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Comment (12) of an anonymous individual on FR Doc # 2015-02309
This is a Comment on the Nuclear Regulatory Commission (NRC) Proposed Rule: List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System, Certificate of Compliance No. 1014, Amendment No. 8, Revision No. 1, Comment Period Closed Mar 9 2015, at 11:59 PM ET
Holtec implies that they should not have to check the status of the fuel, because of cost to the “user” and speaks of “known” or “suspected” “gross” fuel “breaches”. If they don’t look they can say they don’t know or suspect. This is a huge loophole which the NRC is letting pass through. There is no definition given of grossly breached fuel either. This is all subjective in nature.

These documents violate the clear writing act. What is intended is unclear. Furthermore, it looks like people are being intentionally misled, when discussion is made of it being only BWR fuel of 3.3% or less enrichment, whereas approximately 1/3rd of US commercial reactors are BWR.

I object to the constant whittling away of safety by the NRC – that is, what little safety exists.

How can you approve Holtec not properly testing the manufacture of the materials? How can you approve this cheap welding process which is known to cause unevenly welded joints, known as kissing joints, which can’t be checked by non-destructive means? Obviously if you destroy the weld it doesn’t work out, does it? How can you approve the storage of breached, corroded fuel rods, full knowing that with radiolysis the water there will form flammable, explosive gases and that the uranium, plutonium, cesium, itself can be corroded-oxidized. How can you allow Holtec not to be required to do material testing, because they claim that it is ok if made according to instructions? The point of testing is that it checks to see if the manufacturing process was properly done; that the instructions were followed.

I object to the storage of damaged fuel rods, period. This is not allowed in Germany, for instance. Why should we accept weak, dangerous standards? So that we can be Germany’s dumping ground for nuclear waste?

Even if the damaged fuel can be safely stored on site, which is an unknown, leaving them damaged-broken in casks, from which they must eventually be moved, is the real safety danger for workers. Leaking, corroding casks of broken, damaged, fuel is a danger to everyone.

I am also alarmed at the use of aluminum for the fuel baskets, which could create a galvanic cell with the nuclear waste – not only fuel rods, but very reactive cesium, as well as the plutonium and uranium, which is exposed in breached fuel.

I am concerned that the helium backfill, under conditions of corrosion and/or radiolysis can become hydrogen gas, since the only difference between the two is that helium has one extra electron, which can be easily lost through galvanic corrosion or radiolysis. Damaged fuel could make this problem worse.

One year ago, the US CSB announced that the model of high temperature hydrogen embrittlement used by the petroleum industry was invalid and could not accurately predict high temperature hydrogen embrittlement and failures. More recently, Dr. Digby MacDonald, and other corrosion experts, have been shocked at the hydrogen damage at two Belgium nuclear reactors and warned that hydrogen damage was the Ebola of the nuclear industry. But, it’s not just hydrogen damage, but also neutron damage, which causes embrittlement and could lead to sudden failures. Add to this the possible build-up of flammable gases in the nuclear waste casks. The radiological damage and changes in the nuclear waste are still unknowns. Only recently have researchers become alarmed at the dangers of corroded plutonium and uranium in spent fuel. Furthermore, cesium is more reactive than sodium. Cesium is the most reactive metal, besides francium.

I will remind you, as well, of the thin, flimsy nature of the Holtec casks (1/2 in). Concrete, which itself can be a victim of radiolysis, as well as routine degradation, does not help and may actually hinder safety.

Are you all foreigners with plans to return home, like the owner of Holtec probably has? Are you so sure that you will be safely back on your home continents, where ever they are? Are you so ungrateful and hate America so much? Over a decade ago, it was an Iranian-American [Oscar Shirani] who tried to warn everyone about how poorly made the Holtec casks are and lost his job for it. Obviously, he loved America and didn’t want to return to Iran.

