ML24211A052
| ML24211A052 | |
| Person / Time | |
|---|---|
| Site: | 07109218 |
| Issue date: | 07/29/2024 |
| From: | Sellmer T Salado Isolation Mining Contractors (SIMCO) LLC |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| TS:24:03021 | |
| Download: ML24211A052 (1) | |
Text
TS:24:03021 July 29, 2024 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
REPORT PURSUANT TO 10 CFR 71.95
Dear Ms. Helton:
Salado Isolation Mining Contractors, LLC (SIMCO), on behalf of the U.S. Department of Energy Carlsbad Field Office (DOE/CBFO), submits this letter to report a condition pursuant to 10 CFR 71.95 regarding the use of the Type B packaging model number TRUPACT-II, serial number 148. This packaging operates under the U.S. Nuclear Regulatory Commission (NRC)
Certificate of Compliance (CofC) Number 9218. During the shipment of contact-handled (CH) transuranic (TRU) waste to the Waste Isolation Pilot Plant (WIPP) from Los Alamos National Laboratory (LANL), the conditions in Sections 5(a)(3) and 11(a) of NRC CofC No. 9218 were not followed in their entirety.
Following is a description of the events, reported in accordance with 10 CFR 71.95 (c):
(1) A brief abstract describing the major occurrences during the event, including all component or system failures that contributed to the event and significant corrective action taken or planned to prevent recurrence.
TRU waste shipment LA240018 originated at LANL bound for delivery to the WIPP in New Mexico. The shipment consisted of one tractor-trailer hauling three TRUPACT-II packages, Units 132, 148, and 152. All three (3) units each contained one payload assembly and one (1) dunnage assembly. All loaded payload assemblies were designated as 60-day general case shipments in accordance with CH-TRU Payload Appendix 3.4. The CofC No. 9218, Revision 27, Condition 11(a) specifies, Each package must be prepared for shipment and operated in accordance with the procedures described in Chapter 7.0, "Operating Procedures,"
of the application, as supplemented. Section 7.1.5.12 of the TRUPACT-II Safety Analysis Report (SAR) specifies, Install the ICV vent port cover; tighten to 55 - 65 lb-in torque. After receipt at the WIPP and during the unloading process of Unit 148, it was discovered that Unit 148 was received without the inner containment vessel (ICV) vent port cover gasket/O-ring installed.
Document Control Desk TS:24:03021 There were no major occurrences during the event, and no component or system failures that contributed to the event. All other conditions for this shipment complied with the applicable requirements for CofC No. 9218. However, due to the failure to fully implement the requirements in the TRUPACT-II SAR Section 7.1.5.12 for TRUPACT-II unit 148, the conditions in CofC No. 9218 were not followed in their entirety for this shipment.
The following corrective/preventive actions were implemented to preclude recurrence:
x A search of the area where Unit 148 was loaded was made. The missing ICV vent port cover gasket was not discovered.
x Review of the applicable Package assembly documentation was made to verify compliance to condition 11(a) and the applicable DOE/CBFO CH Packaging Operations Manual.
x Briefings were held with all SIMCO Mobile loading Unit personnel on the importance of attention to detail and ensuring compliance to the applicable CH Packaging Operations Manual.
(2) A clear, specific, narrative description of the event that occurred so that knowledgeable readers conversant with the requirements of part 71, but not familiar with the design of the packaging, can understand the complete event. The narrative description must include the following specific information as appropriate for the particular event.
The NRC issued CofC No. 9218 for the TRUPACT-II specifies in Condition 11(a) Each package must be prepared for shipment and operated in accordance with the procedures described in Chapter 7.0, Operating Procedures, of the application, as supplemented. Section 7.1.5.12 of the TRUPACT-II SAR specifies Install the ICV vent port cover; tighten to 55 - 65 lb-in torque.
After receipt at the WIPP and during the unloading process of Unit 148, it was discovered that Unit 148 was received without the gasket/O-ring installed on the ICV vent port cover. Shipment LA240018, consisting of TRUPACT-II Units 132, 148 and 152, departed LANL on May 30, 2024, at 1041 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.961005e-4 months <br /> (MDT) and was received at the WIPP site on May 30, 2024, at 1821 hours0.0211 days <br />0.506 hours <br />0.00301 weeks <br />6.928905e-4 months <br /> (MDT).
All other conditions required for the operation and shipment of the packages in accordance with the CofC were adhered to.
(2)(i) Status of components or systems that were inoperable at the start of the event and that contributed to the event; This criterion is not applicable to the events because there were no components or systems that were inoperable at the start of the events.
(2)(ii) Dates and approximate times of occurrences; Date and approximate time of occurrence was May 14, 2024, at 0832 hours0.00963 days <br />0.231 hours <br />0.00138 weeks <br />3.16576e-4 months <br />.
Document Control Desk TS:24:03021 (2)(iii) The cause of each component or system failure or personnel error, if known; No components or systems failed. All shipment documentation applicable to TRUPACT-II Unit 148 reflects that all required steps for the operation of the package were adhered to during the loading and preparation of the package for shipment.
