Implementation of Changes

DOESTD107393

The management review process should be streamlined to the extent practicable. Management

reviews by many different levels and organizations can dilute accountability for a substantive review and

increase the review cycle duration without adding value.

2.4.2.4 Implementation of Changes

The change package should be reviewed prior to actual implementation of physical changes to ensure

that it is complete and constructible, that there are no unidentifiable physical interferences, and that the

change is likely to meet defined post-implementation acceptance criteria. This constructability review

should be performed independent of the original design organization. A modification or construction

package may be used to define implementation instructions.

Any deviations from the defined change package during implementation/construction should be

identified, reviewed, and approved by the design authority. Provisions for this process, often called field

change requests, should be defined by procedures. Following engineering evaluation and approval,

field change notices should be issued.

As-built documentation should be prepared at the completion of implementation of physical changes.

Post-modification testing should be performed in accordance with methods and acceptance criteria

defined during the change development. If an SSC fails to meet the post-modification acceptance

criteria, it should not be turned over for normal operations until either a technical review and any

necessary follow-up actions have been completed, or the SSC is returned to its original condition and

tested satisfactorily.

Special attention should be given to the partial implementation of changes. Two types of partial

implementation can occur: (1) staged implementation, where availability of time, money, or equipment

dictates that the modification has to be planned and implemented in a staged manner or (2) interrupted

implementation, where the implementation could not be completed as planned for any of a variety of

reasons. Failure to identify this condition and take the proper precautions can lead to the premature

closure of the modification package resulting in an unanalyzed condition, as well as facility

documentation that does not reflect the as-built configuration. Partially implemented changes should

be reviewed and approved by the design authority prior to operation. This design engineering review

should ensure that the original technical reviews are still valid or that new technical reviews are

performed, as necessary.

2.4.2.5 Documentation of Changes

Change documentation is produced at each step of the change process (i.e., identification, review,

approval, and implementation). This is necessary to indicate what is accomplished, to ensure that the

details of the proposed change are established and understood, and to record as-built information.

The change documentation function is established as a unique and separate function within the change

control element to emphasize that change closeout ensures that the change documentation is

complete and all affected documents are identified and updated.

Because essentially every change directly or indirectly affects associated documentation, a major

interface exists between the change control and document control elements. Directly affected facility

documents, such as drawings, are confirmed to be as-built following implementation. Indirectly

affected documents are identified as part of the technical review of changes. The affected documents

should be updated in a timely manner. Critical facility documents, such as drawings and procedures

needed for operation, should be updated prior to placing the SSC in operation.

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