U.S. Nuclear Regulatory Commission
Title: Gasket Defects
See the memorandum from C. E. MacDonald to A. N. Fasano
dated February 11, 1982. This memo discusses requirements
of 10 CFR 71.54 (c) which is now recodified as 71.87 (c).
A gasket containing obvious imperfections is not "free from
defects." Packages sealed with such a gasket do not meet
the requirements of 10 CFR 71.87 (c).
A licensee contended that a gasket with a circumferential
crack and a missing piece on the outer circumference was
not defective. The licensee did not consider the gasket
defective because the 3 to 4 inch-long crack in the gasket
and the missing 1/4 by 1/4 by 1 inch-piece from the outer
edge of the same gasket did not go through the full gasket
radially. In addition, the licensee stated that criteria
for defining a "defect" is not specified in 10 CFR Part 71
or the Certificate of Compliance. Also, the licensee
referenced a definition of a defect found in 10 CFR Part 21.
Part 71 and the Certificate of Compliance do not provide an
explicit definition of "defect." The definition of
"defect" in 10 CFR 21.3 applies only to Part 21. The
requirement in 10 CFR 71.54 (c) on routine determinations
(prior to each use of the package) states: "The closure of
the package and any sealing gaskets are present and are
free from defects" (emphasis provided). The word "defect"
is defined as "imperfection" in the dictionary. It is NRC
opinion that when imperfections are obvious to the naked
eye, a gasket is not free of defects (see, also, HPPOS-090).
Regulatory references: 10 CFR 71.87
Subject codes: 12.15, 12.17