DOE G 433.1-1A, Nuclear Facility Maintenance Management Program Guide for Use with DOE O 433.1B

DOE G 433.1-1A 9-12-11 Nuclear Facility Maintenance Management Program Guide for Use with DOE O 433.1B U.S. Department of Energy Washington, D.C. 20585 NOT MEASUREMENT SENSITIVE DOE G 433.1-1A i 9-12-11 FOREWORD This Implementation Guide is approved for use by all Department of Energy (DOE) and National Nuclear Security Administration (NNSA) organizations and contractors. Throughout this Guide the use of the term DOE includes DOE and NNSA. DOE Guides are part of the DOE Directives System and are issued, as described in DOE Order (O) 251.1C, Departmental Directives Program, to provide acceptable, but not mandatory means for complying with requirements of an Order or Rule. Alternate methods that satisfy the requirements of an order are also acceptable. DOE O 251.1C requires justification of any implementation selected ―to ensure that an adequate level of safety commensurate with the identified hazards is achieved.‖ DOE Implementation Guides cannot be made mandatory by reference in an Order, Notice, or a Technical Standard. This Guide is recognized by DOE as providing acceptable approaches for implementing requirements for Nuclear Maintenance Management Programs (NMMPs) set forth in DOE O 433.1B, Maintenance Management Program for DOE Nuclear Facilities. As such, application of this Guide should facilitate the efficient use of time and resources in developing NMMPs, and result in the favorable review and approval of programs, processes, and Nuclear Maintenance Management Program Description Documentation (NMMP-DD) for implementing and demonstrating compliance with DOE O 433.1B requirements. DOE review and approval authorities should be familiar with the implementation guidance contained in guides when reviewing and approving programs for implementing and demonstrating compliance with requirements of an Order or Rule. Accordingly, this Guide is appropriate for use by review and approval authorities as a benchmark for determining if alternate methods used in whole or part are justified and demonstrate compliance with DOE O 433.1B requirements for NMMPs. Beneficial comments (recommendations, additions, deletions, and any pertinent data) that may improve this document should be sent to: Ashley Ruocco HS-32 U.S. Department of Energy Germantown, Maryland 20874 Phone: 301-903-7010 Email: Ashley.Ruocco@hq.doe.gov ii DOE G 433.1-1A 9-12-11 TABLE OF CONTENTS I. INTRODUCTION .................................................................................................................... 1 A. PURPOSE ............................................................................................................................ 1 B. APPLICABILITY ................................................................................................................ 1 C. OVERVIEW OF THIS GUIDE ........................................................................................... 2 II. NUCLEAR MAINTENANCE MANAGEMENT GENERAL REQUIREMENTS ................ 4 A. NUCLEAR MAINTENANCE MANAGEMENT PROGRAM ...................................... 4 B. NUCLEAR MAINTENANCE MANAGEMENT PROGRAM DESCRIPTION DOCUMENTATION ...................................................................................................... 4 C. APPLICATION OF GRADED APPROACH ................................................................. 5 D. NMMP CHANGES ......................................................................................................... 6

III. NUCLEAR MAINTENANCE MANAGEMENT PROGRAM ELEMENTS ......................... 7 A. INTEGRATION WITH REGULATIONS AND DOE ORDERS AND MANUALS (AND THEIR CRDs) ....................................................................................................... 7 B. MAINTENANCE ORGANIZATION AND ADMINISTRATION ............................... 9 C. MASTER EQUIPMENT LIST ...................................................................................... 18 D. PLANNING, SCHEDULING, AND COORDINATION OF MAINTENANCE ......... 20 E. TYPES OF MAINTENANCE ....................................................................................... 51 F. MAINTENANCE PROCEDURES ............................................................................... 61 G. TRAINING AND QUALIFICATION .......................................................................... 65 H. CONFIGURATION MANAGEMENT ......................................................................... 71 I. PROCUREMENT .......................................................................................................... 73 J. MAINTENANCE TOOL AND EQUIPMENT CONTROL ......................................... 79 K. SUSPECT AND COUNTERFEIT ITEMS ................................................................... 82 L. MAINTENANCE HISTORY ........................................................................................ 84 M. AGING DEGRADATION AND TECHNICAL ........................................................... 89 N. SEASONAL FACILITY PRESERVATION ................................................................ 91 O. PERFORMANCE MEASURES .................................................................................... 97 P. FACILITY CONDITION INSPECTION .................................................................... 101 Q. POST MAINTENANCE TESTING ............................................................................ 108 DOE G 433.1-1A iii 9-12-11 APPENDIX A: NMMP-DD OPTIONS AND EXAMPLES .................................................... 114 APPENDIX B: NMMP ASSESSMENT GUIDANCE ............................................................. 123 APPENDIX C: DEFINITIONS, ACRONYMS, AND REFERENCES .................................... 126 DOE G 433.1-1A 1 9-12-11 I. INTRODUCTION A. PURPOSE This implementation Guide has been prepared to assist Maintenance Managers in understanding and meeting the requirements of U.S. Department of Energy Order (DOE O) 433.1B, Maintenance Management Program for DOE Nuclear Facilities. The Guide also helps DOE employees in the approval and oversight of DOE nuclear maintenance management programs (NMMPs). It is especially useful for review and approval authorities as a benchmark for determining if alternate methods used are justified and demonstrate compliance with DOE O 433.1B requirements. DOE O 433.1B requires DOE facility operators to develop and implement an NMMP for Hazard Category 1, 2, and 3 nuclear facilities under DOE cognizance. An acceptable NMMP consists of processes to ensure that structures, systems, and components (SSCs) are capable of fulfilling their intended function as identified in the facility safety basis. This Guide provides guidance for implementing program NMMP elements in a manner that would be acceptable to DOE for meeting the requirements of the Order. To further clarify the scope of the Order, the term “Structures, Systems, and Components

(SSCs) that are part of the safety basis” includes ―Safety-Class and Safety-Significant SSCs; other systems that perform important defense-in-depth functions; and equipment relied on for the safe operation and safe shutdown of the nuclear facility, and for maintaining the facility in a safe shutdown condition as documented in the safety basis (e.g., DSA). Support systems to Safety SSCs that are required for the safety functions are also included.‖ . This Guide may also be used for development of the maintenance program required in DOE O 430.1B, Real Property Asset Management, for facilities not covered by DOE O 433.1B. The requirements of DOE O 430.1B also apply to nuclear facilities. The NMMP may serve as the single program to satisfy the requirements of both Orders. The Nuclear Maintenance Management Program Description Documentation (NMMP-DD) can be utilized to document the implementation of maintenance requirements in DOE O 430.1B and the implementation of maintenance for SSCs that are not part of the safety basis of a nuclear facility. The Order requires both DOE and contractor personnel to perform assessments. Guidance is provided for the various types of assessments and associated scopes. This guidance may also be used for contractor assurance systems. The approved NMMP-DD provides a description of the locally implemented maintenance program and should be the basis for assessing program execution. Examples in this Guide are for illustration, to aid in understanding the guidelines. The examples should not be construed as the only methods for meeting the intent of the Order. B. APPLICABILITY This guidance applies to all DOE elements involved in the maintenance of DOE hazard category 1, 2, and 3 nuclear facilities, and automatically applies to DOE elements created after it is issued. This includes both Government-owned and Government-operated (GOGO) and Government- owned and Contractor-operated (GOCO) nuclear facilities. The applicability of this Guide is the same as the applicability of DOE O 433.1B. 2 DOE G 433.1-1A 9-12-11 This Guide provides acceptable, but not mandatory methods for meeting the Order's requirements. Alternative methods that satisfy the Order‘s requirements are also acceptable. (DOE O 251.1C par. 5.d.(1)) However, any implementation selected must be justified to ensure achievement of an adequate level of safety (commensurate with the hazards). C. OVERVIEW OF THIS GUIDE The remainder of this Guide is divided into two sections (Section II and Section III) to provide guidance on general requirements and maintenance program elements of the Order. These sections are followed by three Appendices. Section II of this Guide covers the general requirements and includes guidance for the Application of Graded Approach, one especially important element of the General Requirements of DOE O 433.1B. General requirements are also covered within Section I of this Guide. Section III provides guidance on each of the 17 maintenance program elements, which are identified as Specific Requirements in Attachment 2 of the Order. The topics are organized and numbered in the Guide following the same structure outlined in the Order: A. Integration with Regulations and DOE Orders and Manuals (and their CRDs); B. Maintenance Organization and Administration; C. Master Equipment List; D. Planning, Scheduling, and Coordination of Maintenance; E. Types of Maintenance; F. Maintenance Procedures;

G. Training and Qualification; H. Configuration Management; I. Procurement; J. Maintenance Tool and Equipment Control; K. Suspect and Counterfeit Items; L. Maintenance History; M. Aging Degradation and Technical Obsolescence; N. Seasonal Facility Preservation; O. Performance Measures; P. Facility Condition Inspection; Q. Post Maintenance Testing. Each Sub-Section for the 17 maintenance program elements includes:  Order Implementation Guidance: a statement of the Order requirements followed by guidance for the items that the NMMP should address.  Additional Background/Guidance Supporting Implementation and Procedure Development: more detailed guidance useful in supporting development of the NMMP.  Some sections also include example forms and checklists. DOE G 433.1-1A 3 9-12-11 In addition, the Guide includes three appendices: Appendix A: NMMP-DD Options and Examples Appendix B: NMMP Assessment Guidance Appendix C: Definitions, Acronyms, and References 4 DOE G 433.1-1A 9-12-11 II. NUCLEAR MAINTENANCE MANAGEMENT GENERAL REQUIREMENTS This section provides implementation guidance regarding the NMMP and the NMMP-DD, application of the graded approach, and two additional elements of the general requirements part of DOE O 433.1B (i.e., incorporation in the Documented Safety Analysis (DSA) and review of the NMMP as part of the Unreviewed Safety Question (USQ) process). Not all general requirements of the Order are explained in this Guide, as some general requirements are self explanatory in the Order and do not need further guidance. Subsection II.A addresses the NMMP; subsection II.B addresses the NMMP-DD; subsection II.C addresses the application of the graded approach‘ and subsection II.D addresses NMMP changes. A. NUCLEAR MAINTENANCE MANAGEMENT PROGRAM DOE O 433.1B requires DOE facility operators develop and implement an NMMP for Hazard Category 1, 2, and 3 nuclear facilities under DOE cognizance. In accordance with DOE O 433.1B, the NMMP must describe the safety management program for maintenance and the reliable performance of structures, systems and components (SSCs) that are part of the safety basis at hazard category 1, 2 and 3 DOE nuclear facilities. In accordance with DOE O 433.1B, the NMMP must clearly address the 17 elements of maintenance identified in Section 2 of Attachment 2 of DOE O 433.1B (Section III of this Guide provides implementation guidance on these). Beyond the administrative requirements regarding (1) the scope of and areas to be addressed by the NMPP and (2) the timeframes for implementation and review, the Order provides broad latitude for operating organizations in defining their NMMP to best suit their mission and organizational environment. B. NUCLEAR MAINTENANCE MANAGEMENT PROGRAM DESCRIPTION DOCUMENTATION DOE O 433.1B requires NMMP description documentation be, at a minimum, an applicability matrix or a combination of multiple documents that covers: (1) Correlation of the requirements to the applicable facilities; (2) Correlation of the implementing documents (i.e., procedures, work instructions, etc.) to the specific requirements; and (3) Documentation of the basis for applying a graded approach, if applicable. DOE O 433.1B requires each organization to develop a NMMP-DD that addresses the topics listed in the Order and that the NMMP-DD be submitted to DOE for review and approval. Re- submission for review and approval is required at least every three years.

Sites with more than one nuclear facility and/or contractor may develop a consolidated NMMP that can accommodate the facility differences without losing effectiveness. The Order states that the NMMP-DD can be anything from ―a manual‖ to ―a combination of multiple documents,‖ to ―an applicability matrix, as a minimum.‖ The Maintenance Implementation Plan (MIP) that was required by the previous revision of DOE O 433 served a similar purpose to the NMMP-DD. In practice, MIPs varied from a very thick manual with much detail to an applicability matrix that simply lists the procedure documents associated with DOE G 433.1-1A 5 9-12-11 each element of maintenance. Most MIPs included an applicability matrix; some MIPs also included a description of the overall maintenance program. MIPs can be converted into NMMP-DD and compliance with the current Order can be achieved with a NMMP-DD that is only an applicability matrix so long as it identifies the document(s) that document: (1) the basis for applying the graded approach and (2) the implemented (or planned) site-specific methods for satisfying the Order's requirements for each of the 17 elements of maintenance (based on a graded approach, if applicable). An ―applicability matrix‖, as used in context of this Guide, is a table listing a set of applicable procedures and other associated documents and sometimes listing the applicable paragraph numbers of sections of the documents. An applicability matrix does not contain any narratives or explanations of the listed documents. It is recommended that the applicability matrix include/list a single document that provides an overall summary of the NMMP. This summary should be written at a level that comprehensively describes the big picture of the implemented (or planned) site-specific methods for satisfying the Order's requirements for each of the 17 elements of maintenance (based on a graded approach, if applicable). An appropriate title for this document is ―NMMP Summary-Level Description‖ or ―NMMP Summary‖. A recommended practice is for this NMMP Summary to contain an assessment of strengths and weaknesses along with a listing and explanation of the planned continuous improvements (if any). C. APPLICATION OF GRADED APPROACH Attachment 2, paragraph 1.e. (3) of DOE O 433.1B requires federal and contractor organizations to submit NMMP-DD that provides ―Documentation of the basis for applying a graded approach, if applicable.‖ The graded approach methodology ensures the level of rigor for implementing the Order‘s 17 maintenance management elements is based on their importance/significance and associated consequences. Graded approach, as defined in 10 Code of Federal Regulation (CFR) Part 830, Nuclear Safety Management, means the process of ensuring that the level of analysis, documentation, and actions used to comply with a requirement are commensurate with: a. The safety, safeguards, and security function provided; b. The magnitude of any hazard involved; c. The life-cycle stage of a facility; d. Programmatic mission of a facility; e. Particular characteristics of a facility; f. The relative importance of radiological and non-radiological hazards; and g. Any other relevant factor. DOE contractors should use knowledge of their nuclear facilities and sound engineering judgment to determine the depth of detail and magnitude of resources required for implementing each of the Order's 17 maintenance management elements.

The method of and basis for applying the graded approach should be documented and address: 6 DOE G 433.1-1A 9-12-11  How the graded approach defined in 10 CFR Part 830 was used;  Where it was applied (e.g., for a specific SSC, or a group of SSCs); and  Why it was used and how it ensures an adequate level of safety for this SSC (or group of SSCs). Appendix A provides additional guidance for applying the graded approach. D. NMMP Changes General Requirement 1.h requires that NMMPs are identified in the applicable Documented Safety Analysis (DSA). When combined with General Requirement 1.a, there is an expectation that the newly approved NMMP will be the Safety Management Program (SMP) for maintenance and reliable performance of SSCs that are part of the safety basis. This change should take effect upon approval of the NMMP-DD by DOE and review(s) under the Unreviewed Safety Question (USQ) process. The next annual DSA update should reflect this change. 10 CFR Part 830, Subpart B, Appendix A, Table 4 expects that the Administrative Controls section of the Technical Safety Requirements provide information on the commitments to SMPs. The NMMP-DD should be incorporated into the facility safety basis maintenance safety management program as specified in the applicable 10 CFR Part 830 safe harbor. Changes to the NMMP-DD should be evaluated within the facility‘s USQ process. The implementation period should be addressed in the DOE approval letter for the NMMP. . General Requirement 1.i requires review of proposed changes to an approved NMMP, under the USQ process, if the proposed changes could affect the performance of Safety SSCs. However, as an SMP for a nuclear facility 10 CFR 830.203(d) requires all changes to the NMMP, which is incorporated into the DSA to be reviewed pursuant to a DOE-approved USQ procedure. Title 10 CFR 830.203(e) requires DOE approval prior to taking any action to implement the change. The Functions, Requirements, and Authorities (FRA) documents generally identify the Approval Authority for changes affecting the safety basis. The Order does not define whether changes to the NMMP that are not USQs require DOE approval, other than the three-year review cycle. The NMMP-DD should indicate what other types of changes, if any, must be submitted to DOE for approval, and at what level such changes can be approved. DOE G 433.1-1A 7 9-12-11 III. NUCLEAR MAINTENANCE MANAGEMENT PROGRAM ELEMENTS In each of the following sub-sections, the Order requirement is identified and followed by implementation guidance which is the essential guidance that provides an acceptable, but not mandatory means for complying with requirements of an Order or Rule, (in accordance with DOE O 251.1C). Additional good practices/background guidance as well as detailed guidance useful in supporting development of maintenance program implementation documents and some examples then follows, where appropriate. To support ease of finding the guidance for each of the Order specific requirements, a new page of this guide starts each of these sub-sections. A. INTEGRATION WITH REGULATIONS AND DOE ORDERS AND MANUALS (AND THEIR CRDs) A.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B and using a graded approach as applicable, the NMMP must be integrated with applicable programs (e.g., Safety Management Programs) and requirements identified by Federal regulations and other DOE Orders and Manuals (and their CRDs) to

include: Orders and Manuals: 1. DOE O 226.1B, Implementation of Department of Energy Oversight Policy 2. DOE O 414.1D, Quality Assurance 3. DOE O 420.1B, Facility Safety 4. DOE O 430.1B, Chg. 2, Real Property Asset Management 5. DOE O 440.1B, Worker Protection Program for DOE (Including the National Nuclear Security Administration) Federal Employees 6. DOE O 422.1, Conduct of Operations (formerly DOE O 5480.19) 7. DOE O 426.2, Personnel Selection, Training, Qualification, and Certification Requirements for DOE Nuclear Facilities (formerly DOE O 5480.20A) 8. DOE O 436.1, Departmental Sustainability 9. DOE O 458.1, Chg. 2, Radiation Protection of the Public and the Environment (formerly DOE O 5400.5) 10. DOE O 450.2, Integrated Safety Management Code of Federal Regulations (CFRs): 1. 10 CFR Part 830, Nuclear Safety Management; Subpart A, Quality Assurance Requirements 2. 10 CFR Part 830, Nuclear Safety Management; Subpart B, Safety Basis Requirements 8 DOE G 433.1-1A 9-12-11 3. Integrated Safety Management System (ISMS) provisions contained in 48 CFR Part 970.5223-1, Integration of Environment, Safety, and Health into Work Planning and Execution 4. 10 CFR Part 835, Occupational Radiation Protection 5. 10 CFR Part 850, Chronic Beryllium Disease Prevention Program 6. 10 CFR Part 851, Worker Safety and Health Program The NMMP should address the following:  Implementation of the requirements, policies, processes, and procedures contained in each of the above directives and regulations; including integration with the processes and procedures that implement the requirements of DOE O 433.1B; and  How the NMMP is the safety management system for defining the maintenance of SSCs consistent with expectations outlined in the DSA. The description document should address such items as how maintenance supports the safe operation and is integrated with the following safety basis related elements: Documented Safety Analysis (DSA); including Technical Safety Requirements (TSR), the Unreviewed Safety Question (USQ) process, Quality Assurance (QA) Program, Configuration Management (CM), and Integrated Safety Management (ISM). NMMP implementing documents should integrate or reference related requirements from the associated DOE directives and federal regulations listed in the Order. Personnel knowledgeable of these related requirements should be involved in the development and review of these procedures and instructions. A.2 ADDITIONAL BACKGROUND/GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT Subject matter experts in areas such as oversight and self-assessment, quality assurance, nuclear safety, radiological controls, and training developed the requirements in the above directives and regulations. Rather than repeat all these requirements and associate guidance here, and potentially create conflict between governance, these requirements and appropriate implementation guidance are left in their own source documents, guides, and standards. Local implementing governance can be organized as best suits the local organization to refer to or integrate such requirements. A.3 EXAMPLE DOCUMENTS The example Applicability Matrix included in Appendix A includes all the above directives and regulations to show the corresponding local procedures or other related documents. DOE G 433.1-1A 9 9-12-11 B. MAINTENANCE ORGANIZATION AND ADMINISTRATION B.1 ORDER IMPLEMENTATION GUIDANCE

