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Category:Rulemaking-Comment
MONTHYEARNRC-2018-0017, Comment (063) of Patricia Gracian on the Requirements for the Indefinite Storage of Spent Nuclear Fuel2018-06-0505 June 2018 Comment (063) of Patricia Gracian on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18158A2792018-06-0505 June 2018 Comment (062) from Jonathan Adler on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18158A2772018-06-0505 June 2018 Comment (060) from Marion Sprin on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18158A2762018-06-0505 June 2018 Comment (070) from Daniel Dowden on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18158A2702018-06-0505 June 2018 Comment (064) from Mary Jo Poole on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3792018-06-0505 June 2018 Comment (053) from Doris Pfalmer on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3782018-06-0505 June 2018 Comment (052) from Carmela Price on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3742018-06-0505 June 2018 Comment (057) from Arturo Torres on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3732018-06-0505 June 2018 Comment (056) from Irwin Sprin on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3722018-06-0505 June 2018 Comment (055) from Paula Colby on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3712018-06-0505 June 2018 Comment (054) from Joel Goldstein on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3622018-06-0505 June 2018 Comment (049) from Scott Chamberlin on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3572018-06-0505 June 2018 Comment (044) from Sheryl Arruda on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3682018-06-0404 June 2018 Comment (042) of Jo Panitch on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3672018-06-0404 June 2018 Comment (041) of Anne Clorite on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3662018-06-0404 June 2018 Comment (040) from Susan and David Dearing on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3652018-06-0404 June 2018 Comment (039) of Berton Moldow on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3642018-06-0404 June 2018 Comment (038) of Laura Lynch on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3562018-06-0404 June 2018 Comment (043) of Mary Steele on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A2992018-06-0101 June 2018 Comment (034) from an Anonymous Individual on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18157A3002018-05-31031 May 2018 Comment (033) from Patricia Borchmann on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18150A6392018-05-29029 May 2018 Comment (029) from Donna Shanske on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18149A6012018-05-25025 May 2018 Comment (019) from Cord Bauer on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18094A7852018-04-0303 April 2018 Comment (003) from Ken Berg on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18100A3522018-04-0202 April 2018 Comment (012) of Steve Schlesinger on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML18094A7732018-04-0202 April 2018 Comment (002) from Ron Rodarte on the Requirements for the Indefinite Storage of Spent Nuclear Fuel ML16082A0072016-03-18018 March 2016 Comment (112) of Charles R. Langley on Behalf of Public Watchdogs on ANPR-26, 50, 52, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors ML16060A5112016-02-29029 February 2016 Comment (043) of Sara Kaminske on Behalf of Orange County, CA on ANPR-26, 50, 52, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors ML16053A4532016-02-0101 February 2016 Comment (036) of Ron Roberts and Dianne Jacob on Behalf of the County of San Diego, CA, Board of Supervisors on ANPR-26, 50, 52, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors ML14007A0332013-12-20020 December 2013 Comment (00868) of Patricia Holloway on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14006A4422013-12-20020 December 2013 Comment (00845) of G. Korsen on PR-51, Waste Confidence Continued Storage of Spent Nuclear Fuel ML14006A4382013-12-20020 December 2013 Comment (00841) of Bruce Lieberman on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14006A3782013-12-20020 December 2013 Comment (00835) of Yoko Collin on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14001A0572013-12-20020 December 2013 Comment (00786) of Alan Korsen on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14001A0052013-12-20020 December 2013 Comment (00736) of Valerie Burchfield Rhodes on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13365A3372013-12-20020 December 2013 Comment (00717) of Laurenn Barker on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13360A3582013-12-20020 December 2013 Comment (00685) of Ray Lutz on Behalf of Citizens Oversight, Inc. on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13359A0022013-12-19019 December 2013 Comment (00648) of Grace Van Thillo on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14002A0042013-12-19019 December 2013 Comment (00801) of Jim Powers on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14002A0002013-12-19019 December 2013 Comment (00797) of Kevin Carey on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14001A0372013-12-19019 December 2013 Comment (00766) of Ed Maher on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14001A0362013-12-19019 December 2013 Comment (00765) of Juniel Worthington on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14001A0252013-12-19019 December 2013 Comment (00754) of Margaret Kuchnia on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13358A4262013-12-19019 December 2013 Comment (00639) of Kim Stanick on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13358A4252013-12-19019 December 2013 Comment (00647) of Stephanie Jennings on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13358A4162013-12-19019 December 2013 Comment (00632) of Christina Imhoof on PR-51, Waste Confidence Continued Storage of Spent Nuclear Fuel ML13358A3512013-12-19019 December 2013 Comment (00615) of John Dolegowski on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13357A8322013-12-19019 December 2013 Comment (00601) of Roger Johnson on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13352A5172013-12-15015 December 2013 Comment (00461) of Kevin Higgins on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13336A5512013-11-18018 November 2013 Comment (00269) of Bill Hannaman on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel 2018-06-05
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PUBLIC SUBMISSION As of: 6/4/18 10:02 AM Received:
May 31, 2018 Status: Pending_Post Tracking No.
