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The US NRC has another document for comment today, besides the important Brown’s Ferry TVA one: https://miningawareness.wordpress.com/2015/06/02/us-nrc-beyond-design-basis-as-excuse-for-ignoring-risks-revising-pressuretemperature-limits-as-non-significant-hazard-at-the-tvas-browns-ferry-3-nuclear-reactor-hidden-beneath-cybers/
The deadline for both is 1159 pm NY-Washington DC (Eastern) Time, June 4th.

It is called “Seismic Stability Analysis for Spent Fuel Dry Cask Stack-Up Configuration; Draft Regulatorty Issue Summary for Comment” NRC-2015-0098

NRC Tort
Was the typo by the NRC a Freudian slip? “A tort, in common law jurisdictions, is a civil wrong that unfairly causes someone else to suffer loss or harm resulting in legal liability for the person who commits the tortious act, called a tortfeasor.http://en.wikipedia.org/wiki/Tort

It does not seem to even bother to tell how long these dry casks of nuclear waste are to be stacked up.

Those who read the intro to the comment section can quickly see what this is about and what’s at stake. Those who read only the draft itself could easily miss it, as we nearly did.

Action: Draft regulatory issue summary; request for comment. Summary
The U.S. Nuclear Regulatory Commission (NRC) is seeking public comment on a draft regulatory issue summary (RIS), RIS 2015-XX “Seismic Stability Analysis Methodologies for Spent Fuel Dry Cask Loading Stack-up Configuration.” This RIS clarifies the NRC staff’s position on acceptable seismic stability analysis methodologies to determine if a spent fuel dry cask loading stack-up configuration needs to be laterally supported

This issue of lateral support, or rather, of no lateral support appears the crux of the matter. And, making it a question only of seismic stability does not appear to be right. There appear to be other ways that they could tumble without lateral support. Elsewhere the NRC even assures that the odds of an earthquake occurring during cask transfer were so low as not to matter.

In 2010 the NRC said:
For the inspection of a freestanding (unrestrained) stack-up configuration, the inspectors shall request the general licensee to provide the documentation approving the unrestrained stack-up configuration used to perform vertical transfer operations and the associated NRC staff SER. In the absence of such documentation vertical transfer operations shall be postponed until either documentation approving such operations can be provided or a system of lateral restraints has been installed.” See what they just said: “VERTICAL TRANSFER OPERATIONS SHALL BE POSTPONED UNTIL EITHER DOCUMENTATION APPROVING SUCH OPERATIONS CAN BE PROVIDED OR A SYSTEM OF LATERAL RESTRAINTS HAS BEEN INSTALLED.” It continues: “When a lateral restraint system has been provided, the inspectors should review the seismic analysis calculations to ensure the structural adequacy of the lateral restraint design” ( p.5) “Response to Region III Technical Assistance Request for First Energy Operating Company Perry Nuclear Power Plant, Unit 1, Evaluation of Freestanding Stack-up Configuration (ML103010389), Dated 10-29-2010” NRC Memorandum from Vonna Ordaz to Anne Boland, DSST Ticket No. 201100002, ML110200478, February 25, 2011.” cited in: http://pbadupws.nrc.gov/docs/ML1111/ML111160566.pdf
Seismic Stability Analysis for Spent Fuel Dry Cask Stack-Up Configuration; Draft Regulatorty Issue Summary
The stack-up configuration refers to the condition when a transfer cask containing a canister loaded with spent fuel is resting on a storage overpack. While in the stack-up configuration, the loaded canister is lowered from the transfer cask to the storage overpack. During this transfer, when the transfer cask is not attached to a single-failure-proof crane, the stack-up is free-standing and the potential exists for the stack-up configuration to become unstable and tip-over during a seismic event.” http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0098-0002&disposition=attachment&contentType=pdf

This is the only appearance of the term lateral which we found in the draft:
Regarding the acceptance criterion for sliding, for base support surfaces that provide no restraint to lateral sliding, the maximum permissible lateral migration of the stack-up configuration’s base should be limited to one third of the value at which the outer edge of the storage overpack base reaches the edge of the support surface to help ensure the integrity of the support pad. The sliding criterion is not applicable to base support surfaces that are equipped with a physical barrier at their periphery that would prevent uncontrolled sliding. However, such physical barriers should be included in the nonlinear rocking analyses.” (p.4) http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0098-0002&disposition=attachment&contentType=pdf

Interestingly enough, in NUREG 2157, “Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel” (NUREG-2157), they seem to consider the risk of an earthquake happening, while casks are being moved, as almost non-existent, in order to justify the risk of extremely high levels of radiation exposure – up to 1850 mSv for surrounding populations (see also NUREG 1864). While on average this would translate into around 18.5 cases of cancer or leukemia, the risk goes up to 52 out of 100 for women. This assumes that NUREG 1864 did not underestimate exposure. Since it’s the US NRC you can be almost certain that this is an underestimate. According to the National Academy of Sciences BEIR report, in a population of 100,000 exposed to this amount of radiation, 18.5% to 52% will get cancer or leukemia. The second number is for women – presumably due to increased risk of breast cancer from the radio-iodine (iodine binds to breast tissue). NUREG 1864 estimates a 28% chance of container leakage if it is dropped in the transfer cask. And, a seismic event isn’t the only time that even so-called fail proof cranes fail. Crane failure appears frequent, and even routine, at nuclear sites.
Holtec Diablo casks Dec. 2006
Holtec Dry Casks at Diablo Canyon Nuclear Power Station, US DOE or NRC photo
Diablo Canyon Dry Casks

Here’s one comment just to show what it looks like. Please make your comment in your own words because if the comments are exactly the same they use this as an excuse not to post them. Already the US NRC is believed to be hiding many comments – probably 90% of them. There is a limit on characters unless you upload a pdf.
Stack up Spent Nuclear Fuel Comment