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

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)

ML18029A105 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. 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

10 CFR 70.61(e).

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

Jonathan Marcano, NMSS

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