Information Notice 2009-18, Performance of Required Shutter Checks and Reporting of Gauge Shutter Failures
| ML091890514 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/2009 |
| From: | Reis T NRC/FSME/DMSSA |
| To: | |
| Lynch, JL: Region 3/DNMS | |
| References | |
| IN-09-018 | |
| Download: ML091890514 (5) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF FEDERAL AND STATE MATERIALS
AND ENVIRONMENTAL MANAGEMENT PROGRAMS
WASHINGTON, DC 20555 September 18, 2009 NRC INFORMATION NOTICE 2009-18: PERFORMANCE OF REQUIRED SHUTTER
CHECKS AND REPORTING OF GAUGE
SHUTTER FAILURES
ADDRESSEES
All U.S. Nuclear Regulatory Commission (NRC) specific and renewal fixed gauge materials
licensees. All Agreement State Radiation Control Program Directors and State Liaison Officers.
PURPOSE
The NRC is issuing this Information Notice to alert fixed gauge specific and general licensees
about the potential for the failure of shutter closure mechanisms on fixed gauges and the
requirements for reporting these events to the NRC. It is expected that recipients will review the
information for applicability to their facilities and consider actions, as appropriate, to avoid
similar incidents. Recommendations contained in this Information Notice are not new NRC
requirements; therefore, neither specific action nor written response is required. Information
herein is based upon an Information Notice issued by the State of Ohio in December 2008.
NRC is providing this Information Notice to the Agreement States for their information, and for
distribution to their licensees as appropriate.
DESCRIPTION OF CIRCUMSTANCES
Since 1990, NRC received numerous reports of fixed gauge shutter closure failures occurring
during shutter closure checks performed by licensees. The initial reports indicated that the
failures of the shutter open/close mechanisms were sudden and unexpected and most resulted
in the inability of the licensee to close the shutter on the device. In addition, most of these
reports indicated a breakage of some part of the shutter closure mechanism. An investigation
of the circumstances surrounding these events indicated several contributing factors:
1. The devices were typically operating in harsh environments with the presence of grit, dust, and other foreign materials which could get into the shutter operating
mechanism or otherwise interfere with the movement of the shutter during operation.
2. Previous shutter checks performed prior to the reported failure may have indicated
sticking or binding of the shutter during closure, although the licensee was
eventually able to get the shutter closed and reopened.
3. Periodic shutter mechanism checks were not always conducted by licensees as
required, were sometimes neglected over a prolonged period of time, and the result
was a buildup of foreign material or corrosion within the device and a stuck or frozen
shutter which could not be closed.
During the investigation of the reported shutter failures, it was also noted that additional
mechanical means, such as a pry-bar or hammer, were sometimes used to attempt to move a
stuck shutter operating mechanism. Furthermore, Ohios investigation revealed that many
additional similar events had occurred involving fixed gauges, but were not reported as required.
These incidents were identified through service and maintenance reports from manufacturers
and service providers.
DISCUSSION
Fixed gauges containing licensed radioactive materials are used by specific and general
licensees in a wide variety of manufacturing and processing operations to measure parameters
such as flow rates, thickness, density, or volume. The shutter on a fixed gauge is a safety
feature designed to eliminate or significantly reduce the radiation levels at the opening of a fixed
gauge when the shutter is in the closed position. Additionally, shutter closure is necessary to
allow licensee or service personnel to perform certain operations or maintenance activities on or
near the gauge. Therefore, the inability to close the shutter, due to the presence of corrosion or
foreign materials, breakage of the closure mechanism, or some other cause, is considered by
NRC to be a failure of equipment to operate as designed and for which there is no redundant
equipment to perform the required safety function. As such, an NRC licensee which possesses
a fixed gauge with a shutter that cannot be closed is required to notify NRC within twenty-four
hours of any such incident, in accordance with 10 CFR 30.50(b)(2). In addition, the licensee is
required to follow-up the initial report within 30 days with a written report describing the
circumstances which led to the shutter failure and the corrective actions taken. The 30-day
follow-up report is required by 10 CFR 30.50(c)(2).
Fixed gauges routinely operate in a continuous mode with the shutter open, exposing the
radioactive source inside. A shutter closure check is a periodic maintenance activity to be
performed by licensees possessing fixed gauges in accordance with the procedures included in
the manufacturers instructions. The requirement for NRC fixed gauge licensees to conduct
these checks is found in 10 CFR 31.5 (c)(2) for general licensees, and by license condition for
specific licensees. Licensees are required to document that the checks have been performed.
The typical timeframe for conducting a shutter check is every six months.
