ML18066A551

Comment (153) of Alexander Bay Regarding Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18066A551
Person / Time
Site:	San Onofre
Issue date:	01/03/2018
From:	Bay A R - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00153, NRC-2017-0211, NUREG-2215
Download: ML18066A551 (2)

Text

Blount, Barbara

Subject:

Attachments: FW: Burying nuclear waste in cheap canisters at SONGS Comments to NUREG-2215Gilmore2018-0l-02-2.pdf From: Bay, Alexander [1]

• Sent: Wednesday, January 03, 2018 11:10 AM To: Gallagher, Carol <Carol.Gallagher@nrc.gov>

Subject:

[External_Sender] Burying nuclear waste in cheap canisters at SONGS

Dear Ms. Gallagher-I have grave concerns over using thin temporary storage containers at SONGS instead of thick casks used by other countries. As a citizen,

a local, and an academic (historian of science), I find the attempt by Southern California Edison to get by with slipshod safety measures both criminal and part of an institutional history that put company profits over safety. In the least, the spent nuclear fuel should be housed in the absolute best canisters at SONGS, not the cheapest. Thank you, Alexander R Bay Associate Professor 1 -----Fi 5'8,'it./i/ ,, hsl~,1 ----------~ SUNSI Review Complete Template= ADM -013 E-RIDS= ADM-03 Add= ~r~,-f 51h~{.M C .3"'-S~ __ _

Date: January 2, 2018 Comments to NRC Docket ID NRC-2017-0211, NUREG-2215 NRC Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities Draft, November 2017 https://www.nrc.gov/docs/ML1731/ML17310A693.pdf The NRCcannot 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 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 th~ NRC mandated and enforced critical safety requirements 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 thick-wall casks? If so, why? Why does the NRC allow containers that do not meet these basic critical safety requirements? Respectfully, Donna Gilmore, SanOnofreSafety.org donnagilmore@gmail.com 949-204-7794 Basic Safety Requirements Thick walls Won't crack. Ability to inspect inside & out, maintain, repair (fuel baskets, other parts) Monitor to fix problems before leaks ASM E container certification Defense in depth (redundancy) Stored in concrete building Gamma & neutron protection Transportable Proven technology Thin-wall canisters Thick-wall casks No. Only 1/2 to s/gth of an inch Yes. 10 to 19.75 inches No Yes No Yes No Yes No Yes No Yes No . Yes* Requires vented concrete overpack Yes No transport with cracks. 10 CFR § Yes 71.85 No. Conditions unknown. Most in Yes. Inspected and used use less than 15 yrs, a few 30 yrs. over 40 years