ML18295A668

From kanterella
Jump to navigation Jump to search
Comment (22007) E-mail Regarding WCS-CISF EIS Scoping - 2018 FRN
ML18295A668
Person / Time
Site: Consolidated Interim Storage Facility
Issue date: 10/15/2018
From: Public Commenter
Public Commenter
To:
NRC/NMSS/FCSS
NRC/NMSS/FCSS
References
83FR44922
Download: ML18295A668 (7)
v • d • e


Text

1 WCS_CISFEISCEm Resource From:

victor Macks <vicmacks3@gmail.com>

Sent:

Monday, October 15, 2018 10:58 PM To:

WCS_CISFEIS Resource

Subject:

[External_Sender] Comments Regarding: Docket ID NRC-2016-0231.

WCS_CISF_EIS@nrc.gov.

Comments Regarding: Docket ID NRC-2016-0231.

Submitted by Vic Macks, Steerring Committee, Michigan Stop the Nuclear Bombs Campaign 20318 Edmunton St.

St. Clair Shores, MI 48080-3748 vicmacks3@gmail.com 586-779-1782 DOEs Central Interim Storage (CIS) Nuclear Waste Plan risks major radioactive leaks both in transit and in consolidated interim storage. Withdrawn nuclear reactor fuel rods must be removed from necessary fuel pool storage to Hardened on Site Storage, monitored and repackaged as necessary into the indefinite future until science and engineering provides a safe radiation free alternative. Movement of this lethal material over decades across 44 states, twice, invites high risk to workers and the public; highly likely nuclear accidents have a catastrophic beginning but no end.

Risks of Routine or Incident-Free Shipments Nonetheless Being Like Mobile X-ray Machines That Cant Be Turned Off, and Risks of Externally Contaminated Shipments Even routine or incident-free shipments of irradiated nuclear fuel carry health risks to workers and innocent passers by.

This is because it would take so much radiation shielding to completely hold in the gamma radiation, being emitted by the highly radioactive waste, that the shipments would be too heavy to move economically. So NRC has compromised, and allows for or permits a certain amount of hazardous gamma radiation to stream out of the shipping container.

NRCs regulations allow for up to 10 millirem per hour (mR/hr) of gamma radiation to be emitted, about six feet (two meters) away from a shipping casks exterior surface. Thats about one to two chest X-rays worth of gamma radiation, per hour of exposure.

Since the radiation dissipates with the square root of the distance, this means that NRCs regulations allow for up to 200 mR/hr, at the surface of the casks exterior. Thats 20 to 40 chest X-rays worth of gamma radiation, per hour, which NRC allows to stream out, right at the casks surface.

NRC has done a cost-benefit analysis - the cost, to human health; the benefit, to the nuclear power industrys bottom line

- and deemed these exposure levels acceptable or permissible. (Permissible or acceptable should never be confused with safe or harmless - exposures to 200 mR/hr, or even 10 mR/hr, still carry health risks. After all, any level of radiation, no matter how small, has long been confirmed to cause cancer. For more information, see:

https://web.archive.org/web/20160325141005/http://www.nirs.org/press/06-30-2005/1)

The humans actually harmed by these exposures to hazardous radioactivity - related to the industrys NRC-approved, unnecessary shipments, for example - might beg to differ! But of course, any negative health impacts associated with irradiated nuclear fuel shipments will not be closely tracked (or tracked at all) by NRC, or any other government agency for that matter. NRC and industry almost always downplay the health risks, and would almost certainly deny any connection between such exposures and negative health outcomes.

Six feet away could affect a person standing beside a train track, as the train goes by. Some real world examples of this situation include the Takoma Metro Station near Takoma Park, Maryland - the Red Line Metro Station platform is right beside the CSX railway, which is targeted for trains to haul irradiated nuclear fuel from the Calvert Cliffs, MD and North Anna, VA nuclear power plants, such as bound for WCS, TX.

