ML102140405
| ML102140405 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/26/2010 |
| From: | Division of Operating Reactor Licensing |
| To: | |
| Boska J, NRR, 301-415-2901 | |
| References | |
| G20100368, NRC-371, TAC ME4041 | |
| Download: ML102140405 (49) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board RE: Vermont Yankee Nuclear Power Station Mark Leyse & Raymond Shadis on behalf of the New England Coalition Docket Number:
50-271 Location:
(telephone conference)
Date:
Monday, July 26, 2010 Work Order No.:
NRC-371 Pages 1-39 Edited by John Boska, NRC Petition Manager NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 4 CONFERENCE CALL 5
RE 6
VERMONT YANKEE NUCLEAR POWER STATION 7
+ + + + +
8
- MONDAY, 9
JULY 26, 2010 10
+ + + + +
11 12 The conference call was held at 2:03 p.m.,
13 Ted Quay, Chairman of the Petition Review Board, 14 presiding.
15 16 PETITIONERS: MARK LEYSE & RAYMOND SHADIS ON BEHALF OF 17 THE NEW ENGLAND COALITION 18 19 PETITION REVIEW BOARD MEMBERS:
20 TED QUAY, Deputy Director, Division of Policy and 21 Rulemaking, Office of Nuclear Reactor Regulation 22 (NRR) 23 JOHN BOSKA, Petition Manager for 2.206 petition, 24 Plant Licensing Branch 1-1, NRR 25
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1 PETITION REVIEW BOARD MEMBERS: (cont'd) 2 BRETT KLUKAN, Attorney, Office of General Counsel 3
TANYA MENSAH, Petition Coordinator, NRR 4
SHIH-LIANG WU, Nuclear Performance and Code Review 5
Branch, NRR 6
RICHARD DUDLEY, Rulemaking and International Projects 7
Branch, NRR 8
THOMAS SETZER, Senior Project Engineer, Division of 9
Reactor Projects, NRC Region I 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
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P-R-O-C-E-E-D-I-N-G-S 1
(2:03 p.m.)
2 MR. BOSKA: I would like to thank 3
everybody for attending this meeting.
4 My name is John Boska, and I'm the NRC's 5
Petition Manager for this petition.
6 We are here today to allow the 7
Petitioners, Mr. Leyse and Mr. Shadis, to address the 8
Petition Review Board on behalf of the New England 9
Coalition regarding their 2.206 petition dated June 7, 10 2010, on the fuel peak cladding temperature at the 11 Vermont Yankee Nuclear Power Station, which is located 12 near Brattleboro, Vermont.
13 I
am the Petition Manager for the 14 petition. The Petition Review Board Chairman is Ted 15 Quay.
16 Mr. Leyse and Mr. Shadis made an initial 17 presentation to the Petition Review Board, which we 18 may also refer to as the PRB, on June 23, 2010. In a 19 subsequent internal PRB meeting, the PRB's initial 20 recommendation was to not accept this petition for 21 review.
22 This meeting is scheduled to conclude by 23 3:00 p.m. The meeting is being recorded by the NRC 24 Operations Center and will be transcribed by a Court 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 4
Reporter. The transcript will become a supplement to 1
the petition. The transcript will also be made 2
publicly available.
3 I would like to open this meeting with 4
introductions. As we go around the room, please 5
clearly state your name, your position, and the office 6
that you work for within the NRC for the record.
7 I'm John Boska. I'm a Project Manager in 8
the Office of Nuclear Reactor Regulation, which is 9
also referred to as NRR.
10 CHAIRMAN QUAY: I'm Ted Quay. I'm the 11 Petition Review Board Chairman, and I'm also in NRR.
12 MR. WU: Shih-Liang Wu. I'm technical 13 staff working for NRR, in the Nuclear Performance and 14 Code Review Branch.
15 MR. DUDLEY: Richard Dudley. I'm in the 16 NRR Rulemaking Group.
17 MR. SLOAN: I'm Scott Sloan, NRR, as an 18 observer.
19 MS. POPOVA: I'm Alex Popova. I'm a 20 summer hire for the Division of Operating Reactor 21 Licensing, and I'm an observer.
22 MS. SALGADO: I'm Nancy Salgado. I'm a 23 Branch Chief in the Division of Operating Reactor 24 Licensing.
25
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MS. GIBSON: Lauren Gibson from the 1
Division of Operating Reactor Licensing as an 2
observer.
3 MS. INVERSO: I'm Tara Inverso from the 4
Division of Policy and Rulemaking as an observer.
5 MS. MENSAH: Tanya Mensah, the 2.206 6
Coordinator, Division of Policy and Rulemaking.
7 MR. KLUKAN: Brett Klukan, Office of 8
General Counsel.
9 MR.
BOSKA:
We have completed 10 introductions in the room here. At this time, are 11 there any other NRC participants from NRC headquarters 12 on the phone?
13 (No response.)
14 All right. Any NRC participants from the 15 NRC regional office on the phone?
16 MR. SETZER: Hi. This is Tom Setzer. I'm 17 a Senior Project Engineer from Region I.
18 MR. BOSKA: Are there any representatives 19 for the licensee on the phone?
20 (No response.)
21 Mr. Leyse, would you please introduce 22 yourself for the record?
23 MR. MARK LEYSE: Sure. Mark Leyse.
24 MR. BOSKA: And, Mr. Shadis, would you 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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please introduce yourself for the record?
1 MR. SHADIS: Yes. This is Raymond Shadis, 2
last name S-H-A-D-I-S, for New England Coalition.
3 MR. BOSKA: Thank you.
4 MR. MARK LEYSE: And Mark Leyse speaking.
5 I believe Robert Leyse is going to also speak.
6 MR. ROBERT LEYSE: Correct.
7 MR. BOSKA: All right. We understand Mr.
8 Robert Leyse is also on the line.
9 MR. ROBERT LEYSE: Yes.
10 MR. BOSKA: Thank you. And we also 11 understand there are members of the public.
12 I would like to emphasize that we each 13 need to speak clearly and loudly to make sure that the 14 Court Reporter can accurately transcribe this meeting.
