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Holtec casks Diablo Dec. 26 2005 or 2006
Holtec Spent Fuel Casks at Diablo Canyon

[Note that this comment deadline is long past, but the information remains important-relevant]
Comment Deadline April 13th, 2016, 11.59 PM US Eastern Time (i.e. all day on the 13th minus one minute).
ID: NRC-2015-0270-0002 “List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System; Certificate of Compliance No. 1014, Amendment No. 10” https://www.regulations.gov/#!documentDetail;D=NRC-2015-0270-0002
As has become a very routine habit for Holtec, as evidenced by “Amendment 10”, they are asking for more “exemptions” to their CoC (Certificate of Compliance) for their spent nuclear fuel casks, which were already of questionable quality. For instance, the inner cask which is the only part which protects from radioactive discharges into the environment is a mere 1/2 inch thick. They have thicker vented covers which appear to be concrete sandwiched between metal for the HI-STORM OVERPACK. The HI-TRAC TRANSFER CASK appears to be metal. Recently each Amendment has had one Revision and they seem to have multiple requests, so the total changes must be up to around 60, or more, by now.

Those who have followed the USNRC and Holtec for any amount of time know there is going to almost certainly be a con in this “exemption”. In fact, the word “exemption” should be a warning. The spent nuclear fuel canisters and casks should be safe or not. There should be no exemptions. Above all, there should be not be this sick game of constantly whittling away at safety standards in which Holtec and the US NRC appear to have been engaging for some time.

Without knowing that Holtec and the USNRC are constantly up to sleazy tricks it would be easy to let this pass through. The first part of the request is, after all, about Holtec updating to a more recent ASME “standard”. Thus, it also helps to know that ASME itself, based on volunteerism, can be unfortunately infested by individuals who represent corporate interests that are not necessarily in the best interest of public safety. The US NRC and Holtec also mix, match and abuse ASME standards. For instance, this alloy may not have been meant for nuclear uses. In fact, it seems to be a non-nuclear generic standard. Since ASME – despite being voluntary – refuses to make its standards available to the public for free, it is difficult to watchdog.

According to the document on file at the US NRC, the standard currently used for the Holtec spent fuel casks is in the 1.20 to 1.30% range for Manganese, as part of the metal alloy. The new “standard” allows up to 1.50 or 1.60% Manganese. But, what happens at about 1.5% Manganese? Apparently, the steel becomes brittle and continues to do so until 4-5% manganese. On the other hand, much higher amounts, as discussed below can improve the product quality. The material composition must be just right! And, it must be appropriate for nuclear uses, which may be a totally different composition. The requirements of prevalent high-burnup fuel must be considered, as well. The only thing we can know for certain is that neither Holtec, nor the US NRC can be entrusted with public safety: “Pursuant to 10 CFR 72.7, Holtec International requests an exemption from the requirements of 10 CFR 72.212(a)(2) and 10 CFR 72.214 for the HI-STORM 100 System Certificate of Compliance (72-1014)… In ASME Code editions 2007 and 2010, the material specification was updated to include an allowance for increased manganese…” What is this increase to? “B. For each reduction of 0.01 percentage point below the specified maximum for carbon, an increase of 0.06 percentage point above the specified maximum for manganese is permitted, up to a maximum of 1.50% by heat analysis and 1.60% by product analysis.http://pbadupws.nrc.gov/docs/ML1435/ML14352A384.pdf

It is worth recalling that while Germany is keeping its spent fuel in above ground bunker-like facilities and the UK appears to keep it in a sort of aluminum shed, the USA is leaving these spent fuel casks out on gravel or concrete “pads”, i.e. parking lots. Thus, the quality, or lack there of, is even more important. Despite claims to the contrary, a crash upon the facility by an airplane will clearly seriously damage them, and probably pulverize them, releasing lethal levels of ionizing radiation. But, brittleness can be a problem simply with temperature changes or small impacts. The temperature of the metal would not change at the same rate as the concrete, increasing problems. Additionally the transport cover, HI-TRAC TRANSFER CASK, is apparently metal and thus the issue of brittleness is important in case it is dropped, knocked over, or in an accident. Furthermore, their supposed safety-related tests were, by definition, on an earlier metal mixture. This invalidates any testing.
Dry Casks Indian Point Nuclear
Holtec Spent Fuel Casks at Indian Point Nuclear near New York City
Holtec Diablo casks Dec. 2006
Holtec Spent Fuel Casks sitting out at Diablo Canyon
Germany keeps its Spent Nuclear Fuel like this for now:
Ahaus Temporary Storage Facility
Ahaus Temporary Storage Facility

It is very hard to imagine why Holtec would want to make this change, since Manganese is probably more costly. It would seem to be in keeping with the theme of Holtec apparently trying to speed production by using faster, easier methods (e.g. welding) and avoiding quality assurance-testing. They clearly want to spit out their overpriced nuclear “garbage cans” as fast as possible: “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.” The late Mr. Shirani was an advocate of nuclear safety. He further remarked: “Welding flaws are contributing to the already existing design flaws discovered at Holtec manufacturing processes and QA program.http://pbadupws.nrc.gov/docs/ML0631/ML063120249.pdf

If they were nuclear garbage cans when he complained ca 2000 then what are they now that safety has been so constantly whittled away? While one can guess that it’s because they don’t want to be attentive to metal composition, only Kris Pal (“K.P”) Singh, perhaps some workers, and God know the inner machinations of Kris Pal Singh’s not so little head.

The behavior of Manganese Alloy (Mangalloy) quickly reminds one of the story of Goldilocks. The mix of materials must be “just right”. And, it must be right for nuclear uses: “The Goldilocks principle is derived from a children’s story “The Three Bears” in which a little girl named Goldilocks finds a house owned by three bears. Each bear has its own preference of food and beds. After testing all three examples of both items, Goldilocks determines that … one is “just right“. https://en.wikipedia.org/wiki/Goldilocks_principle https://en.wikipedia.org/wiki/Goldilocks_and_the_Three_Bears

Most steels contain 0.15 to 0.8% manganese. High strength alloys often contain 1 to 1.8% manganese.[3][4][5] At about 1.5% manganese content, the steel becomes brittle, and this trait increases until about 4 to 5% manganese content is reached. At this point, the steel will pulverize at the strike of a hammer. Further increase in the manganese content will increase both hardness and ductility. At around 10% manganese content the steel will remain in its austenite form at room temperature if cooled correctly.[6] Both hardness and ductility reach their highest points around 12%, depending on other alloying agents.[1]… Alloys with manganese contents ranging from 12 to 30% are able to resist the brittle effects of cold, sometimes to temperatures in the range of −196 °F (−127 °C).[8][9]https://en.wikipedia.org/wiki/Mangalloy (Emphasis our own).

There are some other exemption requests included, which we will try to add either here or in a new post. While it is increasingly clear that the US NRC will ignore public concerns, even as it is currently ignoring the concerns of seven of its own engineers who have filed a complaint re nuclear reactor safety, and even as it ignored Oscar Shirani, it is important to write to at least tell them that whittling away of public safety is unacceptable The deadline is near US tax day, but you don’t have to write much.

ML14352A384 – One of the documents associated with his request:
Holtec ML14352A384 Manganese Alloy p. 1
Holtec ML14352A384 Manganese Alloy p. 2
Holtec ML14352A384 Manganese Alloy p. 3
Holtec ML14352A384 Manganese Alloy p. 1, p. 4

The Three Bears story: http://www.gutenberg.org/files/17034/17034-h/17034-h.htm