ML26054A255
| ML26054A255 | |
| Person / Time | |
|---|---|
| Site: | 07109218 |
| Issue date: | 02/23/2026 |
| From: | Sellmer T Salado Isolation Mining Contractors (SIMCO) LLC |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| TS:26:03003 | |
| Download: ML26054A255 (0) | |
Text
P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 TS:26:03003 February 23, 2026 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 Sir or Madam:
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 178. This packaging operates under the U.S. Nuclear Regulatory Commission (NRC)
Certificate of Compliance (CoC) 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 CoC 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 LA250102 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 127, 141, and 178. Units 127 and 178 each contained two (2) payload assemblies, and unit 141 contained one (1) 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 CoC No. 9218, Revision 29, Condition 5(a)(3) specifies, The packaging and its components are constructed and assembled in accordance with the following Nuclear Waste Partnership drawings: and 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 7.1.5.9 of the TRUPACT-II Safety Analysis Report (SAR) specifies, Install the ICV seal test port plug; tighten to 55 - 65 lb-in torque. After receipt at the WIPP and during the unloading process of Unit 178, it was discovered that Unit 178 was received without the inner containment vessel (ICV) seal test port plug installed.
Document Control Desk TS:26:03003 P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 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 CoC No. 9218. However, due to the failure to fully implement the requirements in the TRUPACT-II SAR Section 7.1.5.9 for TRUPACT-II unit 178, the conditions in CoC No.
9218 were not followed in their entirety for this shipment.
The following corrective/preventive actions were implemented to preclude recurrence:
x Shipments were already paused due to a scheduled WIPP maintenance outage.
x A search was made of the area where Unit 178 was loaded, and the missing ICV seal test port plug was discovered.
x Briefings reinforcing Conduct of Operations requirements were held with all SIMCO Mobile Loading Unit personnel.
o These briefings included the importance of attention to detail and ensuring compliance with the applicable CH Packaging Operations Manual.
x Shadow boards were secured so they are not easily moved or knocked over.
(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 CoC 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 7.1.5.9 of the TRUPACT-II SAR specifies Install the ICV seal test port plug; tighten to 55 - 65 lb-in torque. After receipt at the WIPP and during the unloading process of Unit 178, it was discovered that Unit 178 was received without the ICV seal test port plug installed. Shipment LA250102, consisting of TRUPACT-II Units 127, 141 and 178, departed LANL on December 23, 2025, at 0926 hours0.0107 days <br />0.257 hours <br />0.00153 weeks <br />3.52343e-4 months <br /> (MST) and was received at the WIPP on December 23, 2025 at 1610 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.12605e-4 months <br /> (MST).
All other conditions required for the operation and shipment of the packages in accordance with the CoC 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 December 23, 2025, at 0926 hours0.0107 days <br />0.257 hours <br />0.00153 weeks <br />3.52343e-4 months <br /> (MST).
Document Control Desk TS:26:03003 P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 (2)(iii) The cause of each component or system failure or personnel error, if known; A breakdown in Conduct of Operations occurred. The operator interviewed discussed they worked through the process, then went back to sign each of the sign offs in the attachment later in the process. This is a procedure non-compliance, as the procedure is intended as a continuous use procedure.
It was also identified that the shadow boards (area where ICV removed components are placed for cleaning and inspections during loading operations) in the Radioassay and Nondestructive Testing (RANT) facility at LANL are not secured and easily moved or knocked over. This could have contributed to the event since the seal test port plug was found in the area on the ground near the toe board of the loading dock.
(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 178 on January 12, 2026, SIMCO Waste Handling personnel discovered the ICV seal test port plug 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; Further investigation into this is ongoing as part of the Causal Analysis. Some initial thoughts under consideration are that this was the last shipment of the year (operations took place on December 18, 2025, and the shipment was released on December 23, 2025) and the operators became distracted.
(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:26:03003 P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 (2)(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents.
Packaging Unit 178 Payload ID LR1075:
Radionuclide Total Activity (Ci)
Percentage of Total AM-241 4.635E+00 11.17%
AM-243 3.500E-06 0.00%
CS-137 1.224E-06 0.00%
NP-237 2.228E-05 0.00%
PU-238 2.758E+01 64.54%
PU-239 8.061E+00 19.13%
PU-240 1.943E+00 4.60%
PU-241 1.281E+01 0.50%
PU-242 2.294E-02 0.06%
SR-90 1.224E-06 0.00%
U-233 0.000E+00 0.00%
U-234 4.135E-03 0.00%
U-235 0.000E+00 0.00%
U-238 0.000E+00 0.00%
Total:
5.506E+01 100.00%
Document Control Desk TS:26:03003 P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 Physical and Chemical Form:
Material Type Weight (lbs)
Aluminum Base Metal Alloys 9.92 Cellulosics 28.00 Iron Base Metal Alloys 495.16 Other Inorganic Material 73.85 Other Metal/Alloys 12.79 Plastics 64.37 Rubber 13.45 Solidified Organic Material 18.74 Cellulosics Packaging Materials 81.57 Plastic/Liners Container Materials 256.62 Steel Container Materials 1001.12 Total:
2055.59
Document Control Desk TS:26:03003 P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 (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 for 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 identified in the Causal Analysis.
x Revision to procedure DOE/WIPP-02-3184 will be made to include independent verification checks and address corrective actions identified during the Causal Analysis, as applicable.
(5) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.
x Salado Isolation Mining Contractors letter number TS:24:03021 dated 7/29/2024:
Missing O-ring from ICV vent port cover.
x Nuclear Waste Partnership letter number TS:22:03001 dated 1/14/2022: ICV outer vent port plug not installed.
x Nuclear Waste Partnership letter number CP:17:01163 dated 6/28/2017:
Incorrect O-ring installed on ICV vent port cover.
x 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.
x 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.
x Washington TRU Solutions letter number PK:11:01634 dated 10/4/2011: Missing O-ring for OCV vent port plug, installed on wrong side of the flange.
x Washington TRU Solutions letter number PK:11:01408 dated 6/3/2011: Incorrect O-rings installed on main ICV upper and lower O-ring seal grooves.
Document Control Desk TS:26:03003 P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 x Washington TRU Solutions letter number PK:08:0005 dated 2/18/2009: Incorrect O-ring installed on OCA upper main O-ring groove.
x Washington TRU Solutions letter number PK:07:0020 dated 6/7/2007: Incorrect upper and lower main containment O-rings installed on both the ICV and OCV.
x Washington TRU Solutions letter number PK:06:0029 dated 12/28/2006: Missing O-ring from ICV seal test port plug.
x Westinghouse Electric Corporation Letter number HA:99:03107 dated 7/20/1999:
OCV vent port cover not installed.
(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.
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: M. Bollinger, CBFO ED C. Cable, EM 4.24 ED L. F. Gelder, EM-4.24 ED J. Marble, EM 4.2 ED J. Shenk, EM-4.24 ED D. M. Smith, CBFO ED M. Toothman, CBFO ED H. M. Stroud, USNRC ED TODD SELLMER (Affiliate)
Digitally signed by TODD SELLMER (Affiliate)
Date: 2026.02.23 11:09:59 -07'00'
Document Control Desk TS:26:03003 P.O. Box 2078 z Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 z Fax: (575) 234-7083 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.doe.gov to resolve any discrepancies in this submittal.
File Name File Size (KB)
Sensitivity Level Submittal Type REPORT PURSUANT TO 10 CFR 71.95 0.2 Publicly Available EIE