ML23107A144
| ML23107A144 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 04/15/2023 |
| From: | D'Arrigo D Nuclear Information & Resource Service (NIRS) |
| To: | Kristina Banovac, James Firth Office of Nuclear Material Safety and Safeguards |
| References | |
| PR-72, NRC-2022-0109, 88FR9195 | |
| Download: ML23107A144 (1) | |
Text
From: Diane D"Arrigo To: Kristina Banovac; James Firth; Docket, Hearing
Subject:
[External_Sender] NRC 2022-0109Direct Final Rule for 40-year CoC renewal HI STORM 100 Cask System Date: Saturday, April 15, 2023 12:05:06 AM Comment to the US NRC on List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System, Certificate of Compliance No. 1014, Renewal of Initial Certificate and Amendment Nos. 1 Through 15 Our organization and 4 others requested a 90 day extension on this proposed Direct Final Rule, renewing the certification of the HI STORM 100 cask system. We were granted a fraction of that but still need the full amount of time requested. We requested and continue to call for the withdrawal of the Direct Final rule process. This renewal is more complicated and dependent on guidance than many others. It took assistance from several staff to simply identify the specific requested renewals and to find the applicants requests and the NRC assessments. The NRC is surely aware of the burdensome process involved in reviewing and intervening in its rulemakings. The decision here will impact numerous communities around nuclear facilities, many unaware, yet they will bear the burden of the consequences. The changes in future climate, more and more severe storms, sea level rise and increasingly powerful weapons are just some of the obvious concern that the Aging Management Guidance do not fully consider. Please reject the renewal, the Direct Final Rule process and provide the additional time for public interest input.