Bob Leyse Submitted the following to ACRS as noted. This is not a part of the attachments to the transcript of that meeting, however, it is in ADAMS, ML102530135.
ACRS Subcommittee on Plant License Renewal September 8, 2010, Room T–2B1, 11545 Rockville Pike, Rockville, Maryland. (Palo Verde)
Facts for the Subcommittee and for the record:
1. On May 23, 2007 Bonaca wrote Kline, SUBJECT: PROPOSED TECHNICAL BASIS FOR THE REVISION TO 10 CFR 50.46 LOCA EMBRITTLEMENT CRITERIA FOR FUEL CLADDING MATERIALS, ML071490090. Bonaca wrote, “The requirements of 10 CFR 50.46 (a) and (b) limit the amount of embrittlement that may occur as result of a design basis accident. They specify limits for the peak clad temperature, the global oxidation of cladding, and the local oxidation of cladding. There are several deficiencies with the current regulations. The correlation specified for the rates of steam reaction with the cladding is viewed by the technical community as an anachronism.” Now, Appendix K to Part 50--ECCS Evaluation Models, Item 5, specifies that the rate of energy release from the metal/water reaction shall be calculated using the Baker-Just equation and § 50.46 Acceptance Criteria, item (b)(1) specifies the peak clad temperature, 2200 degrees.
2. The NRC staff fiercely defends Baker-Just in its Technical Safety Analysis, ML041210109, April 29, 2004, “The Baker-Just correlation using the current range of parameter inputs is conservative and adequate to assess Appendix K ECCS performance. Virtually every data set published since the Baker-Just correlation was developed has clearly demonstrated the conservatism of the correlation above 1800°F.”
3. The nuclear power industry fiercely defends Baker- Just in its Industry Comments, ML101040678, April 12, 2010, “The Baker-Just correlation, using the current range of parameter inputs, has been shown to be conservative and adequate to assess Appendix K ECCS performance. Data published since the Baker-Just correlation was developed has clearly demonstrated the conservatism of the correlation above 1800°F”
4. Contrary to the exceptionally firm consistency between the NEI and NRC appraisals of Baker-Just, the pertinent data sets published since the Baker-Just correlation was developed have clearly demonstrated the non-conservatism of the Baker-Just correlation above 1800°F. The NRC has not recognized that investigations that involve heating of single specimens of zirconium alloys in steam do not yield applicable data for the temperature or range of temperatures at which thermal runaway is initiated in LWRs.
5. NRC has apparently never studied Baker-Just (ML050550198) and until April 2010 it did not even have copies of the key references. Figure 16 is copied from page 37 of the Baker-Just report ML050550198.
Note to reader: Go to ML050550198, page 37 to view the Figure 16. This blog does not copy that.
Only the Lemmon data includes the pertinent temperature region. The Lemmon report, ML100570218, was not acquired by NRC until April, 2010. Thus, NRC never studied Baker-Just. Figure C-1 is from Lemmon page C-4; the adjacent figure is excerpted from the flow sheet, Figure C-3 on page C-5.
Another note to reader: Go to ML100570218, pages C-4 and C-5 to view
Figures C-1 and C-5.
Lemmon induction heated a zircaloy-2 cylinder, 2” long by 0.5” dia. in steam.
6. It is absurd to license the emergency cooling of tons of zirconium alloy having thousands of square feet of interfacial surface area based on the limited investigations that yielded the Baker-Just equation. Despite this, Appendix K to Part 50--ECCS Evaluation Models, Item 5, specifies that the rate of energy release from the metal/water reaction shall be calculated using the Baker-Just equation and § 50.46 Acceptance Criteria, item (b)(1) specifies the 2200 degrees.
7. Data from multi-rod (assembly) severe fuel damage experiments (e.g., the LOFT LP-FP-2 experiment) show the Baker-Just equation is non-conservative for calculating the temperature at which thermal runaway would occur in the event of a LOCA.
8. Investigations by P. Hofmann et al. at Forschungszentrum Karlsruhe reveal that the Baker-Just equation is non-conservative for calculating the temperature at which thermal runaway will occur in a LOCA. Their report is, Physico-Chemical Behavior of Zircaloy Fuel Rod Cladding Tubes During LWR Severe Accident Reflood, Part I: Experimental results of single rod quench experiments, FZKA 5846, http://bibliothek.fzk.de/zb/berichte/FZKA5846.pdf
On page 5 of 177: A series of separate-effects tests is being carried out on Zircaloy PWR fuel rod cladding to study the enhanced oxidation which can occur on quenching. In these tests, performed in the QUENCH rig, single tube specimens are heated by induction to a high temperature and then quenched by water or rapidly cooled down by steam injection.
On gage 12 of 177: No significant temperature excursion during quenching occurred such as had been observed for example in the quenched (flooded) CORA-bundle tests This absence of any temperature escalation is believed to be due to the high radiative heat losses in the QUENCH rig.
And in, “CORA Experiments on the Materials Behavior of LWR Fuel Rod Bundles at High Temperatures,” NUREG/CP-0119, Vol. 2, Proceedings of the Nineteenth Water Reactor Safety Information Meeting. ML042230460, P. Hofmann et al.
On page 98 of 493: The critical temperature above which uncontrolled temperature escalation takes place due to the exothermic zirconium/steam reaction crucially depends on the heat loss from the bundle; i.e., on bundle insulation. With the good bundle insulation in the CORA test facility, temperature escalation starts between 1100 and 1200°C (2012 to 2192°F), giving rise to a maximum heating rate of 15 K/sec.
9. It is amazing that the ACRS has never reviewed Baker-Just in the course of producing its recommendations regarding the initial licensing, the extended licensing and the licensing of power level increases of numerous American light water reactors.
Final note to reader: The following is copied from the from the FSAR for the Palo Verde Units, and this reveals the basis for licensing the ECCS at the Palo Verde units.
Palo Verde, Units 1, 2 and 3 - Updated Final Safety Analysis Report, Revision 14.
