected.
1. The FME barrier shall be in good repair and free of foreign
material or loose parts and fasteners.

b. Prior to removing any FME barrier, the area around the barrier shall
be free of foreign material.
c.

3.11

Documentation of unsatisfactory inspection results with an Action


Request is required.

Special Considerations Working Inside Containment

NOTE:

Inside Containment, the FME Program interfaces closely with PMP-5020RTM-001, Restraint of Transient Material, 1-OHP-4030-001-002,
Containment Inspection Tours, 2-OHP-4030-001-002, Containment
Inspection Tours, and PMP-4010-CAC-001, Containment Access Control. In
many instances, the restraint of loose tools, bags, and equipment for the
purposes of PMP-5020-RTM-001, Restraint of Transient Material will also
achieve protection to the Recirculation Sump from foreign material, since the
foreign, transient material is not free to travel to a place where it can affect
system operation.

NOTE:

Being inside Containment is being inside a system. The Containment system


includes a Recirculation Sump that is required by Technical Specifications to
be operable in Modes 1, 2, 3, and 4.
Every effort shall be made to only take items necessary for the performance
of work into containment.

3.11.1

Entry in Containment during Modes 1 thru 4 requires the use of


Data Sheet 4, Personnel Tool and Material Accountability Log (PMAL), or
an electronic equivalent. [NRC Commitment 8441]

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3.12

Special Considerations Working around the Spent Fuel Pool (SFP)

NOTE:

3.12.1

Buoyant consumables are easy to retrieve should they inadvertently enter the
spent fuel pool.
Use buoyant consumables items (Floating Tie Wraps and Floating Rags) in
and around the spent fuel pool area where possible.

3.13

Obtain Floating Tie Wraps and Floating Rags from the Auxiliary
Building FME Supply Cabinet (outside the Hot Tool Crib) or the FME
Coordinator.

Reports on Unexpected Intrusion of Foreign Materials


3.13.1

Unexpected intrusions of foreign material into open systems, or events that


are not in accordance with the expectations of Data Sheet 1, Standard Risk
FME Area Requirements or Data Sheet 2, High Risk FME Area
Requirements, shall be reported to the Job Supervisor. The Supervisor
shall:

Consider the type of intrusion

Consider the nature of the affected system

Generate an Action Request


AND

3.13.2

Determine if further notifications are appropriate, such as the Shift


Manager, WCC-SRO, or Site FME Coordinator

Loss of FME Integrity


a.

A loss of FME integrity occurs when:


1. Foreign material is found inside the equipment upon initial
opening.
2. Material that is logged into a High Risk FME Area and cannot be
accounted for during log reviews or closure activities.
3. Non-fail-safe materials found inside a High Risk FME Area that is
not logged into the area on the PMAL.

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4. Items that become detached from lanyards inside the FME Area.
5. Material that is dropped into equipment and cannot be immediately
retrieved.
6. Material that cannot float is dropped into or found in the
Refuel/Reactor Cavity, Spent Fuel Pool and Transfer Canal.
7. FME barrier integrity is lost. For example:

Pipe dams are deflated or damaged

Covers are found damaged or missing when the area has been
left unattended

b. IF a loss of FME integrity occurs, THEN inform the Job Supervisor.


3.14

Recovery from Unexpected Foreign Material Intrusion Event


3.14.1

Efforts to recover from an unexpected foreign material intrusion event


should be accomplished under the guidance of the Job Supervisor.
a.

In some cases a verbal briefing may be sufficient, while in others, new


Work Order Tasks may be necessary along with recovery
procedures/plans.

b. View the Foreign Material Recovery Intrusion Plan Template by


accessing them through the FME intranet site on the Maintenance Web
Page. (http://cnp919b.aepngg.com/mt/FME.htm)
3.14.2

Engineering shall be contacted to evaluate any foreign material that cannot


be removed from a system or component. Engineering should be contacted
as deemed appropriate to assist in planning for FME recovery.

3.14.3

Engineering shall review the Action to determine if significant items require


additional evaluations and reviews. Examples include items:

Found in the reactor or on the Reactor Vessel Flange

From damaged plant equipment

Determine if FM is legacy or current FM. The degree of radiation for


FM found in RCS systems and support systems can be used to
determine if FM is legacy FM.

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3.14.4

IF FM is determined to be legacy, THEN a technical evaluation in


accordance with 3.14.2 for source and additional search and recovery
as necessary.

Corrective Action FME information consideration in concurrence with


PMP-7030-CAP-001, Action Initiation, include the following information if
known or applicable:
a.

Details of lost or found items or foreign material

Date and time of discovery

Description

Approximate location

For the Refuel/Reactor Cavity or Spent Fuel Pool FME Area,


use specific location

For material located on Core Plate, use normal core location


designations

For material located in the Spent Fuel Racks, use normal


Spent Fuel Rack designations

Approximate amount

Method of introduction

Potential for additional introduction

Potential effect on plant equipment

b. Determine if material recovery can be made using the existing work


order.
c.
3.14.5

Recommendation for method of locating and recovering the material.

The method for locating material should be performed up to the lesser of:

The isolation valve nearest the equipment breach

Five pipe diameters horizontally from the bottom of a vertical run of


pipe

The bottom of an isolated vessel

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3.14.6

IF necessary, THEN request retrieval Work Order Task / WO Task /WOT.

3.14.7

IF the FM cannot be retrieved, THEN obtain assistance to determine:


a.

Alternate retrieval methods.

b. The effect of the foreign material on the equipment.


3.14.8

Any decision to leave FM in the equipment shall be based on a documented


technical evaluation. (Refer to step 3.14.2).
a.

The evaluation shall be contained in or referenced to the associated


WOT and generated in response to an Action.

b. The evaluation shall address whether the material will be left


indefinitely or removed at a later date. The associated WOT will be
coded URFM (unrecoverable foreign material) in order to track future
recovery of foreign material.
3.14.9

3.15

Special Laydown/Staging Areas


3.15.1

3.16

Each unexpected FM intrusion event may be closed when the material is


retrieved or a decision is made not to retrieve the material and/or other
actions are complete.

A Special Laydown/Staging Area may be designated within or adjacent to,


the boundaries of an FME Area for the purpose of storing tools, changing
PCs, repairing equipment or the temporary storage of material. The
presence of an embedded Special Laydown/Staging Area should be
described in the approved Data Sheet 1, Standard Risk FME Area
Requirements or Data Sheet 2, High Risk FME Area Requirements, for the
job. The physical attributes of the Laydown/Staging Area should be
formalized along with the techniques to be used to protect the area without
introducing FM into the FME Area.

Personnel/Material Accountability, Control Points


3.16.1

Utilize Data Sheet 4, Personnel Tool and Material Accountability Log


(PMAL), for the Personnel Tool and Materials Accountability Log(s) as
required per Data Sheet 1, Standard Risk FME Area Requirements or Data
Sheet 2, High Risk FME Area Requirements and Containment entry during
modes 1-4.

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a.

WHEN all items listed on the PMAL have been accounted for, THEN
the Job Supervisor, Site FME Coordinator or FME Monitor shall
ensure the PMAL is closed out.

b. Closed out Data Sheet 4, Personnel Tool and Material Accountability


Log (PMAL), should remain at the FME Area or alternate location
until final area closeout and/or applicable condition report evaluation
closure, and then can be discarded.
3.16.2

IF Data Sheet 4, Personnel Tool and Material Accountability Log (PMAL),


is being used, THEN consideration shall be given to periodic reconciliation
of the Accountability Log for jobs covering many shifts and designating a
specific person to accomplish this function or denoting self check-in/checkout.

3.16.3

Disposition Codes
a.

Code
R

Descriptor
Removed

Installed*

Exchanged

Left

Verified

Transferred

Found

Use the following codes, on Data Sheet 4, Personnel Tool and Material
Accountability Log (PMAL), to indicate the disposition of items
discovered, removed or left in the FME Area.
Explanation
The item was removed from the FME Area.
Example, a tool is brought into the area and removed upon completion
of the job.
The item was installed in the FME Area.
Example, a new hanger is installed inside the area.
The item was exchanged for a similar item installed in the FME Area.
The exchanged item is the item being logged out.
Example, a valve disc or light bulb is replaced inside the area.
The item was found or dropped in FME Area and was left there.
Reference the Action number in Remarks.
The item was verified in the FME Area during FME close out.
Example, an item is in the reactor cavity FME Area and will remain
there upon FME closeout. The V Code does not apply until Closeout
Accountability
Item is still in the FMEA and has been transferred to a another Data
Sheet 4, Personnel Tool and Material Accountability Log (PMAL).
This allows the closure of a PMAL with a few items remaining while
still tracking the item in the FMEA.
Found during initial breach and removed from area. Reference the
Action number in Remarks.

* For small pieces of weld rod not installed, add a note to remarks stating small pieces not
used and removed from the FME Area, include quantity of weld rod.

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3.16.4

For some FME Areas and often in conjunction with the PMAL, an FME
Control Point should be established with an FME Monitor performing the
duties identified in the General Instructions.
a.

3.16.5

NOTE:

Logging Material

Extensive detail is required to accurately identify material logged on a


PMAL. For example: a wrench would be described as 5/8 open ended with
lanyard. FME Monitor to use Data Sheet 4, Personnel Tool and Material
Accountability Log (PMAL), or an electronic equivalent.
a.

NOTE:

WHEN an independent FME Monitor is not required, THEN a copy of


the applicable Data Sheet 1, Standard Risk FME Area Requirements or
Data Sheet 2, High Risk FME Area Requirements, shall be posted for
self-checking at the control point. Additionally, a PMAL shall be
maintained at the control point to document material(s) to be checked in
and out of the FME Area.

The PMAL shall be used to log items entering an FME Area WHEN
required by a Data Sheet 1, Standard Risk FME Area Requirements or
Data Sheet 2, High Risk FME Area Requirements.

The use of tape shall not be used as an internal FME barrier.


b. Internal FME barriers used in a High Risk FME Area shall be listed on
the Data Sheet 4, Personnel Tool and Material Accountability Log
(PMAL).
c.

Items with missing parts or fasteners shall be logged with the location
of the missing part or fastener noted.

d. IF material accountability is required, THEN rags shall be attached to


a lanyard, unless this creates a safety hazard.
e.

Rigging Equipment remaining on the hook does not need to be logged


into the area. All rigging used must be inspected prior to entering the
area and immediately after being removed from the area to validate all
the pieces are there and intact. Ensure all inspection/identification tags
are made secure or refer to MHI-5025 for guidance on rigging used in
a FME Area. Manufacturer rigging tags with load ratings shall not be
removed. [5.2.1oo]

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f.

Logging instructions:
1. Independent Monitor shall document the date, name, initials, badge
number. N/A section if self monitoring.
2. Provide all information (e. g., name, quantity, detailed description)
requested as completely, legibly and accurately as possible.
3. Record time in 24-hour format.
4. Record as applicable, the FME Monitors initials on each FME
area entry and exit, IF FME Self Monitoring, THEN record the
FME Monitors initials.
5. Additional information associated with the entry may be entered in
the Remarks Section and cross-referenced to a reference number in
the Description Column.
6. To help find an item in the FME Area, enter its location on the
PMAL when practical. General location information may be used
as well as specific column numbers or alphanumeric coordinate
information.

NOTE:

The use of the T code allows the closeout of the original PMAL with a few
items remaining while the FMEA and WO are still active.
7. IF item is still in the FMEA and accountability is transferred to a
new PMAL, THEN enter T Transferred in the Code column
of the original PMAL and enter in the remarks section of the
PMAL that an item has been transferred to another PMAL.
8. Upon job closeout, shift end, or as specified in the Data Sheet 1,
Standard Risk FME Area Requirements or Data Sheet 2, High
Risk FME Area Requirements or final exit from the FME Area,
account for all items logged into the area.
a)

Dosimetry and personal items shall be removed from the FME


Area.

b) Use appropriate disposition codes, if applicable.

