ML18066A527

Comment (136) of Laura Lynch Regarding Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18066A527
Person / Time
Site:	San Onofre
Issue date:	01/02/2018
From:	Lynch L - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00136, NRC-2017-0211, NUREG-2215
Download: ML18066A527 (2)

Text

Blount, Barbara

Subject:

FW: Comments to NRC Docket ID NRC-2017-0211, NUREG-2215 , January 2, 2018 Comments to NRC DockeUD 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/MLl 731 OA693 .pdf @ t:(J. #.. *2f'f'/ ' . 11/15 /~11 SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= :5.f.r-elf'l./5111;#

t. c>"tc.5~ TO WHOM IT MAY CONCERN: I have no confidence in the NRC's Nuclear Waste Plans for San Onofre's SFDS. I have grave concerns that the NRC is considering to allow the burial of 3 .6 million pounds of hot nuclear waste that will remain permanently deadly to all life for more than 10,000 generations; and to bury it only 108 feet from the beach on the shoreline of the Pacific Ocean? This is clearly a huge burden that the NRC has undertaken to relinquish onto the public this TOXIC NUCLEAR TRASH (TNT) and putting 8 million people in extreme danger in one of the most densely populated regions in the U.S .... and on an earthquake fault? ... in a tsunami zone? ... and on a bluff that is likely to collapse?

It is my strong advice as an environmental health and safety advocate that you reconsider all of your options and most of all the comments proposed to you at this time. Here are mine.

SUMMARY

The solution to the radioactive waste problem begins with shutting down the nuclear power plants that generate it in the first place. As far as the highly radioactive waste that e 4 ists and continues to be produced,*

putting it on trucks, train cars, and barges and transporting it across the*country to a scientifically-indefensible site solely for the benefit of the nuclear power industry is an unacceptable environmental health and safety risk to our cities, our communities, our agricultural heartland, and our entire nation. Not only are there numerous safety and emergency issues to consider, there are also design deficiencies in the U.S. storage casks and shipping containers themselves.

The NRC, utility owners, local, state and federal regulators must do everything they can to ensure nuclear waste storage and transportation decisions are based primarily on safety concerns above all else, and not on profits. 1. I strongly endorse the well informed responses and suggested actions recommended by SanOnofreSafety.org (http://files.constantcontact.com/ffe06ec5201/1afa48b2-d770-4703-b178-81e14dafe9fl.pdf) particularly with regards to the construction of the containers and casks themselves

... You must ensure the strongest thickest walled casks that can be manufactured to meet NRC's mission to "ensure adequate protection of public health and safety and the environment," and those casks and containers and SFDS must be designed to endure the

• marine environment for the longest period of time possible as there is no option for a longterm repository on the horizon ... and to enable the accessibility, retrievabilty, and detectability for monitoring of any casks that crack and need to be removed; and thus this storage system must allow for proper inspection or detection should a fuel pool or hot cell need to be removed from a cracked canister.

2. I also strongly recommend that you endorse and consider the Helms Proposal http://www.copswiki.org/Common/HelmsProposal which specifically warrants the dual-wall design canisters and 1,000 year life span ... which are safer and more resilient and will last longer than the 40 years design that the NRC is considering for storing nuclear waste ... especially away from the water, with proper ventilation

... with a 24/7 electronic monitoring capability

... i.e. accessibility and retrievability and thus a storage system that allows for proper inspection for detection should a fuel pool or hot cell need to be removed from a cracked canister.

Licensing term of only 40 years is far too short for public confidence that 1 these systems will last the time they will be required with no geologic repository on the horizon. Single-wall canisters are too thin and flimsy for this purpose! Please remember that the storage of this highly toxic nuclear waste the NRC is planning is only 108 feet from the water's edge; only a few inches above the water table with a main freeway and railroad directly above it in a highly dense population of 8 million people. NRC's risk assessment should not be based on the best scenario ... I but the absolute worst. That is how the NRC will be able to perform the duty of its mission set forth to do on behalf of the health and safety of the public and the environment.

Laura Lynch Environmental Artist/ Activist Health & Safety Advocate artistlauralynch@yahoo.com 2