ML18157A364

Comment (038) of Laura Lynch on the Requirements for the Indefinite Storage of Spent Nuclear Fuel

ML18157A364
Person / Time
Site:	San Onofre
Issue date:	06/04/2018
From:	Lynch L - No Known Affiliation
To:	NRC/SECY/RAS
SECY/RAS
References
83FR12504 00038, NRC-2018-0017, PRM-72-8
Download: ML18157A364 (2)

Text

PUBLIC SUBMISSION As of: 6/5/18 8:57 AM Received:

June 04, 2018 Status: Pending_Post Tracking No.

1k2-93jb-n01r 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-0041 Comment on FR Doc # 2018-05776 Submitter Information Name: Laura Lynch General Comment June 4, 2018Comments to NRC Do cket NRC-2018-0017I Requirements for the Indefinite Storage of Spent Nuclear FuelOffice of Nuclear Material Safety and Safeguards (NMSS)

Gregory Trussell Greg ory.Trussell@nrc.gov I strongly urge the NRC to co nsider the petitioner's (Ray mond Lutz) recommendation to amend its regulations in 10 CFR part 72 regarding spent nuclear fuel and use a Hardened, Extended-life, Local, Monitore d Surface Storage (HELMS) approach which is described in the petitioner's white paper submitted with the petitio n (ADAMS Accession No.

ML18022B213). The HELMS approa ch requires that nuclear spent fuel containers be designed for 1,000 years rather than the current process of NRC licensing for 40 years with possible renewal of another 40; and to employ the Helms Proposal which specifically warrants the dual-wall design canisters and 1,000 year life sp an ... which are safe r and more resilient and will last longer than the 40 years design that the NRC is consideri ng for storing nuclear waste ... especially away from the water, with prop er ventilation ... w ith a 24/7 electronic Page 1 of 206/05/2018https://www.fdms.gov/fd ms/getcontent?objectId=0900006483339482&format=xml&showorig=false monitoring capability ... i.e.

accessibility and retr ievability allowing fo r proper inspection fo r detection should a fuel pool or hot cell need to be removed from a cracked canister. NRC's licensing term of only 40 years is far too short for public conf idence that these systems will last the time they will be required with no geologic repository on th e horizon. Single-wall canisters are far too thin an d flimsy for this purpose!

Also, please remember for inst ance, in the case of San Onofre Nuclear Generating Station, that the storage of this highly toxic nuclear waste being planned is only a little more than 100 feet from the water's (Pacific Ocean) edge; only a few inches above the water table with a main freeway and railroa d directly above it in a highly dense populatio n of 8 million people.

The NRC's risk assessment in al l cases of "Indefinite Storage of Spent Nuclear Fuel" should not be based on the best scenario or the least expensive ... but should always be determined on the absolute worst with people's safety first and costs last. That is how the NRC will be able to perform the duty of its mission to protect the health and sa fety of the public and the environment.

Thank you, Laura Lynch

Environmental Artist/Activist Health & Safety Advocateartistlauralynch@yahoo.comPage 2 of 206/05/2018https://www.fdms.gov/fd ms/getcontent?objectId=0900006483339482&format=xml&showorig=false