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Design Change Management in Regulation of Nuclear Fleets

The 60-year life of a reactor means that a plant will undergo change during its life. To ensure continuing safety, changes must be made with a full understanding of the design intent. With this aim, regulators require that each operating organization should have a formally designated entity responsible for complete design knowledge in regard to plant safety. INSAG-19 calls such an entity the ‘Design Authority’. 

This requirement is difficult to achieve, especially as the number of countries and utilities operating plants increases. Some of these operating organizations will be new, and some will be small. For Generation III plants sold on a turnkey basis, it is even more challenging for the operating company to develop and retain the full knowledge of the design of the plant needed for this role.

CORDEL’s Design Change Management Task Force is investigating options for effective design change management with the aim of supporting design standardization throughout a fleet’s lifetime by means of enhanced international cooperation within industry and regulators. This report starts with considering the causes of design change and identifies reasons for the increased beneficial involvement of the plant’s original vendor in the design change process. A key central theme running through the report is the definition of responsibilities for design change. Various existing mechanisms of vendor-operator interfaces over design change and how they are managed in different organizational and regulatory environments around the world are considered, with the functionality of the Design Authority role and its impact on owners, designers, and Owners Groups being central. The roles played in the design change process by vendors, utilities, regulators, Owners Groups and other organizations such as WANO are considered. In addition, the aerospace industry approach to Design Authority has been assessed to consider what lessons might be learned.

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