(2)(iv) The failure mode, mechanism, and effect of each failed component, if known; This criterion is not applicable to the events because no components failed.
(2)(v) A list of systems or secondary functions that were also affected for failures of components with multiple functions; This criterion is not applicable to the events because no components failed.
(2)(vi) The method of discovery of each component or system failure or procedural error; During the unloading process of TRUPACT-II Unit 148, SIMCO Waste Handling personnel discovered that the gasket/O-ring for the ICV vent port cover was not present. SIMCO Waste Handling personnel notified the SIMCO Packaging & Information Systems Group via telephone and with subsequent electronic documentation.
(2)(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances; This is unknown, as all shipment documentation applicable to TRUPACT-II Unit 148 reflects that all required steps for the operation of the package were adhered to during the loading and preparation of the package for shipment.
(2)(viii) The manufacturer and model number (or other identification) of each component that failed during the event; and Manufacturer and model numbers associated with component failure are not applicable because no components failed.
Document Control Desk TS:24:03021 (2)(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents.
Packaging Unit 148 Payload ID LR0701:
Radionuclide Total Activity (Ci)
Percentage of Total AM-241 3.326E-01 0.17%
AM-243 8.250E-06 0.00%
EU-152 2.380E-06 0.00%
NP-237 8.937E-06 0.00%
PU-238 1.901E+02 96.24%
PU-239 2.890E+00 1.46%
PU-240 7.143E-01 0.36%
PU-241 3.460E+00 1.75%
PU-242 7.800E-05 0.00%
U-232 1.300E-05 0.00%
U-234 2.970E-02 0.02%
Total:
1.975E+02 100.00%
Physical and Chemical Form:
Material Category Material Type Weight (lbs)
Waste Material Cellulosics 46.31 Waste Material Iron Base Metal Alloys 629.97 Waste Material Other Inorganic Material 0.44 Waste Material Other Metal/Alloys 95.70 Waste Material Plastics 50.72 Steel Packaging Material Steel Container Materials 1344.23 Total:
2167.36
Document Control Desk TS:24:03021 (3) An assessment of the safety consequences and implications of the event. This assessment must include the availability of other systems or components that could have performed the same function as the components and systems that failed during the event.
There were no systems or components that failed during the event. There were no safety consequences or implications of the event.
(4) A description of any corrective actions planned as a result of the event, including the means employed to repair any defects, and actions taken to reduce the probability of similar events occurring in the future.
In addition to the interim corrective actions identified in (1) above, the following preventative corrective actions are planned:
x SIMCO Contractor Assurance has initiated a Causal Analysis to identify future corrective actions to reduce the probability of similar events occurring in the future.
x The applicable SIMCO departments will implement the Judgements of Need that are identified in the Causal Analysis.
(5) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.
Nuclear Waste Partnership letter number TS:22:03001 dated 1/14/2022: ICV outer vent port plug not installed.
Nuclear Waste Partnership letter number CP:17:01163 dated 6/28/2017: Incorrect O-ring installed on ICV vent port cover.
Nuclear Waste Partnership letter number CP:13:01330 dated 6/28/2017: Incorrect O-rings installed on ICV seal test port plug and ICV inner vent port plug.
Washington TRU Solutions letter number CP:12:01453 dated 9/6/2012: Incorrect O-rings installed on OCV seal test port plug and OCV vent port plug.
(6) The name and telephone number of a person within the licensee's organization who is knowledgeable about the event and can provide additional information.
T.E. Sellmer, Manager, SIMCO, Packaging and Information Systems, (575) 234-7396 or (575) 302-7583 (7) The extent of exposure of individuals to radiation or to radioactive materials without identification of individuals by name.
There were no exposures to individuals as a result of the event. All pre-shipment surveys satisfied the regulatory dose rate limits.
Document Control Desk TS:24:03021 If you have any questions or require additional information regarding this report, please contact me at (575) 234-7396 or (575) 302-7583.
Sincerely, T. E. Sellmer, Manager Packaging and Information Systems TES:clm cc: L. F. Gelder, SRCC ED K. E. Princen, CBFO ED J. Shenk, EM-4.24 ED K. E. Princen, CBFO ED D. M. Smith, CBFO ED A. J. Walker, CBFO ED B. H. White, USNRC ED TODD SELLMER (Affiliate)
Digitally signed by TODD SELLMER (Affiliate)
Date: 2024.07.29 06:26:33 -06'00'
Document Control Desk TS:24:03021 The following table summarizes the components of this submittal. No deviations occur from the NRC-prescribed PDF formatting for the submitted files. Please contact Ms. C. L. Morrison at (505) 350-3693, or cindy.morrison@wipp.ws to resolve any discrepancies in this submittal.
File Name File Size (KB)
Sensitivity Level Submittal Type 001 TS-24-03021 Report Pursuant to 10 CFR 71.95.pdf Publicly Available EIE 207