Freedom Of Information Act (FOIA) request to NRC regarding crane safety issues related to the June 1st, 2001 accident at San Onofre Nuclear Generation Station
Submitted by Russell D. Hoffman, June 28th, 2001
To: "FOIA/Privacy Act Officer" <email@example.com>
From: "Russell D. Hoffman" <firstname.lastname@example.org>
Subject: Freedom of Information Request under Section [5 U.S.C. 552]
Cc: "Pat Gwynn" <email@example.com>
FOIA/Privacy Act Officer
U.S. Nuclear Regulatory Commission
Mail Stop T-6 D8
Washington, DC 20555-0001
Pat Gwynn <firstname.lastname@example.org>
Deputy Regional Administrator for Region IV
Nuclear Regulatory Commission
Region IV Office, Texas
Russell D. Hoffman
P. O. Box 1936
Carlsbad, CA 92018
Date: June 29th, 2001 (10:50 am local time (PST)) -- (Note: This is a resend/replacement of an FOIA request made yesterday. The documents requested have not changed with this new version.)
Freedom of Information Act request to NRC
Note: "A FOIA or PA request must be in writing and may be sent by mail, facsimile (FAX) or e-mail to the NRC FOIA and PA Officer." -- from: http://www.nrc.gov/NRC/FOIA/foia.html .
Additional comments in bold are quoted from the NRC FOIA web page cited above:
"In accordance with the Freedom of Information Act (FOIA) and NRC regulations in 10 CFR Part 9, any person can request access to NRC records." I am doing so with this email.
"The FOIA requires the NRC to allow the public to have access unless the information is exempt under the FOIA from disclosure (e.g., classified national security, business proprietary, personal privacy, or investigative)." The information I am requesting concerns the lack of investigation into an incident which occurred at San Onofre Nuclear (Waste) Generating Station (hereinafter referred to as SONGS, because the "Waste" ("W") generally is ignored). SONGS is located in San Clemente, California. Unit II is NRC #50-361 and Unit III is NRC #50-362. Unit I is permanently shut down. On June 1st, 2001, a crane being moved by a gantry was dropped. I understand that a sling or strap broke, which caused the other slings or straps to also break, and the
load (a crane) was dropped. The counterweight swung out and demolished a portion of the stairwell which had not been roped off by the move team. Known prior crane accidents occurred in 1997, 1986, and during reactor construction (reactor head dropped 6 inches) and on at least two other occasions, although this is not actually a request for published information about prior accidents except insofar as it should already have been gathered for the investigation which evidently didn't happen and isn't happening. As I understand it, all that is being investigated regarding this incident is whether or not my original complaint was handled properly. The incident itself is not under investigation. Since the crane accident on June 1st, 2001 did not result in an investigation, this is not a request for information which the NRC should consider "investigative". Since it does not
appear that any proprietary straps, cranes, methods, etc. are involved (except perhaps unsafe ones), there is no exemption for business proprietary reasons. The persons to be named are public servants or at work in a large commercial facility, and thus my request does not involve personal privacy matters.
It is inconceivable that any national security issue is involved. Thus there are no reasons any of the information I am requesting should be exempt from public examination.
"The letter must specifically state that it is an FOIA request, and it must adequately describe the specific records or type of records sought so that the NRC staff can conduct a search for the requested records by exerting a reasonable amount of effort. Disclosure will be made by providing a copy of the documents requested or by making copies of the documents requested available for viewing in the NRC Headquarters Public Document Room (PDR). A requester may be required to pay fees for searching, reviewing, and copying records. A requester will be notified beforehand if fees will exceed $25."
I am requesting all records of all hearings, meetings, phone calls, conferences, conversations, emails, and postings of any sort which were conducted since the June 1st, 2001 accident, in which the accident was the purpose of the contact or discussed at any time during the contact. I am requesting the names of all attendees of all those contacts and of all the persons to whom information about those contacts was circulated, and what that information was. I am also requesting information about what contacts were made to the licensee (Southern California Edison Company, aka "SCE") regarding the incident and any reports which resulted from those contacts.
