Monday, April 28, 2014

My second comment on Proposed Rule

The proposed rule was posted on March 24, 2014, Performance-Based Emergency Core Cooling Systems  Cladding Acceptance Criteria

Here is my sybmittal, but I have no idea when (or if) it will be entered into the NRC system.

The proposed rule states: The formation of cladding crud and oxide layers is an expected condition at nuclear power plants.  It also states: Paragraph (g)(2)(ii) would be added to include a requirement to evaluate the thermal effects of crud and oxide layers that may have accumulated on the fuel cladding during plant operation.

This is Paragraph (g)(2)(ii):
(ii) The thermal effects of crud and oxide layers that accumulate on the fuel cladding
during plant operation must be evaluated. For the purposes of this paragraph, crud means any foreign substance deposited on the surface of fuel cladding prior to initiation of a LOCA.

Paragraph (g)(2)(ii) must be augmented as follows:
(ii) The thermal effects of crud and oxide layers that accumulate on the fuel cladding during plant operation must be evaluated. The thermal effects of crud and oxide layers must be evaluated based on the observed crud and oxide layers that are present on the fuel cladding at the start of the forthcoming operating cycle, and in addition, the projected changes in the crud and oxide layers during the course of the forthcoming operating cycle must also be included in order to provide an accurate evaluation.  For the purposes of this paragraph, crud means any foreign substance deposited on the surface of fuel cladding prior to initiation of a LOCA.

Sunday, April 27, 2014

Japan seeking international assistance with Fukushima defueling

A note from Emformable:

Posted: 25 Apr 2014 06:11 AM PDT
On Friday, officials from the International Research Institute for Nuclear Decommissioning (IRID) in Japan attending a seminar asked for input from engineers in Japan and across the world on removing melted nuclear fuel from the crippled reactors at the Fukushima Daiichi nuclear power plant.
Tokyo Electric plans to fill the containment vessels with water in order to shield the workers from the high levels of radiation they would be exposed to while retrieving the damaged fuel.  The roadmap for decommissioning developed by the utility estimates fuel removal activities could begin by 2020, or later.
At the seminar, IRID officials announced to any engineers interested in giving their input that the plan to fill the containment vessels may not be feasible, as not all leaks may be located or plugged prior to fuel removal.
The announcement infers that the containment vessels may be more damaged than initially estimated by Tokyo Electric.  Even if the containment vessels were able of holding the water there are also questions as to whether they would be structurally sound enough to hold the additional weight of the water required for shielding.
Engineers are invited to submit their input on technology that can identify and remove fuel debris in a highly radioactive atmosphere while protecting workers without the aid of shielding by water.  The Japanese government will begin accepting proposals in June.

The post Japan seeking international assistance with Fukushima Daiichi fuel removal appeared first on Enformable.

More from Enformable

Posted: 28 Apr 2014 05:09 AM PDT
Tokyo Electric is planning a more expansive investigation of the damaged containment vessels at Fukushima Daiichi Reactor 1, Reactor 2, and Reactor 3.  The utility hopes that the information gathered during the investigations will help plan fuel removal operations.
Previous investigations uncovered that the damaged containment vessels are likely not capable of holding water, as highly contaminated water has been found in rooms around the containment vessels and turbine buildings, but workers have no idea where the damage is located or its extent.
Tokyo Electric plans to fill the containment vessels with water to shield workers from radiation as they remove the damaged nuclear fuel.
In early May, TEPCO will use an endoscopic camera to survey areas connected to the containment vessel in order to determine where and how water is escaping.
In Reactor 1, the utility will focus on the bottom of the containment vessel.
In Reactor 2, the investigation will explore the suppression chamber in the lower areas at the bottom of the containment vessel.
In Reactor 3, workers will explore connections between the containment vessel and adjoining rooms.
The post Enhanced investigation of crippled containment vessels at Fukushima Daiichi planned appeared first on Enformable.

