Information Notice 2018-06, Determination of Management Measures for Process Isolation Controls Designated as Items Relied on for Safety and Implementation of Adequate Quality Assurance Measures for Plant Features and Procedures
| ML18029A105 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/2018 |
| From: | Craig Erlanger, Chris Miller Division of Fuel Cycle Safety, Safeguards, and Environmental Review, Division of Inspection and Regional Support |
| To: | |
| Smith A | |
| References | |
| IN-18-006 | |
| Download: ML18029A105 (5) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001 April 10, 2018 NRC INFORMATION NOTICE 2018-06: DETERMINATION OF MANAGEMENT MEASURES
FOR PROCESS ISOLATION CONTROLS
DESIGNATED AS ITEMS RELIED ON FOR SAFETY
AND IMPLEMENTATION OF ADEQUATE QUALITY
ASSURANCE MEASURES FOR PLANT FEATURES
AND PROCEDURES
ADDRESSEES
All holders of, and applicants for, a specific source material license for large quantities of
uranium hexafluoride under Title 10 of the Code of Federal Regulations (10 CFR) Part 40,
Domestic Licensing of Source Material.
All holders of, and applicants for, a fuel facility license under 10 CFR Part 70, Domestic
Licensing of Special Nuclear Material, and all holders of, and applicants for, a construction
permit or operating license for a production facility, including a medical isotope facility, under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform
addressees of recent operating experience regarding programs and procedures for determining
and implementing management measures for isolation controls. These isolation controls may
be required to be available and reliable to perform specific safety functions to prevent or
mitigate accident sequences.
The NRC expects that recipients will review the information for applicability to their facilities and
consider actions, as appropriate, to avoid similar issues. The suggestions contained in this IN
are not NRC requirements; therefore, no specific action is required.
DESCRIPTION OF CIRCUMSTANCES
In 2016 and 2017, NRC inspectors documented instances of inadequate management
measures for isolation controls credited for preventing or mitigating releases of hazardous
material at three facilities. Isolation controls, as discussed in this IN, refer to administrative or
engineered controls relied upon to isolate or mitigate potential releases of substances that could
lead to accidents exceeding the performance requirements in 10 CFR 70.61. Examples include
operator actions or isolation valves on processes containing flammable gas or hazardous liquid
and gas.
ML18029A105 Honeywell Metropolis Works (Honeywell)
NRC Inspection Report 40-3392/2016-0051 documented an unresolved item (URI) associated
with the failure of multiple seismically activated isolation valves during testing, one of which was
considered a plant feature and procedure. NRC Inspection Report 40-3392/2017-0022 included
information on the URI with discussion of the licensees evaluation of the failures. The
licensees evaluation indicated two contributing factors for the valves mechanical failures: (1)
the core spring did not seem strong enough to close the valve after been maintained in the open
position for an extended period; and (2) the relatively low testing or cycling frequency of the
solenoids. These factors relate to the licensees preventive maintenance (i.e., management
measures) that maintained the design function of the affected valves.
Honeywell replaced, or performed corrective maintenance on, the failed valves and also
completed an evaluation to determine the probable causes of the valve failures. The results of
the evaluation included initiating corrective actions to: (1) evaluate the testing frequency of
seismically-activated solenoid valves; (2) replace all ASCO Model 8316G001 solenoids with
Model 8320G184; and (3) visually inspect solenoids in areas where environmental factors such
as temperature, humidity, and fluid corrosiveness could prevent the solenoids from performing
their function.
Nuclear Fuel Services, Inc. (NFS) and Global Nuclear Fuels - Americas (GNF-A)
In July 2017, NRC inspectors documented a minor violation of 10 CFR 70.62(d), Management
Measures, at NFS for inadequate testing of valves required to isolate bulk chemicals and gases
during emergencies in NRC Inspection Report 70-143/2017-006.3 Similarly, in November 2017, NRC inspectors documented a minor violation at GNF-A for inadequate testing of valves
required to isolate flammable and combustible gases upon detection of a leak in NRC
Inspection Report 70-1113-2017-006.4 NFS and GNF-A concluded that neither preventive maintenance nor functional testing were
applicable management measures because the integrated safety analysis (ISA) referenced the
administrative action of manually operating the valves as the item relied on for safety (IROFS).
In the context of administrative IROFS (i.e., operator actions) neither NFS nor GNF-A included
management measures, such as preventive maintenance, for the valves that the operator would
operate to fulfil the administrative function. Given that the valves would need to be available
and reliable in order to prevent or mitigate the specified accident sequence, the NRC inspectors
concluded that NFS and GNF-A did not establish adequate management measures for the
valves.
After the NRC inspectors identified the inadequately tested valves, NFS and GNF-A entered the
non-compliances into their respective corrective action systems. During the inspection, NFS
identified that recent maintenance activities caused some of the valves to be cycled and did not
identify adverse conditions in those valves.
1 NRC Inspection Report 40-3392/2016-005 dated January 30, 2017 (Agencywide Documents Access and
Management System (ADAMS) Accession No. ML17030A108)
2 NRC Inspection Report 40-3392/2017-002 dated April 24, 2017 (ADAMS Accession No. ML17115A006)
3 NRC Inspection Report 70-143/2017-006 dated August 4, 2017 (ADAMS Accession No. ML17216A146)
4 NRC Inspection Report 70-1113/2017-006 dated December 20, 2017 (ADAMS Accession No. ML17354A197)
BACKGROUND
In reference to facilities licensed under 10 CFR Part 70 and other facilities that implement
management measures, the term management measures is defined in 10 CFR Part 70.4, as
the functions performed by the licensee, generally on a continuing basis, that are applied to
items relied on for safety, to ensure the items are available and reliable to perform their
functions when needed. Management measures include configuration management, maintenance, training and qualifications, procedures, audits and assessments, incident
investigations, records management, and other quality assurance elements.
