Sample ORR Deficiency Form 2

DOE-HDBK-3012-2003

SAMPLE ORR DEFICIENCY FORM 2

Pre-Start : X

Functional

Objective

Finding: X

Issue No.: CM-1-4

Rev.: 1

Area: CM

No.: 1

Observ.:

Post Start

Date: 1/31/03

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.

REFERENCE(S):

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.

Inspector: __________________________

Team Leader: ________________________