Assuring Facility Conformance

by Damon Haley

                                                                                                   

Two Unfavorable Reports

Unsatisfactory performance was recently reported in two separate situations by two government agencies. Both involve noncon-formances found in regulated facility environments. Department of Energy projects were the focus of one report. The other was commercial nuclear facilities. 

Department Of Energy Projects

The following history was reported in a 1996 GAO (Government Accounting Office) report:

 Of 80 major projects started since 1980, 32 were prematurely terminated. Of the 15 that were completed, there were cost overruns, schedule delays and numerous technical shortfalls.

 Project Failures - Contributing Factors

Based on the GAO report, those in CM would conclude that most of the deficiencies are due to an inadequate CM process; i.e., the CM process for managing changes which impact cost, schedule and/or technical baselines was inadequate.

 CM To Assure Project Stability

The appropriate CM process must be established at the beginning of a project. The CM process provides a foundation-like stability which can withstand the impact of constant changes in personnel and in business processes.

Project team members must be trained in how to use the CM process to assure that conformance to requirements is maintained.                

Commercial Nuclear Facilities

Letter 50.54f, as issued by the Nuclear Regulatory Commission, reports that plant inspections during 1996 revealed various plant conditions which were not in compliance with the licensing documentation and regulations.

In an effort to reduce or eliminate the recurrence of such conditions, the NRC has established a set of information which must be compiled by each operating unit. This information serves to describe how the operating unit is able to assure that their plant conforms to the requirements.

Information Required By The NRC

A. There are five interdependent requirements: Describe the engineering design and configuration control processes.

B. Rationale for concluding that the "basis for detailed design" is properly translated into the appropriate operating, maintenance and test procedures.

C. Rationale for concluding that the detailed designs of systems, structures and components are consistent with the "design basis."

D. Process for identifying problems and implementing corrective actions, including the determination of their cause and actions to prevent their recurrence.

How the overall effectiveness of current processes and programs is measured and how the configuration of the plant is assured of being in conformance with the design basis.          

Consistency Begins With CM

To achieve consistent conformance in a facility, as with any product or process, begins with assuring consistency in the process used to achieve consistent conformance; i.e., CM.

The CM process must be formalized. This means that the requirements which the CM process must achieve must be formally defined; i.e., there must be a CM plan.

The methods for achieving the requirements of the CM plan must also be formally defined; i.e., there must be CM procedures.

Each action which can impact a requirement or a procedure must be authorized; i.e., there must be a business decision.

There must be a way to know that the intended result of each action is actually achieved; i.e., there must be conformance measurements.

The management which enforces the requirements must understand their purpose; i.e., the management which enforces the CM plan must be trained.

The personnel who perform the procedures must understand how to use the procedures to accomplish the requirements; i.e., they must be trained.

Training Through Ownership

Those who "own" the CM plans and procedures must assure that they are clear, concise and valid. Proper ownership must be established.

The best training is achieved when requirements are validated by their owners (creators and users).         

An Ever-Changing Environment

People are constantly changing at a facility. Skills and knowledge change as people change.

Technology and tools are constantly changing. The methods used to accomplish processes, and to measure the results, change accordingly.

Management is also in a constant state of change. It is not uncommon to see overall emphasis change as management changes. This can include changes in the emphasis on CM.

CM Can Never Sleep

CM is not a tool which is to be activated as necessary to correct a nonconformance.

In the name of "saving money," it is not a tool that is to be put back into the toolbox until the next nonconformance comes along.

Show me a quality problem and I will show you a CM problem. Show me schedule problem and I will show you a CM problem. Show me cost problem and I will show you a CM problem.

CM is a process which works behind-the-scenes to make all other processes work.

It is a process for managing requirements, for communicating the requirements to the users, and for assuring that the requirements are achieved.

CM cannot sleep. It must work three shifts per day, seven days per week and 52 weeks per year. If the life cycle is 40 years, CM cannot sleep for 40 years.   

                                                                                                                                                                                                  

Institute of Configuration Management Scottsdale, AZ 85261-5656 Tel: (480) 998-8600 Fax: (480) 998-8923 Email: info@icmhq.com