In accordance with DOE O 433.1B, the NMMP must clearly address the management structure that applies sufficient resources (e.g., oversight and independent assessment, management involvement, funding, assignment of personnel roles and responsibilities, facilities, tools, and equipment) necessary to support the requirements described in this attachment and ensures integration with other programs. The NMMP should address the following:  The organizational structure, including roles and responsibilities of key positions in the organization;  Staffing levels and resources, including a description of how these levels and resources were determined to be adequate to accomplish assigned tasks;  Interfaces with supporting groups, such as Quality Assurance, Materials Management, and Radiological Controls;  Processes in place to actively encourage personnel to provide feedback and develop methods to improve safety, reliability, quality, and productivity;  Performance objectives and indicators that are used to improve maintenance performance;  How management and supervisory personnel will monitor and assess facility maintenance activities to improve all aspects of maintenance performance. This should include a description of how: - Line managers and supervisors will personally take part in monitoring and assessing maintenance activities; - Frequently tours of the plant and observations of ongoing work are expected; - Observations are documented and effective corrective actions are taken for noted problems; - Senior managers will monitor the assessment activities of their subordinate managers and supervisors; - Management and supervisory assessments, and improvement efforts will be performance-oriented; - Assessments by other independent groups, such as QA, will be used by line managers and supervisors as a management tool to assist them in assessing maintenance performance; and - Selected maintenance data reflecting facility performance are analyzed and trended, and the results are forwarded to appropriate levels of management.  The process for determining root causes for problems identified during monitoring of maintenance activities and by analysis of trends, and how corrective actions are initiated and tracked to completion. 10 DOE G 433.1-1A 9-12-11 B.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT The maintenance management structure should ensure sufficient resources (e.g., oversight and independent assessment, management involvement, funding, assignment of personnel roles and responsibilities, facilities, tools, and equipment) to support the NMMP meeting the requirements of DOE O 433.1B and the expectations described in this Guide. The maintenance management structure should provide for integration with other programs. To achieve a high level of performance in facility maintenance senior management should: establish high standards; communicate these standards to personnel who perform maintenance; select and train high-quality personnel; provide sufficient resources to the maintenance organization; set goals and objectives; closely observe and assess performance; effectively coordinate maintenance activities with operations and other facility organizations; and hold workers and their supervisors accountable for their performance. In addition, senior management should provide time for and emphasize long-range planning, as discussed in Section III.D,

Planning, Scheduling, and Coordination of Maintenance. Contractors should establish maintenance processes (including procedures and programs), considering input from maintenance staff and craft workers, as well as from operations, health physics, industrial safety and engineering (including the Cognizant System Engineer, CSE). These processes should clearly define maintenance objectives, responsibilities, and accountabilities. They should also be communicated to the workers by training them in good work practices and by making sure that supervisors observe and guide work activities. Supervisors and managers through direct observation and development of maintenance reports should closely monitor performance in maintenance. Progress toward achieving goals should be examined to measure the effectiveness of the maintenance organization performance. Remedial training should be provided when appropriate. To ensure the safety of DOE facility operations, DOE and contractor corporate and facility managers should be technically informed and personally familiar with conditions at the operating facility. These responsible managers should visit the facility, assess selected activities and portions of the facility; and leave a written record of their observations. Additionally, these managers should periodically review the maintenance programs to verify that they are effectively accomplishing their intended objectives and are upgraded as needed. Section B.2.2 addresses management involvement, performance indicators, goals and objectives, results, progress and feedback reviews, and maintenance program reviews needed for a safe, reliable, effective, and efficient maintenance program. B.2.1 Guidelines - Maintenance Organization and Administration B.2.1.1 Maintenance Organization Policies Maintenance management has the primary responsibility to ensure implementation of contractor management and facility policies that affect the maintenance organization. Maintenance organization procedures should support these policies and clearly identify the responsibilities for their implementation. Maintenance personnel should clearly understand their authority, responsibility, accountability, and interfaces with other groups. Based on these policies, procedures, and other definitive documentation should be developed to guide maintenance DOE G 433.1-1A 11 9-12-11 organization activities. These documents should specify the types of controls necessary to implement maintenance policies. See Section III.F. Maintenance Procedures. B.2.1.2 Maintenance Strategy Working Relationships Each facility should develop an integrated approach to maintenance that encourages effective working relationships among all organizational units that support the maintenance function [e.g., operations, health physics, stores, Quality Control (QC), engineering, procurement, and modifications]. The working relationship strategy should include the following:  Supporting group responsibilities;  Lead responsibilities; and  Mechanisms for issue resolution. Nuclear facilities and their responsible organization should have Memorandums of Agreement (MOAs) or Understanding (MOUs), or other formal documentation that is reviewed annually and updated as necessary to succinctly communicate what each supporting department is to provide (i.e. critical spare parts, fully trained skill of the craft staffing, tools, equipment, WO and PM

record keeping, Master Equipment List, etc.). The management of both organizations should approve documentation. Maintenance Planning Effective management of the maintenance program involves establishing a scope of major activities that shows how funding and staff resources can be managed to meet the needs of the maintenance program. Maintenance planning should consider issues such as the following:  Recurring major maintenance items such as restoration or renovation of systems or facilities;  Timing of planned major facility or equipment outages;  Major projects and modifications requiring maintenance organization involvement;  Future organizational structure and staffing changes aimed at continuing improvements in the maintenance methods, processes, and approaches/alternatives to performing work;  Government and industry issues, events, and lessons learned that may impact the maintenance program;  Budget guidance that may affect maintenance funding; and  Contractor and corporate long-range support. B.2.1.3 Staffing Resources The Maintenance Manager is responsible for selecting high-quality personnel, for effectively using available resources, for assessing resource adequacy, and for making recommendations to the appropriate manager regarding needed change. The manager should be involved in defining entry-level criteria and in screening new personnel. Entry-level criteria should ensure that maintenance personnel have the requisite background and experience to be trainable for work in nuclear facilities. High quality personnel should be selected to establish a staff of supervisory, 12 DOE G 433.1-1A 9-12-11 Subject Matter Experts, engineering, planning, technical (craft workers), warehousing, and other personnel needed to support the maintenance program. Adequate engineering support should be available (e.g., CSEs who are actively involved with such daily maintenance activities as troubleshooting and evaluating unusual conditions). The maintenance staff should have sufficient personnel and time to conduct training activities. A training and qualification program should be developed for maintenance supervisors, planners, craft workers, and warehouse personnel, to ensure that high-quality performance is achieved and maintained. See Section III.G. Training and Qualification B.2.1.4 Goals and Objectives Maintenance goals should be established and used as a management tool for involving cognizant facility groups in improving maintenance performance and for measuring maintenance effectiveness. The current value and the expected value of the parameter should be considered to ensure the goal established is challenging but achievable. The responsible maintenance manager should develop action plans for meeting the goals, with input from personnel involved in conducting maintenance activities. Through this process, maintenance effectiveness can be monitored and improvements achieved. See Section III.O, Performance Measures, for the selection and use of performance indicators. B.2.1.5 Accountability Managers, supervisors, engineers, planners, craft workers, warehouse personnel, and other personnel who support maintenance should be recognized for their performance. Rewards and other forms of positive recognition should be given for superior performance. Personnel involved in significant or frequent violations of maintenance requirements should be encouraged

to improve through counseling, remedial training, or disciplinary measures, as appropriate. Performance feedback should be provided by performance appraisals and managerial or supervisory discussions and feedback to each individual. Each employee should be aware of their responsibility to report problems or unanticipated conditions to their supervisor. Each employee should understand they are accountable for performance of their activities and the areas in which they need to improve. B.2.1.6 Status Reports to Managers Managers identify what is important to them by what they monitor. Managers should receive periodic reports on the status of various programs and on the status of action items. Managers should monitor items that are nearing the completion date to verify that due dates will be met. Managers should deal with overdue items, ensure appropriate action is taken, and the item is resolved. See Section B.3, Management Involvement. Undesirable performance trends should be assessed to determine the contributing and root causes. Corrective actions should be developed and implemented to correct undesirable conditions. Follow-up on the effectiveness of corrective actions for deficient conditions should be scheduled as part of the management-monitoring program to determine whether the immediate condition has been corrected and the root causes eliminated. Some cases will require monitoring of the immediate corrective actions and, after sufficient time for completion of all corrective actions, DOE G 433.1-1A 13 9-12-11 subsequent monitoring to determine whether recurrence of the condition is minimized. Based on the results of the follow-up monitoring, the item can be closed or a new corrective action may be required. Closeout methods should be streamlined to prevent a backlog of completed items. B.2.1.7 Causal Analysis and Event Prevention Problems, whether identified by management assessment, outside organizations, or events should be analyzed to determine underlying causes so effective corrective actions can be developed and implemented. The causal analysis should be graded to an appropriate level depending on factors such as safety, complexity, mission significance, and cost. Particular emphasis should be placed on deficiencies or causal factors identified as having generic implications, i.e. where there may be a broader extent of the condition. Causal analysis methods should be applied to event investigations, undesirable trends in quantitative indicators, and performance deficiencies noted in monitoring reports. For example, if a deficient condition exists because of personnel performance, the underlying cause(s) may be one or more of the following:  Erroneous, incomplete, or unusable procedures;  Insufficient or incorrect training;  Insufficient supervision caused by lack of monitoring, accountability, or improper standards; and/or  System or equipment design deficiencies. Corrective Actions Corrective actions should address the analyzed causes rather than the symptoms of the problem. The objective of causal analysis should be to identify failures at an appropriate level. Where possible, corrective actions should prevent not merely a reoccurrence of the specific problem, but also prevent other problems, which may result from that same cause. Corrective actions should be developed with input from appropriate facility and staff members,

including those tasked with implementing the actions, to achieve ownership of the corrective actions. Facility line management should approve corrective actions and ensure the actions are implemented in a timely manner. Input from organizations such as quality assurance (QA) or corporate support/oversight groups should be considered when determining actions in response to deficient conditions they identified. Management should track corrective actions‘ completion and effectiveness. Responsible managers and supervisors should be held accountable for the timely and effective implementation of corrective actions. Delays in the completion of approved corrective actions should be brought to the attention of the responsible manager who assigned the corrective actions. An escalation process should provide higher levels of management attention to problem areas where corrective action continues to be incomplete or ineffective. Use of Operating Experience Programs should be in place to ensure the timely review of in- house and external industry operating experience to incorporate lessons learned into maintenance programs and practices. Management should use this operating experience in assessing performance and in performing causal analyses of problems. Management should have mechanisms in place to ensure that significant in-house events are promptly provided to the industry for use by other facilities. 14 DOE G 433.1-1A 9-12-11 Another aspect of operating experience involves visits to or communications with other facilities (benchmarking). Maintenance division managers, supervisors, and workers should take opportunities to visit and communicate with other facilities both to help solve specific problems and to learn different approaches to the routine business of operating facilities. B.2.1.8 Management Control of Plant Configuration Management should ensure that plant configuration, including the manner in which the facility is maintained, conforms to the established design basis requirements. Many routine activities, if carried out improperly, can have an adverse impact on facility configuration and cause eventual equipment damage or increase the probability or consequences of a significant event. Effective control of facility configuration requires rigorous attention to detail as well as the understanding and commitment of every member of the maintenance organization to observe and report/record material condition and status. See Section III.H, Configuration Management, for more details. B.2.1.9 Document Control Administration Workers should ensure documents are the current, approved versions before use. The maintenance document control program should ensure technically correct and readily accessible information is provided to support maintenance activities. Technically accurate and approved information written in a clear and concise format is needed to support safe and reliable maintenance operations. The document control system should ensure that only authorized technical information is available for the performance of maintenance activities. Controlled information should include maintenance procedures, maintenance plans, maintenance policy manuals, maintenance records and documentation, drawings, vendor technical manuals, and maintenance correspondence. The document control system should provide for the timely receipt, processing, distribution,

retention, storage, and retrieval of documents originating both within and outside the maintenance organization. More than one department may share the responsibility for document control. For example, one department may be responsible for the control, updating, and distribution of drawings and another responsible for maintaining maintenance procedures and retention and storage of maintenance documents including technical manuals. Controls should be established outlining the responsibilities and authorities of individuals or groups associated with document control. A master control file of maintenance documents should be maintained, with access to change documents limited to designated personnel. Satellite files of controlled maintenance documents should be established as necessary to support maintenance operations. Responsibility for maintaining satellite files should be clearly defined. B.2.1.10 Procedures A formal systematic program should be established for the preparation, review, approval, distribution, and revision of maintenance procedures to ensure continued accuracy and usability. The program should ensure the review and updating of maintenance procedures at regular intervals. All maintenance procedures should use a uniform procedure format. An administrative procedure should be developed that provides the prescribed methods of formatting, content DOE G 433.1-1A 15 9-12-11 determination, and numbering maintenance procedures. See Section III.F, Maintenance Procedures, for details. B.2.1.11 Vendor Information The receipt, processing, and distribution of vendor technical information relating to the systems or components installed at the facility should be controlled to the same level as facility documentation applicable to the same SSC. The proper performance of maintenance activities is strongly dependent upon the availability and use of accurate, up-to-date vendor technical information. The application of controls on vendor manuals depends on the intended use of the manual. If detailed procedures have been developed for use in the conduct of maintenance, then vendor manuals should be used only as reference source material and so marked. If vendor manuals are intended as replacements, substitutes, or supplements for maintenance procedures, then their use should be controlled in the same manner as maintenance procedures. Vendor manuals should be reviewed for completeness, accuracy, and applicability before initial use. Vendor manuals should be treated as maintenance documents, with maintenance management/document control retaining responsibility for maintaining the manuals current. See Section III.F, Maintenance Procedures, for more details. B.2.2 Guidelines - Management Involvement B.2.2.1 Management Involvement DOE and contractor corporate and facility managers should be involved and know what is going on in their facility by touring it frequently. The high profile by management conducting frequent nonscheduled individual tours of work areas both on- and off-shift provides first-hand observation of actual conditions and an opportunity to communicate expected performance standards through appropriate and timely recognition/feedback directly to individuals regarding either positive or negative observations. It also provides an opportunity to involve and establish ownership in approved actions at the level most directly involved in improving performance.

This encourages individuals at all levels to take pride in their accomplishments and motivates first-line supervisors and craft workers to accept responsibility for the early detection of opportunities for improvement. This degree of management involvement promotes timely escalation of significant problems/concerns to the level of management having resolution authority. Maintenance management should also establish the expectation for first-line supervisors to spend a percentage of their time supervising fieldwork, and should monitor and adjust their workload accordingly. These tours by management and first line supervision may be selectively based on concerns resulting from program reviews or other feedback. The results and observations of these tours should be documented and reviewed for action. Fewer errors, higher standards, and improved morale can result. In addition to first-hand observations, Maintenance Managers ensure effective knowledge-based decisions using factual information from a variety of sources. These sources include key performance indicator trend review, critical self assessments, exception reports, problem and corrective action status tracking, lessons learned and alert system reviews, daily and weekly 16 DOE G 433.1-1A 9-12-11 review of staff activities, customer feedback, craft worker input, historical data, and regulatory requirements. Rules, responsibilities and accountability between DOE and contractor and facility managers should be clearly delineated and communicated to all levels of the maintenance organization. DOE managers should be responsible and accountable for the management and maintenance of DOE assets in accordance with federal regulations, DOE directives, and contractual agreements. DOE contractors should be responsible for the operation, management, and maintenance of DOE nuclear facilities in accordance with commitments and agreements under the contract. The contractor managers should ensure that environmental, safety, and health (ES&H) functions and activities become an integral part of their work planning and execution process. DOE involvement in the oversight of nuclear facility maintenance programs should include reviews by the DOE facility representative, field and area offices, and Headquarters. Inspections, audits, reviews, investigations and continuous self-assessment are necessary ingredients to achieving excellence in maintenance activities. Whether DOE or contractor, senior managers should periodically review and assess elements of the maintenance program for effectiveness and to identify areas of needed improvement. A comprehensive assessment of maintenance program elements should be conducted periodically and should include input from managers and supervisors from maintenance and other groups such as operations, technical staff, and appropriate corporate departments. See Sections III.M and P for facility inspection techniques and Appendix B for assessment guidance. B.2.2.2 Management Monitors Performance The results of maintenance performance indicators, goals and objectives, and other related information should be developed, trended, and reported to provide feedback to senior management for use in the progress and feedback reviews discussed below. See Section III.O, Performance Measures, for the development and use of performance indicators, goals, and objectives. Management should ensure there is an effective process for identifying and analyzing problems.

