interrupted implementation, an analysis should be developed and reviewed and approved
by the design authority as soon as possible after the interruption is identified.
220.127.116.11 Operation with Partially Implemented Changes
The design authority must approve partially implemented changes prior to operation.
Documents should be updated and distributed for partial implementation consistent with
the process for documents for uninterrupted implementation. The design engineering
review should confirm that the original technical review is still valid or indicate that a
new technical review is completed and approved.
18.104.22.168 USQ Reviews for Partially Implemented Changes
The contractor should determine if a USQ review is needed prior to operation in the
interrupted condition. The contractor must use the requirements of 10 CFR 830.203 and
the DOE-approved USQ procedures to determine if a USQ review is required.
Implementing Multiple Changes in Parallel
Another area where the contractor must pay particular attention is the parallel
implementation of two or more changes that affect or involve the same structure, system,
or component. In such cases, a single person, such as the Cognizant System Engineer,
should be assigned to oversee the implementation of all changes being made to the
system, structure, or component. In addition, the change control packages should note
any parallel changes that are being made to the system, structure, or component and any
restrictions or limitations on the order of activities from the multiple changes. The
individual assigned to oversee the multiple changes should also sign all field change
notices for any of the parallel changes.
The design analysis for the change must consider any parallel changes and the level of
completion of the change prior to return to operation of the system, structure, or
The quality assurance provisions of 10 CFR 830.122 require contractors to validate work
before implementation and perform acceptance testing. The change control package
should specify the post-modification testing to be performed and the acceptance criteria.
Post-modification testing validates that the system or component performs as intended
and operates within the design requirements after the change is installed and before
turnover to operations. These tests serve as the final and independent check of the
adequacy of the design review for the proposed change.