Discussion - s1044cn10013

DOE-STD-1044-93

3. DISCUSSION

A well-established and maintained labeling program is essential for safe, reliable operation

and maintenance of DOE facilities. During the period December 1990 through August 1992,

DOE facilities reported more than 40 occurrences in which ineffective or incorrect labeling of

equipment and piping contributed to errors in implementation of lockout/tagout, maintenance

on the wrong equipment, inadvertent equipment startup, failure of designated safety or

backup systems, or improper operation of facility equipment. The consequences, or potential

consequences, of these occurrences include personnel injury, equipment damage, release of

hazardous or toxic material, and loss of proper control of nuclear materials and processes.

An effective labeling program will clearly identify each component required in the operation

of the facility, warn of specific hazards, and clearly identify emergency equipment. Effective

labeling will enhance training effectiveness and help reduce operator and maintenance errors

resulting from incorrect identification of facility equipment. Effective labeling will help

reduce personnel exposure to radiation or hazardous materials by reducing the time spent

identifying components. Piping labels that identify the contents, or at least the type of hazard

represented by the contents, and the normal direction of flow will aid in preventing or

mitigating leaks and spills. Labels on electrical equipment identifying the applicable feeder

panel or breaker will aid in isolation for lockout/tagout, and will aid in quick and accurate

response to equipment emergencies.

Labels should be designed to present information in a manner that will enhance operations

and maintenance. The equipment names and number designations used on labels should be

consistent with those used in procedures and drawings. Label size, placement, arrangement,

fabrication materials, color coding, lettering size and type style can all affect the usability of

labels. The Electric Power Research Institute (EPRI) report, EPRI NP-6209, Effective Plant

Labeling and Coding, contains research data and illustrations showing how to use labels

effectively in control room and plant environments.

To remain effective, the labeling program must be an ongoing process. Maintenance

activities involving removal or replacement of equipment may also result in loss or

misplacement of component labels. Spills, passage of time, or other environmental factors

may cause labels to become damaged or unreadable. Equipment modifications may result in

new label requirements. Facility procedures should provide instructions for temporarily

labeling components, and a central point of contact to ensure timely response to ongoing

labeling requirements.