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Hitachi-Zosen bought the MAGNASTOR cask system for spent nuclear fuel a few years back. (As explained last time they are and are not Hitachi). [1] They are requesting and the US NRC granting multiple requests that reduce safety. They wish to use bollards – posts- to keep the casks from turning over in an above design basis earthquake. This does not seem to be strictly a case of grandfathering in older ones, either, but appears to apply to new, as well. There may be need for a special solution for those already packed, which are inadequate for newly found earthquake hazards, but bollards probably is not it. Certainly it is not a proper solution for new dry casks. They want to pack broken fuel-fuel debris. They also want to increase the gamma radiation at the surface of the casks to 26% more than it is currently. In 1985 an entire dry cask facility was to be 40 mrem per hour (0.4 mSv)[2], which is already very high – 350,400 mrem (3,504 mSv), compared to the 1 mSv which the NRC now wants everyone exposed to (EPA is 0.25 mSv). Hitachi-Zosen currently has it at 95 mrem per hour per cask and wish to raise it to 120 mrem per hour, i.e. over 1 million mrem, 10,512 mSv per year.

This is three times higher radiation exposure for one cask, than exposure at an entire facility was to be 30 years ago, according to Oh, et. al. (1985), who give 40 mrem per hour for the entire facility [2]. This increase to 120 mrem per hour per cask unnecessarily increases worker risk, risk to those living or working nearby (at least one reactor has dry casks very near housing), dangers to animals and birds, and would increase the rate of material degradation. Apparently Hitach-Zosen wishes to make the dry casks more cheaply. [Note that Ohr et. al. also has 29.68 mrem per hour for a dry cask in the middle of the facility. This is one quarter of the Hitachi-Zosen request for one cask, and presumably includes surrounding casks full of spent fuel. Allowable radiation in US food has also increased by around four fold (4 x) since the late 1980s. Radiation has NOT been found to be safer, on the contrary.]

The need for radiation protection and earthquake protection point to need of a mausoleum type building into which the dry casks could be securely placed with leakage monitor devices and which would help protect workers, wildlife, surrounding populations from radiation. In other countries the dry casks are kept inside.

Dry Casks for Spent Nuclear Fuel. Appears to be Magnastor.
NRC Dry Casks appear Magnastor
NRC photo

Bollards
Bollards cropped Public Domain via wikiepdia
Bollards: Public Domain via wikipedia

WTF is a bollard?
A bollard is a short vertical post. Originally it meant a post used on a ship or a quay, principally for mooring. The word now also describes a variety of structures to control or direct road traffic, such as posts arranged in a line to obstruct the passage of motor vehicles.http://en.wikipedia.org/wiki/Bollard

Reducing earthquake safety:
Page A4-4 – Authorize use of the MAGNASTOR® System at an independent spent fuel storage installation (ISFSI) where the maximum design basis earthquake (DBE) acceleration is greater than previously evaluated provided that the ISFSI pad is designed with bollards that prevents a cask from overturning and bollards are designed, fabricated, and installed such that they are capable of handling the combined loading of the DBE and any contact between the bollard and cask during the DBE“. (p. 8) ML14357A049 http://pbadupws.nrc.gov/docs/ML1435/ML14357A049.pdf
Read the entire statement at bottom [1]

Increasing Radiation Exposure:

From Summary:
Amendment No. 5 makes the following specific changes to Appendices A and B of the
TSs:
• Page A3-11 – Increase the maximum surface gamma dose rate for LCO 3.3.1
from 95 to 120 mrem/hr.
• Page A4-1 – Change required minimum actual areal density for 10B from 0.334
g/cm2 to the correct value of 0.0334 g/cm2.

(p. 8) ML14357A049 http://pbadupws.nrc.gov/docs/ML1435/ML14357A049.pdf

Longer Version:
3.3.1 CONCRETE CASK Maximum Surface Dose Rate
LCO 3.3.1 The maximum surface dose rates for the CONCRETE CASK, Reference Figure A3-1, shall not exceed the following limits:
a. PWR and BWR – 120 mrem/hour gamma and 5 mrem/hour neutron on the vertical concrete surfaces; and
b. PWR and BWR – 450 mrem/hour (neutron + gamma) on the top.
APPLICABILITY: Prior to start of STORAGE OPERATIONS

See p. A3-11: http://pbadupws.nrc.gov/docs/ML1417/ML14170A036.pdf. This gives an additional 5 mrem per hour neutron for a total of 125 mrem and 450 mrem per hour on top! Poor birdies. This was the earlier 2010 version, which shows that the 5 and 450 are already approved and the increase from 95 to 120 is thus new: http://pbadupws.nrc.gov/docs/ML1024/ML102420568.pdf