Information

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Foreign Material Exclusion (FME)


g. Guidelines for rope lanyards
1. IF rope lanyards or other equipment is divided into smaller pieces,
THEN the additional item shall be entered onto the PMAL. For
example, one lanyard cut into two separate pieces. [CR 99-7687]
2. Items with a lanyard entered onto the PMAL should be logged as a
unit. For example, 1 inch wrench with lanyard. [CR 99-7687]
3. Consideration should be given for encapsulation of the ends of
ropes by melting or covering the frayed ends with an approved tape
or lashing.
4. When possible equipment should be secured with solid lanyards to
fixed anchor points instead of detachable lanyards hooked to
personnel.
h. Guidelines for the use of duct tape.
1. Only RED duct tape is approved for use in a FMEA.
2. Do not use tape as an internal FME devices or FME cover.
3. When using the red duct tape to secure items (personal or
equipment) minimize the use and log the amount of tape used by
length on the PMAL prior to entering a high risk FME areas.
4. A roll of duct tape is not allowed in a high risk FME area.
3.16.6

Logging Personnel
a.

The PMAL shall be used to log personnel entering an FME Area


WHEN required by a Data Sheet 1, Standard Risk FME Area
Requirements or Data Sheet 2, High Risk FME Area Requirements.

b. IF logging of Personnel is required, THEN the workers last name and


OCA badge number shall be entered on the PMAL along with any
exceptions to the FME Ready Worker (See Figure 4, The FME Ready
Worker)
c.

Dosimetry (TLD) and OCA Badges shall be made secure by being


securely attached to a lanyard, taped or contained within the Anti-Cs.
See Figure 4, The FME Ready Worker.

TLD shall be secured to the badge lanyard and the TLD clip
attached to personal clothing

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Foreign Material Exclusion (FME)

3.16.7

Electronic Dosimetry (ED) shall be secured to personal clothing


using the available ED clip and ED lanyard. With ANTI-Cs, the
ED shall be secured inside the ANTI-Cs front pocket with velcro
and sealed with red duct tape for additional protection as
necessary.

Personnel Entry, Exit and Transit


a.

Personnel entering the Standard Risk FME Area shall: (See Figure 4,
The FME Ready Worker)
1. Remove or secure all personal and items such as tie clasps, coins,
keys, knives, jewelry, watches, etc. Tape all pockets containing
items not removed.
2. Secure eyeglasses, hearing protection, badges, or dosimetry worn
outside clothing using lanyards, Velcro or other suitable manner.

IF Anti-Cs are used to contain items, THEN tape leg


openings on Anti-Cs unless leg opening has elastic.

b. Personnel entering the High Risk FME Area shall: (See Figure 4, The
FME Ready Worker)
1. Remove all personal items, (i.e. jewelry, change, wallets, etc.) or
restrained/controlled as noted below from person and pockets.

NOTE:

IF item cannot be removed, THEN the item must be contained


(worn under a glove, taped, etc.) and logged into the area.

Any required medications must be contained, secured to the


person (per Job Supervisor and in a manner that does not
restrict use) and logged into the area.

If supervisor determines hard hat meets fail-safe criteria, then securing hard
hat is not required
2. Secure eyeglasses, hard hats, badges, or dosimetry worn outside
clothing using lanyards, chin straps, Velcro, buttons or other
suitable manner.

IF Anti-Cs are used to contain items, THEN tape leg


openings on Anti-Cs unless leg opening has elastic.

Information

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Foreign Material Exclusion (FME)


c.

The worker or FME Monitor shall perform an inspection for loose


material of all Personnel and items entering and leaving FME Area.

d. Transit through the FME Area


1. Personnel can be authorized to transit the FME Area to access
other areas of the plant without logging onto the PMAL, however
personnel transiting a FMEA shall adhere to all other FME Area
Requirements.

IF an FME Monitor is assigned, THEN the Monitor shall


approve transit through an FME Area
OR

IF there is no FME Monitor, THEN the Site FME


Coordinator or Job Supervisor shall approve a transit.
Personnel in transit shall adhere to all of the FME Area
Requirements. [Ref 5.2.1hh]

2. Items being moved through the FME Area shall be controlled to


minimize the potential of an FME event. Included are personnel
transiting through an FME Area.
3. Personnel exiting an FME Area shall:
a)

Complete the PMAL by logging item out of the area, as


required

b) The FME monitor/self monitor shall ensure the PMAL is


correctly filled out and items leaving the FME Area (personnel
or work related) are checked against the PMAL.
3.16.8

FME Area Inspections


a.

FME Areas and adjacent lay-down areas SHALL be inspected


periodically. The Job Supervisor or designee performs the inspections
using Data Sheet 5, FME Area Inspections.

b. Inspection frequency SHALL conform to the following:


1. At least once per shift or as noted on Data Sheet 1, Standard Risk
FME Area Requirements or Data Sheet 2, High Risk FME Area
Requirements.

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Foreign Material Exclusion (FME)


2. At least once per shift or as noted on Data Sheet 1, Standard Risk
FME Area Requirements or Data Sheet 2, High Risk FME Area
Requirements for the following Outage Critical FME Areas:

Refueling Floor during refueling operations

Reactor cavity area when head is removed

Turbine or Generator when opened

Low Pressure Turbine and Main Feed Pump Turbine steam


side of condensers

Emergency Diesel Generators during maintenance

Steam Generators when opened

Ice Condensers during cycle maintenance

3. At least once per week for the Spent Fuel Pool FME Area.
c.

The FME Area walkdown SHALL verify:

Tools and materials are stored in bags or bins when not in use

Consumable materials are not accumulating inside the FME Area

The FME Area is clean and free of debris

Boundaries or barriers are intact and capable of preventing


inadvertent entry of foreign material into the FME Area

d. The FME PMAL review SHALL verify:

e.

Entries on each form are complete and legible

Items identified on the PMAL are accurately described

The PMAL reconciliation review SHALL verify:

ALL items inside an FME Area that are NOT fail safe are logged
on the PMAL

All items logged on the PMAL are actually in the FME Area

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Foreign Material Exclusion (FME)


3.17

Training Requirements
3.17.1

The following training shall be required to enter an FMEA and to perform


as a self monitor

Foreign Material Exclusion Initial Training


OR

Foreign Material Exclusion Continuing Training

3.17.2

FME Monitors performing the duty of an Independent FME Monitor, as


delineated by the FME Project Plan or the responsible Job Supervisor are
required to attend GP-L-FMEM, FME Monitor training.

3.17.3

The FME Program Owner or the Site FME Coordinator (FMEC) may
approve deviations from the training requirement provided the individual is
familiar with the requirements of this procedure and FME Area
Requirements and is accompanied with an individual that is FME qualified
before they engage in FME work or access a FME Area.
a.

Complete Data Sheet 7, Authorization for Waiver of Foreign Material


Exclusion (FME) Qualification, to request a deviation from the
required training.

b. Obtain FMEC or FME Program Owner approval of the Data Sheet 7,


Authorization for Waiver of Foreign Material Exclusion (FME)
Qualification, for the deviation from the required training.
3.18

Procedure Implementation Plan


3.18.1

Jobs planned after the effective date shall address FME as required by this
instruction.

3.18.2

Jobs that were planned prior to the Effective Date of this procedure will
normally be reviewed as part of the near-term planning/scheduling efforts
as well as job package quality reviews. Adjustments should be made as
necessary to convert the existing job package into the current Foreign
Material Exclusion rules.

Information

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Foreign Material Exclusion (FME)


4

FINAL CONDITIONS

4.1

There is no required reporting as part of this procedure, however, jobs which require
FME controls are expected to have a Data Sheet 1, Standard Risk FME Area
Requirements or Data Sheet 2, High Risk FME Area Requirements, which describes
the expected worker behavior and FME controls/requirements for the job task.

4.2

All applicable data sheets are completed and retained as appropriate (an electronic
form of the data sheets may be used).

REFERENCES

5.1

Use References:

5.2

5.1.1

PMI-2220, Foreign Material Exclusion, Cleanliness, and


Housekeeping/Material Condition

5.1.2

PMI-7030, Corrective Action Program

5.1.3

PMP-5020-RTM-001, Restraint of Transient Material

5.1.4

1-OHP-4030-001-002, Containment Inspection Tours

5.1.5

2-OHP-4030-001-002, Containment Inspection Tours

5.1.6

PMP-7030-CAP-001, Action Initiation

5.1.7

PMP-4010-JOB-001, Pre-Job Briefs and Post-Job Reviews

5.1.8

PMP-2160-CHM-001, Control of Chemical Materials

5.1.9

PMP-4010-CAC-001, Containment Access Control

Writing References:
5.2.1

Source References:
a.

ANSI N45.2.1-1973, Cleaning of fluid systems and associated


components during construction phrase of Nuclear Power Plants

b. ANSI N45.2.3-1973, Housekeeping during construction phrase of


Nuclear Power Plants
c.

10 CFR 20, Standards for Protection Against Radiation

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Foreign Material Exclusion (FME)


d. INPO SER 4-90, Unplanned Exposure From Disintegrating Materials
Stored in the Spent Fuel Pool
e.

SOER 82-1, Radiation Overexposure of Maintenance Personnel

f.

UFSAR Chapter 9, Reactor Components and Fuel Handling System

g. Technical Requirements Manual 8.5.1, Emergency Core Cooling


System (ECCS)
h. SOER 90-02, Nuclear Fuel Defects
i.

SOER 95-1 and CR 95-1151, Reducing Events Resulting From Foreign


Material Intrusion

j.

CR 96-1287, System breach not evaluated for FME

k. CR 97-2834, FME requirements in Containment


l.

CR 98-7571, Adverse trend in FME

m. CR 99-7687, FME Program Deficiencies, [3.16.5g.1, 3.16.5g.2]


n. PMP-2291-OLR-001, On-Line Risk Management
o. PMI 4010, Plant Operations Policy
p. PMP-2220-SCC-001, Cleanliness Inspection Criteria
q. PMP-2220-SCC-002, Cleanliness Inspection Certifications
r.

PMP-2220-SCC-003, System Cleanliness Methods

s.

PMP-5020-001-001, Maintenance Permits

t.

MA-320 INPO Good Practice on Foreign Material Exclusion (FME)


Program

u. NRC Commitment 1222, Walkdown work area for FME issues,


v. NRC Commitment 6661, Approach to FME, [1.1.1b]
w. NRC Commitment 6964, FME Nomenclature, [1.1.1d]
x. NRC Commitment 6980, Ice Condenser Standards,

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Foreign Material Exclusion (FME)


y. NRC Commitment 7164, Flexibility of Alternate FME Methods, [3.6]
z.

CR 02175037 [Figure 2], FME in Forebays

aa. PMP-2270-CCM-001, Control of Combustible Materials


bb. CR 02126061, SA-2002-MNT-007, FME Assessment 2002.
cc. CR 00-04119, CNT 99-269, Containment Recirculation Sump
Protection Action Plan.
dd. CR 99-28189, SA-2000-MNT-010, FME Assessment 2000
ee. EHI-5201, Containment Recirculation Sump Protection Program
ff. CR 99-03629, OE 9588 FME control device lost in controlled
system. 3.4.2e.1
gg. CR 04218086 Administrative FME Controls
hh. CR 04298002 Improvements to the Foreign Material Exclusion
(FME) program have not been fully effective
ii. CR 05257035
jj. EPRI TR-106756, Foreign Material Guidelines
kk. NRC Commitment 8441, I&M Will Maintain the necessary
programmatic and process control.
ll. INPO 07-008, Guidelines for Achieving Excellence in Foreign Material
Exclusion
mm.

AR 00840408, Use of Buoyant Materials around SFP

nn. OE-29761, Unraveling Debris from Fire Blanket Material


oo. MHI-5025, Control and Inspection of Rigging and Lifting Equipment,
Rev 13, step 4.1.3c.2.d
pp. OE/CNPOE: 13-01358, Outage Extension Due To Loss Of FME
Controls

Information

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Rev. 25

Foreign Material Exclusion (FME)


5.2.2

General References
a.

None

Page 43 of 90

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Foreign Material Exclusion (FME)


Attachment 1

1.1

Work Practices

Pages:
44 - 60

Work Practices
1.1.1

1.1.2

1.1.3

Housekeeping

Workers have a responsibility to maintain a clean and controlled work


environment that reflects the basic core work values for safe and
efficient plant operation.

