ML18066A555

Comment (157) of Kathleen Morris Regarding Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18066A555
Person / Time
Site:	San Onofre
Issue date:	03/07/2018
From:	Morris K - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00157, NRC-2017-0211
Download: ML18066A555 (2)

Text

Blount, Barbara

Subject:

FW: Fuel Storage @ San Onofre ] Fuel Storage@ San Onofre To whom it may concerns:

Please reconsider the storage plans for the nuclear waste at San Onofre. Using thin temporary storage containers instead of thick casks used by other countries is not acceptable.

Please review the plans. The NRC plan will be a disaster not just for California but the world. Have you walked the property and reviewed the plan with scientists

& researchers who have dealt with this issue? Kathleen Morris San Clemente, CA 92672 Please see comments to NRC Docket from January 2, 2018 below. 1 SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= '5er~~ ( .:r"s i)

Cl Mail ,11D .2:18 PM

• 40%(£ files.constantcontact.com 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.rirc.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 fuHy inspected (inside or out), and cannot be repaired, maintained and monitored to prevent (not just detect) racltological leaks. There ls no adequate or proven dletailecl plan required to address major radiological leaks, or to address on-site replacement of containers.

Seismic requirements for partial cracks ls 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.

htlps://sar1ono/re.safe.!y.org/holtec-ill-storm,umax-n11clear-wa.s!e-dry-starage,system/

Each canister contalns 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 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 critlcal basic safety requirements we expect in a car. Does the NRC consider thin-wall canisters "conservative assumptions" compared to thick-\*n1il casks? lf so, why? Why does the NRC allow containers that do not meet these basic critical safety requirements?

Respectfully,.

Donna e:jilmore, SanOnofreSafety.org donnagllmore@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 Transportabte Thin-wall canisters Thick-wall casks No. Only 1/2 to 5/8"' of an inch Yes. 10 to 19.75 inches No Yes No Yes No Yes No Yes No Yes No. Yes Requires.

vented concrete o ... erpack Yes No transport with crac:!ks.

10 CTR§ Yes ,'II ac