NRC-2022-0109, Comment (007) from Kalene Walker on PR-72 - 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
| ML23108A279 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 04/14/2023 |
| From: | Walker K - No Known Affiliation |
| To: | NRC/SECY |
| References | |
| NRC-2022-0109, 88FR9195 00007 | |
| Download: ML23108A279 (1) | |
Text
4/17/23, 5:14 PM blob:https://www.fdms.gov/d2a29838-b19a-4ad2-ae5f-58fab8eff389 As of: 4/17/23, 5:14 PM Received: April 14, 2023 PUBLIC SUBMISSION Status: Pending_Post Tracking No. lgh-g6t0-42zu Comments Due: April 14, 2023 Submission Type: Web Docket: NRC-2022-0109 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 Comment On: NRC-2022-0109-0007 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 Document: NRC-2022-0109-DRAFT-0014 Comment on FR Doc # 2023-05831 Submitter Information Name: Kalene Walker Address: United States, Email: ggchappykale@yahoo.com General Comment See attached file(s)
Attachments Docket NRC-2022-0109 blob:https://www.fdms.gov/d2a29838-b19a-4ad2-ae5f-58fab8eff389 1/1
The NRCs proposed Direct Rule claims that Holtecs revised CoCs and Technical Specifications address aging management activities. But NRC regulations fail to require licensees to have technically specific and approved capabilities and processes in their Aging Management Program to find and evaluate cracks or to respond to a degrading or failing canister.
The assumption that canister degradation wont begin for decades ignores findings from other Holtec storage systems that indicate accelerated canister degradation mechanisms are already in place. The proposed Aging Management Program in the Direct Rule is inadequate to ensure public safety. NRC must require licensees to have technically specific and approved methods to prevent canister failure before approving this and other 40 year license renewals.
Specifically, at San Onofre, after Holtec almost dropped a loaded canister 18, Edisons (SCE) visual assessment report showed carbon steel contamination in the walls of the Holtec canisters. ML19261A089 pdf 131-136. The NRCs Special Inspection of the Holtec UMAX system found that the carbon particles were embedded in the canisters due to the lack of a precision downloading system. The NRC determined the canisters were unavoidably scraped and gouged against the carbon steel CEC guide ring as they were lowered into the storage holes. https://www.nrc.gov/reactors/operating/ops-experience/songs-spec-insp-activities-cask-loading-misalignment.html While this rule is not about Holtecs UMAX system, the NRC must consider that a similar scenario of carbon particle contamination of canisters may exist with other Holtec storage systems. Holtecs above ground HiStorm system may also result in canisters scratched and scraped against the carbon steel vertical channels in the over-pack casks. https://sanonofresafety.org/2019/05/16/all-holtec-nuclear-waste-thin-wall-canisters-likely-damaged-from-inferior-holtec-downloading-systems/
This potential initiation of carbon-induced pit corrosion cracking could result in accelerated canister degradation of all Holtec canisters.
The assumption that cracks wont begin for decades also ignores an EPRI study that found a two-year old Diablo Canyon Holtec canister with corrosive salt and low enough temperature for moisture to dissolve the salt, a major trigger for stress corrosion cracking of the stainless-steel canisters. SanOnofreSafety.org Due to these and other potential accelerated canister degradation mechanisms, the NRC must require licensees to have technically specific and approved methods for resolving potential failure modes before approving this and other 40 year license renewals.
- The NRC approve canisters do not and can not meet basic ASME N3 certification for nuclear pressure vessels in storage and transport; the list of exemptions is extensive.
- The NRC approve thin-wall canisters are made of stainless steel prone to microscopic inter-granular cracking, yet the NRC fails to require viable and approved inspection technology that can find and characterize cracks; Visual Assessments can only detect precursors to cracks. The
NRC has acknowledged that once cracks have initiated, cracks can grow through the wall of a canister in as little as 16 years.
https://sanonofresafety.files.wordpress.com/2013/06/ml14258a081-8 14meetingsummary.pdf
- The NRC allows the industry to promote repair technologies as a viable method to stop cracks but repair technologies have not been evaluated or approved by the NRC or ASME. Even the president of Holtec, Kris Singh, recommends against trying to repair a canister and explains why it is not feasible even if you could find the cracks. He stated:
It is my personal belief, it is not practical to repair a canister if it were damaged. If it had a through-wall, first you prevent it, but in the most unlikely circumstance if that canister were to develop a leak, lets be realistic; you have to find it, that crack, where it might be, and then find the means to repair it. You will have, in the face of millions of curies of radioactivity coming out of canister; we think its not a path forward. However, let me you can easily isolate that canister in a cask that keeps it cool and basically you have provided the next confinement boundary, youre not relying on the canister. So that is the practical way to deal with it and thats the way we advocate for our clients.