A neat and clean workplace must be maintained.

Workers capture or contain all generated foreign material and practice


clean as you go.

When a work assignment is completed, or at the end of a shift or day,


the work area is left as clean as or cleaner than it was before the work
activities. This clean or cleaner concept extends to all plant facilities,
shops, and offices.

Shop Practices

Shop and bench work follow the guidelines of this procedure.

Parts received from the warehouse should be properly protected from


FM intrusion. IF not, THEN either the component is completely
inspected and covers are installed or the component is returned to the
warehouse.

Ensure that components stored in the shop are protected with


appropriate FME devices or covers.

Ensure that proper FME devices or covers are reinstalled when


returning equipment or parts to the storeroom.

Job Preparations

Inspect the work area. IF FME controls are required for the job,
THEN inspect the work area to verify that the levels of controls
specified in the work order are correct.

Inspect the surrounding area to determine what types of boundaries


or special covers may be needed.

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Attachment 1

1.1.4

Work Practices

Pages:
44 - 60

Review the work scope to determine if any changes are needed for
the FME Area designation and special requirements.

Consider whether the ventilation system or other local factors


could introduce foreign material into the FME Area during the
work activity. IF so, THEN plan to redirect or secure the
ventilation ducts for the duration of the activity, install temporary
filters on supply and exhaust ducting, or install clean enclosures
such as glove boxes or tents at the work site, as necessary.

Consider types of tools and materials to use. Determine if special


tools will be needed if an FME Area is required. IF tools, parts,
or other items used in an FME Area are not fail-safe, THEN
determine the need for specialty tools and lanyards. IF tools are
not available or cannot be made, THEN request the necessary tools
from the Immediate Supervisor.

IF work will be in or around the spent fuel pool THEN obtain


buoyant consumables for use where applicable/practical.

Conduct prejob briefings. During the briefings, discuss the


necessary FME controls. For jobs that require an FME Area, the
Supervisor and workers discuss the FME requirements in detail,
including monitoring, training, inspection, and prevention.

Establish the Work Site


a.

Establish a controlled area and perform the following:

Establish FME AREA boundaries per program requirements before


actually opening a system or component.

Establish the FME AREA as close as practical to the system


breach.

Install boundary markers and, before establishing the FME AREA,


remove all items within the boundary or log them.

Assign responsibility for tool and material control if logging is


necessary.

Create a log with all items that remain within the FME AREA.

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Attachment 1

Work Practices

Pages:
44 - 60

Ensure that items are logged into the FME AREA with a detailed
description of the item and quantity, when required.

Inspect the FME AREA and adjacent area for loose debris.

Consider establishing a buffer zone around the FME AREA as an


area of enhanced cleanliness and reduced clutter.

Clean the FME AREA and adjacent areas to provide the required
level of pretask cleanliness according to the cleanliness program.

Inspect overhead gratings, walkways, railings, and other structures


and components for dirt and other debris.

Consider whether special considerations need to be made for


placing covers on lighting devices.

Ensure that no activities in or around the FME AREA could


introduce foreign material into the system or component.

b. Set up a laydown area for staging parts, as follows

Establish a suitable laydown area outside the FME AREA to allow


tools and materials to be staged when they are not actively being
used in the FME AREA.

Introduce items into the FME AREA only as required to support


present work activities, to the extent possible. As soon as practical
upon completion of use, collect these items and return them to the
staging area.

Minimize the quantity of items available that could be introduced


into an open system or component. This reduces the likelihood of
such an occurrence.

Place approved material over gratings where small tools or parts


could fall through. The area should be located such that items
cannot be inadvertently introduced into the FME AREA.

Information

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Attachment 1

c.

Work Practices

Pages:
44 - 60

Do not introduce packaging and similar materials into the FME


AREA unless absolutely necessary. For example, packaging that
serves as protection for extremely sensitive components and
containers for small items that might otherwise easily become lost
are considered acceptable.

Ensure that enough FME covers and devices, as well as lanyards,


are staged for use.

Before creating a system breach, workers need to verify that an


FME device is ready and available to be installed when they leave
the area.

Inspect and clean tooling, as follows:

Inspect tools for parts that may fall off, and confirm the existence
and/or tightness of a positive retention mechanism on all such
parts.

Inspect tools for excessive wear, such as rounded heads on chisels


or a Chicago fitting clip that is bent or worn.

Do not use tools and equipment that contain lead, steel, or other
types of shot (for example, diver weight belts and dead blow
hammers) that have a potential for the shot to come loose and
become foreign material.

Clean all tools entering the FME AREA of all dirt, debris, and
excess lubricant that could be introduced into the system or
component.

Cover the openings of portable tools, equipment, and hoses used in


the transfer of material when not in use, to prevent entry of foreign
material. Alternatively, a flushing procedure may be performed
immediately before use.

Ensure that hoses and tubing used for venting or draining are
routed to prevent debris from being siphoned into a system.

Consider taking pictures or videos of complex tooling (for


example, underwater robots) before introducing the tools into the
FME AREA and after removal. This facilitates confirmation of
tool integrity by comparing the pre- and post-video.

Information

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Foreign Material Exclusion (FME)


Attachment 1

Work Practices

Pages:
44 - 60

d. Use lanyards or other similar securing methods for nonfail-safe tools,


to prevent inadvertent entry into the system, as follows

Provide a backup method for preventing material loss inside the


FME AREA by using lanyards when applicable. Lanyards can be
purchased or manufactured at the site. If manufactured, they
should be constructed from materials that do not chip, flake, or
peel. Nylon, rubber tubing, and corrosion-resistant steel wire are
recommended materials. Steel wire is recommended for long-term
exposure in harsh environments.

Manufacture or purchase lanyards that are of the shortest practical


length, to prevent the attached item from hitting or damaging a
component if dropped and to minimize the dropping distance.

Verify that lanyards are strong enough to resist breaking if the item
does drop.

Inspect and test lanyards to ensure that they are securely attached
and are not likely to become detached during use. Stainless steel
lanyards should be checked for fraying and removed from service
if frayed

Do not suspend items by their lanyards, and never use power cords
or air hoses as lanyards.

Attach lanyards in such a manner as to prevent loss from the


anchoring point, such as a handrail or personnel.

Attach tools used over open water or fluids by a lanyard or other


acceptable retention methods.

Secure all installed tooling over open water using redundant


methods, including appropriate knots and fastening systems to
ensure that if the primary lanyard loosens, the device will remain
controlled.

Information

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Attachment 1
e.

Work Practices

Pages:
44 - 60

Work Activities
1. Perform pre-cleaning, as follows

Inspect the work area, including overhead, to ensure that the


component to be opened and the immediate area have no
potential foreign material present before FME controls are
established

Clean the area and initiate a condition report if abnormal types


or quantities of material are discovered that could become
foreign material, such as boric acid crystals found on
containment air coolers or radiation monitor filters or
excessive rust

Preclean any materials introduced into the FME AREA before


beginning work

2. After a system or component is opened for maintenance,


immediately inspect accessible internal portions to ensure there is
no unexpected internal foreign material, and perform the
following:

Obtain an assessment of the level of cleanliness and determine


the resolution if any abnormal or excessive amount of rust
scale, corrosion, or erosion is identified.

Inspect gasket integrity to determine if any foreign material


may have been introduced into the system.

Inspect any gaskets that are removed when a flanged joint or


manway is separated for any reason. Foreign material may
not be evident at the work location, because the process fluid
may have carried it downstream.

3. Log items, as follows:

Establish PMAL for tool material and equipment control when


nonfail-safe items are required within an FME AREA.

Create a log with all items that remain within the FME AREA
after the zone is established, and continue to log all items that
enter or leave the area.

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Attachment 1

Work Practices

Pages:
44 - 60

Record all tools, parts, hoses, and tubing in the PMAL before
these enter and exit the FME AREA.

Use lanyards or other acceptable means to secure all tools,


materials, and equipment that are not fail-safe before
introducing them into the FME AREA.

Ensure that lanyards do not have the potential to become


introduced into the system or component as foreign material.

Control parts removed from installed equipment or


components by tagging, bagging, or staging for identification,
to preclude misidentification and to ensure accurate inventory.

Control all personal items before entering an FME AREA as


follows:

Personnel entering the Standard Risk FME Area shall:


(See Figure 4, The FME Ready Worker)

Remove or secure all personal and items such as tie


clasps, coins, keys, knives, jewelry, watches, etc.
Tape all pockets containing items not removed.

Secure eyeglasses, hearing protection, badges, or


dosimetry worn outside clothing using lanyards,
Velcro or other suitable manner.

IF Anti-Cs are used to contain items, THEN tape leg


openings on Anti-Cs unless leg opening has elastic.

Information

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Attachment 1

Work Practices

Personnel entering the High Risk FME Area shall: (See


Figure 4, The FME Ready Worker)

NOTE:

Pages:
44 - 60

Remove all personal items, (i.e. jewelry, change,


wallets, etc.) or restrained/controlled as noted below
from person and pockets.

IF item cannot be removed, THEN the item must


be contained (worn under a glove, taped, etc.)
and logged into the area.

Any required medications must be contained,


secured to the person (per Job Supervisor and in
a manner that does not restrict use) and logged
into the area.

If supervisor determines hard hat meets fail-safe criteria, then securing hard
hat is not required.

Secure eyeglasses, hearing protection, hard hats,


badges, or dosimetry worn outside clothing using
lanyards, chin straps, Velcro or other suitable
manner.

IF Anti-Cs are used to contain items, THEN tape leg


openings on Anti-Cs unless leg opening has elastic.

Maintain control of the FME AREA by preventing


nonessential personnel from entering. Workers who are not
trained and qualified as FME workers are not allowed in the
FME AREA.

Ensure that items are logged into the FME AREA with a
detailed description of the item and quantity. It is
unacceptable to log toolbox or bag of nails, for example.
Instead, each tool in the toolbox and the number of fasteners to
be taken into the FME AREA are logged, and the minimum
quantity of each item should enter the FME AREA.

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Attachment 1

NOTE:

Work Practices

Pages:
44 - 60

Log cleaning cloths by the approximate size and specific


quantity. Also, consider labeling or numbering each cloth to
verify its removal. This is critical in areas where foreign
material may not be detected when the system is opened.

Do not allow transparent materials, such as visors, clear


plastics, and tubing, in the FME AREA unless they are
conspicuously marked to improve visibility and tracking.
These items are logged by a detailed description and specific
quantity.

Tape is not a means of FME protection, however tape can be used to secure
personal items or FME covers if necessary.

Avoid the use of tape inside the FME area. If its use is
necessary, the amount should be accounted for and controlled.
Remove tape residue from piping and plant systems after tape
is removed per chemical permit.

Ensure that subcomponents are logged, as necessary. For


example, the use of metal tags attached to items should be
minimized and the tags inspected and logged.

4. Use FME covers and devices, as follows:

Use FME covers or internal devices such as pipe dams when


required and if system integrity must be breached and must
also be left open and unattended during task performance.

Use pipe dams or temporary covers during activities such as


grinding, valve lapping, or filing.

Secure FME devices so they will not be sucked in or blown


away by a pressure drop or surge of the system or during
transportation (High air flow).

Information

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Attachment 1

NOTE:

Work Practices

Pages:
44 - 60

Tape is not a means of FME protection, however tape can be used to secure
personal items or FME covers if necessary.

WHEN high air flow conditions exist, THEN secure the FME
covers with tape. Authorized tape includes Fiberglass or glass
cloth tape (See Chemical Permits 2554 and 2566)
Cat ID
Width
0463947000

0463947080 1 1 1/2
04639446690
6
04639446690
8

Do not use paper dams, clear plastic bags, cloths, or similar


materials as FME devices. These items should not be installed
inside the system.

Inspect FME covers to confirm that they are in good repair


and free of foreign material or loose parts and fasteners before
installing them.

Ensure that the FME device will not allow the introduction of
foreign material into the system when the covers are installed
or removed. Brightly colored FME covers are preferred, to
prevent them from being left installed.

