The Shuttle Challenger explosion was a configuration management issue. The bridge over the Tacoma Narrows nicknamed “Galloping Gertie” had a configuration management (CM) issue. Balconies that have collapsed and soccer stadium stands that have failed all can be tied to poor configuration control issues. In the nuclear power industry we have wrestled with configuration management and control issues for years. Data indicates that a significant number of reported events have resulted from errors in the control and maintenance of the configuration of the physical facility, errors in the original design or design modifications, inadequate corrective actions, inadequate testing, and documentation discrepancies. The lessons learned from neglecting an optimum CM program are well known, including construction delays, plant shutdowns, and expensive design basis reconstitution projects. However, with the development of improved information technologies, we are now at a point to fully execute an integrated program of CM and greatly reduce these types of issues. But are we really ready? Is it a need or just another nice thing to have, especially for the new plants?

Although the importance of configuration management is reasonably understood, there is yet no clear roadmap on how to plan and implement configuration management. There are existing resources and much regulatory guidance on CM related issues. The underlying concepts are actually simple, but like much in the nuclear business execution is more complex and more challenging. For nuclear power plants the driving consideration is whether the as-built plant, with its current equipment lineups, as well as its in-progress evolutions and maintenance, are analyzed and determined to be safe. This basic thread has woven a tapestry of initiatives from design bases and their reconstitution, to as-building of plants, document updates, countless procedural update efforts, PRA models, part 21’s and safety reviews. How can we take 30 years of operating experience and create a program with appropriate tools that will be an efficient use of resources, and improve and assure safe plant operations? There is benefit to getting this correct upfront with the next generation of plants in the US.

Implementing a well integrated CM program upfront in the new plants will pay dividends not only in the design and construction phase of the project, but will benefit the operating organization throughout the plant’s lifecycle. This is readily obvious to seasoned operators and engineers who have spent an entire career wrestling with sticks of drawings and other documents that are less than current, along with the effort necessary to research system and component design, construction and startup considerations. In addition, the one step licensing process requires more stringent control of construction and field changes for new plants. Essentially the plant is licensed and needs to address changes as modifications would be addressed in an operating plant. 10CFR52 and 10CFR70.72 provide regulatory basis for this.

For new plants maintaining the integrity of the COL and Design Certification during construction will be a major challenge considering the history and practices of many of the consortia team members that are participating in the projects. Few new engineering and construction projects have the necessary rigors to match the needs of the COL holder. Few team members have the best framework for accomplishing the tasks at hand while maintaining the as-permitted design. For these reasons it is incumbent on the COL holder to design and implement the CM program and dictate the underlying technologies that will be used to facilitate the program. For the plant owners that believe they have negotiated turnkey EPC contracts, this is one area where delegation to the EPC will spell disaster if project success is defined by schedule, cost or regulatory compliance.

While much can be gained with developing the CM program around design change processes and licensing and construction, the new plant’s operating organization must address the development of all its operational programs and procedures in order to meet regulatory requirements and schedule performance. Depending on the approach there may be owner efforts in the development of the startup test program, the inspections, tests, analyses and acceptance criteria (ITAAC). These operational and startup components must be developed in concert with the construction of the plant and are every bit as critical to the plant’s initial operations. These are also components of a well integrated CM program and may not be on the EPC’s radar screen. By developing the appropriate processes early for the CM program and implementing technologies, the COL holder empowers its operating staff to be able to meet the compressed schedule to operations without waiting for a completed plant.

While we have just begun to touch on CM in identifying issues to consider, subsequent pieces will address key facets of a CM program such as CM policy, design change control and program assessments as they pertain to successful new plant CM programs. Look for additional articles on this website addressing this important issue or contact the author for more information.
Contact: Chris Staubus, BCP’s General Manager at [email protected] or 727-736-3151.

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