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NRC-2015-0134 List of Approved Spent Fuel Storage Casks: Holtec International, HI-STORM Flood/Wind Multipurpose Storage System, Certificate of Compliance No. 1032, Amendment No. 0, Revision No. 1 10/28/2015” Write Docket ID NRC-2015-0134 in your comment submission. http://www.regulations.gov/#!docketDetail;D=NRC-2015-0134

There are probably a lot of problems with this Certificate of Compliance (CoC), since it’s USNRC approved, and presumably per Holtec Request, but we’ve no time to examine it carefully.

However, here is one thing which jumps to the eye: Heat removal vent blocked by 50% or more, but “operable”. They say to unblock it, but time limit to do so is “N/A”, “not-applicable”. Some places the time limit is “immediately”. Thus, this seems to mean they can take their time, or even wait until it is “inoperable”. And, this document doesn’t seem to make sense. If it is blocked by less than 50% it is considered operable and 50% or more then inoperable. However, if air temperature requirements are met (whatever that means), then it can be more than 50% blocked and still classified as operable.

And, if the Heat Removal System is inoperable and not restored within 8 hours they are to measure radiation dose rates and within 24 hours (or is it a total of 32 hours?) transfer it to a TRANSFER CASK! This checking for dose rates is what catches the eye because, unlike operating nuclear reactors, these Dry Casks are NOT supposed to leak radioactive materials into the environment. TRANSFER CASKS ARE THICKER AND HAVE BEEN REPORTEDLY USED FOR LEAKING CASKS! In fact, Holtec owner Kris Singh seems to advocate this, or something similar, in the event of a radioactive leak from the casks: https://miningawareness.wordpress.com/2015/04/16/holtec-ceo-kris-singh-on-not-repairing-cracked-nuclear-dry-casks/

SO, IF THEY ARE CHECKING DOSE RATES AND MOVING TO A THICKER CASK ARE THEY ASSUMING INNER MPC (CASK) RUPTURE? THIS LOOKS STRANGE. IT SAYS DURING STORAGE CONDITIONS AND THEY PRESUMABLY MEAN PERMANENT STORAGE SO IT HAS NO BUSINESS IN A TRANSPORT CASK UNLESS THEY EXPECT THAT IT WILL CRACK-BURST OR THAT IT ALREADY DID!
Holtec casks Diablo Dec. 26 2005 or 2006
Holtec Casks at Diablo NPS. They are huge (compare to men standing), but the inner cask, which protects from emission of radionuclides into the environment is a mere 1/2 inch thick!

IS THIS AS STUPID AS IT LOOKS? HARD TO GET MORE STUPID-CRIMINAL THAN THESE HUGE CASKS WITH A MERE 1/2 INCH THICK INSIDE CASK TO PROTECT FROM RADIATION ESCAPING TO THE ENVIRONMENT.

This part says during storage conditions, which presumably means permanent storage conditions.
CERTIFICATE OF COMPLIANCE NO. 1032     APPENDIX A  TECHNICAL SPECIFICATIONS   FOR THE HI-STORM FW MPC STORAGE SYSTEM   Certificate of Compliance No. 1032 Amendment No. 0 Revision No. 1 Appendix A 3.1.2-1
On one hand they say in “SFSC Heat Removal System 3.1.2 , Certificate of Compliance No. 1032 Amendment No. 0 Revision No. 1 Appendix A 3.1.2-1 , 3.1 SFSC INTEGRITY, 3.1.2 SFSC Heat Removal System, LCO 3.1.2 The SFSC Heat Removal System shall be operable
———————————————————-NOTE————————————————– The SFSC Heat Removal System is operable when 50% or more of each of the inlet and outlet vent areas are unblocked and available for flow or when air temperature requirements are met. ——————————————————————————————————————— APPLICABILITY: During STORAGE OPERATIONS.
ACTIONS ———————————————————-NOTE————————————————– Separate Condition entry is allowed for each SFSC. ———————————————————————————————————————
CONDITION REQUIRED ACTION COMPLETION TIME
A. SFSC Heat Removal System operable, but partially (<50%) blocked.
A.1 Remove blockage.
N/A

B. SFSC Heat Removal System inoperable. B.1 Restore SFSC Heat Removal System to operable status.
8 hours
C. Required Action B.1 and associated Completion Time not met.
C.1 Measure SFSC dose rates in accordance with the Radiation Protection Program.
Immediately and once per 12 hours thereafter
AND
C.2.1 Restore SFSC Heat Removal System to operable status.
24 hours
OR
C.2.2 Transfer the MPC into a TRANSFER CASK. 24 hours

CERTIFICATE OF COMPLIANCE NO. 1032
APPENDIX A TECHNICAL SPECIFICATIONS
FOR THE HI-STORM FW MPC STORAGE SYSTEM
Certificate of Compliance No. 1032 Amendment No. 0 Revision No. 1 Appendix A 3.1.2-1

http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0134-0004&disposition=attachment&contentType=pdf
http://pbadupws.nrc.gov/docs/ML0633/ML063380127.pdf

The law just says, “(f) The spent fuel storage cask must be designed to provide adequate heat removal capacity without active cooling systems.https://www.law.cornell.edu/cfr/text/10/72.236

WHY ARE THERE SO MANY REVISIONS AND AMENDMENTS? THEY COULDN’T GET IT RIGHT IN THE FIRST PLACE? OR, IT WAS RIGHT AND THEY ARE CHANGING IT TO WRONG?
2. In § 72.214, Certificate of Compliance No. 1032 is revised to read as follows:
§ 72.214
List of approved spent fuel storage casks.
* * * * *
Certificate Number: 1032.
Initial Certificate Effective Date: June 13, 2011, superseded by Amendment Number 0, Revision 1, on April 25, 2016.
Amendment Number 0, Revision 1, Effective Date April 25, 2016.
Amendment Number 1 Effective Date: December 17, 2014, superseded by Amendment.
Number 1, Revision 1, on June 2, 2015.
Amendment Number 1, Revision 1, Effective Date: June 2, 2015.
SAR Submitted by: Holtec International, Inc.
SAR Title: Final Safety Analysis Report for the Holtec International HI-STORM FW System.
Docket Number: 72-1032.
Certificate Expiration Date: June 12, 2031.
Model Number: HI-STORM FW MPC-37, MPC-89.

http://www.regulations.gov/#!documentDetail;D=NRC-2015-0134-0002

Supp Mats:
Document ADAMS Accession No.
Proposed CoC No. 1032, Amendment No. 0, Revision 1 ML15124A631
Appendix A of Proposed TSs ML15124A636
Appendix B of Proposed TS ML15124A642
Preliminary SER ML15124A644
September 16, 2014, application ML14262A070
March 12, 2015, supplement to application ML15071A472
http://www.regulations.gov/#!documentDetail;D=NRC-2015-0134-0002

Worth recalling – https://miningawareness.wordpress.com/2015/02/05/why-was-holtec-debarred-as-tva-contractor/ Anyone who has bribed or paid kickbacks in the past, should never be trusted again. And, TVA is a US Government owned utility.

HURRY UP ALREADY WITH THE LAWSUITS-INVESTIGATIONS OF HOLTEC AND THE NRC!