Assuming the 120 mrem per HOUR (and ignoring the larger numbers) represents a 26% increase in radiation exposure above 95 mrem. 120 mrem is 1.2 mSv per HOUR. This is more than people are supposed to have in one year! It is 28.8 mSv per day and 10,512 mSv per year! There is a 1 in 100 risk of getting cancer or leukemia per 100 mSv, according to BEIR. Maybe greater. This then gives over 100% risk of getting cancer or leukemia, just for one year’s exposure! This is dangerous for those working at the nuclear power plant-dry cask facility, but especially for any who are living near the dry casks and any birds or animals nearby. With top of the cask dosage higher (450 mrem per hour) birds are at even greater risk. Prairie Island American Indian community is at particular risk due to close proximity, although they appear to have AREVA dry casks. How much does protective gear protect workers or not? Whatever the answer, those who live nearby have no protective gear. Nor do animals and birds. While the exposure decreases with distance the NRC appears to have already increased surface exposure across the board and the numbers of dry casks licensed has gone up and continues to increase, which already increases exposure.

Also, the higher radiation levels would lead to quicker material degradation! So, failure will be quicker and more likely. Even a small leak could allow out deadly amounts of radiation, as this is spent nuclear fuel.

According to Oh, et. al. 1985, the maximum dose rates for the entire dry cask facility was to be 40 mrem per hour, i.e. 0.4 mSv per hour, which was already high. This resulted in 2.5 mrem per hour at the 100 meter storage boundary. The 120 mrem per hour is per cask, it seems. If you go to flickr and look for Magnastor, you will find pictures from 2014 where they appear to be next to a chain link fence and only some deep grass between the photographer and them. It doesn’t look like 100 meters at all.

Hitachi Zosen is asking for a 25 mrem per hour increase which is US EPA recommended exposure for one year, but it’s one hour. 0.25 mSv per hour is 6 mSv per day and 2,190 mSv per year, increasing the chance of cancer or leukemia to 22% or more. 1.2 mSv per hour gives almost certain risk of cancer or leukemia.

Probably because the nuclear industry is getting by with murder and ecocide in Japan and because Holtec is getting by with weakening standards, Hitachi Zosen wants to weaken its US dry cask standards. You have until Friday the 15th of May to object. Amendment 5 probably means that it is the 5th such request.

There actually seem to be two spots to comment, so comment at both to be certain. Put the appropriate NRC ID number and take a screen shot of your comment receipt, as the NRC appears to be hiding comments, which are supposed to be public record, so that others can read them:
List of Approved Spent Fuel Storage Casks – NAC International MAGNASTOR Cask System, Amendment 5
http://www.regulations.gov/#!docketDetail;D=NRC-2014-0261
Summary
The U.S. Nuclear Regulatory Commission (NRC) is proposing to amend its spent fuel storage regulations by revising the NAC International, Inc., MAGNASTOR® System listing within the “List of approved spent fuel storage casks” to include Amendment No. 5 to Certificate of Compliance (CoC) No. 1031. Amendment No. 5 makes numerous changes to the Technical Specifications (TSs) including adding a new damaged fuel assembly, revising the maximum or minimum enrichments for three fuel assembly designs, adding four-zone preferential loading for pressurized-water reactor fuel assemblies and increasing the maximum dose rates in limiting condition for operation 3.3.1, and other editorial changes to Appendices A and B of the TSs.
Dates
Submit comments by May 15, 2015. 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.

http://www.regulations.gov/#!documentDetail;D=NRC-2014-0261-0002 Proposed CoC No. 1031, Amendment No. 5, ML14216A197 http://pbadupws.nrc.gov/docs/ML1421/ML14216A197.pdf

They also seem to want to store damaged fuel, including debris:
2.0 FUEL TO BE STORED IN THE MAGNASTOR SYSTEM

UNDAMAGED PWR FUEL ASSEMBLIES, DAMAGED PWR FUEL ASSEMBLIES, PWR FUEL DEBRIS (DAMAGED FUEL), UNDAMAGED BWR FUEL ASSEMBLIES and NONFUEL HARDWARE meeting the limits specified in Tables B2-1 through B2-41 may be stored in the MAGNASTOR SYSTEM.” (Certificate of Compliance No. 1031 Amendment No. 5 p. B2-1) http://pbadupws.nrc.gov/docs/ML1417/ML14170A036.pdf

Bollards long version
This is the long version. No detailed description of the bollards is found, only what the cask should be able to withstand. There appears to be a risk of puncture with bollards, despite what it says. If it is to be bollard resistant, why not earthquake resistant? We also now know that the US NRC accepts magical thinking-circular logic from the nuclear industry, as in using plastic pipes for the Callaway NPS. Probably some sort of added support would be of help, but probably not bollards!
The maximum design basis earthquake acceleration of 0.37g in the horizontal direction (without cask sliding) and 0.25g in the vertical direction at the ISFSI pad top surface do not result in cask tip-over.