Note that the comment was edited to reflect that approximately 1/3rd of US nuclear reactors are BWR, and that Holtec spent fuel casks are 1/2 inch thick rather than 5/8ths. Holtec constitutes an international menace as it is also present in Europe and even sold its “technology”, which the late Oscar Shirani likened to “garbage cans”, to Chernobyl for spent nuclear fuel storage. We conclude that Holtec owner Kris Singh is the greatest individual menace to world health and safety. Obviously he has individual and institutional enablers in the US NRC and elsewhere.

The late Oscar Shirani wrote a comment to the NRC on Mon, Oct 30, 2006 11:18 AM Subject: “Exelon’s Clinton Early Site permit EIS“. In his comments he noted that “In Dec. 4, 2002, NRC wrote to Shirani: we substantiated that a stop work issued by Exelon’s QA program to GE-NE was lifted based on a vendor’s promises rather than verification that the underlying problems had been corrected…<” In the NRC inspection documents, which we have read, we have also noticed this thing repeatedly. They simply say what’s wrong and make the supplier write a letter saying what they will change. These are often serious and even deadly issues and the NRC doesn’t appear to care at all. The NRC attitude to nuclear suppliers appears to be “It’s alright darling baby doll!” In his comment to the NRC he interestingly states that “Dr. Ross Landsman and Oscar Shirani both believe that the Holtec’s Nuclear spent Fuel Dry Cask are nothing except garbage cans with design flaws, welding flaws, and manufacturing flaws and dangerous to public safety in our backyards.
See Shirani’s comment and more here: https://miningawareness.wordpress.com/2015/02/04/nuclear-supplier-holtec-notice-of-violation-by-nrc-the-india-us-nuclear-deal/

According to Philly.com: “Holtec a tech firm with ambitions to grow” By Joseph N. DiStefano, Inquirer Staff Writer, July 11, 2014 , Holtec filed state and federal documents in 2012 for proposed building small modular reactors at the Savannah River Nucler site. They state that the “proposal won support from South Carolina Gov. Nikki Haley, whose father’s family has roots in the same part of India as Singh’s. She called herself a family friend last fall as she attended dedication ceremonies for the $80 million Krishna P. Singh Center for Nanotechnology at the University of Pennsylvania… Singh donated $3,500 to Haley’s gubernatorial campaign in 2011, according to South Carolina campaign finance records.
(Emphasis added) Read the article here: http://articles.philly.com/2014-07-11/news/51307920_1_singh-center-indian-people-delaware-valley See also: http://sunlightfoundation.com/blog/2012/04/03/buying-news-philly-donors-turn-newspaper-moguls/ (Discusses the campaign donation. However, Norcross apparently is no longer owner as of ca end May 2014: http://www.nj.com/politics/index.ssf/2014/05/lewis_katz_partner_buy_out_george_norcross_to_gain_control_of_philadelphia_inquirer.html )

Republican Presidential Candidate, Stephen Comley, has warned for decades about substandard parts at US Nuclear Power Stations. He even handed a packet of information to President Reagan (see photo on his web site) but was ignored:
Spurred by a letter from then Nuclear Regulatory Commissioner’s Executive Director, Victor Stello, declaring the most vulnerable of our citizens would be left behind in the event of nuclear disaster Stephen B. Comley, Sr. brought the fight to the door of United States’ Presidents, the Nuclear Regulatory Commission (NRC), and the national press.

For twenty-eight-years, Mr. Comley worked outside the political beltway to bring change to an industry fueled by billions of dollars and harnessed control of our nations political machine… The insider information he provided on counterfeit and substandard parts built into seventy-percent of nuclear plants caused the NRC to make the claim he was “conspiring to topple the NRC.” (Emphasis added) http://www.stephencomleysr.com/about/
Learn more here: http://www.stephencomleysr.com/new-blog/ If you are Republican or have an open primary, you need to support this brave and caring man. If he’s not on the ballot then write his name in. Other people, who few had heard of, have become US President.

To learn more than you probably want to know about Holtec do a “search” for Holtec in the Mining Awareness blog and look the following site: http://sanonofresafety.org/holtec-hi-storm-umax-nuclear-waste-dry-storage-system/