DOE O 422.1 Chg 2 (Admin Chg), Conduct of Operations

In Attachment 2, Appendix A Step 2.e.(1) On-Shift Training. Attribute b. states, For positions requiring operator certification, candidates receive on-on-one instruction on station." This is only required when the operator I son watch with the trainer. The Guide to Good Practice identifies that more than one-to-one is allowed.

The Order also allows more than one trainee per trainer in Appendix 2, paragraph 2.e.(4).c

Paragraph 2.e.(1).b requires on-shift training for certain operators. Even if more than one trainee is with the instructor, each would receive "one-on-one" training on station when performing on-shift training.

I am new to DOE requirements and documents and would like to clarify requirements associated with DOE O 422.1. Specifically, where this DOE Order requires "checklists" or system alignments to be used for controlling the position or status of plant equipment, is it the intent of this DOE Order to exclude "computer controlled equipment" from this requirement ? For example, do I need to establish a documented baseline configuration for ALL configurable plant equipment, such as pumps, fans, heaters and valves, including that equipment that can be remotely operated using the station computer network ? Does the requirement to use a checklist or system alignment pertain and apply ONLY to manually operated equipment ? Thanks in advance.

No reference is provided in the comment, but it appears to refer to Appendix 2, paragraph 2.h.(2) for initial system alignments and maintaining control of system status. The requirement in 2.h that "...operators ... ensure facilities operate with known, proper configuration..." flows to 2.h.(2).b where checklists are mentioned for initial alignments and rechecks. Knowing initial and follow-on configuration of equipment is required for all equipment in a facility, whether manually or remotely operated. Operators should determine the desired configuration (on off, standby, remote/local control, open, shut, etc.) for startup, and maintain control through operations to shutdown. In the case of automatic systems, the control system configuration also should have alignment checklists to ensure they are on line, operating in the proper mode, and any variable control inputs (switch positions, digital input selections, etc.) are set properly. See section 2.j on Independent Verification for guidance on verifying critical equipment configuration.

Can locks used to control equipment status be hung on components in the field without an associated tag.(i.e.. lock a valve in the closed position). The question is really, can you hang a lock on a component and not hang a tag with it to identify the component, who hung the lock and who authorized the lock.

Earl Hughes says: Jul 19, 2017 02:21 PM

DOE follows the OSHA rules for control of hazardous Energy, 29CFR1910.147. The Rule section 1910.147 (c)(5)(ii) requires "Lockout and tagout devices shall indicate the identity of the employee applying the device(s)"
Lockout devices with no tags could be mistaken for vandalism and removed. Only an accompanying tag identifying the worker who installed a lockout device and that it is an authorized lockout ensures other workers know that the lockout device is there to protect against hazardous energy and must be left alone.

I concur with Mr. Hughes that a lockout device should have an accompanying tag to indicate not only the associated lockout/tagout identity but also the date and identity of the person placing the lock and tag. In the case of a personal lock placed for a simple lockout/tagout (on onto a lockbox for a group LOTO) our program allows the use of a personal danger tag, a lock body wrap sticker or lock body stickers (as supplied with some Master danger locks) as long as the two criteria of NFPA 70E and 29CFR1910.147 are met: 1) labeled as "Danger Do Not Remove" and 2)identity of person placing the lock.

In attachment 2, 2. SPECIFIC REQUIREMENTS, e., does “on-shift training program” apply only to formal OJT that has a teaching and a testing component, and NOT to evaluations where there the teaching component (unlike OJT) is not formal or documented, thereby negating the need for the evaluator to be qualified to the same level of qualification the trainee attempting to achieve, e.g., evaluator a forklift operator but not formally qualified or authorized to operate the forklift?

Posted on behalf of Earl Hughes -

The section on Control of On Shift Training applies to situation where persons under instruction operate actual facility systems and equipment. In the situation the Anonymous commenter proposes, it appears that the forklift operator could be evaluated under conditions where they would not affect facility systems or equipment, and thus would not be "on shift" in the sense meant in Attachment 2, paragraph 2.e. In Paragraph 2.e, "on-shift" doesn't just mean working one's assigned work schedule; It means performing as part of the assigned "shift" or "crew" operating a facility.

