Title: Implementation of NFPA Arc
Flash Requirements in D&D
Facility:
WVSNCO / West Valley Demonstration Project
Point of Contact: William
Sullivan, 716-942-4012
william.sullivan@wvnsco.com
Related Support Documents:
Brief Description of Best Practice
Throughout the DOE
Complex, systems and facilities are undergoing safe storage,
lay up and dismantlement activities. D&D project activities
are often faced with unexpected risks and hazards while
dismantlement activities occur. Washington Group
International has developed a team approach to prepare the
project for the D&D stage by implementing a comprehensive
NFPA 70E Arc Flash Site Program that places the entire
facility or system in a “safe to work” condition.
This Arc Flash Site
Program guides the project team throughout the preparation
stages to ensure all electrical sources have been
identified, documented, verified and witnessed as correct.
It is only through implementing this Arc Flash Site Program
that we can safely produce Air Gap boundaries that will
eliminate the risk to workers from injury through contact
with sources of electrical energy.
This process, which
requires a team integration of engineering, operations,
safety and qualified electricians, while rigorous and
time-consuming, is a proven means of enhancing worker safety
and is applicable to D&D work throughout the DOE Complex.
Refer to attached
comprehensive description: “Implementation of NFPA Arc
Flash Requirements in D&D”
Why the best practice
was used
This Best Practice was
initially developed to assist the engineering department,
safety department, maintenance electrician, and instrument
tech with identifying and understanding associated risks
involved with working on or adjacent to electrically
energized components. This topic was quickly integrated into
site standards, including revisions to our Personnel
Protective Equipment (PPE) program and training programs.
What are the benefits
of the best practice
Development of this
practice provided a greater understanding of the risk
involved and provided a knowledge base from which our three
(3) part program was designed: appropriate risk sensitive
training, proper (PPE) requirements, and Procedure
Compliance.
The benefits derived
from this practice include improved understanding of
existing conditions, increased awareness of proper PPE, and
improved site procedures to guide us in our day- to-day
efforts.
What problems/issues
were associated with the best practice
Initial deployment
required dissemination of new national standards. With the
support of our Electrical Safety Committee, this mountain of
information was deciphered and molded into three distinct
categories: Procedures, Proper PPE, and Training Program.
The steps taken to roll
out this program could not be avoided or modified to be
easier. The revisions to existing procedures were performed
in accordance with established Document Change Control
Policies in terms of timing and selected reviewers. The
selection of “upgraded PPE” was based on site requirements
and NFPA 70E. Training was designed to be “work task
sensitive” on three levels of intensity.
In addition to rolling
this effective program out to site employees and after a
thorough interview process, we have integrated the same
level of training for our subcontractors that fall into this
category of exposure and risk.
How the success of
the Best Practice was measured
This “Best Practice” has
evolved into a site-wide safety conscience that is evident
in attitude and attention to procedure and details. The
Electrical and Instrumentation Tech workers in the field
have a new level of comfort, through greater knowledge of
the true risks they work with, the supporting procedures,
and a thorough understanding of proper PPE required to
safely perform their daily activities.
The electrical engineers
that author work instructions are fully compliant with this
program, and ensure that the hazards have been screened,
identified, and inserted mitigating steps to safely perform
the work we ask of field personnel.
As a rule, all work is
performed in a de-energized state; however, if equipment or
systems need to remain energized (i.e.: Critical
Ventilation, Critical Safety systems, Critical Testing, or a
condition that would upset the safety of people or
environment), the safety plan is scrutinized by engineering,
subject matter experts, management, and maintenance. An
approved Energized Work Permit, extensive Industrial Safety
Work Permit, selected PPE, and an Engineering issued work
instruction with proper controls in place are all required.
A detailed field walk-down by all who have a role in this
activity is also required.
Description of
process experience using the Best Practice
Through continuous “on the job” application,
the D&D personnel have come to expect a witness point of
“Air Gap” condition, complete with case-by-case labeling as
part of the turnover phase that authorizes permission to
proceed with dismantlement activities associated with a
given electrical removal. As such, site personnel also
subscribe to the Integrated Safety Management System (ISMS)
culture of “Stopping the Job” – or Stand Down - if the
worker encounters an unsafe condition and will not proceed
with a given work activity until issues are resolved.
Initially our program erred on the side of
over protection to the point of being cumbersome. Until the
actual case-by-case energy calculation was complete
(magnitude of arc flash), the program required us to follow
the generic tables published by IEEE and OSHA in the body of
NFPA 70E, which requires a greater level of PPE.
The roll-out of training played a large part
in kick starting our program and provided for common base
line for all site personnel required to perform daily tasks
associated with electrical risks. This concurrent state of
training provided for a cultural mindset that was easily
accepted.
Our personnel immediately embraced this
program and have an excellent attitude toward being safe in
our work place.
While performing an air-gap isolation for D&D
safeguard, this best practice quickly became second nature
to the qualified electrical or instrument personnel.
Whether we work directly on energized components or work
adjacent to exposed energized components, the policy
requirements are strictly followed. As such, our practice
requires us to treat the system and equipment as if
energized until proven otherwise. It is common practice to
find our personnel donning NFPA 70E PPE in order to open a
door to electrical equipment to perform a task as simple as
checking for zero volts.
Our site attitude is to always question and
challenge the action until proven successful and acceptable
on all levels. This mindset allows us to question
ourselves, question each other, and challenge the obvious.
The authors of work instruction packages are
qualified within their respective discipline to define
required work scope. Authors of electrical work instruction
packages are NFPA 70E certified and knowledgeable in the
hazards of Arc Flash mitigation. All electrical work
instructions undergo a strict level of review and walk down
by Peers, Subject Matter Experts, Work Group Supervisors and
electricians / instrument techs that will actually perform
the task, on behalf of hazard identification and development
of necessary controls to eliminate or mitigate the
associated risks.
All hazards and risks are documented and
recorded in the actual work instruction, on Industrial Work
Permits, and on Energized Work Permits as necessary.
Further, a critical part of our practice is
feedback. Our program integrates the feedback component of
ISMS into all phases of our work. The initiating author
develops the work scope due based on knowledge and interview
feedback. The drafted work steps undergo critical review
and additional feedback before the document can be issued
for use.
Conclusion
After a full year of development, we’ve
successfully implemented this new Arc Flash program and
have been fully compliant for more than a year. As a site,
we recognize the level of risk scattered across the facility
and embrace the right way to co-exist with said risk.
