aluminum, aluminum boron carbide, boron, cooling reduction, corruption, crime, criminals, criticality, dry cask storage, exemptions, failures, fraud, HI-STORM, High Level Nuclear Waste, Holtec, Holtec Dry Casks, Holtec International, Kris Singh, material testing, metamic, Metamic HT, New Jersey, NRC, NRC comments, nuclear dangers, nuclear energy, nuclear fuel, nuclear regulatory commission, nuclear safety, public endangerment, public safety, QA, quality assurance, quality control, Spent Fuel, spent fuel storage, Spent Nuclear Fuel, standards, tensile testing, testing, thermal conductivity, US NRC
Forget North Korea, Holtec and its owner Kris Singh is the biggest nuclear menace. Holtec’s nuclear “spent fuel” canisters are already a flimsy 1/2 inch thick, for the sealed metal part which protects the public from radiation, even though they are huge, as seen in the picture. The concrete surrounding the inner 1/2 inch sealed canisters is vented, so that failure of the internal 1/2 inch canister exposes the public to high levels of radiation.
Nonetheless, Holtec continues to request safety-related exemptions. In particular, to not assure quality of the neutron aborber, metamic, which is supposed to prevent a criticality event.
Holtec is up to Amendment 9. The Certificate of Compliance (CoC) should not be amended at all. Amendment 8 was less than a year ago.
To further exacerbate the dangers, Holtec (Kris Singh) wants to pack broken fuel rods.  Holtec wishes to further evade proper material testing.
The US NRC continues to behave similarly to what General Honore 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, in the case of Holtec, involves high level nuclear waste.
If Holtec owner Kris Singh and elements of the US NRC are not indicted soon, we will be discussing those who are probably protecting him-them. We hope to see him in prison before this comment deadline – doing nuclear clean-up in the day and prison at night.
Holtec change requests in the NRC docket, which increase the risk of a criticality accident. They are up to Amendment No. 9, Revision 1, to Certificate of Compliance (CoC) No. 1014 (HI–STORM 100 Cask System) “removes certain testing requirements for the fabrication of Metamic HT neutron-absorbing structural material, and reduces certain minimum guaranteed values used in bounding calculations for this material.”
This violates the law:
“10 CFR 72.124 – Criteria for nuclear criticality safety.
§ 72.124 Criteria for nuclear criticality safety.
(a) Design for criticality safety. Spent fuel handling, packaging, transfer, and storage systems must be designed to be maintained subcritical and to ensure that, before a nuclear criticality accident is possible, at least two unlikely, independent, and concurrent or sequential changes have occurred in the conditions essential to nuclear criticality safety. The design of handling, packaging, transfer, and storage systems must include margins of safety for the nuclear criticality parameters that are commensurate with the uncertainties in the data and methods used in calculations and demonstrate safety for the handling, packaging, transfer and storage conditions and in the nature of the immediate environment under accident conditions.
(b) Methods of criticality control. When practicable, the design of an ISFSI or MRS must be based on favorable geometry, permanently fixed neutron absorbing materials (poisons), or both. Where solid neutron absorbing materials are used, the design must provide for positive means of verifying their continued efficacy. For dry spent fuel storage systems, the continued efficacy may be confirmed by a demonstration or analysis before use, showing that significant degradation of the neutron absorbing materials cannot occur over the life of the facility.” https://www.law.cornell.edu/cfr/text/10/72.124
Amendment 8, R.1 for the HI-STORM 100 was similar and less than a year ago: https://miningawareness.wordpress.com/2015/03/10/holtec-nuclear-waste-snf-casks-friction-stir-welds-kissing-bonds-other-safety-concerns-comment-now/
“The U.S. Nuclear Regulatory Commission (NRC) is amending its spent fuel storage regulations by revising the Holtec International HI-STORM 100 Cask System listing within the “List of approved spent fuel storage casks” to add Revision No. 1 to Amendment No. 8 (effective May 2, 2012, and corrected on November 16, 2012), to the Certificate of Compliance (CoC) No. 1014. Amendment No. 8, Revision No. 1, changes burnup/cooling time limits for thimble plug devices; changes Metamic-HT material testing requirements; changes Metamic-HT material minimum guaranteed values; and updates fuel definitions to allow boiling water reactor fuel affected by certain corrosion mechanisms with specific guidelines to be classified as undamaged fuel.”
“Amendment No. 8, Revision No. 1, changes burnup/cooling time limits for thimble plug devices; changes Metamic-HT material testing requirements; changes Metamic-HT material minimum guaranteed values; and updates fuel definitions to allow boiling water reactor fuel affected by certain corrosion mechanisms with specific guidelines to be classified as undamaged fuel.” 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
Related change requests in the NRC docket (posted, March 19; comment deadline April 20): “On July 31, 2013, Holtec submitted a revision request for the Holtec HI-STORM FW System CoC No. 1032, Amendment No. 1… Amendment No. 1, Revision 1, also removes fabrication testing requirements for the thermal expansion coefficient and thermal conductivity of Metamic HT neutron-absorbing structural material“. The reason? “as these properties have little variability in this aluminum alloy when fabricated according to the manufacturer’s manual.” http://www.regulations.gov/#!docketDetail;D=NRC-2014-0275 BUT THAT IS THE PURPOSE OF TESTING TO SEE IF IT WAS PROPERLY FABRICATED! See how these people are stark raving mad!
“NRC-2014-0275, List of Approved Spent Fuel Storage Casks – Holtec International HI-STORM Flood/Wind Cask System, Amendment No. 1, Revision 1, 04/20/2015”
As posted today:
“NUCLEAR REGULATORY COMMISSION
10 CFR Part 72
List of Approved Spent Fuel Storage Casks: Holtec International HI–STORM 100 Cask System; Amendment No. 9, Revision 1
AGENCY: Nuclear Regulatory Commission.
ACTION: Proposed rule.
SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is proposing to amend its spent fuel storage regulations by revising the Holtec International (Holtec or the applicant) HI–STORM 100 Cask System listing within the ‘‘List of Approved Spent Fuel Storage Casks” to include Amendment No. 9, Revision 1, to Certificate of Compliance (CoC) No. 1014. Amendment No. 9, Revision 1, changes cooling time limits for thimble plug devices, removes certain testing requirements for the fabrication of Metamic HT neutron-absorbing structural material, and reduces certain minimum guaranteed values used in bounding calculations for this material. Amendment No. 9, Revision 1, also changes fuel definitions to classify certain boiling water reactor fuel within specified guidelines as undamaged fuel.
DATES: Submit comments by February 5, 2016. 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.”
 For details search for Holtec within this blog. Some summary points: The storage of breached, corroded fuel rods, in conjunction with radiolysis of remaining water will form flammable, explosive gases. The uranium, plutonium, cesium, itself can be corroded-oxidized, making the internal situation a dangerous, complicated, unknown. Holtec wishes to further evade 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. The storage of damaged fuel rods is not allowed in Germany, for instance. 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 a real safety danger for workers. Leaking, corroding casks of broken, damaged, fuel is a danger to everyone. The use of aluminum for the fuel baskets, 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. 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.