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Comment on: “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

In “PRELIMINARY SAFETY EVALUATION REPORT, DOCKET NO. 72-1014 HOLTEC INTERNATIONAL HI-STORM 100 CASK SYSTEM CERTIFICATE OF COMPLIANCE NO. 1014 AMENDMENT NO. 10“, it says:
Additionally, the NRC staff (staff) is revising CoC Condition No. 9 to provide additional clarity and guidance. The applicant agreed with this change in correspondence dated November 20, 2015, (ADAMS Accession No. ML15327A043).http://pbadupws.nrc.gov/docs/ML1533/ML15331A309.pdf ML15331a309 http://pbadupws.nrc.gov/docs/ML1533/ML15331A318.html

What does ML15327A043 say? (See original image of it at end of this post).
WHY DOES THE US NRC REQUIRE HOLTEC CONCURRENCE?
Contrary to what is alleged, the NRC budget is part of the US budget. While the majority of the budget is supposed to be recovered as fees, the US taxpayer still pays up front and in part. The NRC could choose to do its job and charge more fines to recover their budget, rather than subsisting on fees.
From: Kimberly Manzione [mailto:K.Manzione@Holtec.com]
Sent: Friday, November 20, 2015 4:31 PM To: Goshen, John Subject: [External_Sender] RE: Final Condition 9 language
John,
Holtec concurs with the below condition.
Thanks, Kim

From: Goshen, John [mailto:John.Goshen@nrc.gov] Sent: Tuesday, November 17, 2015 3:21 PM To: Kimberly Manzione Subject: Final Condition 9 language
Kim, I believe this has the changes you recommended. I will need Holtec’s concurrence on this. Thanks, John

MEASUREMENTS ARE TO VALIDATE THE ANALYTIC METHODS?
The user shall then perform an analysis of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR.”

This is upside down and implies intent to play around with the measurements and testing method to get what they want. The measurements shouldn’t validate the methods. In this context, it implies the willingness to manipulate the measurements, if needed. This is especially true when they use the word “demonstrate”. Only in an experimental context where one was trying to prove a theory or method, with throwing it out as an alternative, would this be appropriate. This is not supposed to be experimental to prove theory or not, which would be the only case in which the measurements should validate the method or not. The method should be fixed and the measurements as required. The requirement should include heat and air-flow measurements between the inner and out cask, not only at the vents. Vents measurements must include inlet and outlet, not just inlet.
9. SPECIAL REQUIREMENTS FOR FIRST SYSTEMS IN PLACE
a. For the storage configuration, each user of a HI-STORM 100 Cask and HI-STORM 1 OOU Cask with a heat load equal to or greater than 20 kW shall perform a thermal validation test in which the user measures the total air mass flow rate through the cask system using direct measurements of air velocity in the inlet vents. The user shall then perform an analysis of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR.

It seems that they’ve also decided that only one cask should be tested, whereas the types and age of fuel may be different. Also, one cask could be defective. Testing of cooling should be ongoing for all casks, but apparently is not: “To satisfy condition 9(a) for casks of the same system type (i.e., HI-STORM 100 casks, HI-STORM 100U casks), in lieu of additional submittals pursuant to 10 CFR 72.4, users may document in their 72.212 report a previously performed test and analysis submitted by letter report to the NRC that demonstrates validation of the analytic methods described in Chapter 4 of the FSAR.

Holtec appears to have a long-standing allergy to testing and research methods.

YOU ARE WELCOME TO CALL OR WRITE HIM AND COMPLAIN:
John Goshen , P.E. Project Manager NMSS/DSFM/SFLB Ph (301 ) 415-6933 Cell (202) 557-6818″
His e-mail is here: John.Goshen@nrc.gov
His title: “John Goshen, Office of Nuclear Material Safety and Safeguards, telephone: 301-415-6933, email: John.Goshen@nrc.gov; U.S. Nuclear Regulatory Commission, Washington, DC 20555.

Goshen or Gotham?
ML15327A043 NRC (John Goshen) needs Holtec Approval