ML072250202
2007-06-30
PVNGS UPDATED FSAR
EMERGENCY CORE COOLING SYSTEM
June 2007 6.3-76 Revision 14
6.3.3 PERFORMANCE EVALUATION
6.3.3.1 Introduction and Summary
10 CFR 50.46 provides acceptance criteria for Emergency Core
Cooling Systems (ECCS) for light-water nuclear power reactors
[Reference 1]. The ECCS performance analyses described in this
section demonstrate that the PVNGS ECCS design satisfies these
criteria.
The PVNGS ECCS performance analyses encompass a wide range of
Reactor Coolant System (RCS) break locations and sizes, including
both large and small break Loss-of-Coolant Accident (LOCAs). The
limiting break, which results in the closest approach to 10 CFR
50.46 acceptance criterion for peak clad temperature, is a 0.6
DEG/PD (Double-Ended Guillotine in the Reactor Coolant Pump
Discharge leg) as noted in UFSAR Section 6.3.3.2. The limiting
break, which results in the closest approach to 10 CFR 50.46
acceptance criterion maximum clad oxidation (or local clad
oxidation), is a 0.8 DEG/PD as noted in UFSAR Section 6.3.3.2.
For these limiting breaks, the PVNGS ECCS design meets the
acceptance criteria of 10 CFR 50.46 as follows:
Criterion 1: Peak Cladding Temperature. ". . .The
calculated maximum fuel element cladding
temperature shall not exceed 2200 degrees F. . . ."
For the limiting break, the PVNGS ECCS
performance analysis yielded a peak cladding
temperature of 2110 degrees F.
PVNGS UPDATED FSAR
EMERGENCY CORE COOLING SYSTEM
June 2007 6.3-130 Revision 14
6.3.6 REFERENCES
1. Code of Federal Regulations, Title 10, Part 50,
Section 50.46, "Acceptance Criteria for Emergency Core
Cooling Systems for Light Water Nuclear Power Reactors."
Sunday, December 5, 2010
PRM-50-93 and PRM-50-95 at Full ACRS, December 2, 1010
Presentation to Full ACRS December 2, 2010
I’m Bob Leyse. This presentation is directed to two PRMs that were originated by Mark Leyse. These are PRM-50-93 and PRM-50-95, and today I am standing in for Mark. I’ll move through the 6 page handout in the allotted 5 minutes.
Moving to page 1 of the handout,
NRC should not authorize Plant License Renewals or Power Uprates prior to its resolution of PRM-50-93 and PRM-50-95.
The 2200 degree Fahrenheit PCT limit is too high. The 2200 PCT limit is based on embitterment criteria. The Baker-Just equation was placed into 50.46 and it has been convenient in licensing. Its current use in 50.46 is fiercely defended by the NRC.
Not in the handout, is an incorrect remark by Bajorek at the joint meeting of three ACRS subcommittees on May 31, 2002. “Note by the way Baker-Just in some of the earlier data was based on zirconium data only.” In fact, Baker-Just is very predominantly based on experiments with Zircaloy-2 at Bettis and Battelle. NRC did not even have those references until I appealed to the OGC and then the documents were acquired and placed in ADAMS. The reports are:
WAPD-104 ADAMS Accession No. ML100900446
BMI-1154 ADAMS Accession No. ML100570218
Go to page 2:
At another point in that joint meeting of the three ACRS subcommittees on May 31, 2002, we hear from
MEMBER WALLIS: 2200 has a very iffy
basis. The only justification really is that it is
worked over 30 or 40 years.
However, Member Wallis is wrong. There is nothing iffy about 2200. Very clearly, 2200 is too high and there is nothing iffy about that. Perhaps the most impressive evidence comes from experiment LOFT LP-FP-2 where thermal runaway of the fuel bundle was initiated in the 2060 to 2240 degree Fahrenheit range. And, the series of CORA experiments at Karlsruhe yielded thermal runaway over a range from about 1800 to 2200 degrees Fahrenheit. The CORA experiments used bundles of electrically heated rods having Zirconium alloy cladding and uranium dioxide fuel pellets.
On page 3 of the handout, note that Mark Leyse and Robert Leyse jointly made a 10 minute presentation to the ACRS Thermal Hydraulics Phenomena Subcommittee on Monday, October 18, 2010. Close to the end of the meeting the subcommittee briefly discussed the matter.
To save time, please skip to page 6,
Discussing the review of PRM-50-93 and PRM-50-95, at the October 18 meeting we hear from
MEMBER ABDEL-KHALIK: "And I think from the committee's perspective, we await the staff's evaluation and we will review the staff's evaluation."
Now, one primary mandate of the ACRS is; “to initiate reviews of specific generic matters or nuclear facility safety-related items.” In line with that mandate, I believe that ACRS should evaluate PRM-50-93 and PRM-50-95 in parallel and likely in advance of the NRC’s technical evaluations.
For emphasis I am repeating from page 1: NRC should not authorize Plant License Renewals or Power Uprates prior to its resolution of PRM-50-93 and PRM-50-95.
Thank you.
Handout for Bob Leyse Presentation to Full ACRS, 6 pages, December 2, 2010
Note: This handout to the Full ACRS is a copy of a comment that was submitted to the NRC by Bob Leyse regarding Mark Leyse Petitions for Rulemaking PRM-50-93 and PRM-50-95.
November 26, 2010
Annette L. Vietti-Cook
Secretary
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
Attention: Rulemakings and Adjudications Staff
COMMENTS ON PRM-50-93 AND PRM-50-95; NRC-2009-0554
NRC should not authorize Plant License Renewals or Power Uprates prior to its resolution of PRM-50-93 and PRM-50-95.
The 2200 degree Fahrenheit PCT limit is too high. The 2200 PCT limit is based on embitterment criteria. The Baker-Just equation was placed into 50.46 and it has been convenient in licensing. Its current use is fiercely defended by the NRC.
According to analyses funded by NRC, when the Baker-Just correlation is applied, the predicted thermal runaway starts at 2600 degrees Fahrenheit, while the alternative Cathcart-Pawel correlation of Reg. Guide 1.157 yields runaway at 2700. This is detailed on page 28 of PRM-50-93.
