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Comment on this: “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” Here: https://www.regulations.gov/#!documentDetail;D=NRC-2015-0270-0002

Holtec is up to its 10th Amendment for its Certificate of “Compliance” for its Spent Nuclear Fuel System, for Lethal High Level Nuclear Waste. If the last few Amendments are indicative, each Amendment has been characterized by at least one Revision, and each Amendment and Revision has multiple exemption requests. Thus, Holtec may be as high as 100 exemptions or higher already. If not, they are well on their way. In short, these are Certificates of noncompliance.

Why do they need “exemptions”? It means that either they are whittling away at safety, or that the spent fuel casks weren’t safe in the first place, or both. Occasionally it may really be a clarification, though that classification has been used as a cover story for changes which could impact safety. The part of these things protecting the public and environment from radiation is only 1/2 inch thick. Radiation resistance and corrosion are clearly issues. The casks are huge with small vents (see arrows in photo for vents; size compared to people). Any failures to the external covers could, for instance, lead to puncture and release of massive amounts of radiation. Failures to the inside basket could puncture the flimsy 1/2 inch canister. Changes in the basket composition could lead to a criticality accident. These standards matter.

These casks appear in violation of US law, for there is no redundant sealing, only a 1/2 inch MPC canister protecting the public and environment from massive levels of radiation. The outer cover has small vents.

The US law says: “The spent fuel storage cask must be designed to provide redundant sealing of confinement systems.
(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#a
Holtec vents People Diablo NRC gov
This US gov photo of Holtec Casks at Diablo Canyon was lightened to see the vents better and arrows added. It’s difficult to imagine that these vents provide adequate heat removal capacity, especially sitting out in the sun and on concrete.

If the Holtec Spent Fuel Casks were considered by experts as comparable to garbage cans in 2000, what are they comparable to in 2016, after a laundry list of exemptions, which may impact safety? The late Oscar Shirani wrote in 2006: “I am Oscar Shirani, a Nuclear Whistle Blower against Exelon and against NRC’s negligence to resolve my technical issues. / I had exposed the NRC’s meaningless audits in many of my audit reports and specifically in 1997 against GE and 2000 against Holtec International…. Regarding Shirani’s August 4, 2000 Nuclear Audit Report of Holtec International Spent Fuel Dry Cask Storage issues: How did NRC substantiate my allegations against Holtec and made such a conclusion that issues were resolved only by paper work? Welding flaws are contributing to the already existing design flaws discovered at Holtec manufacturing processes and QA program. My allegation revealed that Holtec QA Program were not and still are not in compliance with the codes of federal regulations and the NRC’s accepted standards. My repeated audits and Tony Frazier’s Quality Control Inspections revealed the loss of design change control process for 100s of nonconforming conditions that were dispositioned by Holtec as Use-As-Is and Repair without any design change control processes as required by 10CFR50 App. B and ASME NQA-1 Supp. 3-S. The loss of design control process was coupled with many welding flaws discovered by Tony Frazier. Subsequently, Tony also was terminated by Exelon one month after this audit. I was transferred out of nuclear department by Exelon’s CFO, Ruth Ann GIllis 7 days after I told Dr. Landsman about the dry cask issues in front of 100 utility members.

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.” http://pbadupws.nrc.gov/docs/ML0631/ML063120249.pdf

If they were nuclear garbage cans when he complained ca 2000 then what are they now, after further whittling away of quality, testing, QA?

Rather deceptively, the USNRC doesn’t list the revisions, only the many Amendments:
Certificate Number: 1014.
Initial Certificate Effective Date: May 31, 2000.
Amendment Number 1 Effective Date: July 15, 2002.
Amendment Number 2 Effective Date: June 7, 2005.
Amendment Number 3 Effective Date: May 29, 2007.
Amendment Number 4 Effective Date: January 8, 2008.
Amendment Number 5 Effective Date: July 14, 2008.
Amendment Number 6 Effective Date: August 17, 2009.
Amendment Number 7 Effective Date: December 28, 2009.
Amendment Number 8 Effective Date: May 2, 2012, as corrected on November 16, 2012 (ADAMS Accession No. ML12213A170).
Amendment Number 9 Effective Date: March 11, 2014.
Amendment Number 10 Effective Date: May 31, 2016.
SAR Submitted by: Holtec International.
SAR Title: Final Safety Analysis Report for the HI-STORM 100 Cask System.
Docket Number: 72-1014.
Certificate Expiration Date: May 31, 2020.
Model Number: HI-STORM 100.

https://www.regulations.gov/#!documentDetail;D=NRC-2015-0270-0002

Some summary info on the Amendment in red which may help clarify: http://pbadupws.nrc.gov/docs/ML1500/ML15007A435.pdf

A few documents to quickly show some of the Amendments plus revisions. The Amendment is Revision 0. One Can Expect Amendment 10 Revision 1 Soon:

Holtec Amendment 8 Revision 1 Federal Register
http://docs.regulations.justia.com/entries/2015-08-18/2015-20141.pdf
Holtec International – HI-STORM 100 CoC 72-1014 Amendment 8, Revision 1.
Jun 19, 2015 – HI-STORM 100 CoC 72-1014 Amendment 8 Revision 1. Reference: [1] Federal Register Docket ID: …
http://pbadupws.nrc.gov/docs/ML1517/ML15170A438.pdf
Ltr K Manzione, Holtec Int’l, Certificate of Compliance No. 1014, Amendment No. 9, Revision No. 1 for the HI-STORM 100 …
Mar 21, 2016 – 9 supersedes CoC No. 1014, Amendment No. 9. The NRC requests that Holtec provide. Revision No.
ML15240A236 – Holtec International – Submittal of HI-STORM 100 CoC 72-1014 Amendment 9, Revision 1.
http://pbadupws.nrc.gov/docs/ML1524/ML15240A236.pdf
Aug 28, 2015 – HI-STORM 100 CoC 72-1014 Amendment 9 Revision 1. Reference: “Holtec International HI-STORM …
Federal Register | List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System; Amendment No. 9, Revision 1
https://www.federalregister.gov › articles
Jan 6, 2016 – 9, Revision 1, to CoC No. 1014 and does not include other aspects of the Holtec HI-STORM 100 Cask  List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System https://www.federalregister.gov/articles/2016/01/06/2015-33280/list-of-approved-spent-fuel-storage-casks-holtec-international-hi-storm-100-cask-system-amendment-no
9, Revision 1, to Certificate of Compliance (CoC) No. 1014. Amendment No. 9, Revision 1, changes cooling time limits . https://www.gpo.gov/fdsys/pkg/FR-2016-01-06/html/2015-33279.ht
Federal Register, Volume 81 Issue 51 (Wednesday, March 16, 2016) – US Government Publishing Office Mar 16, 2016 – 8, for the Holtec HI-STORM 100 with the MPC-68M, to the extent necessary for EGC … Amendment 8 also made other administrative changes. ….. CoC 1014 Amendment 8, Revision 1.
Federal Register, Volume 81 Issue 3 (Wednesday, January 6, 2016) – GPO
https://www.gpo.gov › fdsys › pkg › html
Jan 6, 2016 – 9, Revision 1, to CoC No. 1014 and does not include other aspects of the Holtec HI-STORM 100 Cask …
https://www.gpo.gov/fdsys/pkg/FR-2016-01-06/html/2015-33279.htm