ML20126G630
| ML20126G630 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/22/1981 |
| From: | Quigg C POLLUTION & ENVIRONMENTAL PROBLEMS, INC. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8103270721 | |
| Download: ML20126G630 (4) | |
Text
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4 Pollution & Environmental Problems, Inc.
P.O. Box 309 Pala tine, Illinois 60067 7 '*D
- March 22,1981 0 \\..,
.l
/'4 Mr. Harold Denton, Dirce tor g
Offic e of Nuclear Reac tor Regulation i a N 0
0 U.S. Nuclear Regula tory Commission
.g g
'q, Washington D.C. 20555 Docket No s. 50-295 and 50-304
Dear Mr. Denton:
This letter refers to your letter of February 18, 1981 to Pollution and lihvironmental Problems Inc. (PEP) which informed us tha t our petition of April 17., 1950 to suspend the license amendment nos. 52 and 49 to rerack and compac t the spent fuel pool a t the Zion Station Unit nos.1 and 2 had been denied.
Your denial was "ex post f ac to", coming - as it did - af ter the reracking and spent fuel compaction had already begun at the Zion Station.
Thus it appears that petitions to the Nuclear Regulatory Commission under Section 2.206 of the Code of Federal Regula tions are trea ted by the NRC as mere formalities and not given the due consideration they deserve under the law.
On page six of your decision to deny our request, you note that "the second issue considered in the Salem proceeding which PEP sought to have examined for the Zion facilities dealt with the potential loss of water from the spent bl pooi and the effect such a loss of wa ter would have on a pool with expanded storage c apacit y. "
PEP has reviewed and summarized the Salem transcript (see attached).
l We find in the testimony of NRC witnesses, I:t s. Walter P. Pasadeg and Allan S. Benjamin, sufficient reason to deny Commonwealth Edison lic ense to rerack and compact the spent fuel pool at Zion.
t The NRC 's experts on spent fuel heatup revealed:
1 The spent fuel clad in the Salem pool or any spent fuel pool l
l can undergo a self-sustaining and spreading oxidation.
(Benjamin-at 1398,1399,1401, 1411,1488 Pasadeg at 1580 said further analysis of spreading oxidation by radiant heat transfer is needed.)
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'AEc>3
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8108270 W,
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PAGE TWO i
i 2.
Four year old spent fuel could oxidize...(Benjamin a t 1423, at 1571 he states further analysis is required)...the zirconium clad could melt..,(Benjamin at 1423)...and the fission produc ts within the clad could be released. (Benj amin a t 1423 ).
3.
The consequences of partial lose of cooling water on new or aged fuel in a spent fuel pool' have not been thoroughly investigated. (Benjamin at 1429) 4.
Spent fuel heatup experts have not completed all necessary research to determine the short or long term safety of spent fuel in pool storage.
For sxample, N. Benjamin said:"The que stions that are unanswered right now: is the question of clad reloca tion when melting begins and you have a crust of r
zirconium oxide o ver the top of the melting zirconium..
Sec ond, the question of heat transfer from new spent fuel elements to old spent fuel elements, The que stion of the partition of heating -- what percent. of heat goes into melting fuel and newest spent fuel as opposed to heat that.goes by thermal radiation into older spent fuel..." (Benjamin at 1436) 5.
Melting of. fuel pellets in fresh assemblies is a probability and is likely to happen in fuel one year old or less. (Ben-jamin at 1140 years old or m,1441).
The possibility of fuel pellets four ore melting is not known, (Benjamin at 1441) 6, The interest of public health and safety requires that an i
analysis be done on the propagation of oxidation in the spent fuel pool, Such a study could be done by one individual in several months. (Pasadog at 1492) 7.
W. Dana Powers of Sandia Lab is more qualified on the chemistry N
of zirconium than the NBC 's expert witnesses.
Powers was not present at the hearing. (Benjamin at 1546) 8 New spent fuel could produce hydrogen espable of exploding.
(Benjamin at 1571).
