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Deadline in around 24 hours (11.59 pm Mon. March 9th Washington DC-EDT/3.59 am Tuesday UTC) for comment regarding storage of corroded nuclear spent fuel rods and other safety related exemptions for dry cask storage, to be given to privately owned Holtec by the US NRC. Remember to make the comment uniquely your own, because they don’t count repeats. https://www.federalregister.gov/articles/2015/02/05/2015-02310/list-of-approved-spent-fuel-storage-casks-holtec-international-hi-storm-100-cask-system-certificate For Holtec-NRC discussion of what is damaged, breached, grossly breached, and amputated, but not broken spent nuclear fuel see: https://miningawareness.wordpress.com/2015/03/09/holtec-nrc-confusing-double-speak-damaged-spent-nuclear-fuel-comment-period-ends-today-11-59-pm-eastern-us-4-59-tues-utc/ Holtec has contracts all over the US and the World – at least 67: China, S. Korea, Sweden, Switzerland, Belgium, Spain, UK (Sizewell B) and in the Ukraine, including Chernobyl. They have been accused and fined for bribery-kickbacks by the US Government. Holtec wants exemptions to store “damaged”, corroded, nuclear fuel rods in their dry casks and some other safety related exemptions. The US NRC will grant it, if there is not enough uproar. US NRC workers in Emergency Preparedness Exercise (2008, NRC). The guy in the gold shirt looks perplexed. Only two or three look serious. Some look like they are goofing off. Is this the problem? NRC Emergency Preparedness training 2008 Holtec Dry Casks, as they looked a decade ago at Diablo Canyon, NRC photos. Holtec casks Diablo Dec. 26 2005 or 2006 Holtec Diablo casks Dec. 2006 It is just like General Honore recently said about the Louisiana legislature giving exemptions and exceptions to the clean air and water act for the oil industry, (see approx. 21 min http://youtu.be/taXaWOcpfZI), except that this is nation-wide and high level nuclear waste. At the minimum, this means that the spent fuel casks will be stuck in place with corroded, damaged, fuel, because they can’t safely be moved, although it is certain that Holtec will ask for an exemption for moving the casks and get it, unless people start lawyering up and suing now. While we encourage you to comment for the record, we are almost certain that this is going to take legal action. There is something far stinkier, and certainly more dangerous, than Watergate, which needs to be brought to the light. We can’t tell you if the cause is sheer stupidity or something else. But, it is, in our opinion, worth noting that Holtec was fined by the US government for apparent bribery-kickbacks. However, we find it difficult to believe that NRC workers would endanger their own lives and those of their loved ones with broken nuclear fuel rods in casks, for a bribe-kickback, especially one as small as Holtec is alleged to have given. The sheer rottenness of the US NRC is thus difficult to explain. The CEO, President, Founder and presumed owner of Holtec, Kris Singh, can return to India. Thus, his not caring about the health and safety of Americans, and of the North American environment, should be less surprising. He may also not be too bright – we add this only to give him the benefit of the doubt. Or he’s evil, or he’s not so bright. Is there even evidence of his degree from a university in India? Has anyone checked? He would not be the only foreign national to fake a degree and get by with it. This would have been even easier to do when he came to America. Holtec is active all over the world, even having been given a contract for Chernobyl. If this weakened standard goes through, it will probably have international repercussions. It will be said to adhere to US standards, with no mention of the exceptions-exemptions. When reading the information given at the link, it is worth noting that all or almost all US Commercial Nuclear reactors are Light Water Reactors running off of low enriched (LEU) fuel. Around 1/3rd are non-pressurized (BWR); 2/3rds pressurized (PWR). From our recollection they don’t even want to check if the fuel rods are broken or the general state of the fuel rods, which is one reason they want to run this exemption through for costs. If you think that the NRC info is unclear, you would be right. Already the NRC is in violation of the rule stating that language should be clear and understandable. It is impossible to say if this is by design or by illiteracy. While these are complex topics, they have made them needlessly murky. Damaged Spent Nuclear Fuel at U.S. DOE Facilities, Experience and Lessons Learned, by INL (Brett Carlsen, et. al. Dangers of Corrosion, p. 2 “Damaged Spent Nuclear Fuel at U.S. DOE Facilities, Experience and Lessons Learned, by INL (Brett Carlsen, et. al) , p. 2″ The fuel rods become corroded-form metal oxides, while cooling-stored in water, and with subsequent radiolysis hydrogen gas, and maybe methane gas, can form. It is unclear if this would be enough to make the casks explode or not, if they are not moved. There are all sorts of unknowns regarding embrittlement by neutrons and hydrogen attack, too. Uranium, Plutonium, etc. in broken fuel rods corrode adding to the problems. Cesium is actually one of the most reactive metals. Also Holtec wants to use a cheap new welding method for the baskets, which makes unevenly attached kissing welds, so that the spent fuel holder may collapse. These welds are said to be impossible to inspect, outside of destructive testing. So, there will probably be broken, corroded, nuclear fuel rods, within collapsing internal baskets. Shape is important to prevent criticality accident. Can the collapsed baskets puncture the thin cask? Who knows? Does anyone care? Certainly not the US government and Holtec. Holtec doesn’t want to inspect some of the materials either and is decreasing safety margin. Really bizarre crazy stuff, which the US NRC is allowing Holtec to do. These are just a few of the issues which we recall of the top off our heads. Holtec seems to be a one or two man owned private company. The main owner (Singh) was born and educated in India and was debarred from the TVA and fined for