DOE-STD-1029-92 referenced in Attachment 2, Page 9 Section P, was archived in 1999 in favor of Procedure Professionals Association (PPA) voluntary consensus standards PPA AP-907-005

That isn't quite correct; Standard 1029 was cancelled in July 2015, and a change was drafted to revise the reference in Order 422.1 to refer to the PPA standards instead. The change was not approved by management.

In attachment 2, 2. SPECIFIC REQUIREMENTS, e., for control of on-shift training does use of the term “facility operators” mean this section only applies to positions identified as “operators” in accordance with DOE O 426.2 but not to technicians or maintenance personnel?

No. The Conduct of Operations Order applies to more than nuclear facilities, while Order 426.2 applies only to nuclear facilities. The section on control of on-shift training is intended to prevent problems that arise from persons under instruction performing actual operations on operating systems and equipment, whether in a nuclear or non-nuclear facility.

While it has been stated that 422.1 applies to more than nuclear facilities, and requirements of on-shift training applies to technicians and maintenance personnel, I would like clarification of a similar question. Does "Shift Routines and Operating Practices" apply to maintenance and construction personnel. There appears to be confusion as to the definition of "operators" in this section, with some taking the same interpretation that it applies only to "operators" as defined by DOE O 426.2. Others have taken the position all "operator" requirements of DOE O 422.1 apply to all workers who perform any form of operations, be it plant operations, maintenance operations, or construction operations.

Posted for Earl Hughes -

The meaning of “operator” in DOE O 422.1, Conduct of Operations, depends on the context, but in no case does it mean only the same thing as “operators” as defined in DOE O 426.2, Personnel Selection, Training, Qualification, and Certification Requirements for DOE Nuclear Facilities. Order 426.2 applies only to nuclear facilities, while Order 422.1 can also apply to non-nuclear facilities. Order 422.1 explains in Attachment 2 that the general term "operator" means not an individual, but the organization responsible for operation of a facility. This term is used because the Order is applicable to both Government- and Contractor-operated facilities, and rather than include a Contractor Requirements Document and a separate nearly identical set of requirements for government-operated facilities, the Program Requirements are couched as requirements for the Operator, which can be either a contractor or Federal organization. This general term is used in the Attachment 2 high-level requirements in the form of “The operator must…” followed by the requirements.

In the more detailed passages in Attachment 2 and Appendix A, the text refers to "shift operators, operating personnel, facility operators, or operators" in the sense of individual people rather than an organization, and it means persons whose duties include manipulating facility controls, monitoring parameters, and operating facility equipment (similar to, but broader than, Order 426.2). In general, this would not include construction personnel performing basic excavation, form building, concrete placement, steel erection, carpentry, and the like, but it is possible that some construction work could be considered “operations” and the personnel “operators,” depending on the situation. Maintenance personnel working on operating systems in an operating facility, or performing maintenance on a shut-down facility, when operating or shift personnel were still “on watch” to operate equipment during the shutdown or maintain the status of the facility, would also be “operators” subject to the requirements of the Conduct of Operations program. Facility management should make reasoned, defensible engineering decisions on who the "operators" are, and the Department of Energy line management should review this during their review and approval of the local Conduct of Operations implementation. The “Shift Routines and Operating Practices” section of Order 422.1 is intended mainly for personnel operating a facility, but some items apply to everyone working in a facility, whether they are operators who stand watch, maintenance workers, or even visitors. Everyone should be aware of the requirements to follow safety requirements, proper authority to operate equipment, and professional and disciplined performance of duties. Further, maintenance workers should properly follow work orders (procedures) and properly follow requirements for cross-checking instrument readings and taking action when they are inaccurate or malfunctioning. The specifics of the situation that generated this question involved maintenance personnel following a work order (procedure) who did not stop work upon receiving questionable instrumentation readings, and did not take action for a defective instrument. Facility management should carefully consider the consequences of narrowly construing the applicability of Conduct of Operations principles. There are many people besides the designated operators who can avert injury or equipment damage by following Conduct of Operations principles.