SAMPLE ORR DEFICIENCY FORM 2
Pre-Start : X
Issue No.: CM-1-4
ISSUE: Uncontrolled changes were made to the wiring of the Denitrator Control Cabinet.
REQUIREMENT: The contractor responsible for a hazard category 1, 2, or 3 DOE nuclear
facility must implement the DOE-approved USQ procedure in situations where there is a
temporary or permanent change in the facility as described in the existing document safety
analysis. Unreviewed Safety Question Determinations (USQD) or USQD screenings are
implemented per Y74-809 for the identification and disposition of modifications in support of
Wet Chemistry Operations. The change control process will ensure that changes are properly
identified, developed, reviewed, approved, implemented, and documented.
· Y15-187, 10 CFR 830.203(d), Y-74-809
DISCUSSION: During observance of the Denitrator Over-temperature Interlock Surveillance,
modifications to the rear of the control cabinet were noted. It was determined that there was no
change requested to install these modifications. They were installed under a maintenance request.
Changes cannot be installed under a maintenance request as it does not provide for engineering
and safety review of the change. Since there was no change request package prepared, there was
also no USQD for this change.
CONCLUSION: As this finding relates to the potential for allowing uncontrolled changes to
XXX SSCs and the safety basis without proper analysis and review, this is a pre-start finding.
Team Leader: ________________________