Although further than six feet away, residences located immediately adjacent to these same CSX rail lines in Tacoma, D.C. mean that those living there could well be exposed to gamma radiation, although at a lower dose rate (again, the

2 dose rate decreases inversely with the square root of the distance). However, residents can be expected to be present in their homes a lot more often than commuters standing on a Metro platform - including during sleep hours, when trains carrying irradiated nuclear fuel could still go by. And of course, residents along these tracks, would also be commuters standing on the platform, leading to multiple exposures in their daily (and nightly) lives, for years on end during a WCS shipping campaign.

Trains pausing next to commuter platforms or residences will prolong these potentially hazardous exposures. Paused trains - even ones carrying ones carrying hazardous cargos - are commonplace in the U.S. Pauses can sometimes last a long time. Lead cars stuck by paused trains at railroad crossings could mean the occupants of those cars are exposed to gamma radiation. Even a rolling train car would emit a certain dose as it passed by, to lead car occupants stopped nearest the tracks.

Similar situations will arise across the U.S. Innocent passers by, whose daily lives bring them in close proximity to railways or waterways that would be used to ship irradiated nuclear fuel, mean that ordinary people would be exposed to hazardous gamma radiation in some amount greater than zero - perhaps repeatedly, over the course of years during a WCS, TX shipping campaign.

The 200 mR/hr acceptable dose rate at the surface of shipping casks would most likely impact workers - locomotive engineers, railway workers, inspectors, security guards, etc.

However, when, in 2003, the Big Rock Point reactor pressure vessel (albeit so-called low level radioactive waste, it still serves as a cautionary tale) was shipped by heavy haul truck into Gaylord, Michigan to be loaded onto a train, for its shipment by rail to Barnwell, South Carolina, to be buried in a ditch, neither the nuclear utility, Consumers Power, nor the NRC (nor any other federal or state agency), nor local law enforcement, created a security or safety or health perimeter around the shipping container. As if it were a parade, onlookers were allowed to simply approach the shipping container, walk right up to it, and even touch it. In fact, a parade would probably have had better health, safety, and security precautions in place! (See 2003 written entries, as well as a photo, about this and other incidents that occurred during this single shipment, posted online at:

https://web.archive.org/web/20151211005008/http://www.nirs.org/radwaste/hlwtransport/mobilechernobyl.htm). WCS would involve 4,000 irradiated nuclear fuel shipments into the Andrews, TX parking lot dump; and an equal number out, if the waste ever were to leave.

Likewise, Bob Halstead, several years ago, was able to guide a camera crew deep into the heart of a rail yard, just off downtown Chicago, that would be used to temporarily store (albeit, temporarily could last for days) train cars holding irradiated nuclear fuel. Security was nowhere to be seen. (Halstead, then serving as transport consultant to the State of Nevada Agency for Nuclear Projects, now serves as the agencys director.)

Similary, Rick Hind of Greenpeace U.S.A. guided a Wall Street Journal reporter deep into the heart of underground train tunnels under Washington, D.C. The graffiti and art on the walls showed clearly that the tunnels are frequented by human beings. (Hind was showing the reporter how insecure such tunnels, even the nations capital, are to potential security risks, even as hazardous train cargos - including chlorine shipments - pass by.)

In these ways, that 200 mR/hr permissible dose rate could impact not only workers, but even members of the public.

In this sense, even routine or incident-free shipments of irradiated nuclear fuel can be considered as similar to mobile X-ray machines that cant be turned off, a phrase describing the concept first expressed by Lauren Olson, a supporter of NIRS.

To make matters worse, there have been large numbers of shipments, externally contaminated with radioactivity, making their actual dose rates much higher - and thus more hazardous - in serious violation of the already compromised permissible or acceptable levels.

Areva - a key partner in the WCS proposal - at its home base in France, experienced just such a plague or epidemic of externally contaminated shipments. A full 25% to 33% of Arevas irradiated nuclear fuel shipments, into its La Hague reprocessing facility, were externally contaminated, for years on end, above permissible levels. This amounted to many hundreds of individual shipments, contaminated above permissible levels, over the course of several years. On average, the shipments were giving off radiation dose rates 500 times the permissible level; in one instance, a shipment was emitting radiation 3,300 times the acceptable level.

