ML18032A197

Comment (46) of Cheryl Harding Regarding Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18032A197
Person / Time
Site:	San Onofre
Issue date:	01/02/2018
From:	Harding C - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00046, NRC-2017-0211, NUREG-2215
Download: ML18032A197 (3)

Text

As of: 1/8/18 4:52 PM Received:

January 02, 2018 Status: Pending_Post Page 1 of3 PUBLIC SUBMISSION Tracking No. lk2-90pe-5q57 Comments Due: January 02, 2018 Submission Type: Web Docket: NRC-2017-0211 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-0047 Comment on FR Doc# 2017-24734 Submitter Information

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7 Name: Cheryl Harding Address: Box 309 SUNSI Review Complete Template=

ADM-013 E-RIDS= ADM-03 Stanton, NJ, 08885 Email: cfharding9@gmail.com Add= 1-tr-e.A-Ysp,;#J (J'<S..s:)

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' General Comment Docket ID NRC-2017-0211 I do not understand why the NRC would support the use of thin-walled canisters.

Such canisters clearly do not have the safety features needed to protect us or the environment.

They are an accident waiting to happen, and once they begin to leak, it will be next to impossible to contain the damage. The short-term savings will only lead to escalating long-term costs. I strongly endorse the following comment submitted by Donna Gilmore. Date: January 2, 2018 Comments to NRC Docket ID NRC-2017-0211, NUREG-2215 https://www.fdms.gov/fdms/getcontent?objectld=0900006482d9037l&format=xml&showorig=false 01/08/2018 NRC Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities Draft, November 2017 https://www.nrc.gov/docs/MLl 731/MLl 7310A693.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.

nuclear-waste-dry-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).

NUREG-2215 states it requires "conservative assumpt ions", "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 a nd 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, https://www.fdms.gov/fdms/getcontent?objectld=0900006482d903 71 &format=xml&showorig=false Page 2 of3 01/08/2018 Donna Gilmore, SanOnofreSafety.org donnagilmore@gmail.com 949-204-7794 https://www .fdms.gov/fdms/

getcontent?objectld=0900006482d903 71 &format=xml&showorig=false Page 3 of3 01/08/2018

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