Change Control Element - s1073ch20039

DOESTD107393

2.4 CHANGE CONTROL ELEMENT

The development of the change control element is discussed below in two stages: the initial

development activities and the fully developed program element. The initial development activities

include those actions necessary to identify and evaluate existing change mechanisms. The fully

developed program element entails the activities involved in ongoing, steady-state change control.

2.4.1 INITIAL DEVELOPMENT ACTIVITIES

Major change mechanisms and immediate actions to improve change control will have been identified

by the initial program assessments and described in the CM program plan. This serves as the starting

point for a complete review of existing change mechanisms or processes. During this evaluation,

corrective actions should be Initiated promptly where necessary to prevent unauthorized, unreviewed,

improperly controlled, and poorly documented changes. An overview of the initial development

activities is presented as Figure 213, and these activities are discussed in more detail below.

2.4.1.1 Change Process Identification

A survey should be conducted to identify each change source (such as operations, maintenance,

procurement, procedures, and software) for each major change type (physical changes, document

changes, or design changes resulting in either). Facilities should focus on each change type (physical,

document, or design) individually to determine which sources initiate these changes and which

mechanisms are used to identify, evaluate, and control these changes. Input from each facility

organization should be solicited to identify the change sources and the control processes currently in

use. All change sources, mechanisms, organizations, and control processes that can possibly affect

configuration management should be identified. The identification of change processes is often the

most critical step to achieve effective change control. Change mechanisms that are not identified

cannot be controlled.

Facility personnel should strive to identify subtle change sources that do not conveniently fall in one of

the previously identified sources. Some change mechanisms exist independent of formal procedures

or processes. For example, if the system engineer approves minor changes such as different gaskets,

this should be identified and reviewed as a change source. Mechanisms for temporary physical

changes and temporary document changes should be identified for formal change control.

2.4.1.2 Change Process Evaluation

After the various sources of change have been identified, a determination should be made regarding

which of those processes after the configuration and therefore need formal controls. Formal control

measures should be provided for any change process that affects either (1) the physical configuration,

as defined by the SSCs included in the CM program or (2) the facility documents included in the CM

program. An example of a change mechanism that might be out of scope is the control of scaffolding

that cannot affect an SSC within the CM program (i.e., no system interaction through failing, etc.) or its

associated documentation.

The adequacy of the existing controls should be evaluated against each of the basic change control

functions, depicted in Figure 214 and described in Section 2.4.2. Checklists may be used to ensure

that the evaluations are complete and documented. Any weaknesses or deficiencies should be

identified. For example, if operations or maintenance personnel make undocumented changes to the

facility, existing controls are not adequate and do not meet the objectives of the CM program. Similarly,

if operations or maintenance personnel make changes without considering and documenting whether

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