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Comment By Jul 30 2018, at 11:59 PM ET, ID: NRC-2018-0052-0058 on Holtec’s proposed spent nuclear fuel facility in New Mexico: https://www.regulations.gov/docket?D=NRC-2018-0052 Documents here:
https://www.nrc.gov/waste/spent-fuel-storage/cis/hi/hi-app-docs.html See too: https://miningawareness.wordpress.com/2018/07/26/facts-on-how-holtec-spent-nuclear-fuel-canisters-are-substandard-and-should-not-be-used-parked-or-buried-anywhere-comment-by-july-30th-1159-pm-et/

Welded shut Holtec (and Areva) spent nuclear fuel canisters stand in stark contrast to the much thicker German CASTOR. In the CASTOR a “pressure sensor continuously measures pressure in the gap between the primary and secondary lid“, and the “system is wired to [the] Main Dosimetry Control Room“. There is a temperature sensor for continuous surface temperature monitoring, too. See “Operational Experience of Castor 440/84 Casks in Dukovany NPP” by Stanislav Kuba, 14th International Symposium on the Packaging and Paper # 022 Transportation of Radioactive Materials (PATRAM 2004), Berlin, Germany, September 20-24, 2004. http://www.iaea.org/inis/collection/NCLCollectionStore/_Public/37/088/37088667.pdf

The Holtec HI-STORM CIS (Consolidated Interim Storage) System has major design flaws.

Holtec proposes transporting aging thin-wall stainless steel canisters across the country and double stacking them in concrete steel lined holes. This is an experimental and unproven below ground system that has not been approved by the Nuclear Regulatory Commission (NRC).

Each thin-wall canister contains about as much highly radioactive Cesium-137 as was released from the Chernobyl nuclear disaster. There is no adequate plan to safely transport or store these “Chernobyl” cans.

Holtec President Dr. Kris Singh admits canisters cannot be inspected or repaired and states even a microscopic through-wall crack will release millions of curies of radionuclides into the environment….” See the rest further below and at link: https://sanonofresafety.files.wordpress.com/2015/10/designedtoleakholtec-cis-2017-06-24.pdf

In the Holtec HI-STORE CIS drawing, “Holtec does not show the air vents in the lids (required for convection cooling of the fuel waste), giving the illusion of total burial of the fuel waste cans.  However, a through-wall crack in the thin-wall canisters will result in radioactive gases escaping into the environment.  Flooding, small critters and debris can enter through those air vents, yet there are no drains in the holes. What could possibly go wrong?

The Nuclear Regulatory Commission (NRC) has not approved the Holtec CIS system or the proposed New Mexico CIS facility, but has accepted Holtec’s application:  NRC Letter to K. Manzione re: Holtec International’s Application for Specific Independent Spent Fuel Storage Installation [ISFSI] License for the HI-STORE Consolidated Interim Storage [CIS] Facility for Spent Nuclear Fuel-Accepted for Review, February 28, 2018 (ML18059A25) https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18059A251… ” (Excerpted from: https://sanonofresafety.org/holtec-hi-storm-umax-nuclear-waste-dry-storage-system/