In Part 1 and Part 2 of this series of articles on the importance of configuration management in new plants, an argument has been made for the importance of a well developed CM program and tools to assure success in the design and construction of the next generation of nuclear plants. Also the importance of a well defined CM policy as a foundation was discussed including the leadership role of the utility owner/operator in the policy development and implementation.
This article in the series is to build on the previous articles and address configuration management as a process. The discussion is to include fundamental processes and functions documented and proceduralized at well run projects to include key inflection or interface points that helps CM to become a project and plant integrating force. Integration of the myriad of processes and programs under CM is critical in projects with consortia, multiple members with a variety of interests and view of what constitutes successful work completion with regard to capital project completion.
Beginning with the End in Mind
The Institute of Nuclear Operations (INPO) has defined configuration management as a process for identifying and recording the characteristics of a facility’s structures, systems, and components ensuring that changes to these characteristics are properly developed, assessed, approved, issued, implemented, verified and incorporated into the facility information. This definition is well constructed for the issues the plants have faced in the past and for corrective actions taken to recover from deficient management of configuration. The definition is equally relevant in new builds because it focuses on an important characteristic of CM, that it is a process and repository.
As a process, CM as most often considered focuses on engineering and design changes plant components, systems and structures these are implemented. This is foundational and must be easily managed and even accelerated by way of a well design configuration management process and system. The control of design, design approval, and development of specifications are all well documented processes with adequate industry guidance and experience, however these are just the beginning. In addition, other functions must be managed in the CM process. For instance including procurement of materials, components and equipment, their receipt, inspection, warehousing, issue, installation and use in construction is a significant CM process especially with modular build projects. While not previously considered directly as a CM issue another consideration should be environmental qualification (EQ). If a component’s EQ is based on storage, shipping and other conditions in order to know its qualified life in the purest sense shelf life, lost of air conditioning in a warehouse could affect the component and hence CM. Thirty years ago this was at times discussed due to the long construction cycles for some projects, but the tools were not available to more than pencil whip the issue in the past. To what degree these types of issues should be included in the CM process and information capture depends on how well integrated the owner would like to see their CM program.
While many would focus on the impacts of design changes on the systems and structures, this INPO definition is more global as it is worded to address such issues as aging of components, impacts of plant and environmental effects on systems, components and structures in performing their functions including abnormal conditions and line-ups. Grasping the greater global breadth and perspective of the INPO definition is necessary to delivery on the potential promise available in an integrate CM program that goes well beyond the design and construction phase of a new build yielding greater benefits in startup and operations. The broader view will permit a well designed configuration management system (CMS) to support the plant in all phases of the lifecycle as a primary tool in plant lifecycle management (PLM) assuring asset management.
From COLA to Operations: It is all about process
In the purest sense, CM needs to begin prior to submittal of the NSSS design certification application (DCA) and Early Site Permit (ESP). Design, design basis, materials, modeling, simulations, calculations and tracking of relevant changes are all made easier with CM firmly instituted. It allows further development of specifications, BOMs, vendor qualification, QA/QC, inspections to progress from a core of information integrating multiple disciplines and functions while progressing in unison. In most cases, the owner/operator has not fully mobilized the project at this point in the lifecycle so the CM tools used are largely for the benefit of the NSSS vendor’s processes. It should be recognized that even at this early stage CM is necessary to assure the DCA must remains consistent with the as designed plant.
Figure 1 below is a simple flowchart representing a plant lifecycle. The lifecycle begins with the DCA and ESP. Plant lifecycle ends with decommissioning. The use of this simple lifecycle depiction is to draw clarity in the concepts and importance of a well integrated CM process. The plant design changes that are manifest in the as-built plant are the obvious aspects of CM that the industry has worked to address for several decades. The changes in the licensing process have driven the development of Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) program from a configuration standpoint to assure what is built is licensed (current regulatory approach) in lieu of licensing what is built (historic regulatory approach). What ITAAC does for design-built relationship of the plant lifecycle a well developed and integrated CM program should continue through to include as operated.
If the focus of a CM program is only managing the early phases of the plant lifecycle a major opportunity is lost. If the driving interest of the CM program is to assure design is matched with the as-licensed plant, the project will struggle with schedule and resources. The broader view helps to assure the “soft assets” match the as-licensed which ultimately is the as-operated plant. In the late pre-COL and early post-COL phase of the plant’s lifecycle work must begin on the development of the “soft assets” or operational programs and procedures. As design changes are made the test program, operational engineering programs, maintenance program, etc. must address the changes. These activities working in parallel during the design-construction phases are needed to assure not only the plant can be completed in a 50 to 60 month window, but the plant is ready for operations at the end of construction without undue delay.
