ML14192A040

Interim Report - 10CFR Part 21 Evaluation Regarding Potential Deficiencies

ML14192A040
Person / Time
Site:	Browns Ferry
Issue date:	07/03/2014
From:	Stewart T Preferred Metal Technologies
To:	Document Control Desk, Office of New Reactors
References
PMT 14-01
Download: ML14192A040 (4)

Text

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July 3, 2014 PMT Report No.14-01U.S. Nuclear Regulatory Commission Attn: Document Control DeskWashington, DC 20555-0001

Subject:

Interim Report -10CFR Part 21 Evaluation Regarding Potential Deficiencies The purpose of this letter is to provide the NRC a report in general conformity to therequirements of 1 OCFR Part 21.21 (a)(2).Preferred Metal Technologies (PMT) was notified by Steris Isomedix Services that the appliedradiation dose reported on their Component Irradiation Certificates did not account for all theuncertainties involved (i.e. density of unrelated products in carriers, off-carrier location within theirradiator and Cobalt-60 source decay). This potential defect was originally identified as part ofNRC Inspection Report No. 99901445/2014-201.

Required information as per 1 OCFR Part 21.21 (d)(4) follows:(i) Name and Address of the individual or individuals informing the Commission:

Tim Stewart, Vice President NuclearPreferred Metal Technologies, Inc.140 East Tower DriveBurr Ridge, Illinois 60527(ii) Identification of the facility, the activity, or the basic component supplied for suchfacility or such activity within the United States which fails to comply or contains adefect:The Radiation Qualification of the following basic components is affected by thisdiscrepancy:

(a) Electric Spring Return Actuator, PC # T-7360 (PMT Project No. N1839)(b) Various non-metallic materials (Gasket PC # T-7621, Bearings PC # T-7597,Seal PC # T-6669 and Adhesive PC # T-7594) utilized as part of a completedamper assembly (PMT Project No. N1893)Refer to section (vi) of this letter for specific project details.140 E. Tower Drive -Burr Ridge, II1., 60527 -Phone 630.887.7700

-Fax 630.887.0770 Report No.14-01r PREFERRED METAL Page 2 of 4--rmWiLd TECHNOLOGIES, INC.(iii) Identification of the firm constructing the facility or supplying the basic component which fails to comply or contains a defect:Preferred Metal Technologies, Inc.140 East Tower DriveBurr Ridge, Illinois 60527(iv) Nature of the defect or failure to comply and the safety hazard which is created orcould be created by such defect or failure to comply:Preferred Metal Technologies (PMT) was notified by Steris IsomedixServices, a 10CFR 50 Appendix B supplier who provides component irradiation

services, regarding an evaluation that they performed on theapplied radiation dose for items processed in off-carrier locations withintheir irradiator.

This evaluation was performed as a result of an NRCInspection of the Steris Isomedix Services facility in Whippany, NJ. Thisevaluation determined that the actual dose delivered may have differedup to +/-5.1% from that value reported on their Component Irradiation Certificate depending on the location within the irradiator where thecomponent was processed.

The worse case variability

(+/-5.1%) is basedon the density variation, source decay and intercomparison variability.

This variance is in addition to the standard uncertainty of the dosimetry system (+/-6.5%).

As a result, there is a potential safety hazard that thebasic components supplied by PMT may not be qualified for operation atthe postulated radiation levels that may occur during an accident.

(v) The date on which the information such defect or failure to comply was obtained:

Notification was received on the afternoon of June 23, 2014(vi) In the case of a basic component which contains a defect or fails to comply, thenumber and location of these components in use at, supplied for, being supplied for, ormay be supplied for, manufactured or being manufactured for one or more facilities oractivities subject to the regulations in this Part:After a thorough review of all purchase orders issued to Steris IsomedixServices and PMT Projects that the irradiation test results were utilizedon, PMT has determined that there are two projects where the appliedradiation dose may have failed to meet the minimum required radiation dose to ensure that the safety related equipment would continue tooperate satisfactorily during / after an accident.

The details of those twoprojects are as follows:140 E. Tower Drive -Burr Ridge, II1., 60527 -Phone 630.887.7700

-Fax 630.887.0770

.1Report No. 14-01-PREFERRED METAL Page 3 of 4!rLWA!-iiTECHNOLOGIES, INC.wPMT Owner'sPMT Oner's Quantity and Description Project Owner Facility Purchase quit ScrptionNumber Order Number of Equipment SuppliedN1839 Tennessee Valley Authority Browns Ferry 473351 6 (Six) Electric Spring ReturnActuators N1893 Commisi6n Federal de Laguna Verde 700419016 32 (Thirty Two) DamperN1893Electricidad LauaVre 70106Assemblies (vii) The corrective action which has been, is being, or will be taken; the name of theindividual or organization responsible for the action and the length of time that hasbeen or will be taken to complete the action:PMT has documented the deficiency per our procedure PMT 16.1.G, onCorrective Action Report (CAR) No. 64. Concurrent with this notification to the NRC, PMT is providing notification of this failure to comply to theaffected Owners. PMT Engineering will determine and implement asupplemental test program on the original qualification components suchthat the minimum dose applied meets or exceeds the originalenvironmental qualification requirements contained within the Owner'spurchase order. Affected documents (e.g. EQ reports) will besupplemented or revised as applicable.

PMT will review the supplierrestrictions imposed on Steris Isomedix Services for inclusion ofadditional requirements to prevent recurrence.

Final corrective actions tobe implemented will be as specified within the PMT disposition to CARNo. 64 and will be documented within the Final Part 21 Report issued toNRC. Final closure of CAR No. 64 is targeted for the week of August 4,2014.(viii) Any advice related to the defect or failure to comply about the facility,

activity, or basiccomponent that has been, is being, or will be given to purchasers or licensees:

Each owner / utility will need to review the radiation dose applied, takeinto account the applicable reduction due to the reported

variance, andthen evaluate whether or not the environmental qualification testingperformed still envelopes the minimum requirements for the application.

(ix) In the case of an early site permit, the entities to whom as early site permit wastransferred:

Not Applicable 140 E. Tower Drive -Burr Ridge, II1., 60527 -Phone 630.887.7700

-Fax 630.887.0770 p-Report No. 14-01rT PREFERRED METAL Page 4 of 4--rWAm-E TECHNOLOGIES, INC.If you have any questions or wish to discuss this matter or this report, please feel free to contactme.Sincerely, Tim Stewa¢Vice President Nuclearcc: John Berzanskis, Jr., President

-Preferred Metal Technologies, Inc.Joe Emerson, Quality Assurance Manager -Preferred Metal Technologies, Inc.USNRC, Region Il1, Lisle, ILTVA Nuclear, Nuclear Assurance and Licensing, Attn: Manager, Operating Experience Comisi6n Federal De Electricidad, Attn: Ing. Agustin Lozano Laez140 E. Tower Drive -Burr Ridge, II1., 60527 -Phone 630.887.7700

-Fax 630.887.0770