Environmental watchdogs and journalists revealed this contaminated shipment scandal. See the WISE-Paris write up, Transport Special - Plutonium Investigation n°6/7, posted at http://www.wise-paris.org/ under Bulletins.

But such externally contaminated shipments have happened in the U.S., as well. Halstead documented this in a report prepared for the Nevada State Agency for Nuclear Projects in 1996. It is entitled Reported Incidents Involving Spent Nuclear Fuel Shipments, 1949 to Present. 49 surface contamination incidents are documented. This report is posted online at: http://www.state.nv.us/nucwaste/trans/nucinc01.htm.

DOEs CIS Nuclear Waste Plan Risks Major Radioactive Leaks It is premature to focus on consent criteria until urgent critical legal and safety issues are resolved. No informed community would accept DOEs current Consolidated Interim Storage (CIS) pilot plan if they knew the plan included unsafe transport and

3 storage of highly irradiated spent nuclear fuel in canisters that do not meet current Nuclear Waste Policy Act (NWPA) requirements.

U.S. dry storage thin steel canister systems cannot be inspected, maintained, repaired, adequately monitored to avoid radioactive leaks, and the DOE pilot plan has no plan for replacing failing canisters or retrieval of fuel, as required by NWPA.

The DOE consent meetings did not disclose the major safety flaws in their proposed CIS plan and there are no public hearings scheduled regarding the pilot plan in spite of numerous public concerns about storage and transport issues. Instead, the DOE booklet distributed at these meetings and on the DOE website implies all U.S. nuclear waste is safely stored.

The DOE should advocate for and demand utility licensees comply with NWPA safety requirements and should not accept lower safety standards. Any proposed legislation that reduces safety requirements should be actively opposed by the DOE. The Nuclear Regulatory Commission (NRC) has approved canisters for short-term storage that do not to meet many NWPA DOE requirements. The following are examples of NWPA legal and safety requirements that the NRC and DOE CIS pilot plan do not comply with:

  • provide continuous monitoring, management, and maintenance of spent fuel and waste for the foreseeable future [including short-term storage];
  • minimize the impacts of transportation and handling of such fuel and waste;
  • provide for public confidence in the ability of such system to safely dispose of the fuel and waste;
  • impose minimal adverse effects on the local community and the local environment;
  • provide a high probability that the facility will meet applicable environmental, health, and safety requirements in a timely fashion.

NWPA Subtitle C Monitored Retrievable Storage, Section 141(b)(1) and Section 144 http://energy.gov/sites/prod/files/edg/media/nwpa_2004.pdf It is an unnecessary major safety risk to transport and store waste at a consolidated interim storage site, especially with the heavy U.S. use of high burnup fuel that can cause the Zirconium cladding to become brittle and shatter like glass. The issue of whether just train vibrations can cause this is still being studied. Interim storage can best be accomplished through the safest dry storage of spent fuel at the site of generation, except that when there is a clear and present danger, spent fuel should be transferred to a nearby more stable site, possibly another reactor site, for storage. This complies with the NWPA requirement to minimize the impacts of transportation and handling of such fuel and waste.

July 31, 2016 The NRC approves high burnup fuel based on how it performs in the reactor without considering the impacts of how it performs in storage or transport. The DOE should take an active role in finding a way to prevent this practice. Since the DOE and the public pay the consequences for NRC action, its up to both of us to advocate for improved safety standards at the NRC that comply with NWPA.

All dry storage systems must provide storage in a manner and location that is as safe as possible to prevent radioactive leaks in both short and long term storage. This requires a system that provides defense in depth, is fully inspectable, maintainable, repairable and not subject to critical degradation (such as corrosion and cracking). It must provide a continuous early warning monitoring system that warns prior to a radiation release and have a plan in place for safely retrieving and monitoring spent fuel without destroying the containers. Emergency Planning should be provided and funded, including public access to continuous radiation monitoring. The proposed DOE pilot system does not meet any of these requirements. The NRC only requires quarterly radiation monitoring. The DOE must do better to meet NWPA requirements.