I am also requesting all information which NRC gathered from SCE regarding the incident, including but not limited to whether or not NRC has learned answers to the following questions regarding the incident:
Who was the manufacturer of the strap that broke ? (I understand the first strap to fail broke, although it may have come off the hook.)
What was the safety factor of the sling?
When was the sling purchased?
What was the width, thickness, and material of the sling?
In the reports on this incident, have there been any suggestions concerning other ways the load could have been handled so that this would not have happened?
Are NRC crane operation regulations for non-nuclear fuel lifts based on OSHA regulations?
Are NRC nuclear fuel lifts regulated by additional safety requirements and if so, how might those rules have helped SCE not to drop this load, had they been applied in the non-nuclear fuel portion of their operation?
What recommendations did NRC make after the incident?
When were those recommendations made?
How many moves and of what weight had the sling previously been used for?
How many slings were used for this move?
How many slings like it exist at the plant and have they each been inspected?
How many slings have been discarded from the plant since the accident?
When was NRC first informed about the accident?
When was the first NRC person other than on-site inspectors informed of this accident?
Does NRC have a crane safety training program for non-nuclear fuel crane operators?
What precautions exist to prevent non-nuclear loads from falling on or damaging radioactive materials, such as in the Spent Fuel Pools?
Does crane operator instruction include the reasons for the importance of not dropping a load into a Spent Fuel Pool or other nuclear-related portion of the plant? Are the full extent of the consequences presented in no uncertain terms?
What instructions are given to nuclear power plants for them to distribute to their crane operators concerning the swingout of the counterweight after a load drop?
How many crane inspectors work at NRC?
What information does NRC provide licensees regarding safe crane operation?
Was/Were the person/persons who trained the persons who dropped the load licensed for moving nuclear fuel at any time?
Were the persons who planned and/or executed the failed move licensed for moving nuclear fuel at any time?
How soon after the accident was an on-site NRC inspector present at the site?
Did the on-site NRC inspector note if any damage occurred outside the area that had been taped or roped off for the move?
Was the gantry centered over the load when the lift started or did the load swing?
Was the load jerked?
How many hours of gantry operation did the operator have?
How many qualified riggers approved the move prior to start (I understand it was at least three)?
What was the heaviest load the operator had ever lifted?
What percentage of rated capacity for the gantry, slings, hook, etc. was this load calculated to be?
Was the actual weight of the load ever measured?
Was a warning horn sounded prior to the lift?
Was the hoist brake tested for this load?
When was the hook last inspected for cracks, bends, throat opening, or broken latch?
When was the hook last inspected for wear?
How worn was the hook when its wear amount was last measured?
Were any sling hooks hanging loose when the load was lifted?
Were limit switches used to stop the load lift?
Is there a fire extinguisher in the cab of the gantry?
When was the rail alignment of the gantry last checked?
Was the load kept as close as possible to the floor at all times?
When was the last performance test done on the gantry that dropped the crane?
The following questions apply to both the crane that was dropped and the gantry from which it was dropped, and are developed from a National Safety Council publication. I would like to know the answers provided by the licensee (SCE) to NRC, and the results of any on-site NRC inspections of the applicable hoisting equipment.
When were the bearings last inspected?
When were all brakes last inspected for shoe wear?
When was the bridge last checked for proper alignment?
When were all bumpers last inspected?
When were all collector shoes or bars last inspected for pitting, wear, looseness, or breakage?
When were all controllers last tested for proper operation?
When were all couplings last inspected for looseness or wear?
When were all end stops on the trolley last inspected for looseness, missing, or improper placement?
When was all the footing last inspected?
When were all gears last inspected and/or lubricated?
When were all guards checked for bent, broken, or missing parts?
When were all hoisting cables last inspected for broken wires, etc.?
When were all hooks last checked for wear or bending, pitting, etc?