At a joint meeting of three ACRS subcommittees on May 31, 2002, there is the following pertinent exchange:
MR. LAUBEN: That's it. Sure. No.
That's an easy and quantifiable way to compare it. It
just gives you a minimum measure because what's really
true because of the slope changes so much is that you
can see a much bigger difference. In general I would
say I could never achieve turn-around much above 2300
in the limited 100 calculations I did with Baker-Just
but I could reach something as close to 2800 with
Cathcart-Pawel. Now that's –
MEMBER WALLIS: Maybe you need to show
these calculations. Something more convincing than
what we heard today --
At another point in that joint meeting of three ACRS subcommittees on May 31, 2002:
MEMBER WALLIS: 2200 has a very iffy
basis. The only justification really is that it is
worked over 30 or 40 years. If you are going to
change it you're going to have to have some really
good arguments.
However, Member Wallis is wrong. There is nothing “iffy” about 2200. At Karlsruhe it had already been clearly demonstrated that 2200 is too high and there is nothing “iffy” about the fact that 2200 is too high. An array of experiments having multirod assembles of rods with zirconium alloy cladding reveal that thermal runaway begins well below the 2600 to 2700 range. Perhaps the most impressive is LOFT LP-FP-2 where thermal runaway of the fuel bundle was initiated in the 2060 to 2240 degree Fahrenheit range. And, the series of CORA experiments at Karlsruhe with bundled electrically heated rods having Zirconium alloy cladding and uranium fuel pellets, yielded thermal runaway over a range from about 1800 to 2200 degrees Fahrenheit.
Although PRM-50-93 is dated November 2009, there is little evidence that the NRC has pursued its evaluation. On April 26, 2010, NRR issued a USER NEED REQUEST FOR TECHNICAL ANALYSIS OF PETITION FOR RULEMAKING ON 10 CFR 50.46 (PRM-50-93) and at that time the activity was (finally) assigned a high priority. Quoting from the User Need Request, "The requested deliverable for this user need is a technical letter report. Your office provided an outstanding technical analysis [reference 2] of a similar rulemaking petition, and we request the final deliverable for this user need be in this same format. We also request that a draft of your report be provided for comment by August 31, 2010 and the final report by September 30, 2010. We will provide comments on the draft within one week of receipt."
However: On October 27, 2010, the NRC published for public comment a notice of consolidation of petitions for rulemaking. The PRMs to be consolidated are PRM-50-93 filed by Mark Edward Leyse on November 17, 2009, and PRM-50-95 filed on June 7, 2010, by Mark Edward Leyse and Raymond Shadis, on behalf of the New England Coalition. What Mark Leyse filed on June 7, 2010 was not a PRM, it was a 2.206 petition. It appears that by consolidating these actions by Mark Leyse, the NRC has substantially extended the deadline for producing a Technical Letter Report regarding PRM-50-93. Nevertheless, the priority is established by the technical facts that are in the record and high priority attention by the NRC reviewers remains warranted.
In fact, Mark Edward Leyse first learned about the extended deadline when the ACRS Thermal Hydraulics Phenomena Subcommittee briefly discussed the matter on Monday, October 18, 2010. Mark Leyse and Robert Leyse had jointly made a 10 minute presentation, and at the end of the meeting the subcommittee discussed the matter as follows:
CONSULTANT KRESS: I found it very unusual
17 that public comments are made to the subcommittee.
18 Those usually go to the full committee. I don't know
19 what your obligation is with respect to those.
20 CHAIR BANERJEE: I think to report it to
21 the full committee and ask if –
22 CONSULTANT KRESS: Just report it to the
23 full committee.
24 CHAIR BANERJEE: ask if they wish it to be
25 made to the full committee. I don't think that we can
act on it.
2 CONSULTANT KRESS: No. That was my point.
3 It has to be acted by the full committee.
4 CONSULTANT WALLIS: But if you want a
5 comment, it looked as if there could be a significant
6 point here, I mean it's something that is not trivial
7 to look at and see is there a question here and what's
8 the evidence for –
9 CHAIR BANERJEE: Has the comments been made
10 to the staff or is it just to the subcommittee?
11 MR. BAJOREK: This is Steve Bajorek.
12 Actually there are two petitions in play right now.
13 The petition they talked about brings up the point
14 that they Baker-Just is possibly not conservative. He
15 has the same comment on Cathcart-Pawel. Asks to look
16 at some of these other test data that he claims we
17 have not looked at before.
18 He also submitted –
19 CHAIR BANERJEE: Particularly bundle data.
20 MR. BAJOREK: Bundle, yes. The staff has
21 put together a small group to start to evaluate these
22 concerns. We started to take a look at it and another
23 petition came in, this one on the behalf of
24 Connecticut or Yankee, it's a plant that's been up for
25 relicensing. There are --
CONSULTANT WALLIS: Vermont Yankee?
2 MR. BAJOREK: Vermont Yankee, that's right.
3 Vermont Yankee is being relicensed. They have also put
4 in a petition on their behalf where they cite many of
5 the same concerns. Because these petitions are over
6 lapping, the staff decided they were not going to look
7 at them individually, they were going to put them
8 together. We went through our OGC. They said that was
9 an appropriate thing to do and now the window of time
10 for evaluating those petitions and those concerns has
11 been reopened and I think we have another -- I think
12 we have a year to go through and reevaluate
13 everything. So there's a group that is looking at
14 that.
15 CHAIR BANERJEE: So I think we can report
16 that to the full committee.
17 CONSULTANT WALLIS: But just report that.
18 That's all we have to do.
19 MEMBER ABDEL-KHALIK: And I think from the
20 committee's perspective, we await the staff's
21 evaluation and we will review the staff's evaluation.
22 MR. BAJOREK: He did make the point that
23 while there was a user need letter, point out and the
24 research was supposed to have responded by I think the
25 end of August. That was the original schedule. But
because they amended their own petition, and submitted
2 another petition, OGC decided to lump it together and
3 that window of time has moved out.
4 CHAIR BANERJEE: Okay. Well with that, I
5 think I'd like to thank you all and adjourn the
6 meeting.
