DRC-2024-007630

November 21, 2024 CD-2024-238
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, UT 84114-4880
Subject: EPA ID Number UTD982598898
Radioactive Material License UT2300249
Follow up to Potential Discrepancy with Shipment 1072-07-0875
Dear Mr. Hansen,
In a letter dated November 15, 2024 (CD-2024-234), EnergySolutions notified the
Director of the Division of Waste Management and Radiation Control of a potential
discrepancy from shipment 1072-07-0875; Bates Number L140077 (GSAP 2011011105).
As described previously; while performing the Radiological Acceptance Survey on
November 14, 2024, dose rates that exceed the limits from Department of Transportation
(DOT) 49 CFR Part 173.441, Radiation level limitations and exclusive use provisions,
and Nuclear Regulatory Commission (NRC) 10 CFR 71.47, External radiation standards
for all packages, were obtained.
Shipment 1072-07-0875, consisting of Demolition Debris from the Omaha Public Power
District (OPPD) Fort Calhoun Nuclear Generating Station (FCS) Decommissioning
Project destined for direct disposal at LLRW, was moved into the Restricted Area and the
generator notified. The Radiological Acceptance Survey from Railcar FURX322364 (see
attached) performed in the field yielded results with the highest contact dose rate at 765
mR/hr with instrument model L-3078 (serial number 25023333) and a confirmational
contact dose rate at 744 mR/hr was taken with model L-78 (serial number 234101),
where DOT limits in 49 CFR 173.441 and NRC limits in 10 CFR71.47 prohibit dose
rates in exceedance of 200 m/R/hr at any point on the external surface of the package.
Railcar FURX322364 was managed at Clive in the Rotary Facility on November 15,
2024. A Radiological Survey (see attached) was performed on the dumped material to
find that the high dose rates were due to a small piece of concrete/rubble with contact
dose rates as high as 986 mR/hr contact (see attached). It is believed that this small piece
was shielded at the time of the DOT-compliant departure survey.
Mr. Doug Hansen
November 21, 2024
CD-2024-238
Page 2
As part of immediate corrective actions associated with waste stream 1072-07, on
November 14, 2024, OPPD suspended both the loading of railcars and all future
shipments, until objective evidence from corrective actions is established within their
Corrective Action Program. However, prior to issuing the stop shipment order for Railcar
FURX322364, the following 12 additional railcars containing waste from 1072-07 were
already in transit and will arrive at the Clive facility prior to the implementation of any
corrective actions:
Expected
Arrival
Railcar
Number
Shipment
number
11/27/2024 FURX322336 1072-07-0893
11/27/2024 FURX322504 1072-07-0892
11/27/2024 FURX322355 1072-07-0891
11/27/2024 FURX322519 1072-07-0890
11/27/2024 FURX322402 1072-07-0889
11/27/2024 FURX322360 1072-07-0888
11/27/2024 FURX322540 1072-07-0887
11/27/2024 FURX322590 1072-07-0886
11/27/2024 FURX322372 1072-07-0885
11/27/2024 FURX322518 1072-07-0884
11/27/2024 FURX322403 1072-07-0883
11/27/2024 FURX322585 1072-07-0882
Since these railcars underwent routine comprehensive external surveys and inspections
prior to their dispatch from OPPD, it is unlikely that load shifting similar to what was
suspected with Railcar FURX322364 will result in excessive external dose rates.
Nevertheless, these railcars will be thoroughly inspected and undergo Radiological
Surveys upon arrival at the Clive facility to ensure compliance with DOT requirements
and Clive’s Incoming Shipment Procedures. In addition to the immediate corrective
actions outlined above, OPPD has developed a detailed plan to address both short-term
and ongoing actions, as outlined in the “Fort Calhoun Waste Loading Operations Action
Plan OPPD CR-2024-00198” Memo to file (see attached).
Mr. Doug Hansen
November 21, 2024
CD-2024-238
Page 3
Condition Report CR-2024-1090 has been generated to track actions associated with this
issue. Please consider this the follow-up written notification (required in Radioactive
Materials License UT2300249, Condition 68) for this discrepancy.
Should there be any questions regarding this notification, please contact me at 801-649-
2043.
Sincerely,
Steve D. Gurr
Environmental Engineer and Manager
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment
for knowing violations
Mr. Doug Hansen
November 21, 2024
CD-2024-238
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