Tether internal FME devices externally whenever possible, to


avoid their inadvertent loss into the system during work
activities. When internal FME devices are used, document
them on the PMAL by location and quantity.

Consider installing additional or larger FME barriers before


commencing maintenance activities that involve the use of
tools that can break or have pieces come off and before
manipulating parts, such as fasteners, when the loss of control
of such parts could result in a loss of FME integrity.

Consider the use of rigid covers if horizontal openings are


accessible for falling or heavy objects that could damage or
penetrate the cover.

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Foreign Material Exclusion (FME)


Attachment 1

Work Practices

Pages:
44 - 60

5. Review work details and activities for vulnerability to FM


intrusion, as follows:

Pick up waste material and remove it from the FME AREA as


work progresses. To the extent practical, capture and contain
foreign material that is created.

Clean as you go, and avoid the approach of cleaning up after


work activities are complete. Final inspection and cleanup
should be minimal.

Anticipate the results of planned actions for work within the


FME AREA.

Use the STAR method of stopping and thinking before acting,


then follow up with a review before initiating any action.
Workers should always expect the unexpected.

Ensure that component surfaces are clean and free of foreign


material when performing activities that require grinding,
machining, or lapping of valve seats. Vacuum cleaning alone
is not sufficient to ensure the removal of lapping compound or
metal residue.

Use wipes, flushes, or similar methods to ensure that all grit


and debris are removed, to prevent intrusion into the system.
Stellite debris from activities such as valve grinding or lapping
is of particular concern, because it becomes highly radioactive
after passing through the reactor.

Ensure that all welding residue such as slag, grinding dust, and
spatter is removed during welding or grinding inside a system.

Implement special precautions or procedures when work tasks


intentionally introduce foreign material into a system or
component, such as with leak-sealing compounds, chemical
cleaning compounds, inert gas blankets, decontamination
compounds, and excessive lubricants. These special
precautions or procedures may include the use of tents,
barriers, or dams, as well as workers to vacuum, flush, and
inspect the work area periodically.

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Attachment 1

Work Practices

Pages:
44 - 60

Inspect for nondestructive examination residues, and clean


appropriately.

Use care during work on instrumentation air piping and


downstream tubing when applying thread lubricants or
sealants, to prevent their intrusion into the system.

Clean all tools and parts of any excess lubricant that could be
introduced into the system.

Employ the blue-line cutting method or comparable method


that will not result in any internal cutting debris, unless other
measures are used to contain debris caused by cutting, when
breaching vertical pipe runs.

Employ normal cutting methods as long as filings and debris


generated can be completely removed upon completion of the
cut when horizontal pipe runs are breached.

Take special precautions when work activities (spray painting,


sand blasting, grinding, cutting, welding, insulating, chemical
cleaning, and so forth) may generate airborne dust, debris, or
chemical fumes that could be introduced into operating plant
equipment such as motors, switchgear, control panels, and
electrical cabinets. This would include tagged-open vents and
drains, motors with air intake paths, and sensitive
instrumentation.

Do not use wire wheels and wire brushes unless there is no


other option. The wire strands can separate from the wheels
and brushes and might become a source of foreign material
migrating into adjacent FME AREAs if proper controls are not
maintained.

Control the necessary use of wire wheels and brushes, and


minimize their use near systems that interact with the fuel.

Use caution when removing fill or sample ports and sight


glasses, being sure to preclean before removal to prevent the
introduction of paint chips or debris into the reservoir.

Ensure that sampling equipment is free of debris and residue


when taking oil samples.

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Foreign Material Exclusion (FME)


Attachment 1

Work Practices

Pages:
44 - 60

Pre-clean grease fittings, and ensure that the grease gun


injection end is free of grit and debris when greasing motor
bearings.

Do not use tie-wraps that incorporate metal tabs in the plant


unless specifically evaluated by Engineering for that specific
task. When used, be sure that tie-wraps are sized
appropriately to prevent failure.

Use FME covers on vents and drains that could allow foreign
material intrusion if oriented between the 8 oclock and 4
oclock positions and if they are to be left open and
unattended. Vents and drains with drain lines that divert the
fluid to drains do not require covers.

6. Reassemble components with FME controls, as follows:

Inspect the local area surrounding the device thoroughly to


ensure that no foreign material has built up on the device or
around its edges before removing an installed internal FME
device.

Clean the device thoroughly before removal.

Exercise caution when removing internal FME devices.


Hazards from pressure buildup, heat, and airflow are examples
that should be considered before device removal. Pressure
from isolation valve leakage can build up behind these devices.
Heat buildup may cause unexpected action from released FME
devices.

Document the removal in the PMAL, and continue this


practice for all removed FME covers and devices after
removing the device.

7. Inspect the accessible portions of the affected areas before


installing components that may prevent later final closeout
inspection. A boroscope, mirrors, and other aids may be used to
examine inaccessible or difficult-to-see surfaces properly.

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Foreign Material Exclusion (FME)


Attachment 1

Work Practices

Pages:
44 - 60

8. Clean new components before installation. New parts,


components, and equipment to be installed in the plant should be
carefully inspected to ensure that no foreign material is present,
such as packaging material, shipping plugs, spacers, desiccants,
lubricants, and preservatives used for shipping or storage.
9. Examine tools upon exit. All tools and parts that cross the
boundary will be logged as required and inspected for damage or
missing parts.
10. Perform as-left closeout inspections, because they are the final
barrier for detecting foreign material intrusion. Perform the
inspections as follows:

Inspect accessible internal portions of the equipment for


foreign material immediately before closing the equipment
breach.

Ensure that all tools and materials have been removed from the
FME AREA and adjacent areas upon overall task completion.

Ensure that PMALs are reconciled, and remove and account


for all FME devices.

Implement a post maintenance inspection of the FME AREA


with an inspection of the FME AREA and adjacent areas.

Remove all barriers used to establish and maintain FME


controls and the FME AREA boundary, and return the area to
its pre-maintenance state.

Properly store reusable barriers, and dispose of all consumable


items removed.

11. Conduct post-job critiques after critical FME work, to determine


lessons learned and methods to improve FME controls. Feedback
from station and supplemental workers should be requested and
respected.
12. Discuss corrective actions taken based on worker feedback with the
workers after the corrective actions are taken, to demonstrate to the
workers the value of their feedback.

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Attachment 1
1.1.5

Work Practices

Pages:
44 - 60

Other Considerations For Electrical and I&C Maintenance


a.

For maintenance on electrical equipment, as with all other plant


equipment, consider whether any potential FME implications exist for
each task during both planning and performance. While it is necessary
to follow the work practice guidance that applies to other plant
components, some special considerations are recommended, as follows:

Ensure covers are installed on open electrical enclosures, cabinets,


boxes, and conduits required to be left open by procedure, plant
operations, or the work task supervisor

Maintain positive control of all mounting screws, wire nuts, and


other miscellaneous material while working in an electrical cabinet,
and remove as necessary

Ensure all wire end stripping, tie-wrap ends, and other incidental
debris are captured when the task is complete

Use special catch devices or tooling as necessary to minimize the


risk that small screws or fasteners will be dropped on removal or
installation

Establish controls for work activities that generate airborne debris


to prevent foreign material from entering electrical and
instrumentation enclosures via the ventilation openings

Before closing an electrical cabinet, ensure that all parts are


accounted for and that all disturbed mounting screws or fasteners
are sufficiently tight so they do not become loose and subsequently
displaced

Ensure no inappropriate material is stored in the cabinet, such as


spare fuses or bulbs

Keep circuit breakers covered when transported or stored; and


perform an effective cleaning, parts accountability, and visual
inspection when working on switchgear. If an internal inspection
of transformers is required, establish an FMEZ. Other electrical
equipment has additional requirements along with those that apply
to electrical cabinets

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Foreign Material Exclusion (FME)


Attachment 1

Work Practices

Pages:
44 - 60

Perform a thorough general inspection of motors before removal.


Pay particular attention to any screens or filters that cover air
intakes; and clean them before disassembly, being careful not to
introduce foreign material. Also for motors, drain and flush oil as
required

Use caution when removing fill or sample ports and sight glasses,
being sure to clean these before removal so as not to introduce
paint chips or debris into reservoirs

Ensure sampling equipment is free of debris and residue when


taking oil samples

Clean grease fittings and verify that the grease gun injection end is
free of grit and debris when greasing motor bearings. If storing or
transporting motors, ensure air intake ports are covered

Take precautions to capture debris generated by the cutting of


tubing and supply hoses when working on air-actuated components.
Tubing being replaced should be free of debris. If cleanliness
cannot be ensured, consider flushing

Use the correct flushing medium for the system/component being


worked

Account for small screws, clips, and other fasteners after


performing work in controllers

Use the proper thread sealant, ensuring that excessive sealant does
not restrict flow or contaminate the system

Secure bolts, fasteners, and clips, and inspect them to verify they
are in good shape before instrumentation is reinstalled

Verify controls are maintained on a periodic basis. During active


work, verify that FME controls are maintained sufficiently
throughout the duration of the work. This can be accomplished by
periodic inspections

Ensure openings are covered to prevent the entry of foreign


material when work on an open system is stopped

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Foreign Material Exclusion (FME)


Attachment 1

1.1.6

Work Practices

Pages:
44 - 60

Ensure the controls are rigorous enough for the entire duration if
work areas are inactive for an extended period. Perform an
inspection before resuming the work activity

Stop the work activity and implement the foreign material intrusion
actions if FME integrity is lost or if items are discovered with
undocumented missing parts or fasteners

Non-maintenance Activities
a.

Maintenance is not the only activity that can result in FM intrusion.


Additional activities and situations that can cause material to get into
systems and components are as follows:

Environmental conditions normally open systems, equipment


degradation and failures, and routine activities performed by other
station personnel

Applicable activities in the power plant boundaries or equipment


such as lubrication, chemistry additions, sampling, venting, filling,
draining, radiation surveying, housekeeping, inspections,
surveillances, testing, maintenance, and refueling activities. The
FME program applies to any group that performs such activities

Operations activities such as venting and draining, racking breakers


in and out, changing fuses, refueling, and adding resin, as well as
operator rounds and inspections

Radiation Protection activities such as radiological surveys of plant


equipment and monitoring of operations activities within the plant
by a variety of personnel

Warehouse activities such as receipt inspection, material and


component storage, and periodic maintenance; vendor work on
plant equipment; and security activities such as training exercises,
security rounds, and equipment searches

Field observation and inspection activities such as management and


oversight observations, quality control, and engineering walk
downs

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Foreign Material Exclusion (FME)


Attachment 2

1.1

Work Instructions

Pages:
61 - 65

This section is meant to assist Planners, Supervisors and craft in establishing proper
controls to prevent foreign materials from entering plant systems or components.
Work Order Tasks should be structured appropriately to ensure that the integrity of
the system or component is maintained by considering the following:
1.1.1

Does this work activity involve opening a system or component? If yes,


then identify any special requirements and include appropriate steps in the
work package instructions. FME requirements should consider the
following:

Special cutting methods when cutting into piping systems, especially for
vertical components where debris may not be visible after piping is
breached.

Controls to prevent the loss of FME during installation and removal of


support commodities such as scaffolds, rigging, temporary cables, and
insulation.

1.1.2

Before system closure, is a final visual inspection of internal cleanliness


performed? If not possible because of configuration or other
circumstances, are the FME controls of the highest level?

1.1.3

Should the area surrounding the work activity be posted and roped off? IF
yes, THEN define the work area and consider the following when defining
the FME boundary requirements:

1.1.4

Posting signs

Installing barriers

Controlling access to a room or cubical by establishing FME control


points

Consider the use of a FME Buffer Zone

Can the ventilation cause dirt and debris to be introduced into the
system/component or become contaminated and spread dirt and debris to
other areas of the station? IF yes, THEN consider securing or redirecting
ventilation; installing temporary filters on supply and exhaust ducts; or
installing clean enclosures, such as glove bags or tents (with or without selfcontained ventilation systems), at the work site or in adjacent areas.