Now, it is unlikely that the combined review of PRM-50-93 and PRM-50-95 adds sufficient complexity and data to justify a one year extension to the deadline for producing the Technical Analysis that is to be the basis of a recommendation to the NRC Commissioners for action on PRM-50-93 and PRM-50-95. Certainly, a substantial amount of review of PRM-50-93 should have been already completed prior to the merging of PRM-50-93 with the recent PRM-50-95.
Robert H. Leyse
P. O. Box 2850
Sun Valley, ID 83353
I’m Bob Leyse. This presentation is directed to two PRMs that were originated by Mark Leyse. These are PRM-50-93 and PRM-50-95, and today I am standing in for Mark. I’ll move through the 6 page handout in the allotted 5 minutes.
Moving to page 1 of the handout,
NRC should not authorize Plant License Renewals or Power Uprates prior to its resolution of PRM-50-93 and PRM-50-95.
The 2200 degree Fahrenheit PCT limit is too high. The 2200 PCT limit is based on embitterment criteria. The Baker-Just equation was placed into 50.46 and it has been convenient in licensing. Its current use in 50.46 is fiercely defended by the NRC.
Not in the handout, is an incorrect remark by Bajorek at the joint meeting of three ACRS subcommittees on May 31, 2002. “Note by the way Baker-Just in some of the earlier data was based on zirconium data only.” In fact, Baker-Just is very predominantly based on experiments with Zircaloy-2 at Bettis and Battelle. NRC did not even have those references until I appealed to the OGC and then the documents were acquired and placed in ADAMS. The reports are:
WAPD-104 ADAMS Accession No. ML100900446
BMI-1154 ADAMS Accession No. ML100570218
Go to page 2:
At another point in that joint meeting of the three ACRS subcommittees on May 31, 2002, we hear from
MEMBER WALLIS: 2200 has a very iffy
basis. The only justification really is that it is
worked over 30 or 40 years.
However, Member Wallis is wrong. There is nothing iffy about 2200. Very clearly, 2200 is too high and there is nothing iffy about that. Perhaps the most impressive evidence comes from experiment LOFT LP-FP-2 where thermal runaway of the fuel bundle was initiated in the 2060 to 2240 degree Fahrenheit range. And, the series of CORA experiments at Karlsruhe yielded thermal runaway over a range from about 1800 to 2200 degrees Fahrenheit. The CORA experiments used bundles of electrically heated rods having Zirconium alloy cladding and uranium dioxide fuel pellets.
On page 3 of the handout, note that Mark Leyse and Robert Leyse jointly made a 10 minute presentation to the ACRS Thermal Hydraulics Phenomena Subcommittee on Monday, October 18, 2010. Close to the end of the meeting the subcommittee briefly discussed the matter.
To save time, please skip to page 6,
Discussing the review of PRM-50-93 and PRM-50-95, at the October 18 meeting we hear from
MEMBER ABDEL-KHALIK: "And I think from the committee's perspective, we await the staff's evaluation and we will review the staff's evaluation."
Now, one primary mandate of the ACRS is; “to initiate reviews of specific generic matters or nuclear facility safety-related items.” In line with that mandate, I believe that ACRS should evaluate PRM-50-93 and PRM-50-95 in parallel and likely in advance of the NRC’s technical evaluations.
For emphasis I am repeating from page 1: NRC should not authorize Plant License Renewals or Power Uprates prior to its resolution of PRM-50-93 and PRM-50-95.
Thank you.
Handout for Bob Leyse Presentation to Full ACRS, 6 pages, December 2, 2010
Note: This handout to the Full ACRS is a copy of a comment that was submitted to the NRC by Bob Leyse regarding Mark Leyse Petitions for Rulemaking PRM-50-93 and PRM-50-95.
November 26, 2010
Annette L. Vietti-Cook
Secretary
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
Attention: Rulemakings and Adjudications Staff
COMMENTS ON PRM-50-93 AND PRM-50-95; NRC-2009-0554
NRC should not authorize Plant License Renewals or Power Uprates prior to its resolution of PRM-50-93 and PRM-50-95.
The 2200 degree Fahrenheit PCT limit is too high. The 2200 PCT limit is based on embitterment criteria. The Baker-Just equation was placed into 50.46 and it has been convenient in licensing. Its current use is fiercely defended by the NRC.
According to analyses funded by NRC, when the Baker-Just correlation is applied, the predicted thermal runaway starts at 2600 degrees Fahrenheit, while the alternative Cathcart-Pawel correlation of Reg. Guide 1.157 yields runaway at 2700. This is detailed on page 28 of PRM-50-93.
At a joint meeting of three ACRS subcommittees on May 31, 2002, there is the following pertinent exchange:
MR. LAUBEN: That's it. Sure. No.
That's an easy and quantifiable way to compare it. It
just gives you a minimum measure because what's really
true because of the slope changes so much is that you
can see a much bigger difference. In general I would
say I could never achieve turn-around much above 2300
in the limited 100 calculations I did with Baker-Just
but I could reach something as close to 2800 with
Cathcart-Pawel. Now that's –
MEMBER WALLIS: Maybe you need to show
these calculations. Something more convincing than
what we heard today --
At another point in that joint meeting of three ACRS subcommittees on May 31, 2002:
MEMBER WALLIS: 2200 has a very iffy
basis. The only justification really is that it is
worked over 30 or 40 years. If you are going to
change it you're going to have to have some really
good arguments.
However, Member Wallis is wrong. There is nothing “iffy” about 2200. At Karlsruhe it had already been clearly demonstrated that 2200 is too high and there is nothing “iffy” about the fact that 2200 is too high. An array of experiments having multirod assembles of rods with zirconium alloy cladding reveal that thermal runaway begins well below the 2600 to 2700 range. Perhaps the most impressive is LOFT LP-FP-2 where thermal runaway of the fuel bundle was initiated in the 2060 to 2240 degree Fahrenheit range. And, the series of CORA experiments at Karlsruhe with bundled electrically heated rods having Zirconium alloy cladding and uranium fuel pellets, yielded thermal runaway over a range from about 1800 to 2200 degrees Fahrenheit.
