identify the approved change,
list the systems, and major SSCs affected by the change,
identify any impacts or constraints on current operations,
identify and deviations or waivers that have been approved to originally
provide a status report on the implementation and verification of the changes.
Paying Attention to Partially Implemented Changes
The contractor should pay special attention to partially implemented changes. Failure to
identify and take the proper precautions for partially implemented changes can lead to the
premature closure of a modification package, operation in an unanalyzed condition,
and/or documentation that is inconsistent with the actual configuration.
Two types of partially implemented changes can occur:
staged implementation, where availability of time, money, or equipment dictates
that the modification has to be planned and implemented in a staged manner or
interrupted implementation, where the implementation could not be completed as
planned for any of a variety of reasons.
DOE O 5480.19 defines requirements for conduct of operation, including temporary
modification control. It states:
Administrative control systems should be established for installation of temporary
modifications such as electrical jumpers, lifted leads, pulled circuit boards, disabled
annunciators/alarms, mechanical jumpers/bypasses, temporary setpoint changes, installed
or blocked flanges, disabled relief or safety valves, installed or removed filters or
strainers, plugged floor drains, and temporary pipe supports. Prior to modification, these
controls should provide for communicating the installation of temporary modifications to
the design authority to allow for technical oversight and an evaluation of the impact on
current design activities, and approval of the design modification. These control systems
should make provisions for safety reviews, installation approval, independent verification
of correct installation and removal, documentation of the modification, update of
operating procedures and documents, training, marking of installed modifications, and
the periodic audits of outstanding modifications.
In addition, DOE O 5480.19 contains additional instructions related to control of
equipment status, lockouts and tagouts, and other areas associated with conduct of
operations applicable to partially implemented changes.
184.108.40.206 Design Analysis for Partially Implemented Changes
The change control package for a staged implementation should identify the various
stages of implementation and provide an analysis of the operation at each stage. For