15 If you do have something that you would 16 like to say, please first state your name for the 17 record.
18 For those dialing into the meeting, please 19 remember to mute your phones to minimize any 20 background noise or distractions. If you don't have a 21 mute button, this can be done by pressing the keys 22 star 6. To unmute your phone, press the star 6 keys 23 again.
24 Please do not place this call on hold, 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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since many phone systems play music when a call is on 1
hold, which is very annoying for the other callers.
2 Thank you.
3 At this time, I will turn it over to the 4
Petition Review Board Chairman, Ted Quay.
5 CHAIRMAN QUAY: Good afternoon. I'm Ted 6
Quay, the Petition Review Board Chairman. Welcome to 7
this meeting regarding the 2.206 petition submitted by 8
Mr. Leyse and Mr. Shadis.
9 I
would like to first share some 10 background on our process. Section 2.206 of Title 10 11 of the Code of Federal Regulations describes the 12 petition process: the primary mechanism for the 13 public to request enforcement action by the NRC in a 14 public process. This process permits anyone to 15 petition the NRC to take enforcement-type related 16 action to NRC licensees or licensed activities.
17 Depending on the results of its 18 evaluation, the staff could modify, suspend, or revoke 19 an NRC-issued license, or take any other appropriate 20 enforcement action to resolve a problem. The NRC 21 staff's guidance for disposition of 2.206 petition 22 requests is in Management Directive 8.11, which is 23 publicly available.
24 The purpose of today's meeting is to give 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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the Petitioners an opportunity to provide any 1
additional explanation or support for the petition.
2 The Petitioners have been advised that the Petition 3
Review Board's initial recommendation is to reject 4
this petition, as the PRB found no evidence that 5
Vermont Yankee was in violation of an NRC rule.
6 This petition describes what the 7
Petitioners believe are deficiencies in existing NRC 8
rules, and the PRB believes the proper process for it 9
is the rulemaking process.
10 This meeting is not a hearing, nor is it 11 an opportunity for the Petitioners to question or 12 examine the Petition Review Board on the merits or the 13 issues presented in the petition request. No decision 14 regarding the merits of this petition will be made at 15 this meeting.
16 Following this
- meeting, the Petition 17 Review Board will conduct its internal deliberations.
18 The outcome of this internal meeting will be 19 communicated to the Petitioners. The Petition Review 20 Board typically consists of a Chairman, usually a 21 manager at the Senior Executive Service level at the 22 NRC. It has a Petition Manager and a Petition Review 23 Board Coordinator. Other members of the Board are 24 determined by the NRC staff based on the content of 25
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the information in the petition request.
1 At this time, I would like to introduce 2
the Board. I'm Ted Quay, the Petition Review Board 3
Chairman. John Boska is the Petition Manager for the 4
petition under discussion today. Tanya Mensah is the 5
office Petition Review Board Coordinator.
6 Our technical staff includes Shih-Liang Wu 7
from NRR's Nuclear Performance and Code Review Branch; 8
Tom Setzer from NRC's Region I, Division of Reactor 9
Projects; and Richard Dudley from NRR's Rulemaking 10 Branch.
11 We also have legal advice from Brett 12 Klukan from the Office of General Counsel.
13 As described in our process, the NRC staff 14 will ask clarifying questions in order to better 15 understand the Petitioners' presentation and to reach 16 a reasoned decision whether to accept or reject the 17 Petitioners' request for review under the 2.206 18 process.
19 I would like to summarize the scope of the 20 petition under consideration and the NRC activities to 21 date. On June 7, 2010, Mr. Leyse and Mr. Shadis 22 submitted to the NRC a petition, ML Number 101610121, 23 under 10 CFR 2.206, regarding the fuel peak cladding 24 temperature at the Vermont Yankee Nuclear Power 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 10 Station, which may also be referred to as VY.
1 Petitioners request that the NRC order the 2
licensee to lower the licensing basis peak cladding 3
temperature in order to provide a necessary margin of 4
safety. The Petitioners state that VY's licensing 5
basis for a peak cladding temperature of 1960 degrees 6
F does not provide a necessary margin of safety to 7
prevent fuel from melting in the event of a loss of 8
coolant accident, referred to as a LOCA, L-O-C-A.
9 The Petitioners state that data indicates 10 the licensing basis peak cladding temperature should 11 be lowered at least to 1832 degrees F, and possibly 12 lower. The Petitioners also state that, although 13 revisions to 10 CFR 50.46(b)(1) limit of 2200 degrees 14 F on peak cladding temperature has been proposed in a 15 rulemaking petition, this petition has been filed 16 separately under 2.206, because the concerns brought 17 forward are plant-specific and have immediate bearing 18 on safety margins at Vermont Yankee and require prompt 19 NRC review and action.
20 Allow me to discuss the NRC activities to 21 date. On or about June 7, 2010, the NRC received this 22 petition. On June 8th, this petition was assigned to 23 the NRC's Office of Nuclear Reactor Regulation for 24 evaluation.
On June
- 23rd, the Petitioners 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 11 participated in a teleconference with the Petition 1
Review Board. The transcript of that teleconference 2
is publicly available from the NRC's website under 3
ADAMS Accession Number ML101890014.
4 On July 8th, the Petition Manager informed 5
the Petitioners that the PRB's initial recommendation 6
was to reject this petition and offered the 7
opportunity for a meeting with the PRB. That led to 8
this teleconference.
9 As a reminder for our phone participants, 10 please identify yourself if you make any remarks, as 11 this will help in the preparation of the meeting 12 transcript that will be made publicly available.
13 Thank you.
14 Mr. Leyse and Mr. Shadis, I will turn this 15 over to you right now to allow you to provide any 16 information you believe the PRB should consider as 17 part of this petition, especially reasons why this 18 petition should be considered separately from the 19 petition for rulemaking.
