My email to Chairman NRC - The TRACE Mess

TO: Chairman NRC:

I am amazed that the NRC refuses to provide its public with the documents that I requested under FOIA/PA 2009-0067. I was sent very heavily sanitized reports by each of the four consultants and that is unsatisfactory. The TRACE game has been going on for over 30 years and the NRC now claims that, “Disclosure of predecisional information would tend to inhibit the open and frank exchange of ideas essential to the deliberative process.” This is highly absurd. What the NRC is inhibiting is the open and frank exchange of ideas with its public; an open and frank exchange that is essential to public understanding, participation and acceptance of nuclear power and other NRC regulated activities.

The American public has the right to expect accurate claims when the NRC labels the readiness of TRACE. NRC labeled TRACE as follows at ACRS on September 4, 2008:

TRACE IS NOW READY TO BE

FULLY INCORPORATED INTO THE NRC'S

REGULATORY FRAMEWORK

I doubt that TRACE is now ready to be fully incorporated into the NRC’s regulatory framework. In addressing my doubts, I would value the complete set of the reviewers’ reports that I requested under FOIA/PA 2009-0067.

For some time I’ve been thinking about River Bend’s performance during cycles 8 and 11. The following should not be outside of NRC’s regulatory framework and it would be a great challenge for TRACE.

The design basis for the emergency core cooling system ("ECCS") at River Bend-for clean cladding, without heavy crud and oxide layers-is described in Chapter 6.3 of the RBS USAR. It states that at the onset of a LOCA, the cladding surface temperature would be in the range of 578"F, and that the PCT would be 1580°F. However, with heavy crud and oxide layers on the cladding (the conditions of cycles 8 and 11) the ECCS design basis for River Bend is substantially non-conservative. With the heavy fouling of the fuel elements at River Bend Cycles 8 and 11, the following would have characterized a LOCA in contrast to the design basis for the emergency core cooling system.

1. Reduced coolant flow at the heavily fouled fuel prior to and during the LOCA.
2. Reduced coolant inventory in the vicinity of the heavily fouled fuel at the start of LOCA.
3. Massive oxidation of the heavily fouled fuel at the start of LOCA.
4. Extensive absorption of hydrogen and oxygen in the heavily fouled fuel at the start of LOCA.
5. Higher starting temperature of the heavily fouled fuel at the start of LOCA. {The cladding surface temperature at some locations at River Bend Cycle 8 has been reported to have reached temperatures approaching 1200°F1}.
6. Substantially greater stored energy of that fuel at the start of LOCA.

The above factors mean that:

The duration of the LOCA is substantially increased. The peak temperature is substantially increased. The time to reach peak temperature is substantially increased. The time to quench is substantially increased; indeed the NRC’s assumed quench process will not apply at the agglomeration consisting of the degraded fuel and the thick fouling. The fuel element damage is substantially increased, normal cooling paths are blocked, subsequent cooling of the fuel element is relatively ineffective and further damage of the fuel proceeds during the so-called long term cooling.

1NRC, "River Bend Station - NRC Problem Identification and Resolution Inspection Report 050045812005008," 02/28/06, Report Details, p. 10, located at: www.nrc.gov, Electronic Reading Room, ADAMS Documents, Accession Number: ML060600503.