Saturday, July 26, 2014

Saturday, July 19, 2014

risks have become increasingly evident to the public

the 2011 mass meltdown/blow-outs at Japan’s Fukushima Daiichi power station 

reference Enformable July 19, 2014

Thursday, July 17, 2014

Thermal Runaway and Baker-Just

Following is a copy of my blog of August 1, 2010.  I'll submit related documents as a public comment on proposed 10 CFR 50.46c.

Sunday, August 1, 2010


Thermal Runaway and Baker-Just

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.

So, how did this fall through the cracks?
The Baker-Just equation was published by the AEC during 1962; long before NRC was established during January 1975. Although it has a very weak foundation, the Baker-Just equation has survived to this day because it is convenient for licensing of nuclear power plants. This equation was first applied to the licensing of nuclear power plants during the era of the AEC when “regulators” were very strongly encouraged to expedite the role of what was then called atomic energy. The AEC, under the direction of the Congressional Joint Committee on Atomic Energy, worked very closely with the industry’s lobbying group then called the Atomic Industrial Forum. The lobbying group for today’s nuclear power industry is named the Nuclear Energy Institute (NEI).

It is unlikely that the nuclear power industry has ever commissioned a study of the roots of the Baker-Just correlation. However, today’s nuclear power industry fiercely defends Baker- Just. This defense is well documented by the NEI in its very recent comment 16 opposing PRM-50-93, “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,” refer to ML101040678, Industry Comments on Petition for Rulemaking (PRM-50-93); Multi-Rod (Assembly) Severe Fuel Damage Experiments. Docket ID NRC-2009-0554, April 12, 2010.

The NRC also fiercely defends Baker-Just. In its analysis of PRM-50-76, “The Baker-Just correlation (Reference 4) 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.” refer to Memo to Matthews/Black-Technical Safety Analysis of PRM-50-76, A Petition for Rulemaking to Amend Appendix K to 10 CFR Part 50 and Regulatory Guide 1.157 - ML041210109, April 29, 2004.


Contrary to the exceptionally firm consistency between the NEI and NRC
evaluations 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 never admitted 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. Certainly, the NRC evaluators who produced ML041210109, April 29, 2004, should have been aware of the many references that are cited in PRM-50-93.




And, the following Letter from NRC to your blogger, ML100950085, documents in detail how Baker-Just fell through the cracks. NRC did not even have the key references in its files until your blogger persisted in demanding the key references. Click on the following to enlarge and use your back arrow to return here.







So, the above letter reveals:
  • that your blogger pursued the roots of Baker-Just,
  • that NRC did not believe that those roots constituted a significant part of its basis for denying PRM-50-76,
  • that those roots were not available in NRC files when it evaluated PRM-50-76,
  • that those roots were not transferred to NRC when it was created in 1974,
  • that NRC finally acquired and placed those roots in ADAMS during April 2010,
  • that NRC promptly informed your blogger when those roots became available in ADAMS.
It is interesting that NRC did not believe that those roots constituted a significant part of its basis for denying PRM-50-76 even though those roots were not then available in NRC files.
Furthermore: I'm adding the following on August 8, 2009.
When the NRC placed document BMI-1154 into ADAMS during April 2009 the document was incomplete. I recently found this out when I was seeking the references on page C-48. I contacted BMI at Pacific Northwest Laboratories (PNL) and I was told that there was no page C-48, "No, it does not have page C-48." So I copied and e-mailed the table of contents and I replied, "I wonder how that vital list of references vaporized." Next PNL told me on 8/4/2010, "Bob, Try this version. I found it on Energy Citations Database (www.osti.gov/energy/citations). It has C-48. Thanks. Cheryl Wiborg." I sent that information to the NRC and the complete copy was placed into ADAMS. NRC thanked me on 8/5/2010 as follows: "The NRC version in ADAMS has been updated (ML100570218). It may take a couple of days to copy to the NRC public server, but it has been fixed. Thanks for locating a complete copy of BMI-1154. John Boska, Indian Point Project Manager, NRR/DORL, U.S. Nuclear Regulatory Commission." And here is the latest in ADAMS, it has 125 pages, prior to the correction by Boska it had only 98 pages.
Report BMI-1154, "Studies Relating to the Reaction Between Zirconium & Water at High Temperatures." ML100570218 1957-01-03 125
So, I'll now add item 7 to the prior bulleted list because the above paragraph reveals:
  • that your blogger studied BMI-1154 and effected corrections, although he did not immediately find the omissions in the ADAMS copy.

Baker-Just and Sparklers (My blog of July 4, 2010}

  
Following is copied from my blog of July 4, 2010. 

BAKER-JUST and SPARKLERS (Single Rods ain’t Bundles)

I've discussed the 2200 degree Fahrenheit game that NRC plays; a game that is derived from the single rod tests that are referenced by Baker-Just. With bundle tests, runaway starts at much lower temperatures.

Analogies have weaknesses. However, the following from the Wall Street Journal is interesting. A bundle of sparklers yields wild behavior.