20 Mr. Leyse and Mr. Shadis, you may now 21 proceed.
22 MR. SHADIS: Thank you. This is Raymond 23 Shadis. If I may, Mark, if it's good with you, I'll 24 lead off.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 12 MR. MARK LEYSE: Yes, I think that's a 1
good idea. Mark Leyse speaking. And then, my father 2
will -- Robert Leyse will follow you, and then I will 3
follow Robert Leyse.
4 MR. SHADIS: Thank you. I want first to 5
try to restate, in the plainest terms, what our 6
concern is. First, this petition is brought by New 7
England Coalition. New England Coalition is not a 8
party to any proceeding where this concern could be 9
admitted as part of the proceeding.
10 New England Coalition was not a party or a 11 commentator with respect to the rulemaking petition.
12 As we see it, we have no means of involving ourselves 13 in that petition. Therefore, as we see it, we have no 14 recourse other than the 2.206 process. This is our 15 only means of redress for what we see as a very 16 serious safety concern at Vermont Yankee Nuclear Power 17 Station.
18 Our concern, in simple terms, is that if 19 this particular plant, because of a loss of coolant 20 accident, should reach, exceed, or even approach the 21 licensing basis peak cladding temperature, there may 22 be at that point a chemical reaction initiated with 23 the fuel cladding that would greatly accelerate the 24 buildup of heat and temperature to the extent that 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 13 there would be no credible means of recovery.
1 And with respect to Vermont Yankee in 2
particular, this is a
powerplant where various 3
accident-mitigation-related components have been in 4
recent history shown to be inoperable at any given 5
point. We cannot ascertain how many such defects may 6
exist.
7 Our concern is that there should be no 8
allowance for any defects in accident mitigation 9
systems, and I would point in particular to the most 10 recent inspection report that we have in which the 11 high pressure coolant injection system was inoperable 12 for a period of time, and also in which safety-related 13 cables connected to the emergency diesel generators 14 were submerged, although they were not qualified for 15 wet conditions or submerged conditions.
16 The real questions here are the degree to 17 which the licensee would depend on any of these 18 systems when it comes to accident mitigation. We are 19 very concerned that the timeframe in which the 20 licensee has to act is very short, that the buildup of 21 temperature to peak cladding temperatures is a matter 22 of minutes, not hours, and that that time in which to 23 respond is shortened exponentially if you reach the 24 point at which the fuel cladding begins to rapidly 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 14 oxidize.
1 So, you know, those variables, if you 2
will, can add up rather quickly to eliminate the 3
margin that has been allowed. Our position is that 4
for safety's sake the maximum margin obtainable for 5
the design peak cladding temperature and any likely 6
experienced peak cladding temperature has to be as 7
wide as it can be. And that is definitely not the 8
case at Vermont Yankee.
9 So, in short, it is New England Coalition 10 bringing this petition. We have no other recourse 11 that we can find within NRC regulation, other than the 12 2.206. And the issue is one of gravest, gravest 13 safety concern, and one of immediacy.
14 Thank you.
15 MR. BOSKA: Mr. Shadis, we have some 16 questions from the Petition Review Board for you.
17 MR. SHADIS: Thank you.
18 MR. KLUKAN: Mr. Shadis, this is Brett 19 Klukan. You say, Mr. Shadis, that New England 20 Coalition had no other recourse. Why couldn't New 21 England Coalition have submitted the 2.206 as a 22 petition for rulemaking?
23 MR. SHADIS: What forecloses that is the 24 fact that rulemaking is a process that generally takes 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 15 a few years. It is --
1 MR. KLUKAN: I mean, that process is still 2
available to you.
3 MR.
SHADIS:
- Well, the process is 4
available. One thing is that a rulemaking on the 5
generic question of peak cladding temperature is 6
already underway. It is -- as far as we can read the 7
regulation, we are precluded from filing a petition 8
for rulemaking on top of that petition for rulemaking.
9
- But, in
- addition, it is simply 10 inappropriate because the rulemaking takes as long as 11 it does to address general issues, whereas in this 12 case there is the immediacy of the fact that VY is 13 being run at 120 percent of its original design 14 capacity, and the yield in fission products and the 15 resultant decay heat from that is greater, out of 16 proportion, than the original.
17 So, you know, this is -- again, this is 18 immediate, and it is particular to VY. So we don't 19 think -- our reading of it is that we can't enter into 20 a rulemaking, and, if we did, it would be not 21 productive, not appropriate, because of the timeframe 22 involved in getting NRC action.
23 MR. KLUKAN: Thanks. Two additional 24 questions. This is again Brett.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 16 MR. SHADIS: Sure.
1 MR. KLUKAN: So you are -- just to 2
understand why this is -- why you believe this is 3
distinct from the generic, is because of VY's history 4
of inoperable accident mitigation devices? Is that 5
what is different about it, that they have, in your 6
opinion, a poor history?
7 MR. SHADIS: Well, that is one factor, and 8
in that I -- you know, in my own inarticulate way, I 9
tried to point to the fact that if you have a very 10 small margin of safety between your design maximum 11 peak cladding temperature and what you may -- you 12 know, at what temperature you may actually get a rapid 13 oxidation
- reaction, then that small margin is 14 susceptible to any number of variables that you can 15 throw in. I mean, you may have an issue with failure 16 of a few control assemblies to insert.
17 And, you know, with Vermont Yankee there 18 is a concern for shadow corrosion that might distort 19 the channels and prevent that from happening. You 20 might have a question of blockage. With Vermont 21 Yankee, you have a steam hood, steam dryer, that has 22 got a number of cracks in it. And within the dynamics 23 of a loss of coolant accident, it might result in 24 loose parts that could cause blockage.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 17 What I'm saying is that those kinds of 1
considerations, plus the fact that there has been a 2
history of inoperability of various accident 3
mitigation systems, can add up to -- you know, those 4
variables can add up to effectively eliminate that 5
small margin. Our position is that that margin needs 6
to be expanded.
