DD-97-15, Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request

Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request

ML20148M050
Person / Time
Site:	Palisades, Point Beach, Arkansas Nuclear, 07201007
Issue date:	06/18/1997
From:	Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	DON'T WASTE MICHIGAN, LAKE MICHIGAN FEDERATION
References
2.206, DD-97-15, IEB-96-004, IEB-96-4, NUDOCS 9706230327
Download: ML20148M050 (32)

Text

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DOCKETED USHRC l UNITED STATES OF AMERICA NUCLEAR REGULAiORY COMMISSION OFFICE OF SECRETARY OFFICEOFNUCLEARMATERIALSAFETYANDSADQgg G & SERVICE Malcolm R. Knapp. Acting Director ANCH In the Matter of )

t )

WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266.

(Point Beach Nuclear Plant) ) 50-301, 72-5 >

)

CONSUMERS POWER COMPANY ) Docket Nos. 50-255. i (Palisades Nuclear Plant) ) 72-7

)  :

ENTERGY OPERATIONS. INC. ) Docket Nos. 50-313.

(Arkansas Nuclear One) ) 50-368. 72-13

)

SIERRA NUCLEAR CORPORATION ) Docket No. 72-1007

)

) (10 CFR 2.206)

CIRECTOR'S DECISION UNDER 10 CFR 2.206 I. g t0 DUCTION On October 18.105 Don't Wasu .' chigan and the Lake Michigan Federation (Petitioner. filed a Petition pursmnt to Section 2.206 of Title 10 of the Code of Federa' Regulations (10 CFR 2.206) requelting that the U. S. ,

Nuclear Regulatory Commission take the following action:

Prohibit loading of Ventilated Storage Casks (VSC-24s) un'.'1 the ,

certificate of compliance (C0C). the safety analysis report (SAR), and '

the safety evaluation report (SER) are amended following 'n independent.

third-party review of the VSC-24 design, to address conc tri s raised by J the Petitioners' engineering consultant. Dr. Rudolf Hausb r The Petition has been referred to me pursuant to 10 CFR 2.206. By j

letter dated December 10. 1996, to Dr. Mary Sinclair and Ms. Eleanor Roeme; .

on behalf of the Petitioners. NRC acknowledged receipt of the Petition and {

provided the NRC staff's determination that the 'etition did not require 7- 5-Y

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1 mediate action by the NRC. Notice of receipt was published in the Federal Reaister on January 13. 1997 (62 FR 1783).

[ On the basis of the NRC staff's evaluation of the issues and for the

f reasons given below. I have determined that the Petitioners' request should be kh g denied.

II. BACKGROUND On May 28. 1996, a hydrogen gas ignition occurred during the welding of the shield lid after spent fuel had been loaded into a VSC-24 at the Point Beach Nuclear Plant. The hydrogen was formed by a chemical reaction between a zinc-based coating (Carbo Zinc 11) and the borated water in the spent fuel pool. On June 3.1996, the NRC issued confirmatory action letters (CALs) to those licensees using or planning to use VSC-24s for dry storage of spent nuclear fuel, i.e.. licensees for Point Beach Nuclear Plant. Palisades Nuclear Generating Plant, and Arkansas Nuclear One (AND). The CAL issued 10 the licensee for ANO was suppleraented on June 21. 1996, and the CALs issued to the licensees for Point Beach and Palisades were supplemented on June 27. 1996.

The f,ALs. as ripplemented. documented the licensees' commitments not to load or unlued a "S1-24 without resolution of material compatibility issues identified in a forthcoming generic communication and subsequent NRC confirmation of corrective actions taken by the licensees. The generic communication was issued on July 5.1996, in the form of NRC Bulletin 96-04

" Chemical. Galvanic, or Other Rea . :.ns in Spent Fuel Storage and Transportation Casks." NRC Bulletii 96-04 notified addressees about the potential for adverse chemical, galvanic, or other reactions among the materials of a spent 7. . Sw.o0e or transportation cask. its contents, and tne environments the cask may encounter during use. The actions requested in

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. Bulletin 96-04 included reviewing the cask materials for potential adverse ,

reactions. evaluating the short-term and long-term effects of any identified reactions, and determining the adequacy of cask operating procedures to minimize the consequences of any identified reactions. The NRC staif hos acknowledged that the event demonstrated that the cask vendor's (Sierra Nuclear Corporation) SAR for the VSC-24 and related NRC review, as documented in the NRC staff's SER did not adequately address the use of a zinc-based coating and its reaction with the acidic water in spent fuel pools.  !

In response to Bulletin 96-04 and to subsequent NRC staff inquiries the ,

licensees for ANO. Point Beach, and Palisades submitted to the NRC evaluations of possible material interactions and the effects of such interactions on cask performance and operation. The licensees also submitted information on the '

operating controls and limits that were implemented to prevent hazardous conditions which may result from adverse material interactions. The operating I controls and limits included controls for the environments that the casks i

encounter during use, requirements for inspections and environmental sampling, and additional precautions for various cask operations.

The NRC staff evaluated the responses submitted by the licensee for ANO.

As documented in the staff's safety evaluation dated December 3.1996, the staff determined that the licensee's submittals provided the necessary level of confidence that the VSC-24 can be used to safely store spent fuel over the 20-year period of the certificate. The staff also determined that the operating controls and limits proposed by the licensee are acceptable and satisfy regulatory requirements. By a separate letter, also dated December 3.

1996. 'oe nerf informed the licensee for AND that its corrective actions had

been verified by inspections performed by the NRC staff. Shortly thereafter, the licensee initiated cask loading activities.

The NRC staff also evaluated the responses submitted by the licensees for Point Beach and Palisades. As documented in the staff's safety evaluations dated respectively April 6.1997, and June 12. 1997, the staff-l 1

determined that the licensees' evaluations and proposed operating control.s and limits are acceptable and satisfy regulatory requirements. However, the CALs placed on Point Beach and Palisades'still remain in place until an NRC l

inspection is performed to verify that the licensees' corrective actions are j 1

properly implemented.

III. DISCUSSION The Petition requests an NRC order to users of VSC-24s not to load additional casks until: (1) the C0C. SAR. and SER are amended to contain operating controls and limits to prevent hazardous conditions: (2) an independent third-party review team has examined the safety issues raised b."

the Petitioners: (3) the potential impacts of all material aspects of the l

casks have been fully assessed: (4) there is experimental verification of temperature calculations and heat transfer assessments and other design assumptions; and (5) the safety of the material coatings on components and l structures has been justified.

t Item 1- Prohibit Loadino of VSC-24s Pendino Amendment of Documents l

As noted in the NRC letter to the Petitioners'on December 10,1996, the -

l Petitioners' request to amend the COC SAR, and SER is similar to a request l l made by the Citizen's Utility Board (CUB) in a Petition dated Seotember 30.

i 1996. The NRC staff denied the CUB petition on April 17, 1997, for the

4 reasons that are identical to the reasons stated here in denying the first part of the Petitioners' request.

The circumstances set forth above made clear that, following the event at Point Beach, the NRC staff recognized that additional evaluation of potential material interactions was warranted for all spent fuel transportation and storage casks. In regard to the VSC-24, the event and subsequent NRC inspections made it apparent that actual changes in the operating procedures or the design of the cask would be necessary. CALs were issued to confirm licensees

• commitets to refrain from loading VSC-24s pending completion of the NRC staff's review of the responses to Bulletin 96-04 and verification of the associated corrective actions. As discussed, the CALs established a process by which the NRC staff could obtain confidence that operating controls and limits to address potential hazardous conditions are developed and implemented by each licensee using VSC-24s.

In particular, the CAL process ensures that licensees will incorporate the necessary operating controls and limits into revised plant procedures.

Moreover, under existing NRC requirements, the licensee must adequately implement those revised procedures. For this reason, no changes to the C0C or SAR are needed to ensure that enforceable operating controls and limits are in place to address potential hazardous conditions during the loading or unloading of a cask. Further, as previously indicated, the NRC staff has documented the process, information, and results of its review of the licensees' responses to Bulletin 96-04 for use of the VSC-24 at ANO, Point Beach, and Palisades in safety evaluations available for public review.

Although the actions taken as part of the CAL process provide adequate assurance that technical and regulatory compliance issues raised by the event

6-at Point Beach will be resolved before a licensee loads or unloads a VSC-24 the NRC staff agrees with the Petitioners that it would be beneficial if the SAR and other licensing basis documents accurately describe the identified chemical reaction and the associated operating controls and limits. The NRC l

, staff is currently reviewing a proposed amendment to the SAR and C0C for the VSC-24 design and will ensure that the info'rmation related to the identified chemical reaction and associated operating controls is adequately addressed in i the appropriate licensing-basis documents. In addition, the NRC staff is processing a petition for rulemaking. PRM-72-3 that may lead to additional updating of independent spent fuel storage installation SARs and the inclusion of information on operating controls and limits implemented as a result of the event at Point Beach. However, the previously discussed controls to be implemented by the licensees and verified by the staff as part of the CAL process, and the enforceability of those controls under existing NRC requirements, make it unnecessary to require revision of the specific licensing documents cited by the Petitioners as a precondition for resuming cask operations at the facilities using VSC-24s. Therefore, there would be no regulatory basis for granting the first part of the Petition to require amendment of the C0C. SAR or SER before further loading of VSC-24s.  ;

Item 2- Prohibit loadino of VSC-24s Pendina Indeoendent. Third-Party Review 1

Petitioners request the NRC to prohibit loading of VSC-24s until the C0C, SAR and SER are amended following an independent, third-party review to

( address concerns raised by the Petitioners. The NRC staff performed a review l of the VSC-24 design prior to certification in 1993. As a result of the review, the staff determined that the design and operation of the cask system 1 is in compliance with 10 CFR Part 72. The staff also concluded, with a high I

degree of assurance, that the VSC-24 will safely store spent fuel over the 20-year period of the certificate. Notwithstanding the staff's review and determination in 1993, the Petitioners are claiming that a new. independent review is needed before further VSC-24s are loaded.

While the event at Point Beach revealed the need for additional evaluation by licensees and NRC of potential material interactions in the VSC-24 (and other transportation and storage casks), the actions already I taken, in the staff's judgment provide an adequate response. In particular. )

Bulletin 96-04 was issued to request additional information from licensees i using the VSC-24 on material interactions and compatibility in the VSC-24 and on the orrective actions implemented. The NRC staff then received and l reviewed the responses submitted by the licensees for ANO. Point Beach. and Palisades. The staff's reviews (as well as the licensees') have been exhaustive and were performed by an inter-disciplinary team of engineers knowledgeable in materials corrosion, metallurgy. chemistry, structural engineering, heat transfer, nuclear engineering, and other technical fields l needed to perform the review. The results of the staff's reviews, including the necessary corrective actions, are documented and justified in the staff's i December 3. 1996. April 8. 1997, and June 12. 1997, safety evaluations. These corrective actions include: cleanliness checks before placing the cask in the spent fuel pool, venting and monitoring of the air space beneath the VSC-24 shield lid during welding or cutting activities, discontinuing welding or cutting should the hydrogen concentration exceed 0.4% by volume (10% of the minimum amount necessary for a combustible concentration), and sampling the boron concentration in the spent fuel pool and multi-assembly sealed basket (MSB) water. While the staff agreed that the corrective actions were

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necessary to prevent hazardous conditions during the loading and unloading of VSC-24s. the information submitted by the Petitioners does not raise any new ,

issues or provide any reason for the staff to question its conclusion that the VSC-24 will safely store spent fuel over the 20-year period of the .

certificate.