Although PRM-50-93 is dated November 2009, there is little evidence that the NRC has pursued its evaluation. On April 26, 2010, NRR issued a USER NEED REQUEST FOR TECHNICAL ANALYSIS OF PETITION FOR RULEMAKING ON 10 CFR 50.46 (PRM-50-93) and at that time the activity was (finally) assigned a high priority. Quoting from the User Need Request, "The requested deliverable for this user need is a technical letter report. Your office provided an outstanding technical analysis [reference 2] of a similar rulemaking petition, and we request the final deliverable for this user need be in this same format. We also request that a draft of your report be provided for comment by August 31, 2010 and the final report by September 30, 2010. We will provide comments on the draft within one week of receipt."
However: On October 27, 2010, the NRC published for public comment a notice of consolidation of petitions for rulemaking. The PRMs to be consolidated are PRM-50-93 filed by Mark Edward Leyse on November 17, 2009, and PRM-50-95 filed on June 7, 2010, by Mark Edward Leyse and Raymond Shadis, on behalf of the New England Coalition. What Mark Leyse filed on June 7, 2010 was not a PRM, it was a 2.206 petition. It appears that by consolidating these actions by Mark Leyse, the NRC has substantially extended the deadline for producing a Technical Letter Report regarding PRM-50-93. Nevertheless, the priority is established by the technical facts that are in the record and high priority attention by the NRC reviewers remains warranted.
In fact, Mark Edward Leyse first learned about the extended deadline when the ACRS Thermal Hydraulics Phenomena Subcommittee briefly discussed the matter on Monday, October 18, 2010. Mark Leyse and Robert Leyse had jointly made a 10 minute presentation, and at the end of the meeting the subcommittee discussed the matter as follows:
CONSULTANT KRESS: I found it very unusual
17 that public comments are made to the subcommittee.
18 Those usually go to the full committee. I don't know
19 what your obligation is with respect to those.
20 CHAIR BANERJEE: I think to report it to
21 the full committee and ask if –
22 CONSULTANT KRESS: Just report it to the
23 full committee.
24 CHAIR BANERJEE: ask if they wish it to be
25 made to the full committee. I don't think that we can
act on it.
2 CONSULTANT KRESS: No. That was my point.
3 It has to be acted by the full committee.
4 CONSULTANT WALLIS: But if you want a
5 comment, it looked as if there could be a significant
6 point here, I mean it's something that is not trivial
7 to look at and see is there a question here and what's
8 the evidence for –
9 CHAIR BANERJEE: Has the comments been made
10 to the staff or is it just to the subcommittee?
11 MR. BAJOREK: This is Steve Bajorek.
12 Actually there are two petitions in play right now.
13 The petition they talked about brings up the point
14 that they Baker-Just is possibly not conservative. He
15 has the same comment on Cathcart-Pawel. Asks to look
16 at some of these other test data that he claims we
17 have not looked at before.
18 He also submitted –
19 CHAIR BANERJEE: Particularly bundle data.
20 MR. BAJOREK: Bundle, yes. The staff has
21 put together a small group to start to evaluate these
22 concerns. We started to take a look at it and another
23 petition came in, this one on the behalf of
24 Connecticut or Yankee, it's a plant that's been up for
25 relicensing. There are --
CONSULTANT WALLIS: Vermont Yankee?
2 MR. BAJOREK: Vermont Yankee, that's right.
3 Vermont Yankee is being relicensed. They have also put
4 in a petition on their behalf where they cite many of
5 the same concerns. Because these petitions are over
6 lapping, the staff decided they were not going to look
7 at them individually, they were going to put them
8 together. We went through our OGC. They said that was
9 an appropriate thing to do and now the window of time
10 for evaluating those petitions and those concerns has
11 been reopened and I think we have another -- I think
12 we have a year to go through and reevaluate
13 everything. So there's a group that is looking at
14 that.
15 CHAIR BANERJEE: So I think we can report
16 that to the full committee.
17 CONSULTANT WALLIS: But just report that.
18 That's all we have to do.
19 MEMBER ABDEL-KHALIK: And I think from the
20 committee's perspective, we await the staff's
21 evaluation and we will review the staff's evaluation.
22 MR. BAJOREK: He did make the point that
23 while there was a user need letter, point out and the
24 research was supposed to have responded by I think the
25 end of August. That was the original schedule. But
because they amended their own petition, and submitted
2 another petition, OGC decided to lump it together and
3 that window of time has moved out.
4 CHAIR BANERJEE: Okay. Well with that, I
5 think I'd like to thank you all and adjourn the
6 meeting.
Now, it is unlikely that the combined review of PRM-50-93 and PRM-50-95 adds sufficient complexity and data to justify a one year extension to the deadline for producing the Technical Analysis that is to be the basis of a recommendation to the NRC Commissioners for action on PRM-50-93 and PRM-50-95. Certainly, a substantial amount of review of PRM-50-93 should have been already completed prior to the merging of PRM-50-93 with the recent PRM-50-95.
Robert H. Leyse
P. O. Box 2850
Sun Valley, ID 83353
2200 degrees Fahrenheit is Too High
PRESENTATON BY BOB LEYSE TO ACRS SUBCOMMITTEE ON POWER UPRATE, NOVEMBER 17, 2010
2200 FAHRENHEIT IS TOO HIGH
I’m Bob Leyse and I have been in this business since 1950. I’ll race through the slide in 10 minutes. The slide covers two PRMs by Mark Leyse. The Committee is urged to digest those after this meeting, and that will take longer than 10 minutes, however, the members can certainly justify applying that time in their billing to ACRS. The slide has the ML numbers.
There are two items: the 2200 degree Fahrenheit PCT limit is too high and crud has a substantial impact on the PCT during a LOCA. Moving for a moment to today’s meeting, most of the AREVA presentation is reasonably not available to the public, however, I think it is likely that none of the KATHY games include the impact of a range of crud deposits.
OK, back to the slide. This is called the POWER UPRATE COMMITTEE, which presupposes that Power Uprates are in order. What we really need is a Power Level Review Committee.
