Readiness Certification Assurance (RCA) Process

The Backstory of the Readiness Certification Assurance Process

The RCA process was born out of a desire to have a high level of confidence that a major half-billion dollar nuclear project would be operationally ready and provide the needed mission capabilities it was being built to deliver. This should be every Project Managers dream, right. Despite obstacles along the way, the process worked to rave reviews and acclaim. To top that, it was also done within budget and on schedule. Dream realized.

So what is this RCA Process?

It is a proven process developed in 2008 within the Department of Energy (DOE) regulatory environment as a means to demonstrate compliance with requirements to certify, with high confidence (i.e., low risk), the operational readiness of a new nuclear (high-risk) facility.

The Department of Energy (DOE) regulates high-risk activities under its jurisdiction via a series of directives. One of those directives (DOE Order 425.1, Verification of Readiness to Start up or Restart Nuclear Facilities) requires that verification reviews be conducted on new or restarted facilities or processes to verify the readiness of that facility or process to safely and compliantly operate. Prior to starting this verification review, the contractor’s management responsible for operating the facility or process must:

Issue a formal written memorandum certifying that the facility or process is ready for startup or restart;
Verify that the preparations for startup or restart have been completed; and
Verify that any prerequisites for safe and compliant operations have been met.

Definitions:

“Certify” management has officially attested or authoritatively confirmed as complying with specified requirements or standards.

“Verify” management has substantiated or confirmed, with evidence, that specific requirements are met.

The RCA process is a means to establish or specify the set of requirements or standards that the facility or process must meet and provide the structure to verify the requirements have been met and to capture electronically the evidence of that verification.

In the case of most highly regulated industries the set of defined requirements are those established by the regulatory agency or in the case of DOE, they are established by the contract between the managing contractor and DOE. Contract requirements are typically implemented through site command media (i.e., procedures) applicable to the scope of the Startup or restart. Other regulatory bodies might issue guides or standards containing the requirements to gain their approval.

Early identification of the requirements that must be met, and in process (i.e., integrated with the project management lifecycle) verification that they are met, are key elements for successfully achieving operational readiness.

Management certification of operational readiness means they have completed a defined and documented process that provides a high level of confidence that should the verification review not be performed, then they could immediately (with no further actions needed) begin the work processes required in a safe and compliant manner that will ensure mission objectives are met.

The Readiness Certification Assurance process is designed to accomplish this systematic approach to verifying that a set of defined requirements applicable to a specific scope of work have been met and quality evidence exists to demonstrate that fact regardless of whether or not the regulatory body will validate the achievement.

Readiness Certification Assurance

Readiness Certification Assurance is a proven process to achieve the systematic approach to operational readiness assurance discussed above. It provides an integrated approach that compliments the established project management framework. The focus of the RCA process is ensuring that the people, equipment, and programs are in place and ready to support operations that meet mission objectives. A major benefit of the RCA process is to mitigate the risk of not being able to operate a facility or process when it is completed. This can be a significant risk for large and highly complex projects in high-risk industries.

Capturing the set of Requirements

In the case of sites regulated by DOE, the Core Requirements from DOE O 425.1 were evaluated against the site specific DOE contract to identify applicable directives, and determine how the requirements from those directives flow into corporate or site Command Media (i.e., procedures). The applicable Command Media define the expected documents (i.e., evidence) and records that would demonstrate compliance.

From the Command Media, Performance Criteria are developed to establish the detailed expectations needed to assure upper level requirements are met. The Performance Criteria each capture the associated source documents (procedures) that contain the requirements along with the expected evidence (documentation) that the Command Media requires to be produced, including the expectations for the content and quality of that documentation.

The performance criteria can also be associated with the specific regulatory requirements contained in agency guides or industry standards. In addition, the evidence for each performance criterion can be binned according to type of document (e.g., Purchase Request, Work Instruction, operating procedure, Maintenance Work Order, etc.), to allow for sorting when the evidence is displayed for a review.

Integration with Project

The RCA process establishes accountability for success. It assigns responsibility to individuals and obtains agreement as to ownership of requirements and expectations for project deliverables, thereby instilling accountability across various organizations for the certification of readiness to operate a facility, or process. The value of the RCA process is to clearly communicate and document expectations and agreement on those expectations and validate that they have been meet in a systematic manner that flows with the project. Most major projects carry risks, one being that when they get to the end they find problems that prevent successful operations. The application of the RCA process is a risk mitigating approach that substantially reduces the risk of problems late in the project life.

Since meeting industry standards and regulatory requirements is already encompassed with the scope of most projects, the documentation needed to demonstrate that each applicable Performance Criteria has been met is typically already required as part of a project deliverable. Thus, the application of the RCA process to a project does not require additional project activities, but rather validates that the proper requirements are captured by the project. In this sense, the RCA process is a network that lays on top of the project framework to ensure that deliverables from selected project activities needed to support operational readiness certification meet quality and content expectations. The RCA process has proven to be an effective means to verify that the Project Work Breakdown Structure (WBS) actually has all the key activities to support the determination of operational readiness. The Project and Readiness Lifecycle diagram illustrates the alignment of the key phases of the Project and the RCA process. As the Project develops its schedule and cost estimates, the RCA process defines the Performance Criteria needed for Operational readiness thus supporting the Project planning. The Performance Criteria are each binned into one of 24 functional areas (e.g., Engineering, Configuration Management, Industrial Safety, Operations, Maintenance, Training, etc.). The use of Functional areas supports the Project by closely aligning the RCA process with typical organization structures, project team representation, and with the manner in which work is accomplished, thus aiding with the integration. The RCA process requires that management “certify” that the Performance Criteria has been met. This means that the management responsible for technical adequacy of the documentation provided must certify that it meets the quality and content expectations. The RCA process then provides for the objective verification that those performance criteria expectations have been met prior to the declaration of readiness to operate.

The Integrated RCA Process

The RCA Process includes three distinct phases, Planning, Execution, and the optional Validation phase. The Planning phase is the initiation of the process and translates the scope of a project into the elements needed to support the RCA process. The Execution phase collects the documentation to support the certification of operational readiness and verifies it meets requirements. The Validation phase is an optional double check on the verification by a RCA Board comprised of a panel of individuals that can represent senior management in validating that requirements have been met.

In considering the volume of documentation required for a typical facility or process, to be effective, the RCA process requires an automated means to manage the documentation and the reviews. Thus, the birth of the Readiness Certification Assurance Process Tracking System (RCAPTS). This web-based software is a DOE copyrighted solution; tailorable to fit projects of all sizes from simple process modifications to new multi-billion dollar facilities.