In reaching this conclusion, the NRC staff evaluated the specific concerns raised by the Petitioners related to the design of the VSC-24. The

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staff believes that these concerns have already been addressed by the recent evaluations submitted in response to Bulletin 96-04, by information submitted to NRC to support the certification of the VSC-24 design in 1993. or by other information submitted in support of NRC review and inspection activities.

Each of the Petitioners' specific concerns is addressed below.

(i) The Petitioners claim that the cask design allows for fuel elements to be in contact with the zinc primer creating a galvanic couple which will ,

l accelerate the corrosion of the zinc. The NRC staff considered galvanic  !

effects between the Zircaloy fuel rods and the Carbo Zinc 11 coating. The i i

staff agrees that a galvanic effect would increase the corrosion rate of the l zinc. with a corresponding increase in the hydrogen gas generation rate, as  !

the zinc in the Carbo Zinc 11 coating is polarized to a more active potential.

However, in the VSC-24 design, several factors reduce the amount of zinc l polarization such that tiere would not be a significant increase in hydrogen generation. One factor is ths contact resistances between the stainless steel fuel assembly end-fittings and the Zircaloy fuel rods and between the end-fittings and the Carbo Zinc 11 paint. Another factor is the geometry of the VSC-24 and the fuel assemblies. The fuel assemblies are placed in fuel storage sleeves with a clearance of approximately 0.1 inch to 0.5 inch between l

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9 the sides of the fuel assembly and the sleeves. This clearance and the physical design of the fuel assemblies create shielding between the fuel rod surfaces and the Carbo Zine 11 coating. This shielding effectively reduces the galvanic action between the Zircaloy fuel rods and the Carbo Zinc 11

, coating. The Zircaloy fuel rods could contact the Carbo Zinc coated sleeves i if the fuel assembly is not centered in the storage sleeves or if the fuel rods are bowed. However, the shielding effect and small Carbo Zinc /Zircaloy contact area would still prevent significant galvanic action. Hydrogen j concentration measurements made at Point Beach and the hydrogen monitoring I performed at ANO during loading of a VSC-24 in December 1996 (NRC Inspection Report Nos. 50-313/96-25 and 72-13/96-02) support the conclusion that significant galvanic action between the Zircaloy and zinc coating, and hence.

increased hydrogen generation, is not occurring in the VSC-24. In addition, even if there was an increase in hydrogen generation because of the galvanic  !

action, the staff has determined that the controls implemented by the  !

licensees for AND and Point Beach would prevent accumulation of a combustible concentration of hydrogen and its ignition. The staff will also review and i verify the adequacy of the controls implemented by the licensee for Palisades.

(ii) The Petitioners claim that there were numerous discrepancies in the responses to Bulletin 96-04. As noted, the NRC staff completed its review 4 of responses for ANO. Point Beach, and Palisades. The staff found these responses to be acceptable and found no discrepancies of concern. There were minor differences in the operatihg controls implemented at the three facilities. However, the staff reviewed these controls and concluded that all three sets of controls are adequate to preclude hazardous conditions during cask operation.

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l (iii) The Petitioners claim that the epoxy coating applied to the exterior of the Multi-Assembly Sealed Basket (MSB) could not withstand the l temperatures developed during long-term storage. Technical data on the type of epoxy coating used on the HSB were provided by the licensees in their l

responses to Bulletin 96-04. The data show that the epoxy is temperature-resistant up to 350*F. The SAR for the VSC-24 (which the staff reviewed and accepted prior to certification in 1993) shows that under normal or off-normal storage conditions. the temperature of the HSB exterior will not exceed 300*F.

for the maximum allowable heat load of 24 kW and, therefore, will not degrade the epoxy. l Civ) The Petitioners claim that the low-temperature specification in ,

the COC for moving the VSC-24 MSB was not properly translated,to the HSB shell material compositions. Low-temperature embrittlement of the MSB shell material was evaluated by the NRC staff during its safety review before certification of the VSC-24. The composition of the MSB shell material (SA516. Grade 70 carbon steel) is specified in the American Society for i Mechanical Engineers. Boiler & Pressure vessel Code.Section II. SA-516.

" Specification for Pressure Vessel Plates. Carbon Steel, for Moderate- and ,

Lower-Temperature Service." The impact testing requirements for the MSB material are found in American Society for Testing and Materials Specification A370 (ASTM A370). " Methods and Definitions for Mechanical Testing of Steel Products." As specified in the C0C. SER, and SAR. each MSB shell material must be shown, during fabrication by Charpy test per ASTM A370. to have '

15 ft-lbs of absorbed energy at -50*F. Further, movement of the MSB must occur only at ambient temperatures of 0*F or above to avoid potential brittle l

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fracture of the MSB material'. The NRC staff considers the 50*F temperature difference to provide sufficient margin because it places the MSB material at a temperature that is significantly above the temperature where brittle fracture could occur. It should also be noted that the temperature of the HSB shell itself would actually be substantially higher than the ambient temperature (e.g., 20*F for 25-year-old fuel), thus providing an even higher margin. In addition, it is highly unlikely that any MSB movement activity would take place at temperatures below 0*F.

(v) The Petitioners claim that zinc-steel interaction at 800*F to 1000*F and possible steel embrittlement over a 20-year period were not considered. Zinc-steel interaction at the 800*F to 1000*F temperature range was not considered and is not a concern because, as documented in the VSC-24 SAR, temperatures in the MSB will not reach 800*F during storage. Maxiinum temperatures would be 688'F under normal conditions and 708'F under off normal conditions, for the maximum allowable heat load of 24 kW. Furthermore, over the storage pe'iod, the temperatures within the MSB will continue to decrease as the heat load decreases due to the decay of the spent fuel.

(vi) The Petitioners claim that the effect of molten zinc on Zircaloy has not been verified experimentally. The NRC staff evaluated the durability and behavior of the zinc coating under the range of storage temperatures. The presence of molten zinc is not expected under the storage temperatures and

'At Palisades, the licensee has administratively set a minimum ambient temperature of 10*F for moving the first four MSBs (CMSB-01 through 04) to be loaded because the shell material for these MSBs does not have 15 ft-lbs of absorbed energy at -50*F. Rather, these MSBs have 15 ft-lbs of absorbed energy at -40*F. Thus, to retain the 50*F temperature margin, the licensee has restricted movement of these four MSBs to an ambient temperature of 10*F or above. The NRC staff has reviewed and approved the licensee's administrative limit. as documented in NRC safety evaluation dated September 26, 1995.

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i conditions, thus the effect of molten zine on Zircaloy is not a concern. l However, as documented in the staff's safety evaluations for AND (dated l December 3,1996), Point Beach (dated April 8.1997), and Palisades (dated I June 12. 1997). the staff did evaluate the potential interaction between zinc i

vapor and Zircaloy and the effect of this interaction. Based on the i

information provided in the responses to Bulletin 96 04, the staff concluded that the potential interaction between zinc vapor and Zircaloy presented no I imediate or long-term safety concern for the spent fuel stored in the VSC-24.

(vii) The Petitioners claim that the vacuum-drying process does not seem to have been experimentally verified. Vacuum drying is a well-established, widely used method for removing moisture from spent fuel storage and transportation casks. The process used for the VSC-24 is a common process, which the NRC staff evaluated and determined to be acceptable during the safety review before certification in 1993. Inthestaff'sjudgment, experimental testing to verify a well-established process is unnecessary.

(viii) The Petitioners claim that the thermal analyses for the VSC-24 have not been experimentally verified. The thermal analyses for the VSC-24 ,

1 contained conservative key assumptions. including a total heat generation of l 1 kW per assembly (a total of 24 kW per cask). This assumption is l conservative because it is highly unlikely that each assembly loaded in the cask will generate 1 kW of heat. In addition, the assembly and total cask j heat loads will continually decrease over time as the spent fuel decays. In light of the conservatisms in the thermal analyses, the staff does not see the l l

need for requiring experimental verification of the VSC-24 thermal analyses.

Nevertheless, the COC requires that a thermal test be performed on the first VSC-24 to be loaded. The purpose of the test is to measure the heat removal  !

performance of the VSC-24 system. The licensee for Palisades performed such a test and summarized its results in a letter to NRC dated June 10. 1993. The >

temperatures nieasured during the test were lower than the predicted  !

temperatures. The results thus indicate that the VSC-24 performs its intended l heat removal function. The thermal test at Palisades was performed with a 12 kW heat load. To date, no VSC-24s have been loaded with greater than 12 kW  !

heat load. As required by the C0C. the thermal test must be perfomed for the i first cask to use any higher heat loads, up to 24 kW.

The NRC staff believes, based on the foregoing, that an independent, third-party review is not warranted by the Petitioners' specific concerns.

However. NRC review activities relating to the VSC-24 will nonetheless .

t continue. In particular. NRC inspection activities at the facilities operated  ;

by the licensees the VSC-24 vendor, and the VSC-24 fabricators may lead to additional reviews of the VSC-24. In addition, the staff is currently t reviewing a proposed amendment, submitted by the VSC-24 vendor, to the SAR and CDC for the VSC-24 design. This review will be performed in accordance with ,

the staff's " Standard Review Plan for Dry Cask Storage Systems' (NUREG-1536) to ensure the thoroughness, quality, and consistency of the review. Where i relevant, recent operational, technical, and safety issues related to the VSC-24 design will be considered by the staff in this review 2.

In addition it is my judgment that the NRC staff is fully capable of fulfilling the responsibility for reviewing, approving, and certifying dry cask storage systems to be used under 10 CFR Part 72 which, by law. belongs to i

! 'Recent concerns relating to the MSB closure welds, as documented in NRC Inspection Report No. 72-1007/97-204, dated April 15. 1997, may result in further evaluations of the VSC-24 design and if necessary, appropriate regulatory action to ensure continued safe use of the VSC-24.

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the NRC. In conducting its review, the NRC staff must have reasonable assurance that the cask system will safely store spent fuel over the period of the certificate. Further the staff will assign the necessary resources and expertise to perform such reviews. When the NRC staff lacks either the resources or expertise to perform all or portions of the review in-house. the NRC may, and does, supplement its wn ranks by using outside specialists.

Item 3- Prohibit Loadino of VSC-24s Pendina Assessment of Cask Materials

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Petitioners request the NRC to prohibit loading of VSC-24s until the  !

potential impacts of all material aspects of the casks have been fully assessed. As previously stated. Bulletin 96-04 was issued to request inform 6 tion on material interactions and compatibility in spent fuel storage i and transportation casks. In response to this request. the licensees for ANO.