Licensees should promptly contact the manufacturer or other licensed service provider for
guidance on necessary maintenance or service and whenever the gauge requires repair. At no
time should the licensee attempt to apply additional force or pressure to the closure mechanism
through the use of pry bars, hammers, or other mechanical means. Use of such methods is
prohibited and may cause damage to or breakage of the operating handle or the bolts used in
assembly of the device.
NRC fixed gauge licensees are advised that NRC will place additional emphasis during future
inspections on licensee performance of required shutter checks, documentation of the checks, and reporting of equipment failures such as those described in this Information Notice.
CONTACT
S
This Information Notice requires no specific licensee action or response. If you have any
questions about the information in this notice, please contact one of the technical contacts
below, or the appropriate regional office.
Terry Reis for /RA/
Robert J. Lewis, Director
Division of Materials Safety
and State Agreements
Office of Federal and State Materials
and Environmental Management Programs
Technical Contacts: J. Bruce Carrico, FSME
(301) 415-7826 E-mail: Jbruce.Carrico@nrc.gov
Jim Lynch, Region III
(630) 829-9661 E-mail: james.lynch@nrc.gov
Enclosure: List of Recently Issued FSME
Generic Communications
CONTACT
S
This Information Notice requires no specific licensee action or response. If you have any
questions about the information in this notice, please contact one of the technical contacts
below, or the appropriate regional office.
Terry Reis for /RA/
Robert J. Lewis, Director
Division of Materials Safety
and State Agreements
Office of Federal and State Materials
and Environmental Management Programs
Technical Contacts: J. Bruce Carrico, FSME
(301) 415-7826 E-mail: Jbruce.Carrico@nrc.gov
Jim Lynch, Region III
(630) 829-9661 E-mail: james.lynch@nrc.gov
Enclosure: List of Recently Issued FSME
Generic Communications
ML091890514 OFC RIII/DNMS RIII/DNMS FSME/RMSB FSME/LB FSME/RMSB FSME/MSSA
NAME JLynch: sxg6 SReynolds AMcIntosh JFoster CEinberg RLewis
DATE 07/09/09 07/09/09 07/27/09 07/27/09 08/10/09 09/18/09 OFFICIAL RECORD COPY
IN 2009-18 List of Recently Issued Office of Federal and State Material
and Environmental Management Programs Generic Communications
Date GC No. Subject
Addressees
03/30/09 IN-2009-07 Withholding of Proprietary All current holders of and potential applicants
Information from Public Disclosure for licenses, certificates of compliance, permits, or standard design certifications, as
well as any other persons submitting a request
that information be withheld from public
disclosure under the provisions of Title 10 of
the Code of Federal Regulations (10 CFR)
Section 2.390, Public inspections, exemptions, requests for withholding.
07/27/09 IN-2009-12 Exempt Distribution Licensing All holders of NRC exempt distribution licenses
Requirements For Irradiated authorized to distribute irradiated gemstones.
Gemstones Organizations associated with importing, distributing or selling irradiated gemstones or
jewelry containing irradiated gemstones. All
Radiation Control Program Directors and State
Liaison Officers.
07/29/09 IN-2003-22, Heightened Awareness for Patients All U.S. Nuclear Regulatory Commission (NRC)
Supplement 1 Containing Detectable Amounts of medical-use licensees and NRC master
Radiation from Medical Administrations material licensees; all Agreement State
Radiation Control Program Directors and State
Liaison Officers.
04/29/09 RIS-2009-05 Uranium Recovery Policy Regarding: (1) All holders of operating licenses for uranium
The Process for Scheduling Licensing recovery facilities and all companies who have
Reviews of Applications for New submitted applications to construct new
Uranium Recovery Facilities and (2) The uranium recovery facilities of all types
Restoration of Groundwater at Licensed (conventional mills, heap leach operations, and
Uranium In-Situ Recovery Facilities in-situ recovery facilities) or letters of intent to
submit such applications.
05/07/09 RIS-2009-07 Status Update for the Implementation All U.S. Nuclear Regulatory Commission
of NRC Regulatory Authority for Certain material and fuel cycle licensees. All Radiation
Naturally Occurring and Accelerator- Control Program Directors and State Liaison
Produced Radioactive Material Officers.
07/13/09 RIS-2009-09 Use Of Multiple Dosimetry and All U.S. Nuclear Regulatory Commission
Compartment Factors in licensees, Agreement State Radiation Control
Determining Effective Dose Equivalent Program Directors, and State Liaison Officers.
from External Radiation Exposures
Note: This list contains the six most recently issued generic communications, issued by the Office of Federal and State
Materials and Environmental Management Programs (FSME). A full listing of all generic communications may be viewed at
the NRC public website at the following address: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/index.html