Saturday, September 28, 2013

Hardened Vent: the basis was apparently only recently documented.

As is clear from my recent entries, it was only following my recent inquiry that NRC published the basis for the capacity of the hardened vent system.  Here it is:
http://pbadupws.nrc.gov/docs/ML1322/ML13221A011.pdf
The document is dated August 9, 2012, however this is backdated by one year.  The correct date is August 9, 2013.

What I am gong to try to find out now, is what actions the NRC went through in order to produce the above document.

I requested the basis for the following:


1.2 The HCVS shall include the following design features:
1.2.1 The HCVS shall have the capacity to vent the steam/energy equivalent of 1 percent of licensed/rated thermal power (unless a lower value is justified by analyses), and be able to maintain containment pressure below the primary containment design pressure. 

Page 3 of 3 of the August 12, 2013, document ML13221A011, lists 10 references as follows:

References:
1. “American National Standard for Decay Heat Power in Light Water Reactors.” American
Nuclear Society Standards Committee Working Group ANS 5.1. Approved August 29,
1979.
2. NUREG/CR-3908, “Survey of the State of the Art in Mitigation Systems.” January 1988.
3. Generic Letter 89-16, “Installation of a Hardened Wetwell Vent.” September 1, 1989.
4. Information Notice 9639, “Estimates of Decay Heat using ANS 5.1 Decay Heat Standard
may very significantly.” July 5, 1996.
5. HSK-R-40/d, “Filtered Venting for Containment Vessels of Light Water Reactors (LWR):
Design Requirements.” March 1993.
6. Technical Report 1998-03, “Decay Heat Estimates for MNR.” February 23, 1999.
http://www.nuceng.ca/papers/decayhe1b.pdf
7. Decay heat illustration2.PNG. http://enm.wikipedia.org/wiki/File:Decay heat
illustration2.PNG.
8. IAEA-TECDOC-1661, “Mitigation of Hydrogen Hazards in Severe Accidents in Nuclear
Power Plants.” July 2011.
9. NUREG/CR-5597, “In-Vessel Zircaloy Oxidation/Hydrogen Generation Behavior during
Severe Accident.” September 1990.
10. NUREG/CR-2726 SAND82-1137R3, “Light Water Reactor Hydrogen Manual.” August
1983.
Date: August 9, 2012
ADAMS Accession No.: ML13221A011

It is noteworthy that of the ten references, reference 8, IAEA-TECDOC-1661, July 2011, is the only reference that has been published since the Fukushima detonations.  It is also noteworthy that although reference 8 itself has 100 pertinent references in the matter of Mitigation of Hydrogen Hazards in Severe Accidents in Nuclear Power Plants, none of the other nine references of document ML13221A011 are cited. 

On page 1 of 3 of is the assertion:
Generic Letter 89-16 (Reference 3) related to installation of hardened wetwell vents was issued in September 1989 and stated that the system installed by Boston Edison Company at the Pilgrim Nuclear Power Station and associated analysis was acceptable. The design analysis included a vent design objective of venting approximately 1 % of decay heat for a 56 psi saturated steam conditions in the torus.

So, I downloaded reference 3, but the attachment that discusses the Pligrim analysis is not included.  I'll contact NRC's PDR and ask for the attachment.  

The NRC's PDR very courteously provided the best copy that they could.  I e-mailed the following request:

From: Bobleyse@aol.com [mailto:Bobleyse@aol.com]
Sent: Monday, September 30, 2013 7:24 PM
To: JLD_Public Resource
Cc: CHAIRMAN Resource; CMROSTENDORFF Resource; CMRAPOSTOLAKIS Resource; CMRMAGWOOD Resource; CMRSVINICKI Resource
Subject: Fwd: Please assist (again)

JLD_Public Resource

The document that the PDR courteously sent is not completely readable, and those parts that are readable are not expediently readable. You should recognize that the matter is of intense importance.  Accordingly, you should take actions that will provide a very readable document in ADAMS, and those actions should proceed immediately.

Robert H. Leyse                 bobleyse@aol.com

And I received the following infuriating reply:
Subject: RE: Please assist (again)
Date: 10/1/2013 8:00:32 A.M. Mountain Daylight Time
From: JLD_Public.Resource@nrc.gov
To: Bobleyse@aol.com

Thank you for contacting the NRC’s Japan Lessons-Learned Project Directorate. Your comments will be considered to the extent possible.

Office of Nuclear Reactor Regulation
Nuclear Regulatory Commission

And, we pay those clowns for that kind of service.  I suppose the staff of the NRC's PDR may be chastised for providing courteous attention to my request; that courteous attention is beyond the requirements on NRC regulations.

 

 

  

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