The process should include collecting relevant data, conducting a causal analysis to identify the root cause and appropriate corrective action(s), and follow up to determine the effectiveness of the corrective actions and whether it has generic implications. Inspections, audits, reviews, investigations, and self-assessments can assist line managers and supervisors in the identification and correction of program deficiencies. An evaluation of each maintenance program element should be conducted periodically and should include inputs from maintenance managers, supervisors, and other groups, such as operations, technical staff, and appropriate corporate departments. The evaluation should address the overall effectiveness of the program element and any inter- or intra-organizational coordination problems that create work delays or reduce productivity. Areas needing improvements should be assigned for corrective action and follow-up. The program elements to be considered in this evaluation are those identified in the Order and this Guide as Elements III.B-Q. B.2.2.3 Problem Analysis Problem analysis is addressed in Section III.O, Performance Measures. DOE G 433.1-1A 17 9-12-11 B.2.2.4 Information Collection Problems should be coded and clearly defined to permit status tracking and trending. In addition to maintenance history files, information pertinent to the most recent occurrence is valuable during problem analysis and may be obtained from:  WRs/WOs;  Shop floor activity logs;  Strip-chart and other recording devices;  Operator statements (facts and symptoms);  Troubleshooting results;  Craft worker statements; and/or  Industry experience. Information and data gathered from the most recent occurrence should be recorded as maintenance history. B.2.2.5 Feedback Management should set aside time to actively solicit and encourage written or verbal feedback regarding concerns or suggestions for improvement from all affected individuals and organizations including line, staff, support (craft workers, planners, engineers, etc.), and customers regarding performance concerns and opportunities for improvement at all levels of the maintenance organization. Feedback should be evaluated and actions that result in improved maintenance services implemented. The individual providing the feedback should receive a timely response from management that explains the rationale for either no action or alternate action, and indicates status of the suggested action. Concerns that involve broad areas of responsibility should be addressed by project teams consisting of representatives from all affected crafts and organizations. These project teams should be given the necessary time to provide effective action. Application of lessons learned from in-house maintenance experiences (and the experiences of other facilities) is essential for long-term success. Management should use information about problems encountered during maintenance activities to improve performance. B. 2.2.6 Program Reviews Management should periodically review and assess the maintenance program in accordance with the facility self-assessment program as addressed in DOE O 226.1B. 18 DOE G 433.1-1A 9-12-11 C. MASTER EQUIPMENT LIST C.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B, the NMMP must include a process for developing, implementing, managing, and maintaining the Master Equipment List (MEL) at a level that

clearly identifies the Structures, Systems, and Components (SSCs) that are part of the safety basis. The NMMP should address the following:  Development and maintaining up-to-date of a comprehensive listing of SSCs that are a part of the safety basis; and  How the MEL will be used by maintenance and support personnel to identify and apply appropriate controls to maintenance. C.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT 10 CFR 830 Subpart B, Nuclear Safety Management, and DOE O 420.1B, Facility Safety, require formal definition of minimum acceptable performance of Safety Structures, Systems, and Components (SSCs) in the Documented Safety Analysis (DSA). This is accomplished by first defining a safety function, then describing the SSCs, placing functional requirements on those portions of the SSCs required for the safety function, and identifying performance criteria that will ensure functional requirements are met. A product of initial safety basis development and updates should be a listing of these SSCs, which is then used to develop and maintain the MEL. The MEL clearly identifies all SSCs that are part of the safety basis, thus requiring controls that are more rigorous. The organization may include in the MEL and the nuclear maintenance program those non-safety SSCs to which they chose to apply rigorous controls. Within the design change and/or configuration management process, the facility should evaluate changes/modifications to identify any necessary updates to the MEL. The work planning process should include checking equipment, which will be effected in the MEL to determine if special controls are required in the maintenance package. While an approved hard-copy list of all SSCs that are part of the safety basis is acceptable, typically the MEL is maintained electronically in the facility‘s computerized maintenance management system and includes all facility equipment, with the safety basis items coded for identification. Thus, the MEL can be an index with many uses, including periodic maintenance, spare parts inventories, and equipment history. Each MEL item should be identified uniquely. An engineering group typically develops and maintains the MEL. Additional information, such as the following, may be included or linked/referenced to the MEL items:  Equipment name/type;  Equipment tag in field (location);  Safety category;  Reference to safety basis source; DOE G 433.1-1A 19 9-12-11  Any applicable TSRs/LCOs;  Installed make and model;  Spare Parts; and/or  Status (active, retired, inactive). 20 DOE G 433.1-1A 9-12-11 D. PLANNING, SCHEDULING, AND COORDINATION OF MAINTENANCE D.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B, the NMMP must include the process for planning, scheduling, coordination, and control of maintenance activities, and properly emphasizing equipment availability. The process must include the application of a Cognizant System Engineer Program in accordance with DOE O 420.1B in the planning and execution of maintenance activities. The NMMP should address the following:  Planning group organization and responsibilities;  Expectations for management commitment, overview, and support of the program;  The process for ensuring the appropriate level of detailed work instruction so that workers, schedulers, and other affected organizations can carry out the activities as

planned;  The process for coordination of integrated discipline of work packages to ensure involvement of the appropriate persons and the proper sequence of carrying out the work;  Expectations for experience or qualification of individuals performing work planning;  How feedback from maintenance personnel is used to facilitate improved future planning activities;  The use of job history for establishing standard job duration, parts, and consumables for repetitive jobs;  The manner in which the planning system addresses the following: - Identification and control of the hazards associated with the work activity and area; - Reduction of the impact of planned outages by planning, coordinating, and completing maintenance activities in a timely manner; - Reducing facility and equipment downtime; - Reducing human errors; - Reducing radiological and toxicological exposure to workers; - Controlling and reducing the number of contaminated areas; - Completing scheduled surveillances and PM activities in a timely manner; - Establishing appropriate post-maintenance/post-modification testing and acceptance criteria; - Managing the corrective maintenance backlog to minimize the backlog and completion time of outstanding deficiencies; - Controlling overtime; - Completing outage and non-outage work on schedule; and DOE G 433.1-1A 21 9-12-11 - The process for reviewing completed work packages for proper documentation, post-maintenance testing, safety hazards encountered, feedback, possible changes to the PM program, and equipment history update. The NMMP should further address how:  The work-control system provides management with an accurate status of maintenance planning and outstanding maintenance work;  Control of work is accomplished through the effective use of a priority system and the backlog of work is effectively managed;  Work planning considerations such as material, tool, and manpower requirements; interdepartmental coordination; safety considerations; radiological protection requirements; and QC requirements are included; and maintenance history records are considered where appropriate;  The work to be accomplished is clearly defined by a work document that identifies or includes applicable procedures and/or instructions. Troubleshooting activities are con- trolled by applicable work documents;  Advance planning is performed and routinely updated for scheduled and unscheduled outages. Considerations such as work priority, work procedures and instructions, facil- ity/system conditions, length of outage required, pre-staging of documents and materials, and coordination of support activities are included;  ALARA concepts are used in work planning to minimize man-rem exposure;  Scheduling and coordination of maintenance activities avoids unnecessary removal of equipment and systems from service and uses manpower effectively;  Post-maintenance testing requirements are clearly defined and include the following: - Clearly written test instructions; - Test scope sufficient to verify the adequacy of work accomplished; and - Test acceptance criteria.  Post-maintenance testing results are documented and reviewed to ensure proper system/equipment performance before returning the system to service; and  Completed work-control documents are reviewed in a timely manner to check proper completion of maintenance work and to verify that corrective action resolved the problem.

In accordance with DOE O 420.1B, the CSE must maintain integrity of a facility‘s safety basis as well as maintain overall cognizance of the system and be responsible for system engineering support for operations and maintenance. The CSE must provide technical assistance in support of line management safety responsibilities and ensure continued system operational readiness. In accordance with DOE O 433.1B, the NMMP must describe the application of a CSE to the maintenance activities. 22 DOE G 433.1-1A 9-12-11 The NMPP should address how System Engineering is involved in the following activities:  Remaining apprised of operational status and ongoing modification activities;  Assisting in review of key system parameters and evaluate system performance;  Identifying trends from operations and maintenance, and providing assistance in determining operability, correcting out-of-specification conditions, and evaluating questionable data;  Remaining cognizant of system-specific maintenance and operations history and industry operating experience, as well as manufacturer and vendor recommendations and any product warnings regarding safety SSCs in their assigned systems in order to advise the maintenance organization;  Initiating actions to correct problems;  Reviewing and concurring with design changes and maintenance modifications;  Providing input to the development of special maintenance and test procedures; and  Ensuring that system configuration is being managed effectively, including reviewing and concurring with post-maintenance/post-modification testing and acceptance criteria for assigned systems. D.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT Effective work planning is necessary to identify the required support and detailed scoping to successfully schedule, coordinate, and control maintenance activities. Accurately defining the work to be performed and providing qualified workers and appropriate procedures or instructions can reduce maintenance errors and the risk of injury to personnel. Planning also reduces work delays and improves efficiency by ensuring required support items such as special tools, personal protective equipment, other equipment, repair parts, and materials are available when needed. Coordinating maintenance activities is necessary to help ensure work can be effectively accomplished. Coordination should ensure the availability of necessary safe work permits; equipment lockouts/tagouts; and QC verifications. Coordination should include the CSE when the maintenance activities involve safety class and safety significant SSCs as defined in the facility‘s DOE approved safety basis, as well as to other systems that perform important defense- in-depth functions, as designated by facility line management (DOE O 420.1B). Coordination is needed where various groups (e.g., mechanical, electrical, instrumentation and control, and contractor) are involved in a work activity or are concurrently working in the same area. A knowledgeable individual responsible for the major portion of the work activity should be assigned the lead in identifying and coordinating needed support. D.2.1 Guideline – Control of Maintenance A maintenance work-control program should be integrated with the planning system and with ISMS. The work-control program should ensure work activities are consistent with the facility

safety basis and effectively identified, initiated, planned, approved, scheduled, coordinated, performed, and reviewed for adequacy and completeness. The program should ensure the availability and operability of the SSCs that are a part of the safety basis. The work-control DOE G 433.1-1A 23 9-12-11 program should apply the same policies and procedures for non-facility contractor and subcontractor personnel conducting maintenance on the site as facility personnel. The work-control system should provide the data necessary to properly plan and schedule maintenance activities, as well as to support failure analysis (see Section III.O, Performance Measures) and maintenance history (see Section III.L, Maintenance History). The maintenance organization should establish high standards for all maintenance personnel supervising and performing maintenance activities (see Section III.B, Maintenance Organization and Administration). Maintenance management should be involved and oversee work to ensure these standards are met and work is conducted in accordance with DOE, contractor, and facility policies and procedures. Configuration control is maintained by ensuring that systems and equipment are restored to their original condition following maintenance. (See Section III.H, Configuration Management) This section describes a system for effectively planning, scheduling, and coordinating routine maintenance activities as well as unplanned and planned outages, and for effectively controlling maintenance activities. D.2.2 Guideline - Planning D.2.2.1 Planning for Maintenance Activities The primary objective of work planning is to identify all technical and administrative requirements to complete a work activity and to provide the materials, tools, and support activities needed to perform the work safely and correctly. Effective planning, scheduling, and coordination will help minimize delays. Work planning should be periodically assessed through field observation of work being performed and direct feedback from maintenance personnel to maintenance planners. An effective planning program should contain the following:  Management commitment, overview, and support of the program;  The appropriate level of detailed work instruction so that workers, schedulers, and other affected organizations can carry out the activities as planned;  Proper coordination of integrated discipline review to ensure involvement of the appropriate persons and the proper sequence of carrying out the work;  Involvement of experienced individuals in work planning;  Feedback from maintenance personnel to facilitate improved future planning activities; and  Use of job history for establishing standard job duration, parts, and consumables for repetitive jobs. The planning system should address the following:  Identifying and controlling the hazards associated with the work activity and area;  Reducing the impact of planned outages by planning, coordinating, and completing maintenance activities in a timely manner; 24 DOE G 433.1-1A 9-12-11  Reducing the number of forced outages;  Minimizing challenges to SSCs that are a part of the safety basis;  Reducing worker lost-time accident rate;  Reducing facility and equipment downtime;  Reducing human errors;  Reducing radiological and toxicological exposure to workers;  Controlling and reducing the number of contaminated areas;

 Completing scheduled surveillances and PM activities in a timely manner;  Establishing appropriate post-maintenance/post-modification testing and acceptance criteria;  Reducing repeat maintenance WRs (rework);  Managing the corrective maintenance backlog to minimize the backlog and completion time of outstanding deficiencies;  Controlling overtime;  Staffing and training the maintenance organization; and  Completing outage and non-outage work on schedule. D.2.2.2 Planning-Group Organization Planning maintenance activities can be accomplished by a dedicated planning staff or by maintenance supervisors at facilities with smaller staffs. If a dedicated group is used, it may be centralized or decentralized, with planners for each discipline working within their respective groups. The planning process should involve knowledgeable maintenance personnel and experienced personnel from such other disciplines as safety, operations, QC, and radiological protection. A small facility may function well with maintenance supervisors being responsible for all planning. A larger facility may gain by having a dedicated planning group to relieve the first-line supervisor of most planning duties to allow adequate time for other supervisory duties, such as observing and directing activities at the work sites. D.2.2.3 Planning-Group Responsibilities A planner should review all Ready-to-Work Work Requests /Packages. Different levels of planning attention should be applied to different jobs. The review should address the following items.  Definition of the problem and identification of the work scope (e.g., by work-site inspection, by review of other maintenance that should or could be performed within the lockout/tagout boundary for the equipment);  Identification of personnel hazards expected to be encountered during the maintenance activity, and safe work practices to be used to mitigate and eliminate such hazards; DOE G 433.1-1A 25 9-12-11  Identification and review of necessary procedures, drawings, vendor manuals, and maintenance history;  Procurement of necessary repair parts, materials, tools, and equipment;  Assessment of labor and skill requirements for nuclear facility, non-nuclear facility, and subcontractor personnel and their availability;  Identification and review of possible conflicts, including other tasks scheduled to occur in the immediate area during the same period;  Pre-job ALARA planning;  Identification of initial conditions and prerequisites, including applicable TSR and LCOs;  Identification of QC inspection requirements and code requirements;  Establishment of equipment restoration and post-maintenance inspection or testing requirements; and  Review of work instructions or work packages for completeness. Once the work is completed, the completed work packages should be reviewed for proper documentation, post-maintenance testing, industrial safety hazards encountered, feedback, possible changes to the PM program, and equipment history update. D.2.2.4 CSE Responsibilities In accordance with DOE O 420.1B, the CSE is required to maintain integrity of a facility‘s safety basis as well as maintain overall cognizance of the system and the CSE is responsible for system engineering support for operations and maintenance. In accordance with DOE O 420.1B, the CSE is required to provide technical assistance in support of line management safety

responsibilities and ensure continued system operational readiness. The CSE supports the planning and performance of maintenance activities by:  Ensuring that system configuration is being managed effectively, including reviewing and concurring with post-maintenance/post-modification testing and acceptance criteria for assigned systems;  Remaining apprised of operational status and ongoing modification activities;  Assisting in review of key system parameters and evaluate system performance;  Initiating actions to correct problems;  Remaining cognizant of system-specific maintenance and operations history and industry operating experience, as well as manufacturer and vendor recommendations and any product warnings regarding safety SSCs in their assigned systems in order to advise the maintenance organization;  Identifying trends from operations and maintenance;  Providing assistance in determining operability, correcting out-of-specification conditions, and evaluating questionable data; 26 DOE G 433.1-1A 9-12-11  Providing or supporting analysis when the system is suspected of inoperability or degradation;  Reviewing and concurring with design changes and maintenance modifications; and  Providing input to the development of special maintenance and test procedures. D.2.2.5 Worker Skills To perform the planning function correctly and efficiently, the maintenance activity should be evaluated to determine the necessary worker skills along with the necessary level of detail in procedures to support the activity. The requirements to provide procedures to maintain SSCs important to facility safety are defined in DOE O 433.1, Maintenance Management Program for Nuclear Facilities, DOE O 422.1 (formerly DOE O 5480.19), Conduct of Operations, 10 CFR Part 830 and the facility TSR. The training and qualification program should provide a foundation for the basic skills and knowledge a worker (contractor and permanent staff) needs to possess to perform the job. (See Section III.G, Training and Qualification) The use of mock-ups and run-throughs should be used as needed to facilitate the workers performance of complex or very sensitive tasks. D.2.2.6 Supervisor and Worker Responsibilities The first-line supervisor/team leader is accountable to senior management for the quality of work performed in the following areas:  Understanding and ensuring the correct use of the approved NMMP;  Selecting qualified people to perform work;  Ensuring experienced workers assigned to perform work activities are appropriately qualified;  Identifying and controlling job hazards;  Following an integrated work schedule to manage time and resources effectively;  Periodically observing work-in-progress, while providing job-site coordination and supervision;  Ensuring proper return to service of equipment, including job-site cleanliness and post- maintenance testing; and  Maintaining the quality of the completed work packages to record the work actions performed adequately. DOE G 433.1-1A 27 9-12-11 Craft workers provide specialized hands-on skills. At the direction of first-line supervisors/team leaders, the workers perform those tasks necessary to preserve or restore the equipment. Craft worker responsibilities are in these general areas:  Maintaining appropriate skill levels;  Using and following procedures and work instructions properly;  Recording information accurately;