Subpart H of 10 CFR Part 70, codifies the requirement for management measures in
10 CFR 70.61(e) and 70.62(d). Paragraph 70.61(e) establishes the performance requirement of
designating IROFS and ensuring those IROFS are available and reliable to perform their
intended functions when needed. Paragraph 70.62(d) designates management measures as
the mechanism for complying with all the performance requirements of 10 CFR 70.61, including
Paragraph 70.62(d) states, Each applicant or licensee shall establish management measures
to ensure compliance with the performance requirements of § 70.61... The management
measures shall ensure that engineered and administrative controls and control systems that are
identified as items relied on for safety pursuant to § 70.61(e) of this subpart are designed, implemented, and maintained, as necessary, to ensure they are available and reliable to
perform their function when needed, to comply with the performance requirements of § 70.61 of
this subpart.
In reference to Honeywell (licensed to operate in accordance with 10 CFR Part 40),
Confirmatory Order EA-12-1575 requires, in part, that quality assurance (QA) measures are
developed and implemented for modifications made to the facility that address identified
vulnerabilities to external events such as natural hazard phenomena. At a minimum, the QA
measures must address design, procurement, inspections and tests, installation, document
control, procedures and drawings, and records.
DISCUSSION
Although Honeywell established QA measures, the seismically activated solenoid-operated
isolation valves still failed during testing. As discussed above, the licensees evaluation
indicated that weakening of the core spring and relatively low testing or cycling frequency of the
solenoids contributed to the valve failure. In addition, without additional testing and/or
preventive maintenance, a manufacturer-reported failure rate may change if valves are installed
in operational environments that are different than were used in the manufacturers evaluation.
For instance, if the failure rate of a solenoid valve is based upon low humidity, moderate
temperatures, a pH neutral environment, and minimal stress on the core spring, then installing
and operating the valve under different conditions may increase the failure rate and, therefore, warrant additional testing and/or preventive maintenance.
5 Section IV.2. Honeywell shall develop, implement, and have available for NRC inspection the quality assurance
measures for the modifications referred to in Item 1.c [refers to documentation of the design bases for the proposed
modifications to the Metropolis Works facility that were needed to define and provide the safety basis for external
events and revise the facility emergency response plan]. These quality assurance measures shall address, at a
minimum, the following areas: design, procurement, inspections and tests, installation, document control, procedures
and drawings, and records. Dated October 15, 2012, ADAMS Accession No. ML12289A800. For licensees that operate under 10 CFR Part 70 requirements, considering only the operator
action as the IROFS may result in the failure to establish management measures for the
equipment or components needed to prevent or mitigate the associated accident sequence. In
this scenario, an operator could initiate the safety action, (e.g., manually closing a valve) but the
failure of the valve (e.g., due to a lack of preventive maintenance) would render the safety
action ineffective in preventing or mitigating the accident sequence. The circumstances
discussed above emphasize how weaknesses in the identification of management measures in
the licensees ISA programs led to non-compliances with the referenced provisions of 10 CFR
Part 70, Subpart H. Without implementing management measures for the valves, the licensees
lacked a basis for the overall reliability and availability of the IROFS. For the minor violations
discussed above, the NRC inspectors cited the failure to meet 10 CFR 70.62(d) which requires
licensees to maintain IROFS available and reliable to perform their intended safety function.
To ensure compliance with 10 CFR 70.61(e) and 70.62(d), licensees must implement
management measures for controls required for the functionality of IROFS. The operating
experience referenced in this IN suggests that there may be administrative controls that are
dependent on engineered components to perform a safety function and that those components
may not be subject to adequate QA or management measures to ensure the administrative
controls are effective.
CONTACT
S
Please direct any questions about this matter to the technical contacts listed below.
/ra/ /ra/
Craig G. Erlanger, Director Christopher G. Miller, Director
Division of Fuel Cycle Safety, Safeguards, Division of Inspection and Regional
and Environmental Review Support
Office of Nuclear Material Safety and Office of Nuclear Reactor Regulation
Safeguards
Technical Contacts: April Smith, NMSS
301-415-6547 Email: April.Smith@nrc.gov
301-415-6731 Email: Jonathan.Marcano@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under NRC Library.
ML18029A105 *concurred via email
OFFICE NMSS/FCSE/PORSB NMSS/FCSE/FMB QTE* NMSS/FCSE/PORSB/BC*
NAME ASmith TBrockington JDougherty JDowns (acting)
DATE 02/01/2018 02/01/2018 03/13/2018 03/28/2018 OFFICE NRR/DLP/PRLB/BC (A)* NRR/DIRS/IRGB/PM NRR/DIRS/IRGB/LA* NRR/DIRS/IRGB/BC
NAME SLynch TKeene ELee HChernoff (w/comment)
DATE 03/29/2018 03/30/2018 03/29/2018 04/04/2018 OFFICE NRR/DIRS/D NMSS/FCSE/D
NAME CMiller CErlanger
DATE 04/10/2018 04/10/2018