Nuclear insider cites dangers of Vermont Yankee casks
By Kathryn Casa | Vermont Guardian
Posted March 24, 2005
The casks that Vermont Yankee plans to use to store highly radioactive nuclear waste in Vernon are “time bombs” riddled with material, design and welding flaws, according to a former nuclear industry inspector and auditor of the Holtec cask system.
Oscar Shirani, the lead quality-assurance auditor in 1999 and 2000 for Commonwealth Edison, which later became the nuclear giant Exelon, pinpointed major design and fabrication problems during an inspection of casks made by Holtec International, the supplier from which Vermont Yankee owner Entergy Nuclear plans to purchase casks to store waste from the Vernon reactor.
Holtec casks are in use at 33 nuclear sites around the country, according to the New Jersey-based company’s website. There is no known problem with any of the casks in use, and a spokeswoman for the company notes that the Nuclear Regulatory Commission found no basis for Shirani’s allegations.
But Shirani says the structural integrity of the casks is so questionable that problems are “only a matter of time.”
“We’ve been lucky so far. We may be lucky for the next 10 years. But we cannot for sure say that there are reasonable assurances that these casks are safe. There is reasonable assurance that the structural integrity is not intact. It should be the other way around,” Shirani said in one of several interviews with the Vermont Guardian.
The 2000 audit that he led uncovered so many design, manufacturing, and regulatory code violations with the Holtec casks that in May 2000, the Shirani issued a “stop work order” to force the company to correct its practices.
He alleges that Exelon refused to allow him to perform a follow-up of his audit, and that the company falsified quality-assurance documents, stating that his allegations had been resolved when in fact they were not.
Exelon did not return phone calls regarding this story.
The NRC formally discount’s Shirani’s concerns, but Ross Landsman, an NRC Region III inspector, has backed the charges and has refused to approve the NRC’s resolution of Shirani’s concerns.
“The guys who falsified my audit reports to say theses casks are safe are worse than any terrorists because these casks are not safe, they are not structurally sound,” Shirani told the Vermont Guardian.
The problems with the Holtec casks are systemic and relate to quality assurance in the material, welding and inspection of the casks, he charged.
“The same quality assurance applies to all the casks that they do, it doesn’t matter how many different types they have,” said Shirani, who also performed audits for international coalitions of nuclear utilities. “The quality-assurance design process, the inspection process, the welding process is the same. There has been a significant quality-assurance program breakdown.”
Holtec International spokeswoman Joy Russell said the company takes Shirani’s charges “very seriously, but we have always held that they were unfounded and we feel the NRC’s ... report has backed up our belief.”
Russell would not say whether the company has altered its manufacturing or quality-assurance practices since Shirani’s audit. “We view quality assurance as a journey that we are always striving to improve. So if we have undergone an audit or some sort ... if we have a finding or recommendation we always give it the utmost importance and will incorporate such comments as necessary,” she commented.
According to Vermont Yankee spokesman Rob Williams, "The issues received a thorough review by the NRC and by the NRC's office of inspector general, and were found to be unsubstantiated. The manufacturer is a leader in the industry and does quality work, and part of makes them a leader in the industry is their effective quality-assurance program and the oversight. That's why we do business with them."
In an application filed with the Windham Regional Commission, Entergy is seeking permission from the state to build a temporary nuclear waste storage site using up to 36 Holtec HI-STORM 100S system casks on a concrete pad near the Vernon reactor.
Holtec’s HI-STORM 100S is one of 15 dry-cask systems issued a general 20-year license by the NRC, which means Entergy needs no modification to Vermont Yankee’s federal operating license to install the casks in Vernon. But Vermont law requires the company to get approval from the state Legislature, as well as a certificate of public good from the Vermont Public Service Board, before any nuclear waste facility can be built here.
At least one U.S. senator wants to see the facility become a permanent disposal facility.
Like more than 100 commercial nuclear reactors throughout the country, Vermont Yankee eventually expected to move its waste to a central federal repository at Nevada’s Yucca Mountain. But numerous problems have stalled approval of that facility and called into question whether it will ever open.
Nevada lawmakers have been battling to keep the waste out of their state. On March 10, Sen. Harry Reid, D-NV, said he plans to introduce a bill that would require the Department of Energy to assume responsibility for storing nuclear waste at the sites where the waste is created, thereby setting up the specter of a long-term waste dump in southern Vermont.
Vermont’s legislative leaders appear to have accepted that possibility, and seem poised to allow Vermont Yankee to use the Holtec system in exchange for a per-cask tax, similar to one imposed in Minnesota, that could be used to develop renewable energy sources.
Ken Pentel, a member of the Minnesota Green Party, said approval of dry-cask storage has been a slippery slope in his state. The legislature recently removed a 1994 limitation on the number of casks allowed, and this year $10 million of the state’s $16 million renewable energy fund — generated from tax on the casks — has been earmarked for a coal gasification plant.