7 MR. KLUKAN: By "margin," do you mean the 8
temperature?
9 MR. SHADIS: Yes, the difference between 10 your license design peak cladding temperature and the 11 peak cladding temperature at which an exothermic 12 reaction may begin.
13 MR. MARK LEYSE: Mark Leyse. I just want 14 to state one thing. It would be the temperature where 15 there would be an exothermic reaction that would 16 begin, which would then -- the heat generated by that 17 reaction would in turn speed up the reaction rate, 18 which would in turn generate even more heat, so there 19 would be a loop and there would be runaway oxidation, 20 and that could perhaps, according to experimental 21 data, commence at 1832 degrees Fahrenheit roughly, 22 which is well below the current license basis peak 23 cladding temperature at Vermont Yankee.
24 Anyway, I'll turn it back to Ray. I just 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 18 wanted to interject that.
1 MR. SHADIS: Thank you, Mark, for that 2
clarification.
3 MR. BOSKA: This is John Boska. There's 4
no further questions from the Petition Review Board, 5
so you may continue with the presentation.
6 MR. SHADIS: Well, I am, at least at this 7
point, unless there are some points to be clarified or 8
followed up on after Robert and Mark Leyse present, I 9
am done for the time being. So I will just step 10 aside, and I think Robert Leyse is next as far as I 11 recall.
12 MR. ROBERT LEYSE: Okay. Thank you. This 13 is Robert Leyse, and I want to thank John Boska for 14 getting my two slides to the Petition Review Board. I 15 will read these.
16 Slide 1 of 2, preventing thermal runaway.
17 It is disturbing that the Petition Review Board 18 reports, "There was considerable technical review 19 involved in the selection of 2200 degrees, and it will 20 involve considerable technical review to reach a 21 decision on PRM 50-93, and decide if that number 22 should be revised."
23 This 2.206 petition calls for prompt 24 action independent of PRM 50-93. It is a fact that 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 19 the considerable technical review involved in the 1
selection of 2200 degrees was focused on embrittlement 2
criteria, not thermal runaway.
3 There is no need for considerable 4
technical review and further delays to confirm that 5
2200 degrees is non-conservative. The evidence is 6
complete. NRC has apparently never studied Baker-7 Just, ML050550198, and until recently it did not even 8
have copies of the key references.
9 Figure 16 is copied from page 37 of the 10 Baker-Just report. And for the record, it shows the 11 effects of temperature on the zirconium-water 12 reaction. It lists data points by three separate 13 investigators. However, only the Lemmon data includes 14 the temperature region that is really pertinent to 15 what we are talking about.
16 That is, the Lemmon data covers a pretty 17 wide range, but it is the only investigator who covers 18 from 1000 Centigrade up to a little over 1200 19 Centigrade, which is, in my opinion, the region of 20 interest.
21 So slide 2 of 2, preventing thermal 22 runaway. The Lemmon report, ML100570218, was not 23 acquired by the NRC until April 2010. Figure C1 is 24 from page C4, and the adjacent figure is excerpted 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 20 from the flow sheet, Figure C3 on page C5. Note the 1
Figure C1, the Zircaloy-2 specimen, two inches long, 2
half-inch in diameter, with a hole roughly half the 3
length for a thermocouple installation.
4 To the right you see the excerpted figure, 5
which shows the specimen in place within a Vycor tube, 6
which isn't labeled as such, with an induction coil 7
around it.
8 THE COURT REPORTER: This is the Court 9
Reporter. We're getting audio interference that is 10 going to make transcribing this portion difficult, if 11 not impossible. If you are not speaking, if you could 12 mute your phone, we would appreciate it.
13 MR. ROBERT LEYSE: I don't believe I am 14 causing it. This is Robert Leyse.
15 Okay. I will proceed. Anyway, getting 16 back to the
- slide, Lemmon induction heated a
17 Zircaloy-2 cylinder two inches long by a half-inch in 18 diameter, as illustrated in the above figures.
19 So now I'll read the last paragraph of 20 that slide. It is absurd to license the emergency 21 cooling of tons of zirconium alloy with thousands of 22 square feet of interfacial surface area based on the 23 limited investigations that yielded the Baker-Just 24 equation. Despite this, Appendix K to Part 50, ECCS 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 21 Evaluation Models, Item 5, specifies that the rate of 1
energy release from the metal/water reaction shall be 2
calculated using the Baker-Just equation and 3
Number 50.46, Acceptance
- Criteria, Item (b)(1),
4 specifies the 2200 degrees. Moreover, this 2.206 5
petition presents data from multi-rod (assembly) 6 severe fuel damage experiments, for example, the LOFT 7
LP-FP2 experiment, that show that the Baker-Just 8
equation is non-conservative for calculating the 9
temperature at which thermal runaway would occur in 10 the event of a LOCA.
11 So, moving on beyond these slides, you 12 might ask the question: well, how did all of this 13 fall through the cracks? From the NRC's website I 14 read some history, in part labeled AEC to NRC, and I 15 quote, "By 1974, the AEC's regulatory programs had 16 come under such strong attack that Congress decided to 17 abolish the agency. Supporters and critics of nuclear 18 power agreed that the promotional and regulatory 19 duties of the AEC should be assigned to different 20 agencies." And, thus, NRC began operations in January 21 1975.
22 So let's trace a little bit of the history 23 of Baker-Just. All this came about under the old AEC.
24 The Baker-Just equation came out in May 1962, some 13 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 22 years before the NRC came online.
1 Now, regarding the reports that NRC didn't 2
have until recently, there is the Bostrom report, 3
which came out of the old Naval Reactors Division, 4
Rickover material. In that case, they induction 5
heated a Zircaloy cylinder a half-inch long by a 6
little over a half-inch in diameter with an internal 7
diameter a little over a quarter of an inch.
8 And then, Lemmon came along three years 9
later and did the test that I have referred to with a 10 two-inch long rod.
