ML18157A300

Comment (033) from Patricia Borchmann on the Requirements for the Indefinite Storage of Spent Nuclear Fuel

ML18157A300
Person / Time
Site:	San Onofre
Issue date:	05/31/2018
From:	Borchmann P - No Known Affiliation
To:	NRC/SECY/RAS
SECY/RAS
References
83FR12504 00033, NRC-2018-0017, PRM-72-8
Download: ML18157A300 (3)

Text

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