Part 21 Report - 1997-491

ACCESSION #: 9706270226 NOTE: This text document was processed from a scanned version or an electronic submittal and has been processed as received. Some tables, figures, strikeouts, redlines, and enclosures may not have been included with this submittal, or have been omitted due to ASCII text conversion limitations. In order to view this document in its entirety, you may wish to use the NUDOCS microfiche in addition to the electronic text. 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. *** END OF DOCUMENT ***

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