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Foreign Material Exclusion (FME)


Attachment 2

Work Instructions

Pages:
61 - 65

1.1.5

Can the use of special clothing significantly reduce possible introduction of


foreign material? IF yes, THEN define special clothing requirements such
as the wearing of cotton gloves and booties and cloth or paper suits or
hoods.

1.1.6

Should new parts/components/equipment be disassembled and verified free


of foreign material before installation? Inspect new valves and pumps
received from the warehouse for cleanliness before installation. Employ
intrusive methods (fiber optic scope) to inspect and, if necessary, clean
hard-to-reach portions of the component. Minor disassembly may be
warranted, provided it does not violate warranties or initial setup settings.

1.1.7

Does the system or components require Performance Verification


inspections or verification points by maintenance personnel? IF yes,
THEN ensure that the hold points and verification points are identified in
the work package.

1.1.8

Do the system cleanliness requirements need to be verified following the


maintenance activity? IF yes, THEN coordinate with the appropriate
personnel to perform appropriate flushes, inspections, and other activities in
accordance with plant procedures, industry standards, and regulatory
requirements.

1.1.9

Consider the effects of activities on the reliability of electrical and


electronic equipment (such as insufficient control of metal shavings during
the drilling of holes in electrical panels; insufficient covering of open
breaker mechanisms that are partially or fully removed from switchgear;
and improper control of cleanliness of equipment stored or being repaired in
a shop).

1.1.10

Does the work area need to be cleaned before work begins? IF yes, THEN
include instructions for cleaning the area of dirt and debris, removing
material, and cleaning overhead.

NOTE:

1.1.11

The work planner should work with Engineering to identify alternatives to the
use of lock wire installed internal to components in fluid systems such as
systems with feed water check valves.
Is lock wire being used or removed during the work activity? IF yes,
THEN include special notes to control the lock wire and trimmings when
the lock wire is installed or removed.

Information

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Foreign Material Exclusion (FME)


Attachment 2

Work Instructions

Pages:
61 - 65

1.1.12

Use barriers and frequent cleanings when machining stellite surfaces.


Machining can result in sharp shards of metal that are particularly harmful
to fuel rods. Use foam sealant around the pipe inner diameter and bladder
inserted for FME control.

1.1.13

When gaskets are to be replaced in piping systems, restrict the use of wirewound gasket types that are likely to degrade and release wire-like debris
into fluid systems. Some gasket types are known to degrade and, in some
cases, to introduce wire-like debris into systems. Gasket material has been
directly linked to fuel failures and steam generator tube breaks.

1.1.14

In general, do not use wire or steel brush devices for work in FME highrisk areas. Mechanical Maintenance Manager management approval is
required for the use of wire or steel brush devices in these areas. Controls
over their use should include actions to retain control of any loose bristles,
as well as a thorough closeout inspection following the work.

1.1.15

Evaluate the potential spread of loose bristles from a wire or steel brush
device being used outside of an FME high-risk area. IF the bristles could
be directed into the area, THEN erect barriers or tents to capture the
bristles. Consider similar controls for frayed wire ends, stud hole cleaning
tools, and other devices that could create small, metallic, wire-like debris.

1.1.16

Specify the use of buoyant consumables in and around the spent fuel pool
area where applicable/practical.

1.1.17

Before refueling outages, add controls to inspect and, if necessary, clean


empty, dry new fuel storage rack locations that are to be used for new fuel.

1.1.18

Add controls for management personnel to periodically inspect the SFP and
surrounding FME high-risk area for cleanliness. Inspection criteria should
include the following:

The FME high-risk area immediately surrounding the SFP is free


of all debris.

Tooling or nonpermanent plant equipment is not located inside the


FME high-risk area unless completely secured, logged, and
inspected on a periodic basis.

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Foreign Material Exclusion (FME)


Attachment 2

Work Instructions

1.2

Pages:
61 - 65

Clear plastic, Plexiglas, and glass items used in the immediate


areas that surround the SFP have been appropriately evaluated for
use in the SFP, and these items are clearly marked to aid in
retrieval.

1.1.19

IF a hot-tapping process is used, THEN put controls in place to capture


debris from shavings that are generated from the cutting device. FME
evaluation is required for Hot Tapping activities.

1.1.20

Document in an AR foreign material found or recovered from a reactor


coolant or attached system.

1.1.21

Document the results of closeout inspections in the work package.

1.1.22

During outage periods when reactor internals become accessible to some


degree, perform visual inspection and cleaning as a standard practice.
Inspect and clean accessible in-vessel areas as needed before vessel
reassembly. Document as-found conditions.

1.1.23

The handling of new fuel and reload fuel can increase vulnerability to
debris intrusion. The following are appropriate practices for fuel-handling
activities:

High-Risk FME controls shall be in effect for new fuel from the
moment the shipping containers are opened on site. Perform
receipt inspection of new fuel, because fabrication and preparation
for shipment may have resulted in debris intrusion into the new
fuel.

When obtaining previously discharged fuel from the spent fuel pool
for reinsertion into the reactor core, visually inspect the assembly
to ensure it is free of debris.

Include operating experience in the work instructions, and use it during pre-job
briefings to reinforce expectations and to ensure that stations not only learn from
others but do not repeat similar occurrences. Relevant OE can be found on the
INPO Web site.

Information

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Foreign Material Exclusion (FME)


Attachment 2

NOTE:

1.3

Work Instructions

Pages:
61 - 65

FME plans are developed to define specific FME requirements but should not
supersede any FME programmatic guidance.

Develop FME plans for more complex and critical activities commensurate with the
probability and consequences of foreign material intrusion. When determining if a
plan is required consider the following questions:

Do existing procedures lack specific FME controls for each breaching,


opening, or removal evolution to be performed during the activity?

Is the work to be performed in a continuously exposed area (that is, the


spent fuel pool, refueling pool, steam generator, or turbine generator)
where the highest level FME standards are continuously in effect?

Is the work to be performed on equipment, such as control oil systems and


close tolerance equipment, extremely sensitive to foreign material intrusion?

Does the work generate particulate where a visual closeout inspection would
not ensure all debris has been removed and the material would be difficult
to retrieve?

Does the work entail multiple work groups, large component replacement,
or multiple system breaches?

1.3.1

IF developing FME Project Plans, THEN use the template provided on


Data Sheet 6, FME Project Plan or an equivalent that addresses the same
critical areas. Instructions for completing the Project Plan are included on
Data Sheet 6, FME Project Plan.

Information

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Foreign Material Exclusion (FME)


Attachment 3

1.1

1.2

Material Storage

Pages:
66 - 67

Storeroom Supervisor Responsibilities

Storeroom Supervisors ensure that material in warehouse storage is


maintained in a condition consistent with the FME procedure guidelines.
They provide FME training to warehouse and receipt-inspection personnel
that is equivalent to or better than training received by station personnel.
They ensure that appropriate FME devices are installed on parts or material
as required. Storeroom Supervisors communicate to plant personnel that
returned material and parts are free of foreign material and that appropriate
FME devices are installed when items are being returned to the warehouse

Storeroom Supervisors ensure that the contents of MMDG.409, Cook Plant


Material Management Foreign Material Exclusion (FME) Guidelines are
communicated and understood

Warehouse Practices
1.2.1

NOTE:

Storeroom supervision ensures that parts and materials provided to station


and supplemental personnel are free of foreign material. Several options
can be used meet this criterion. One is to inspect all parts and materials
that leave the storeroom/warehouse for foreign material before issuance.
Another option is more conservative and includes the following:

Order materials supplied by vendors and manufacturers with contracts


that specify FME requirements as applicable. Equipment should arrive
on site with the appropriate FME covers and caps.

Identify if materials arrive without FME protection or the appropriate


FME devices in place during receipt inspection, and put appropriate
FME controls in place.

Tape is not a means of FME protection, however tape can be used to secure
personal items or FME covers if necessary.

Use only caps, plugs, tapes, or adhesives that are made of materials
that enable them to perform their intended function without causing
deleterious effects on items or in systems operation.

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Attachment 3

NOTE:

1.3

Material Storage

Pages:
66 - 67

Tape is not a means of FME protection, however tape can be used to secure
personal items or FME covers if necessary.

WHEN tape is required to secure FME covers and devices, such as


areas with high air flow or when transporting exposed pipe on a truck
or trailer THEN use only tape authorized for FME use (e.g., fiberglass
or glass cloth tape. See Chemical Permits 2554 and 2566).

Perform receipt inspections using the guidelines of the station FME


program for intrusive inspections.

Ensure that stored items have all covers, caps, plugs, and other
closures intact. If covers are removed for internal access, at any time
and for any reason, perform an inspection. Following inspection,
replace the covers and reseal openings to preserve FME integrity.

Tape is not a method for FME protection. However, tape can be used
to hold or attach, or secure FME protection. Dependent on the type
used, tape can leave a residue that may have detrimental affects on
components. Remove any tape residue after use.

Inspect hoses and hose fittings for foreign material during bulk
chemical deliveries before connecting to plant piping, to prevent
foreign material from being introduced.

Maintain the warehouse free of debris and possible foreign objects that
could enter material. Check for cleanliness and orderliness on a
continuing basis to meet program requirements. Do not permit trash to
accumulate in receipt or storage areas.

Issued Material

Materials delivered to the plant must meet the FME requirements, with
covers installed. Store materials properly until installed in the plant or
returned to the warehouse. Materials being returned to the warehouse
should have the proper FME covers installed while being transported and
when returned to inventory. If security searches are required, FME covers
should be reinstalled after the search.

Information

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Attachment 3

Material Storage

Pages:
66 - 67

Bulk pipe stored outside should be supported to avoid collection of


moisture, if applicable. Unless specified otherwise pipe ends for bulk pipe
(stored outside or inside) are not required to be covered. After pipe has
been fabricated and flushed/cleaned to the level of the system, control all
openings in accordance with the station FME procedure

Prior to sending equipment off site for service or repair, implement proper
FME controls. Ensure that the equipment is properly packaged for
transportation and that controls are in place while the equipment is at the
service facility

Information

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Foreign Material Exclusion (FME)


Data Sheet 1

NOTE:

Standard Risk FME Area Requirements

Pages:
69 - 69

Perform as much work as possible outside the FME Area


Refer to step 3.11 for FME requirements when working inside containment
PMAL required for entry into Containment during modes 1-4.

Location:_____________________________________________________________________________________
Work Order Task /Procedure: ____________________________________________________________________
Job Description: _______________________________________________________________________________
Check each box as applicable:
Yes
No
Yes
No
FME-job brief
Personnel Tool and Material Accountability Log
(PMAL)
Secure/Redirect ventilation
FME barriers/devices used
Remove nonessential materials from area
Check hoses for cleanliness prior to use
Clean area prior to starting work
No Clear, unlabeled plastic
Clean overhead areas
Examine Tools Prior to Entering FME Area
Install Boundaries around area
Remove or Secure personal objects from pockets
Post Signs
Lanyard tools, badges, TLDs or other items
Control Access/Control Point
Monitor T
Self Monitor T
(Step 3.16.8a, b, c) FME Area Walkdown:
(Step 3.16.8c, d) PMAL Accuracy Review:

Yes T Waived T Shiftly T Other ________


Yes T

Shiftly T Other ________

(Step 3.16.8e) PMAL Reconciliation Review: Yes T Waived T Shiftly T Other ________
Additional Requirements/Remarks: ______________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Approved by: _________________________________________________________________________________
Job Supervisor/Designee or Site FME Coordinator: Print
Signature
Date
Change Approval: _________________________________________ / ________________
Job Supervisor or Site FME Coordinator
Date
(Step 3.10.2a) As Found Breach Inspection Performed by: ____________________________ Date: __________
(Step 3.10.2b) Internal Part(s) Inspection

Performed by: ____________________________ Date: __________

(Step 3.10.2d) System has been inspected for foreign material and results recorded in the Additional Requirements/Remarks
section. [NRC Commitment 1222]
Job Supervisor_________________________
Date _________
Signature
Final conditions:
Tools, Materials, FME Area Postings and Boundaries, etc. removed (and PMAL closed if Applicable)
Job Supervisor ________________________ Date _________
Signature

Information

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Foreign Material Exclusion (FME)


Data Sheet 2

High Risk FME Area Requirements

Pages:
70 to 70

Data Sheet 2, Standard Risk FME Area Requirements


NOTE:

Perform as much work possible outside the FME Area.


