United States Nuclear Regulatory Commission - Protecting People and the Environment


ACCESSION #: 9706110118



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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                              Dir: (301) 564-3309

VICE PRESIDENT, PRODUCTION                   Fax: (301) 571-8279



                              June 6, 1997



                                        SERIAL: GDP 97-0076



U.S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, D.C.  20555-0001



Portsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70-7002

Written Notification of 10 CFR 21 Report



     The purpose of this letter is to provide written notification to the

NRC of a reportable (see below) defect that has been identified at the

Portsmouth Gaseous Diffusion Plant (PORTS), in accordance with 10 CFR

Part 21.  The NRC was verbally notified of this situation on June 6,

1997.  The defect involves probable inadequate fusion of lifting lug

welds found on new model 48G cylinders supplied by Westerman Inc., 245

North Broad St., P.O. Box 125, Bremen, Ohio 43107.  Portions of the lug

welds on four cylinders from a lot of 32 cylinders were found to have

weld defects known as overlap.  Assuming all other factors are equal, a

weld pattern with overlap is more likely to fail at a lower load than an

otherwise identical weld pattern without overlap.  Therefore, the margin

of safety could have been reduced if the cylinders had been placed in

service.  While PORTS has not performed a full engineering evaluation to

determine if the lug welds would actually have failed, the situation is

being conservatively reported due to its potential significance to the

GDPs and other users of 48G cylinders.



     The condition was initially discovered on April 7, 1997 during

receipt inspections as required by the associated Engineering

Specification Data Sheet (ESDS), which require 100% external visual

inspection of each cylinder, and has been under evaluation since that

time.  The four cylinders with the observed defects were returned to the

vendor.  The remaining cylinders, which were all determined to be

acceptable, were placed in stock.  It has been determined that the weld

defects were restricted to a single lot, according to information

provided by Westerman, and that the problem has been corrected.



         Offices in Livermore, California     Paducah, Kentucky

                   Portsmouth, Ohio    Washington, DC



U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

June 6, 1997

GDP 97-0076 Page 2



     The Paducah plant has been apprised of this situation, and has

implemented a parallel action plan.  The associated PORTS 10 CFR 21

evaluation checklist and a copy of pertinent PORTS problem report is

enclosed.



     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)                                           97-0004



                   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  X     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  X     Yes       Has the condition been reported to the 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.1, A.2, and A.3 are "No", continue with the

evaluation.



B.1       No        Yes  X    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  X     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 in 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.



See Remarks in Section E.



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  X     Yes       1)   The installation, use, or operation of

                                   a basic component containing a

                                   deviation?



          No        Yes  X    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  X     Yes       3)   A failure to comply with any

                                   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.



                               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  X     Yes       1)   Exposure in excess of 10 CFR 20.1201

                                   limits.



          No  X     Yes       2)   Exposure of an individual in an

                                   unrestricted area to more than 0.5 rem

                                   in one calendar year (10 CFR

                                   20.1301(c)).



          No        Yes  X    3)   Release of radioactive material to an

                                   unrestricted area in excess of the

                                   limits in 10 CFR 20 Appendix B, Table

                                   2.



          No        Yes  X    4)   A deficiency which seriously

                                   compromised the ability of a UF sub 6

                                   containment system to perform its

                                   designated function.



          No        Yes       5)   Other (explain)



If all of the 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  X    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 check list and forward to

                              Commitment Management for closure of

                              Problem Report.



          Summary of evaluation and basis for conclusions.



          References:



          A.   PR-PTS-97-3501, Problem Report for Rejected Cylinders

          B.   DR-QA-97-0133, Disposition of Non-Conforming Item

          C.   UE2-EG-GE1039, 10CFR21 Evaluation and Reporting

          D.   10CFR Part 21, Reporting of Defects and Non-Compliances

          E.   NUREG-0302, 10CFR21 Q & A Remarks



          B.2) Marking part B no would normally screen out a Part 21

          notification; however, this section assumes that the supplier

          would be required by law (Reference E) to make this

          notification.  Discussions with Central Procurement (J.

          Mahoney) indicated that the affected Purchase Orders are

          several years old and do not invoke Part 21 on the supplier.

          For this reason the screening review will continue.



          The bases for TSRs 2.5.4.2 and 2.5.3.10 are to prevent the

          dropping of a liquid cylinder during lifting and to maintain

          the UF6 containment barrier.  An attachment weld that has a

          structural flaw reduces the margin of safety available for

          lifting of the cylinder.  Furthermore, a problem is indicated

          in the suppliers QA program that allowed the shipment of these

          cylinders.  Because this deviation creates a condition in a

          basic component that could affect a UF6 containment system or

          cause an unacceptable release of UF6 it has been determined to

          be reportable under the notification requirements of 10CFR Part

          21.



Investigator

                         Name                Signature           Date



Independent Reviewer:

                         Name                Signature           Date



NRA

                         Name                Signature           Date



Attachment "PROBLEM REPORT" omitted.



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