Point Beach. and Palisades submitted evaluations on possible material i interactions in the VSC-24 and the effects of such interactions on cask performance ar.d operation. The only significant material interaction identified was between the zint-based coating and the borated spent fuel pool  !

water. As previously discussed, the operating controls and limits put in >

place by the licensees provide an adequate level of confidence to prevent the  ;

adverse effects of this interaction (generation and possible ignition of hydrogen gas and possible depletion of boron in the water). The staff reviewed these evaluations and, based on the information provided, concluded that none of the identified material interactions would adversely affect the VSC-24's ability to safely store spent fuel over the 20-year period of the l

certificate. The results of the staff's reviews are documented in the staff's

• December 3.1996. April 8.1997, and June 12, 1997, safety evaluations for ANO. Point Beach and Palisades, respectively. l

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Item 4: Prohibit loadina of VSC-24s Pendina Exoerimental Verification of Thermal and Other Desian Assumotions i

Petitioners request the NRC to prohibit loading of VSC-24s until there j is experimental verification of temperature calculations and heat transfer  !

assessments and other design assumptions. The thermal and other engineering and design analyses for the VSC-24 contained conservative key assumptions which are discussed in the SAR and SER. In addition, the acceptance criteria for these analyses have margins of safety that the staff considers to be l sufficient. In light of the conservatisms and safety margins in the thermal i

and other analyses the staff does not see the need for requiring experimental verification of the thermal and other design assumptions used in evaluating l the VSC-24. I Item 5: Prohibit Loadina of VSC-24s Pendina Assessment of Material Coatinos Petitioners request the NRC to prohibit loading of VSC-24s until the safety of the material coatings on components and structures has been justified. As discussed above material interactions within the VSC-24 and i

their effect on cask operations and performance were evaluated by the licensees in response to Bulletin 96-04 and reviewed by the staff.

Specifically, the licensees evaluated, and the staff reviewed. tha use of the zint-based coating its reaction with borated water and other casi environments. and the effect of the reaction or reaction products on cask operations and on the performance of the various cask components and structures. The staff concluded that use of existing VSC-24s with the zinc-based coating is acceptable in light of the operating controls and limits for preventing hazardous conditions that must be properly implemented by licensees during cask loading and unloading. Based on the information provided. the

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j j' staff also concluded that neither the coating itself, nor its reaction with  !

borated water or other cask environments, would have an adverse effect on the i f performance of the cask components or structures during the period of spent l fuel storage.

l IV. CONCLUSION  !

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j The Petitioners requested that the NRC prohibit loading of VSC-24s.until  !

1 the COC, SAR, and SER are amended to contain operating controls and limits to L  !

prevent hazardous conditions. After reviewing each of the Petitioners'  !

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j- . claims. I conclude that, for the reasons discussed above, no adequate basis i i

exists for granting the Petitioners

• request to prohibit licensees

• use of the l

1 i VSC-24 for dry cask storage of spent nuclear fuel at Palisades, Point Beach,

} or AND pending: (1) revision of the SAR. SER, and C0C for the VSC-24 to j f contain operating controls and limits to prevent hazardous conditions: (2) an l 1

j independent third-party review to examine the safety issues raised by the  ;

i Petitioners: and (3) experimental verification of temperature calculations and  :

j heat transfer assessments and other design assumptions. Furthermore. I <

, conclude that the Petitioners' other two requests, an assessment of potential j i

impacts of VSC-24 material aspects and a safety justification of material  !

l coatings on components and structures, have already been fulfilled through the i staff's review of the licensees' responses to Bulletin 96-04.  !

A copy of this decision will be filed with the Secretary of the  !

Commission for the Commission ;o review in accordance with 10 CFR 2.206(c).

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As provided by this regulation, this decision will constitute the final-l i

action of the Comission 25 days after 1:;suance, unless the Comission, on its j own motion, institutes a review of the decision within that time. '

Dated at Rockville Mar.yiand, this /[^ day ofInc. 1997 l FOR 1HE NUCLEAR REGULATORY COMMISSION fAr k Malcolm R. Knapp. Acting Dire I

Office of Nuclear Material Safety )

l and Safeguards <

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EDO Principal Correspondence Control FROM: DUE: 11/14/96 EDO CONTROL: GT96801 DOC DT: 10/18/96 FINAL REPLY:

M2ry P. Sinclair, Don't Waste Michigan E102nor Roemer, Lake Michigan Federation TO:

James Taylor FOR SIGNATURE OF : ** GRN ** CRC NO:

, o DESC:

ROUTING:

2.206 PETITION RE UNRESOLVED DESIGN PROBLEM OF -Tayto[" '['.'~'- -

THE USC-24 CASK -Minoan

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Thompson Blahlt Mira glia, NRR Paperiello,NMSS DATE: 10/22'/96 Lieberman,OE ASSIGNED TO: CO!CACT:

OGC Cyr -

1 SPECIAL INSTRUCTIONS OR REMARKS:

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Don't Waste Michigan fSfR 5711 Summerset Dr.

Midt d (mTr M14864j s.r r3 W JUN 18 P1 :08 Lake Michigan Federation '

59 E. VanBuran Suite 2215 Chicago, Illinois 60605 0FFICE OF SECRETARY Oct.18,1996 .

DOCKETING & SERVICE James M. Taylor uit) 933 -cqy BRANCH Executive Director of Operations U.S. Nuclear Regulatory Commission '

1 White Flint North 11555 Rockville Pike

• Rockville, Md. 20RS2 4

Dear Mr. Taylor:

On behalf of Lake Michigan Federation and Don't Waste Michigan , we are enclosing a petition pursuant to 10 CFR 2.206 of the Commission's regulations. This petition addresses new information on the umsolved design problems of the VSC-24 car.k which have,become known to the public as a result of the hydrogen ignition / explosion at the Point Beach, W1 nuclear plant on May 28,1996. ,,

We have retained a highly competent corrosion engineer, Dr. Rudolf HauAler, to review the limited number of documents that m available to the public. Th NRC denied our request for a detaile'd engincedng design of the cask system.

Dr. Hausler points out the significant safety issues that have not been addressed by either the vendor or the NRC before the Certificate of Compliance for the VSC-24 cask was issued. The utilities have also failed to address these issues in response to NHC's recent requests for additional infonnation . -

It is imperative that these, issues be addressed at this time and incorporated in the SAR, the SER and the COC of the VSC-24 cask system.

Dr. Hausler is highly regarded in the nuclear field as well as in industry as a whole.

We appreciate the attention of the Commission to this petition. l l'

Yours sincerely,

.. asea.1 0ph _ f0>sm 9  := '

Mary P. Sinhair, PhD Eleanor Roemer, Staff Anorney )

Co chair, Don't Waste Michigan Lake Michigan Federation  !

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UNITED STATES NUCLEAR )

1 REGUIATORY COMMISSION )

Respondent ) j Railtion l

) Pursuant tio 10 CFR Part 2.206 of the Commission's regulations,IAKE MICHIGAN FEDERATION and DON'T WASTE MICHIGAN <

petition the Nuclear Regulatory Commission (NRC) to  !

l

1) Prohibit the loading of any and all VSC 24 nuclear waste f

' storage casks by users of the cask under the general license, l until tbc NRC, following an independent third party review of ,

i the VSC44 cask design, has amended the Safety Analysis l

! Report (SAR), Safety Evaluation Report (SER), and Certificate of '

! Cornpliance (COC) to address the significant safety concerns  :

[ raised by corrosion engineer consultant, Dr. Rudolf Hausler, and listed below.

f The following summary of unresolved corrosion issues affecting ,

safety in the VSC-24 cask system (Full Report attached),

associated with the Point Beach (Wisconsin Electric Power Co) hydrogen explosion, prepared by Dr. Rudolf Hauster, points out a range of short and long term critical issues la the VSC-24 cask system that have not been addressed by the vendor, the NRC or the utilities. (Dr. Hausler is a highly regarded corrosion j consultant who was retained by the Electric Power Research  !

Institute (EPRI) to develop and prove the effectivenens and )

safety of the corrosion inhibitor for off- line chemical cleaning inside reactors.) His conclusions on p. 5 and 6 of his Full Report  :

are as .follows: -

"Some safety aspects of the Sierra Nuclear Fuel Storage System have been reviewed la the wake of the Point Beach (Wisconsin  ;

Electric Power Company) hydrogen explosion. Both short term  ;

and long term concerns are discussed.  !

a ,, .

4 I h j- Page. Two (i) The storage configuration allows for the fuel elements to he t

{

' in contact with zine (metal) primer which is applied to all l internal steel surfaces of the MSB. This creates a galvanic element between the zine and the Zircaloy which in ' turn god

. - o r -f N accelerates the corrosion of the zinc. No tests have been N'hA

{ performed simulating this galvanic situation.

j 4

relating to the hydrogen evolution rate and SPFCalculationswater /

con'tamination rate, which are based on the available tests, j have therefore littic relevance.

4 i

(ii) Numerous discrepancies in the responses submitted by the various companies to the NRC request for additional assessmjnt W

!k j

?

of safety concerns reveal an alarming lack of consensus.

till) The epoxy coating applied to the outside or the MSB cannot

]

possibly withstand the temperatures said to develop on long term storage. This will result in an expensive SFP water f

/ { g ,- r i j contamination during unloading of the radioactive material.

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eu MM j

(iv) The NRC has published temperature specifications relating '

to low temperaturc emtirittlement of the structural carbon ggt .

steels used' in the Sierra Nuclear spent fuel storage system.

l These specs have not been tre. slated properly to the i pA - /2. 7 2 f corresponding material composition specifications (for the I2 steels in question), thereby creating additional hazards in i

handling the storage casks under possible emergency situations. , ,

,c<-

q ,.

(v) The zinc-steel interaction at 800 to 1000 degrees F. and ./

! 1 possible steel embrittlement over a period of 20 years has not V l

} been considered, again creating an additional hazard for

{ handling the MSB in the future. g(> 'gL T' i

, p*,

(vi) Similarly, the effect (or the absence thereof) of molten zinc l

.t on Zirealoy has not been verified experimentally. The possible l

failure of the cladding could make unloading of the spent fuc!

rods impossible,

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(vii) The vacuum drying process does not seem to have been g i.

[

' experimentally verified relative to residual water remaining in .'

l l

the MSD. All calculated data relating to pressure in the MSB 7

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.y _

T .. -

.B Page Three '

during storage, and continued integrity of the seal welds are l therefore open to questioning. ,  ;

(viii) None of the temperature calculations and heat transfer f

assessments have been experimentally verified. There has pr g never been a field test of this storage system. It is not I

{ apparent that the storage system has been instrumented in [^j order tu verify the design assumptions." g gW 6 l>

Facts vf & I~'Y Lrr- d .

i 1. The NRC issued a Certificate of Compliance 72-1007 for the  ;

Ventilated Storage ' Cask VSC-24, May 7, 1993. l

)

2. Casks of the Model VSC-24 are used by Consumers Power Co.'s, WEPCo's and Entergy's general . license issued pursuant to  !