 Performing work using good quality and ES&H work practices;  Identifying and controlling job hazards; and  Stopping work if an unanticipated or unsafe condition is identified. A balanced combination of written guidance, craft skills, and work-site supervisory observation is required to achieve the appropriate rigor and quality workmanship essential to safe, efficient, and reliable facility operation. Rigor is the amount of supervision and written direction based on the risk and complexity of the task and the known skills of the craft worker. The relationship of all three elements should be considered during task planning and personnel assignment. Once the work is completed, the completed work packages should be reviewed for proper documentation, post-maintenance testing, industrial safety hazards encountered, feedback, possible changes to the PM program, and equipment history update. D.2.2.7 Ranking Hazards in Planning Work When developing controls for a maintenance work activity, consideration should be given to the probability and significance of negative consequences due to the identified hazards associated with the work activity and area.1 The complexity of the work activity will also impact the probability of an undesirable outcome. A simple matrix (such as shown below) would show hazard consequence measured on one axis and probability measured on the other. The worse the potential consequence and the greater the probability of an undesirable outcome, the more robust the controls or the defense-in-depth should be. The purpose of the matrix is to gage the appropriate effort to expend on control development and implementation, graded from the least to the most hazardous work activities. The level of hazards analysis and controls is graded based upon the likelihood and severity of the consequences to the worker, the public, and the environment. Depending on the particular maintenance work activity, the individual planning the work should use a team approach in evaluating the hazard(s). The team may include environmental, health, and safety professionals, the CSE, the facility owner, and worker representation in determining whether the consequence and the probability of the hazard(s) are at the high, medium, or low level. 1 For a comprehensive look at this subject, see ―the red book‖, Guidelines for Hazard Evaluation Procedures, Second Edition with Worked Examples Center for Chemical Process Safety. 28 DOE G 433.1-1A 9-12-11 The information gained from the matrix should be used in planning the work to determine the proper degree of rigor needed to ensure the safe and effective performance of the work activity. Controls to be considered include:  Mix of worker skills and qualifications (apprentice, master, special qualifications);  Degree of worker preparations (Pre-Job Briefing, Mockup Training);  Detail of work instructions (minor maintenance, comprehensive work package); and  Level of supervisory oversight (routine, frequent, continuous). HAZARD RANKING MATRIX CONSEQUENCE PROBABILITY H M L H HH HM HL M MH MM ML L LH LM LL D.2.2.8 Planning System A system of planning, scheduling, and coordinating maintenance work activities should consist of five interrelated processes applicable to each maintenance job. The processes are as follows.  Plan Maintenance Job Identify the scope of a needed maintenance job. Produce a maintenance job plan. Determine maintenance job planning category, priority, and safety

concerns. Identify and procure materials, and identify other maintenance task resources. Prepare the maintenance job package.  Schedule Maintenance Job Calculate estimated start date and project resources for the maintenance job. Schedule and commit required resources and special tools/equipment items to allow performance of all maintenance tasks within the maintenance job.  Execute Maintenance Job Initiate and perform a maintenance job and collect job information as defined in the maintenance job package.  Execute Post-Maintenance Test (PMT) Verify facilities and equipment items fulfill their design functions when returned to service after execution of a maintenance job.  Complete Maintenance Job Perform maintenance job closeout including completion of all documentation contained in the maintenance job package to ensure historical information is captured and feedback on opportunities for improvement. DOE G 433.1-1A 29 9-12-11 D.2.2.9 Work Request/Work Order Maintenance performed on nuclear facility systems should be controlled by the facility WR or by another approved work-control document. The document should clearly define the work to be performed and should include the following:  Equipment identification;  Name of the person initiating the WR;  Date WR was initiated;  Description of the symptom, problem, or work requested;  Location of equipment;  Job priority;  Personnel safety and radiation protection requirements or permits (e.g., confined-space entry permit, welding and burning permit, lockout/tagout, isolation, draining, depressurization of the component, and RWPs);  Applicable TSR, time constraints, and associated LCOs;  Qualification requirements (such as environmental and seismic qualifications);  Applicable work instructions and references;  Inspection, safety, or ALARA hold points associated with the work;  Required post-maintenance testing, inspections, and acceptance criteria;  Authorization by the appropriate management to perform work;  Narrative description of conditions found by the experienced workers;  Documentation of actual work performed with post-maintenance testing and inspection results;  Acceptance of the equipment by operations; and  Final reviews and signoffs by maintenance, QC, and other groups in the WR or other approved work-control document review cycle. The WR or other approved work-control document should be reviewed by affected groups or their representatives (such as maintenance, operations, technical support, CSEs, QC, safety, and radiation protection personnel) during the planning process to ensure it is current and accurate. D.2.2.10 Maintenance Work Request/Work Order Processing A maintenance WR/WO should be initiated and a maintenance deficiency tag/sticker attached or applicable status indicator/tracking system updated as soon as practical after discovery of a facility equipment deficiency. 30 DOE G 433.1-1A 9-12-11 All WR/WOs for facility equipment should be delivered to the equipment owner/operator or designated representative for review and appropriate action to minimize further equipment damage. The owner/operator review should ensure the following:  The WR/WO is not a duplicate of an existing WR/WO;  Equipment name, identification number, and location are properly entered;  Originator information is included on the form and is legible;  Deficiency tag number and location are documented, if applicable;

 Failure/problem description is accurate and clearly stated;  Special conditions necessary to remove equipment from service such as an LCO, a system outage, or a major facility outage are clearly identified; and  Priority is assigned, TSRs are identified, and time limits for action are specified, if applicable. After review, the owner/operator representative should forward WR/WOs to the maintenance- planning department. The planning supervisor or designated individual should review the WR/WO to determine whether it should be performed as a minor maintenance task and assign it to the responsible craft planner. The craft planner should review the WR/WO and perform the following. 1. Verify that the WR/WO is not a duplicate of an existing WR/WO. 2. Walk down the identified deficiency using the walk down checklist, as necessary, to assist with job planning. 3. Verify the identified deficiency accurately describes the equipment problem. For example, ―waste disposal pump leaks‖, does not communicate the urgency of needed repairs or provide accurate direction or performing repairs. A more useful description would be, ―The casing flange on the waste disposal pump leaks 10 drops per minute during pump operation at full load. The pump design does not permit any leakage from the casing flange. Continuation of the leakage will damage the pump and result in its inoperability.‖ 4. Identify special equipment/conditions to be considered in planning the work such as scaffolding requirements, special tools, interference removal, special radiological considerations, etc. 5. If the activity should be performed as minor maintenance, forward the WR/WO to the appropriate craft supervisor or scheduler for accomplishment. DOE G 433.1-1A 31 9-12-11 D.2.2.11 Maintenance Work Request/Work Order Planning The planner should perform the following steps using a walk down checklist. 1. Identify any other pending and/or appropriate maintenance tasks, such as PM, surveillance tests, or related corrective maintenance, that may be performed concurrently with the work being planned. Discussion with operations, scheduling, and the system engineer/engineering, may be necessary to coordinate all associated work. (PMs that might affect the results of surveillance testing should be scheduled to occur following the completion of surveillance testing to avoid pre-conditioning the surveillance testing results.) 2. Identify and initiate appropriate requests as necessary for additional task and/or support needs such as scaffolding erection, electrical disconnection, piping removal, etc. 3. Review component history to determine when and what actions were previously taken for similar repairs. Consider repairs to similar equipment in other locations. Repetitive maintenance trends for problem equipment, components, and structures should be brought to the attention of the system engineer/engineering for resolution. 4. Obtain applicable detailed drawings of the components and associated systems to be repaired or affected by the repair. 5. Review vendor information for special requirements for component repair and parts that may be needed to perform repairs. 6. Provide a list of required special tools and parts for the job in the job package. If like- for-like replacement parts are not available, contact the system engineer/engineering for resolution. 7. Check for parts availability. Order/reserve parts as necessary to perform repair.

8. Determine procedure requirements based on equipment classification, ALARA considerations, and/or extent of repair needed to restore the equipment to operating condition (see DOE-STD-1029, Chg 1, Writer’s Guide for Technical Procedures). Where pre-approved procedures are available, work should be performed using these procedures. Review and consider feedback from previous performance of the maintenance procedure. 9. If an approved procedure is not required as determined in Step D.2.3, provide work instructions to the craft worker in sufficient detail to correct the equipment deficiency. Vendor recommendations, engineering requirements, craft training/skills (skill-of-the- craft), special tool needs, and hazards involved in performing the task should be considered when preparing these instructions. System engineer/engineering review of new work instructions should be performed to ensure adequacy. Work instructions to control troubleshooting should also be developed. 10. Working with craft supervision, review maintenance history records to determine time and coordination requirements to accomplish the task. 11. Initiate special permits necessary to perform the maintenance task. Flame permits, confined space permits, tagging requests, RWP requests, etc., should be included in the work package, if available. 32 DOE G 433.1-1A 9-12-11 12. When ALARA work planning is performed, special consideration should be given to providing adequate detail to assist the craft worker in performing the task and reducing radiation exposure. Examples of items that should be considered include the following:  Reviewing previous work packages for lessons learned and effective methods of performing the task;  Reviewing area photographs, if available, to identify problems that may delay work;  Providing detailed tool lists;  Providing rigging and handling sketches;  Performing mockups or practice runs in non-radiation areas;  Using portable shielding to reduce radiation levels;  Dividing work into distinct tasks to be performed by different individuals;  Holding an in-depth pre-job briefing to ensure craft workers have a clear understanding of the tasks to be performed;  Improving access to the work through portable scaffolding or work platforms;  Posting work areas to control access;  Including ALARA personnel in the planning process; and  Designing special tools that may reduce time to complete repair. 13. Work with the Operations Manager and the System Engineer/engineering to determine the following:  Operational impacts such as alarms, possible actuation, special system alignment, or operator actions; and  PMTs that should be performed to check the maintenance performed and to return the component to operation (see Section III.Q, Post Maintenance Testing). 14. Assemble the work package. The craft worker in performing the maintenance uses facility document control procedures should be followed to ensure the most recent revision of a procedure. 15. Place the work package in the appropriate file or forward it to scheduling for accomplishment. Files should indicate the following:  Ready to Work - All requirements are met; parts are available; support needs, such as scaffolding, are identified;  Hold for Parts - Repair parts are on order but have not been received or are not available;  Hold for Facility Conditions - All requirements have been met; however, special

facility conditions, such as a component outage/LCO, are needed to perform the work; and  Outage Item - Facility outage or major system outage is needed to perform task. DOE G 433.1-1A 33 9-12-11 Consider maintaining a library of routine, recurring maintenance instructions to minimize planning time. Previous job histories should be reviewed to establish standard job durations, typical parts and consumables needed, and other job requirements. D.2.3 Guideline – Scheduling Maintenance Activities D.2.3.1 Control of Work Backlog Work requests (WRs) should be entered and retained in the system from the time the work is identified until all work actions are complete, including post-maintenance testing and administrative reviews. The system should provide a serialized list of WRs with a brief description of work required, priority assigned, date initiated, and plant conditions required for performing the work. Work should be scheduled and combined with other maintenance activities on the same equipment, or with other maintenance on similar equipment in proximity. For example, corrective maintenance could be scheduled simultaneously with an upcoming PM action that requires the same or a similar lockout/tagout, or PM routes could be established that allow craft workers to lubricate all equipment on a particular elevation, or quarterly and annual PM could be scheduled simultaneously. Delays beyond the scheduled due dates for PM actions should be approved by the facility manager. D.2.3.2 Work Priority Each WR related to repairs of production equipment should be reviewed by the operations department to determine its impact on facility operations. Meaningful priorities that determine how soon a WR needs to be worked should be set based on operational and industrial safety and reliability. Communication among cognizant groups should be established to enable proper priorities to be set. Items that should be considered when priorities are assigned to WRs include the following:  Personnel and radiological safety;  Equipment repair urgency;  Operability of redundant equipment;  Operating approval commitments (e.g., TSR, LCO);  Facility conditions required for equipment repair;  Status of repair or replacement parts;  ALARA considerations such as exposure and contamination control;  Personnel availability; and  Minimization of the spread of contamination from leaks. 34 DOE G 433.1-1A 9-12-11 The following list illustrates a priority system. 1. Non-outage work. a. Priority 1 - Emergency or severe adverse impact on personnel safety; limits facility operation (top priority: work today and provide special coverage if necessary). b. Priority 2 - Urgent; hinders facility operation (schedule within 24 hours). c. Priority 3 - Necessary; has potential to degrade or hinder facility operation (schedule within seven days). d. Priority 4 - As time permits. 2. Outage work (subcategories for Priority 5 and 6 work as part of outage planning are also useful). a. Priority 5 - Hot shutdown or hot standby. b. Priority 6 - Cold shutdown. Scheduling corrective and preventive maintenance as well as planned and forced outage work is necessary to ensure that maintenance is conducted efficiently (e.g., within prescribed time limits). Scheduling daily activities based on accurate planning estimates improves facility production capacity through effective use of time on the job and helps to reduce hazardous

worker exposures. Scheduling planned outages is important to support the return of the facility to service on schedule (and within the approved budget) and results in improved availability and capacity factors. In addition to the integrated maintenance schedule, a contingency schedule should be maintained so that if a forced outage occurs, the forced outage time is minimized and effectively used and so that all needed maintenance is performed before an anticipated facility restart. Sufficient detail should be included in the integrated maintenance schedule to coordinate activities and track progress. By grouping individual work items and integrating major tasks, more efficient use of technical support and scarce resources should be achieved. The integrated maintenance schedule should form the basis for progress reporting. Effective daily schedules are needed to implement the maintenance activity plans represented by the integrated schedule. Management should track and periodically assess performance to the daily schedule. D.2.3.3 Schedule Requirements The schedule should be a management tool (particularly for first-line supervisors) to control and direct maintenance activities. Management should use it to determine the critical path and explore alternatives when needed. The schedule should be a concise method for tracking completion of maintenance tasks, particularly critical path activities. The following are some of the attributes that should be included in the schedule.  The schedule should be an accurate, living document. Workers should understand the relationship of their tasks to the schedule as a whole; DOE G 433.1-1A 35 9-12-11  The schedule report format should be appropriate for the user. The level of detail in the schedule needed by the facility manager may be different from the level of detail needed by a craft supervisor;  The schedule should be proactive, predicting and leading activities. The schedule should be credible and up to date. It should be based on the best information available and reviewed and accepted by those actually responsible for doing the work;  The schedule should be flexible, within the overall goals of the facility, to deal with unanticipated events and produce optimum results; and/or  There should be one overall schedule developed such that a hierarchy of schedules of varying detail may be obtained from a common database. D.2.3.4 Schedule Methods To be responsive to the needs of management, a computerized scheduling system should be used. Computerized scheduling offers the following advantages:  Rapid update capability;  Ease in exploring alternatives;  Supports resource determination and leveling capability;  Supports identification of work-site congestion; and  Reports tailored to users. All supervisory personnel should have a basic understanding of the schedule program appropriate to their needs and uses. D.2.3.5 Schedule Detail The detail included in the overall schedule should be that required to ensure coordination of work and permit assessment of progress. It is particularly important to include details of tasks that have interfaces among the various craft and support personnel. The following are some examples of the detail that may be required.  The operations manager should be able to anticipate tagout needs;  Radiological protection personnel should be able to anticipate the schedule and need for

RWPs, technician support, and major radiological protection actions, such as installation of temporary shielding;  QC personnel and other inspection groups should be able to anticipate the need for their presence at the job site; and  Critical resource needs, such as overhead cranes and scaffolding, should be described in sufficient detail to avoid interference, conflicts, and work delays. A sufficient number of activities should be scheduled to ensure the short-term visibility needed for work coordination and progress tracking. Use of these intermediate milestones may provide an overall measure of the progress of maintenance activities and identify tasks significantly behind schedule. 36 DOE G 433.1-1A 9-12-11 D.2.3.6 Daily Schedules Daily schedules are important to ensure that work is properly coordinated even when there may be last-minute schedule changes. A daily schedule is generally used as the basis for discussions at daily meetings (e.g., Plan-of-the-Day). A 3-day outlook schedule, updated and issued daily, has proven useful at many facilities. This schedule provides the detail necessary to control the present day‘s work and provides an opportunity for craft planning for the next few days without an unreasonable amount of data. Extending the outlook period further than about 5 days and/or not issuing the schedule on a daily basis increases the risk that data may not be current when needed. A detailed review of the daily schedule should be an integral part of shift turnover activities to ensure that the oncoming shift is familiar with any short-term adjustments made to the schedule. This is particularly important for operator turnovers to ensure that operators know the status of the facility and are familiar with upcoming maintenance activities including tagging needs. D.2.3.7 Schedule Preparation The following items should be considered during the schedule preparation process.  Work items should be coded to identify their discrete locations in the facility and reviewed together to assess the degree of area congestion and to minimize duplication of support work such as scaffolding and insulation removal;  The schedule should be craft loaded and the sequence and timing of activities adjusted to ensure that resource requirements are consistent with resource availability;  Tests, inspections, or other tasks that may identify additional work should be scheduled as early as possible to permit time for completion of the additional work within the established time frame; and  Significant as-found, post-maintenance, and post-modification testing should be explicitly scheduled. Time should be allotted for testing, line up, and other activities required for returning systems to service. System interactions and operator resources should be considered when scheduling system and facility start-up. D.2.3.8 Schedule Integration Integration of major tasks is a key to successful schedule development. There should be one overarching schedule that includes work to be done by both non-facility contractors contributing support to the schedule and site personnel. The planning organization should involve non- facility contractors as early as possible in the planning process to ensure their work is integrated and scheduled properly. Those responsible for the tasks should provide details for specific tasks. The planning organization should integrate these details into the overall schedule.