Refer to step 3.11 for FME requirements when working inside containment

Location: ____________________________________________________________________________________
Work Order Task /Procedure: ____________________________________________________________________
Job Description: _______________________________________________________________________________
Check each box as applicable:
Yes
No
Yes
No
FME brief at
Personnel Tool and Material Accountability
Job site T Alternate Location T
Log (PMAL)
(CR 04218086)

Secure/Redirect ventilation
Remove nonessential materials from area
Clean area prior to starting work
Clean overhead areas
Install Boundary around area
Post Signs
Control Access/Control Point
Monitor T
Self Monitor T
(Step 3.16.8a, b, c) FME Area Walkdown:
(Step 3.16.8c, d) PMAL Accuracy Review:

FME barriers/devices used


Check hoses for cleanliness prior to use
No Clear, unlabeled plastic
Examine Tools Prior to Entering FME Area
Remove personal items from pockets
Lanyard tools, badges, TLDs or other items
Remove all exposed jewelry. Rings under a glove
may be allowed per step 3.9.1

Yes T Waived T Shiftly T Other ________


Yes T

Shiftly T Other ________

(Step 3.16.8e) PMAL Reconciliation Review: Yes T Waived T Shiftly T Other ________
(Step 3.16.5e)All lifting/rigging equipment has been inspected for loose or missing parts prior to entering FMEA
____________________________________________
Inspection Performed by
(Step 3.16.5e)All lifting/rigging equipment has been inspected for loose or missing parts upon removal from the FMEA
____________________________________________
Inspection Performed by
Additional Requirements/Remarks: ______________________________________________________________
_____________________________________________________________________________________________
AEP Manager Approval: ____________________________________________________________________________
AEP Manager Review and approval [CR 04218086]: Print
Signature
Date
Change Approval: _________________________________________ / ________________
AEP Manager
Date
(Step 3.10.2a) As Found Breach Inspection Performed by: ____________________________ Date: __________
(Step 3.10.2b) Internal Part(s) Inspection

Performed by: ____________________________ Date: __________

(Step 3.10.2d) System has been inspected for foreign material and results recorded in the Additional Requirements/Remarks section.

[NRC Commitment 1222]


Job Supervisor_________________________ Date _________
Signature
Final conditions:
Tools, Materials, FME Area Postings and Boundaries, etc. removed (and PMAL closed if Applicable)
Job Supervisor ________________________ Date _________
Signature

Information

PMP-2220-001-001

Rev. 25

Page 71 of 90

Foreign Material Exclusion (FME)


Request for Transfer or Storage of Foreign Material to
SFP or Transfer Canal

Data Sheet 3

NOTE:

Pages:
71

Use N/A for steps that do not apply. Material stored in the Spent Fuel pool SHALL be
stored away from the suction and discharge line openings for Spent Fuel Pit Cooling.

1. Description of Foreign Material:


2. Dose Rate:
3. Requested storage location and reason:
4. Storage Period:
5. Chemistry review for chemical compatibility impact:
Material(s) in step 1 have been reviewed for chemical compatibility impact for the requested storage period
in step 4 and found to be:
T Acceptable

T Not acceptable for storage in the SFP or Transfer Canal.

Determined by:

Date

If the materials in step 1 have been found acceptable for storage, the requester is to initiate an Action
Request for removal of the materials prior to the end of the approved storage period listed in step 4.
AI #

Transfer Requested By:

Dept.

Date

6. Method of attaching or securing the material ___________________________________________________


___________________________________________________________________________________________
7. Transfer of requested materials to the SFP or Transfer Canal is:
T Approved

T Not Approved
Engineer

8.

Date

Materials transferred to the SFP or Transfer Canal were tagged appropriately, AND
Storage Location:
Transfer By:

Date:

RP to verify that appropriate actions and signatures are completed.


Verified by:

Date

10 Forward these data sheets or copies of, to Containment/SFP System Engineering and Reactor Engineering
for documentation.
Received By:

Date

PMP-2220-001-001

Information

Rev. 25

Page 72 of 90

Foreign Material Exclusion (FME)


Personnel Tool and Material Accountability Log
(PMAL)

Data Sheet 4

Pages:
72 - 72

Work Order Task

Location or Component

* Logging responsible individuals name indicates that the individual is a FME Ready Worker prior to entering FMEA (See Figure 4)

Date
In

Time In

Responsible
Individuals
Last Name

Monitor
Initials

OCA #

Material Description or Personnel Material


Exceptions
(Use to document exceptions to the FME Ready Worker
or any material/tools being taken into the FMEA,
otherwise mark N/A)

Location

Date
Out

**Codes: R-Removed from area I-Installed and will remain L-Found or dropped in the area and left E-Exchanged for a
like item in the area V-Verified in the FME area T-Transferred to another PMAL F- Found during initial breach and
removed from area
Date
Monitor Name (print)
Initials

Time
Out
Monitor
Initials

Badge #

(N/A, if Self -Monitoring)


Remarks:

Reviewed By:

Date:

Page

of

FME Coordinator/Supervisor/Monitor
Retain completed forms with the WOT until the job is closed out, then form can be discarded. Retained by the Job Supervisor or Site FME
Coordinator for large areas during outages.

(Note: An Equivalent Electronic PMAL form may be used. Reference section 3.16.5)

**
Code

Information

Rev. 25

PMP-2220-001-001

Page 73 of 90

Foreign Material Exclusion (FME)


Data Sheet 5

Page:
73

FME Area Inspections

Location
Unit #:

Outage:

Page:

of

Continued T Yes

T NO

Print Use Ink Enter time in 24 hour format


Walkdowns, Accuracy reviews and Reconciliation will be performed by the Site FME Coordinator, Job Supervisor or Monitor
IF the FME Area Walkdown and/or PMAL Reconcillation Review are waived per Date Sheet 1 or 2, THEN enter Waived in the
Performers Name box along with the Performers Name.

Shift
1
1
1
2
2
2
3
3
3

Time

Activity
FME Area Walkdown

Performers Name

OCA Badge #

PMAL Accuracy
Review
PMAL Reconciliation
Review
FME Area Walkdown
PMAL Accuracy
Review
PMAL Reconciliation
Review
FME Area Walkdown
PMAL Accuracy
Review
PMAL Reconciliation
Review

Remarks
Walkdown includes an evaluation of FME area housekeeping and FME barrier integrity.

Retain completed forms with the WOT until the job is closed out, then form can be discarded. Retained by the Job Supervisor or
Site FME Coordinator for large areas during outages.

(Note: An Equivalent or Electronic Walkdown, Review, and Reconciliation form may be used.)

Information

Rev. 25

PMP-2220-001-001

Page 74 of 90

Foreign Material Exclusion (FME)


Data Sheet 6

FME Project Plan

Pages:
74 - 78

*Guidance to determine if an FME Project Plan is required can be found on the last page of this form.*

Title:
Revision Number:

Prevention is our focus!


This plan addresses FME Controls for the listed FME Area/Project. The intent of this plan is
to supplement the guidance and requirements of PMP-2220-001-001, Foreign Material
Exclusion (FME), and is not intended to allow exception to the procedural requirements.

This plan must be covered in the Pre-job brief or project


meetings with all participants working in the area.
Approvals:
Title

Print

Sign

Date

Project/HIT Lead
Project Mgmt
Sponsor

FME Coordinator
Maintenance Mgr.

Approved FME Project Plan will be included in the Work Package and is required to be at the worksite
with the FME Monitor.

Information

PMP-2220-001-001

Rev. 25

Page 75 of 90

Foreign Material Exclusion (FME)


Data Sheet 6

FME Project Plan

Pages:
74 - 78

Complete each pre-defined area below:


1.

Work Order:

(This could contain multiple work orders.)

2.

Project or Evolution Title:

(Low Pressure Turbine Overhaul, Generator Work, etc)

3.

Planned Work Dates:

(This will help understand Potential FME Risks from other work in area and
to schedule FME support.)

4.

References:

(Other materials used to develop this plan, (Procedures, Previous plans,


lessons learned, Condition Reports, Industry Events, etc...))

5.

Work Scope:

(Briefly describe the work activities and the areas/actions that have the
potential to introduce foreign material.)

6.

General Requirements:

(Any requirements established for the entire work scope to mitigate FM


Intrusion (FMI) risk and prevent FME events. The requirements of this plan
do not supersede/change any plant procedures. The intent is to use this plan
in parallel with PMP-2220-001-001 and any station training that has been
established.)

7.

Special FME Control:

(Description of specialized FME controls developed specifically for the work


activity. Examples include specially designed FME covers or barriers,
addition of a buffer zone, specific work flow planning to minimize exposure to
foreign material intrusion, hold / verification points for FME accountability,
etc...)

8.

Housekeeping:

(Clean as you go controls to be established throughout the entire duration


of the major or complex activity.)

9.

FME Inspections/Closeout:

(List who has the responsibility of performing inspections for disassembly,


reassembly and final closeout inspections specifically for FM.)

10.

Contingency
Plan/Recovery Plan:

(Define equipment required to be available in the unlikely event that foreign


material is introduced. Identify personnel who can operate special retrieval
equipment such as robots etc)

11.

Responsibilities:

(Define who has ownership and their responsibilities specific to the FME
Plan.)

Information

PMP-2220-001-001

Rev. 25

Page 76 of 90

Foreign Material Exclusion (FME)


Data Sheet 6

FME Project Plan

Pages:
74 - 78

12.

Boundary and Access


Control:

(Describe the FME boundary and how it will be established. How access will be
controlled. Include area maps or sketches as applicable.)

13.

FME Monitor or
Oversight
Requirements:

(This should list what Monitor, Roving Monitor (if applicable), Job Supervisor
and Oversight your project will require and who is providing.)

14.

FME Devices Required:

(List all known devices needed and identify special needs materials to ensure
timely procurement. Ensure all required FME devices are staged prior to start
of project/task)

15.

Training Requirements:

(Description of FME training requirements for personnel performing the work


activity. Strong consideration shall be given to providing special training in the
FME plan for the work activity.) (FME Monitor/Worker Training) In addition,
when performing mock-ups FME behaviors and practices shall be implemented.

16.

Wire Wheel/Brush
Control:

(Wire Wheel and Brushes are only to be used if there is not a suitable substitute
for the job being performed. If a suitable alternative product is not available
then the necessary measures need to be put in place to ensure all debris is
controlled and a complete closeout inspection has been done. Those measures
need to be listed in the plan.)

17.

Debris Generating
Activity Controls:

(Description of the controls to prevent FMI during activities like welding, drilling
and machining.)

18.

Material Storage
Controls:

(Description of the controls to maintain material cleanliness and FME.)

19.

Rigging Material
Accountability:

(Description of the accountability of transient rigging material. (e.g. the


movement of overhead cranes above an established FME Areas)). All
lifting/rigging equipment will be inspected for loose or missing parts upon entry
into and removal from the FMEA.

20.

Other Specific
Requirements:

(Use for any additional controls or requirements that are being used to ensure
success but not covered by other sections. Examples may be contractors gang
boxes, special control measures during breaches or specific task scheduling
requirements.)

21.

Emergency Response:
In the event of an emergency FME controls are not to interfere with emergency responders. Job Supervisor and
Monitor will make an attempt to observe the evolution for evidence that integrity may have been lost. After the
response to the event is complete then the area will be inspected and verified free of foreign material. IF the area is
verified clean THEN continue with established logging requirements. IF unaccounted debris is identified THEN
carry out the procedural requirements of PMP-2220-001-001 for a loss of foreign material integrity.

Information

PMP-2220-001-001

Rev. 25

Page 77 of 90

Foreign Material Exclusion (FME)


Data Sheet 6

FME Project Plan

Pages:
74 - 78

Guidance to determine if a Foreign Material Exclusion Project Plan is required:


1.

1.

2.

3.

4.

5.

6.