10 CFR 72.210, ' subject to the conditions specified by 10 CFR 72.212 and the conditions for Cask Use contained in the Certificate of Compliance 72-1007. .

i

3. The VSC-24 cask is a dry storage system for utilizing a concrete storage cask, and a carbon steel, seal welded multi-assembly basket (MSB) to store irradiated nuclear fuel. The VSC system includes:

(i) Ventilated Concrete Cask '(VCC)

(ii) 24 -Assembly Multi Assembly Scaled Basket (MSB)

(iii) MSB Transfer Cask (MTC) for on site use (iv) Vacuum drying and Helium Back-fill System (v) Enginected Cask Transporter for on site use

4. At 2:45 a.m. (CDT) on May 28, 1996, hydrogen gas ignited during closure welding of a VSC-24 multi assembly scaled basket loaded with spent fuel at WEPCo's nuclear power plant at Point Beach, Wisconsin. The hydrogen gas ignition displaced the MSB shield lid weighing about 6,390 pounds, leaving it in place but tipped at an angle, with one edge about 3 inches higher than normal. (U.S NRC Information Notice 96:34, May 31, 1996) 9 9

. I 3 .

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Page Four Zine 11 coating when in contact with the borated water in the spent fuel pool. (July 3,1996, NRC issues Augmented Inspection Team Report on Hydrogen Oas Burn in Spent Fuel

! Cask at Point Beach Plant) ~

6., An NRC Augmented Inspection Team (AIT), at a June 7 j 1996, Exit Meeting, also concluded - that the source of the .

I hydrogen ga's was a chemical reaction between boric acid in the i spent fuel . pool water and zine in a coating on the carbon steel interior of the MSB.

7. Neither WEPCo nor the NRC have satisfactorily addressed the

! significance of the galvanic reaction between the zinc coating l

! and the Zircaloy cladding of the fuel rods and its effect of generating increased levels of hydrogen. [Hausler, III (2) (b)J

8. Specific operational controls and limits necessary to prevent *

criticality, maintain confinement, shielding, heat removal, and i structural integrity under normal and accident operations must

] be identified and sunoorted in the SA R. ( draft NUREO-1536, j 12 3, Feb., 1996. Ilmphasis' added).

9. The Safety Analysis Report (SAR) for the Ventilated Storage 3

Cask System prepared. by PSNA and SNC, October,1991,

concluded that the materials from which the VSC is constructed j will not experience significant chemical, galvanic, or other  !

reactions in a water atmosphere. (SAR, section 3.4.1)

10. The conclusions of the October,1991. SAR, for the VSC-24 do A21 identify 1) the potential for hydrogen gas formation as a result of reactions between coatings used on components '

important to safety and spent fuel pool water; 2) the potential of this hydrogen gas formation to ignite as a result of operations performed on the MSB shield lid during loading and unloading operations; and (3) the potential for boron depletion as a result of the reaction between the MSB coatings and the l spent fuel water and the resulting potential impact on criticality; (4) the potential for charring of the epoxy coating on l the MSB and the resulting impact on spent' fuel pool water when unloading; (5) the potential for steel embrittlement; and

(6) the galvanic corrosion element between the zinc and the ,

, Zircaloy cladding of the fuel rods.

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Page Five .

I

" 11 The SER of Anril 28. 1993.and the Certificate of comellance issued by the NRC on May 7.1993. did not identify any or the issues described in No. 10 ' above. l

=

, 12. MSD coatings were not classified as important to safety

even though the coating is applied to the inside of the MSB j -

basket which is classified as important to safety. (NRC i

Inspection Team Leader at SNC, June 5,1996, notes.)

l

13. The NRC concluded that the designers of the VSC-24 cask l

} never considered fire or explosion due to hydrogen. (Ibid.)

1 l

14. SNC design review of VSC did not include a corrosion engineer or environmental effects specialist. (Ibid.)

j 15. The NRC's AIT teams review of the SAR for the VSC System ,

showed that consideration of the temporary condition of the '

j cask being immersed i

in borated water was not assessed. (NRC

' AIT Review of the May 28, 1996, Hydrogen Uns ignition During Dry cask Storage Welding. Operations Reports No. 50-266/96005: 50/301/96005, July 1, 1996)

16. The occurrence of the hydrogen ignition event at Point l Beach, Wl, on May 28, '96 provides clear evidence that the l VSC-24 vendor and licensees did not adequately address material reactions and material compatibility with possible i

environments, in the design and design review of the VSC-24 l cask. (Ibid., p. 11-12) i j ,

17. The NRC did not consider material reactions and material

compatibility in its licensing review of the VSC-24 cask. (SER, j

April 2g,1993, COC May 7,1993, NRC Bulletin, July 5,1996, '

{ p. 4) *

18. The NRC issued NRC Bulletin 96-04 on July 5,1996, i -

requiring all holders of operating licenses for power reacturx to submit information to the NRC regarding the susceptibility of their cask to chemical, galvanic, or other reactions on the casks

ability to maintain the structural integrity and retrievability of the spent fuel through the tenn of the license; an evaluation of the effects of the reaction among Carbo Zinc 11 or other equivalent coatings and' the water environment the cask may a

~ . - - . _ - . -4 i~ . i Page Six encounter, and an evaluation of the procedures for unloading a  ;

cask to ' consider the likely presence of hydrogen gas inside the MSB and. the possible adverse effects of the hydrogen gas on cask handling and performance.

19. The nuclest facilities, including WEPCo, CPCo, and Entergy i

have responded to the NRC's request for information, but, as Dr.

i Hausler points out in the attached report, the materials performance questions do not address the significant safety 1 issues, and there are numerous discrepancies in the companies' responses. .

20. The descriptions of the cask use and design contained in the VSC-24 SAR and associated SER have not been reviewed to the extent necessary to assure prevention or hazardous conditions caused not only by the reaction between MSB cuatings and the spent fuel pool water, but by certain other metallurgical, chemical reactions and temperature effects as pointed out by Dr. Hausler in the attached report.

21. Corrosion Consultant Dr. Rudolf Hausler in his Preliminary Report, based on the limited number of documents availabic to  !

l him, has nevertheless, been 'able to idenfy a number of these '

key issues for the NRC which an indepredent third party

- review team should explore in greater detail, to' establish parameters for the safe operation of the VSC-24 cask system.

These. include:

(i) questions regarding the impact of the galvanic reaction between the zinc coating and the zircaloy cladding;

- (ii) discrepancies in responses . submitted by utiliths and the vendor to the NRC's July 5 memorandum; (iii) questions regard'ing the impac'ts of long term storage j un the epoxy coating; l

, (iv) risk scenarios related to low temperature embrittlement of the structural stecin used in the Sierra Nuclear spent fact storage system; i

)

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Page Seven

! (v) risk scenarios related to zinc-steel interaction at 800-1000 degrees F. and possible steel embrittlement over a

, period of 20 years; (v'i) experimental verification of temperature calculations I and heat transfer anessments.

Conclu sin.an

! 22. The VSC 24 SAR and the associated SER do not contain:

.i l (i) documentation of the conditions produced by the i reaction between the MSB coatings and the spent fuct i pool water, including the formation of ignitable, and l explosive quantities of hydrogen and its impact' on the

boron concentration; cask performance; temperature l cffects on materials performance; and verification of j temperature calculations, heat transfer assenments, and .

design assumptions;

! . (ii) adequate operating' controls and limits to prevent ,

hazardous' conditions from being caused by reactions between MSB coatings and the spent fuel pool water; j the potential impact of molten zinc and the Zircaloy i cladding; and consideration of temperature effects and i metal embrittlement; i .

l (iii) ju.stification that the conditions produced by the j reaction between MSB coatings, spent fuel pool water, i j and other material performance issues do not result in i unsafe cask operation.

• l 23. Specific operational controls and limits necessary to ,

j prevent criticality, and maintain confinement, shiciding, heat l j removal and - structural integrity under normal and accident I j operations must 'be identitled and supported in the .SAR and SER. ,  !

24. The COC for the VSC-24 was issued on' the basis of a review of the vendor's SAR and the determination that the cask design 4

4 Page Eight

! meets the applicable requirements of 10 CFR Part 72 as l discussed in the NRC's SER. Because the vendor's SAR did not l

address the potential consequences of .MSB coatings reaction with the spent fuel pool l water, as well as other metallurgical  ;

issues and chemical reactions, as well as temperature related j issues, as pointed out by Dr. Hauster, it is inadequate to .

1 provide - the basis for a Certificate of Compliance.

25. The COC for the VSC-24 does not contain operating controls  !

and limits that prevent hazardous conditions caused by chemical and galvanic reactions. It does not confirm any experimental verification of temperature calculations and heat i transfer assessments, and other design assumptions.

26. In order for the VSC-24 dry cask storage system to be used in a manner which protects public health and safety and allows for the safe operation of the cask over its licensed

• lifetime, the VSC-24 cask system should not be used until:

(i) an independent third party review team has explored

- and satisfactorily resolved 'the safety issues raised by Dr.

Hausler in the attached report; (ii) the identification of the potential impacts of all the materials performance of. the cask have been fully assessed; (iii) there is experimental verification of temperature calculations and heat transfer assessments and of other design assumptions; ,

(iv) justification of the safe use of the material coatings on components and structures important to public health and safety has been made; (v) the SAR, SER and COC are amended by the NRC to include the necessary , operating controls and limits to direct the safe use of the VSC-24 cask.

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Page Nine i= . ,

j THERh? ORE, petitioners, Lake Michigan Federation and - ')

j Don't Waste Michigan, petition the NRC to order users of the  ;

j VSC-24 system not to load VSC-24 casks until the COC, SAR i j' and SEK of the VSC-24 are amended to contain the operating

[ controls and limits that prevent hazardous conditions, i 'incNding but not limited to the generation of explosive gases, ,

l due to VSC-24 materials reactions with environments'

! encountered during loading, storage, and unloading of the

V S C-24.

f -A n independent. third party interdisciplinary review .

l team that includes corrosion engineers, metallurgists, chemical engineers and others must determine the operating controls j ,

and limits . which should be clearly documented and justified in l 1

the technical review sections of the SAR and associated SER for j the VSC 24 cask, and incorporated .in ai revised COC.

1 Date: October 18. 1996 k~ e_d w m Eleanor Roemer, Staff Attorney ~ Mary P. clair, P'hD l Lake Michiga'n Federation Co-Chair, in't Waste Michigan ,

. l (This petition under 10 CFR 2.206 should not be laterpreted as a petition for. rulemaking, including emergency rulemaking).

ec. Chairperson shirley Jackson,NRC Vice-President Al Gore Carol Browner, Adm. EPA. Sacy of Energy, Bazel O' Leary 4

Valdus Adankus, EPA senator Frank Murkowski

, senator Carl Levin senator spencer Abraham senator Joseph Lieberman congressman Fred Upton senator Paul' simon ~ Senator Carol,Moseley Braun Senator Russell Feingold senator Herbert Kohl

' Senator Paul Wellstone Dinah Bear, Gen. counsel,CEQ  ;

Attorney Gen.F. Kelley,MI Governor John Engler, MI Attorney Gen.J. Doyle,WI i

Governor Tommy Thompson,WI Michigan Public Service Wisconsin Public Service conunissioners commissioners 9

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i ,

{.-

I _'. :g@jpj Pl;,1 -

Rudolf H.Hausler  ;

i f,osyo& .