My personal position is a canister that develops a microscopic crack (all it takes is a microscopic crack to get the release), to precisely locate it itself it is a tall order and then if you try to repair it (remotely by welding) and of course remotely you can go and weld, the problem with that is you create a rough surface which becomes a new creation site for corrosion down the road.
ASME Sec 3. Class 1 has some very significant requirements for making repairs of Class 1 structures like the canisters, so I, as a pragmatic technical solution, I dont advocate repairing the canister. Kris Singh transcript https://sanonofresafety.files.wordpress.com/2015/09/attachment-14-declaration-of-donna-gilmore.pdf Kris Singh video https://youtu.be/euaFZt0YPi4 Kris Singh and others have suggested putting a problem canister in a storage overpack cask, but this has not been approved by the NRC. Years ago, when the NRC analyzed this process for much cooler fuel at Big Rock Point, the NRC approved it for a very limited time, only. The NRC has not done an updated analysis.
- Please give a technical response to the public comment on NUREG 2224 which raises the technical concerns of criticalities and/or hydrogen gas explosions from canister failure. https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18269A037 The NRC continues to approve higher and higher fuel burnups knowing that higher burnup fuel cladding develops hydrides, hydride reorientation, becomes brittle which results in significant instabilities in storage. The NRC has also failed to acknowledge that canister crack growth-rate increases exponentially with higher heat loads.
- The NRC approved welded-shut canisters do not meet fuel retrievability requirements of 10 CFR Part 72.122(l) and the Nuclear Waste Policy Act (Monitored Retrievable storage). No Dry Transfer Facility (hot cell) exists in the U.S. capable of handling canister fuel transfer. And
apparently it is not feasible to return canister fuel to a spent fuel pool. Listen to Edisons former Chief Nuclear Officer, Tom Palmisano explain why fuel from a canister can not be returned to the spent fuel pool. https://youtu.be/mjgna2atn7Y The NRC has approved almost 4,000 canisters across the U.S. that are known to crack, yet licensees have no viable or technically approved methods to find cracks, repair cracks, contain a failing canister, or repackage fuel from a failing canister.
Please require the Aging Management Program, related NUREGs and technical documents for the Hi-Storm system to address these generic canister issues before approving this Direct Rule and 40 year license extension.
The NRCs proposed Direct Rule claims that Holtecs revised CoCs and Technical Speci"ca ons address aging management ac vi es. But NRC regula ons fail to require licensees to have technically speci"c and approved capabili es and processes in their Aging Management Program to "nd and evaluate cracks or to respond to a degrading or failing canister.
The assump on that canister degrada on wont begin for decades ignores "ndings from other Holtec storage systems that indicate accelerated canister degrada on mechanisms are already in place. The proposed Aging Management Program in the Direct Rule is inadequate to ensure public safety. NRC must require licensees to have technically speci"c and approved methods to prevent canister failure before approving this and other 40 year license renewals.
Speci"cally, at San Onofre, a er Holtec almost dropped a loaded canister 18, Edisons (SCE) visual assessment report showed carbon steel contamina on in the walls of the Holtec canisters. ML19261A089 pdf 131-136. The NRCs Special Inspec on of the Holtec UMAX system found that the carbon par cles were embedded in the canisters due to the lack of a precision downloading system. The NRC determined the canisters were unavoidably scraped and gouged against the carbon steel CEC guide ring as they were lowered into the storage holes. h ps://www.nrc.gov/reactors/opera ng/ops-experience/songs-spec-insp-ac vi es-cask-loading-misalignment.html While this rule is not about Holtecs UMAX system, the NRC must consider that a similar scenario of carbon par cle contamina on of canisters may exist with other Holtec storage systems. Holtecs above ground HiStorm system may also result in canisters scratched and scraped against the carbon steel ver cal channels in the over-pack casks. h ps://sanonofresafety.org/2019/05/16/all-holtec-nuclear-waste-thin-wall-canisters-likely-damaged-from-inferior-holtec-downloading-systems/
This poten al ini a on of carbon-induced pit corrosion cracking could result in accelerated canister degrada on of all Holtec canisters.