“The intent of the renewable energy fund is being distorted and misused, in my opinion,” Pentel said.
“A lesson learned is that once it happens you end up displacing hundreds of millions of dollars from local economic development in energy efficiency, co-generation and renewables,” Pentel said. “The more we keep these central, very toxic systems going, we’re adding to the remedial activity later. We end up paying for future waste so that’s an add-on cost. If you stop that type of investment you immediately can go into things that are going to decrease the cost of energy through efficiency and local production of renewables.”
In 2000, the NRC determined that the Holtec’s HI-STORM 100 cask system, “as designed and when fabricated and used in accordance with the conditions specified …” meets NRC requirements and “will provide adequate protection of public health and safety and the environment.”
“The lid welding and testing requirements and the structural and thermal analyses … give the NRC staff reasonable assurance that cask confinement and fuel integrity will be maintained under design basis normal, off-normal, or accident events,” the agency concluded.
But Kevin Kamps, a nuclear waste specialist with the of the Nuclear Information and Resources Service in Washington, points out that problems with other types of cask systems have arisen after only a few years in use, including helium leaks, cracks in a concrete outer shield and weld flaws.
“These repeated chemical failures, premature aging, degradation and deterioration really point to the need for a comprehensive review of the cask licensing process,” Kamps told regulators during a February 2000 NRC briefing on spent-fuel projects.
At the Palisades nuclear plant in Michigan, Kamps said, the storage concrete pad was poured on a sand dune. “That’s what happens when there is no (environmental impact study) and no challenge.”
The NRC says casks are designed to resist floods, tornadoes, projectiles, temperature extremes “and other unusual scenarios.” The agency requires that spent fuel to be cooled in a spent-fuel pool for five years before being transferred to dry casks.
“Typically, the maximum heat generated from 24 fuel assemblies stored in a cask is less than that given off by a typical home heating system in an hour,” according to the NRC website. “As the fuel cools further, the heat generated will decrease over time.”
But Kamps has called on the NRC to abandon the general license procedure. “These nuclear waste dumps are being located next to environmental treasures, fresh drinking water supplies, public property and nearby communities,” he stated in 2000.
“In short, the NRC has stripped the public of its right to an adjudicatory process of the right to discovery and cross examination which they would have with public hearings,” Kamps stated.
He noted that even the agency’s chairman, Nils Diaz, opposed the extension in a 2-1 split. “My hope is that he would be, like we are, concerned about a 40-year extension – that’s long time out to rubber stamp.”
Call for Congressional probe
According to Shirani, the NRC license for Holtec is meaningless because federal regulators failed to look closely at the company’s design process. He claims his 2000 audit embarrassed the NRC because the agency had also audited the Holtec casks just a few months previously and found no problems.
“The NRC goes into a corner and reads procedures and writes a report,” Shirani told the Vermont Guardian. “I constantly check work during an audit.”
Shirani has a master’s degree in civil structural engineering from George Washington University in Washington and worked for more than two decades in the nuclear industry before being sidelined by Exelon in 2000, he says, for refusing to back down on his audit of the Holtec casks.
He said after he confronted Holtec officials with his findings during a November 2000 meeting, he was transferred out of the Exelon’s nuclear department into finance, a field in which he has no training, and was eventually fired.
Anti-nuclear activists have called for congressional hearings to investigate Shirani’s findings.
Kamps said any dry-cask storage facility that Vermont approves should include concrete, steel or earthern berms surrounding dispersed casks, to safeguard the facilities from attack. “The Holtecs are only a couple feet of concrete and then 3.25 inches or metal or steel,” Kamps said. “There are weapons — high explosives, shaped charges, an aerial attack — that could pretty easily destroy that.”
He added: “We’re not clear on what improvements have happened since Sept. 11. We hear from the NRC that they have greatly enhanced security. But the only evidence that we have is security guards working 72 hour work weeks.”
Summary of Oscar Shirani’s Allegations of Quality Assurance Violations Against Holtec Storage/Transport Casks.
Holtec storage/transport casks are the first dual purpose container for irradiated nuclear fuel certified by the U.S. Nuclear Regulatory Commission (NRC). According to Holtec International's website ( http://www.holtecinternational.com), Holtec casks are already deployed at 33 U.S. nuclear power plants. Up to 4,000 rail-sized Holtec storage/transport casks would also be used at the proposed Private Fuel Storage interim storage facility in Utah. Given the U.S. Department of Energy's (DOE) recent decision to use “mostly rail” transport to the proposed Yucca Mountain repository, Holtec casks could very well become among the most used shipping containers for highly radioactive waste.
