ML18023A144

Comment (3) of Donna Gilmore on Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18023A144
Person / Time
Site:	San Onofre
Issue date:	01/02/2018
From:	Gilmore D San Onofre Safety
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00003, NRC-2017-0211, NUREG-2215
Download: ML18023A144 (3)

Text

As of: 1/8/18 3:53 PM Received:

January 02, 2018 Status: Pending_Post Page 1 of2 PUBLIC SUBMISSION Tracking No. lk2-90p9-u0xm Comments Due: January 02, 2018 Submission Type: Web Docket: NRC-201 7-0211 Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities Comment On: NRC-2017-0211-0001 Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities; Request for Comment on Draft NUREG Document:

NRC-2017-0211-DRAFT-0004 Comment on FR Doc# 2017-24734

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• Submitter Information Name: Donna Gilmore Address: United States, Email: donnagilmore@gmail.com SUNSI Review Complete Template = ADM -013 E-RIDS= ADM -03 J~r~1n:y5mifh Cjt:fSQ , _______ .. ______ h_*---~------------*----------------~-----**-**----*------------------------------***

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r General Comment The NRC cannot meet its mission to "ensure adequate protection of public health and safety and the environment" if it continues to allow thin-wall welded canisters they admit are vulnerable to cracks, that cannot be fully inspected (inside or out), and cannot be repaired, maintained and monitored to prevent (not just detect) radiological leaks. There is no adequate or proven detailed plan required to address major radiological leaks, or to address on-site replacement of containers.

Seismic requirements for partial cracks is not addressed.

See below webpage for details on the Holtec UMAX System planned for San Onofre and why this is an example of a system with major problems that should not be approved.

https://sanonofresafety.org/holtec-hi-siorm-umax-nuclear-waste-dty-storage-system/

Each canister contains about as much or more lethal Cesium-137 as released from the 1986 Chernobyl nuclear disaster, yet the NRC knows the boron metal in the canisters will not prevent the fuel from going critical if exposed to non-borated water from through wall cracks (in storage or transport).

https://www .f~ms.gov/fdms/

getcontent?objectld=0900006482d8e2a6&format=xml&showorig=false 01/08/2018 I

/ Page 2 of2 NUREG-2215 states it requires "conservative assumptions", "inspections", and admits to many "unknowns".

NUREG-2215 is not "conservative", does not require adequate "inspections", and does not resolve the many "unknowns" that would be eliminated if the NRC mandated and enforced critical safety requirements to inspect, monitor, maintain and repair (both inside and out) to PREVENT leaks. Proven dry storage technology exists that meets critical basic safety requirements we expect in a car. Does the NRC consider thin-wall canisters "conservative assumptions" compared to thick-wall casks? If so, why? Why does the NRC allow containers that do not meet these basic critical safety requirements?

See attached document and below link containing these comments, plus a Basic Safety Requirements Chart comparing thin and thick wall containers.

https://sanonofresafety.files.wordpress.com/2018/01/comments-to-nureg-2215gilmore2018-01-02.pdf Respectfully, Donna Gilmore, SanOnofreSafety .org donnagilmore@gmail.com 949-204-7794 Attachments Comments to NUREG-2215Gilmore2018-01-02 https://www.fdms.gov/fdms/getcontent?object1d=0900006482d8e2a6&format=xml&showorig=fals(?

01/08/2018 Date: January 2, 2018 Comments to NRC Docket ID NRC-2017-0211, NUREG-2215 NRC Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities Draft, November 2017 https://www.nrc.gov/docs/ML1731/ML17310A693.pdf The NRC cannot meet its mission to "ensure adequate protection of public health and safety and the environment" if it continues to allow thin-wall welded canisters they admit are vulnerable to cracks, that cannot be fully inspected (inside or out), and cannot be repaired, maintained and monitored to prevent (not just detect) radiological leaks. There is no adequate or proven detailed plan required to address major radiological leaks, or to address on-site replacement of containers.

Seismic requirements for partial cracks is not addressed.

See below webpage for details on the Holtec UMAX System planned for San Onofre and why this is an example of a system with major problems that should not be approved.

https://sanonofresafety.org/holtec-hi-storm-umax-nuc/ear-waste-dry-storage-system/

Each canister contains about as much or more let~al Cesium-137 as released from the 1986 Chernobyl nuclear disaster, yet the NRC knows the boron metal in the canisters will not prevent the fuel from going critical if exposed to non-borated water from through wall cracks (in storage or transport).

NUREG-2215 states it requires "conservative assumptions", "inspections", and admits to many "unknowns".

NUREG-2215 is not "conservative", does not require adequate "inspections", and does not resolve the many "unknowns" that would be eliminated if the NRC mandated and enforced critical safety requirements to inspect, monitor, maintain and repair (both inside and out) to PREVENT leaks. Proven dry storage technology exists that meets critical basic safety requirements we expect in a car. Does the NRC consider thin-wall canisters "conservative assumptions" compared to thick-wall casks? If so, why? Why does the NRC allow containers that do not meet these basic critical safety requirements?

Respectfully, Donna Gilmore, SanOnofreSafety.org donnagilmore@gmail.com 949-204-7794 Basic Safety Requirements Thick walls Won't crack. Ability to inspect inside & out, maintain, repair (fuel baskets, other parts) Monitor to fix problems before leaks I ASME container certification Defense in depth (redundancy)

Stored in concrete building Gamma & neutron protection Transportable Proven tEichnology Thin-wall canisters Thick-wall casks No. Only 1/2 to 5/8th of an inch Yes. 10 to 19. 75 inches No Yes No Yes No Yes No Yes No Yes No Yes Requires vented concrete overpack Yes No transport with cracks. 10 CFR § Yes 71.85 No. Conditions unknown. Most in Yes. Inspected and used use less than 15 yrs, a few*30 yrs. over 40 years