Part 21 Report - 1997-491
ACCESSION #: 9706270226
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USEC United States
Enrichment Corporation
2 Democracy Center
6903 Rockledge Drive
Bethesda, MD 20817
Tel: (301) 564-3200
Fax: (301) 564-3201
JAMES H. MILLER
VICE PRESIDENT, PRODUCTION Dir: (301) 564-3309
Fax: (301) 571-8279
June 24, 1997
SERIAL: GDP 97-0106
U.S. Nuclear Regulatory Commission
Attention: NRC Operations Center
Washington, D.C. 20555-0001
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002
Initial Notification of 10 CFR 21 Report
The purpose of this letter is to provide initial notification to the
NRC in accordance with 10 CFR 21.21(d)(3) of a reportable defect that has
been identified at the Portsmouth Gaseous Diffusion Plant (PORTS). The
defect is associated with Release 21.1 of the STAAD-III structural
analysis program supplied by Research Engineers, Inc., 22700 Savi Ranch,
Yorba Linda, California, 92887-4608. This program is being used to
evaluate the existing crane support structure at the X-326 ERP Withdrawal
Station as part of an ongoing project to replace the existing liquid UF
sub 6 handling crane at this location.
An error was identified in Release 21.1 of the STAAD-III program
which yielded non-conservative results. If the results provided by
Release 21.1 of the program had been used as input for the design of the
crane support structure, the margin of safety could have been reduced and
the potential to drop a cylinder containing liquid UF sub 6 could have
increased, thereby creating a substantial safety hazard.
The Paducah Gaseous Diffusion Plant has been apprised of this
situation. The associated PORTS 10 CFR 21 evaluation checklist and a
copy of the pertinent PORTS problem report is enclosed.
Offices in Livermore, California Paducah, Kentucky
Portsmouth, Ohio Washington, DC
U. S. Nuclear Regulatory Commission
Attn: NRC Operations Center
June 24, 1997
GDP 97-0106 Page 2
Any questions related to this subject should be directed to me at
(301) 564-3309 or Mark Lombard at (301) 564-3248.
Sincerely,
James H. Miller
Vice President, Production
Enclosures: As stated
cc: NRC Region III Office
NRC Resident Inspector - PGDP
NRC Resident Inspector - PORTS
ENCLOSURES
PORTS PART 21 CHECKLIST AND RELATED PROBLEM REPORT
UE-141 (11-22-96) 10CFR21 97-0013
10 CFR PART 21 EVALUATION CHECKLIST
Page 1 of 2
The following questions provide the criteria for evaluation of 10 CFR
Part 21 reportability:
A.1 No Yes Has the NRC already been informed of this condition
pursuant to 10 CFR 21 (for example, by a supplier)?
A.2 No Yes If yes, has USEC or LMUS been named as a recipient of
the defective item?
A.3 No Yes Has this condition already been reported to NRC in
accordance with procedure UE2-MC-RE1030?
If the answer to Questions A.1 and A.2 are "Yes", or the answer to
Question A.3 is "Yes", the condition need not be reported under
10 CFR 21. Attach objective evidence of notification of the NRC and
complete Part E.
If the answers to Questions A.2, A.2, and A.3 are "No", continue with the
evaluation.
B.1 No Yes Is the identified condition a deviation or failure to
comply associated with a basic component (including
design, analysis, inspection, testing, fabrication,
replacement parts, or consulting services)?
If the answer to Question B.1 is "No", the condition is not reportable
under 10 CFR 21; attach basis for conclusions and proceed to Section E.
If the answer to Question B.1 is "Yes", continue the evaluation.
B.2 No Yes If the answer to Question B.1 is "yes", has the basic
component been delivered to USEC/LMUS and accepted
for use in the plant or an activity (includes USEC-
dedicated commercial grade items)?
If the answer to Question B.2 is "No", the condition is not reportable
under 10 CFR 21; attach basis for conclusions and proceed to Section E.
If the answer to Question B.2 is "Yes", condition is potentially
reportable. Continue with the evaluation.
C. Further, does the activity or basic component contain any of the
following types of conditions? (Deviation means a departure from the
technical requirements included in a procurement document)
No Yes 1) The installation, use, or operation of a basic
component containing a deviation?
No Yes 2) A condition or circumstance involving a basic
component that could contribute to exceeding a
safety limit as defined in the GDPs Technical
Safety Requirements (TSRs)?
No Yes 3) A failure to comply with my applicable
regulation, order, or certificate issued by the
NRC?
If all of the answers in this section are "No", the condition is not
reportable; attach basis for conclusion and proceed to Section E. If any
answers are "Yes", continue with the evaluation.
UE-141 (11-22-96) 10CFR21 97-0013
Page 2 of 2
D. Could the deviation or failure to comply create a substantial safety
hazard resulting in any of the following (assume there are no
redundant or back-up systems):
No Yes 1) Exposure in excess of 10 CFR 20.1201 limits
No Yes 2) Exposure of an individual in an unrestricted
area no more than 0.5 rem in one calendar year
(10 CFR 20.1301(c))
No Yes 3) Release of radioactive material to an
unrestricted area in excess of the limits in 10
CFR 20, Appendix B, Table 2
No Yes 4) A deficiency which seriously compromised the
ability of a UF sub 6 confinement system to
perform its designated function
No Yes 5) Other (explain)
If all answers in this section are "No", the condition is not reportable;
complete Part E. If any answer is "Yes", condition is reportable.
Continue with evaluation.
E. Evaluation results and recommendation. Recommend condition be
reported?
No Yes If answer is "Yes", sign this part and continue to
follow procedure UE2-EG-GE1039. Sign the evaluation
checklist and forward to the Manager, NRA. If answer
is "No", evaluation is complete. Sign the evaluation
checklist and forward to Commitment Management for
closure of Problem Report.
Summary of Evaluation and basis for conclusions
Reference: PR-PTS-97-4184, Error in Structural Analysis Software
STAAD III, Revision 21.1, was used to evaluate the existing ERP
crane support structure for Project No. E2072, X-326 ERP Crane
Replacement Project. Problem Report No. PR-PTS-97-4184 identified
an error in this software prior to final approval of the design
package, therefore, no field modifications have been implemented.
Because an error in the analysis of a liquid UF sub 6 handling
system could compromise the integrity of that system, this defect
has been determined to be reportable under the notification
requirements of 10 CFR Part 21.
Investigator
Name Signature Date
Independent Reviewer
Name Signature Date
NRA:
Name Signature Date
10CFR21 97-0013
Attachment "PROBLEM REPORT" omitted.
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