ML18037A681

Comment (93) of Ricardo Toro Regarding Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18037A681
Person / Time
Site:	San Onofre
Issue date:	01/02/2018
From:	Toro R - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00093, NRC-2017-0211
Download: ML18037A681 (3)

Text

As of: 1/9/18 11:07 AM Received:

January 02, 2018 Status: Pending_Post Pagel of2 PUBLIC SUBMISSION Tracking No. lk2-90pg-oep6 Comments Due: January 02, 2018 Submission Type: Web Docket: NRC-2017-0211 Standard Review Plan for Spent Fuel Dry Storage Systems and FaciFties i 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-0094 Comment on FR Doc# 2017-24734 ) ___ _ ([§) Submitter Information

~J f' I? 6 ;J 'I'-/'{ Name: Anonymous Anonymous JI /15 /;1017 General Comment I would like to express my concerns over using thin temporary storage containers instead of thick casks used by other countries.

Although I don't live too close to the San Onofre Plant, I'm concerned that a leakage from the temporary containers may cause significant damage to the nearby areas. I support the SanOnofreSafety comments submitted by Donna Gilmore. Respectfully, Ricardo Toro 151 S Alice Circle Anaheim, CA 92806 Attachments SUNSI Review Complete Template=

ADM -013 E-RIDS= ADM -03 Add= ""5Gye.JH.)"_~lll1V,U (Jq5_~ https://www.fdms.gov/fdms/getcontent?objectld=0900006482d909b4&format=xml&showorig=false 01/09/2018 Page 2 of2 Comments to NUREG-2215Gilmore2018-01-02 https://www.fdms.gov/fdms/

getcontent?objectld=0900006482d909b4&format=xml&showorig=false 01/09/2018 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-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 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 man.dated 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 ASME container certification Defense in depth (redundancy)

Stored in concrete building Gamma & neutron protection Transportable Proven technology 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