11 Incidentally, the Bostrom report, the 12 WAPD-104, the one with the cylinder a half-inch long, 13 goes back 21 years before the NRC came in. That was 14 1954, I believe. Then, Lemmon's came in in 1957. Yet 15 the NRC had never looked at this, even though one of 16 the reasons why the NRC was set up was because 17 apparently people felt this wasn't covered adequately.
18 So, anyway, I just want to finish. This 19 2.206 petition on Vermont Yankee clearly establishes 20 that Vermont Yankee's licensing basis PCT of 1960 21 degrees F is not low enough to protect public health 22 and safety. The PRB is urged to accept this petition 23 for prompt review.
24 So I am finished. So the next speaker may 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 23 proceed.
1 MR. MARK LEYSE: Yes. Mark Leyse 2
speaking. I just want to add that Robert Leyse has 3
conducted experiments with both single
- rod, 4
inductively heated tests of Zircaloy, and also multi-5 rod bundle tests. So he has a lot of experience in 6
this area with Zircaloy.
7 Anyway, yes, Mark Leyse speaking, and I 8
will now begin. I sent some information to John Boska 9
last night, and I'm wondering, were you able to print 10 out those pages and provide them to the Petition 11 Review Board?
12 MR. BOSKA: This is John Boska. We did 13 get the pages from the Three Mile Island accident 14 slides, and the Petition Review Board does have a 15 copy.
16 MR. MARK LEYSE: Oh, thank you very much.
17 Yes, I want to begin just by talking about that, and 18 then I will talk about your initial decision and e-19 mail that I received from you on July 8th.
20 But basically I find it very compelling 21 that in a presentation at the American Nuclear 22 Society, and the European Nuclear Society's 2007 23 international meeting, the title of that was Making 24 the Renaissance Real, that Robert E. Henry, who is 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 24 the Senior Vice President of Fauske and Associates, he 1
delivered a presentation titled TMI-2: A Textbook in 2
Severe Accident Management.
3 And basically he stated that thermal 4
runaway due to the exothermic oxidation of Zircaloy 5
commenced at 1000 degrees Celsius during the Three 6
Mile Island Unit 2 accident in 1979. So that would be 7
commenced at 1832 degrees Fahrenheit.
8 Basically, one of the slides 9
unfortunately, they are not numbered, but it should --
10 it was page 130 of the presentation, so I think it 11 will be your seventh page. Basically, there are three 12 bullet points, and I will just read the last two. The 13 title of the slide is Fuel Cladding Oxidation, and 14 he said, "Increasing temperatures caused the Zircaloy 15 oxidation rate to increase, which was accompanied by 16 an increased release rate of chemical energy."
17 Then, the third point is, "At about 1000 18 degrees Celsius, the oxidation energy release rate 19 equaled the decay power." From that point on, the 20 core was in a thermal-runaway state.
21 Now, I want to point out that when he says 22 that this was initiated at 1000 degrees Celsius -- so 23 that's 1832 degrees Fahrenheit -- this is speculation, 24 because there was no thermocouple data, unfortunately, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 that could confirm this. But it is very compelling 1
that he would state that, and he obviously has a lot 2
of experience in the -- I'm sorry, there was some 3
interference.
4 Yes. So I find it very compelling that he 5
would claim or state that thermal runaway commenced at 6
1000 degrees Celsius during the Three Mile Island 7
Unit 2 accident. And he did present this at the 8
American Nuclear Society meeting and European Nuclear 9
Society 2007 international meeting.
10 And then, what is interesting is that in a 11 slide that was on page 50 -- and this should be the 12 sixth page that you have -- it has a title Example:
13 Core Heat
- Uprate, Escalation Due to Cladding 14 Oxidation. And the bullet point is:
15 Important tests:
16 Out-of-Reactor - CORA; 17 In-Reactor - SFD, (I believe that would be for the 18 power burst facility severe fuel damage experiments),
19 FLHT, then, he states, "LOFT-FP2," meaning LOFT 20 LP/FP2, and PHEBUS.
21 Now, I have mentioned all of these 22 experiments in the Vermont Yankee petition, the 2.206 23 petition, except the SFD experiments. I did not 24 mention those. But I relied very heavily on the CORA 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 26 experiments and the LOFT, the final LOFT experiment.
1 So here there is a presentation at an ANS 2
meeting, and he is stating that these are very 3
important experiments regarding the oxidation rates 4
during an accident, and that they are very important 5
for the core heatup rate and the escalation --
6 temperature escalation that would be due to oxidation.
7 So now I just want to move on, having said 8
that, to the letter that I received, the e-mail I 9
received, on July 8th from John Boska. And, first, I 10 want to thank you for forwarding the material 11 regarding the reaction between boron carbide and 12 stainless steel that is in the control blades, 13 forwarding that to Rulemaking Branch.
14 But I do want to address an important 15 issue. In the e-mail you state that -- and you have 16 stated so earlier in this meeting, that the Petition 17 Review Board finds no evidence that Vermont Yankee is 18 in violation of 10 CFR 50.46.
19 Now, that would be regarding peak cladding 20 temperature, and that would be the 2200 limit that 21 that rule stipulates.
22 Now, I don't see how you could come up 23 with a statement like that -- that the petition 24 presents no evidence, because I think the evidence is 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 27 rather strongly discussed in the petition, and there 1
is a lot of experimental data that I reference in the 2
petition -- the same experimental data from the same 3
experiments that were cited by Robert E. Henry at the 4
ANS meeting in 2007 as being very important regarding 5
temperature escalations that can occur during a severe 6
accident due to oxidation rates.
7 So, in the 2.206 petition I have discussed 8
experimental data from the CORA experiments in which 9
runaway oxidation commenced at 1000 degrees Celsius, 10 1832 degrees Fahrenheit, and the local cladding 11 temperature increased at that point by tens of degrees 12 Fahrenheit per second.
13 So within a period less than 30 seconds 14 the cladding temperature would have exceeded 2200 15 degrees Fahrenheit, the regulated limit. So Vermont 16 Yankee's licensing basis peak cladding temperature 17 right now is 1960 degrees Fahrenheit, and that is 18 indeed below 2200 degrees Fahrenheit.