The assump on that cracks wont begin for decades also ignores an EPRI study that found a two-year old Diablo Canyon Holtec canister with corrosive salt and low enough temperature for moisture to dissolve the salt, a major trigger for stress corrosion cracking of the stainless-steel canisters. SanOnofreSafety.org Due to these and other poten al accelerated canister degrada on mechanisms, the NRC must require licensees to have technically speci"c and approved methods for resolving poten al failure modes before approving this and other 40 year license renewals.
- The NRC approve canisters do not and can not meet basic ASME N3 cer "ca on for nuclear pressure vessels in storage and transport; the list of exemp ons is extensive.
- The NRC approve thin-wall canisters are made of stainless steel prone to microscopic inter-granular cracking, yet the NRC fails to require viable and approved inspec on technology that can "nd and characterize cracks; Visual Assessments can only detect precursors to cracks. The
NRC has acknowledged that once cracks have ini ated, cracks can grow through the wall of a canister in as li le as 16 years.
h ps://sanonofresafety."les.wordpress.com/2013/06/ml14258a081-8 14mee ngsummary.pdf
- The NRC allows the industry to promote repair technologies as a viable method to stop cracks but repair technologies have not been evaluated or approved by the NRC or ASME. Even the president of Holtec, Kris Singh, recommends against trying to repair a canister and explains why it is not feasible even if you could "nd the cracks. He stated:
It is my personal belief, it is not prac cal to repair a canister if it were damaged. If it had a through-wall, "rst you prevent it, but in the most unlikely circumstance if that canister were to develop a leak, lets be realis c; you have to "nd it, that crack, where it might be, and then "nd the means to repair it. You will have, in the face of millions of curies of radioac vity coming out of canister; we think its not a path forward. However, let me you can easily isolate that canister in a cask that keeps it cool and basically you have provided the next con"nement boundary, youre not relying on the canister. So that is the prac cal way to deal with it and thats the way we advocate for our clients.
My personal posi on is a canister that develops a microscopic crack (all it takes is a microscopic crack to get the release), to precisely locate it itself it is a tall order and then if you try to repair it (remotely by welding) and of course remotely you can go and weld, the problem with that is you create a rough surface which becomes a new crea on site for corrosion down the road.
ASME Sec 3. Class 1 has some very signi"cant requirements for making repairs of Class 1 structures like the canisters, so I, as a pragma c technical solu on, I dont advocate repairing the canister. Kris Singh transcript h ps://sanonofresafety."les.wordpress.com/2015/09/a achment-14-declara on-of-donna-gilmore.pdf Kris Singh video h ps://youtu.be/euaFZt0YPi4 Kris Singh and others have suggested pu ng a problem canister in a storage overpack cask, but this has not been approved by the NRC. Years ago, when the NRC analyzed this process for much cooler fuel at Big Rock Point, the NRC approved it for a very limited me, only. The NRC has not done an updated analysis.
- Please give a technical response to the public comment on NUREG 2224 which raises the technical concerns of cri cali es and/or hydrogen gas explosions from canister failure. h ps://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18269A037 The NRC con nues to approve higher and higher fuel burnups knowing that higher burnup fuel cladding develops hydrides, hydride reorienta on, becomes bri le which results in signi"cant instabili es in storage. The NRC has also failed to acknowledge that canister crack growth-rate increases exponen ally with higher heat loads.
- The NRC approved welded-shut canisters do not meet fuel retrievability requirements of 10 CFR Part 72.122(l) and the Nuclear Waste Policy Act (Monitored Retrievable storage). No Dry Transfer Facility (hot cell) exists in the U.S. capable of handling canister fuel transfer. And
apparently it is not feasible to return canister fuel to a spent fuel pool. Listen to Edisons former Chief Nuclear Ocer, Tom Palmisano explain why fuel from a canister can not be returned to the spent fuel pool. h ps://youtu.be/mjgna2atn7Y The NRC has approved almost 4,000 canisters across the U.S. that are known to crack, yet licensees have no viable or technically approved methods to "nd cracks, repair cracks, contain a failing canister, or repackage fuel from a failing canister.
Please require the Aging Management Program, related NUREGs and technical documents for the Hi-Storm system to address these generic canister issues before approving this Direct Rule and 40 year license extension.