ML18033A498

Comment (66) of Nancy Alexander Regarding Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18033A498
Person / Time
Site:	San Onofre
Issue date:	01/02/2018
From:	Alexander N - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00066, NRC-2017-0211, NUREG-2215
Download: ML18033A498 (2)

Text

As of: 1/9/18 10:05 AM Received: January 02, 2018 Status: Pending_Post Page 1 of2 PUBLIC SUBMISSION Tracking No. 1 k2-90pf-ccpz Comments Due: January 02, 2018 Submission Type: Web Docket: NRC-2017-0211 Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities Comment On: NRC-2017-0211-0001 Standard Review Plan for Spent Fuel Dry Storage Systems and Facilitie~~ Request for Comment on Draft NUREG -Document: NRC-2017-0211-DRAFT-0067 Comment on FR Doc# 2017-24734 SUNSI Review Complete Template= ADM-013 E-RIDS= ADM-03 Add= :J~ 5JHt'l-t CJ&cs *submitter Information &J i2 Pt ~;21¥'/ Name: Nancy Alexander 11 /1s /;;~17 -General Comment I completely agree with the following statement submitted by Donna Gilmore: Comments to NRC Docket ID NRC"'"2017-021 l, NUREG-2215 NRC Standard Review Plan for Spent Fuel Dry-Storage Systems and Facilities Draft, -November 2017 https://www.nrc.gov/docs/ML 1731/ML 1731 OA693 .pdf The NRC cannot meet its mission to "ensure adequate protection of public health and safety and the environment" if it continues to allow thin-wall welded canisters they admit are vulnerable to cracks, that _ cannot be fully inspected (inside or out), and cannot be repaired, maintained and monitored to prevent (not just detect) radiological leaks. There is no adequate or proven detailed plan required to address

• major radiological leaks, or to address on-site replacement of containers. Seismic https://www.fdms.gov/fdms/ getcontent?objectld=0900006482d90854&fonnat=xml&showorig=false 01/09/2018 Page 2 of2 requirements for partial cracks is not addressed. See below webpage for details on the Holtec UMAX System planned for San Onofre and why this is an example of a system with major problems that should not be approved. https://sanonofresafety.org/holtec-hi-storm-umax-nuclear-waste-dry-storage-system/ Each canister contains about as much or more lethal Cesium-137 as released from the 1986 Chernobyl nuclear disaster, yet the NRC knows the boron metal in the canisters will not prevent the fuel from going critical if exposed to non-borated water from through wall cracks (in storage or transport). NUREG-2215 states it requires "conservative assumptions", "inspections", and admits to many "unknowns". NUREG-2215 is not "conservative", does not require adequate "inspections", and does not resolve the many "unknowns" that would be eliminated if the NRC mandated and enforced critical safety requiremei:its to inspect, monitor, maintain and repair (both inside and out) to PREVENT leaks. . Proven dry storage technology exists that meets critical basic safety requirements we expect in a car. Does the NRC consider thin-wall canisters "conservative assumptions" compared to wall casks? If so, why? Why does the NRC allow containers that do not meet these basic critical safety -requirements? https://www.fdms.gov/fdms/ getcontent?objectld=0900006482d90854&format=xml&showorig=false 01/09/2018