19 However, there is experimental data just 20 cited, and also cited by Robert E. Henry in his 21 presentation, that in the event that the cladding 22 could reach 1832 degrees Fahrenheit, more than 100 23 degrees Fahrenheit below the licensing basis peak 24 cladding temperature of Vermont Yankee, within 30 or 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 28 so seconds it would be over 2200 degrees Fahrenheit, 1
thus 10 CFR 50.46 would be violated.
2 And what would happen is it would just 3
continue rapidly increasing in a local area, and it 4
would get up to around 3300 degrees Fahrenheit in less 5
than a minute, or less than two minutes to be 6
conservative, and at that point, in that local area, 7
the Zircaloy would start to melt and that would be 8
what would lead to a partial meltdown or a complete 9
meltdown.
10 So now I just want to ask you a couple of 11 questions regarding your statement. And, again, it is 12 a very strong statement: I think that there is no 13 evidence presented in the petition. Could you please 14 explain that, the statement that there is no evidence?
15 I mean, does the Petition Review Board believe that 16 the experimental data that was cited in the papers 17 discussed in the petition, that that is incorrect?
18 MR. KLUKAN: Mr. Leyse, this is Brett 19 Klukan. I think you already hit the nail on the head.
20 You stated that VY, as their license dictates, has a 21 peak cladding temperature of some 1900 degrees, which 22 is below the 2200 that is dictated by the rule. And 23 they are in compliance with the rule, and you provide 24 no evidence to the contrary.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 29 What you would then do, to which the PRB 1
is not taking a position on at this point, is whether 2
that 2200 number is correct given the data you present 3
in the experiment. Those are two separate issues.
4 Whether VY is currently in compliance with 5
the rule as written, and whether the rule should be 6
changed as you contend, or as my understanding of what 7
your contention is, is that the rule is incorrect in 8
setting that limit, are two separate questions. You 9
yourself have conceded that VY is in compliance with 10 50.46 as the peak cladding temperature, as written.
11 MR. MARK LEYSE: Yes, I would like to 12 respond. I think I have just demonstrated -- and, as 13 I say, the experimental data cited in the petition 14 illustrates that it is possible that if the cladding 15 would reach 1832 degrees Fahrenheit, basically within 16 60 or so seconds, maybe a little longer, it is going 17 to be up around 3300 degrees Fahrenheit.
18 So basically your limit might as well, you 19 know, be the 3300. I mean, what is the point? You 20 are going to just delay this for another 60 seconds.
21 That is the margin of safety that you have.
22 I think that you are correct, 1960 degrees 23 Fahrenheit is below 2200, but my point is, if you get 24 to 1832, you are going to get up well past 2200 within 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 30 about 60 seconds. So I think that demonstrates --
1 now, this is experimental data, that that demonstrates 2
that actually, 1960 degrees Fahrenheit really is not a 3
margin of safety, and it demonstrates that Vermont 4
Yankee is actually not in compliance with 10 CFR 5
50.46.
I
- mean, that is if you believe the 6
experimental data that I cited in the petition.
7 MR. KLUKAN: Again, Mr. Leyse, this is 8
Brett Klukan. The PRB is not necessarily taking a 9
position on your arguments regarding what the number 10 should be. Quite frankly, it means that you believe, 11 or my understanding of your contention is is that the 12 number, as set out in the rule, the 2200, is incorrect 13 due to these experiments you brought forward, which 14 show that the number should be lower.
15 The PRB is not taking necessarily a final 16 position on that -- is not taking a final position on 17 that statement, and the factual evidence you bring in 18 support of that statement. The only thing we stated 19 was that, as written, VY is in compliance with 50.46.
20 Do you believe that there is some other 21 enforcement concern here? What I'm trying to get at, 22 how, then, would your contention not simply be solved 23
-- or not simply, but be solved by a petition for 24 rulemaking to change 50.46?
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 31 MR. MARK LEYSE: If you were able to 1
facilitate that and get it done as rapidly as the 2
Petition Review Board could mend the problem at 3
Vermont Yankee, that would be fine. But I actually 4
submitted another petition, which is actually being 5
considered in the rulemaking process, and I am very 6
well aware that it takes at least a few years, perhaps 7
even longer than that. It is still not finished.
8 This is something I submitted back in 2007.
9 I'm also aware of other petitions for 10 rulemaking that were submitted regarding the metal-11 water reaction rate. One I can think of was submitted 12 back in 2002. That would be PRM 50-76 that was 13 submitted by Robert Leyse. That took until 2005 for 14 the NRC to actually reject it, and that was without 15 even consulting the reports that Robert Leyse just 16 mentioned earlier when he was speaking -- the Bostrom 17
- report, the Lemmon
- report, inductively-heated 18 specimens that are about two inches long, when you are 19 actually licensing tens of thousands of square feet of 20 interfacial fuel rods -- I mean, there are tens of 21 thousands of fuel rods in a core, so that's why you 22 would get a different reaction rate.
23 Anyway, I guess I'm kind of going off on a 24 tangent, but I'm very well aware of how long the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 32 petition review process can take. And I think that 1
this is a very serious issue. We are talking about if 2
you have a loss of coolant accident at this aging 3
plant -- Ray Shadis has discussed some of the problems 4
at Vermont Yankee.
5 If you have such an accident, and the 6
temperature of the fuel rods gets up to 1832 degrees 7
Fahrenheit, based on experimental data you may have a 8
partial or a complete meltdown. I think that's 9
something that is a very serious issue, and obviously 10 the rulemaking process could solve this problem, but 11 it may take too long. It could take decades.
12 I mean, believe it or not, this very same 13 issue -- thermal runaway -- that was brought up by 14 Union of Concerned Scientists in the Atomic Energy 15 Commission rulemaking hearings in the early '70s, and 16 they presented data from a Zircaloy experiment multi-17 rod test that was conducted by General Electric.