The 2200 degree Fahrenheit PCT limit is too high. The 2200 PCT limit is based on embitterment criteria. The Baker-Just equation was placed into 50.46 and it has been convenient in licensing. According to analyses funded by NRC, when the Baker-Just correlation is applied, the predicted thermal runaway starts at 2600 degrees Fahrenheit, while the alternative Cathcart-Pawel correlation of Reg. Guide 1.157 yields runaway at 2700. However, an array of experiments having multirod assembles of rods with zirconium alloy cladding reveal that thermal runaway begins well below the 2600 to 2700 range. Perhaps the most impressive is LOFT LP-FP-2 where thermal runaway of the fuel bundle was initiated in the 2060 to 2240 degree Fahrenheit range. The series of CORA experiments at Karlsruhe with Zirconium alloy cladding of bundled electrically heated rods yielded thermal runaway over a range from about 1800 to 2200 degrees Fahrenheit.
The NRC staff is taking PRM-50-93 very seriously, and so should the ACRS.
The current User Need Request from NRR to RES is High Priority.
The requested deliverable for this user need is a technical letter report and the initial due date for a thoroughly researched final report was September 30, 2010.
However: On October 27, 2010, the NRC published for public comment a notice of consolidation of petitions for rulemaking. The PRMs to be consolidated are PRM-50-93filed by Mark Edward Leyse on November 17, 2009, and PRM-50-95 filed on June 7,
2010, by Mark Edward Leyse and Raymond Shadis, on behalf of the New England Coalition. What Mark Leyse filed on June 7, 2010 was not a
PRM, it was a 2.206 petition. It appears that by consolidating these actions by Mark Leyse, the NRC has extended the deadline for producing a Technical Letter Report regarding PRM-50-93. Nevertheless, the priority is established by the technical facts that are in the record and diligent and timely attention by the ACRS is most certainly called for under its mandate “to initiate reviews of specific generic matters or nuclear facility safety-related items.”
Moving to the impact of crud; PRM-50-84 details the impact of crud on the steady-state temperature distribution and stored energy in the fuel at the onset of a postulated LOCA.
Crud increases the operating fuel rod surface temperature and fuel rod stored energy. Crud decreases the overall heat transfer coefficient at the fuel rod. Crud adversely impacts the coolant flow distribution throughout the reactor core (fuel rod locations with heavier crud layers have less flow). Thus crud leads to substantial increases in the PCT during a LOCA.
In its Advance Notice of Proposed Rulemaking: Performance-Based ECCS Acceptance Criteria, July 29, 2009, NRC addresses PRM-84 as follows: In summary, to address the technical concerns related to crud in the PRM-50-84 petitioner’s request for rulemaking, the NRC is considering amending § 50.46 to specifically identify crud as a parameter to be considered in best-estimate and Appendix K to Part 50 ECCS evaluation models.
PRM-50-84 reports that EPRI will complete a program during 2008 that will “… determine the effect of tenacious crud on fuel surface heat transfer.” So far, I have found no open reporting of this.
AREVA and Westinghouse have brochures that describe ultrasonic fuel cleaning services. The recent Westinghouse brochure lists more than 12 LWRs that have used Ultrasonic Fuel Cleaning for crud removal from fuel elements. And from the AREVA brochure I quote, “AREVA NP offers patented Electric Power Research Institute (EPRI) Ultrasonic Fuel Cleaning (UFC) to prevent uneven crud deposits that can negatively affect fuel performance.”
Also interesting is a patent application: Chemical Enhancement of Ultrasonic Fuel Cleaning. Here are a few sentences (Only read the three sentences that are in bold.)
A method for cleaning an irradiated nuclear fuel assembly includes chemically enhancing a technique utilizing an apparatus including a housing adapted to engage a nuclear fuel assembly. A set of ultrasonic transducers is positioned on the housing to supply radially emanating omnidirectional ultrasonic energy to remove deposits from the nuclear fuel assembly. Any corrosion products remaining after ultrasonic fuel cleaning will have exposed surfaces that are susceptible to chemical dissolution.
The mechanical cleaning is effective, but it is not 100% efficient because corrosion products remain on the fuel assemblies. It is estimated that ultrasonic cleaning removes up to 80% of the total corrosion product inventory on the fuel
According to the subject method, chemical addition is localized to the water in the ultrasonic cleaning chamber rather than throughout the primary system, which minimizes the total liquid waste generated by orders of magnitude. Less aggressive chemistries can be selected that take advantage of the ultrasonic fuel cleaning environment. Only the fuel assemblies are exposed to the chemicals, so there is less chemical cleanup required for the vessel or ex-core piping. In certain embodiments, the chemical addition steps could be applied to selected high flux assemblies that have high corrosion deposition, while other fuel assemblies could be cleaned only ultrasonically.
The references by Mark Leyse and J. S. Lee that are listed at the end of the handout each disclose that crud significantly increases the local surface temperature of the cladding and the stored energy within the fuel.
NRR and RES are continuing their preparation of the Technical Letter Report that is to be the basis for a timely recommendation to the NRC Commissioners regarding the disposition of PRM-50-93. In the meantime, ACRS should not concur with any Power Uprate proposal until PRM-50-93 is resolved.
I have about two minutes left. I have worked at GE, Hanford and San Jose; Westinghouse, Monroeville; DuPont, Savannah River; Argonne, and the Nuclear Safety Analysis Center at EPRI. Elsewhere, during the 1970s, I invented, branded and marketed the RADCAL GAMMA THERMOMTER. GE Hitachi references my IEEE paper that describes the gamma thermometer that is central to their current licensing report, "Gamma Thermometer System for LPRM Calibration and Power Shape Monitoring." October 6, 2010. Accession Number ML102810320.
For emphasis, I repeat, you may tell the Full Committee to not concur with any Power Uprate proposal until PRM-50-93 is resolved.
Thank you.