D.2.3.9 Schedule Review Schedules should be periodically reviewed. Opportunities for schedule improvements should be explored during the review process. This should include review of TSR and other regulatory DOE G 433.1-1A 37 9-12-11 requirements to determine whether changes that may result in work efficiency or schedule improvements are possible without sacrificing safety. The overall intent of the schedule review process, coupled with obtaining user input to the planning process, should be to provide a sense of ownership of the schedule to those who are expected to implement it. D.2.3.10 Format, Progress Reporting, Updating, and Distributing The schedule information provided to users should be concise and understandable. Detailed information should be limited to the needs of the recipient. The fundamental principles of a schedule progress reporting system should be simplicity, accuracy, and timeliness. The individuals responsible for the work should be responsible for progress reporting. The individuals responsible for progress reporting should be identified and trained in the process. Vendors and contractors should be included in the progress reporting system. Progress may be reported in a number of ways depending on the facility needs and on the particular scheduling system used. D.2.4 Guideline – Coordinating Maintenance Activities Facility personnel should be apprised of scheduled maintenance activities that affect them to ensure proper activity coordination. This may be accomplished by publishing and updating a short duration rolling schedule covering about 3 days. The responsible maintenance supervisor should be provided with work packages soon enough for adequate shop level preparation and pre-job instructions before starting the job. Each supervisor should have sufficient fill-in work assigned to maintain crew productivity. If fill-in work has facility conditions requirements associated with it, then it should be identified on the rolling schedule so that all cognizant groups are aware of the jobs. The schedule should allow for unexpected or emergency work requirements. Facility management should identify and approve WRs that could be postponed or stopped to allow the work force to accomplish emergency work. After jobs have been scheduled and assigned on the rolling schedule, the lead group, the group responsible for the most significant portion of the job, should assume the responsibility for support coordination. The lead group should then be responsible for coordinating such activities as verifying that lockouts/tagouts are available as required, that QC inspectors are available as required, and that parts are available at the job site. Daily meetings with affected individuals should be conducted to focus on the progress of key jobs and to provide short-range coordination of scheduled activities. Meetings should be managed to use the time of the managers and supervisors efficiently, to minimize redirection of work in progress, and to prevent delays to oncoming work shifts. Many items, particularly material needed for modifications and repair parts for older equipment, may be long lead-time items. They should be identified and ordered well in advance and tracked to delivery to ensure that they will be available at the job site when needed. 38 DOE G 433.1-1A 9-12-11 Extensive involvement of managers and supervisors in maintenance activities promotes timely

completion of work, quality of completed work, and safety of personnel and equipment. Supervisors should focus on:  Monitoring on-going work to control quality and progress;  Providing accurate and timely status reports;  Coordinating support and interface work activities;  Ensuring the timely availability of tools, supplies, and parts; and  Understanding schedule interpretation and use. Supervisory oversight should include independent verification of such activities as tagouts before opening piping, valves, or mechanical equipment or before working on electrical equipment. D.2.4.1 Pre-job Coordination Line supervisors should consider specific coordination and integration activities in preparing for work include the following:  Effective integration of facility system operation and maintenance activities to ensure proper facility conditions, timely equipment or system tagouts, initiation and completion of maintenance or modifications, and timely performance of inspections;  ALARA actions, including shielding installation and pre-job briefings on ALARA precautions;  Support of maintenance activities by health physics and decontamination personnel, including support during the performance of tasks, identifying and posting work areas, and timely decontamination of tools, floors, and equipment;  Allocation of space and crane use;  Inspection of maintenance activities by QC personnel, including completion of associated documents; and  Continuous document processing, issuing, and closeout throughout the job. D.2.4.2 Material Staging and Availability Convenient staging of the proper materials for scheduled maintenance is one key to success. Responsibilities regarding procurement of material required for maintenance and modifications should be specified. Having one organization responsible for coordinating material needs and a single point of contact for expediting material has proven successful at other facilities and should be considered. Parts and material required for maintenance activities should be identified and purchased in time to allow for receipt and inspection well before they are needed. After processing, these parts and material should be identified for specific work packages and segregated from other stock inventory. Standard stock items and consumables required for planned work should be allocated to ensure their availability. DOE G 433.1-1A 39 9-12-11 Adequate storage and protection of parts and materials segregated for planned maintenance activities should be provided. This is particularly important for material staged at the job site and not within normal storage areas. Periodic reports highlighting any material or parts problems should be distributed to appropriate management personnel. Problems with material availability should be identified early to permit contingency planning. D.2.4.3 Daily Meetings Well managed planning and scheduling meetings are necessary to keep facility personnel aware of significant maintenance activities that are in progress and to make corrections to schedules. Meetings should be effectively managed to limit the time personnel spend in the meetings. Participation in meetings should be limited to those personnel affected. Three types of meetings, discussed below, have been shown to be effective in improving communications among work groups and in enhancing job coordination. A daily directional meeting may be held after the start of the primary work shift. Management

and representatives should attend this meeting from major work groups. It should focus on major jobs and evolutions planned for the next 48 hours and identify any redirection necessary due to significant problems. Results of the directional meeting affecting activities should be factored into the schedule at the daily planning meeting. A planning meeting should be held each day following the directional meeting to review the near-term (next 3 to 5 days) schedule and verify that jobs may be worked as scheduled. Planners and representatives of the operations manager, radiological protection, and other support departments should attend. The participants should ensure the information contained in the next updated schedule is consistent with current plans and resource availability. The schedule should be updated by incorporating information from the directional meeting and the planning meeting. A shift work coordination meeting should be held shortly before the start of each shift. This meeting should be attended by oncoming shift supervision for each of the groups supporting the maintenance schedule, including maintenance, health physics, technical staff, system engineer/engineering, area coordinators, and task coordinators, for jobs requiring significant support. The operations supervisor for the oncoming shift should also attend. This meeting should address all schedule problems for work to be performed by the upcoming shift and should modify the schedule as necessary to reflect last-minute changes. Groups supporting the maintenance should be notified. Each attendee should leave the meeting with a clear understanding of what their work group should do on the upcoming shift. The meeting should end in time for supervisors to return to their work groups before the shift starts. Assignments for problem resolution should be made at meetings, but resolution should not be attempted during the meeting. The meetings should not be used as the primary method to determine the status of maintenance activities. D.2.5 Guideline – Planning, Scheduling And Coordinating Outages Assign responsibility for the overall control of planned and unplanned long-term outages (typically three or more days) and for adherence to the outage schedule. Revise the schedule as required ensuring that the schedule reflects achievable goals and real-time progress. Monitor 40 DOE G 433.1-1A 9-12-11 activities on the critical path and near critical paths at least once per shift during the outage. Structure the outage management system so that individuals responsible for areas of outage work present status reports directly to outage management staff as well as to their line managers. Schedules of past outages (planned and unplanned) should be retained for reference in planning for future outages, particularly for unplanned outages. D.2.5.1 Planned Outages Preparation for and scheduling of major maintenance activities and modifications may have to begin several years in advance, depending on the complexity of the effort. Assign a designated outage manager or coordinator to direct preparations for and management of the outage. Complete engineering work as early as possible. Allow adequate time for review of work packages, resolution of comments, budgeting, contracting, procurement, and other long lead-time planning functions. Maintain a current list of proposed outage activities. It should include all demands for resources

(such as non-nuclear facility contractor and subcontractor resources) and activities (such as corrective maintenance, PM, surveillance, in-service tests and inspections, and modifications). Periodically hold outage-planning meetings to refine and update this list. An initial milestone list that identifies cutoff dates for major activities required to support outage planning should be prepared. This list should include items such as the following:  Identification of major jobs;  Letting of bids for contracts and materials;  Identification of corrective maintenance, PM, surveillance, and in-service test requirements;  Identification of major modifications and dates for design work, work package preparation, and procurement of materials, parts, and services;  Identification of pre-outage work that can and should be performed to reduce the demand for resources during the outage (such as pipe prefabrication, cable pulling, conduit runs, raceway installation, fabrication of supports, and scaffold erection);  Identification of facilities required for outage support and milestones for their construction;  Identification of temporary services that may be required by experienced workers when lockout/tagout of equipment related to the maintenance activity disrupts normal services (e.g., electricity, lighting, air, and water);  Staging of special tools and equipment and preparation of work areas; and  Development of schedules. Develop an overall outage schedule as soon as all major outage activities are identified. Periodic revisions to this schedule should be issued throughout the outage planning process. The schedule should identify and allocate such critical resources as labor, shop facilities, cranes, equipment accessibility, personnel radiation dosage, and availability and scheduling of outside subcontractors and non-facility contractor groups. DOE G 433.1-1A 41 9-12-11 Based on the overall schedule, a detailed outage schedule committing all affected groups should be issued before the scheduled outage start date. Addition of unanticipated work to the outage schedule should require a formal review and approval process. D.2.5.2 Unplanned Outages or Other Limitations to Facility Operations Management of unplanned outages and other facility operating limitations is necessary to minimize the duration of these conditions and to use available time effectively. Facility management or the maintenance supervisors should maintain a prioritized list of corrective maintenance, modifications, surveillance, PM, special items, or commitments that need to be performed under a system or facility outage. Resource requirements, industrial safety considerations, and task completion time for each of the identified jobs should be estimated to aid in planning, scheduling, and coordination. To the extent possible, an up-to-date list of prioritized outage tasks and assembled work packages, including procedures, repair parts and materials, lockout/tagout requests, special tools, and personnel entry forms (such as RWPs or confined-space entry permits) should be prepared. Potential short outage work should be grouped by the required facility condition and approximate duration. Activities should be grouped to accomplish as much work as possible. Other maintenance activities, such as surveillance or PM, should be reviewed to determine whether they should be performed while equipment or systems are out of service.

An unplanned outage work list should be prepared, and outage activities should be coordinated. Facility management should periodically update the list. Copies of the updated proposed outage list, reflecting current planning, should be sent to all affected facility organizations. If an unplanned outage or other major limitation occurs, appropriate facility managers should initiate selected work from the outage list based on the estimated duration of the outage and resources available. Facility management should conduct coordination meetings to determine the critical path and major milestones and to accept or reject any new or significant work to be accomplished. Support requirements should be verified and coordinated among cognizant departments. During the outage, a status should be obtained during each shift to measure progress and to make required adjustments. After completion of each outage, facility management should conduct a critique to determine how outage improvements could be made and designate personnel to implement these improvements. D.2.6 Guideline - Planning, Scheduling, and Coordinating Maintenance Performance Monitoring Facility management should develop performance measures to periodically monitor and report the progress toward meeting facility maintenance goals. The following are typical performance measures:  Rate of activity completion (checked against the projected activity completion, the number of activities remaining, and the time remaining on the schedule to ensure that the current rate supports the scheduled completion date);  Percent compliance to the daily schedule (maintained at a high level to ensure that scheduled work is being completed to support the overall facility maintenance goals); 42 DOE G 433.1-1A 9-12-11  Progress against the schedule (is tracked to identify areas where work completion does not support the schedule);  Amount and rate of bulk work (nonscheduled or listed work) completed (completions should be tracked against remaining resources and time to ensure that bulk work is being completed at a rate that supports the schedule);  Expended worker hours by craft or work group versus planned worker hours (expended worker hours are tracked against the earned value (original estimates) of completed jobs, planned worker hours, remaining scheduled work, and remaining time to ensure that sufficient resources and time exist to complete the maintenance activities as scheduled);  Number of accidental occurrences;  Expended man-rem versus planned man-rem (should be tracked to identify areas of concern where actual values are exceeding projections);  Amount of rad waste generated (should be tracked to identify areas of concern where actual values are exceeding projections); and  Number of skin and clothing contaminations (should be tracked to identify areas of concern where actual values are exceeding projections). The performance measures should be reviewed periodically to ensure they are valid measures of facility maintenance status. Deviations in the expected results identified in reviews of the performance measures should be analyzed to identify their root causes and should be reported to facility management for appropriate corrective action. D.2.7 Guideline -Work Control D.2.7.1 Work-Control Procedure The work-control procedures should, at a minimum, address the following:  Personnel responsibilities for identifying and tagging deficiencies and initiating WRs that

adequately describe the symptoms or problems;  Supervisory responsibility for controlling the safe conduct of maintenance activities and processing WRs;  The process for initiating and processing WRs, including the pre-job review, approval cycle, and post-job review;  The priorities used to schedule work;  Determinations of the impact of maintenance activities on facility operations;  Work planning and scheduling;  Conduct of routine maintenance planning meetings;  Requirements for personnel and equipment safety and radiological protection;  Post-maintenance testing (see Section III.Q, Post Maintenance Testing); and DOE G 433.1-1A 43 9-12-11  Collecting data for maintenance history files (see Section III.L, Maintenance History). The work-control procedure may cross-reference or include outage scheduling and control procedures (see Section III.F, Maintenance Procedures). D.2.7.2 Supervision of Maintenance Activities First-line supervisors should spend the majority of their time in the field. They should monitor work in progress to ensure that maintenance activities are conducted safely in accordance with DOE and facility policies and procedures. Good work practices should be recognized and encouraged; poor work practices should be corrected on the spot. Causes of poor work practices should be identified and corrected; and generic corrective actions should be initiated as needed. Success in safety is achieved by the consistency of policies and procedures applied by supervisors. Examples of work practices that should be checked include the following:  Pre-job briefings and applicable training (e.g., mockup training);  Industrial safety and radiological protection practices (e.g., appropriate use of safety equipment, adherence to lockout/tagout requirements, proper handling of hazardous chemicals, proper use of ALARA concepts, and minimizing spread of contamination);  Worker awareness of their responsibility to immediately notify their supervisor and stop work on any activity that they believe to be unsafe or out of scope, and are to prevent others from performing the activity until appropriate reviews are completed; (For less significant work related issues or questions that may be corrected with minimum effort and time issues a graded approach should be used. Some sites may establish the grading within their stop work process, while others establish a separate time-out/safety pause process for addressing less significant work related issues.);  Quality of workmanship, materials, and parts;  Procedure use, including adherence to step-by-step requirements, signoffs, and work hold points;  Open system and component protection;  Accountability of tools, chemicals, and materials;  Correct tool use for the job (e.g., short, non-sparking tools for batteries and test instruments used on correct ranges);  Clean and orderly work sites;  Work progress and time required to perform the job, especially if an LCO exists;  Work being performed on the correct component, system, or unit;  Adequate documentation of actual work performed; and  Proper use of post-job reporting and, when applicable, post-job critiques. 44 DOE G 433.1-1A 9-12-11 D.2.7.3 Review of Completed Work Requests The equipment owner/operator should compare the work accomplished to the post-maintenance testing or inspection performed to determine that all work is acceptable before returning the

equipment or system to normal service. Maintenance supervisors should review completed WRs for adequacy of repair, complete documentation, notation of generic corrective actions, and identification of rework. A post-job review/discussion should be held with the workers involved to determine whether any unexpected problems or unsafe conditions occurred and/or how the activity can be accomplished more efficiently and safely the next time. Where appropriate and in accordance with facility instructions, other reviews should be accomplished by technical support, QC, safety, radiation protection, and other organizations. Feedback should be provided to planning, scheduling, and maintenance personnel to highlight areas that were exemplary and areas that needed improvement. D.2.7.4 Temporary Repairs For temporary repairs or modifications to the facility, see Section III.H, Configuration Management. D.2.7.5 Control of Non-facility Contractor and Subcontractor Personnel Non-facility contractor and subcontractor personnel (workers not directly employed by the facility operating contractor) who perform maintenance or modifications on facility systems should be trained and qualified for the work they are to perform. This should include general employee training and specific training in appropriate facility administration, safety, QC, and radiation protection procedures and practices. The training required should recognize the individual‘s previous training and experience. Qualified personnel should continuously supervise non-facility contractor and subcontractor personnel who are not fully trained and qualified for the job to be performed. Non-facility contractor and subcontractor personnel should perform maintenance under the same controls as and the same high work standards as facility maintenance personnel. Non-facility contractor and subcontractor managers and supervisors should be held accountable for the work performance of their personnel. Facility supervisors should review the work of these personnel during preparation for work, at the job site, and during post-maintenance testing and acceptance inspections to the extent needed to enforce these requirements. D.2.7.6 Integrated Safety Management System (ISMS) An ISMS is based on the concept that safety requires the involvement of the workers and hands- on contractor line managers. They should determine safe work practices and other hazard mitigating requirements. Safety management should not be an add-on to strategic planning, but a central part of that planning. ES&H considerations should be integrated with the programmatic requirement setting, resource allocation, and budgeting process. Safety should be incorporated into management and work practices at all levels, addressing all types of work and all types of hazards to ensure safety of workers, the public, and the environment. ISMS should be the foundation of the budget formulation and allocation process, and a primary factor in establishing expectations and accountability. The seven ISMS management principles are as follows: DOE G 433.1-1A 45 9-12-11 1. Line management responsibility for safety; 2. Clear roles and responsibilities; 3. Competence commensurate with responsibilities; 4. Balanced priorities; 5. Identification of safety standards and requirements; 6. Hazard controls tailored to the work being performed; and 7. Operations authorization.