7 sos PenmassIans, Dallas,TX 7524:

l s4hh Tel:214 490 seas Pac 214 490 ss7:

i i

i Dr. Mary Sinclair October 6,1996

} 5711 Summerset Dr.

i Midland, MI 48640 i

(

Subject:

Pavilminary Review of Documentation relating to'the Safety L Evah:stian of the Use of the Sierra Nuclear Corporation's j Dry Fuel Storage System i

l I. Scope i his analysis is based on the documentation available at the time of the analysis (see i references attached as Apxndix II). He primary focus is corrosion and materials i perfonnance both during tk loading process of the dry morage system components and 1

during long term stora, ge. It is assumed that the reader is fanuhar with the components of 8 i this symem (Ventilatec Storage Cask System, VCS) and its com punts (Multi-Assembly i

Scaled Basket, MSB; Multi-Aasambly Transfer Cask, M'IC, anc the Ventilated Storage -

} Cask, VSC). Therefore a detailed description of these components is omitted here.

1 L II. Background 2

• s l De issues relating to corrosion and materials performance of the ISFSI (Independent Spent j Fuel Storage Installation System) arose when an er Aosion occurred during the welding of i the lid onto the MSB. Subsequent to this incident, t te NRC issued Bulletin 96 04 i

requesting information on the "Chamical, Galvanic, or other Reacsions in Spent Fuel i Storage and Transportation Casks" dated July 5 1996. The responses to this request, as well as the responses to subsequent Confirmatory Action Letters (CAL's) by the NRC are i

! reviewed. t i

ne immediate concxrns relate to the nkture of the explosive gas which appanntly was

! generated inside the MSB, possible means to avoid such incidences in the future, and l questions relating to the behavior of materials associated with the MSB and the VSC on long term exposure to high temperatures.

4 l HI. The Evolution of Hydrogen.

4

! he MSB, consisting of a cylinddcal morage can containing 24 rectangu:ar sleeves l (designed to hold one fuel rod assenbly each) is fabricated from heavy meel sheet. The j

outside of the MSB is coated with a zinc primer covered by an epoxy coating. All inside j meel surfaces are coated only with a zinc pruner. This includes the mside wall of the MSB l as well as all surfaces of the sleeves. As a consequence, the Zircaloy fuel rods are in

electrical contact with primer coated surfaces and form a galvanic cormsion element.

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10/9/"., 1 g0M ocW rhh/sinclair/Snal 1

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III. I Boric Acid f%=iery fuel pool (SFP) water contairu 2850 ppm of boron er 16,310 ppm of boric

, @Mqf *\De

. 4 acid. is no indiation in the available literature that the solution might be buffered Q with sodium borate). The pH of this solution can be calculated as 4.86 (see Appendix 3})k i&

I). Contrary to a comment by Wisconsin Elearic Power Company (WEPCO)'the boric acid ofwater;

/ ther pum water does

. the corrosion of zine isnot maesse accelerated, not the pH(see reduced butref.reduces it from the p1, pg. 2, last pa

?x It atpes./ ever, that the low pH of the borated SFP water has been r==ni=4 and f8 is qu.- sig about 4.5 in several other documents.

HI. 2 Corrosion of Zinc in Barated Water ne corrosion rate of zinc primer applied to steel coupons appears to have been measured by NWT and by Entergy (Ref. 7) These tests seem to have focused on the rate of hydrogen genration and precipitate formation. No corrosion rate data are available, nor have the tests been desaibed in any detail in the available documents. It is being said that the results from NWT Corporation (San Jose, CA) " appear to be fairly consistent with those from Entegy Company", but about 8 times higher than the rate mdicated by WEPCO. WEPCO assumed a nne corrosion rate of 0.028 inches per year (ipy) based on literature data quoted in Uhlig's Han&ook of C-usion.

However, no effort was made by WEPCO to translate that into a hydrogen evolution rate. Rather, WEPCO chose to assume a hydrogen evolution rate based on some ,

measurements (Ref. 9) Dese measurement indicate that the solution was saturated with hydrogen at a partial of one atmosphere. The reported concentration of 15 cc H 2/kg H2O to saturation of the water with hydro ge gas at of I sta and a temperatureof25 One does not know from the report, w iere the water was sampled and how the analysis was made. However, if the water in the MSB became

. saturated with hydrogen at I sta, the hydroga evolution was no doubt te fast and the atmosphere above the water must have been very ridt in hydro gm. ofthese factoids are useful for the assessment of the zine corrosion rate anc. the associated H3 -

evolution rate under use conditions.

Dere are several effems witich must ce taken into consideration in the design and evaluation of corrosion tests, or when comparmg literature results.

a. T te data quoted by WEPCO (from Uhlig) were obtained on solid zinc samples and hencupportioned to a measurable surface area. De zine primer conssts of nne powder m an inorganic matrix. Depending on the particle sire and the zine contet in the rimer, a surface aren many, times the apparent aren may be exposed to the corrosive mec ium. Because of the small mze of the particles, corrrsion is very likely sooelerated over that measured on solid coupons. Furthermore, the hydrogen evolution rate would be p.yunionseely larger at the ratio of the apparent, or geometric, surface arts to the rest surface are of the zinc partides. Literature data, such as those quoted by Uhlig, have no relevance with respea to zine particle corrosion in paint primers,

b. Galvanic Couwsbe: De Zircaloy surfaces of the fuel elements inside the sleeves of the MSB are in elemrical contaa wah the zinc primer, with which the inside surfaces of the sleeves are coated. It has bee amply demonstrated, e.g., that the Inconel tubes in a steam generator galvanically accelerate the corrosion of the carbon steel walls of the generator during chemial cleaning (Ref.12) . (The effect on the welds is even larger).

Dere is no reason to assume that Za'rcalcy will not mmilarly accelerate the corronon of 10/9/96 2 thh/sinclairMnal

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zinc. As a consequence, this fact must be considered in tests which pmport to evaluate  !

! the behavior of the zinc primer when in contaa with the SFP water dunng loadmg of

! ' the MSB and nubsequent operations.

i i ne NRC has repeatedly caHed for comments r - Lg galvanic reaions. His

! question has not been answered to date. indicates (ref.9) that the" rate of  ;

! galvanic conosion of the zine from the Cartio Zinc 11 SG may be three times higher "

than in neutral (pH 7) water". Clarly tl.is comment does not answer the question smce  !

i the salvanically accelerated conosion nae at the low M is not :Wed.De same l l reference, pg. 2, indicates that " Published data were Found for t3e kinaics of zinc j- corrosion a, boric acid". However, no reference is given and no data are quoted.

4

c. Conosion Kinetics: All meals which can form a solid corrosion product who

{ conoding in an aqueous medium exhibit passivation behaver. His means that the conosion rate observed on the bare metal upon immersion into the conesive fluid l gradually demases with time. De initial conosion rate, immediatdy upon immersion,

may be orders of magnitude higher than the average rate for the duran,on of the test. De L extent and the rate to which this decrease of the rate occurs ds on the natureof the l corrosion product. Herefore, an average conosion rate (such as weight loss)

! which has been obtained in a long term test is not repmeentative of the possible short i .

tem corrosion rate and is a funamn of the test duration.

{ Furthermore, a test such as the one performed by ANO (Ref.10) may be misleading in e ~

other ways. The test protocol called for increasing the tempermure from 120 'F,

! following immersion of a primer coated coupon mto the borated water, to 200 'F, i ' e{"

p/v^6fg.

{ followed again a slow cool down to the starting temperature. De duration of the test y j

j-was 75 hrs. It is that increasing temperature promotes passivation. De conosion rate in barated water may actually decrease with increanng temperature. (he phmomenon is well documated for CO conosion). Hence the tanperature cycle (g[r

performed in ANO tests ma not be representative of the worst case condition. In view

} of theimportance, physi and financially, of the question of the rate of hydro gm

generation and associated S water contamination, it would seem that a full eva .uation i of the zine corrosion under all possible conditions of actual use in the application under i consideration should be conducted.

i

! d.De Nature of the Zinc Primer.

Ref. 8 (WEPCO) discusses the use of zine primer from the point of view of

{ contamination introduced into the SFP water. Here it is stated that the primer contains i

"25,000 ppm of zine and 530 oflead". All other specifications for the zine level in i the primerindicate 85% (850, ppm) . If the lead contamination of the zinc in the ximer were indeed 2%, as indicated by the WEPCO numbers, then the the amount of j end introduced into the SFP water through corrosion of the zine would be 34 times t larger than what WEPCO assumed it to be. His discrepancy, it would seem, calls for a f

re< valuation of the led impurities which could be introduced into the SFP water, in light of the limiting amount oflead which can be tolasted according to the Westinghouse spec,6 cations (ibid).

IH. 3 Conclusions It would appear from the above that the question of conosion of the zine in the primer has not been resolved quantitatively, neither hem the point of view of hydroge evolution, nor from the point of view of SFP water contamination.

10/9/96 3 rhh/sinclair/ final

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!* The NRC request for review of the materials pformanne quesions by a corrosion spedalist does not seem to have been fulfma 4

IV. Additional Concerns Relating to Materials Performance

! IV.1.Tsaperature and Epoxy Coating i l Specifications for the Epoxy coating to be applied to the outside surface of the MSB are  !

i presented in Ref.11. It is noted that no temperature celimits are specified. In  !

view of the faa that the temprature in the MSB on tem

! 800 to 900 T (in the amame as much as 1000 armance g@ top cost m :poxy tmxxnnes a concern.

M It is rwhu- me space betwee the MSB and the VOC is air i

cooled.*Ihis suggests that the overall heat transfer coefficient is given by the natural

{

1 convection of the air through the annidar space. As a consequece, the temperature of the '

epoxy would be expected to be very little below the values quoted. Degradation by i b i ti f the organic matmal can, therefore, be arna*M No surface temperature '

a been calculated for the anteide of theMS]L Since the nat=iing or the VCS is part of g(M( # . a:: on za ono

. ,y theuftry evaluanon, and since it would also have to be performed in the SFP, the 9 corrosion of the residual zine on the outside of the MSB m contaa with charred epoxy paint 3[

l becomes a real concern.

! While extensive simulat:crn and calculations of the heat transfer rates from the MSB to the i

mvironmmt have been made it should be ramgni=i that the het transfer coefficients for radiation, conduction, and natural convection are affliaed with uncertainties. It is therefore i suggested that confidence limits be give for all such calm 1stinnt and be reviewed by a

third party. Clearly the heat transfer annot be very efficient if the ta====tures in the MSB l can nse to 1000 T. Common uncertainties in the coefficients of 20 to"50% (particularly

{ with respect to thmnal mn&rtivity thmugh coatings) can alter the calentatiness -

1 sigmficantly.

