Interview with Eugene Yang – Principal Consultant,  KISMET Consulting, Inc.  and former president of the Nuclear Information and Records Management Association (NIRMA)

Eugene, thank you so much for giving us this time.  To start, can you give a brief overview of your background and history working with Document Management and Nuclear Utilities?

I have been working with document management for the vast majority of my 45-year career.  I was initially exposed to the nuclear power industry and document management with Entergy (nee Middle South Utilities), whereupon I embarked on my consulting career with Stone and Webster Engineering, transitioning to The Granite Group as well as Litton PRC, all this focusing on petrochemical engineering and nuclear power utilities.  My wife founded KISMET Consulting in 1994, and I joined forces with her in 1997 when we got married. Since then, I have continued working with clients primarily in the nuclear power generation field.

I have been involved with the Nuclear Information and Records Management Association (NIRMA) for 36 years and was the president back in 1999-2001.

I’ve had some great clients over the years: Constellation Energy; the Nuclear Regulatory Commission; Southern Company; Duke Energy; Evergy, Inc.; Tennessee Valley Authority, and the Emirates Nuclear Energy Corporation, to name a few.

Can you give a brief overview of how Document Management is used in the Nuclear Power Generation industry?

All of us in the US Nuclear Generation industry are tremendously proud of our safety record, and Document Management is a critical part of managing the safe and efficient running of a nuclear power plant.  It is absolutely crucial that employees have access to the correct, approved documents such as Standard Operating Procedures and drawings, as well as maintain records to demonstrate compliance to strict quality assurance regulations mandated by federal law.

There is a constant stream of documentation revisions at nuclear power plants. Replacement parts regularly have different installation and verification steps, and changing regulations impact many existing processes and procedures. Current, approved, and issued procedures are critical; no change to the plant (operationally or structurally) can occur unless there is a procedure in place. Additionally, thousands of records are created daily documenting plant activities that demonstrate the plant is adhering to the high level of safety regulations. The management of these documents and records requires a change control process that can process thousands of requests a day, some needing to be turned around in hours, yet always functioning in a repeatable and quality manner.

Given how Document Management is used, what are some of the key requirements for selecting a Document Management vendor, system and integrator?

Some features and key requirements I look for are:

• Electronic Review and Approval including eSignatures.
• Enforcing major and minor versioning.
• Ability to apply security to different versions of a document (i.e. in-progress and superseded versions must have limited access).
• Change Package Support.
•  Dynamic Workflow.
•  Workflow Status Reporting.
• Audit Trail.
• Annotations.
• A robust search engine that not only searches through both metadata and content (text-readable), but also provides precise results.
• A strong, dependable development and implementation vendor that is well versed in the platform while also having the industry savvy to understand and anticipate deployment issues.

You mentioned Dynamic Workflow.  Can you describe what you mean?

An absolutely critical component of change control for nuclear documents is ensuring that the correct review and electronic signatures are consistently applied in a document change process.  Capturing why a document change is occurring is typically managed by a Change Request document.  The Change Request gathers the information about the change, allowing the change request and subsequent workflow process to adjust based on the gathered information. For example, a change to an electrical maintenance activity may need to be signed off by the head of the electrical department, safety, and the plant manager whereas a change to the retention schedule would be approved by legal, IT and regulatory.  Having the system adjust and automatically determine approvers based on what is changing significantly reduces errors, re-routing, and compliance violations.

How have you seen the Document Management Industry evolve over your career?

When I first began my career, we were in the infancy of electronic document management and really just trying to replace paper and microfiche.  In the 1990’s we saw a surge with clients looking to utilize proven vendors like FileNet or Documentum, and those systems have been around and modified over the last 30 years.

From my work with a recent client, I think many companies are now looking for what’s next and how to reduce the cost and effort of maintaining their own systems, and the cloud is a natural extension to facilitate that change.  With movement to the cloud, my clients are taking a hard look at their existing systems to determine if there should be a vendor change as many of the older vendors have not been able to keep up with the latest cloud trends or technologies.

You just went through an RFP and implementation where the client chose the solutions from Alfresco/Hyland.  Can you share what some of the differentiators were for that decision?

Well, I should share that I have known Ellen Ryan for about 15 years because of her team’s implementation work at multiple nuclear customers and their involvement with the NIRMA organization.  She initially introduced me to the Alfresco suite during a presentation at NIRMA years ago.

In evaluating the Alfresco Content Accelerator for Policy and Procedures, the evaluation team and I were impressed with the complete offering that included integration and migration services, product (Alfresco Content Accelerator), successful nuclear clients, functionality (change request and dynamic workflow), and a key aspect was that the entire stack was AWS hosted, cloud native and implemented using a no/low Code configuration approach.  When comparing the new combination of Alfresco and looking at the other RFP participants, none had as good of a cloud-based change and document control solution and experienced team to help us with our implementation, and frankly, the cost was very competitive.

What should a business know up front when moving from an on-premise solution to the cloud?

Moving to the cloud requires the project team to think about and be aware of different impacts.  Integrations with other systems are unavoidable and need to be thought through, especially when another company is hosting the cloud solution.  Hosting companies, understandably so, need to limit what is installed on their servers and how outside applications push and pull information from their servers. This needs to be thought through and the impacts understood to prevent any surprises later in the project.

Additionally, when moving from an on-premise application to a SaaS or PaaS solution, vendor quotes typically limit the size of the non-production environments. When working in a regulated industry, we require the Test/QA environment to be of similar specifications to production. Understanding how non-prod environments are sized and any cost impacts to increase these environments in number or size should be understood upfront.

Also, know upfront the “off-ramp” approach from the cloud offering. As we have learned in the nuclear industry, document management solutions and systems come and go, and typically a utility may transition from one vendor/product to another.  In what format is the content stored? Is it easily identifiable? Is the metadata in a structure that lends itself to another database management system or scheme? Migrating this information (data and content) becomes ever more challenging as the size of the repository increases (dramatically!) over time.

Lastly, unique to the nuclear industry, we require vital records to be always accessible and available in the event of a disaster and/or internet outage. Cloud backups and redundancy do not fulfill these requirements.  Because of this requirement, some hardware and software must be deployed on-premise. The cloud will not fully remove these dependencies.

Did you have to install a fully redundant ECM solution on premise to meet this redundancy requirement for vital records?

That is one of the biggest selling points to the Alfresco solution. At the NIRMA (Nuclear Information and Records Management Association) conference, I had heard of how Docuvela (formerly TSG) had solved this exact issue for one of my clients that manages a large nuclear fleet of plants.  They did this by leveraging the Alfresco Content Accelerator, migration capabilities (OpenMigrate) and NoSQL/Solr repositories to provide both a read-only portal in the cloud for access to documents outside of the main ECM system as well as a sub-set of documents in a portal locally on a redundant laptop in the control room of every plant. 

This approach was superior to the other cloud approaches we considered from both a cost as well as resiliency perspective.

Any last thoughts to share with our readers?

I think all of us in the Nuclear Generation industry are excited about the realization of the new potential of Nuclear Generation, specifically with climate change issues, exponential demand for electricity (see use of electric vehicles) and using nuclear power to drive yet another carbon-friendly source, hydrogen.  Whether a new, modern, small modular reactor plant is built, or an existing plant is modernized in their processes and solutions, the nuclear plants in and outside of the US will continue to need Document Management and will increasingly look to provide these capabilities via the cloud.  I’m happy to continue to share my thoughts and experience with your readers as the industry makes this transition.