apparent bribery-kickbacks: https://miningawareness.wordpress.com/2015/02/05/why-was-holtec-debarred-as-tva-contractor/ The casks are thin, though it’s almost impossible to find the info. We have found some info on the over-casks, which are vented. The current thickness for the sealed cask proper (MPC) is 1/2 inch. A 5/8ths inch canister was proposed as part of High-storm UMax for San Onofre, but apparently is not yet approved. The concrete in the over-casks is also susceptible to degradation, accelerated by the radiation. Here are a few of the concerns about the spent fuel cladding being breached, expressed by the US Nuclear Waste Technical Review Board, 2010. Note that Holtec and the US NRC want to start with it being corroded, damaged, breached! “In summary, given the damaged and unknown state of cladding at any point of time during dry storage, there is a possibility that accidents or handling could fail weakened fuel-rods. Furthermore, the uncertain hydrogen embrittlement and delayed hydride cracking mechanism could result in additional failed cladding. The likelihood of the latter mechanism increases with time. Accordingly, cladding failure during dry storage and handling could present significant hazardous conditions to workers and especially if the used fuel needs to be handled. While analytical methods can be used to predict future conditions of the fuel and cladding, it is recommended that a validation inspection program of both low and high-burnup fuels be instituted after 15 and 30 years of storage similar to that performed for Surry fuel by NRC and EPRI. This would provide additional confidence of our understanding of degradation phenomenon for extended periods of dry storage. For the case of failed cladding and a breached canister, there is the possibility that corrosion mechanisms within the canister could be activated. The new cladding degradation mechanisms that could be significant include pitting corrosion, stress corrosion cracking, induced cladding stress leading to creep failure, the potential of slow fuel oxidation that may result in unzipping, and biocorrosion. Analysis of the possibility of a breached canister due to degradation is explored in the next subsection. However, a breached canister should be able to be detected based on the release of radioactive contaminants. Given the initial-state condition of cladding when it is placed into dry storage (after the drying process), there may be fuel rods that are close to failure (defined as having pinhole and hairline cracks; undamaged fuel). A fuel-rod breach could potentially occur by two processes: impact forces causing a mechanical rupture, or thermal creep and rupture of embrittled cladding. The breached rod would depressurize and release radioactive gas, and possibly fines material, into the interior of the bolted or welded container. For this reason, a PRA approach would be used to calculate the percentage of fuel rods within a dry-storage cask that are expected to fail given an initiating event, instead of calculating the probability of failure for some “typical” fuel rod. In summary, normal events are not expected to result in conditions that could breach the Zircaloy fuel-rods. However, there are a number of off-normal and accident scenarios (mechanical impact and fire-related thermal-mechanical loading) and natural phenomenon scenarios (seismic motions, cask tip-over) that, when coupled with hydride embrittled cladding and higher burnup cladding corrosion, could result in cracked or leaking fuel-rods.” ( US Nuclear Waste Technical Review Board, 2010, p. 118). Unlike the US NRC-Holtec, they clearly think that damaged fuel rods are a problem. Contrary to what they say, there are no validation models. The US CSB recently concluded (2014) that the current model for high temperature hydrogen attack in the oil industry is inadequate. More recently, corrosion experts appear perplexed regarding the cracking of nuclear reactor pressure vessels in Belgium, which it is feared may be a highly dangerous and widespread international nuclear reactor “disease”, which could lead to sudden rupture with devastating consequences. The impacts of ionizing radiation on materials are complex and unknown, even in the best of conditions. So, why will the US NRC allow Holtec exemptions to further decrease safety? Submit comment green button: https://www.federalregister.gov/articles/2015/02/05/2015-02310/list-of-approved-spent-fuel-storage-casks-holtec-international-hi-storm-100-cask-system-certificate “Thursday, February 05, 2015 Agency: Nuclear Regulatory Commission Dates: The direct final rule is effective April 21, 2015, unless significant adverse comments are received by March 9, 2015. If the direct final rule is withdrawn as a result of such comments, timely notice of the withdrawal will be published in the Federal Register. Comments received after this date will be considered if it is practical to do so, but the NRC staff is able to ensure consideration only for comments received on or before this date. Comments received on this direct final rule will also be considered to be comments on a companion proposed rule published in the Proposed Rules section of this issue of the Federal Register.” Reference Note: “United States Nuclear Waste Technical Review Board Evaluation of the Technical Basis for Extended Dry Storage and Transportation of Used Nuclear Fuel, December 2010, This report was prepared for the U.S. Nuclear Waste Technical Review Board by Dr. Douglas B. Rigby, staff member, in support of the Board’s analysis of issues associated with extended dry storage and transportation, an effort lead by Dr. Andrew C. Kadak, Board member.” PLEASE NOTE THAT THIS POST IS A REMINDER EMERGENCY POST, AS WE THOUGHT THE DEADLINE WAS THE 18TH OF MARCH. THUS IT IS BY NO MEANS COMPREHENSIVE, AS WE HAD WANTED. IF WE HAVE TIME WE WILL PUT UP MORE DETAILED INFO BEFORE THE DEADLINE. PLEASE COMMENT, AT LEAST TO LET THEM KNOW THAT YOU ARE WATCHING THEM. THIS IS A LIFE OR DEATH TOPIC. Given the deadly consequences of their dirty deeds, it is small consolation that those working for Holtec and the US NRC will rot in hell, as will the entire nuclear industry.