This augments the above

Thursday, July 10, 2014

Monticello: 13% +, Wild from Enformable

"Over the last five years, Xcel has upgraded reactor pumps, the turbine and other components in order to increase the power output by 13% and keep the plant online for at least twenty more years.  Despite the ongoing upgrades, the plant will not likely operate at the increased output until 2015 or 2016."
Posted: 09 Jul 2014 06:18 AM PDT
http://enformable.com/wp-content/uploads/2014/07/Monticello-nuclear-power-plant.jpg
A group of nuclear and financial experts hired by utility regulators in Minnesota found that management at Xcel Energy did not completely understand or adequately plan for replacing major reactor components at the Monticello nuclear power plant.  The investigation found that Xcel did not properly manage contractors and also blamed the NRC for some of the delays that lead to the cost overruns.
Mark Crisp, one of the nuclear experts hired by the state Commerce Department gave his assessment of the way Xcel managed the project in written testimony saying, “The confusion, contradictory information to the NRC and start-stop process suggest management indecisiveness and strategic planning that, at best, was not adequately thought out.”
According to Dave Sparby, chief executive of Xcel’s operations in Minnesota, the utility will file a reply to the issues raised by the investigation within the next month.
Over the last five years, Xcel has upgraded reactor pumps, the turbine and other components in order to increase the power output by 13% and keep the plant online for at least twenty more years.  Despite the ongoing upgrades, the plant will not likely operate at the increased output until 2015 or 2016.
The state investigation was launched in 2013 by the Public Utilities Commission after it was determined that the project would greatly exceed cost projections.
In 2008, Xcel estimated that it would cost some $320 million to replace major components that would allow the plant’s life to be extended and also increase the power output, but by 2013 the price tag had more than doubled to $665 million.  It is estimated that the final price tag will be almost $750 million, the largest cost overrun of any public utility project in Minnesota.
Xcel is pushing utility regulators to make ratepayers liable for the entire cost of the upgrade project including the cost overruns by requesting for a 10.4% rate hike over two years.  It is likely that Xcel will push for even more rate increases in the coming years.  If ratepayers are not left on the hook for the upgrade overages, Xcel’s earnings could end up suffering instead.
Source: Star Tribune
The post Xcel Energy management blamed for Monticello cost overruns appeared first on Enformable.

Sunday, July 6, 2014

Information of potential regulatory interest to the NRC

 In its Confirmatory Order of May 14, 2007, NRC observed:
Specifically,
FENOC’s commitments are designed to
ensure that information of potential
regulatory significance is recognized by
FENOC and FirstEnergy employees and
communicated to the NRC in a timely
and effective manner.

I'm trying to get NRC to open up.  So far, no response to my e-mail requests.


Subject: Fwd: Please research and respond
Date: 6/11/2014 8:20:26 A.M. Mountain Daylight Time
From: Bobleyse@aol.com
To: OPA.Resource@nrc.gov


Please reply:

 
The complete order is at:


The order includes seven actions and here is number five:
5. The Licensee shall provide an
Operating Experience (OE) document to
the nuclear industry through the
industry’s established OE process. The
document shall discuss the issues
surrounding the NRC’s May 14, 2007,
Demand for Information, including the
review of technical reports prepared as
part of a commercial matter. The OE
document shall be provided to the
nuclear industry, and to the Director,
NRC Office of Enforcement, within 30
days of the date of this Order.

So, OPA, please send me an ML number (ADAMS) for the Operating Experience (OE) document that is demanded in 5. above. 

From: Bobleyse@aol.com
To: OPA.Resource@nrc.gov
Sent: 5/13/2014 11:29:39 A.M. Mountain Daylight Time
Subj: Please research and respond

The complete order is at:


The order includes seven actions and here is number five:
5. The Licensee shall provide an
Operating Experience (OE) document to
the nuclear industry through the
industry’s established OE process. The
document shall discuss the issues
surrounding the NRC’s May 14, 2007,
Demand for Information, including the
review of technical reports prepared as
part of a commercial matter. The OE
document shall be provided to the
nuclear industry, and to the Director,
NRC Office of Enforcement, within 30
days of the date of this Order.

So, OPA, please send me an ML number (ADAMS) for the Operating Experience (OE) document that is demanded in 5. above. 

Since I have had no response, I'm asking for more. Of course, I would have anyway. Here is my latest email:

Subject: Did any person request a hearing?
Date: 7/6/2014 1:39:59 P.M. Mountain Daylight Time
From: Bobleyse@aol.com
To: OPA.Resource@nrc.gov

The complete Confirmatory Order is at

The Confirmatory Order advises, "Any person adversely affected by this Confirmatory Order, other than the Licensee, may request a hearing within 20 days of its issuance."

So, OPA, please tell me if any person requested a hearing within 20 days of its issuance."
 

Saturday, July 5, 2014

Tuesday, July 1, 2014

10 CFR 50.59, Draft Rule Language for 10 CFR 50.46c, Appendix K to Reg Guide?

Critical seeds were planted during the  public meetings that NRC hosted on June 24-26, 2014, regarding 50.46c.  More later.