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.
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