Further research and analysis is required on whether a zirconium reac tion with water could produce hydrogen capable of exploding in the older assemblies.
(henjamin at 1571)
It is PEP 's belief that the Salem discussion of spreading fire or flames in a spent fuel pool was entirely. irrelevant and that i
the intervenors should not have pressed this point.
In our opinion, l
t i
4 l
+
t PAGE THR1iE f
i t
it is ranid oxidation in the form 'of sustained burning -- that causes the fuel clad to melt and the radioac tivity. to be released from the spent fuel.
It was not necessary for the intervenors.
to prove spreading fire or flames in the pool to make their case;.
only that sustained burning of the fuel clad la credible.- The NIC 's witnesses, Drs.. Benjamin and Pasedag, made the intervenors 8 case for them and it should be accepted as such.
I. refer you to the following exchange between hearing officer Milho111n and Dr.
Benjamin at 1398-l Chaiman Hilhollin:
"...I interpret what you say to mean that zirconium can melt' and oxidize without flame."
Benjamin:
"Yes."
.{
Milho111n:
" And that you believe that oxidation can-be propagated,"
l Benjamin:
"I believe that oxidation can be propagated if the temperature reaches...self-su staining temperatures."
IP. Pasadeg (at 1596) agreed: "I think the clad in the Salem pool or-any spent ~ fuel pool can undergo a 'self-sustaining oxidation if the conditions are right as opposed to a fire.
It doesn 't require a fire in order for oxidation to occur "
Then again, (at citation unknown):
Milho111n:
You can melt and oxidize without flame?
Benjamin:
"Yes... oxidation can be propagated if the tempera ture reaches self-sustaining oxidation tempera tures.
It is a fune tion of heat transfer and kinetics."
The Salem hearing was narrowly limited from the outset.
PEP does no t unders tand why.
The hearing limitations outlined below 4
did not serve the public interest.
l 1
Discussion was limited to a gross loss of water accident.
l Scientist Gordon Thompson with the Union of Concerned Scientists has long contended that a partial loss of water accident i
would have more dire consequences than a gross loss of water I
accident.
Dr. A lan S. Benj amin in his SAND 77-1371 indicates l
that a partial loss of water could be a greater safety problem than a gross loas of water accident in a compact ' spent fuel pool.
1 l
PAGE FOUR 2
The Salem hearing testimony narrowly focused on the differences in consequences between a gross loss of water accident in an unexpanded and an expanded __ spent fuel pool.
It is PEP's opinion that a loss or water accident in either an expanded or unexpanded spent fuel pool could have unacceptable consequences on the surrounding environment and population.
Common sense dictates that the more spent fuel in a given pool, the greater the potential adverse consep' The potential ences.
As Dr. Walter F. Pasadeg said on April 4,1981:
for radiological consequences from any accidental release of water from the spent fuel pool would be directly propor-tional to the fission and ac tivation product concentrations in the water."
The above reasons and o ther testimony of the NBC 's own experts provide compellin6 reasons to prohibit reracking and compac ti on of the Zion spent fuel pool, the Salem pool and any other spent fuel pool in the United States -- until appropriate and compre-hensive research, as described by Ws. Pasadeg and Benjamin, has been carried to conclusion.
The testimony of Dr. Dana Powers should be added to the record.
In addition, I urgently request that the NRC solicit testimony from Dr. Earl A. Gulbransen, research professor, School of Engineering, Department of Me tallurgy and Materials EngineerinE, University of Pittsburgh.
I am attaching a letter from Dr.
Gulbransen responding to my summary of the Salem proceedings.
Dr.Gulbransen is known throughout the world as a leading research-er and expert in the field of metallurgy.
His concerns deserve your swif t a ttention.
In conclusion, the evidence is not yet in.
The c ase ha s not been settled.
Salem has appealed.
The citizens of the Zion area have appealed.
This letter constitutes our appeal of l
your decision of February 18, 1981 Your denial to our original petition should no t be final until the Salem appeal has been decided.