When were all hook block sheaves last inspected for chips, wear, etc?
When were all lights inspected?
When were all limit switches last inspected?
When were all lubrication elements inspected?
When were all mechanical parts such as rivets, covers, etc. inspected for looseness?
When were records for all overload relays inspected for indications of frequent tripping?
When were all rails inspected for breaks, chips, cracks, etc.?
When were all wheels last inspected?
Please note the following example of the importance of these and other steps, transcribed from page 101 of the Accident Prevention Manual for Industrial Operations, Engineering and Technology, Ninth Edition (copyright 1988 by the National Safety Council): "Many companies believe in performance tests for all hoisting equipment. They make sure that all hoisting equipment satisfactorily completes a performance (operating) test when placed in service on a project. The test should be repeated prior to unusual or critical lifts of load bearing or load controlling parts; after alteration, modification, or reassembly; and at least every year. The test results should be recorded and kept available for review." (My italics). I would like to see all those records for the past five years that apply to the two lifting devices
involved in this accident (the crane that fell and the gantry it fell from) as well as for all hooks, slings, wires, ropes, control boxes, etc. involved in the move for the same period of time.
"If a person is seeking records that pertain to another person, that information is usually not disclosed unless the requester obtains the other person's written consent and submits it along with the request." I assume this is not applicable because I am seeking information about an incident, and all persons mentioned are only named for determining that proper licenses have been obtained, training has been done, other accidents by the same persons have been reviewed, etc.. Any names, or lists of names will not be used for commercial purposes. NRC is required under federal statute to, in cases where an exemption may apply to some material (like say a person's name which if released would violate the Privacy Act) to redact only that portion of the document that the exemption applies to and must release the rest of the document.
I would appreciate it if this matter is expedited quickly, because SONGS continues to operate as we wait, despite recurring accidents and indications that the entire station is in sorry need of being retired because it is wearing out far faster than expected. Furthermore it appears that NRC took control from OSHA for safety issues at nuclear power plants around the country, but it appears that NRC did not replace OSHA regulations with an equal or stronger regulatory control. These questions are designed to determine if NRC's crane regulations and oversight are sufficient to protect the public from the serious consequences which are possible if a lifting accident involving nuclear fuel occurs. Also, this author has heard that the counterweight swung out well past the area protected by personnel barriers during the lift. If this is true, then it would appear that even non-nuclear accidents can have nuclear consequences,
since proper separation of the two cannot be assured by current personnel, since they cannot keep their lifting accidents within the blocked-off areas. Furthermore, in normal industrial safety analysis, all accidents at a site would be considered when determining whether a plant is safely operated. It appears NRC ignores everything that can, by any stretch of reason, be considered a non-nuclear accident at the plant. These questions are designed to determine if the licensee is capable of protecting the public based on past behavior in the event that, as assumed here based on known lack of NRC interest to this incident as shown so far, NRC regulations and/or operations are insufficient to protect the public.
An important purpose of this request is to educate the public on important aspects of the function of government and the successful (or unsuccessful) actualization of that function, specifically NRC as it pertains to its responsibilities under the Atomic Energy Act and other federal legislation. I and my affiliates are in a better position to do this, and reach more people than is possible for NRC to do under any existing NRC public information programs, and as such I am requesting a waiver of any fees related to this request.
I would appreciate acknowledgement of receipt of this request with some indication of how quickly it will be acted upon. Every day San Onofre Nuclear (Waste) Generating station operates it produces about 500 pounds of High Level Radioactive Waste (HLRW) and about a ton of so-called Low Level Radioactive Waste (LLRW), which is HLRW with filler added (steel, brass, plastic, cloth, water, etc.).
All this nuclear waste has to be moved many times, by someone using a crane. This accident and all lifting accidents at the plant should be considered indicative of the licensee's nuclear-fuel-handling capabilities.
Russell D. Hoffman
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First posted June 29th, 2001.
Webwiz: Russell D. Hoffman