United States Nuclear Regulatory Commission - Protecting People and the Environment


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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