Current-Argus Staff Writer
CARLSBAD — The Department of Energy's Carlsbad Field Office has provided its regulators with information detailing why a drum of transuranic waste may have been mistakenly shipped from Los Alamos National Laboratory to the Waste Isolation Pilot Plant near Carlsbad despite extensive procedures designed to keep such a problem from happening.
The drum, which contained a prohibited amount of liquid, has been returned to LANL, but shipments from LANL have been postponed, pending an investigation. An Environmental Protection Agency visit to LANL, originally scheduled for this week, has been pushed back to later in the month.
On Friday, Dave Moody, manager of the Carlsbad Field Office, issued a five-page memo to the EPA outlining the history of the LANL drum that was characterized and shipped despite having an unresolved non-conformance report.
The 55-gallon drum, Moody wrote, was originally examined through real-time radiography and no deficiencies were identified. However, a portion
of waste containers examined through radiography were also required to be examined visually, and the drum in question was selected for a follow up visual examination in 2005. During the visual examination, liquid in excess of 1 percent of the waste container was identified. The drum was tagged as noncompliant and set aside for remediation, Moody wrote. Remediation, in the case of a liquid, could have meant a variety of procedures used to absorb or vacuum the liquid out.
But in April 2008, the non-conformance report for the visual examination was mistakenly dismissed due to an assumption that the condition had been fixed. The drum was overpacked with three other drums from the same waste stream into a standard waste box and shipped to WIPP.
On June 6, employees of Washington TRU Solutions noticed the problem when a routine check of unresolved non-conformance reports identified the drum as already placed within the repository, Moody wrote. Carlsbad officials decided to remove the drum based on the fact that it was emplaced at WIPP with the non-conformance report.
"It should be noted that the prohibition on liquids is based on the volume of the payload container," Moody wrote. "Thus, even though the drum was overpacked for container integrity reasons, the overpacking resolved the prohibited condition."
What checks were in place to make sure such a problem didn't occur?
A primary check, Moody wrote, requires that two people independently ensure that no unresolved non-conformance reports exist prior to the certification of a given waste container. A secondary check requires that all containers issued non-conformance reports be tagged and/or physically segregated. No container is shipped with an NCR tag attached.
The two individuals who approved the drum in the primary check — essentially the paperwork portion of the process — said there were no unresolved non-conformance reports. Moody speculated that they may have missed identifying the non-conformance report partially because nearly all of the waste containers processed at LANL have been tagged for remediation at some point.
"Nearly all of the containers remaining in the inventory similarly require remediation," he wrote. "The condition is more severe at LANL than any other location where (Central Characterization Project) is deployed."
As another reason, Moody wrote, there are only a handful of waste containers that have passed the radiography test but were then considered to be noncompliant due to the visual examination.
"Of the nearly 50,000 containers processed by the CCP, this total population amounts to eight containers," Moody wrote.
Non-conformance reports are sometimes issued against an individual container, Moody wrote, but they also may be issued against a group of containers due to a common problem.
"Accordingly, in this specific instance, both individuals assumed they were looking at a container that had been processed and corrected through remediation," Moody concluded "This assumption led to an inadequate review by both individuals."
The secondary check — physically noting the non-conformance tag — also failed in this instance, and personnel involved with operations have stated that no tags were attached. The presence or absence of the tag will be verified, Moody wrote.
"Our reviews of tagging operations at LANL have shown that tags do, in fact, occasionally become separated from the container," Moody noted. The plastic tie used to secure the tag appears to be the problem, and project employees had already begun substituting metal ties in place of the plastic ones.
So far, Moody wrote, the DOE has examined other shipments and waste containers to verify that there are no other unresolved non-conformance reports. The agency has added workplace meetings and briefings to emphasize the reviewing process and will add two additional interim reviews to ensure no containers are shipped or certified with unresolved non-conformance reports. Additionally, an electronic hold has been placed on all LANL waste containers with unresolved non-conformance reports until every container can be checked to verify that it is appropriately tagged. Plastic ties have also been replaced.
In response to Moody's letter, Environmentalist Don Hancock, with the Southwest Research and Information Center, issued his own letter to the EPA calling for increased segregation of non-compliant containers.
"We urge that EPA require changed procedures and actual physical segregation of containers and that you conduct inspections to insure adequate implementation of those procedures, in addition to inspecting the changes that CBFO proposes, before allowing shipments from LANL to resume," he wrote.
He also called for additional EPA investigations at other sites that send waste to WIPP.
"We believe that the actions (proposed by the DOE) are insufficient and will not provide adequate confidence that such an error will not recur," Hancock wrote.