2016 - 03 - 25 San Luis Obispo Mothers for Peace comments on NRC draft rule related to transportation of radioactive wastes.

Docket ID NRC-2015-0234 NUREG/CR-7209 COMMENTS ON: A Compendium of Spent Fuel Transportation Package Response Analyses to Severe Fire Accident Scenarios, DRAFT San Luis Obispo Mothers for Peace (SLOMFP) wishes to provide the following comments to the NRC’s draft report in the matter of spent fuel transportation safety. SLOMFP is the legal intervenor in matters pertaining to safety at the Diablo Canyon nuclear power plant in Avila Beach, CA.


With over six million pounds of highly radioactive waste stored on a fragile, earthquake-prone coastline, SLOMFP has great interest in its ultimate disposition at some time in the future. Given the location of Diablo Canyon, highly radioactive waste can only be moved by roadway or barge. The issue of fires on barges has not been addressed in NUREG/CR-7209, which is a grave omission.

The proposed NUREG/CR-7209 paints a rosy picture of the safety of transporting high-level radioactive waste on the highways and railways of our country. It proposes transporting HOLTEC HI-STAR 100 SNF canisters on specially designed railroad cars.

The report makes false assumptions. It makes no provision for moving the SNF from existing thin-walled stainless steel canisters (1/2” to 5/8” thick) that cannot be inspected, repaired, maintained, have no early warning system prior to a radiation leak, can corrode and crack, and can start leaking millions of curies of radiation after 20 years of storage, possibly sooner, into the transport cask.

A 2015 Sandia Lab report shows that once cracks start in hotter thin- walled stainless steel canisters, they can grow through the wall of the canister in less than 5 years A failure of even one of these

“Chernobyl” canisters could be catastrophic. There is potential for explosions, due to the unstable and pyrophoric nature of these materials when exposed to air. (Damaged Spent Nuclear Fuel at U.S. DOE Facilities, Experience and Lessons Learned, INL, Nov 2005 INL/EXT-05-00760, Page 4 & 5). https://inldigitallibrary.inl.gov/sti/3396549.pdf

NRC regulations do not allow the transportation of canisters with even partial cracks (10 CFR § 71.85 Packaging and Transportation of Radioactive Materials). Neither the outside or inside structure of
these thin-walled welded canisters can be inspected, let alone repaired. Other countries use thick-walled casks that do not have these problems.

NRC has chosen to continue endorsing the inferior technology even though NRC Commissioners directed staff to “encourage the adoption of state of the art technology for storage and transportation”. Staff Requirements – COMDEK-09-0001 – Revisiting the Paradigm for Spent Fuel Storage and Transportation Regulatory Programs, February 18, 2010 http://pbadupws.nrc.gov/docs/ML1004/ML100491511.pdf

Canisters may need to stay on-site for up to 45 years before they are cool enough to meet Department of Transportation radiation dose requirements.

Thin-walled stainless steel U.S. irradiated spent fuel storage canisters at higher temperatures will have faster crack growth rate. A Sandia Lab chart shows higher temperatures can cause canisters to penetrate the wall in less than 5 years. This chart assumes canister wall is 0.625” (5/8”) thick. The majority of the U.S. canisters are only 0.50” (1/2”) thick. It is unknown when a crack will start, but these canisters are subject to corrosion and cracking from environmental conditions such as chloride salts, air pollution (sulfides), pitting, and microscopic scratches. The report states that canisters such as those at Diablo Canyon have temperatures in these heat ranges. Draft Geologic Disposal Requirements Basis for STAD Specification, A. Ilgen, C. Bryan, and E. Hardin, Sandia National Laboratories, March 25, 2015, FCRD-NFST-2013-000723 SAND2015- 2175R, PDF Page 46 http://prod.sandia.gov/techlib/access-control.cgi/2015/152175r.pdf The only NRC approved high burnup transport cask is the NUHOMS MP197HB. NUREG/CR-7209 postulates that highly radioactive spent fuel rods will be transported using the HOLTEC HI STAR 100, which is not approved for high burnup fuel transport. Most irradiated spent fuel stored onsite at nuclear facilities can be classified as high burnup.

Canisters with 37 spent fuel assemblies may require up to 45 years to cool (after removal from the reactor) before they are safe enough to transport (~20 kW) per Dept. of Transportation radiation limits. Research and Development Activities Related to the Direct Disposal of Dual Purpose Canisters, William Boyle, Director, Office of Used Nuclear Fuel Disposition R&D (NE-53), U.S. Department of Energy, Nuclear Waste Technical Review Board Meeting, April 16,2013 http://www.nwtrb.gov/meetings/2013/april/boyle.pdf Safety Evaluation Report Docket No. 71-9302, NUHOMS-MP197HB, Certificate of Compliance No. 9302, Rev. 7, Page 14 http://pbadupws.nrc.gov/docs/ML1411/ML14114A132.pdf

NRC has once again failed to address the core problem involving transportation of highly radioactive used fuel rods. The thin-walled canisters storing the fuel rods are inadequate. In order to transport the canisters, the fuel rods will have to be transferred to a transport cask; however, the fragile, 1⁄2”thick canisters may likely be leaking radiation at the time of transfer, making transfer itself a potentially lethal undertaking.

Proposed NUREG/CR-7209 states that there has never been an incidence of Class B radioactive waste being mishandled during a shipment. NRC incident report from March 16, 2016 states, “"The Agency [Texas Department of State Health Services] was notified by a manager for a common carrier of radioactive material that a package had fallen out of the transport vehicle. The package was found by a member of the public on a highway [when he] swerved to miss hitting the package. The person collected the package and called the number on the package. The number was to the manufacturer of the source. The radiation safety officer (RSO) for the company met the member of the public to collect the package. The RSO completed a survey of the package and performed leak testing. The container was a type B package containing two Ir-192 sources, SN29629G and 29630G, joint activity of 8,188.8Gbq (>100 curies each) with transport index of 1.2. The package outer shipping box was damaged although the type B container was in good condition and was not leaking. The sources are currently at the manufacturer's location in storage. The sources were enroute to the manufacturer's Baton Rouge location when the container fell out of the transport vehicle onto the freeway. The details of the time frame the member of the public had the package in their possession is being confirmed and details of the time the package was on the freeway is being acquired. Investigation into this event is ongoing and details will be provided in accordance with SA 300 guidelines."

The potential for terrorism with regard to transportation of highly radioactive nuclear fuel is terrifying to most people. With the rise in international terrorism, the targeting of nuclear power plants by ISIL, the oversized, slow-moving raillway cars transporting nuclear waste might as well have bullseyes painted on them.

Highly radioactive spent fuel rods should not be moved more than once. There is no permanent repository for the waste now; Congress has yet to even designate a proper, safe location. To move the lethal waste not once, but TWICE, in order to continue to produce nuclear power, is unconscionable.

As more nuclear facilities shut down, the NRC will be pressured by the utility industry to permit lethal waste to be moved across the country. San Luis Obispo Mothers for Peace urges you to step back, update your studies rather than relying on data that does not take into account moving high burnup fuel, and cease your efforts to locate interim storage sites. Focus on identifying a permanent repository for the long-term.