Friday, April 18, 2014

Comment Number 1, Performance-Based Emergency Core Cooling Systems Cladding Acceptance Criteria

I'll edit this later,for now, here it is. ADAMS ML14098A491

Rulemaking1CEm Resource
From: RulemakingComments Resource
Sent: Tuesday, April 08, 2014 4:41 PM
To: Rulemaking1CEm Resource
Cc: RulemakingComments Resource
Subject: FW: Strange reference to Baker-Just
PR#: PR-50 and PR-52
FRN#: 79FR16105
NRC DOCKET#: NRC–2008–0332, NRC–2012–0041, NRC– 2012–0042, NRC–2012–0043
TITLE: Performance-Based Emergency Core Cooling Systems Cladding
Acceptance Criteria
From: []
Sent: Wednesday, April 02, 2014 9:10 PM
To: Inverso, Tara
Subject: Strange reference to Baker-Just
A Strange reference to Baker-Just
16116 Federal Register / Vol. 79, No. 56 / Monday, March 24, 2014 / Proposed Rules
For this case, appendix K to 10 CFR part
50 ECCS evaluation models would
continue to use the Baker-Just (BJ)
weight gain correlation for estimating
the rate of energy release and hydrogen
generation from the metal/water
It is strange that BJ is deployed, because neither Baker-Just nor BJ is used elsewhere in
the entire document.
Furthermore, it is strange that only Cathcart-Pawel is used in Figure 1; there is no
comparison with Baker-Just:
Robert H. Leyse
Hearing Identifier: Secy_RuleMaking_comments_Public
Email Number: 987
Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D0016513891473)
Subject: FW: Strange reference to Baker-Just
Sent Date: 4/8/2014 4:40:57 PM
Received Date: 4/8/2014 4:40:59 PM
From: RulemakingComments Resource
Created By:
"RulemakingComments Resource" <>
Tracking Status: None
"Rulemaking1CEm Resource" <>
Tracking Status: None
Post Office:
Files Size Date & Time
MESSAGE 1193 4/8/2014 4:40:59 PM
Untitled.jpg 28993
Priority: Standard
Return Notification: No
Reply Requested: No
Sensitivity: Normal
Expiration Date:
Recipients Received:

Saturday, April 12, 2014

ANL-6548 Baker-Just Equation 5/1962 ML050550198

Saturday, April 5, 2014

An update on Ultrasonic Cleaning of Nuclear Reactor Fuel

Here is a reference to a patent that issued during 2013:

United States Patent 8,372,206
Gross ,   et al. February 12, 2013

High power density ultrasonic fuel cleaning with planar transducers

Provided are a range of ultrasonic cleaning assemblies that include radiating surfaces activated by corresponding arrays of planar transducers configured to increase the power applied to a reduced volume of fluid associated with a fuel assembly, thereby increasing that applied power density for improved cleaning. The individual ultrasonic cleaning assemblies may be arranged in a variety of modules that, in turn, may be combined to increase the length of the cleaning zone and provide variations in the power density applied to improve the cleaning uniformity.

Inventors: Gross; David J. (Bethesda, MD), Arguelles; David (Herndon, VA)
Name City State Country Type

Gross; David J.
Arguelles; David




Assignee: Dominion Engineering, Inc. (Reston, VA)
Family ID: 41115275
Appl. No.: 12/353,950
Filed: January 14, 2009

And here is a reference to a patent that issued during 2002:
United States Patent 6,396,892
Frattini ,   et al. May 28, 2002

Apparatus and method for ultrasonically cleaning irradiated nuclear fuel assemblies

An apparatus for cleaning an irradiated nuclear fuel assembly includes 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.

Inventors: Frattini; Paul L. (Los Altos, CA), Varrin; Robert Douglas (Reston, VA), Hunt; Edwin Stephen (Arlington, VA)
Assignee: Electric Power Research Institute, Inc. (Palo Alto, CA)
Family ID: 22435141
Appl. No.: 09/545,354
Filed: April 7, 2000

Here is the link to Mark Leyse's PRM-50-84:

Here is link to Summary of Public Comments on PRM-50-84:

Here is a link to a significant inspection report;
Following is from the above inspection report:
Cycle 8 Fuel Failures: During Operating Cycle 8, the licensee experienced seven fuel
pin failures in high power regions of the core. All the fuel pin failures were located in
first burn fuel bundles. During Refueling Outage 8, the licensee found a significant layer
of crud on the fuel surface. Pictures of the crud indicated that it was primarily composed
of loose iron oxide deposits but the team observed some tenacious crud on the cladding
surface as well. The licensee did not perform a chemical analysis of the crud.

The crud increased the thermal resistance between the fuel cladding and the coolant
such that cladding surface temperatures were substantially higher than would normally
be expected. Normal cladding surface temperatures are about 560 EF (close to the bulk
coolant temperature). General Electric (the fuel vendor) calculated that the cladding
surface temperatures approached 1200 degrees F in localized areas. The higher temperatures
increased the cladding oxidation rate and, at approximately 1 year into the cycle, the
cladding oxidation layer extended the entire way through the cladding, creating a hole.