1k2-93gp-xxmx Comments Due:
June 05, 2018
Submission Type:
Web Docket: NRC-2018-0017 Storing Spent Nuclear Fuel WasteComment On:
NRC-2018-0017-0003 Requirements for the Indefinite Storage of Spent Nuclear Fuel Document:
NRC-2018-0017-DRAFT-0036 Comment on FR Doc # 2018-05776 Submitter Information Name: Patricia Borchmann Address: 1141 carrotwood glen escondido, CA, 92026 Email: patriciaborch mann@gmail.com General Comment Altho I do not have a degree in engineering, I am convinced by the ca reful engineering work performed by Ray Lutz (for Citi zens Oversight) that the Pr oposed HELMS design (Hardened Extended Life Monitored Surfac e Storage) and system descri bed in NRC Petition (Docket 72- PRM) is a carefully engineered plan that Nuclear Regulatory Commission (NRC) must adopt at earliest possible opportunity , because public stakeholders in California are well informed, and failure by NRC to do so is expected to be a gross breach of duty, and failure to conform with mandates for public health and safety.
I have invested many years during most of my adult life, to be come as well informed as I can to familiarize myself with NR C regulations, Parts 70 through 72, and have been an active public participant during many years of NRC's ongoing Rulemaking process (undertaken almost 20 years ago) to develo p regulations, establis h specific safety design criteria, and Page 1 of 306/04/2018https://www.fdms.gov/
fdms/getcontent?object Id=090000648331be53&format=xml&showorig=false phased implementation plans necessary for app lication at numerous nuclear reactors in various stages of Decommission ing. I live in Escondido (San Di ego county) with in 50 miles of San Onofre SONGS 2 & 3, in southern CA where unique phy sical site circumstances exist which pose readily foreseeable risks (seismic, tsunami, accele rated bluff retreat, erosion, rising sea levels, climate change impacts that ar e expected to be accele rated beyond forecast projection dates so flooding impacts are now expected to be more seve re, more serious, and extremely underestimated in N RC's fast-track streamlined permit processing of series of
'emergency exemptions' during summer 2015, when Nuclear Regulatory Commission's premature permit approval of authority to substantially modify the San Diego County Emergency Response Plan in a way that severely reduced layers of safety, defense in depth features, eliminated over 39 critical fire safety positions, reduced fund ing, training for first responders, and approved a grossly negligent cost cutting Emergency Plan, based on superficial, inaccurate assumptions and faulty computer modeling, and eliminated emergency assistance and funding from FEMA, in the event of a potential radiological emergency at San Onofre, or release of radiation.
By the time this case arrived on doorstep of California Coastal Commission for permit approval, extreme ex parte co ntacts between Commissioners and utility SCE Edison, and its contractors/consultants and in dustry advocates had already taken place so often it was established practice (despite expl icit policy to prohibit or restrict ex parte communications by Coastal Commissioners. So, it was well befo re the Coastal Commission public hearing in Long Beach on 10 06 18, wher e I and many other local activists had only 3 minutes to describe technical reasons for strong opposition, with technical detail necessary in our collective effort to convince Coastal Commissioners to reject the poorly designed ISFSI, the proposed use of inferior Holte c Umax spent fuel storage cask s, and inform Commissioners about extremely poor operational history perf ormed by Holtec Intern ational, and domestic applications in United States th at were already in evidence in NRC's po ssession. As a public stakeholder during that 10 06 15 CA Coastal Commission public hearing, I was among many other stakeholders that found 3 minutes was insufficient, so I submitted my formal written comments for the public record. Coastal Comm ssion approved the coas tal development permit after lunch in Long Beach, following hours of he aring time mostly afforded to SCE Edison, or consultants retained by Edison , and their attorneys. The ce ntral message was the Coastal Commissioners approved the permit, without cons ent by the public for Edison to construct ISFSI, over objections by ov er 45 local informed activists and independent experts .
After failed steam generators at SONGS cost ratepayers b illions, SCE prematurely retired Units 2 & 3 in 2013, series of la wsuits through 2017 left stakehol ders in CA fatigued. Then in Feb. 2018, work at SONGS on th e ISFSI was suspended, due t o loose bol ts discovered in four of the first Holtec Umax cask s installed at the ISFSI, due to Holtec engineering design defects, with pins elevating bottom surface of Holtec contai ner which broke. The serial Amendments (over 14) approved for Holtec Umax casks makes it apparent that 'ideal design' is constantly moving target.Page 2 of 306/04/2018https://www.fdms.gov/
fdms/getcontent?object Id=090000648331be53&format=xml&showorig=false Long story... Skip to the chase here on HE LMS. The proposed improved design by Citizens Oversight must be adopted immediately by NRC, to initiate necessary regulatory reform and acceptance of prudent de sign criteria, with service life of 1,000 years, constant cask monitoring (real time), 24/7, 3 65 days/year, with specific maintenance protocols, and leak detection system to trigger warning to operat ors, and apply urgent technical diagnostics, immediate cask replacement. URGENT need to relocate SONGS HLRW away from ISFSI on coastline. Page 3 of 306/04/2018https://www.fdms.gov/
fdms/getcontent?object Id=090000648331be53&format=xml&showorig=false