Is the 100 in Holtec’s Spent Nuclear Fuel HI-STORM 100 Cask a Reference to “Exemptions” to its Certificate of “Compliance” (CoC)? Comment Deadline 13 April 2016, 11.59 PM ET (one minute to the 14th)
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…
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