18 And someone -- Roger Griebe from Aerojet, 19 he was the contractor for the Atomic Energy 20 Commission, and he basically largely agreed with the 21 point of Union of Concerned Scientists on this. There 22 was a situation where a bundle of fuel rods had 23 thermal runaway, and it commenced, according to plots 24 of the temperature
- data, below 2200 degrees 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 33 Fahrenheit. And they brought that up during the 1
rulemaking hearings in the early '70s. I mean, this 2
has been going on for decades. There is a paper trail 3
on this.
4 And you are not doing anything about this, 5
and this is -- you are a regulator. You are supposed 6
to look out for the public safety. This is a very 7
serious issue. So I think that is just really 8
something
- that, you
- know, I
have presented 9
experimental data on the Baker-Just equation, which is 10 what you used -- what Vermont Yankee used to set their 11 licensing basis PCT, that is based off of experimental 12 data also.
13 What do you think? Do you really think 14 that a piece of two-inch long cladding, a small little 15 specimen, do you really believe that that data is 16 superior to data from multi-rod experiments regarding 17 the reaction rate? I mean, I think this is a very 18 serious issue that I think you should just take into 19 consideration, you know, immediately.
20 MR. KLUKAN: Mr. Leyse, this is Brett 21 Klukan again. By no means does the PRB -- the PRB 22 takes your concerns with all due seriousness, as the 23 NRC does all concerns raised by the public 24 regarding --
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 34 THE COURT REPORTER: This is the Court 1
Reporter. I cannot pick up Mr. Klukan's comments.
2 MR. KLUKAN: I'll start again. This is 3
Brett Klukan. Mr. Leyse, by no means is the PRB 4
discounting the seriousness of the concerns you are 5
raising. We treat all concerns raised by the public 6
with due seriousness regarding the safety of our 7
regulated facilities.
8 One additional question I have, and I'm 9
trying to wrap my mind around still, is why is it not 10 a generic issue to all reactors, or the majority of 11 reactors in the United States? Why is it simply about 12 VY?
13 MR. MARK LEYSE: Well, I would agree with 14 you what I'm talking about right now regarding the 15 metal-water reaction rate, it most certainly is a 16 generic issue. So I am not going to say that that is 17 only pertinent to Vermont Yankee. It is definitely an 18 issue that affects all nuclear powerplants that are 19 licensed in the United States, as you stated, as John 20 Boska stated in his e-mail of July 8th. I do not see 21 that as being a real reason for not taking this into 22 consideration regarding Vermont
- Yankee, regarding 23 particular problems at Vermont Yankee that Ray Shadis 24 has discussed in this meeting and in our previous 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 35 meeting.
1 And I think what I'm trying to impress 2
upon you is just that this is a very serious issue.
3 It's a very serious safety issue, and it is something 4
that the rulemaking process could take far too long to 5
address properly.
6 I would hope that the rulemaking process 7
in this case would be expedited, but --
8 MR. SHADIS: Okay. May I add on?
9 MR. MARK LEYSE: Most certainly.
10 MR. SHADIS: Thank you. We have just a 11 few minutes in the allotted time. With respect to the 12 violation of a particular part of 10 CFR Part 50, I 13 would refer you -- as the Section 2.206 refers you 14 back to Section 2.202, that what is required here is 15 that there be alleged violations or, it says, 16 potentially hazardous conditions and other facts 17 deemed sufficient grounds for the proposed action.
18 So, you know, I don't know how you all 19 want to look at it. We're not attorneys, and we are 20 also not specifically grounded in NRC regulation. You 21 know, this could be proceeding under an unanalyzed 22 condition. The question really here is a question of 23 safety margin.
24 And with respect to the specificity of 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 36 Vermont Yankee, this petition is brought by New 1
England Coalition, which is headquartered within the 2
emergency planning zone. Our constituents live there.
3 They are affected directly by Vermont Yankee. This 4
particular plant has conditions that are similar to 5
many other plants, but not in combination.
6 This is a plant which took a 20 percent 7
power uprate in one step, the first one to do so. It 8
is a plant nearing the end of its original license 9
term. It is a plant with a history of maintenance 10 failures, management failures, and, in particular, 11 directed to, you
- know, the accident mitigation 12 systems.
13 I think that we are asking, really, NRC to 14 take a look at this plant in total to -- and I guess 15 also, I might mention, that there have been a number 16 of design basis issues that have emerged over time, 17 including some things that are actions to be taken in 18 response to an onset of an accident.
19 So, you know, it is Vermont Yankee in 20 particular, in combination with all of the defects 21 that it has exhibited over time, and the extra stress 22
-- the extra heat load of extended power uprate, and 23 the fact that the Petitioner is affected by Vermont 24 Yankee.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 37 We have no knowledge of what conditions 1
may be at other plants. We have not reviewed any 2
other plants' peak cladding temperature analysis.
3 What we have is information from Vermont Yankee, and 4
we are bringing this petition directly on that basis.
5 So, please, go back and, -- NRC is 6
entitled here to take, you know, action within its 7
discretion. And the bottom line is assuring public 8
health and safety, and to do that one has to establish 9
reasonable margins at every level. So that is our 10 position in the short.
11 Thank you.
12 CHAIRMAN QUAY: Okay. At this time, does 13 the staff here at headquarters have any questions for 14 Mr. Leyse or Mr. Shadis?
15 (No response.)
16 Seeing none, what about the region?
17 MR. SETZER: No questions. Thank you.
18 CHAIRMAN QUAY: Okay. Before we conclude 19 the meeting, members of the public may ask questions 20 about the NRC process for 2.206 petitions. However, 21 as stated at the opening, the purpose of this meeting 22 is not to provide an opportunity for the public to 23 question or examine the Petition Review Board 24 regarding the merits of the petition request. Do any 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 38 members of the public have any questions?
1 (No response.)