Most U.S. commercial independent spent fuel storage installations (ISFSI) do not meet the above safety requirements. The NRC acknowledges the over 2000 U.S. thin-walled (mostly 12 thick) steel spent nuclear fuel dry storage canisters cannot be inspected (even on the outside), so no one knows the condition of the canisters, fuel or internal critical parts (such as the fuel storage baskets). They cannot be repaired and maintained and have no continuous or other early-warning monitoring system prior to radioactive leaks.

According to DOE inventory data, most of these thin-walled canisters have been in use less than 10 years. The NRC states leaks can happen 16 years after cracks start. They state the Koeberg nuclear plant had a similar component (a waste water tank) leak in only 17 years. The Koeberg tank cracks were deeper than the thickness of most U.S. thin-wall canisters (0.61 vs.

0.50). Holtec president, Dr. Kris Singh, one of the major manufacturers of these thin-wall canister systems, admits even if you could find the cracks, even a microscopic through-wall crack will releases millions of curies of radioactivity into the environment, and even if it was possible to repair them, this would introduce a rough area for future cracking.

The Nuclear Regulatory Commission (NRC) approved most of these facilities and containers for 20 years by ignoring aging management issues that may occur after 20 years and by ignoring NWPA DOE Monitored Retrievable Storage requirements.

The NRC has approved a few license renewals in spite of the following unresolved critical problems in the thin-walled (mostly 12 thick) welded stainless steel canister systems.

  • CANNOT BE MAINTAINED: canisters cannot be inspected (inside or out), repaired or maintained. Fuel and interior critical structures (such as fuel assembly storage baskets) cannot be inspected without destroying the canister, so it is not feasible to inspect them. No current on-site capabilities for replacing failing canisters or resolving problems with canisters or fuel. Canisters have been misloaded, but the NRC has not required inspection of contents.
  • SHORT-TERM RADIATION RISKS: The NRC states canisters may leak after 16 years once a crack starts. The Koeberg waste water tank leaked in 17 years. A Sandia Lab analysis shows cracks can grow faster in hotter canisters (Attachment B). A Diablo Canyon canister has all the conditions for cracking in a 2-year old canister. No seismic evaluations are required for cracked canisters or degraded concrete storage overpacks. Each canister contains more radioactive Cesium-137 than released from Chernobyl.

4

  • UNSAFE FOR TRANSPORT: Canisters are susceptible to undetected cracks that can continue to grow through the wall of the canister. Even partially cracked canisters are not approved for transport (NRC 10 CFR § 71.85). Zirconium clad fuel allowed to burned longer in reactors (high burnup fuel) is subject to embrittlement even after dry storage and may shatter like glass, especially during transport (with or without an accident).
  • NO CONTINUOUS MONITORING: Canisters cannot be continuously monitored to prevent radioactive releases. Radiation monitoring is only required quarterly.

Page 2

  • NO EMERGENCY PLANNING: No off-site emergency planning required for nuclear waste storage installations. No publicly accessible, timely, or continuous radiation monitoring in spite of the above problems.

It is the DOEs responsibility to advocate for and enforce NWPA safety requirements, as required by the DOE Standard Contract. Most other countries have standardized on dry storage systems that meet NWPA and other safety requirements, so there is no good reason the U.S. cannot do the same. However, we need the DOE to play an active role to make this happen.

The DOE must demonstrate that the federal government can fund, transport, and manage nuclear waste without significant short-term or long-term radioactive leaks and demonstrate that the federal government can comply with existing nuclear waste laws, contracts and agreements. This is currently not the case. At the DOE consent-based meetings, the issue of lack of public trust of the DOE was a major issue acknowledged by the DOE. Enforcing instead of ignoring NWPA requirements may help the DOE build public trust.

