ML18066A545

Comment 150 of Steve Guich on Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18066A545
Person / Time
Site:	San Onofre
Issue date:	01/02/2018
From:	Guich S - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00150, NRC-2017-0211
Download: ML18066A545 (2)

Text

Blount, Barbara

Subject:

FW: NRC-2017-0211 Attachments:

Comments to NRC Docket ID NRC-2017-0211.pdf; ATTOOOOl.txt Living 15 miles from San Onofre in South Laguna Beach, we have particular concerns for the quality and durability of the storage containers to be chosen to safeguard the highly radioactive remnants of the SO nuclear reactor. I submit that the thoughtful analysis of SanOnofreSafety.org (pdf attached) is critically important for the NRC to consider in making any decisions, and I implore you to not ignore or put at risk the health of safety of 1 Os ( or 1 OOs) of thousands of people in making your important decision.

Thank you Steve Guich 1 SUNSI Review Complete Template = ADM -013 E-RIDS= ADM -03 ~dd= "J-er-ervt St>t i~ { _Jt:t5i)

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 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 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/ho/tec-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 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, SanOnofreSi:!fety.org . donnagilmore@gmail.com 949-204-7794 Basic Safety Requirements I Thick walls Won't crack. Ability to inspect inside & out, maintain, repair (fuelbaskets, other parts) Monitor to fix problems before leaks ASME 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 5/8th of an inch Yes. 10 to 19.75 inches No Yes No Yes No Yes No Yes No Yes No Y,es 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