In the interest of f airness to PEP and the citizens of Zion and northern Illinois, we urge you to reconsider your denial and delay your final decision on our appeal, pending the outcome of the Salem appeal and scientific research into those areas defined by your own witnesses.
Sincerely yours, lb&
s.<A-j C '
f
/
l Catherine 411gg, research ; director Pollution & Environmental Problems, Inc.
(312/381-6695) 1
l j
e
(
$LECTED EXCERPT 3 FROM U.S. NRC DOCKET #50-272 i
Publia, service Electric & Gas Conpany mleen 1, talem, New Jerosy April 28,1980 t
FROM 3LLEM TRANSCRIPT.
1.
Testimony of Walter F. Pasedag, h/26/M "The potential radiolcgical consequences from av accidental release of water fron the spent fuel pool (3FP) wuld be directly proportional to the fission and activation product concentrations in the water."
2 Dr. A. 3. Benjamin 8...on the basis of current knowledge...po ssibility cannot be ruled out pp 1391 that the oxidation of zirconium might, propogate to older fuel elements
-1392 seen older than 4 yearn. I do not believe a zirconium fire would occur..."
(
n..what cannot be ruled out is po soibility that by process of theral radiation from fuel aseembly to fuel assembly, it my be po ssLbic to propagate a =irconium roection to the older fuel elemento. I belists that this process would take hours, at least...g area of diengreement with Mr. Pasedag is that hLe otatement that there io no credible mechanida for this propagation to occur.a
- p. 1393 Flame involves a great deal of convyce and ersading of flames fion fuel assembly to fuel assembly. Congited -A th Dr. Lewis Baker, Argonnne, espert on sbjoet and he says not po saible for flame of this type to der elope. 8That any buming o r oxidation that occurred might resit in a brightr.ess or a kind of white illuminonity about the fuel name in the immediate vicinity of where this reaction...but that it would not l
re sit in flamee." In Dr. Baker's opinion, it was oil in the bins containing zirconium scrap that caused theos flames to occur and not the tiroonium itself... don't beliste rapidly greading fire or defisgration possible.
p = 1397 "I interpret the word ignition to mean a buming that is initiated and which metains itself because of an inability to remove heat fast enough in order to be able to put it out...our calculations for spent fuel pools say this will happen in the newest or hottest gent fuel elemente, ence ther reach a temperature of approximately 900 deg.C. "We have continued our calculations bgond the 900 deg.C temperature up to and beyond the temperature of zirconium zelting."
L i
I
PAGE TWO SLII.M D/JI3CRIPT 2
Dr. Bejamin (entinued) p.1397
'I interpret the word ignition to seen a burnir.g tht is initiated and which setmins itself becau se of an inability to romcr e heat fast mough in order to be able to put it out...our calculations ofr opet fuel pools say this~will happe in the newed or intteet, epent fuel elements, once the reath a tuperature of approximately 900 deg. C.
- Te hve continued our calculations beyond the 900 deg.c temperature up to and beyond the temperatures of zirconium zelting.*
CFAIRMAN MIL 10LLIN:
"...I interprd, what you any to mean tht zircenium can melt and oxidizes wittout flame.'
p.1398 BENJAMIN:
" Ye e."
MILIDLLIN:
'And tkt you believe that oxidation can be propagated."
r
(
BENJAMIN:
"I believe that' oxidation can be propagated if the temperature reaches...
self-$daining oxidatice temperaturoe."
p.1393 Propagation of exidation could not be ruled cut.
"It ie g opinion 1399 that...if there is no eknge in genstay at all in the peol, no nelting of zirconiun...tht the heat trenefer would be woh that propagation would be a distinct po ssibility, but when zircenium darts to melt la i
the hotted elemet s of the spent fuel pool, the goonetty changesee.
it is predicted zirconium molting will occur before all the oxidation is cotyleted.'...'The date of art involved in molting of Zirsaloy is not well enough advanced to be able to deters:ine a specific asmario r
by which the geometry changes.
