Part 21 Report - 1997-461
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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