The team reviewed one technical study that discussed the behavior of crud on the
surface of boiler tubes (“Two-Phase Flow and Heat Transfer,” D. Butterworth and G.F.
Hewitt, Oxford University Press, 1977). The team noted that the thermal resistance of
crud is not normally sufficient to cause cladding temperature increases consistent with
those observed during Cycle 8. In most circumstances, “wick boiling” occurs within the
crud. That is, capillary coolant channels within the crud deliver coolant to the cladding
surface. Steam then escapes from the cladding surface in chimney type plumes. This
is a fairly effective method of heat transfer. However, in some instances the capillary
coolant channels can become clogged, creating a static steam blanket on the cladding
surface. Steam is an exceptionally good thermal insulator. This is the process that
caused the very high cladding surface temperatures and ultimately resulted in fuel
cladding failure.

Following is my blog entry from 2008:

Wednesday, September 3, 2008

Ultrasonic Fuel Cleaning: AREVA, EPRI, Westinghouse, Dominion and more

Go to GOOGLE and enter Ultrasonic Fuel Cleaning. Hunt a bit and you will find a lot: Areva, EPRI, 50.59 game,
Following is the text of Areva's advertisement, minus the photographs.

Ultrasonic Fuel Cleaning

Effective fuel cleaning technology to help assure performance and improve safety. AREVA NP offers patented Electric Power Research Institute (EPRI) Ultrasonic Fuel Cleaning (UFC) to prevent uneven crud deposits that can negatively affect fuel performance. With proven performance in applications at several domestic U.S. utilities, UFC can also reduce dose rates on primary components contaminated by the migration of activation products from core surfaces. Plus, we are an official EPRI licensee authorized to supply UFC equipment and services to nuclear stations worldwide. We can provide UFC for your next outage.

UFC was developed by EPRI to eliminate in-core flux depression by effectively removing deposits from fuel assemblies during refueling outages. Ultrasonic waves cause small particles of crud to release from the fuel assembly. Fuel pool water cools the fuel and transports particles to the filter banks where they are collected for final disposal. The system employs disposable filters to remove radioactive corrosion and activation products. Customers can store the filters in their fuel pool or process them for immediate shipping.

Cleaning Chamber Ensures Even Distribution A special cleaning chamber, similar to a fuel rack, holds ultrasonic transducers positioned on each face of the fuel assembly in an overlapping pattern. This configuration ensures even distribution of the ultrasonic energy into the fuel assembly. Reliable Console Controls the Process An operating console, located on the refuel floor near the edge of the spent fuel pool or reactor vessel, controls the process. The operator can easily observe the cleaning parameters and performance of the filtration unit. Underwater Filters Capture Removed Deposits. The underwater filters contain removed deposits while maintaining radiation to acceptable levels. A variety of filtration system designs are available to provide custom optimization.

BWR or PWR application
Effectively removes crud
Improves fuel flux distribution
Improves fuel utilization
Reduces radiation source term
Reduces primary system dose rate

And here is the notice of EPRI's R&D award, also on GOOGLE:

EPRI's Patented Nuclear Fuel Cleaning Technology Receives R&D 100 Award; Award Reception Slated for Oct. 20
PALO ALTO, Calif.--(BUSINESS WIRE)--Oct. 5, 2005--The Electric Power Research Institute (EPRI), three member companies, AmerenUE, Exelon Corp., and South Texas Project Nuclear Operating Co., and Dominion Engineering, Inc. (DEI) have earned a prestigious 2005 R&D 100 Award for ultrasonic cleaning of nuclear fuel, a promising new technology that safely removes deposits from irradiated fuel assemblies in nuclear power plants.
The annual awards are given by R&D Magazine for the most outstanding technology developments with commercial potential. The award reception will take place Thursday, Oct. 20 in Chicago; EPRI Senior Vice President and Chief Technology Officer Ted Marston is scheduled to attend.
"The future of the energy industry relies on pursuing innovative technologies that advance efficient, reliable and environmentally sensitive power generation and transmission," said EPRI CEO Steven R. Specker. "I applaud our team and member companies for their contribution towards this end."
The technology awarded delivers a patented process for removing corrosion products deposited on irradiated nuclear fuel pins using a unique form of ultrasonic technology. The technology was first applied at their nuclear power plants by the three EPRI member companies noted above, using equipment supplied by DEI.
"We were pleased to hear that our technology received an R&D Award," said Christopher J. Wood, a technical manager in EPRI's Nuclear Sector. "This breakthrough technology allows the full potential of current nuclear fuel designs to be achieved while maintaining excellent fuel reliability. Availability of a safe, reliable cleaning technology will also now allow utilities to further optimize fuel performance, core design, and reduce radiation fields and electricity generating costs."
This unique technology, developed in EPRI's Fuel Reliability Program, solves a significant emerging problem by removing deposits from nuclear fuel assemblies in nuclear power plants. Enhancing the performance of nuclear fuel is crucial to continue the improvement in electricity production from nuclear units. Over the past decade, nuclear power production has increased by over 20 percent, but this has placed additional demands on the fuel, as fuel temperatures have increased.
Some of the potential problems with fuel reliability result from the buildup of deposits on the surfaces of the fuel elements, which produces an insulating layer that could result in corrosion of the fuel cladding material at increased fuel pin temperatures. Until EPRI's developed technology, there was no effective way of removing these deposits during the working life of the fuel. Including early development demonstrations, this ultrasonic fuel cleaning technology has been used successfully eight times at nuclear power plants in the USA through 2004, and has been licensed worldwide. Seven additional commercial applications have taken place in 2005, including one in Spain. The technology used cleans all the fuel elements in every fuel assembly without any adverse effects. The cleaning process does not extend the schedule of routine refueling outages and is very cost-effective in pressurized water reactors. It is expected to result in a major reduction in radiation fields in boiling water reactors.
About the Electric Power Research Institute
The Electric Power Research Institute (EPRI), with major locations in Palo Alto, California, and Charlotte, North Carolina, was established in 1973 as an independent, nonprofit center for public interest energy and environmental research. EPRI brings together member organizations, the Institute's scientists and engineers, and other leading experts to work collaboratively on solutions to the challenges of electric power. These solutions span nearly every area of power generation, delivery, and use, including health, safety, and environment. EPRI's members represent over 90% of the electricity generated in the United States. International participation represents nearly 15% of EPRI's total R&D program.

And here is how NRC accepted Ultrasonic Fuel Cleaning under 50.59!

And here we have EPRI, way back in 1999, highlighting its Ultrasonic Fuel Cleaning Process at Callaway as a 1999 payoff:

And, during September 2003, Westinghouse advertised its ultrasonic fuel cleaning service. "As a result, the plant safety review committee granted the application 10 CFR 50.59 approval."
Ultrasonic cleaning means fast, safe removal of fuel-assembly crud buildup
Crud — corrosion products that accumulate on fuel surfaces — can break loose and spread to other parts of the system, causing radioactive buildup. Over time, crud that builds up on fuel surfaces becomes activated by neutrons to form radioactive nuclides, making crud cleanup a high priority.
Ultrasonic fuel cleaning can break up crud deposits during normal refueling, trapping particulates in filters for storage in the fuel pool. Designed by Dominion Engineering, Inc. (DEI), and patented by EPRI, the technique blasts crud with ultrasonic transducers.
Ultrasonic cleaning reduces the risk of fuel damage and takes a fraction of the time required by other methods. Controlling crud and other particulate inventory reduces out-of-core radiation fields and lowers radiation dosage levels.
Eliminating crud also mitigates local in-core flux supression and decreases the likelihood of axial offset anomaly (AOA) caused by lithium and boron concentrations. Ultrasonic cleaning also helps prevent crud-induced power shifts that can reduce output by as much as 20 percent.
Ultrasonic fuel cleaning was first used and verified at the Callaway plant in Missouri in 2001. After a year, no evidence of core-wide AOA was found, and early ex-core dosage was reduced significantly with no impact on critical path time. Measurements of assemblies before and after cleaning, and of particulate discharge at the filters, showed that ultrasound cuts crud deposits by about 80 percent. As a result, the plant safety review committee granted the application 10 CFR 50.59 approval.Ultrasonic cleaning is fast, too. During routine refueling, an assembly scheduled for reuse can be cleaned in as little as seven to ten minutes. Westinghouse is the first vendor to use this technique commercially. Our partnership with DEI gives utilities access to ultrasonic cleaning with minimal incremental costs.
Dominion (DEI), the inventors of Ultrasonic Fuel Cleaning, may have discussed this at a very recent meeting of PWR operators.
Sunday, July 20, 2008
PWR ALARA Association Board Meeting - Board Room
Wednesday, July 23, 2008
General PWR Session – Day 2
10:00 Ultrasonic Fuel Cleaning Process/Success – Dr. Robert Verrin (Dominion Engineering) Tentative