The DOE Integrated Waste Management Consent-Based Siting booklet distributed at the DOE Consent-Based Siting meetings and on the DOE website implies the current U.S. dry storage systems are safe (page 21). Correcting this misinformation would be a good first step in improving public trust. http://www.energy.gov/sites/prod/files/2016/05/f31/Booklet_16_05_17.pdf Other issues related to consent.

  • The federal government must guarantee sufficient funds will be allocated for as long as the waste needs be transported and needs be stored -- up to 120 years for short-term storage (per NRC definition of short-term) and for long-term storage, which is basically forever. Communities impacted by a radioactive release need to be adequately financially compensated.
  • States and Tribal Nations must have legal authority to set higher standards for such things as storage and transport containers, aging management and radiation exposure levels. States must have enforcement authority for nuclear waste stored in or near their communities based on potential radioactive contamination zones. They also must have adequate funding to administer and enforce these requirements.
  • The DOE must adequately address major transport infrastructure issues affecting the safe transport of spent fuel through our communities.
  • Each state and locality must be legally authorized to establish its own criteria for standing and volunteer status, and no further requirements may be set by the federal government except that any expression of interest must affirm that it is consistent with the requirements of Executive Order 12898 regarding Environmental Justice.

Until such time as these issues are resolved, no informed communities would agree to host spent nuclear fuel waste. The Governor of New Mexico April 10, 2015 letter to Energy Secretary Moniz supported consent. However, the letter stated the CIS site would use proven technology and a safe system, which is not true. This is not informed consent.

The DOE should discontinue expending resources on consent. Instead, it is urgent the DOE take a leadership role in resolving the issues addressed in these comments. If you dont, who will? Each thin-walled steel canister contains about as much Cesium-137 as was released from Chernobyl and some of the existing canisters could start leaking in the near future with no plan in place to mitigate leaks.

See Attachments and SanOnofreSafety.org for references and additional information.

Page 3 ATTACHMENT A - REFERENCES AND ADDITIONAL SUBSTANTIATION REFERENCES AND ADDITIONAL SUBSTANTIATION

  • Thin-walled spent fuel canisters cannot be inspected and may leak 16 years after loaded.

The majority of current U.S. irradiated spent fuel storage facilities use thin-walled (mostly 1/2 thick) stainless steel canisters that the NRC acknowledges cannot currently be inspected or repaired and are vulnerable to cracking and leaking 16 years after a crack starts.

Summary of August 5, 2014 Public Meeting with the Nuclear Energy Institute on Chloride-Induced Stress Corrosion Cracking Regulatory Issue Resolution Protocol. http://pbadupws.nrc.gov/docs/ML1425/ML14258A081.pdf

  • Storage containers must meet these requirements Storage containers must be designed to be inspectable (inside and out), repairable, maintainable, not subject to structural cracks, and have continuous early-warning monitoring prior to radiation leaks. Sites must have provisions for replacing failing fuel or failing canisters, such as empty spent fuel pools.

Storage container requirements must be based on meeting short and long term needs, rather than on how much money Congress is willing to allocate each year. The DOEs current recommendation is the latter (partially due to Congress redirecting existing funds that were designated for a permanent repository).

5 Most other countries use thick-walled (about 10 to 20 thick) irradiated spent fuel storage casks that meet or exceed NWPA monitored retrievable storage requirements, such as Germany and Japan (including at Fukushima). Those countries also store their irradiated spent fuel containers in reinforced structures for additional environmental protection.

  • Radiation monitoring must be required Near real-time radiation monitoring with public access should be required.
  • DOE must improve its performance The DOE must demonstrate that the federal government can fund, transport, and manage nuclear waste without significant radioactive leaks and demonstrate that the federal government can comply with existing nuclear waste laws, contracts and agreements. They have not done this.
  • Funding inadequate The federal government must guarantee sufficient funds will be allocated for as long as the waste needs be transported and needs be stored -- up to 120 years for short-term storage (per NRC definition of short-term) and for long-term storage, which is basically forever. Communities impacted by a radioactive release need to be adequately financially compensated.