2 Okay. Mr. Leyse and Mr. Shadis, thank you 3
for taking time to provide the NRC staff with 4
clarifying information on the petition you have 5
submitted.
6 Before we close, does the Court Reporter 7
need any additional information for the meeting 8
transcript?
9 THE COURT REPORTER: This is the Court 10 Reporter on the line now. I will have to go back and 11 relisten to portions. Is there a specific person on 12 staff, if I have technical questions, that I should 13 call? I don't know at this point if Google is going 14 to provide me with the answers to questions I will 15 develop.
16 CHAIRMAN QUAY: Yes. You could consult 17 with John Boska.
18 MR. BOSKA: My phone number is 301-415-19 2901.
20 THE COURT REPORTER: 2901. Thank you. If 21 I have those, I expect I will develop them within the 22 hour2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
23 CHAIRMAN QUAY: Thank you.
24 THE COURT REPORTER: Thank you.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 39 CHAIRMAN QUAY: With that, this meeting is 1
concluded, and we will be terminating the phone call.
2 MR. MARK LEYSE: Mark Leyse. I just 3
wanted to thank the Petition Review Board, and thank 4
John Boska for providing those slides.
5 MR. SHADIS: Ray Shadis here, and I will 6
second that. Thank you so much.
7 CHAIRMAN QUAY: You're welcome. Thank 8
you.
9 (Whereupon, at 3:05 p.m., the proceedings in the 10 foregoing matter were adjourned.)
11 12 : Two slides on Preventing Thermal 13 Runaway, discussed by Robert Leyse.
14 : Seven slides from a TMI-2 workshop by 15 Robert Henry, discussed by Mark Leyse.
16 17 18 19
1 Leyse/Shadis 2.206 petition G20100368, Vermont Yankee PCT Slide 1 of 2 PREVENTING THERMAL RUNAWAY It is disturbing that the Petition Review Board reports: There was considerable technical review involved in the selection of 2200 degrees, and it will involve considerable technical review to reach a decision on PRM 50-93, and decide if that number should be revised.
This 2.206 Petition calls for prompt action independent of PRM-50-93.
It is a fact that the considerable technical review involved in the selection of 2200 degrees was focused on embrittlement criteria, not thermal runaway.
There is no need for considerable technical review and further delays to confirm that 2200 degrees is non-conservative. The evidence is complete.
NRC has apparently never studied Baker-Just (ML050550198) and until recently it did not even have copies of the key references.
Figure 16 is copied from page 37 of the Baker-Just report:
Only the Lemmon data includes the pertinent temperature region.
2 Slide 2 of 2 PREVENTING THERMAL RUNAWAY The Lemmon report, ML100570218, was not acquired by NRC until April, 2010. Figure C-1 is from page C-4 and the adjacent figure is excerpted from the flow sheet, Figure C-3 on page C-5.
Lemmon induction heated a zircaloy-2 cylinder, 2 inches long by 0.5 inches in diameter, as illustrated in the above figures.
It is absurd to license the emergency cooling of tons of zirconium alloy with thousands of square feet of interfacial surface area based on the limited investigations that yielded the Baker-Just equation. Despite this, Appendix K to Part 50--ECCS Evaluation Models, Item 5, specifies that the rate of energy release from the metal/water reaction shall be calculated using the Baker-Just equation and § 50.46 Acceptance Criteria, item (b)(1) specifies the 2200 degrees. Moreover, this 2.206 Petition presents data from multi-rod (assembly) severe fuel damage experiments (e.g., the LOFT LP-FP-2 experiment) that show the Baker-Just equation is non-conservative for calculating the temperature at which thermal runaway would occur in the event of a LOCA.
TMI-2: A Textbook in Severe Accident Management R. E. Henry NISD Professional Development Workshop 2007 ANS/ENS International Meeting November 11, 2007
Acknowledgments
- Dana Powers for sending me the slides he has used in lectures on the TMI-2 accident.
- Hans Fauske for looking over all of the slides we are using today.
What are the Key Accident Management Insights to be Discussed
- Timing of the coolant inventory loss and the core overheating
- Rapidity of the core damage once the fuel cladding oxidation begins
- Available fission barriers
- Available debris barriers
- Cooling of a compacted core
- Ultimate cooling of the debris
- Hydrogen Generation and Combustion
TMI-2: What Happened on March 28, 1979?
- Due to a lack of makeup/injection, the reactor core was starved of water, i.e. the core was eventually uncovered.
- As a result of decay power the core was overheated sufficiently that a significant oxidation reaction occurred between the Zircaloy fuel cladding and steam in the core.
- The chemical energy release caused the core to overheat faster and eventually melt or liquefy the individual constituents.
- Most of the molten core material eventually relocated outside of the original core boundaries.
- The core material was eventually quenched by water in the Reactor Pressure Vessel (RPV).
Fuel Cladding Oxidation
- The Zr in the Zircaloy cladding will oxidize in a high temperature steam environment: hydrogen and energy (heat) are released by this reaction Zr + 2H2O ZrO2 + 2H2 + HR The heat of reaction, HR, is about 6.5 MJ/kg.
- At about 1000 C, the rate of chemical energy release approximately equals the decay power.
- The oxidation rate increases with increasing temperature, which leads to an escalating core heatup rate.
- Therefore, the core damage was generally caused by the cladding oxidation.
Example: Core Heatup Rate Escalation Due to Cladding Oxidation
- Important Tests Out-of-Reactor - CORA In-Reactor SFD, FLHT, LOFT-FP2 and PHEBUS
Fuel Cladding Oxidation
- As the boil-off of the water in the core continued, the uncovered region continued to heatup with the highest cladding/fuel temperatures being at about the 3/4 core height location.
- Increasing temperatures caused the Zircaloy oxidation rate to increase which was accompanied by an increased release rate of chemical energy.
- At about 1000 C, the oxidation energy release rate equaled the decay power. From this point on, the core was in a thermal-runaway state. During this interval the Zircaloy reaction was limited by the rate of steam generated in the covered part of the core which decreased as the water level decreased.