Exelon, the largest nuclear utility in U.S., uses Holtec casks for irradiated fuel storage at its reactor sites. In 1999 and 2000, Oscar Shirani, as a lead quality assurance (QA) auditor for Exelon, identified numerous “major design and fabrication issues” during a QA inspection of Holtec International (the cask designer), Omni Fabrication, and U.S. Tool & Die (the subcontractors responsible for manufacturing the casks). In fact, he identified a “major breakdown” in the QA program itself. The problems were so severe that Shirani sought a Stop Work Order against the manufacturer of the casks until the problems were addressed. Instead, he was run out of Exelon. According to Shirani, these design and manufacturing flaws mean that the structural integrity of the Holtec casks is indeterminate and unreliable, especially under heat-related stress such as during a severe transportation accident.
Although NRC has dismissed Shirani’s concerns, NRC Region III ( Chicago office) dry cask inspector Ross Landsman refused to sign and approve the NRC’s resolution of Shirani’s concerns, concluding that this same kind of thinking led to NASA’s Space Shuttle disasters.He stated in September 2003, “Holtec, as far as I’m concerned, has a non-effective QA program, and U.S. Tool & Die has no QA program whatsoever.” Landsman added that NRC’s Nuclear Reactor Regulation division did a poor follow-up on the significant issues identified, and pre-maturely closed them.
Shirani alleges that all existing Holtec casks, some of which are already loaded with highly radioactive waste, as well as the casks under construction now, still flagrantly violate engineering codes (such as those of the American Society of Mechanical Engineers [ASME] and American National Standards Institute [ANSI]), as well as NRC regulations. He concludes that the Holtec casks are “nothing but garbage cans” if they are not made in accordance with government specifications.
Specific examples of the QA violations and related problems alleged by Shirani include:
Welding problems, such improper “fast cooling” of hot cask welds and metal using fans and air conditioning equipment, which are in violation of ASME and ANSI codes and risk tearing and cracking of the unevenly cooling welds and metal, in order to meet production goals. Welds on the casks were also performed by unqualified welders. Even NRC has acknowledged that “weld quality records are not in agreement with the code requirements.”
Inadequate controls on the quality of materials used in the manufacturing process, risking brittleness and weakness in the casks.
Holtec’s failure to report holes in neutron shielding material (neutrons are especially hazardous emissions from highly radioactive waste).
US Tool & Die’s failure to use coupon (a small physical sample of metal) testing, and Post Weld Heat Treatment on a regular basis, as required by ASME code and in violation of the codes that were part of the license agreement with NRC.
Holtec and U.S. Tool & Die quality control inspectors’ bypass of hundreds of non-conforming conditions, departures from the original design during cask manufacture. The departures from the original design amount to design changes that require revised analysis to guarantee that manufactured casks actually live up to the structural integrity of the original design. The fact that this revised analysis was never done is in violation of ASME and ANSI codes, and thus NRC regulations, and means the actual manufactured casks' structural integrity is questionable, according to Shirani.
Holtec’s consent to allow U.S. Tool & Die to make design decisions and changes, despite the fact that U.S. Tool & Die does not have design control capability under its QA program.
Failure to conduct a “root cause investigation” of Holtec’s QA program, even though root causes are the main reason for repeated deficiencies.
Exelon’s obstruction of Shirani from performing any follow-up of the audit to confirm that problems had been solved, despite knowing that the fabrication issues identified would have a detrimental impact on the design.
Exelon’s falsified quality-assurance documents and the misleading of the NRC investigation, stating that Shirani’s allegations of QA violations were resolved when in fact they were not.
Lack of understanding in the NRC of the design control process and Holtec's QA program, relating to flaws in welding, design, manufacturing, and materials procurement control. NRC lacks a corrective action mechanism for repeated findings. Shirani alleges his audit findings embarrassed NRC because it had also audited the Holtec casks just a few months previously but found no problems whatsoever.
Shirani concludes that these numerous design and manufacturing flaws call into question the structural integrity of the Holtec casks, especially under heat-related stress such as during severe transportation accidents. He also warns that his eight-day audit showed him only a snap shot of problems, and that there could in fact be additional ones yet to be identified.
 Elizabeth Brackett, "Nuclear Controversy," " Chicago Tonight," WTTW Channel 11 Television, Chicago, Illinois, January 29, 2004.
 J.A. Savage, "Whistleblower Alleges PG&E Proposed Dry Casks Slipshod," California Energy Circuit, Vol. 1, No. 1, Berkeley, California, September 5, 2003.
 April 2002 NRC review panel memo, cited in J.A. Savage, "Whistleblower Alleges PG&E Proposed Dry Casks Slipshod," California Energy Circuit, Vol. 1, No. 1, Berkeley, California, September 5, 2003.
* This summary was prepared by Kevin Kamps (202-328-0002 ext. 14; firstname.lastname@example.org), Nuclear Waste Specialist at Nuclear Information and Resource Service in Washington, D.C. July 22, 2004.