Thursday, April 3, 2014

Mark Leyse and PRM-50-84 at ACRS, December 15, 2011

Here is the reference:

Mark Leyse is referred to as Mark Lacey

The Members wanted to see Statements of Consideration if possible.
There was a petition from Mr. Lacey concerning the effects of crud. 132-133, 161

Official Transcript of Proceedings
Title: Advisory Committee on Reactor Safeguards
Materials, Metallurgy and Reactor Fuels
Docket Number: (n/a)
Location: Rockville, Maryland
Date: Thursday, December 15, 2011

MEMBER SHACK: There was a statement that
19 the new rule was going to address Mr. Lacey's
20 petition, and I haven't seen anything that really does
21 that. Is it something in the Statement of
22 Considerations?
23 MR. CLIFFORD: There was an analytical
24 requirement added to the rule itself that said the
25 effects of crud have to be accounted for.

MEMBER SHACK: I missed it. I missed it.
2 MR. CLIFFORD: So, any new LOCA model we
3 review they would have to say how are they accounting
4 for crud.
5 MEMBER SHACK: I missed it.
6 CHAIR ARMIJO: Paul, don't most of them
7 already do that?
8 MR. CLIFFORD: A lot of them. I can't say
9 -- there are a lot of LOCA models dating back decades
10 some of them. A lot of them do.
12 MR. CLIFFORD: I can't say that they all
13 do.
15 MR. CLIFFORD: But they may not
16 specifically account for it, but the way you measure
17 oxidation layers, sometimes you get the tenacious crud
18 that's mixed in with the oxide when you do your eddy
19 current testing.
21 MR. CLIFFORD: You get a combination of the
22 two, so when you adjust your oxidation model you're
23 kind of getting the inherent -- some inherent effects
24 of tenacious crud.
25 CHAIR ARMIJO: Yes. Yes. Is that it?

 Slide by  Tara Inverso
Rulemaking Purpose
• Revise ECCS acceptance criteria to
reflect recent research findings
• SECY-02-0057
– Replace prescriptive analytical
requirements with performance-based
– Expand applicability to all fuel designs
and cladding materials
• Address concerns raised in two
PRMs: PRM-50-71 and PRM-50-84

Here is the link to PRM-50-84:

Here is the biography of ACRS Member William Shack at the time of his appointment to ACRS on October 19,1993:

Tel. 301/504-2240 (Tuesday, October 19, 1993)


The Nuclear Regulatory Commission has appointed Dr. William
J. Shack, Associate Director of the Energy Technology Division,
Argonne National Laboratory in Chicago, Illinois, to the
independent Advisory Committee on Reactor Safeguards (ACRS).
The ACRS was established in 1957 by the Congress to advise
the former Atomic Energy Commission, and subsequently the Nuclear
Regulatory Commission, with regard to the safety aspects of
proposed and existing nuclear facilities and the adequacy of
related safety standards. The ACRS also performs such other
special assignments as the Commission may request, including the
review of related research programs.

Dr. Shack was born in 1943, in Pittsburgh, Pennsylvania. He
received his B.S. degree in civil engineering from the
Massachusetts Institute of Technology (MIT) in 1964, and his M.S.
and Ph.D. degrees in applied mechanics from the University of
California-Berkeley in 1965 and 1968, respectively.
In 1968, Dr. Shack joined the Mechanical Engineering
Department at MIT as an assistant professor. He taught there
until 1975.

He joined Argonne National Laboratory in 1975. His work has
included measurement and modeling of residual stresses, fracture
mechanics analyses of stress corrosion crack growth, assessment
of leak-before-break behavior in piping systems, and fatigue of
reactor materials.

Dr. Shack is the author or coauthor of more than 75
publications on a variety of topics in applied mechanics and
materials behavior. He has served on the NRC Piping Review
Committee and various ad hoc NRC committees to assess the impact
of environmentally enhanced material degradation on reactor
safety and operation. He has also been involved in research on
corrosion and stress corrosion cracking of candidate materials
for the Yucca Mountain, Nevada, high-level waste repository