- p. 1401 EENJAMIN:
Ibw retilation affects fire or oxidation.. 8vantilation (at Sea) would be $fficiet to provide oxygen to the zircaloy clad in order to setain a propagation of zircaloy 3xidation.
p.1402 "If you are gJing to ligM, a c}mrcoal Pl.*e...if charcoal ham't reached its ignition tasperature blowing on it will ted to ecol it dous and
(
make it lees likely to burn. If it tas reached ito ignition temperature.
blowing on it will increase the fire, or increase the burning; s the L
availability of sfficient vetilation is a good way to try to prewet any of the fuel elemente from reaching this alf-setaining oxidation t emp erature. Once it ks reached that tec:perature, the availability of oxyge can work again at you.'
PAGE TISEE
, 51.EM T!1ANSCRIPT P
p.1403-SENJAMIN(CONTINUZD) 1404 Dr. Uebb has postulated a fire in which a rapid deflagration or fire would blew the roof off the building because of the rapid preeste transist that would occur.
t
"...I beliere tht the building, typical buildings for apet fuel storage are euch that they tend to leek when prospre escoede a certain lerel, s:aewhat less than s, F5[. They don't tend to explode unless there is a rapid pressre excursion as might occur from sme kind of explo eLon or something of t}mt. sort "
p *1410 PA SDAG4 8...I beliers the geometry would change as the zirconium would start.
to oxidize, that melting would occur which would draw away a good bit of the heat and s that heat would not be available for spreading to p.311 the older fuel olmente...the lo$ ding pattom is not the eene all the time...and sitconium oxide, once it does start to oxidize, changes from a metal to a very refractory type substance which tende to be a good inslator and the heating of the older elemente would be done pri:narily from the radiation from the never elemat e and'therefore
(
the heating is external to the rode for the older ones and the ingplat-A ing air would reduce the a:: cunt of heat transferred... chances are very
- ini:mzal that there would be a apreading oxidation to the old elements.'
Greading oxidation -
8...it cannot be theoretically ruled out.'
- p. 1412 BENJA! ens "I can't at this time state that what he (Webb) po stulates is true and I can't state it io fales.'
l F. 1413 PANDA 6
"... oxidation of the zirconium...would occur in the interior of the and me son as you have an oxide layer outaide. The buming would not take place out side the oxide Wt it would take place at the interface wit h the metal it self...in a fire...oombustion tekee place eartomal to the material it self in the flame. Thio do es not happen here. The zirconium does not vaporize and bum outeide the rod. It bums at the interface with the metal."
1 pel414 "There is still some heat being gmerated within the rod, Mt that heat is nowhere near adequate to heat the rod to oxidation temperaturee...'
k
- ...the consequences of pool accidet...would certainly be no worae than a full reactor core accident as po stulated in TASH-1400.8
l PAGE FOUR fALEM TRANSCRIPT pel417 BDiJA!EN: (00NTINUED) 6 The only way to prevet oxid$ation from propagating is to remove the heat by conv oction, natural convoction frm the fuel aecomblie....if tre zirconium oxidation were te initiate in the newed fuel elements which were not able to recov e the heat fad enough, the a::munt of thermal radiation causing pmpagation to other fuel assemblies would be larger than tht removed by natural air convetien.8 pel423 ELICLLIN:
Do you think 4 year old rods would reach a tanperature sfficist to oxidize?
B2NJEAMIN:
8...There is a groeter pc solbility for tht to hppen than not t.o Appen."
ELIDLLIN:
(
"If that stould happen, would the cladding molt?"
BCiJAEN:
"The cladding rould nelt, at load a portion of the clad on the fuel assemblies would =elt.8 MIL 10LLIN:
'ould the fission products within the cladding by released?
BEW AEN:
"The fission products in the gap between the fuel currente ankhe clad-ding would be released.'
p.1427
!IILEOLLINt
'If all the fuel in the pool were 3 years old or older, there would r
be no ignition 1' L
EDiJA$2I$l:
" tat ' s ao rrect.'