This approach to CM does require owner/operator leadership early in the process. Abdicating this leadership will lead to CM focused only on the early phases of the plant lifecycle with a emphasis on design tools and design control, but not on the integration of functions with appropriate stakeholders necessary for an expedited construction phase and smooth transition to plant operations. This is not because of some conspiracy, but because of perspective of the EPC and NSSS vendor in the beginning phases of the lifecycle.
The broader view of CM provides a foundation and tools that will support every phase of the plant’s lifecycle. Once in operations the plant configuration can be equally fluid especially with regards to abnormal line-ups, out of service equipment and temporary modifications which all have a potential of impacting the risk profile and probability and risk assessment (PRA) operational and maintenance strategies. Managing these less permanent configurations are no less critical to assure the plant has adequate safety margin and does not enter an unreviewed safety condition. In addition degraded conditions in areas of flow and performance of components impact configuration and may be managed in a CM system.
Key Early Phase CM Processes
The CM program can be designed to address numerous processes and become a central clearinghouse for information and status. In addition to the early phase design change process for the NSSS vendor, EPC and other consortia members, CM should be designed to address procurement processes, module/component fabrication, construction, the various levels of turnover of components and systems, testing and ITAAC. In each of these areas there would be multiple aspects for capture including manufacturing and fabrication processes, QA/QC inspections, preliminary NDE inspections, certifications, shipping, results and outcomes of all types. The constant question is whether what is in the plant (or to be installed in the plant) meets what was licensed-designed and that the “as-built” plant performs as intended by licensed-design.
The aspects that would be captured by CM maintain ITAAC in the early plant lifecycle phases and reduces operational and regulatory risk in the operational phases.
Interfaces and Integration
Equally important to having CM in place early is inclusion of key functions and the relevant human assets in the process. A wagon wheel is a good mental model for how centralized information is connected to programs and functions. Omitting a necessary connection would be analogous to a truly integrated project schedule that doesn’t include all the activities. If an activity or function is not included the schedule will not accurately indicate the appropriate finish date. In the CM process if a function is not integrated into the process the gap potentially creates the inability to answer the ultimate question, “Is the plant as to be operated what is licensed?”
For a case in point consider measurement and test equipment (M&TE). M&TE is critical in the testing and validation of performance to design bases and is tightly controlled by procedures. No test engineer would ever consider running a key test with out of calibration or uncertified test equipment. Is proper use of M&TE critical to certifying that the as- to-be operated plant is what was designed and licensed? Of course it is.
Like M&TE, most of the necessary programs and procedures that support execution of necessary functions exist. It is their integration into the CM program along with the interfacing links that should be considered when conceptualizing the CM program. If an instrument is found to not hold calibration, a well integrated CM program would help determine the impact of the resolution of that issue. Since that would impact the ITAAC potentially for multiple components and related systems, an argument could be made it affects configuration and should be integrated with into the CM program.
Continuing with the example, when the instrument issue is identified, the CM system must provide communication to affected individuals/functions such as the test engineer that the instrument problem requires corrective action and conveying the situation to the responsible EPC procurement engineer, QA, ITAAC authority and systems engineer. If the instrument is used elsewhere in the plant or a Part 21 is issued a well designed and integrated CM system significantly reduces the effort to research such regulatory and operating experience reports particularly important with greater standardization of plants.
It is the integration of functions and interfaces creating a powerful communication mechanism that helps to accelerate deployment of not only design changes, but problem resolution. Hence the broader view of CM reduces risk to project schedule and resources by integrating programs and process.
An integrated CM program is a collection of processes most of which already exist for new nuclear plant projects. It is the integration of these processes and functions creating a powerful repository of information and communication mechanism that helps to reduce cycle times in processing changes in design throughout the consortia and project team. This permits moving the implication of those changes faster through the whole project team. The simple plant lifecycle flow depicted in Figure 1 points to the importance of an integrated CM program in condensing the design and construction schedules reducing the risk of delay of the plant becoming operational. It does little good to complete construction in 52 months but then have to wait 12 months to complete necessary operational programs, modifications to the simulator and training of operators because design control was the sole concern of configuration management.
For more information on how BCP Engineers & Consultants might assist in the area of configuration management or other areas critical to capital programs contact: Chris Staubus, BCP’s General Manager at [email protected] or 727-736-3151.
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