. IV. 2. Zinc-SteelInteractions ne melting point of zine is 786 T, or well below the anticipated tern wraturet inside the MSB. His raises a serious concern about liquid metal embrittlement. While sv6

>henomena are not , generally observed following the galvanizing process of 21., it must

>e recognized also t sat during galvaniring, steel is in contact with molte zinder a very short time only. The exposure of steel at 800

• T to molte zine over a perie J of y. ars is .

totally unchaned territory and needs to be seriously inv%==4 IV. 3. Zinc-Zirtaloy Interactions The continued integrity of the Zircaloy cladding over the 20 year licensin,g period is imperative if the fuel rods are to be unloaded any time in the future. In tlns context at least two issues need to be reviewed relating to stress corrosion cradcing and liquid metal embrittlement. It has been reported (Ref.14) that conmotrated methanol and organic solvents containing small amounts of chloride can cause stress corrosion of zirconium.

Generic specification of cleaning solvets should therefore not be permissible, since many such solverits either contain met sanol, are chlorinated hydis.tuuns, or contain chlorinated hydrocarbons.

10/9/96 4 rhh/sinclair/Snal

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l, Similarly liquid metal embrittlenent has been reported for zirconium in cantact with  !

mohen ca, sum or when exposed to liquid sodium orcadmium. De affem of zine maal in i contaa with Zircaloy at 800 to 1000 T mua therefore also be examinarf since zinc, like

!_ cadmium and mercury is also a 2b transition meal. Liquid embrittlement of meals by j merary is wellknown.

1 i Mon Zircalays behave very similar to zirconium because the alloying constituents are l l present in the Zirmloy in small amounts only. j i

j IV. 4. Performance of Steels at law Temperatures

a. Manganese Steels: De generic sp=:'-cation of struaural meets such as A-36 and A-516 4 t is unsatisfaaory from the point of view of cold tanperature behavior. De embrittlenent temperature is voy dependet on the manganese contet in the meet as well as on other l

} alloying elemets wtuch are not included in the generic compositional specifications of i these steds (Ref.13). A-516, e.g.,b . ;.. .rc of 0.8 to 1.2 5. In view of the faa that

the NRC has specified a temperadire 50 T the embrittlement temperature, etYouts

{ mun be madeto develop more pnicise ' cations for the steels to be used in order to j assure safe handhng of the morage cask under all possible conditions including emergencies.

b. Welds: It is noted that no spec 2htions relative to the embrittlement temperatures have j been defined for welds. De abst.nce of such specifications is considered very dangerous.

( o l IV. 5. Residual Corrosion of the Zine in the MSB and Resulting Pressure on Long Term Storage l

1 j.

It has been proposed that following closure of the MSB (welding of the seal lid) the water is drained from the inside of the basket. Complete drying is the attempted by a vamum

[ 0,ky, to be no verification of the residual water whichdmay remain j

zocess.There a -

mska. Such vert cation is essential in order to determine the pressures which might develop in the basket, particularly if these pressures need to be used in the evaluation of the strucniral integrity of t a basket on long term scrage.

V. Summary Some safety aspects of the Sierra Nuclear Fuel Storage System have been reviewed in the wake of Point Beach (Wisconsin Electric Power Company) hydroga explosion. Both short term and long term concerns are diamenarl De storage configuration allows for the fuel elemets to be in contaa with zine (maal) prime which is applied to all internal acel surfaces of the MSB. This creates a galvanic elementbetweenthezincandthe

• which in turn acederates the corrosion of the zinc. No tests have bem puformed sim ' g this salvanic situation. Calculations relating to the hydro gm evolution rate and the SFP water contamination rate, which are based on the availab e tests, have therefore little relevance.

Numerous discrepancies in the responses submitted by the various companies to the NRC request for additional assessment of safay concems reveal an alarming lack of consensus.

The epoxy coating apph'ed to the outside of the MSB cannot possibly withstand the temperatures said to' develop on long term morage, his will result in an expensive SPF water contamination during unloading of the radioactive mataial I

l 10/9/96 5 rhh/sinclair/ final 1

l t . De NRC has published tanperature sped 5<stions rdating to low temperature l anbrittimwrv of the structural carbon steds used in the Sierra Nuclar spent fud

storap systesn. Dese specs have not bem trunalstad to the wupding 2

matenal composition ' cations (for the meets in gi ther by acatmg additional hazardsin g the storage casks under possible energency situations.

)

• De zinc-steel intascrion at 800 to 1000 *F and,possible steel embrittlermnt over a

xriod of 20 years has not been considered, agam creating a n additional hazard for j undling the MSB in the future.

Similarly, the effect (or the absence thereof) of molte zinc on has not been verified experimentally, ne possible failure of the claddmg could unloadingof j the spent fud rods impcssible.

The vacuum drying procas does not seen to have been experimentally veri 5ed relative i to residual water remaining in the MSB. All calculated data relating to pressure in the MSB,during storage, and continued integrity of the seal wdds are therefore open to questiomng.

l None of the temperarnre calculations and heat transfer assessmets have bem

] experimatally vanfr i nere has never been a fidd test of this storage systern. It is

not apparent that the r orage system has been instrumented in order to verify the design

!, assumptions.

i

/

R.H. Hau .

10/9/96 6 rhh/sinclair/ Anal 4

. . . _- - - - . =. ._- . - .

4 APPENDIX I e

4

Determination of pH of Boric acid solution

Solution- Disulled water @ room temperature '

Boron content 2850 ppm; 16,310 ppm boric acid; 0.264 mol/L boric acid (K,)' (boric acid) = 7.3x10

h Therefore:

7.3*10- 0 -

[H '[H2B N

[H3 B03 ]  :

since:

[H+)-[H2BO] 3 and (H+]2 - 7.3*10-3

• 0.264 ,, {

pH - 4.86  !

10& M 7

rhh/sinclair/ final

. s

I

! APPENDIX IL

References:

1. Sqfay Analysis Repon (SAR), October 1989; Section 3: Principal Cask Design QillDR

2. Sqfety Emlaarion Repon ; NRC March 29,1991

3. Sqfay Emlaatim Report; NRC April 1993

4. Notice ofNon-Coqformance; NRC, June 7 1996

5. InitialRaponser to CAL 4-4002; Entergy perations, June 2,1996

6. RequestforadditionalIqfonnatin reganting"Bullain 9644, "Onenlai, Galmnic, or otherReaaions in Spast FuelStomge Caks , I.atter from NRC to WEPCO 91486

7. SNC response to NRC Bullain %04for VSC-24 Dryfuel Stomge Systen; Sierra  ;

Nuclear Corp., August 16,1996

8. Use of Carbozinc Paint as a primerfor the hiulti assanNy Stomge Bader, Internal  ;

Memo, Wisconsin Electric Power, July 181995 , i

9. WEPCO response to NRC Bulletin %04for VSC-24 Dryfuel Stomge System; WEPCO August 16,1996 '

10. Consumers Power response to NRC Bulletin %04for VSC-24 Dryfuel Stomge Systan: Galmnic, or other Reaions in Spent FuelStomge and Trxouportation Cask:

August 19,1996

11. WEPC0 response to NRC requarforadditionalinfonnaria telming to: Bulletin %

04for VSC-24 DryfuelStomgeS Stomge and Trxvuponation Cask;ystem:

September 61996 Galmnic, or other Ruaions in Spent F

12. Non Proprietary Corrosia inhibitorsforSolvesa to Omn Stearn Genemtors; R.H.

Hausler, EPRI report NP 3030,1983.

13. Maals Handbook,9th Edition, Vol.1 Properties and Seleaion ofIrons and Steels, American Society for Metals,1978, pg. 689

14. Metals Handbook; Desk Edition; American Society for Metals,1985, pg. 20-35  ;

10/9/96 8 thh/sinclair/tinal ,

. RUDOLF H. HAUSER  !

i ,

7804 PENCROSS LANE

• DALI.AS, TEXA5 75348 l (214) 490 8605 OR (806) 495 3808 TE!.EPHONE * (214) 490 8878 OR (806) 495-40

SUMMARY

l 1  :

Over 20 years planned, conducted, and directed advanced chemical research focused on oil productio and processing additives.

j Acquired expertise in corrosion prevention, inhibition and materials selection, failure analysis trouble shooting and economic analysis. Proficient in German, French and

hattan.

}

EXPERIENCE i  :

3

Mobil Oil Company (Dallas Research Center), Dallas, TX i 1991-1995 l

seniorEneinerrine Adchar l

j Developed corrosion testing facilities for basic research and to meet specific oil field requirements.

Planned and developed H2 S corrosion test facility.

Planned safety and wrote safety manual. "

2 Developed unique continuous Flow-Through corrosion Test Facility (1.5 MMS).

j

• Developed test protocols and supervised operations of the FTTF.

Extensive consultation with Affiliates on problem solving and ek= lee! usage. '

i Established supplier relationships and consulted with. Affiliates on establishing Enhanced Supp Relationships.

Developed theory and practice of novel approach to autoclave testing.

2 Petrolite Corporation, St. Louis, MO 1979-1991

} R,c, arch Anneiar-(1986.1991) s j Directed

• and conducted the development of novel corrosion inhibitors for extreme operating conditio New corrosion inhibitor to combat erosion corrosion of carbon steel in gas condensate we!!s.

L Extensive studies on CO 2 corrosion aimed at establishing predictive corrosion model.

t

• Saorial A eelerant to Fvormative Vier P.--'2*nt(192f.1987) j Special Assignments focused at supporting Is..dional Sales.

Extensive travel to secure major accounts in Europe, Russia and East Asia.

{ Monitored out-sourced R&D in Germany and England.

j. semiar R,c, arch td,=rier /1979.19Arj 4

• Developed novel chemical composition under contract with EPRI for corrosion inhibition of i

cleaning fluids used in nuclear steam generators and methodology of application (only effective formulation still used today).

Developed unique corrosion model for 2CO corrosion in oil and gas wells.

i Conducted numerous detailed field studies to establish case histories of chemical performance and applications technology, i

I i,

1

.._m___ _.

a .

i .e '

j RL' Dots H. hat >sLER Pact 2 -

j .

j Gordon Lab, Inc., Great Bend, KS 1976-1979 Treb.te 1 nin etar

Responsible for all technical issues involving formulation, application and sales of stripper well production chemicals (corrosion, emulsion, scale, bacteria).

• Conducted failure analysis for customers and developed pertinent reports.

l"

• Supervised service laboratory.

• Established !Wieal training of sales and support personnel.

• Developed technical sales literature and company brochure.

j 4

i l UOP (Division of Signal Companies), Des Plaines, IL 1963-1976 Research Anociate(19721976)

Associate Research Coordinator (1%71972) l Rmarch Chemist (19631967) i To conduct research in electrochemistry, analytical methods development, heat exchanger fouling l processes and refinery process additives.

i

• Developed novel organic electrochemical synthesis procedure.

• Developed unique (patented) test apparatus for measuring anti-foulant activity. 5 l

• i Introduced statistical design and evaluation of experiments to R&D department.

• Developed full 3 credit hour corrosion course to be taught at 11T and DeSoto Chemical company.

• Developed 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> course on statistics,

) '

i .

, EDUC ATIO N Ph.D. Chemical Engineering, Swiss Federal Institute of Technology, Zurich, Switzerland l BS, MS Chemical Process Technology, Swiss Federal Institute of Technology, Zurich, Switzerland i PROFESSION AL ASSOCI ATIONS i

i '~American Chemical Society

The Electrochemical Society l Society of Petroleum Engineers

! NACE International (Corrosion Engineers) j American Society of Metals (ASM) l Active in NACE on local, regional and national level i HONORS AW ARDS, RECOGNITIONS 17 patents,55 publications and more than 100 technical presentations NACETechnical Achievement Award (1990)

Registered Professional Engineer (Corrosion Branch, California)

NACE Certified Corrosion Specialist

L.