PACE FIVE Sk1EM TRANSCRIPT j
_{
p.1429 PACl!lDAG1
"...in the absence of fuel any younger than ene year, there'is no chance the temperatures in the pool agwhere will go above 900 dag.c."
MILIDLLIN:
Does this conclusion asume total absence of water in pcol - so ocarction could occur by air ecaing under bottom of rask?
PA3llDAGS Yes.
MILIDLLIN:
If you aneuse ese water is left in the bottom of the pool so air oculd not reach that area. would you still make that statemt?-
PA3EDAGt "I don't know about that ocmario...I have not investigated it very tic reughly.a
.?pl429 BENJAMIN:
1430 8...it's Po sible to block off the air inlets at the bottom cf the e
pool simply by having the water covering the base plates...so 'there is not mough saoe to have air come in to the bottom of the gent fuel ruoke and up through the fuel assembly..a e the fuel will.ted to overheat more readily in a situation like that than it will in a situation where air convection can' be Watained...lowever oxidation is much less likely...bocau e there is m way for air to get to the s
cladding - e there' e no igni'in pc aiuility.8 s
p.1432
"(Zirconium) con react with steem to predace lydrogen. Of course it can't do that if it ha s been oxidized by air. The water would quench the zirmniu:n.8 MILIDLLIN:
Could 4 year old fuel or older melt if the inlets were blocked by water in the bottom of the pool?
BCTJAMIN:
"I don't believe I can ear whether it would or would not.'
5
- -. - ~
PAGE $II 3ALEM T?Af3CRIPT '
April 29,1980 pel4%
BENJAENs The questions that are unanesered rigli nows is the que' tion wf clad s
relocation whm melting begins and you inve a crus of zirconium oxide over. the top of the molting zirconium.
>nd, th.e quedion of heat transfer from new spent fuel elemmts to old $ mt fuel elemmt e.
The question of the partition of heating - what percent of heat goes into molting fuel and newed opent fuel as oPpo med to heat that goes by ther::al radiation into older spot fuel "
!ELIDLLIN:
m e..you are undirs whether clad on older elemets would melt?
BENJAMIN:
Yoo.
MILIDLLIM p.1440 Could fission products in fuel pellets themselves of the fresh fuel encape the spent fuel pool in a gre s lo es of ruter.
s 3CTJA!.lIN8 Melting of fuel pellets in fresh assemblies 10 a probc 111ty.
MILIDLLIN:
You thirt it is likely to happm?
p.1441 3ENJAENs Yes...in fuel about one year old or leoc.
l l
MILIDLLIN:
1 Would fuel pellets 4 years old or more melt 3 1
l l (
SETJAYIN:
Cen' t on ener.
l l
1 l
PAGE T/Di
,.fAIEM TRANCCRIPT p.1448
?A MDAGI "I believe calmlations for WASIbl400_ would be appropriate estimates of rolesees.. 8Ii" the 1/3 core m t roomtly diocharged melts.. 8the j
e the consequences would be v ery similar to those po dulated tor 'a roactor accidet in 7As!bl400 oxcept it would be 1/3 of the core instead' of full ocre.8
... any oxidation of older aamembliea would be yery limited and probably not. lead to. melting of cladding. The number of a ssemblies would be smalls only the se in clo oo proxi:sity to vsry fresh fuel and dependa on storage. oonfiguration.
MILIDLLIN:
8 3 you testi:eny is there would be sme ralcase of gap activity, perinp s, but no release of activity contained in fuel it self of the older a saemblies?'
PAsiDAG8
'Yo e, that' s cn rrect.8 p.1472 SWA! ens Oxidation of zirconium means the reaction of zirconium with oxygen to form zirconium oxide or with an oxysm carrier sch as steam to fom zirconium onido. It does't imply anything about propagation or oon-tinuance of that reaction. Ignition implies a situation in which this reaction not only occuro but sotaina itself gmerally leading to increase in to:peratures.