SLIDE: PRESENTATION TO SUBCOMMITTEE ON POWER UPRATE
2200°F is nonconservative. PRM-50-93(ML093290250)
Petitioner (Mark Leyse) requests that NRC revise 10 C.F.R. § 50.46(b)(1) to require that the calculated maximum fuel element cladding temperature not exceed a limit based on data from multi-rod (assembly) severe fuel damage experiments.
Mark Leyse also authored and submitted on behalf of New England Coalition a 2.206 petition requesting that NRC order the lowering of LBPCT of VYNPS (ML101610121). NRC recently converted this to PRM-50-95; the public comment period is now open.
The User Need Request for PRM-50-93, NRR to RES, is High Priority. (ML100770117)
Multirod severe fuel damage experiments reveal that 2200°F is too high.
LOFT LP-FP-2 experiment at INL Runaway began at 2060°F – 2240°F
CORA experiments at Karlsruhe Runaway began at 1832°F - 2192°F
PHEBUS B9R-2 Runaway began at <2200°f>Impact of crud PRM-50-84 (ML070871368)
Petitioner (Mark Leyse) requests that NRC amend Appendix K to Part 50—ECCS Evaluation Models I(A)(1), The Initial Stored Energy in the Fuel, to require that the steady-state temperature distribution and stored energy in the fuel at the onset of a postulated LOCA be calculated by factoring in the role that the thermal resistance of crud and/or oxide layers on fuel cladding plays in increasing the stored energy in the fuel. This requirement also needs to apply to any NRC approved best-estimate ECCS evaluation models used in lieu of Appendix K calculations.
To address the technical concerns related to crud ... in PRM-50-84 ... the NRC is considering amending § 50.46 to specifically identify crud as a parameter to be considered in best-estimate and Appendix K to Part 50 ECCS evaluation models.
ANPR: Performance-Based ECCS Acceptance Criteria, 07/29/2009, ML091250132.
Ultrasonic Fuel Cleaning under 10 C.F.R. § 50.59: An Areva brochure, Ultrasonic Fuel Cleaning, was recently updated, 11/05/2010. The Westinghouse brochure, NS-FS-0085, April 2009, reports, Ultrasonic Fuel Cleaning has been used at the following plants: ANO, Callaway, Catawba, Ft. Calhoun, McGuire, Millstone, Quad Cities, Seabrook, South Texas 1 & 2, Vogtle 1 & 2, Vandellos, and Watts Bar.
Mark Leyse coauthored, “Considering the Thermal Resistance of Crud in LOCA Analysis,” ANS 2009 Winter Meeting, November 15-19, 2009, Washington, D. C.
J. S. Lee, et al., “Effects of Crud on the Fuel Rod Integrity in Steady-State and LB-LOCA Condition,” 2008 Water Reactor Fuel Performance Meeting, Seoul, Korea.
2200 FAHRENHEIT IS TOO HIGH
I’m Bob Leyse and I have been in this business since 1950. I’ll race through the slide in 10 minutes. The slide covers two PRMs by Mark Leyse. The Committee is urged to digest those after this meeting, and that will take longer than 10 minutes, however, the members can certainly justify applying that time in their billing to ACRS. The slide has the ML numbers.
There are two items: the 2200 degree Fahrenheit PCT limit is too high and crud has a substantial impact on the PCT during a LOCA. Moving for a moment to today’s meeting, most of the AREVA presentation is reasonably not available to the public, however, I think it is likely that none of the KATHY games include the impact of a range of crud deposits.
OK, back to the slide. This is called the POWER UPRATE COMMITTEE, which presupposes that Power Uprates are in order. What we really need is a Power Level Review Committee.
The 2200 degree Fahrenheit PCT limit is too high. The 2200 PCT limit is based on embitterment criteria. The Baker-Just equation was placed into 50.46 and it has been convenient in licensing. According to analyses funded by NRC, when the Baker-Just correlation is applied, the predicted thermal runaway starts at 2600 degrees Fahrenheit, while the alternative Cathcart-Pawel correlation of Reg. Guide 1.157 yields runaway at 2700. However, an array of experiments having multirod assembles of rods with zirconium alloy cladding reveal that thermal runaway begins well below the 2600 to 2700 range. Perhaps the most impressive is LOFT LP-FP-2 where thermal runaway of the fuel bundle was initiated in the 2060 to 2240 degree Fahrenheit range. The series of CORA experiments at Karlsruhe with Zirconium alloy cladding of bundled electrically heated rods yielded thermal runaway over a range from about 1800 to 2200 degrees Fahrenheit.
The NRC staff is taking PRM-50-93 very seriously, and so should the ACRS.
The current User Need Request from NRR to RES is High Priority.
The requested deliverable for this user need is a technical letter report and the initial due date for a thoroughly researched final report was September 30, 2010.
However: On October 27, 2010, the NRC published for public comment a notice of consolidation of petitions for rulemaking. The PRMs to be consolidated are PRM-50-93filed by Mark Edward Leyse on November 17, 2009, and PRM-50-95 filed on June 7,
2010, by Mark Edward Leyse and Raymond Shadis, on behalf of the New England Coalition. What Mark Leyse filed on June 7, 2010 was not a
PRM, it was a 2.206 petition. It appears that by consolidating these actions by Mark Leyse, the NRC has extended the deadline for producing a Technical Letter Report regarding PRM-50-93. Nevertheless, the priority is established by the technical facts that are in the record and diligent and timely attention by the ACRS is most certainly called for under its mandate “to initiate reviews of specific generic matters or nuclear facility safety-related items.”
Moving to the impact of crud; PRM-50-84 details the impact of crud on the steady-state temperature distribution and stored energy in the fuel at the onset of a postulated LOCA.
Crud increases the operating fuel rod surface temperature and fuel rod stored energy. Crud decreases the overall heat transfer coefficient at the fuel rod. Crud adversely impacts the coolant flow distribution throughout the reactor core (fuel rod locations with heavier crud layers have less flow). Thus crud leads to substantial increases in the PCT during a LOCA.
In its Advance Notice of Proposed Rulemaking: Performance-Based ECCS Acceptance Criteria, July 29, 2009, NRC addresses PRM-84 as follows: In summary, to address the technical concerns related to crud in the PRM-50-84 petitioner’s request for rulemaking, the NRC is considering amending § 50.46 to specifically identify crud as a parameter to be considered in best-estimate and Appendix K to Part 50 ECCS evaluation models.