ATTACHMENT A Page 2

  • More State and Tribal Nation legal authority States and Tribal Nations must have legal authority to set higher standards for such things as storage and transport containers, aging management and radiation exposure levels. States must have enforcement authority for nuclear waste stored in or near their communities based on potential radioactive contamination zones. They also must have adequate funding to administer and enforce these requirements.

Each state and locality must be legally authorized to establish its own criteria for standing and volunteer status, and no further requirements may be set by the federal government except that any expression of interest must affirm that it is consistent with the requirements of Executive Order 12898 regarding Environmental Justice.

States and communities currently have no legal rights to set higher standards for storage and transport and have no legal recourse for DOE mismanaged facilities or for DOE broken promises. The State of Idaho is one of the few states with a legal agreement, yet the DOE has not met the conditions of that contract. DOEs promise to remove nuclear waste from Idaho by 2035 appears to be a goal rather than a commitment. https://www.deq.idaho.gov/inl-oversight/oversight-agreements/1995-settlement-agreement/

  • Transport safety and funding issues unresolved The DOE must address major transport infrastructure issues and the safety of transporting irradiated spent fuel through our communities. Communities must have on-line access to transport accident records and status of transport infrastructure for any potential routes used for transport. Some canisters may require up to 45 years of cooling before they meet Department of Transportation radiation limits (Attachment C - Transport).
  • Current DOE sites have radioactive leaks Current DOE managed sites consistently have radioactive leaks into the environment from leaking or exploding inferior storage containers, such as Hanford in Washington, Savannah River Site in South Carolina, the Waste Isolation Pilot Project (WIPP) in New Mexico, Idaho National Lab and other sites.

There is a pattern of selecting inferior containers that are not even sufficient for short-term storage containers that cannot be inspected, monitored, repaired and maintained. In essence, these storage containers as designed will inevitably fail and leak radiation. The DOE must demonstrate they can resolve these issues before moving forward with any consent-based siting process.

  • DOE pilot project will inevitably fail with radioactive leaks The proposed DOE irradiated spent fuel nuclear waste storage plan as designed will inevitably fail with highly radioactive leaks.

It proposes transporting and storing existing thin-walled stainless steel canisters (1/2 to 5/8 thick) that cannot be inspected, repaired, maintained, have no early warning system prior to radioactive leaks, can corrode and crack, and can start leaking millions of curies of radioactivity after 20 years of storage, possibly sooner. A 2015 Sandia Lab report shows that once cracks start in hotter thin-walled stainless steel canisters, they can grow through the wall of the canister in less than 5 years (Attachment B - Sandia Chart).

A failure of even one of these Chernobyl canisters could be catastrophic. There is potential for explosions, due to the unstable and pyrophoric nature of these materials when exposed to air. (Damaged Spent Nuclear Fuel at U.S. DOE Facilities, Experience and Lessons Learned, INL, Nov 2005 INL/EXT-05-00760, Page 4 & 5). https://inldigitallibrary.inl.gov/sti/3396549.pdf ATTACHMENT A - Page 3 The DOE pilot design has no provisions to address these issues and provides no remediation for failing canisters. Most of the over 2000 U.S. thin-walled canisters have been in use less than 20 years, so we have not seen through-wall cracks yet.

However, the DOE must address this issue in their plans. The NRCs initial 20-year dry storage container certification considers out of scope any problems that may occur after 20 years. In their relicensing the NRC aging management plan (NUREG-1927 Rev 1 Draft) requires canisters with 75% through-wall cracks be taken out of service. However, the method to accomplish this or even inspect and measure cracks does not exist for canisters filled with irradiated spent fuel.

http://pbadupws.nrc.gov/docs/ML1605/ML16053A199.html NRC regulations do not allow the transportation of canisters with even partial cracks (10 CFR § 71.85 Packaging and Transportation of Radioactive Materials).

Neither the outside or inside structure of these thin-walled welded canisters can be inspected, let alone repaired. Other countries use thick-walled casks that do not have these problems.