• e .

~

PUBLICATIONS

1. ELECTROCHEMICAL PRINCIPLES IN CORROSION R. IL Hausler, Heating, Piping, Air Conditioning, fl. (#9) 11(1%9)

2. THE USE OF STATISTICAL DESIGN AND ANALYSIS IN THE DEVELOPMENT OF A CORROSIGN INHIBITOR TEST R. H. Hausler, L A. Goeller, R. H. Rosenwald, Proceedings of the National Association of Corrosion Engineers 26th National Conference, March 2-6, 1970, paper #63.

3. CON'IRIBUTION TO THE FILMING AMINE THEORY R. H. Hausler, L A. Goeller, R. P. Zimmermann, R. H. Rosenwald, Corrosion,2L (#1) 7 (1972).

4. CONTRIBUTION TO THE MECHANISM OF HYDROGENSULFIDE CORROSION INHIBITION.

R. H. Hausler, L A. Goeller, R. H. Rosenwald, Proceedings of the 3rd ,,

European Symposium on Corrosion Inhibition, Ferrara, Imly,197:, p. 399.

5. CORROSION CONTROL IN CRUDE UNIT OVERHEAD SYSTEMS R. H. Hausler, N. Coble, Proceedings of the API Division of Refining, New York, May 813,1972. Also published in: Oil and Gas Journal,20, (#29) 92, 1972; Hydrocarbon Processing, May 1972, p.108; Petroliere D'Italia,,12, (#8) 21,1972; Petroleum Times, June 2,1972, p.10.

6. RUST INHIBITION AND INHIBITOR TESTING, A CRITICAL DISCUSSION R. H. Hausler, R. C Kunzelman, Materials Protection and Performance, .11

(# 11) 27 (1972).

7. PROCESS CORROSION AND CORROSION INHIBITORS IN THE PETROLEUM i

INDUSTRY R. H. Hausler, C Stanski, A. Nevins, Proceedings of the National Meeting of the National Association of Corrosion Engineers, March 1974, Paper #123.

Materials Performance,119 (1974).

8.

i FOULING STUDIES IN HYDROCARBON STREAMS IN THE PETROLEUM INDUSTRY R. H. Hausler, Oil and Gas Journal,21, (#23) 56, (1973).

9. FREE ENERGY AND ENERGY FUNCTIONS R. H. Hausier, Encyclopedia of Chemistry, (Hampil-Hawley, Editors) 3rd i Edition, p. 467 (1973).

i 8

~

s.

3 i .  ;

I i i i

~

i 10. SYSTEMS APPROACH 'IO CORROSION ENGINEERING IN THE CHEMICAL i INDUSTRY

! R. H. Hausier, Invited paper presented at the AIChE Meeting, Chemical i

! Engineering / Corrosion Interface, Washington, Dec.1974.

i IL FOULING AND CORROSION IN FEED EFFLUENT EXCHANGER l R. H. Hausler, C E. Thalmayer, Discussion of a new Test Method; j

Proceedings of the API Division of Refining 40th Midyear Meeting, May 13, 1975, Chicago, Ill. .

i i 12. SOME CONSIDERATIONS REGARDING THE USE OF ELECTROCHEMICAL

! CORROSION. MEASUREMENTS IN THE PRESENCE OF CORROSION l PRODUCTLAYERS i R. H. Hausler, Presented at the NACE 1975 North Central Regional Conference, October 21-23,1975.

! 13. INSTRUMENT MEASURES PROCESS FOULING, ETC.

R. H. Hausler, Oil & Gas Journal, Feb. 14,1975, p. 92.

l f 14. CONTRIBUTION TO THE UNDERSTANDING OF FOULING PHENOMENA IN ,,

i THE PETROLEUM INDUSTRY 16TH NATIONAL HEAT TRANSFER CONFERENCE ..

l- R. Braun, R. H. Hausler. St. Louis, August 11,1976, Paper #76-l CSME/CSChE - 23.

l .

i 15. PRACTICAL EXPERIENCES WITH LINEAR POIARIZATION MEASUREMENTS R. H. Hausler, Corrosion, 33. (No. 4) 117-1977

! 16. CORROSION INHIBITION AND INHIBITORS l R. H. Hausler, Published in ACS Symposium Series Vol. 89, " Corrosion i Chemistry"; p. 262-320,1977, Jan.1979.

17. ECONOMICS OF CORROSION CONTROL j R. H. Hausler, Materials Performance 12, (#6) 9,1978 i 18. OIL TREATING CHEMICALS - EMULSIONS R. H. Hausler, Oil & Gas Journal, September 4,1978.

19. SCALING AND SCALE CONTROL IN OILFIELD BRINES R. H. Hausler, Oil & Gas Journal, Sept. 18,1978.

20. CORROSION INHIBITION AND GALVANIC COUPLES IN THE OILFIELD R. H. Hausler, Paper presented NACE: CORROSION /79, Atlanta, Georgia, 1979, paper #17 9

j l

1 a

2L (

PREVENTING SCALE AND EMULSION PROBLEMS IN OIL PRODUCTION

} R. R Hausler, Invited paper presented before the International Petroleum Exhibition, Tulsa, Oklahoma, Sept.1979 i

22.

CORROSION MONITORING IN CHEMICAL CLEANING SOLUTIONS i

R. R Hausler, J. M. Jevec, W. S. I.medy; NACE: Corrosiorv831983 Paper No.

! 227 p.13.

i 23.

I.ABORATORY INVESTIGATIONS OF THE CORROSION MECHANISM AS l APPLIED TO HOT DEEP GAS WELLS i

R. H. Hausler; NACE: Corrosion /831983 paper No. 47,16 p; Advances in l CO2Corrosion, Vol 1, p. 72, (1984).

24.

THE COPRA CORRELATION - A QUANTITATIVE ASSESSMENT OF DEEP HO GAS WELL CORROSION AND ITS CONTROL-i R. H. Hausler; NACE: Corrosion /831983 Paper No. 48 37 p; Advances in

! CO2Corrosion, Vol.1. P. 87 (1984).

25.

1 THE ROLE OF HYDRAZINE IN EDTA CONTAINING CHEMICAL CLEANING SOLVENTS  !

R. H. Hausler NACE: Corrosion /821982 Paper No. 30,12 p.

26.

CORROSIVENESS OF EDTA CHEMICAL CLEANING SOLUTION R. H. Hausler, A. L Savage; NACE: Corrosion /821982 Paper No. 31,15'p.

27.

INHIBITION OF CORROSION REACTION BY CORROSION PRODUCT LAYERS OF 'IYPE METAL ION CHELATING AGENTS R. H. Hausler; NACE: Corrosion /81,1981 Paper No. 252,17 p.

28.

CORROSION INHIBITION AND GALVANIC COUPLES IN THE OILFIELD R. H. Hausler, NACE: Corrosion /791979 Paper No.17 29.

NONPROPRIETARY CORROSION INHIBITORS FOR SOLVENTS TO CLEAN STEAM GENERATORS R. H. hausler, EPRI Final Report (346 pp) #NP-3030), Project S-148, June 1983.

30.

THE IMPORTANCE OF THE INTERPHASE IN THE CONTROL OF CORROSION IN EDTA SOLUTIONS R. H. Hausler, Presented before the International Conference on Corrosion Inhibition, NACE May 1983, published in CORROSION INHIBITION, NACE-7, p.132 (1988).

10

39.

i STUDIES RELATING'ID THE PREDICITVENESS OF CORROSION INHIBITOR EVALUATIONS IN LABORATORY AND FIELD ENVIRONMENTS j

R. H. Hausler, D. W. Stegmann, EUROPEC/88, I.ondon, SPE paper #18369, j 1988, accepted for publication in Petroleum Production Engineering,1990.

i

40.

IABORATORY STUDIES ON FLOW INDUCED LOCALIZED CORROSION IN CO/H S ENVIRONMENTS, I. DEVELOPMENT,OF TEST METHODOLOGY D. W. Stegmann, R. Hausler, C I. Cruz, H. Sutanto, presented at 6th Asian Paci6c Corrosion Control Conference, Singapore, September 1989; also

{ accepted for CORROSION /90, NACE 1990, paper #90005.

41.

LABORATORY STUDIES ON FLOW INDUCED LOCALIZED CORROSION IN CO,H S ENVIRONMENTS, IL PARAMETRIC STUDIES ON THE EFFECTS OF H S, CONDENSATE, METALLURGY AND FLOWRATE.

R. H. Hausler, D. W. Stegmann, C I, Cruz, D. Tjandroso, ibid.

42.

LABORATORY STUDIES ON FLOW INDUCED LOCALIZED CORROSION IN CO/H 2S ENVIRONMENTS, IIL CHEMICAL CORROSION INHIBITION R. H. Hausler, D. W. Stegmann, C I. Cruz, D. Tjandroso, ibid.

43. THE COPRA CORRELATION REVISITED R. H. Hausler, T. D. Garber, accepted for presentation at CORROSION /90, NACE 1990, paper #90045.

44.

CO CORROSION AND ITS INHIBITION UNDER EXTREME SHEAR STRESS '

O. Schmitt, T. Simon, R. H. Hausler, accepted for presentation at CORROSION /90, NACE 1990 paper #90022.

45.

CHEMICAL INHIBITION OF FLOW INDUCED LOCALIZED CORROSION IN CO CONTAINING MEDIA R. H. Hausier, D. W. Stegmann, Proceedings of the 7th European Symposium on Corrosion Inhibitors, p. 1247,1990, Ferrara, Italy, Sept.1990.

46. INTERPRETATION OF LINEAR POLARIZATION MEASUREMENTS (Discussion Contribution) DECHEMA Monograph, Vol.101, Electrochemical Corrosion Testing, p. 109-114, 1986.

12

. i BOOKS I L

CORROSION IN OIL AND GAS PRODUCTION '

L E. Newton, R. H. Hausler, NACE, Houston, TX.1983.

i 2.

ADVANCES IN CO: CORROSION VOL 1 R. H. Hausler, H. L Godard, NACE, July 1985.

3.

CORROSION INHIBmON R. H. Hausler, NACE-7,1988.

AWARDS AND RECOGNmON

1. }

NACE Technical Achievement Award, May,1990.

2.

Plenary I.ecture,6th Asian Pacific Corrosion Control Confe 1989. , .

3.

Plenary Lecture, 7th European Symposium on Corrosion In Sept.1990.

i 4.

Plenary I.ecture,5th Middle East Corrosion Conference, Bahrain, Ja d

4 13

PAPERS PRESENTED BEFORE TECHNICAL MEEIINGS i

by R. H. Hausler 1

1. Corrosion in H,S Containine Media. before the NACE, T8-2 Committee, January, 1970.

2. Corrosion and Corrosion Inhibition in H,S and C1 Containing Media. before the Montreal, Canada, Section of the NACE, December 8,1970.