Complete the following checklist to determine the need for an FME Project Plan. The
criterion comes from PMP-2220-001-001, Foreign Material Exclusion (FME).
Is the work to be performed in a continuously exposed High Risk FMEA like the Spent
Fuel Pool or Refueling Cavity, as shown on Figure 2 of PMP-2220-001-001?
Yes

FME Project Plan required.

No

Continue to next question.

Do existing procedures lack specific FME controls for each breach, opening or removal
evolution to be performed during the activity?
Yes

FME Project Plan required.

No

Continue to next question.

Is the work to be performed on equipment, such as control oil systems and close tolerance
equipment, extremely sensitive to foreign material intrusion?
Yes

Based on work scope, consider the use of a FME Project Plan or continue
to next question.

No

Continue to next question.

Does the work generate particulate where a visual closeout inspection would not ensure all
debris has been removed and the material would be difficult to retrieve?
Yes

Based on work scope, consider the use of a FME Project Plan or continue
to next question.

No

Continue to next question.

Does the work entail multiple work groups, large component replacement/overhaul, major
plant modification or multiple system breaches?
Yes

FME Project Plan required.

No

FME Project NOT required.

Uncertain

Continue to next question.

IF question 5 above is uncertain, THEN the FME Program Owner or Site Coordinator
determines the need for FME Project Plan.
Yes

FME Project Plan required.

No

FME Project Plan not required. Recommendation will be given to proceed


with FME in the WO package.

Information

PMP-2220-001-001

Rev. 25

Page 78 of 90

Foreign Material Exclusion (FME)


Data Sheet 6

FME Project Plan

Pages:
74 - 78

Instructions requirements for Foreign Material Exclusion Project Plan:


2.

If it is determined that a project plan is required, consider the following:


a. Develop plan as early as possible to allow for potential changes to the design and
planning for the work.
b. Plan should contain both engineered FME Controls as well as passive FME
Controls.
c. If contractors will be in charge of the work, consider an FME discussion with AEP
Project Manager FME Coordinator and Lead from contracting company.

3.

Complete the FME Project Plan Data Sheet 6. Each predefined section shall be included in
the plan. If a section does not apply, then you must provide justification for its exclusion in
the affected section.

4.

Review and approval of the plan must be done prior to work start. If the plan requires
revision it must go thru the same approval process unless otherwise determined by the FME
Program Owner or Site FME Coordinator.

5.

The approved FME Project Plan should be covered in the pre-job brief to ensure
understanding from all workers who will be performing functions in the area.

6.

A copy of the approved FME Plan will be at the FME Area access for review as required.

Information

PMP-2220-001-001

Rev. 25

Page 79 of 90

Foreign Material Exclusion (FME)


Data Sheet 7

Purpose:

Authorization for Waiver of Foreign Material


Exclusion (FME) Qualification

Pages:
79 - 79

Document the approval of a waiver for the site FME Qualification per step 3.16.2 of
PMP-2220-001-001, Foreign Material Exclusion (FME) procedure. Personnel
granted this waiver will be allowed entry into FME Areas without completing the site
FME Qualification per this waiver and if meeting the stated conditions.

Conditions: 1 Waiver granted by FME Program Owner or Coordinator as documented on this


form.

2 Must be briefed by the FME Qualified Site Host/Sponsor on the FME


Requirements in the areas that they will be entering.

3 Must be under control of the FME Qualified Host/Sponsor at all times.


4 Must adhere to station procedures and policies and follow the direction of the
Host/Sponsor at all times.

5 Must sign that they acknowledge and accept these conditions for waiver.
6 Host/Sponsor signs this form accepting the responsibility to brief and control the

waived visitor and accepts accountability for their actions and for maintaining the
requirements of the FME Area and the FME Procedure.

Applicant:
Name

Affiliation/Company

Name

Department

Sponsor:
Location(s)/Activity: (Provide description of location and planned activity)

I agree to and understand the conditions stated above. I understand that compliance with these
conditions is the basis for this waiver approval.
Applicant (Sign/Date)

Sponsor (Sign/Date)

Waiver of the Site FME Qualification approved by:


Print Name

Sign/ Date

This waiver will expire seven days after approval unless an extension is granted.
Extension
approved:
Title / Sign / Date
Forward a copy of the signed form to Site FME Coordinator. (PDF is preferred)

Title

Expires

Information

Rev. 25

PMP-2220-001-001

Page 80 of 90

Foreign Material Exclusion (FME)


Figure 1

No

Implement Housekeeping
controls per PMP-2220-HSK-001
and good FME awareness

FME Risk Assessment Chart

Pages:
80

Will the system/equip.


boundary be breached?

Yes

Does an established area


level exist? (See Fig 2)

Yes

Use approved FME Level.


Standard/High

No

Is it possible to
inspect all areas of the
breach prior to closeout?

No

Implement High Risk FMEA


Controls. (Data Sheet 2)

Yes

If FM is introduced
into the system/equip, can it
be easily located and
immediately
retrieved?

Yes

No

Implement Standard Risk FMEA


Controls. (Data Sheet 1)

NOTE: Activities considered normal operations (vent, drain, tank sounding, etc) are exempt from the controls in this procedure,
step 3.2.3.a.1. However, good housekeeping and FME awareness should be utilized to prevent FM introduction to plant systems
and components.

Information

PMP-2220-001-001

Rev. 25

Page 81 of 90

Foreign Material Exclusion (FME)


Figure 2

List of Area Levels

Standard Risk Areas

Page:
81 - 83

Location of Area Requirement/Posting

Upper Containment: All areas except Ice


Condenser

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

Lower Containment - Annulus and rooms


above (Accumulators, regen, HV-CLV and
so forth)

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

Lower Containment Inside the Cranewall

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

Ice Condenser (Upper Plenum) With


intermediate deck doors installed and closed.

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

Ice Condenser (Lower Plenum) At all


times

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

New Fuel Vault

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

Screen house any boundary breaches in the


Forebay west of the screens. [CR 05257035]

Posting begins at the job site.

Outage Only: East of the screens with diver


safety net installed.

Posting begins at the job site.

Outage Only: Circ water pump ledge/cubicle


below grating (with diver safety net
installed)

Posting begins at the job site.

Outage Only: circ water inlet tunnel

Posting begins at the job site.

Main Condenser when tubes are covered

Posting begins at the job site.

Load Center and Breaker Cubicles. Unless


being opened for visual inspection or minor
maintenance such as replacing fuses.

Posting Begins at the Job Site.


Program Owner recommendation to ease
unnecessary burden for minor maintenance.

Information

PMP-2220-001-001

Rev. 25

Page 82 of 90

Foreign Material Exclusion (FME)


Figure 2

List of Area Levels

Page:
81 - 83

High Risk Areas

Location of Area Requirement/Posting

Refueling Reactor Cavity when the Reactor


Head is Removed.

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

Ice Condenser (Upper Plenum) With


intermediate deck doors removed or opened.

Radiation Protection Access Control (RPAC)


and/or 609 Access Control

Work on the Reactor Coolant Pump Seal


Package

Radiation Protection Access Control (RPAC)


and/or 609 Access Control and/or at the job
site

Spent Fuel Pool or Transfer Canal

Radiation Protection Access Control (RPAC)


and/or 609 Access Control and/or at job site

New Fuel Vault with new fuel inside

Access points to the New Fuel Vault, Door


and at the job site

Containment Recirc. sump

Posting begins at the job site.

ESW Pumps, Circulating Water Pumps,


Traveling Screen or any boundary breaches
in the Forebays east of the screens.

Posting begins at the job site.

[CR 02175037]

Main Condenser until tubes are covered.

Posting begins at the job site

EHC System (breaches)

Posting begins at the job site

Information

PMP-2220-001-001

Rev. 25

Page 83 of 90

Foreign Material Exclusion (FME)


Figure 2

List of Area Levels

Equipment and piping that form or have


direct
connection to the primary system OR to
systems where heightened
cleanliness controls are required to prevent
the failure of systems,
structures, and components required for
plant operation including:
a. Internal equipment and piping surfaces in
the following systems:
Reactor Coolant System
Pressurizer
Emergency Core Cooling Systems (CCP,
RWST, etc.)
Chemical and Volume Control System
Residual Heat Removal System
Safety Injection System
Spent Fuel Pit System (does not include
Spent Fuel Pit)
Emergency Diesel Generator (EDG)
maintenance, disassembly and re-assembly
activities.
The Emergency Diesel Generator fuel oil
system between the inlet of the filter through
the High Pressure Fuel Injection Pumps.

Posting begins at the job site

Posting begins at the job site

[CR 04117069 and 04336020]

Crankcase Maintenance will be High Risk


until the oil drain line is plugged/covered or
the sump is drained. May be down graded if
conditions are met.
Internal equipment and piping surfaces in the
following systems and equipment:
Feedwater and auxiliary feedwater
systems after the pump suction
strainers
Steam generators (secondary side).

Posting begins at the job site

Page:
81 - 83

Information

PMP-2220-001-001

Rev. 25

Page 84 of 90

Foreign Material Exclusion (FME)


Figure 3

NOTE:

1.1

Duties and Responsibilities

Pages:
84 - 89

The following information is covered during the pre-job briefings for all High
Risk work and work requiring a PMAL.

FME Worker Responsibilities


1.1.1

Possesses a thorough understanding of FME requirements and adheres to


FME fundamentals.

1.1.2

Review FME requirements during walkdown to ensure adequate


preventative measures are included.

1.1.3

Assists establishing, maintaining, and restoring FME controls.

1.1.4

Unpacks parts, tools, material, etc. prior to entering the FMEA, when
possible.

1.1.5

Obtains resolution of FME questions or concerns from FME


Coordinator/Supervisor prior to commencing work in an FMEA.

1.1.6

Notifies appropriate supervision of activities that threaten FME integrity,


including activities in surrounding and overhead areas that may result in
foreign material entering an open system or component.

1.1.7

Ensures FME discrepancies are reported to responsible Supervisor.

1.1.8

Ensures the designated FME Monitors are aware of parts, tools, and
materials taken into and removed from the FME High Risk areas and Peer
Checks the FME Monitor for PMAL accuracy for the entry and exit.

1.1.9

Verifies FME Qualification utilizing the Plant Qualification Matrix prior to


performing work in a FMEA.

1.1.10

Encouraged to do the maximum for FME not minimum.

1.1.11

Ensure you are an FME Ready Worker (See Figure 4, The FME Ready
Worker) prior to entering and FME Area.

Information

PMP-2220-001-001

Rev. 25

Page 85 of 90

Foreign Material Exclusion (FME)


Figure 3
1.2

Duties and Responsibilities

Pages:
84 - 89

Job Supervisor Responsibilities


1.2.1

Verifies FME qualification for workers is current prior to assigning work in


an FMEA.

1.2.2

Provides oversight and coaching to ensure FME controls and practices are
implemented for activities within their area of responsibility.

Must monitor changing job site conditions to ensure FME controls


applied at the start of the job are still adequate.

1.2.3

Develops FME Plans when required.

1.2.4

Ensures FME discrepancies are reported to the FME Coordinator.

1.2.5

Provides feedback to work planning regarding FME problems or effective


practices.

1.2.6

Reviews work package FME requirements to ensure they are appropriate


for the task and local conditions at the work site.

1.2.7

Identifies additional FME requirements, such as flushing.

1.2.8

Ensures FME controls are addressed at the job brief.

1.2.9

Ensures appropriate FME boundaries and postings are established by


conducting periodic work site observations.

1.2.10

Ensures the FMEA has a controlled entry point(s) when establishing a


FME boundary.

1.2.11

Ensures a Post-Job Review is completed, as needed, upon completion of


work in an FMEA.

1.2.12

Ensures Actions are initiated, if FME requirements have not been met.

1.2.13

Ensures Data Sheet 4, Personnel Tool and Material Accountability Log


(PMAL), is reconciled immediately upon completion of work and at least
once per shift or, as directed, to ensure that all tools, parts, FME Devices,
and materials have been properly removed and/or accounted for, and
documents reconciliation in the appropriate section of the Data Sheet 5,
FME Area Inspections.