Site-specific cask sliding is permitted with validation by the cask user that the cask does not slide off the pad and that the g-load resulting from the collision of two sliding casks remains bounded by the cask tip-over accident condition analysis presented in Chapter 3 of the FSAR.

For design basis earthquake accelerations greater than 0.37g in the horizontal direction and 0.25g in the vertical direction at the ISFSI pad top surface, the use of ISFSI pad bollards are permitted provided the cask user validates that the cask does not slide off the pad or overturn, g-loads resulting from the cask contacting the bollard is bounded by the cask tip-over accident condition presented in Chapter 3 of the FSAR andý the ISFSI pad and bollards are designed, fabricated and installed such that they are capable of handling the combined loading of the design basis earthquake and any contact between the bollard and cask during tbe design basis earthquake.” Certificate of Compliance No. 1031 Amendment No. 5 p. A4-4 http://pbadupws.nrc.gov/docs/ML1417/ML14170A036.pdf

g is the acceleration of gravity 9.8 (m/s2) or the strength of the gravitational field (N/kg) (which it turns out is equivalent).
When acceleration acts on a physical body, the body experiences the acceleration as a force. The force we are most experienced with is the force of gravity, which causes us to have weight.
….
When there is an earthquake, the forces caused by the shaking can be measured as a percentage of gravity, or percent g.
For example: The shaking at a particular location is measured as an acceleration of 11 feet per second, or 11*12*2.54 cm/sec/sec = 335 cm/sec/sec. The acceleration due to gravity is 980 cm/sec/sec, so the measured shaking is 335/980, or 0.34 g. As a percentage, this is 34% g.

http://earthquake.usgs.gov/learn/glossary/?term=G%20or%20g
http://earthquake.usgs.gov/hazards/about/basics.php
http://earthquake.usgs.gov/hazards/products/conterminous/2014/2014pga2pct.pdf

OUR APOLOGIES FOR ANY ERRORS. WE ARE TIRED.
Notes, References, Image credits:
[1] http://en.wikipedia.org/wiki/Hitachi_Zosen_Corporation
http://en.wikipedia.org/wiki/Nissan_Group
From Shunko Konwa-kai web site.
The 20 Members of the Shunko Konwa-kai:
     ・Hitachi, Ltd.
     ・NISSAN CHEMICAL INDUSTRIES, LTD.
     ・Sompo Japan Nipponkoa Holdings, Inc.
     ・Sompo Japan Nipponkoa Insurance Inc.
     ・NISSAN MOTOR Co.,LTD.
     ・JX Holdings, Inc.
     ・JX Nippon Oil & Energy Corporation
     ・JX Nippon Oil & Gas Exploration Corporation
     ・JX Nippon Mining & Metals Corporation
     ・Nippon Suisan Kaisha,Ltd
     ・NOF CORPORATION
     ・Nichirei Corporation
     ・Hitachi Zosen Corporatin
     ・Hitachi Metals, Ltd.
     ・Hitachi Chemical Co., Ltd.
     ・UD Trucks Corporation
     ・Hitachi Construction Machinery Co., Ltd.
     ・Hitachi Capital Corporation
     ・Hitachi High-Technologies Corporation
     ・NISSAN SHATAI Co.,LTD.

[2] “Radiological analysis for dry cask storage of spent fuels”
by Oh, I.; Sells, J.E.; Silverberg, T.C. (Stone and Webster Engineering Corp., Denver, CO; Northern States Power Co., Minneapolis, MN) fromWaste Management ’85: Waste Isolation in the US – Technical Programs and Public Education. Volume 2. Waste policies and programs, low-level waste https://inis.iaea. org/search/search.aspx?orig_q=RN:19001604

The Charles Miller Flickr account has some recent pictures of the Magnastor Dry Casks at Zion Nuclear Power Station. They appear closer to the fence than 100 meters. Unfortunately it is not Creative Commons so it cannot be used. You can find it by searching Magnastor at Flickr. There were 2 photos:
Charles Miller
Magnastor Dry Cask Nuclear Waste Storage Containers 1117
Taken on September 1, 2014