Fire... implies oxistcnce of flames.end significant conductive currents that produce a propagation of buming through the spread of flames...the latter would not happa in a get fuel pool... oxidation occurs gradually until the temperature get a to '
about 900 deg. O in the spent fuel pocl. At about that temperature, ignition oecurs. T}nt ia the reaction becomee self-Wstaining in tho e fuel rod s in which the temperature of about 900 dog.0 las been.
s s stained. Thm, at that point, the temperature in ticse fuel reda fairly rapidly increa ses.
- p. 1475 "Once oxidation occurred, vetilation would tend to su tain oxidation s
l by providing oxygen, whereas in a pool without ventilation, it would be difficult to $ stain oxidation tor a 1engtly period of time bocause of a depletion of oxygen in the building.8
...with no y entilation, overheating would ocer, resulting in temperatures that could produce clad rupture and reluse the fission products.
(.1482
...the primary way for heat to propagate from e scambly to assembly is
.\\
by thermal radiation. Sme convection could play a part.
PAGC EIGIT 3ALEM TRANSCRIPT P.1488 SE JA!EN:
"I thLnk tht the po sdbility of clad oxidation propagation is signifi-cant 'mough to warrant its consideration in determining whether there is a differmee betwee one special $mt fuel geometry and another."
p.1490
"...the Doral would melt if the steel (racks) melted, certainly."
p.1491 PA SDAG:
"...we are dieking with the invented semario...namely an instentaneou e p.1492 lo cs of water.Utithout the water, we wouldn't hvo any criticality p re bl es."
pel492 8...the Board he conclusively established that the intered of public health and safety would require an analysis to be done which would take a few mnths to do by one individual on the prepagation of oxidation in the went fuel pcol."
i p elf 02 PA CDAG
(
"The prepo ned high dm eity rack mrdiguration would restit in less convoctive heat transfer effectivmese and therefo re would Ancreate the po ssibility of overhontir.g the newly di rcharged fuel."
- p. 1504 8...the heatup of seversi fuel elements in a bundio ie a part of the German core melt recearch program"
...It is a semi-annual progrees report from the Kemforschingszentrum Karlanthe f.ated EPs 21% May 1975.
(No English trnnslation available). Involved a test of a few rods heated up to 2000 deg. and there was no flame that jumped from fuel red to fuel red in the asee=bly.
l 1509 VAIOPS:
"Do I understand one thing that you and Dr. 3mjamin definitly agree on, is that if there was, oxidation of $=e or all of the new went fuel, under no circumstances would we be dealing with a situation where we would have explo dons and flames shooting 50 feet high and -
the root going off the get fuel building.' In that correct?
PA 2DAGt "That i s errect."
b 7A10'E Faye you red Dr. Lewis Saker's Chapter 17, Technology of Nuclear Reactor Wety, Volume 2, published by Thomp son i Seokorly?"
?AGC TG5 3183 NN
( 1909
?A,T.AG t That fire (Dettie) included the oxidation of cony :nateriale, of which zirconiu= was one.
l 1921
"...in the spent Pael pool...we hve fael rods with slid zirconium cladding. As oppo sai to chips or cilling. Ycu could get zirconium 1524 fires with omall or finely ground =aterial -- but not with zirealoy re d e.
1525 7AICRE
"...if you get zirconium oxidation you =ight create powdero and yeu might create bite of zirconiu= other than large pieces."
PACEDAG I do not believe s.
I know of no mechani:fz th1t cree.tes a:: nil particlee, bit s of zirznium.
VAIC328 What about a fionion gse pleaun?
1526 D EEDAG
".a.leen thn 10 percent of the total ficcion product invetory neuld be in the gap betwoat the f.tel clo:: tent, the fuel pellets and the zirconium clad."
VAIORE:
(Referred to Nuclear ::cience & Engineering, Vol.15, pp. 395-403 in 1963 article called "32 ming Velocities of urenium cnd zirconium in air by L. Leibowitz et. al.3nd pp. 3SS-394 article "&arrJ.ng Temperature of uranium and zirmnium in air" by Edward :Jouriain and Lewis Saker, Jr.