Information

PMP-2220-001-001

Rev. 25

Page 86 of 90

Foreign Material Exclusion (FME)


Figure 3
1.3

Duties and Responsibilities

Pages:
84 - 89

FME Monitor Responsibilities


1.3.1

FME Monitors are required when an independent FME Monitor is specified


in an FME Project Plan or when identified as necessary by the Supervisor.

1.3.2

Understands and ensures requirements for the FMEA are implemented.

1.3.3

Verifies FME qualification is current prior to performing FME Monitor


tasks.

1.3.4

IF performing as an Independent FME Monitor, THEN verify that you


have attended FME Monitor Training.

1.3.5

Inspects all personnel and material for conditions that could result in a loss
of FME controls prior to authorizing entry into an FME High Risk area or
FME Standard Risk area.

Ensure that the person entering the FME Area has Work Supervisor
authorization to enter the FME Area and the person has been briefed on
required FME controls.

Control all personal items before entering an FME AREA as follows:

Personnel entering the Standard Risk FME Area shall: (See Figure 4,
The FME Ready Worker)

Remove or secure all personal and items such as tie clasps, coins,
keys, knives, jewelry, watches, etc. Tape all pockets containing
items not removed.

Secure eyeglasses, hearing protection, badges, or dosimetry worn


outside clothing using lanyards, Velcro or other suitable manner.

IF Anti-Cs are used to contain items, THEN tape leg openings on


Anti-Cs unless leg opening has elastic.

Information

PMP-2220-001-001

Rev. 25

Page 87 of 90

Foreign Material Exclusion (FME)


Figure 3

Duties and Responsibilities

Pages:
84 - 89

Personnel entering the High Risk FME Area shall: (See Figure 4,
The FME Ready Worker)

Remove all personal items, (i.e. jewelry, change, wallets, etc.)


or restrained/controlled as noted below from person and
pockets.

IF item cannot be removed, THEN the item must be


contained (worn under a glove, taped, etc.) and logged
into the area.

Any required medications must be contained, secured to


the person (per Job Supervisor and in a manner that does
not restrict use) and logged into the area.

Secure eyeglasses, hearing protection, hard hats, badges, or


dosimetry worn outside clothing using lanyards, chin straps,
Velcro or other suitable manner.

IF Anti-Cs are used to contain items, THEN tape leg


openings on Anti-Cs unless leg opening has elastic.

Ensure that hand tools have lanyards when required.

Ensure that all items, including consumables, are logged on Data


Sheet 4, Personnel Tool and Material Accountability Log (PMAL).
Ensure PMAL is complete, accurate and legible. (items are accurately
described on PMAL)

1.3.6

Authorizes personnel entry into FME High Risk area or FME Standard
Risk area when a FME Monitor is being utilized.

1.3.7

Provides guidance to personnel who are not familiar with the job specific
FMEA controls and have not attended a pre-job brief for entry into the
FMEA.

1.3.8

Logs all tools and material on Data Sheet 4, Personnel Tool and Material
Accountability Log (PMAL).

1.3.9

Monitors work activities, exercises Stop Work authority and notifies the
FME Coordinator and Work Group Supervisor of any unresolved problems.

Information

PMP-2220-001-001

Rev. 25

Page 88 of 90

Foreign Material Exclusion (FME)


Figure 3
1.3.10

1.3.11

1.3.12

Duties and Responsibilities

Pages:
84 - 89

Performs periodic review of the FMEA to ensure standards are being met.

Randomly monitor personnel inside the FME Area to ensure adherence


to FME requirements and controls, such as use of lanyards on tools.

Check items inside the FME Area to ensure Data Sheet 4, Personnel
Tool and Material Accountability Log (PMAL) is accurate at least once
per shift.

Reconciles the Data Sheet 4, Personnel Tool and Material Accountability


Log (PMAL), immediately upon completion of work and at least once per
shift or, as directed, to ensure that all tools, parts, FME Devices, and
materials have been properly removed and/or accounted for, and documents
reconciliation in the appropriate section of the Data Sheet 5, FME Area
Inspections.
a.

Data Sheet 4, Personnel Tool and Material Accountability Log (PMAL)


sheets containing 2 or less open entries may be closed out by
transferring the information onto a new log sheet.

Transfer information from item being transferred onto new page.

Description and Quantity

Original date and time in

Enter old page and line number of transferred item in the remarks
section of the new page.

Enter transferred in the date/time out field on the Data Sheet 4


page being closed, and print Name and Badge number.

Enter note in the remarks section of the Data Sheet 4 page being closed
stating new page and line number of transferred item.

When personnel exit the FME Area

Ensure that tools/equipment have no missing parts (such as bolts or


screws) that were not previously identified prior to entry.

Ensure that items have been properly logged out of the Data Sheet 4.

Information

PMP-2220-001-001

Rev. 25

Page 89 of 90

Foreign Material Exclusion (FME)


Figure 3

Duties and Responsibilities

1.3.13

Conducts a turnover brief with the oncoming FME Monitor.

1.3.14

At the completion of the work/activity

Pages:
84 - 89

Ensure that all items are accounted for by reviewing the Data
Sheet 4 and FME Area walk down.

Ensure that the Supervisor Review of the Data Sheet 4 is


completed and documented on the backside of the Data Sheet 4.

Information

PMP-2220-001-001

Rev. 25

Page 90 of 90

Foreign Material Exclusion (FME)


Figure 4

The FME Ready Worker

The FME Ready Worker

Pages:
90 - 90

REVISION SUMMARY
Procedure No.: PMP-2220-001-001
Title: Foreign Material Exclusion (FME)

Rev. No.:

25

Alteration
Section 2 added definition of Roving Monitor

Justification
Recommendation from Program Owner

3.1.1 added the word monitors

Recommendation from Program Owner

3.2.1b 3rd bullet added note stating Tape is


not a means of FME protection, however tape
can be used to secure personal items or FME
covers if necessary.

Recommendation from Program Owner


GT 2013-1470-1

3.2.1f removed the words Consider and

Recommendation from Program Owner

3.2.1g - Changed at completion of the job. To as


required.

Recommendation from Program Owner

3.3.4h. added new bullet Ensure you are an

Recommendation from Program Owner

FME Ready Worker (See Figure 4, The


FME Ready Worker) prior to entering and
FME Area.
3.4.2e, 3.10.2c & 3.16.5b added Note
reminding user tape is not to be used as an
internal FME barrier

Recommendation from Program Owner

3.9.1 added 2 new bullets for control of tool


cards

Recommendation from Program Owner

3.14.1b added new step for the Foreign

Incorporating a reference to the new Foreign


Material Intrusion Recovery Plan.
GT 2011-7342 - 18

Material Recovery Intrusion Plan Template


3.16.3a Added new code F = Found
Also removed M code from table
( no marginal marking)

Recommendation from Program Owner


GT 2013-1470-1

3.16.5f.1. added the date to the step

Recommendation from Program Owner

3.16.5f.7.a) (Rev 24) deleted step since the M


code is no longer used ( no marginal marking)

Recommendation from Program Owner


GT 2013-1470-1

3.16.5h. added new section for the Guidelines


for use of duct tape

Recommendation from Program Owner

3.16.6 added new section for logging


personnel

Recommendation from Program Owner

Office Information for Form Tracking Only - Not Part of Form


This is a free-form as called out in PMP-2010-PRC-002, Procedure Alteration, Review, and
Approval.

Page 1 of 4

REVISION SUMMARY
Procedure No.: PMP-2220-001-001
Title: Foreign Material Exclusion (FME)
Alteration
3.16.6c added 2 bullets describing how TLDs
and Electronic Dosimetry (ED) are secured

Rev. No.:

25

Justification
Recommendation from Program Owner

prior to entering an FME area


3.16.7a.2 added hearing protection and
removed buttons

Recommendation from Program Owner

3.16.7d.1 added however personnel transiting a


FMEA shall adhere to all other FME Area
Requirements.

Recommendation from Program Owner

3.16.8b.1 & 2 added or as noted on Data Sheet


1, Standard Risk FME Area Requirements or
Data Sheet 2, High Risk FME Area
Requirements

Recommendation from Program Owner

5.2.1pp. added reference to OE/CNPOE: 13-

Editorial correction criteria n

01358, Outage Extension Due To Loss Of


FME Controls
Attachment 1 steps 1.1.4e.3 & 1.1.4e.4 bullets
added note stating Tape is not a means of FME
protection, however tape can be used to secure
personal items or FME covers if necessary.

Recommendation from Program Owner


GT 2013-1470-1

Attachment 1 steps 1.1.4e.3 - 2 bullets - added


hearing protection and removed buttons

Recommendation from Program Owner

Attachment 3 step 1.2.1 bullets added note


stating Tape is not a means of FME protection,
however tape can be used to secure personal
items or FME covers if necessary.

Recommendation from Program Owner


GT 2013-1470-1

Data Sheet 1 revised wording from Avoid


clear, unlabeled plastic to No Clear, unlabeled
plastic ( no marginal marking)

Recommendation from Program Owner


GT 2013-1470-1

Data Sheet 2 revised wording from Avoid


clear, unlabeled plastic to No Clear, unlabeled
plastic ( no marginal marking)

Recommendation from Program Owner


GT 2013-1470-1

Data Sheet 2 added sign offs for inspections of


all lifting/rigging equipment for loose or missing
parts upon entry into and removal from the
FMEA

OE/CNPOE: 13-01358, Outage Extension Due


To Loss Of FME Controls
GT 2013-6287-1

Office Information for Form Tracking Only - Not Part of Form


This is a free-form as called out in PMP-2010-PRC-002, Procedure Alteration, Review, and
Approval.

Page 2 of 4

REVISION SUMMARY
Procedure No.: PMP-2220-001-001
Title: Foreign Material Exclusion (FME)

Rev. No.:

25

Alteration
Data Sheet 4 added Date In and Date Out
Columns; Removed M-Moved code; Added FFound code
Added Date Column next to Monitors Name
( no marginal marking)

Justification
Recommendation from Program Owner
GT 2013-1470-1

Data Sheet 6 number 13 added Roving Monitor


(if applicable)

Recommendation from Program Owner

Data Sheet 6 number 15 added In addition,


when performing mock-ups FME behaviors and
practices shall be implemented.

Recommendation from Program Owner

Data Sheet 6 number 19 added All


lifting/rigging equipment will be inspected for
loose or missing parts upon entry into and
removal from the FMEA

OE/CNPOE: 13-01358, Outage Extension Due


To Loss Of FME Controls

Figure 3 added new step 1.1.11 Ensure you

Recommendation from Program Owner

GT 2013-6287-1

are an FME Ready Worker (See Figure 4,


The FME Ready Worker) prior to entering
and FME Area.
step 1.2.10 added a controlled entry point(s)
Step 1.3.5 - added hearing protection and
removed buttons
Figure 4 several editorial changes (no marginal
markings)

Mark the figure understandable to the user

These changes involve administrative procedures governing the conduct of facility operations. There
are no systems, structures or components affected by this procedure or its revision. The governing
process covers all aspects of these proposed activities therefore a 50.59 review is NOT required.

Office Information for Form Tracking Only - Not Part of Form


This is a free-form as called out in PMP-2010-PRC-002, Procedure Alteration, Review, and
Approval.

Page 3 of 4

REVISION SUMMARY
Procedure No.: PMP-2220-001-001
Title: Foreign Material Exclusion (FME)

Rev. No.:

25

IMPLEMENTATION PLAN
Summary of Change
See Rev Summary
Reason for Change
See Rev Summary
Implementation Schedule
Approved and effective after 8/18/2011
Training Needs
None
Expiration Date
N/A
Required Basis Documents Update
None
Related Processes and Procedures
None
Transition Plan
Previous revisions of Procedure Forms may be used in accordance with
PMP-2010-PRC-003 requirements.
Related Equipment Modifications
None
Communication Plan
Change to be communicated by program owner to plant.
Special Tools, Aids, Permits, Etc.
None
Related Action Requests
GT 2013-1470-1, GT 2011-7342 18, GT 2013-6287-1

Office Information for Form Tracking Only - Not Part of Form


This is a free-form as called out in PMP-2010-PRC-002, Procedure Alteration, Review, and
Approval.

Page 4 of 4

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