Some background.
The U. S. Nuclear Regulatory Commission (NRC) is managing a series of public meetings on THE PERFORMANCE-BASED EMERGENCY CORE COOLING
SYSTEMS CLADDING ACCEPTANCE CRITERIA (TITLE 10 OF THE
CODE OF FEDERAL REGULATIONS SECTION 50.46c) PROPOSED
RULE AND ASSOCIATED DRAFT REGULATORY GUIDANCE,
Tuesday June 24, 2014 through Thursday June 26, 2014.
Westinghouse presented a series of 20 slides and on June 25 I briefly commented that DG-1261 is absurd. Thus I stated, "I have modified the first line of slide 20 by substituting absurd for the remainder of the slide." Following is that slide as modified:
Westinghouse Non-Proprietary Class 3
© 2014 Westinghouse Electric Company LLC. All Rights Reserved.
10 CFR 50.46c Proposed Rule and Associated Draft Regulatory Guides
Westinghouse Electric Power Company Recommendations
David Mitchell, Fellow Engineer, Rockville, MD
June 24, 2014
Conclusion and summary on DG-1261 (Slide 20)
• Proposed breakaway corrosion testing and reporting is absurd.
On June 26, I briefly promised to submit a formal comment and I added that an appropriate reference is WCAP-12610, Appendix E, August, 1990. As readers will read read several lines below in the DOCKET of December 14, 2002, I had access to a highly censored version of proprietary WCAP-12610 at that time. However, when I again sought that report on June 27, 2014, I had no success, and NRC's PDR reported as follows;
| Subject: | RE: WCAP-12610, Appendix E, August, 1990 | ||
| Date: | 6/27/2014 1:53:03 P.M. Mountain Daylight Time | ||
| From: | PDR.Resource@nrc.gov | ||
| |||
Hi
Bob,
This
document is non-public. I found its record in ADAMS Legacy, which is below.
You would need to file a FOIA request for
it.
------------------------------------------------------------------------------------------------
Document
Title: Proprietary WCAP-12610,App E, "ZIRLO High Temp Oxidation Tests."
Withheld.
Document
Date: Aug 31, 1990
Estimated
Page Count: 18
Document
Type: "REPORTS-TOPICAL (BY MANUFACTURERS-VENDORS ETC)"; "TEXT-SAFETY REPORT"
Availability:
Non-Publicly Available
Accession
Number: 9009130156
Document/Report
Number: "WCAP-12610-APP"; "WCAP-12610-APP-E"
------------------------------------------------------------------------------------------------
Sincerely,
Mary
Mendiola
Technical
Librarian
US
NRC Public Document Room
301-415-4737
800-397-4209
From: Bobleyse@aol.com
[mailto:Bobleyse@aol.com]
Sent: Friday, June 27, 2014 2:45 PM
To: PDR Resource
Subject: WCAP-12610, Appendix E, August, 1990
Sent: Friday, June 27, 2014 2:45 PM
To: PDR Resource
Subject: WCAP-12610, Appendix E, August, 1990
Hello:
10
years ago or more I found the subject documentation, WCAP-12610, Appendix E, August,
1990. Today I am having no luck. I believe that PDR experts
may find this.
Thank
you,
Bob
bobleyse@aol.com
DOCKET
(6 1 F 511 s3 )
December 14, 2002
Petitioner's Responses to Comments by Westinghouse and NEI
DOCKETED
USNRC
December 16, 2002 (4:30PM)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF
On page 2 of the attachment to its comments dated October 22, 2002, Westinghouse states, "More recently, Westinghouse conducted tests with pure oxygen instead of steam." With difficulty, the Petitioner located a reference that apparently describes this work, WCAP-12610, Appendix E, August, 1990. Only a limited portion of the report is available to the public and it is classified by Westinghouse as a proprietary report. The high temperature oxidation tests were performed by Nuclear Electric, plc in the United Kingdom. Twenty four ZIRLO alloy and six Zr-4 samples were tested at temperatures ranging from 1832F to 2372F. The cylindrical tubing specimens were approximately 0.6 inches long and were from production grade 17x1 7 tubing.
Appendix E candidly discloses: "Since, particularly at high temperatures, the self heating of the specimen results in its being at a higher temperature than its surroundings, any temperature measured will be equal to or lower than that of the test specimen." In other words, in order for the investigators at Nuclear Electric to prevent runaway from the heat of reaction at high temperatures (self heating) it was necessary to maintain the surroundings at a substantially lower temperature than the specimen. In this manner, the heat loss by radiation to the relatively cold surroundings compensated for the heat produced by chemical reaction with the pure oxygen. This then leads to the question: What if Nuclear Electric had conducted the investigation with a 17x 17 arrangement of ZIRLO or Zr-2 tubes captured within a Zircaloy-4 structural grid with ZIRLO thimbles as depicted in FIGURE 2-1 of WCAP-12610? The answer is that the assembly would have rapidly been destroyed in runaway if a sufficient flow of oxygen had been maintained.
The oxidation tests of the ZIRLO alloy and Zr-4 samples were conducted within a very "quiet" oxygen atmosphere. The apparatus was extremely delicate. The investigators reported, "Pure oxygen gas was used as the oxidant rather than steam. It is believed that, if steam were used, condensation on the suspension wire could invalidate the weight gain measurements." From this it may be inferred that the apparatus was certainly insufficiently robust to accommodate the turbulent thermal hydraulic conditions of LOCA. The oxygen supply system and flow rates are not disclosed in Appendix E, but it must have been a very tender application of oxygen to not upset the suspension wire and the weight gain apparatus.
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