PRM-50-84 reports that EPRI will complete a program during 2008 that will “… determine the effect of tenacious crud on fuel surface heat transfer.” So far, I have found no open reporting of this.
AREVA and Westinghouse have brochures that describe ultrasonic fuel cleaning services. The recent Westinghouse brochure lists more than 12 LWRs that have used Ultrasonic Fuel Cleaning for crud removal from fuel elements. And from the AREVA brochure I quote, “AREVA NP offers patented Electric Power Research Institute (EPRI) Ultrasonic Fuel Cleaning (UFC) to prevent uneven crud deposits that can negatively affect fuel performance.”
Also interesting is a patent application: Chemical Enhancement of Ultrasonic Fuel Cleaning. Here are a few sentences (Only read the three sentences that are in bold.)
A method for cleaning an irradiated nuclear fuel assembly includes chemically enhancing a technique utilizing an apparatus including a housing adapted to engage a nuclear fuel assembly. A set of ultrasonic transducers is positioned on the housing to supply radially emanating omnidirectional ultrasonic energy to remove deposits from the nuclear fuel assembly. Any corrosion products remaining after ultrasonic fuel cleaning will have exposed surfaces that are susceptible to chemical dissolution.
The mechanical cleaning is effective, but it is not 100% efficient because corrosion products remain on the fuel assemblies. It is estimated that ultrasonic cleaning removes up to 80% of the total corrosion product inventory on the fuel
According to the subject method, chemical addition is localized to the water in the ultrasonic cleaning chamber rather than throughout the primary system, which minimizes the total liquid waste generated by orders of magnitude. Less aggressive chemistries can be selected that take advantage of the ultrasonic fuel cleaning environment. Only the fuel assemblies are exposed to the chemicals, so there is less chemical cleanup required for the vessel or ex-core piping. In certain embodiments, the chemical addition steps could be applied to selected high flux assemblies that have high corrosion deposition, while other fuel assemblies could be cleaned only ultrasonically.
The references by Mark Leyse and J. S. Lee that are listed at the end of the handout each disclose that crud significantly increases the local surface temperature of the cladding and the stored energy within the fuel.
NRR and RES are continuing their preparation of the Technical Letter Report that is to be the basis for a timely recommendation to the NRC Commissioners regarding the disposition of PRM-50-93. In the meantime, ACRS should not concur with any Power Uprate proposal until PRM-50-93 is resolved.
I have about two minutes left. I have worked at GE, Hanford and San Jose; Westinghouse, Monroeville; DuPont, Savannah River; Argonne, and the Nuclear Safety Analysis Center at EPRI. Elsewhere, during the 1970s, I invented, branded and marketed the RADCAL GAMMA THERMOMTER. GE Hitachi references my IEEE paper that describes the gamma thermometer that is central to their current licensing report, "Gamma Thermometer System for LPRM Calibration and Power Shape Monitoring." October 6, 2010. Accession Number ML102810320.
For emphasis, I repeat, you may tell the Full Committee to not concur with any Power Uprate proposal until PRM-50-93 is resolved.
Thank you.
SLIDE: PRESENTATION TO SUBCOMMITTEE ON POWER UPRATE
2200°F is nonconservative. PRM-50-93(ML093290250)
Petitioner (Mark Leyse) requests that NRC revise 10 C.F.R. § 50.46(b)(1) to require that the calculated maximum fuel element cladding temperature not exceed a limit based on data from multi-rod (assembly) severe fuel damage experiments.
Mark Leyse also authored and submitted on behalf of New England Coalition a 2.206 petition requesting that NRC order the lowering of LBPCT of VYNPS (ML101610121). NRC recently converted this to PRM-50-95; the public comment period is now open.
The User Need Request for PRM-50-93, NRR to RES, is High Priority. (ML100770117)
Multirod severe fuel damage experiments reveal that 2200°F is too high.
LOFT LP-FP-2 experiment at INL Runaway began at 2060°F – 2240°F
CORA experiments at Karlsruhe Runaway began at 1832°F - 2192°F
PHEBUS B9R-2 Runaway began at <2200°f>Impact of crud PRM-50-84 (ML070871368)
Petitioner (Mark Leyse) requests that NRC amend Appendix K to Part 50—ECCS Evaluation Models I(A)(1), The Initial Stored Energy in the Fuel, to require that the steady-state temperature distribution and stored energy in the fuel at the onset of a postulated LOCA be calculated by factoring in the role that the thermal resistance of crud and/or oxide layers on fuel cladding plays in increasing the stored energy in the fuel. This requirement also needs to apply to any NRC approved best-estimate ECCS evaluation models used in lieu of Appendix K calculations.
To address the technical concerns related to crud ... in PRM-50-84 ... the NRC is considering amending § 50.46 to specifically identify crud as a parameter to be considered in best-estimate and Appendix K to Part 50 ECCS evaluation models.
ANPR: Performance-Based ECCS Acceptance Criteria, 07/29/2009, ML091250132.
Ultrasonic Fuel Cleaning under 10 C.F.R. § 50.59: An Areva brochure, Ultrasonic Fuel Cleaning, was recently updated, 11/05/2010. The Westinghouse brochure, NS-FS-0085, April 2009, reports, Ultrasonic Fuel Cleaning has been used at the following plants: ANO, Callaway, Catawba, Ft. Calhoun, McGuire, Millstone, Quad Cities, Seabrook, South Texas 1 & 2, Vogtle 1 & 2, Vandellos, and Watts Bar.
Mark Leyse coauthored, “Considering the Thermal Resistance of Crud in LOCA Analysis,” ANS 2009 Winter Meeting, November 15-19, 2009, Washington, D. C.
J. S. Lee, et al., “Effects of Crud on the Fuel Rod Integrity in Steady-State and LB-LOCA Condition,” 2008 Water Reactor Fuel Performance Meeting, Seoul, Korea.
Subscribe to:
Posts (Atom)
