greater cost-effectiveness. Wherever the pilot approach is pursued, priority attention to timely
assessment of the change control functions is warranted.
126.96.36.199 Initiation of Immediate Corrective Actions and Interim Upgrade Actions
The initial assessments should be conducted as planned and directed from the site/division level. If the
initial assessments of programs and procedures reveal major weaknesses that warrant corrective
action prior to the complete development and Implementation of the CM program, management should
initiate immediate corrective actions to mitigate these weaknesses. These immediate measures may
be replaced by Improved processes as the CM program matures.
Priority attention should be given to identifying and stopping uncontrolled and unauthorized changes to
the facility. If the initial assessments determine that uncontrolled changes are occurring, ft facility
should initiate immediate corrective actions, such as implementing an Interim change control program.
An effective approach to interim change control is lo require that nondesign organizations send all
potential changes to the design engineering organization for evaluation. This action may have to
remain in place until the change control element is fully implemented and design reconstitution efforts
An Interim upgrade of existing document control processes may also be necessary to ensure a proper
interface with the change control program and to improve document accuracy or retrievability. Other
areas that should receive priority attention, where major weaknesses are identified, are facility
walkdowns to establish the physical facility configuration and a formal review of summary design
information to establish an initial set of design requirements.
Interim measures are vital to prevent the continuing loss of facility configuration, thereby invalidating
other CM activities such as drawing and procedural updates. To the extent practical, interim measures
should be taken within existing program and organizational structures. In some cases, it may be
necessary to halt existing programs or processes temporarily until upgrade actions are completed.
Interim measures should be replaced by improved programs and processes, implemented within
normal line management structures, as the CM program matures.
188.8.131.52 Facility Program Plans
After the site/division directive is issued, facilities should apply the directive and develop facility CM
program plans. Configuration management program criterion 184.108.40.206.c identifies the topics that should
be addressed by CM program plans. The facility should adopt equipment scope criteria consistent with
the site/division policy directive. The facility should also review the site/division CM policy directive to
determine whether the equipment scope criteria for SSC inclusion can be applied as is or need
modification or clarification at the facility level. The CM program plan should identify the specific criteria
for each design requirement type. The specific list of SSCs is not necessary at this stage of program
Much of the CM program plan will focus on the objectives and description of the CM program activities
needed to develop and implement each program element and function. A CM program plan format
organized by program elements and functions is likely to facilitate efficient application and review. The
development and implementation of each CM program element and function should be consistent with
the program criteria and the CM directive from site/division management. As an example, under the
program management element, the CM program plan should include descriptions of plans for
establishing appropriate interfaces, including vendor control; plans for developing CM governing and
implementing procedures, including associated training; and plans and criteria for CM equipment and