6 Both the DOE and NRC have chosen to continue endorsing the inferior technology even though NRC Commissioners directed staff to encourage the adoption of state of the art technology for storage and transportation. Staff Requirements - COMDEK-09-0001 - Revisiting the Paradigm for Spent Fuel Storage and Transportation Regulatory Programs, February 18, 2010 http://pbadupws.nrc.gov/docs/ML1004/ML100491511.pdf NRC Director of Spent Fuel Management Division, Mark Lombard states inspecting these canisters is not a now thing (https://youtu.be/QtFs9u5Z2CA).

Dr. Kris Singh, Holtec thin-walled canister President, states that even a microscopic crack will release millions of curies of radiation into the environment and that the canisters are not repairable. (https://youtu.be/euaFZt0YPi4).

Canisters may need to stay on-site for up to 45 years before they are cool enough to meet Department of Transportation radiation dose requirements (Attachment - Transport).

  • Would you buy a car that could not be inspected?

Would you buy a car for your family that could not be inspected, maintained, and repaired and provided no warning before the engine or brakes failed? That is basically what you are asking our families to do with these thin-walled irradiated spent fuel storage canisters. The Delorean cars looked good until the stainless steel 304 alloy panels began corroding. This is the same material used in most of the over 2000 U.S. thin-walled stainless steel canisters. NRC material engineers state that operating experience with both 304 and 316 stainless steel alloys demonstrate these problems. Numerous environmental and other factors can initiate corrosion and cracking (e.g., corrosive salt particles and from sulfites in air pollution and vehicle exhaust).

Additional resources and information at SanOnofreSafety.org ATTACHMENT B - Sandia Chart Thin-walled stainless steel U.S. irradiated spent fuel storage canisters at higher temperatures will have faster crack growth rate.

The Sandia Chart below shows higher temperatures can cause canisters to penetrate the wall in less than 5 years. This chart assumes canister wall is 0.625 (5/8) thick. The majority of the U.S. canisters are only 0.50 (1/2) thick. It is unknown when a crack will start, but these canisters are subject to corrosion and cracking from environmental conditions such as chloride salts, air pollution (sulfides), pitting, and microscopic scratches. The report states that canisters such as those at Diablo Canyon have temperatures in these heat ranges.

Draft Geologic Disposal Requirements Basis for STAD Specification, A. Ilgen, C. Bryan, and E. Hardin, Sandia National Laboratories, March 25, 2015, FCRD-NFST-2013-000723 SAND2015-2175R, PDF Page 36 & 46 http://prod.sandia.gov/techlib/access-control.cgi/2015/152175r.pdf ATTACHMENT C - Transport Canisters with 37 spent fuel assemblies may require up to 45 years to cool (after removal from the reactor) before they are safe enough to transport (~20 kW) per Dept. of Transportation radiation limits.

Research and Development Activities Related to the Direct Disposal of Dual Purpose Canisters, William Boyle, Director, Office of Used Nuclear Fuel Disposition R&D (NE-53), U.S. Department of Energy, Nuclear Waste Technical Review Board Meeting, April 16, 2013 http://www.nwtrb.gov/meetings/2013/april/boyle.pdf Safety Evaluation Report Docket No. 71-9302, NUHOMS-MP197HB, Certificate of Compliance No. 9302, Rev. 7, Page 14 http://pbadupws.nrc.gov/docs/ML1411/ML14114A132.pdf Note: The only NRC approved high burnup transport cask is the NUHOMS MP197HB.

Federal Register Notice:

83FR44922 Comment Number:

22007 Mail Envelope Properties (6719C2D2-8C1F-435E-8085-7426453AF2DD)

Subject:

[External_Sender] Comments Regarding: Docket ID NRC-2016-0231.

Sent Date:

10/15/2018 10:57:48 PM Received Date:

10/15/2018 10:58:14 PM From:

victor Macks Created By:

vicmacks3@gmail.com Recipients:

Post Office:

gmail.com Files Size Date & Time MESSAGE 31931 10/15/2018 10:58:14 PM Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

Retrieved from "https://kanterella.com/w/index.php?title=ML18295A668&oldid=4954522"