Under ISMS, contractor safety responsibilities and accountability should be clearly established. The ISMS functions are: 1. Define the scope of work; 2. Analyze the hazards; 3. Develop and implement hazard controls; 4. Define performance of work within controls; and 5. Provide feedback and continuous improvement. The Safety Analysis Report (SAR) and TSR are part of a nuclear facility‘s authorization basis. The SAR describes the hazard analysis and accident consequence analysis that was conducted to define the conditions under which the facility can be safely operated, and specifies safe operating conditions and parameters. The TSR contains individual operational requirements that need to be met to ensure safe operation. Effective ―Control of Maintenance Activities‖ is essential in ensuring the safe operating conditions and maintaining the facility safety basis. The dependence of a facility‘s authorization basis on periodic maintenance of safety-related systems can be a strong justification for maintenance budget requests (see DOE P 450.4A, Integrated Safety Management Policy; and 10 CFR Part 830, Nuclear Safety Management). D.2.7.7 Human Performance in Maintenance Errors during the performance of maintenance are more prevalent than during typical operations for some of the following reasons:  It involves removal and replacement of a large numbers of varied components;  Performance is usually under severe time pressure;  Work locations are often cramped and poorly lit spaces;  Can involve the use of unusual or unavailable tools;  Vendor manuals and procedures rarely reflect tasks under real life conditions;  Often those who start the job are not the ones required to finish it;  A number of different groups may work on the same item of equipment; and/or  Equipment troubleshooting requires the use of system knowledge and may require actions beyond routine maintenance instructions. 46 DOE G 433.1-1A 9-12-11 Most maintenance errors have been judged by experience workers as having happened before and likely to happen again. The fact that the same errors keep on happening to different people in different organizations strongly suggests that we should focus our remedial attention more upon the task and the workplace, than upon the presumed psychological inadequacies of those making the errors. Maintenance supervisors, work planners, and workers should anticipate the likelihood of human error as a hazard to maintenance. DOE-HDBK-1028-2009, Human Performance Improvement Handbook discusses numerous factors that impact error-free performance and provide tools that may be utilized to improve maintenance. DOE G 433.1-1A 47 9-12-11 Examples of Mechanical Minor Maintenance A. The following are examples of work that may qualify as minor maintenance. 1. Manual Valve: Adjust packing on manual valves not subject to testing, repair or replace handwheel, lubricate valve stem. 2. Pumps: Adjust packing; adjust cooling water flow. 3. Flanges: Tighten to stop leakage (not to exceed recommended torque values). 4. Diaphragms: Seal against in-leakage. 5. Brackets/Hangers: Replace missing bolts (except safety-related/seismically qualified or material substitution). 6. Doors: Repair or replace knobs, hinges, bars, or closures. 7. Plumbing: Repair or replace commodes, water fountains, sinks. 8. Structures: Patch walls, roofs, etc. (except fire barrier seals).

9. Grating/Stair: Treads: Repair or replace grating, clips, or treads. B. The following are examples of work that does not qualify as minor maintenance. 1. Manual Valves: Adjust packing on valves that require testing. 2. Motor-operated Valves: Adjust or replace packing. 3. Pumps: Replace packing or seals, replace casing bolts, replace gasket. 4. Flanges: Replace gasket or fasteners; install or remove blank flange. Examples of Electrical Minor Maintenance A. The following are examples of work that may qualify as minor maintenance. 1. Lamps or Bulbs: Replace. 2. Fuses: Replace where fuse is not required to be safety-related. 3. Junction Boxes (non-environmentally qualified): Replace covers or screws. 4. Conduit: Replace covers, screws, brackets. 5. Motors: Replace air filters, replace cover screws, and replace screens. 6. Facility Paging System: Repair or replace handles, knobs, etc. 7. Portable Sump Pumps: Repair or replace motor or wiring. 8. Door Locks or Latches: Repair or replace (except fire and security doors). 9. Telephone Equipment: Install, replace, or repair. B. The following are examples of work that does not qualify as minor maintenance. 1. Light Fixture: Repair or replace where tagout is required. 2. Fuses: Replace where fuse is safety-related. 3. Fire Alarm Panel: Repair. 4. Protection Relay Test Switches: Repair or replace. Table III.D-1 Examples of Minor Maintenance 48 DOE G 433.1-1A 9-12-11 Examples of Instrument Minor Maintenance A. The following are examples of work that may qualify as minor maintenance. 1. Lamps or Bulbs: Replace. 2. Fuses: Replace where they do not perform a safety function. 3. Pressure Gauges: Replace gauge or glass. 4. Instrument tubing: Tighten. 5. Air Filters: Replace. 6. Knobs: Tighten, repair, or replace. B. The following are examples of work that does not qualify as minor maintenance. 1. Electro-pneumatic Equipment and Positioners: Clean or adjust. 2. Pneumatic Controllers: Clean, adjust, or calibrate. 3. Fuses: Replace when the fuse performs a safety function. 4. Transmitters: Vent or fill. Table III.D-1(continued) Examples of Minor Maintenance DOE G 433.1-1A 49 9-12-11 Example Troubleshooting Guide For work that requires troubleshooting for unknown conditions on energized, pressurized, or operating equipment, perform the following. 1. Use the following sources to develop the troubleshooting methodology: System engineers Owner/operator personnel (organization responsible for the equipment) Training Technical Safety Requirements Final safety analysis report Equipment vendor manuals Equipment manufacturers Applicable procedures Applicable system/circuit drawings Vendor drawings 2. Include the following, as applicable, in the work instructions. Notes, precautions, and prerequisites for the specific task (e.g., ―System contains live steam; do not vent‖; ―Do not exceed three motor starts in any one-hour period‖; ―Do not remove input/output signal cable before de-energizing power supply‖). Steps to record and observe as-found/as-left conditions of the affected equipment. Steps to record any abnormalities observed during equipment operation (e.g., bearing noise, smoke, vibration) Steps to prevent further damage if any abnormal conditions are observed. Specific instructions for craft workers/technicians to stop work when problems or conditions encountered were not anticipated or are not understood. They should be

directed to consult with their supervisors or planners before taking action. Steps to record and verify lifted/landed leads. Lifted lead forms should be included in the work package as required. Steps to record the identification numbers and calibration due dates of measuring and test equipment used Steps to tag and retain all parts removed during the troubleshooting process. These parts will be retained as appropriate for further investigation/analysis by maintenance or system engineer. Table III.D-2 Example Troubleshooting Guide 50 DOE G 433.1-1A 9-12-11 3. For troubleshooting equipment important to safe and reliable facility operation, a troubleshooting impact statement should be included as part of the planning package. Include the following information on the statement: a. scope of the troubleshooting, b. required equipment status, c. work boundaries for the activity, d. potential facility upsets that may occur, and e. approval of owner/operator supervision before beginning troubleshooting activities. 4. Any follow-up corrective maintenance deemed necessary as a result of troubleshooting should be performed under a separate corrective maintenance work order or under an approved revision to the work plan. Table III.D-2 (continued) Example Troubleshooting Guide DOE G 433.1-1A 51 9-12-11 E. TYPES OF MAINTENANCE E.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B, the NMMP must include a process for utilization of appropriate types of maintenance (e.g., preventive maintenance, predictive maintenance, corrective maintenance) to provide for safe, efficient, and reliable operation of SSCs that are part of the safety basis. Types of maintenance generally fall into two categories: Periodic (or Proactive) – scheduled by calendar period, operating hours, or other situational event (e.g. prior to startup) and Corrective (or Reactive) – repairs, alignments, etc. needed when equipment fails or does not perform its intended purpose. Periodic Maintenance includes Preventive Maintenance (PM), Surveillances, and Predictive Maintenance (PdM). The NMMP should address the following: • The types of maintenance used by the facility, their definitions, and applicability; • The methodology for developing balanced maintenance strategies which result in safety basis compliance; high production reliability and quality; and worker, public, and environmental safety; • How PMs and PdMs are selected and assigned appropriate periodicity. Considerations such as operational experience, consensus standards, vendor recommendations, engineering analysis, and cost/benefit analysis are used as a basis to establish optimum periodic maintenance tasks and intervals; • How maintenance activities are scheduled and performed within established intervals; PMs are waived or deferred only with appropriate approval related to SSC significance and amount of delay; • Recording PM activities performed; data collected; and, where appropriate, the ―as- found‖ and ―as-left‖ condition of the equipment; • How using PM techniques and results to assess equipment performance, program adjustments are made and other corrective actions are taken where needed; • How PdM is appropriately used to limit unnecessary PMs; • Expectations for managers and supervisors to routinely observe maintenance activities to identify and correct problems, and to ensure adherence to facility policies and procedures;

• Maintaining and reviewing tracking and trending compliance with periodic maintenance intervals, equipment availability, and maintenance rework and backlog; and • Analyzing missed goals and unsatisfactory trends to identify causes, generic implications, and corrective actions to minimize cost and maximize reliability. 52 DOE G 433.1-1A 9-12-11 E.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT An effective maintenance program provides a high degree of equipment and facility predictability, reliability, and cost-effectiveness. Individual equipment maintenance plans may vary, but should be optimized for the equipment. This maintenance approach may range from: ―Run-to-Failure‖ – for non-safety related, low cost, easily replaceable equipment; to a very proactive plan of ongoing maintenance – for equipment whose failure can impact safe operation, product quality, and facility mission. Many factors should be considered in establishing an effective and efficient balance of the various types of maintenance. For safety related systems and equipment, a thorough technical analysis using a method such as Reliability-Centered Maintenance (RCM) should be used to establish this balance. RCM provides a systematic method for analyzing functions, failure modes, and periodic maintenance to monitor and maintain equipment to ensure it continues to meet its functional requirements. For other equipment, the amount of periodic maintenance may be determined through industry experience, consensus standards, and good engineering judgment; then adjusted based upon results during the operating cycle. The Federal Energy Management Program (FEMP) - Operations & Maintenance (O&M) Best Practices Guide, Chapter 5 provides a good description of various techniques for effective maintenance, including RCM and predictive maintenance options. Follow the linked reference for more information. Elements needed to implement this maintenance program successfully include the following: • The Master Equipment List (MEL) of Section III.C, which includes a listing of all SSCs that are part of the safety basis. The MEL may also include other SSCs that are not part of the safety basis. The MEL should be used as the listing for development of system and component maintenance plans. • A System Engineering Program per DOE O 420.1B, which should take the lead in developing, monitoring, and revising maintenance plans in conjunction with maintenance and operations. The effectiveness of these maintenance plans should be periodically reviewed. • Work control planners should develop standard work procedures for this periodic (recurring) maintenance and ensure it is scheduled at its required periodicity. • Maintenance management should monitor compliance with periodic maintenance schedules and provide input to improve the efficiency of the program. Performance of this maintenance should be evaluated in their self-assessment program. E.2.1 Preventive Maintenance (PM) and Surveillance PMs consist of all those systematically planned and scheduled actions performed to prevent equipment failure. The PM program should define the required activities and the frequency with which they should be performed. Selection of required PM actions should be based on manufacturers‘ recommendations, plant experience, and good engineering practice. PM frequency should be based on adequately implementing the entire program, considering such

elements as regulatory requirements, consensus standards (e.g. NFPA), vendor recommendations, ALARA considerations, and performance monitoring. A documented basis DOE G 433.1-1A 53 9-12-11 for the planned actions should be provided. Further, any deferral of planned tasks should have a technical basis. A Subject Matter Expert (SME) should lead or be directly involved in the establishment of the PM Program and individual PM activities. Effectiveness should be monitored and the program revised if necessary. Surveillance is the term normally used to denote preventive maintenance, inspections, or tests on safety SSCs required by the facility safety basis. These surveillances are important as they help to maintain the safety basis valid and maintain compliance with the TSR, where applicable. Normally, Operations tracks the scheduling and performance of surveillances, in addition to the general work control process, because of their safety basis relationship. E.2.1.1 Determining PM Intervals The initial interval for PM tasks should be established to maximize equipment reliability. The objective of a maintenance program is to increase the availability of SSCs by eliminating hidden faults before equipment fails. Unfortunately, maintenance actions sometimes introduce new failures because of factors such as human error. Therefore, there is a need to establish an effective interval (or frequency of maintenance) that yields the maximum achievable availability. Optimization of maintenance intervals involves the following general activities: • Ranking PM tasks; • Monitoring PM activities, plans, and schedules; • Accessing PM and other maintenance data; • Listing recurring failure modes/parts; • Calculating and monitoring SSC availability; • Keeping track of PM cost; and • Calculating the PM interval by balancing availability, reliability, and cost. E.2.1.2 Scheduling PMs The management of PM scheduling should incorporate the following concepts: 1. A master resource-loaded schedule should be prepared for all PMs. 2. PM work-control documents should be prepared for each task. Since they are recurring and may be used on more than one piece of equipment, they should be designed for easy replication. 3. PM tasks are capable of being quickly sorted and listed by system and required operational condition. This can aid in planning work items during forced outages or unplanned changes in operating conditions. 4. PMs should be scheduled at their nominal intervals and, where practical, with corrective and other related maintenance or testing on the same equipment. 5. PMs that might affect the results of surveillance testing such as lubrication, venting, and equipment exercising should be scheduled to occur following the completion of surveillance testing to avoid pre-conditioning the equipment and affecting the results. 54 DOE G 433.1-1A 9-12-11 6. PMs are intended to be performed at their nominal periodicity (e.g. weekly, monthly, quarterly), using a graded approach. To allow some flexibility for workload and other unforeseeable conditions, the maintenance program documents should define what is meant by each technically based nominal period. Generally, this allowance should not be more than 25% of the PM interval (e.g. monthly equals three to five weeks) not to exceed one quarter regardless of the interval, and should be approved as part of the interval

determination. PMs should be scheduled at their nominal intervals under normal circumstances. 7. Delays in the performance of scheduled PMs beyond their defined period should require escalating approval. For example, approval should be obtained from system engineers, maintenance supervisors, operations managers, maintenance managers, and the facility manager, depending on the length of time that the task is to be delayed and the potential risk involved. 8. Maintenance and operations personnel should be encouraged to recommend changes in PM interval based on real-time observations and conditions. System engineers should evaluate and the operations and maintenance management should approve these proposals. Figure III.E-1 provides a sample form. 9. The Maintenance Manager should report periodically to the Operations Manager any associated problems with performing PM tasks, including the number overdue. E.2.1.3 Performing PMs PMs should be performed using the normal work control processes for recurring maintenance. All involved parties should be coordinated (e.g., operations, radiological protection, QA/QC). Good work practices; such as pre-job briefings, data recordings, cleanliness, correct tool use, supervision, and history update; are essential to the PM task. E.2.1.4 Evaluation of the PM Program PM program assessments should include the overall effectiveness of the program in improving facility and equipment availability, as well as reducing the cost of maintenance. This evaluation should consider PMs that are being performed unnecessarily or excessively, thereby consuming valuable and limited resources that may otherwise be used to upgrade other maintenance programs. Additionally, excessive PMs may increase item deterioration, radiation exposures, maintenance errors, and rework. Items to be considered in the evaluation should include: • Adequacy of PM procedures as deemed by worker feedback; • Applicable QA audit reports and self-assessment findings; • Failure trend reports for facility and industry equipment; • Applicable occurrence, nonconformance, and material deficiency reports; and/or • Deferral statistics and causes. DOE G 433.1-1A 55 9-12-11 Using the results of these evaluations, the following items should be addressed and implemented as appropriate: • Adjustment of PM task intervals; • Redefinition of PM activities; • Addition or deletion of PM activities; • Adjustment of spare parts stocking levels; • Replacement of cost/labor intensive items; • The need for personal protective equipment in performing PM tasks; • Propose design changes; • Identification of special tools; and/or • Revised PM program and/or PM task procedures. E.2.2 Predictive Maintenance (PdM) PdM consists of measurements or tests performed to detect equipment or system conditions. These activities should be less invasive, time consuming, and costly than preventive or corrective maintenance. The results of PdM can be analyzed to determine what degree of maintenance is required and when it is needed. This provides benefits similar to preventive maintenance without performing unneeded maintenance with its cost and potential for human error. Corrective maintenance efficiency may be improved by directing repair efforts (manpower, tooling, parts) at problems detected using PdM techniques. Industry studies have shown significant savings and improved reliability using PdM. PdM should be integrated into the

overall maintenance program so that ―proactive repair‖ planned maintenance may be performed before equipment failure. Not all equipment conditions and failure modes can be reliably monitored; therefore, PdM should be selectively applied. It is normally limited to components and systems that are important to the safe and reliable operation of the facility. The effectiveness of the program is dependent on the accuracy of equipment degradation rate and time to failure assessment. Many different predictive maintenance techniques are used throughout industry. The following paragraphs describe some of the common predictive maintenance techniques. Although the key elements of the program are applicable to all facilities, some of the details may need to be modified to reflect individual facility conditions and needs. Bearing temperature monitoring is a technique used to measure and trend temperatures of critical machinery bearings to predict failure. Changes in bearing temperature may indicate wear due to loss of lubrication, excessive vibration, or intrusion of foreign material into the rotating assemblies. Bearing temperature analysis is often performed in conjunction with the vibration monitoring and lubricating oil analysis/ferrography programs. Infrared thermography is a technique based on the fact that the infrared radiation emitted by a source varies with its surface temperature. Infrared surveys may be performed on heat- producing equipment such as motors, circuit breakers, batteries, load centers, and insulated areas 56 DOE G 433.1-1A 9-12-11 to monitor for high resistance, loose connections, or insulation breakdown. Additionally, this technique may be applied to pinpoint condenser air in-leakage locations and valve leaks. Lubricating oil analysis, ferrography, and grease analysis are techniques used for the early detection of lubricant breakdown and abnormal wear. • Lubricating oil analysis monitors the actual condition of the oil itself. Parameters measured include viscosity, moisture, additive package, and the presence of other contaminants. • Ferrography is a technique used to analyze oil for metal wear products and other particulates. Trending and analyzing the amount and type of wear particles in a machine‘s lubrication system may pinpoint where degradation is occurring. • Grease analyses are techniques used to detect changes in the lubricating properties of grease. Sensory tests such as color, odor, and consistency are most often applied to greases. A penetration test is sometimes used to quantify grease consistency. Grease analyses are often performed on samples obtained from motor-operated valves. Vibration monitoring is a technique used for monitoring and analyzing facility rotating equipment. This technique is used to analyze displacement, velocity, and acceleration parameters to predict the need to correct problems such as bad bearings, poor alignments, or improper balance. In addition to the predictive maintenance techniques already described, various other methods, including the following, may be used as a predictive approach to monitoring facility performance. • Eddy current testing is used to monitor heat exchanger tube wall thickness. • Temperature differential is used as a means of monitoring heat exchanger performance. • Flow measurement is used to monitor heat exchanger and pump performance. • Unit heat rate is used to measure facility steam cycle efficiency.