Poli 37 FA:EDAG "If you denied all water to the pool...you would start to oxidize the cuter $2rfaceo of zirconium at topcratures : mach below the 900 deg....
and it would be a olow hiild up of oxide en the metal sarface.
SL:nilar to a layer of ru t on dt.eol or 1:en.
s
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PAGE TIN
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OA12M TRANCCRI?T 1546 3D:J/J4ET:
Dr. Dana.Nwere of ra dia would be :miro (Jalified to snaner questions
~
n en checistr/ of zirarmium reaction t'tn I would.
1%3 YAIOREt Articles in Ruelear Engineering deal with propagation of fire in a oingle piece or strip of zirconium. Did Dr. 3aker ever carr/ that snalysis further into aggregates of zirconium?
1555 33UtJJIN:
If calculations showed that =iresnium vapor being formed, I weuld have to take into ocnsideration the.po ssibility of buming in an air evironment.
1556 SENJA'EN s
- g deflagration, I seen a rapid groading of a fire.
h571 VA'43E:
8...tiouldn't you any that tho cafety cnd halth of the public is put
- ere in j eopardy by having larger smunttof gent fael...in the centext of po seible lydrogon explosion in the orent cf a lo sa of water accident.8 BENJAMIN:
The newest want fuel could produce it by reaction of stea$a with sirconium. The only way for older ones to pmduce tydrogen would be the propagation of oxidation acro es the fuel asse:nblies. And whether u
this occurs or not is a mattor that requires analysis.
i 1575 PASEDAG8 "The orent we hve been po stulating tius far has bem a co:glete in stantaneous 30 es of all water from the gent fuel pool. We don't believe it is credible...se have not identified any po sible accident o
scenario, combination of effect s, which wdd...first of all empty out the pool and eeoondly preret you from refilling the poole...within plenty of ti:ne to prevet an ov erheating of the rods...even if you did Po tulate that the pool water was instantaneously lo d, and...you cannot s
( 377 refill the pool, it is still nct, credible that the fire in the gent fuel pool would occur or would gread to the old fuel rode.
PAGE El& CT
, f,AIEM TRAN3C3IPT i
l 1530 PA 5DAG: (CONTIWED) 1 "I agree with Dr. Benjamin, that in the absence of having done the ::cre detailed calculations, it cannot be theoretically di $roven at this point that zirconium would oxidi::e in the pool and that sich oxidation would $ read in the pcol by radiant heat transfer.a 1596 "I think the clad in the atisa spent fuel pool or any gent fuel pool can undergo a self-81 staining exidation if the conditions are i'ight, as opPo ed to a fire. It do ee't need a fire in order for oxidation s
to ocatre" 2998 MILICLLIN:
Would the vetilation be turned off to reduce entissions out side the
'azilding?
PAGEDAGt to ::r knewledge, there is no g/ ster:: to automatically turn the ventila-tion estem off if you started clad oxidation or if you lo st water la t
(
the pool... it would be nere desirable to keep it running becau se it would filter the effluerits frca the building....what I' mu'd do is not worrf about the vmtilation esten -- but get a ha ao and put water in the pool.
fW Participant as Dr. Allan S. Benjada, US NRC staff expert Dr. Walter F. Pasedag,UD-NRC etaff witness Carl Valore, Jr., Iaq., intervenor Gar / L.151?ollin, Esq., chairman, AtoElC 3Lfety and LicenDing 3eard' 7
l~
, _ 3AIa TEstI!CND APRIL 28, 1980 Extrseted witleut page refermees
(
MILIDLLIN:
Zirconium can mit and oxidizes without flamer 3EUAMIN:
Yes... oxidation em be propagated if the temperature reaches self-Wetaining oxidation temperature. It is a function of heat transfer 1
and kinetics
- PA NDA0:
Potmtial radiological consequences from any accidental release of water frem spent fuel pool would be directly proportional to the fission and activation product concentrations in the water... For fresh spat fuel, continued denial of water cooling capability may erantually lead to oxidation and failure of the clad, and to overheating of the uranium oxide fuel, with the potential for the releaps ofission products in the uranium oxide fuel in either the preset or expanded pool.