3. Time Effects on Polarization Measurements. before the Chicago Section of the NACE, May 18,1971.

4. Rust Inhibition and Inhibitor Testina. before the North Central-Northeast NACE Regional Conference, October 16-18, 1972.

5. Process Side Fouline of Heat Exchanners. before the NACE T8 2 Committee, Chicago, March 8,1973.

6. On the Mechanism of Hydrochloric Acid Inhibition by Organic Molecules: Presented 5 at the Gordon Research Conference on Corrosion, July 1974.

7. On the Mechanism of Corrosion Inhibition by Oreanic Chemicals before the Chicago Section of the Electrochemical Society, January 9,1975.

8. Seminar on Corrosion and Fouline in the Petroleum Industry. Full day seminar given before the engineers of the Peruvian Petroleum Company (Petroperu) upon invitation, June 22,1975, Lima, Peru. -

9. Linear Polarization Techniaue. Paper presented before NACE-Corrosionn6, Houston, Texas, March 22-26,1976.

10. Corrosion Inhibition. Presented as ACS/NACE/ECS sponsored short course on .

Chemistry in Corrosion, Chicago, February 24,1976.

11. Corrosion Inhibitors and Sulfide Corrosion. presented before the NACE Western Kansas Section, Great Bend, KS., May 7,1976.

12. Cooline Water Treatment. Presented before the first annual Corrosion Control Seminar Sponsored by the Kansas Section of the NACE, November 9,1977, Great Bend,KS. '

13. Economics of Corrosion Control. Dinner Talk before the Srst annual Corrosion Control Seminar sponsored by the NACE Great Bend, KS. Section.

14'

i

. \

3, .

)

l 14.

Corrosion Inhibition and Galvanic Couoles in the Oilhld. NACE North Central Regional Meeting, October 19-21, (1981).

15.

Mechaniem of Corrosion Inhibition with Reference to Automotive Coolants. NACE North Central Regional Meeting, Octo er 19-21 (1981).

16. CO, Corrosion in the Oil and Gas Production. and Overview. NACE South Central Regional Meeting, Oklahoma City, October,1983.

17. CO, Corrosion in Oil and Gas Production. An Overview. presented before the Corrosion Center of the University of Manchester Institute of Technology, July 4, 1985.

18. New Mechanism for Pittina of Carbon Steel in Inhibited Hydrochloric Acid.

presented before the faculty of the Materials Engineering Department of the University of Ferrara, June 24,1985.

19. Metallurcical Effects on Corrosion Inhibition. presented before the faculty of the Corrosion Center of the Institute for Technical Chemistry and Petrc+;u.; Twmistry ,

at the University of Aachen, June 28 (1985).

20. CO, Corrosion and Prevention. Formal seminar presentation at NAM-Assen (Holland) June 20 (1985).

. 1

21. Systems Anoroach to Corrosion Eneineerina as Aonlied to Oil and Gas Production.

presented before the AI.L-Union Union Oil Institute, Krasnodar, Russia, June 1985.

22.

The Effect of Ohmic Resistance on Linear Polarization Measurements for Corrosion Rate Determination. presented before the NACE Chicago Section, October,1973.

23. Corrosion Monitorina in Sweet Production. NACE, Canadian Region Western Conference, Calgary, Febr. 25 (1986).

24. Overview of the CO, Corrosion Mechanism and inhibition of Erosion Corrosion.

NACE South Central Region Committee, Lafayette, Nov. 16-18, 1987.

l

. 25. Novel Anoroach Toward k<assine Inhibitor Cost for CO, Corrosion: Fr= mole of a I CO, Flood. ibid. -

26. Systems Anoroach to Corrosion Inhibition of Gas and Gas Condensate Producina Facilities. Gulf Coast Corrosion Seminar Febr.1987.

27. Predictina Corrosion Inhibitor Performance - Imboratory Evaluations vs. Field Performance. New Orleans NACE Section Meeting, Jan. 22,1990.

l 15 I

- . . ~ . . _ . . - - - . _ . -. .- . -. - . - -. , . -

1 l.

l '. PATENTS t

i USP 3 790 4% R. H. Hausler; Alkylene Polyamine Polymeric Reaction Product i Corrosion Inhibitor

. USP 3 609 549 R. H. Hausler, R. W. Sampson; Corrosion Measuring Device i

a USP 3 810 009 R. H. Hausler, ' R. W. Sampson; Apparatus for Measuring ,

Fouling of a Test Specimen i

~

USP 3 731187 R. H. Hausler. R. W. Sampson; Temperature Compensated Fouling Measuring Method and Apparatus USP 3 705109 R. H. Hausler, L A. Goeller; Corrosion Inhibiting Composition and Use Thereof USP 3 622 503 R. H. Hausler, Hydrogen Transfer Agent for Slurry Processing of Hydrocarbonaceous Black Oil USP 3 562138 R. H. Hausler; ' Structural Element for Use in an Electrolytic Cell ,

Swiss Patent 4393/62 V. Spreter, R. H. Hausler, Electrode pour' Element

,Galvanique USP 3 696 049 R. H. Hausler, L A. Goeller; Corrosion Inhibiting Composition and use Thereof USP 3 696 048 R. H. Hausler, L A. Goeller, Corrosion Inhibiting Composition and use Thereof USP 3881957 R. H. Hausler; Electrochemical Cell Comprising a Catalytic Electrode of a Refractory Oxide and a Carbonaceous Pyropolymer USP 3 913 378 R. H. Hausler; Apparatus for Measuring Fouling on Metal Surfaces USP 3 923 606 R. H. Hausler, Prevention of Corrosion USP 3 972 732 R. H. Hausler; Electrochemical Cell USP 4 454 006 R. H. Hausler, L Savage, J. B. Harrell; Method and apparatus for Measuring Total Corrosion Rate 16 i

j

o

. a USP 4 495 336 R. H. Hausler, N.E.S. Thompson; Mercapto-Polycarboxylic Acids i

EP 027 5651 R. H. Hausler, B. A. Alink, M. E. Johns, D. W. Stegmann; i Carbondioxide Corrosion Inhibiting Composition

i and Method of Use Thereof.

, EP 927 5646 R. H. Hausler, Carbon Dioxide Corrosion Inhibiting Comp 3sition ,

and Method of Use Thereot I

i b

4 4

17

1.

!

• EDUCATIONAL LECTURES i

by R. H. Hausler I

i i

i I- 1. Electrochemistry - a Modern Challence: . presented December 1966 to Science Seminar at Taylor University, Marion, Indiana. February 1970, to Science Seminar '

of the ACS Student Affiliate Chapter at University of Illinois, Circle Campus, Chicago.

i L 2. Corrosion-5 Billion Dollar Business. presented to an advanced Science Class as l Hillcrest High School, Country Club Hills, Illinois, December 13,1972.

3. Discussion on Cathodic Protection. together with' Harry E. Kroon of Illinois Bell

] Telephone, presented at an Educational Seminar of the Chicago Section, NACE, May j 1970.

4 j 4.

• Aeolication of Potentiostatic Techniaues in Corrosion Research. presented at an

! Educational Seminar of the Chicago Section, NACE, October 24,1970.

$ 5. Electrical Methods for Determinine Corrosion Rates. at the 4th Annual Seminar on ,

Fundamentals of Corrosion, Milwaukee School of Engineering, November 23,1971.

6. _ Organic Corrosion Inhibii6n and, i

j. 7. Corrosion Prevention in 'the Chemical Process Industrv. both presented at the j j Summer Engineering Conference o' n Corrosion Engineering, University of Michigan, l

l Ann Arbor Michigan, June 19-23,1972, published in the Proceedings.  ;

I -

j 8. Chemistry of Corrosion. course taught at the Illinois Institute of Technology, Evening ,

j Division (Chem 544),3 credit hours, Jan May,1975. l i i

9. Chemistry of Corrosion. course taught for DeSoto,Inc. Research Centre, started Nov.

l 1975,15 2-hour lectures.

4 l 10. Statistical Desien and Evaluation of Exoeriment. 20 2-hour lectures with examples j and applications presented in-house at UOP.

11. " Corra=ian Kneineerine (Course based on MIT Video Tapes), organized 20 seminars l- at Petrolite and 1/2 hour discussion sessions follcwing review of tapes.

4 L

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18 i

l 4

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CONTINUED PROFESSIONAL EDUCATION i

1. Short Course on Corrosion. University of California Extension, Los Angeles, June 26-l 30, 1967,.

2.

Short Course on Statistical Desien and Evaluation of Exoeriments. University of i

Detroit, Summer 1966.

1 3.

' Engineerir..r Summer Short Course on Statistical Exoerimental Desien. University of Wisec sin Extension, Madison Wisc. June 24-28,1968.

} 4.

Evolutionary Ooerations ar.d Non-Linear Estimating. Short Course, Chicago,1967.

5.

R&D and New Venture Mananement. University of Wisconsin Extension, Madison, Wisconsin, May 15-16, 1969.

6. Industrial Research Institute. Mid-Management Grouns Seminar. New York, October

, 28-30, 1973.

I /

7. Gordon Research Conferences: Electrochemistry 1965,1966,1967,1968; Corrosion

, 1969,1971,1973.

8.

Two Phase Gas-Liould Flow. University of Houston, February 22 26, (1982).

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l.,. -

{

I I i

. . 'i 1

i

• PROFESSIONAL ACITVITIES

} THE ELECTROCHEMICAL SOCII!TY Member since 1964

e Chicago Section Secretary 1964-1 % 5 1

Treasurer 1966-1967

Vice-Chairman 1966-1 % 7

! Chairman 1 % 7 1968 j Councilor 1972-1976 e National Meeting 1968 Co-Treasurer j e National Meeting 1973 Hospitality Chairman 1 THE NATIONAL ASSOCIATION OF CORROSION ENGINFFRS i

l Member since 1968 ,

?

l e Chicago Section Treasurer 1971-1973 ..

j Vice-Chairman 1973-1974 i Chairman 1974-1976 4 <

i

e l National Meeting 1974 ' General Chairman

} e North Central Region Program Chairman 1972 '

i Regional Meeting i

! i 1

Education Chairman 1982-1985 1 l

l e Unit Committee T-3A Chairman 1973-1975 -

e Research Committee Member 1975-1978 i

l i Vice-Chairman 1983-1984 i j Uaison Education Committee i 1982-1984

! Liaison TPC 1981-1983

( -

e Education Committee Member 1983-1985 i

j e Awards Committee Member 1984-1986 i

{ 20 i

j i

..r.- ,

1 e Group Committee T-1 Member 1976-Vice Chairman T-1-3 1981-1984 Various T-1 Unit Committees and Task

. Groups e Organized numerous conferences, among others:

• International Conference on Corrosion Inhibition, Dallas,1983 l e International Symposium on.CO2 Corrosion, Los Angeles,1983

~

e Co-Editor Advances in Corrosion Inhibition (in preparation).

THE CHICAGO TECHNICAL SOCIETIES COUNCIL Member 19ti8 Treasurer 19'TO-1972 Vice-Chairman 1972-1974

Chairman 1974-1975 Awards Jury 1970-1976 4

+

21