Acoustic testing is in many cases one of the few techniques that can locate leaks in buried lines. Acoustic testing utilizes various devices that amplify the sound produced by leaking fluids to aid in the detection and location of leaks in buried pipelines. Acoustic testing can be used for leak detection in water, steam, gas and air lines. The Federal Energy Management Program (FEMP) - Operations & Maintenance (O&M) Best Practices Guide, Chapter 6 provides additional discussion and references regarding Predictive Maintenance Technologies. E.2.3 Corrective Maintenance Corrective Maintenance is performed in response to failed or malfunctioning equipment, systems, or facilities in order to restore their intended function and design capabilities. Analysis should be performed to determine the causes of unexpected failure and the corrective action that should be taken, including feedback into the preventive and predictive maintenance programs, and training and qualification programs. The establishment of priorities for corrective maintenance should be based on plant objectives and the relative importance of the equipment. Section D of this Guide provides information on planned and unplanned maintenance DOE G 433.1-1A 57 9-12-11 scheduling. Emergency management procedures should manage equipment failures leading to emergency conditions. This is not to be confused with urgent maintenance, failure of equipment important to safety and/or mission performance. Urgent maintenance may have accelerated processes, but should continue to follow the ISM model for work scope definition, hazard identification and control, and work authorization. A program for identification and timely repair of deficient SSCs should be established. There should be established criteria and responsibilities established for timely review and approval of deficiency reports and work requests. A reliable method should be in place to confirm that all material deficiencies are identified and entered into the work-control system. Inspection criteria, including a process to measure the degradation of standby and passive safety-related systems should be in place, and inspection tours should be periodically conducted to identify any exceptions or deviations. The criteria should include: • Mechanical systems and equipment are in good working order; • Good equipment lubrication practices are being followed; • Fluid system leaks are minimized, monitored, appropriately corrected or controlled, and assessed for impact on safe operations; • Instrumentation, controls, and associated indicators are operable and calibrated as required; • Electrical and electronic equipment are operable and appropriately protected from adverse environmental conditions; • Mechanical operators, fasteners, and supports are in place and operable; • Components, systems, and structures are preserved and insulated; and • Housekeeping is adequate to support reliable system operations. E.2.4 Maintenance of Facilities in Transition Many DOE nuclear facilities are in transition rather than an operational or standby mode. Some of these facilities are large and complex, geographically widespread, and contain potentially hazardous chemical, nuclear, or radiological materials. Their transition includes deactivation, decommissioning, surveillance and maintenance (S&M), demolition, and site remediation. A review should be conducted to provide the safety basis, and physical and administrative

characteristics of the facilities following cessation of operations, but before the disposition begins. The objective of the review should be to identify and evaluate the boundaries of the facility being transferred; its physical condition; the extent, nature, and level of contamination; inventories/estimates of types and quantities of special nuclear, fissionable, toxic, hazardous, and/or radioactive materials; and the appropriate S&M requirements. DOE G 430.1-2, Implementation Guide for Surveillance and Maintenance during Facility Transition and Disposition, provides guidance pertaining to S&M activities. Throughout a facility‘s transition phase, S&M activities should be performed to monitor and document the presence, status, and/or condition of SSCs and hazards associated with the facility. S&M should be adjusted as needed following deactivation, decommissioning, and demolition activities. Continuing S&M should ensure adequate containment of contamination, and potential 58 DOE G 433.1-1A 9-12-11 hazards to workers, the public, and the environment are minimized. As remediation occurs at a facility in transition and the hazard profile changes, the authorization basis and associated S&M requirements should also change to be commensurate with the hazards and impacts to workers, the public and the environment. DOE-STD-1120-2005, Integration of Environment, Safety, And Health into Facility Disposition Activities, provides guidance for integrating ES&H into facility disposition activities. It also provides guidance that addresses authorization basis and its changes during facility disposition. DOE G 433.1-1A 59 9-12-11 Preventive Maintenance (PM) Document Validation and Feedback Form PM Task Number: ___________________________ Work Order No.: ______________ PM Description/Title: ___________________________________________________________ Component Tag Number: _____________________ Component Description: _________________________________________________________ Performers/Discipline: ___________________________________ _______________________________________ ___________________________________ _______________________________________ ___________________________________ _______________________________________ ___________________________________ _______________________________________ ___________________________________ _______________________________________ Evaluation Factors YES NO NA Comment 1. Materials and tools equipment list complete and adequate? 2. Can PM task be performed as written? 3. Procedure reflects current as-built facility configuration? 4. Referenced parts/equipment correctly identified and easily located? 5. Graphic illustrations accurate, legible, and easy to understand? Indicate enough illustrative detail to perform the PM task adequately? 6. Data sheets follow sequentially with the procedure book? 7. Prerequisites, precautions, and limitations clearly identified? 8. Tag numbers, nomenclature, and units/symbols identical to those on the components or instruments? 9. PM frequency adequate? 10. Step, Caution, and Note statements easily understandable? 11. Changes to Work Order required? 60 DOE G 433.1-1A 9-12-11 Evaluation Factors YES NO NA Comment 12. Personnel allocations/ requirements adequate? 13. Concurrent maintenance correctly identified? 14. Editorial/grammatical errors identified? Recommended changes to format, flow, or technical content:

Additional Comments: Resolution/Justification: Resolved by: ________________________________________ Signature Date: ___________________ Figure III.E-1 Sample Preventive Maintenance Document Validation and Feedback Form DOE G 433.1-1A 61 9-12-11 F. MAINTENANCE PROCEDURES F.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B, the NMMP must include the process for developing and implementing documented and approved work instructions for work on safety SSCs (i.e., work packages, procedures, work instructions, and drawings). In meeting this requirement, maintenance procedures should be prepared and used to provide appropriate work direction and to ensure that maintenance is performed in a safe, efficient, and consistent manner. Maintenance procedures should be technically accurate, complete, up to date, and presented in a clear, concise, and consistent manner to minimize human error. DOE-STD- 1029-92, Chg 1, provides information on maintenance procedures. Guidance should be provided for the development, writing, verification, validation, approval, and use of maintenance procedures as required. The guidance should also include such factors as procedure: issuance, periodic review, revision, reference material control, identification, and storage The NMMP should address the following: • A process governing the development of procedures which includes: - Ensuring procedures are clear, concise, and contain adequate information for users to understand and perform their activities effectively; - Verifying technical details such as set points, control logic, and equipment numbers are consistent among procedures, drawings, valve lineup sheets, and system descriptions; - Including hold-points such as quality and radiological protection checks in procedures, as needed; - Incorporating human performance factors into procedures to promote error-free performance; - Documenting post-maintenance/modification testing requirements and acceptance criteria, follow-on steps, and restoration instructions, where appropriate; and - Checking new, changed, or revised procedures to ensure usability before or during initial use. • Control of the review, approval, and revision of procedures and other work-related documents; • How documents used in lieu of or in support of procedures (such as excerpts from vendor manuals) receive the same review and approval as procedures, and are maintained technically accurate and up-to-date; • How effective procedures are clearly identified and maintained readily available for workers; • Management‘s expectations for procedure use; • Identifying actions to be taken when procedures conflict, are inadequate for the intended tasks, or when unexpected results occur; and 62 DOE G 433.1-1A 9-12-11 • Periodic procedure reviews for technical accuracy, human performance factors, and the inclusion of in-house and industry operating experience. F.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT As addressed in DOE O 433.1B, the term ‗maintenance procedures‘ is a generic term for documents providing maintenance directions (e.g., work packages, procedures, work instructions, and drawings). Maintenance procedures should be prepared and used to provide appropriate work direction and to ensure that maintenance is performed in a safe, efficient, and consistent manner. Maintenance procedures should be technically accurate, complete, up to date,

and presented in a clear, concise, and consistent manner to minimize human error. DOE-STD- 1029-92, Chg 1, provide information on maintenance procedures. Guidance should be provided for the development, writing, verification, validation, approval, and use of maintenance procedures as required. The guidance should also include such factors as procedure: issuance, periodic review, revision, reference material control, identification, and storage A balanced combination of written direction, skilled workers, and work-site supervision is required to achieve the quality work essential to safe and reliable facility operation. F.2.1 Guidelines - Maintenance Procedure Development and Writing Maintenance procedures should be written for and used in all maintenance of SSCs that are part of the safety basis in Hazard Category 1, 2, and 3 nuclear facilities. Maintenance procedures should be developed following ISM and the five core functions: define the scope of work, analyze the hazards, establish the controls, perform the work safely, and obtain feedback. Maintenance procedures should extend the five core functions into the planning and performance of work. Using the graded approach, the procedures may include information such as special skill levels required; materials and special tools needed; facility or system conditions and permits needed; and other safety requirements and precautions needed to perform the maintenance. Workers should be involved in procedure development and verification whenever possible. In addition, the procedures should identify system interactions and interconnectivities that could result in equipment/systems undergoing maintenance adversely affecting other SSCs. The maintenance procedures should be clear and concise with the user in mind, to ensure accurate understanding. Experienced workers and engineers can be trained to write maintenance procedures, or procedure writers can be used, with experienced workers or engineers providing technical input. Maintenance procedures should include the following: • Procedure identification and approval status; • Procedure purpose and scope; • Consistent organization, presentation and format; • Clearly understandable text, using correct grammar and punctuation; appropriate level of detail; concise instruction steps in logical sequence; flags to identify instructions steps that need to be performed in a prescribed sequence; specific nomenclature; quantitative and compatible values; referencing methods; coordination of multiple actions; effective formatting; and clear table, graph, and data sheet layout; DOE G 433.1-1A 63 9-12-11 • Clear indication of hold points, warnings, caution statements, independent verification requirements, or data to be recorded; • Nuclear facility and system prerequisites, precautions and limitations, required special tools and materials, and required personnel; • Clear indication of post-maintenance/post-modification testing and acceptance criteria, follow-on steps, and restoration instructions where appropriate; • Applicable operating experience information; • Direction to workers to stop work and notify management of maintenance that cannot be completed as originally planned; and/or • Reference to source information. F.2.2 Guidelines - Procedure Verification Verification is review of a new or revised procedure to determine whether it is technically accurate and in the proper format. The review should ensure the work activity is adequately

described, all hazards are analyzed and controls are established, and that human factors principles and appropriate administrative policies are incorporated. The technical accuracy review should review the procedure against the design requirement for the system or component it concerns. This may be accomplished by comparing the vendor manual and design specifications to the procedure. Verification should be conducted by one or more reviewers who were not involved in writing the procedure but are representative of the intended users. Reviewers from other disciplines, such as health physics, engineering, and operations, should be considered for involvement in the process. F.2.3 Guidelines - Procedure Validation Validation is review of a procedure to determine its usability and correctness. This review evaluates whether the procedure provides sufficient and understandable direction to the worker and is compatible with the equipment or system being maintained. Validation may be conducted in a shop, in a training environment, on a mockup or simulator, or by the worker and supervisor walking through the procedure prior to its approval. In general the walk through of the procedure should be done at the location where the work will be performed to identify any issues with equipment, the procedure, access, unanticipated hazards, controls, etc. In certain hazardous circumstances, such as a high radiation area, it may be necessary to identify any issues without performing the walk through at the work location. F.2.4 Guidelines - Procedure Approval Proposed procedures and changes to procedures, which could affect the performance of safety SSCs, should be reviewed as part of the USQ process. In accordance with administrative procedures, management should approve maintenance procedures. F.2.5 Guidelines - Procedure Use A process should be in place to ensure the worker has the most current procedure prior to performing work. 64 DOE G 433.1-1A 9-12-11 Management should establish and reinforce clear expectations and requirements for the use of procedures to perform maintenance activities. Management should ensure procedure use requirements are understood and met by the workers. Normally, three levels of procedure use are defined: • Continuous use of procedures for activities having direct impact on nuclear safety and reliability or difficult, complex tasks independent of the frequency performed (generally the worker will have the procedure in-hand or immediately available for use in executing tasks); • Reference use for tasks easily accomplished from memory or for tasks for which improper actions pose no immediate consequences to workers or equipment (generally the worker will have the procedure available in the work area for referral as needed); and • Information use for tasks that can be performed without referring to the procedure (generally the worker will cover these procedures in training or preparing to perform work, separate from the work area). Procedures should clearly identify and distinguish between steps or groups of steps that may be performed out of sequence and those that need to be performed in a prescribed sequence. Procedure users should understand the need to use procedures with forethought and good judgment, even when step-by-step compliance is not required. Workers should not proceed with work and should seek supervisory assistance with any situation that is unclear or unexpected.

(See definition of stop work and time out/safety pause.) Supervisors or managers should resolve such inquiries promptly F.2.6 Guidelines - Procedure Change Control, Periodic Review, and Revision Responsibilities for procedure program administration should be clearly defined. Procedure changes (i.e., redlines) and revisions should be controlled in accordance with facility administrative requirements. All procedures should be periodically reviewed to ensure their continued applicability and accuracy. Redline changes and revisions of procedures should receive the same review, approval, and distribution as new procedures with the extent of these reviews varying depending on the extent of the revision. The implementation impacts need to be evaluated and communicated to affected parties (e.g., training and other procedures/forms/processes). Vendor manuals or the portions of a vendor manual and other reference materials used in support of maintenance should be technically accurate, up to date, and controlled. Reference material (e.g., an instruction section of a vendor manual and vendor or contractor drawings) used in lieu of facility-prepared maintenance procedures should receive the same review and approval as facility maintenance procedures. DOE G 433.1-1A 65 9-12-11 G. TRAINING AND QUALIFICATION G.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B and using a graded approach as applicable, the NMMP must include a training and qualification program for maintenance positions specified in DOE O 426.2, Personnel Selection, Training, Qualification, and Certification Requirements for DOE Nuclear Facilities (formerly DOE O 5480.20A). The NMMP should address the following: • That a maintenance training and qualification program should establish and maintain the knowledge and skills needed by maintenance personnel to perform maintenance on all SSCs that are part of the safety basis for Hazard Category 1, 2, and 3 nuclear facilities; • Maintenance is performed by or under the direct supervision of personnel who are qualified on the tasks to be performed; • Maintenance personnel, including temporary and non-facility personnel, are knowledgeable of the following (as applicable to their activities) or escorted by an individual who is: - General plant layout; - Purpose and importance of facility/systems and equipment; - Maintenance policies, processes, and procedures; - Effect of work on facility systems; - Industrial safety, including hazards associated with work on specific; equipment/systems; - Radiological protection and ALARA principles; - Job-specific work practices; - Principles to be used in the identification of potential suspect/counterfeit items; and - Cleanliness and housekeeping practices. • On-The-Job Training activities being evaluated for qualification sign-off are evaluated by personnel qualified as OJT instructors/evaluators; • Maintenance personnel are knowledgeable of appropriate lessons learned from industry and in-house operating experiences (including actual events) applicable to their craft; • Maintenance personnel are capable of troubleshooting equipment problems in a safe and efficient manner; • Continuing Training is performed to maintain and enhance worker proficiencies and qualifications; • Maintenance training is reviewed as part of the facility‘s Self-Assessment Program; and • Periodic systematic evaluations of maintenance training and qualification (not to exceed

three years) in accordance with DOE-STD-1070-94 "Guidelines for Evaluation of Nuclear Facility Training Programs‖ are performed (This may be done as a portion of the periodic evaluation of the overall facility/organization training program). 66 DOE G 433.1-1A 9-12-11 G.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT A balanced combination of written guidance, worker skills, and work-site supervision is required to achieve the quality workmanship essential to safe and reliable facility operation. This section discusses maintenance training program guidance (i.e., worker skills). Many organizations find that applying the same principles from DOE O 426.2 to all levels of maintenance promotes safe and efficient worker performance. Many facilities rely heavily on what is known as ―skill-of-the-craft‖, but have not assessed the actual skill levels of their personnel. For example, it is commonly accepted that an electrician possesses the necessary skills to install wiring and terminal lugs; however, certain electrical products require specialized training and skills to install electrical wires, cables, and conduits (e.g., termination and sealing of various types of medium voltage (5–15 kV) cables; environmental sealing of connections of cables to bus bars rated up to 15 kV in accordance with ANSI C37.20; and sealing connections to medium voltage motors). While work instructions should take credit for the skill-of-the-craft, to reduce the potential for inadequate instructions to personnel, maintenance managers should establish minimum levels of craft proficiency and implement training programs to ensure that the expected craft skill levels are developed and maintained. This baseline skill-of-the-craft training may be coordinated with or conducted by bargaining unit organizations that provide maintenance workers. Specialized and facility- specific training is normally provided by the facility training organization. Some examples of maintenance skills-of-the-craft may include: • Lubricating equipment; • Cutting fasteners to length; • Installing tubing; • Tightening or replacing fittings; • Replacing gaskets, bolting, valve packing, and stationary seals; • Taking electrical readings, such as insulation resistance and voltage; • Replacing fuses and lamps; • Insulating cables (except on printed circuit boards); • Soldering (except on printed circuit boards); and/or • Crimping lugs and splices (non-EQ). Maintenance management should be directly involved in this training program, which should establish and maintain the knowledge and skills needed by personnel to perform maintenance. This involvement should include coordination with the training organization to establish and maintain individualized training and qualification programs, course objectives and content, required reading, On-The-Job Training (OJT) exercises, and schedules. Additionally, maintenance management should routinely provide feedback to improve training program content and emphasis based upon observation of maintenance activities. DOE G 433.1-1A 67 9-12-11 G.2.1 Responsibilities Responsibilities for establishing, implementing, and maintaining the Maintenance Training Program should be clearly defined and understood. The key element for success is coordination between the management of the maintenance and training organizations. Maintenance Managers should ensure:

• Nuclear maintenance is only performed by qualified individuals, or trainees under direct supervision of a qualified worker; • Training Programs are defined and developed for jobs associated with the maintenance of SSCs related to the safety basis of nuclear facilities with emphasis on successful performance in the field; • Individual training plans are assigned to individuals based upon their prospective job assignments and their previous education, training, experience, and skill level; • Required training, including OJT, is appropriately scheduled and attended by maintenance personnel; and • Training-effectiveness feedback is provided to enhance and adjust course teaching methods, content, and emphasis. G.2.2 Training Program Development DOE O 426.2 states: ―All technicians and maintenance personnel must be qualified to perform the tasks associated with their specialty, or work under the direct supervision of personnel qualified to perform the activity or task.‖ ―Personnel who perform work on engineered safety features as identified in the facility Documented Safety Analysis must be trained on those systems/components. Included in this category are systems having a direct impact on the safe operation of the facility. System training must, at a minimum, include the following elements: 1 Purpose of the system; 2 General description of the system including major components, relationship to other systems, and all safety implications associated with working on the system; and 3 Related industry and facility-specific experience.‖ The training program should be established utilizing the Systematic Approach to Training (SAT) Process. The basic SAT elements include: job analysis; performance objectives; training design, development, and implementation; trainee evaluation; and improvement of the training based on the performance of trained personnel in the job setting. DOE-HDBK-1078-94, Training Program Handbook: A Systematic Approach to Training, and DOE-HDBK-1074-95, Alternative Systematic Approaches to Training, should be used to implement a graded SAT approach. Additional implementation guidance (e.g., analysis, learning objective development, developing examinations) can be found on the DOE Technical Standards web site http://www.standards.doe.gov/. Each trainee‘s previous education, experience, and skill level should be reviewed to determine if they can be credited with satisfying any portions of the training program. One method to http://www.standards.doe.gov/ 68 DOE G 433.1-1A 9-12-11 accomplish this is to administer a written examination to prospective employees. Based on the exam results, a training program and milestones for the individual could be established. Training should be defined and developed or obtained to include managerial, supervisory, planning, craft, and other positions, as deemed necessary. G.2.3 On-the-Job Training OJT is practical, hands-on training by which employees learn skills through training conducted within the job environment. OJT is a formal part of maintenance training. This aspect of an individual‘s training is normally conducted in the facility as part of their day-to-day work activities. Accordingly, maintenance department supervisors and selected experienced workers should be directly involved in OJT. Key elements of OJT include the following. • Program Adherence. OJT should be conducted in accordance with formally defined

training programs that specifically identify items the trainee needs to accomplish. Knowledge requirements for each item, as well as the action a trainee is required to do (perform, simulate, observe, or discuss), should be defined. Both the trainer and the trainee should understand what is required for each training item. • Trainer Qualification. OJT evaluations should be performed by personnel who are qualified as OJT instructors/evaluators. Personnel in the training department who have maintenance experience, as well as personnel in the maintenance department itself, may be used as OJT instructors/evaluators. They should have good verbal communication skills and technical knowledge, and should have the ability to provide trainees with effective hands-on experience. • Trainee Supervision and Control. Non-qualified personnel should work under the direct supervision of personnel qualified to perform the activity or task. The trainee should understand how to avoid errors that could affect personnel safety or adversely impact the station. Before performing maintenance on equipment, trainees should discuss the procedure with the qualified worker and talk through required actions by pointing to the control switch, valve breaker, or other component that will be manipulated. Incorrect actions should be discussed, particularly if they could result in a plant transient such as an equipment trip. The trainee should also demonstrate industrial safety and radiological protection aspects of the job (e.g., the equipment to be maintained is properly tagged and isolated, and an RWP is used). When trainees perform maintenance for qualification purposes, a qualified OJT instructor should observe the work so that the trainee properly accomplishes the activity in accordance with OJT evaluation guidance. • Logs and Reports. The qualified worker should review any information recorded by the trainee on official work and data sheets, and should stress to the trainee the importance of maintaining accurate training and nuclear facility records. In addition, they should discuss with the trainee out-of-specification values and their consequences, and the required reporting of such issues. • Number of Trainees. Consideration should be given to the training effectiveness and the effect on the equipment being maintained when a number of trainees are involved in an activity. Limiting the number will help each trainee receive the most effective instruction and will help ensure that the qualified worker is not overwhelmed by having too many DOE G 433.1-1A 69 9-12-11 trainees at once. An individual may be able to handle several trainees for disassembly and assembly of a pump. However, it may be prudent to have only one trainee at a time for work involving a live, high voltage circuit or for conducting safety system surveillances. • Qualified to Conduct Maintenance. The Maintenance Manager should establish a process that only allows individuals to perform independent maintenance on equipment for which they are qualified. This process should specify how supervisors determine that an individual is qualified before they are independently assigned to perform a task. G.2.4 Qualification Maintenance management should review an individual‘s training accomplishments before qualifying them for a given task. Similarly, qualifications of contractor personnel should be reviewed. This review should include the following:

• Verifying completion of all required prerequisite training; • Conducting or evaluating the results of a final written, oral, or practical examination, if required; • Evaluating the recommendations of the individual‘s supervisors; and • Formally approving and documenting qualification. G.2.5 Management and Supervisory Training There should be a formalized training program that provides the necessary training to develop and maintain managerial and supervisory skills. The program‘s training should include, but not be limited to accountability; assessment and observation of routine activities; communication skills; teamwork; and company management styles and philosophies. It should also include position-specific technical areas that enable these individuals to communicate properly with their workers and to carry out their responsibilities. This is especially important to aid first-line supervisors in managing maintenance activities. Career progression planning should be used to help customize the training program for personnel being considered for specific supervisory and managerial positions. G.2.6 Continuing Training Continuing training programs should be established to maintain and enhance the knowledge and skills of personnel who perform functions associated with engineered safety features as identified in the facility safety basis. Process and administrative changes that affect the workers should be included. The guidance in DOE-HDBK-1118-99, Guide to Good Practices for Continuing Training, should be used to develop continuing training programs. Satisfactory participation in this program and work performance, and completion of any periodic prerequisite training (e.g. GET) should maintain worker qualifications following initial qualification. G.2.7 Training Program Approval, Effectiveness, and Feedback The Maintenance Manager should be directly involved in approving and periodically reviewing the Maintenance Training Program. The performance of maintenance personnel should be monitored to identify enhancements and emphases for the initial and continuing training 70 DOE G 433.1-1A 9-12-11 elements as part of the facility‘s self-assessment process. Any performance trends indicating maintenance knowledge or skills that need improvement should be considered during review of the maintenance training. Trainee feedback on their perceptions and suggestions for improving the training program should be obtained. The training organization should address recommendations from the Maintenance Manager for changes to training programs. DOE G 433.1-1A 71 9-12-11 H. CONFIGURATION MANAGEMENT H.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B, the NMMP must include incorporation of the configuration management program to control approved modifications and to prevent unauthorized modifications to Safety SSCs. Implementation of Configuration Management (CM) programs shall be in accordance with requirements of DOE O 420.1B. The NMMP should address the following: • The process to document and maintain plant configuration and handle desired changes, while maintaining the facility safety basis and without increasing risk to personnel, facility equipment, or the environment; • The process to authorize the use of equivalent repair parts, and a method for workers to verify this approval; • The role of the CSE in CM according to DOE O 420.1B; and

• A method to ensure that planners and workers are familiar with the need for engineering review and approval if maintenance will not result in returning SSCs to their design configuration; H.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT Proper CM is integral to the ongoing integrity of the safety basis. Baseline configurations of SSCs that are part of the safety basis should be maintained or changes controlled to ensure they continue to support their safety function with no increase in risk to personnel, facility equipment, or the environment. Nuclear facility maintenance is integral to configuration management in the following ways: • Proper maintenance helps maintain consistency among design requirements, documentation, and the physical equipment; • Proactive maintenance (PM/PdM) staves off degradation and keeps equipment operating within design requirements; • Corrective maintenance returns SSCs to their designed/documented configuration and function; • Work controls ensure intended changes are made and unintended changes are not introduced; • Post-Maintenance Tests ensure SSCs conform to design requirements after maintenance or planned modification; and • Surveillance & Testing verify continuing SSC functionality to design/safety basis requirements. 72 DOE G 433.1-1A 9-12-11 H.2.1 Maintenance Program Interface with Modifications A modification is a planned and controlled change to a facility SSC that is accomplished in accordance with the requirements and limitations of applicable procedures, codes, standards, specifications, licenses, and predetermined safety restrictions identical to or commensurate with those of the item being modified. DOE-STD-1073-2003, Configuration Management, provides detailed guidance for the overall CM Program and will not be repeated here. Generally, the engineering group has cognizance of the CM Program. The maintenance process should address installation and verification of facility modifications based on the complexity of the task, the extent of the modification, and the importance of the equipment, just as is done for normal maintenance activities. Typically, maintenance packages, which implement a design change, have additional commissioning and/or post-installation testing requirements specified by the design change package to validate the operability of the installation. Normal maintenance practices are intended to closeout work with the affected equipment in its original baseline configuration. Replacement parts should be identical to the installed parts unless item equivalency has been reviewed and approved by engineering. The modification process addresses control of activities, which can change SSC configuration. H.2.2 Temporary Modifications Temporary modifications allow equipment to remain in or be returned to service in a condition that is not the same as the currently approved design. They may also result in short-term alterations to facility SSCs such that they do not conform to permanent drawings or other design documents. Temporary modifications should be reviewed (including reviewing for Unreviewed Safety Questions), approved, documented, and periodically reassessed. This ensures that temporary alterations made to facility SSCs do not unacceptably alter or degrade the original design, facility safety (including the safety basis), or reliability. The number and duration of

temporary modifications should be minimized. Temporary and non-standard repairs should be approved and tracked as temporary modifications. Temporary modification control is discussed further in DOE-STD-1039-93, ―Guide to Good Practices for Control of Equipment and System Status‖. The following are examples of conditions that may be temporary modifications to in-service equipment: • Lifted electrical leads or jumpers; • Mechanical bypasses, jumpers, or blank flanges; • Temporary set point changes or disabled annunciators/alarms; • Disabled relief or safety valves; • Temporary equipment or pipe supports; and • Disabled floor drains. DOE G 433.1-1A 73 9-12-11 I. PROCUREMENT I.1 ORDER IMPLEMENTATION GUIDANCE In accordance with DOE O 433.1B, the NMMP must include appropriate integration of the procurement process with the NMMP to ensure the availability of parts, materials and services for maintenance activities. Overall, procurement normally falls under the responsibility of the Materials Management/Supply/Procurement organization. However, as a customer of the procurement process, maintenance should be involved in the aspects of procurement, which impact the parts, materials, and services received; and how they effectively integrate into those processes. Additionally, 10 CFR Part 830.120, DOE O 414.1D, Quality Assurance, and its associated Guide provide the requirements and implementing guidance for the quality aspects of materials management. The NMMP should address the following: • The process to identify, order, receive, store, and install proper parts and materials for work activities while meeting all quality requirements; • Mechanisms to provide for the expeditious procurement of parts and material on a high priority basis when needed; • How materials are stored and identified in ways that result in timely retrieval; • How safety-related parts and components are properly controlled, segregated, and identified in all material storage areas; • Identifying, segregating, and properly controlling flammable, contaminated, radioactive, and other hazardous materials; • How parts and materials issued for installation are properly controlled, and appropriate unused parts and materials are promptly returned to inventory; • Providing input to stock level adjustments, as necessary, to meet facility needs; and • How lessons learned from experience, such as lead times, parts usage, and supplier reliability, are factored into materials management. I.2 ADDITIONAL BACKGROUND/ GUIDANCE SUPPORTING IMPLEMENTATION AND PROCEDURE DEVELOPMENT The procurement process should support maintenance by providing the correct parts, materials, and services in a timely and cost effective manner. Achieving this goal requires efficient coordination from the equipment designers, through processes, which compile a master parts listing, establish and maintain an appropriate supply of these parts, and make them available to the workers in the field. Additional controls are used to ensure the characteristics and quality of materials and services used in all SSCs that are part of the safety basis. 74 DOE G 433.1-1A 9-12-11 I.2.1 Procurement Policy and Procedures Policies should be established for the procurement of parts, material, and services. These policies should be understood by procurement personnel and other personnel who interface with them, such as engineers, maintenance supervisors, and work planners.

Identification of the need for specialized services from vendors should be made in time to provide for solicitation of bidders, and for bidding on and awarding contracts. Provisions should be made when possible for general service agreements so that services can be supplied at short notice. Procedures should be available to describe specific procurement actions and the specific responsibilities of personnel involved in the procurement of special items, such as: • Safety-class SSCs; • Safety-significant SSCs; • Critical spare parts; • Major project purchases; • Routine procurement purchases; • Contracted work and services; and/or • Hazardous materials. I.2.2 Spare Parts Establishing the master catalog of spare parts and appropriate stocking levels requires a significant effort initially and ongoing effort over the life of the facility. The starting point should be the Master Equipment List (MEL), which at a minimum contains a list of all SSCs that are part of the safety basis. This equipment is expanded into its respective subassemblies, components, and piece parts to identify potential spare parts using drawings, manuals, and vendor information. With this list, vendor recommendations, operations and maintenance experience, and engineering judgment, as well as duplicate equipment and common parts used in multiple units, should be balanced to determine the items and amount to stock on hand. Consideration is also required of the lead-time, cost, shelf life, size, and storage requirements for selecting stock levels, as warehouse facilities, their contents, and maintenance compete with other funding priorities. A catalog (electronic or hard copy) of parts, materials, and equipment normally used at the facility should exist with an up-to-date indication of what is available for issue. This catalog should provide a cross-reference listing that contains such information as manufacturer part number, local part number, name, and component or system for which a part is used. This catalog assists in more efficient planning and execution of maintenance activities. Spare parts and stocking levels should be reviewed over the life of the facility to ensure they are effectively supporting maintenance and operations. Usage data should be kept and reviewed to identify unnecessary materials kept in stock. Updates should occur when facility modifications add, remove, or change equipment; or periodic maintenance activities are changed. Maintenance should provide input to this process and recommendations when stocking levels are considered inappropriate for maintenance support. DOE G 433.1-1A 75 9-12-11 I.2.3 Procurement Control To maintain the validity of the safety basis, replacement parts and materials should meet the equipment design criteria. A graded approach is used to verify the critical attributes of these items based upon the importance of each item. Not every piece part of a safety system is integral to the system‘s safety function and may not require the degree of rigor to verify its capabilities as those items that are critical to the safety function. The QA Program should specify the processes used to approve suppliers; upgrade commercially obtained materials; perform receipt inspections; and document, track, and disposition identified deficiencies. Additionally, the terms "like-for-like" or "like-in-kind" should be applied to assure the correct component or part is used.

A process for providing the data that forms the basis for procurement of items, which support all SSCs that are part of the safety basis, and other major purchases (i.e., equipment and construction projects) should exist, typically within the engineering organization. This data should include: • Critical parameters and their acceptance criteria; • Unique or special testing requirements/methods; • Reorder instructions; and • Suspect/counterfeit parts information. Procurement controls should be developed and maintained to help maintenance obtain parts, materials, and services promptly. Consideration should be given to the following: • The ability to track procurement status from receiving through delivery to issue-for-use; • Ability of the procurement organization to track procurement progress and take necessary measures to meet maintenance and outage schedules; • Emergency procurement policies and an expediting process to obtain parts, materials, and services that are needed immediately to support safe and reliable facility operation; • Control and maintenance of QA records to provide documentation for qualified parts and materials, and to ensure traceability of parts and materials; • Assurance that procurement documents and controls prevent the delivery or use of suspect/counterfeit parts; • Segregation and status resolution of damaged, nonconforming, or otherwise deficient items. Technical reviews should be initiated promptly to aid in the resolution of these items; • Retaining special receipt inspection documentation to support future procurement; • Provisions for qualifying nonqualified material (i.e., commercial grade dedication). An effective upgrade process will result in improved availability of quality parts and materials; and • Verification of the reliability of supplier performance. This can be accomplished by audits, inspections, or surveillances of supplier facilities. 76 DOE G 433.1-1A 9-12-11 I.2.4 Receipt and Inspection When parts, materials, and equipment are received, stores personnel should inspect them before they are accepted. This inspection is conducted to verify that the items delivered agree with the approved purchase documentation, are packaged in accordance with purchase order specifications, have necessary product control requirements furnished by the vendor (such as special storage or shelf life information), and appear to be in good condition. In the case of safety items stores personnel and QA should inspect them to ensure that the vendor has supplied what was ordered, that the necessary formal documentation has accompanied the shipment or is otherwise on hand, and that items have been received in an acceptable condition. An acceptance tag or label placed on the received material may be used to signify that the receiving inspection was performed and that the applicable requirements have been met. Maintenance should have access to this documentation. Engineering and maintenance personnel may be needed to assist in the receipt inspection of more complicated parts, materials, and equipment. Recurring or special test/inspection packages may be required for maintenance personnel to conduct and document these checks on received material prior to being released for issue. In some situations, outside facilities/organizations may be used to conduct speci