According to.WRED/CR-06h9: get fuel like klem's cannot reach self-(-
sotaining oxidation if its age ( sLnce recoval f:om the reactor) arceeds 280 daye.
i DCiJAMIN:
L No oxidation after ene year doesy.
"The po asibility cannot be ruled out that the oxidation of zirmnium might propagats.to. older fuel elements, eran older than 4 years old.
I'do not'belivire that a siimiiunit fire would occur, there would not not be a deflagration that would lead to a rapid cons:nption of the ziroonium in the pool, but what can't be ruled out is the Po setbility that* by process of thermal radiation from fuel assembly to fuel assembly, it may be possible to propagate a siroonium reaction to the older fuel elsasnte...This process would take }nurs, at least.
I consul, ed with Dr. Lewis Baker, Argonne exp ert on zirconium and he said "it would not be po sdble for a flame to derelop.'
Therefore, any buming or oxidation that occurred might resit in brightness o r a kind of white illumino sity about the fuel cans in the immediate vicinity where this reaction is occurring - but it would not resit in flames...the difference is that in zirconium powdere...
(
there is a much larger Wrface to volume ration... According to Dr.
Baker, at Bettis, there was oil present - In his opinien, it was oil in the bins containing the zirconium scrap that caused these flanes to occur and not zirconium itoolf...I believe it is Po scible to have intness in vicinity where ox$d atica in occurring and ;.o adble to transfer heat from fuel assembly to fuel assembly by the process of thermal meistion, but I don't beliere that deflagration and fire with flames and rapidly apreading fire is po sible in a spent fuel pool.
s M
6.
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University of Pittsburgh SCHOOL OF ENGINEERING Department of Metallurgical and Materials Engineering June 20, 1980 Mrs. Catherine Quigg Pollution and Environmental Problems 838 Harriet Lane Barrington, Illinois 60010
Dear Mrs. Quigg:
I have your note of June 2, 1980 and the statement of Walter F.,Pasedag concerning Docket No. 50-272 " Proposed Issuance of Amendment to Facility Operating License No. DPR-70", also the comments of Dr. A. S. Benjamin. Both are NRC staff experts and witnesses. It is unfortunate that Mr.' Carl Valore, Jr., as an inter-venor did not have available his own technical witnesses in addition to Dr. Richard Webb.
Dr. Webb is a nuclear engineer and a very knowledgeable one but not a materials expert.
i Dr. Benjamin and Mr. Pasedag assume with the NRC staff and industry the Baker - Just parabolic rate law to describe the kinetics and heat effects of the zirconium-steam reaction and conventional data for the air oxidation of zirconium.
The Baker - Just equation for exanple is ba. sed on a series of studies on the steam-zirconium reaction without adequately consicering the influence of steam flow which can have a najor influence on the kinetics of the reaction. Grain bouadary penetration of oxygen greatly accelerates the deterioration of th unre.-
acted zirconium tube. Also the development of the Baker - Just' equation is based on very dubious extrapolations. In addition oxygen raises the a -S transition temperature which leads to spikes of brittle oxygen-saturated a-Zr crystals into the B structure.
My criticism of the testimony which you kindly sent to me is that they have not used the proper rate equations and that zirconium probably reacts much faster than that predicted by the Baker - Just equation. The same would hold true for the air - oxidation. Both nitrogen and hydrogen present in the zirconium can lead to blowing out of small particles of zirconium igniting neighboring fuel rods and spreading the reaction.
I hope the above comments answer your questions.
Very truly yours, j h //7
.:'t.ib-w n, Earl A. Gulbransen Research Professor
/ps P.S.
Send Dr. Webb's testimony if it is available.
848 BENEDUM HALL. PITTSBURGH. PA.15261
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