ML14308A098
ML14308A098
ML14308A098
10 CFR Part 50
SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is denying two related
Edward Leyse. The petitioner requested the NRC to amend its regulations for the
domestic licensing of production and utilization facilities. The petitioner asserted that
data from multirod (assembly) severe fuel damage experiments indicate that specific
criteria and evaluation models are not conservative and that additional regulations are
necessary. The NRC is denying these petitions because existing NRC regulations
provide reasonable assurance of adequate protection of public health and safety. The
petitioner did not present sufficient new information or arguments to support the
requested changes.
DATES: The dockets for the petitions for rulemaking, PRM-50-93 and PRM-50-95, are
search for Docket ID NRC-2009-0554. Address questions about NRC dockets to Carol
(ADAMS): You may obtain publicly-available documents online in the ADAMS Public
search, select “ADAMS Public Documents” and then select “Begin Web-based ADAMS
Search.” For problems with ADAMS, please contact the NRC’s Public Document Room
Documents.”
• NRC’s PDR: You may examine and purchase copies of public documents at
the NRC’s PDR, Room O1-F21, One White Flint North, 11555 Rockville Pike, Rockville,
Maryland 20852.
2
SUPPLEMENTARY INFORMATION:
V. Conclusion
Subpart 2.802 of Title 10 of the Code of Federal Regulations (10 CFR), “Petition
November 17, 2009, Mark Edward Leyse submitted a PRM under 10 CFR 2.802. The
NRC assigned docket number PRM-50-93 to this petition and published a notice of
receipt and request for public comment in the Federal Register (FR) on January 25,
The petitioner asserted that data from multirod (assembly) severe fuel damage
experiments indicate that specific aspects of the NRC’s regulations and associated
regulatory guidance on ECCS acceptance criteria and evaluation models are not
conservative and that additional regulations are necessary. Therefore, the petitioner
requested the NRC to (1) amend its regulations to require that the calculated maximum
fuel element cladding temperature not exceed a limit based on data from cited
experiments, (2) amend its regulations and associated regulatory guidance to require
that the rates of energy release, hydrogen generation, and Zircaloy cladding oxidation
3
from the metal-water reaction of zirconium with steam considered in the evaluation
models used to calculate ECCS cooling performance be based on data from cited
experiments, and (3) issue a new regulation that requires minimum allowable core
On June 7, 2010, Mark Edward Leyse, on behalf of the New England Coalition,
submitted a petition for enforcement action under 10 CFR 2.206, “Requests for Action
under This Subpart.” The petitioner requested the NRC to order the Vermont Yankee
Nuclear Power Station to lower its licensing basis peak cladding temperature to provide
an adequate margin of safety in the event of a LOCA. The NRC staff concluded that this
petition did not meet the criteria for review under 10 CFR 2.206 because it identified
generic issues that could require revisions to existing NRC regulations. Therefore, the
NRC decided to review it as a PRM under 10 CFR 2.802 and assigned it docket number
PRM-50-95. Because PRM-50-93 and PRM-50-95 address similar issues, the NRC
consolidated their review into a single activity. On October 27, 2010, the NRC published
The NRC identified three main issues in the two petitions. The remaining
paragraphs of Section I summarize the following information for each main issue: (1)
relevant background information; (2) arguments in the petitions; and (3) specific requests
4
Under Subpart 50.46, “Acceptance Criteria for Emergency Core Cooling Systems
for Light-Water Nuclear Power Reactors,” of 10 CFR Part 50, “Domestic Licensing of
Production and Utilization Facilities,” light-water nuclear power reactors fueled with
uranium oxide pellets within cylindrical Zircaloy cladding must be provided with an ECCS
that must be designed so that its calculated cooling performance following postulated
50.46(b)(1), the calculated maximum fuel element cladding temperature shall not exceed
cooling.
The petitioner asserted that data from multirod (assembly) severe fuel damage
experiments indicate that the calculated maximum fuel element cladding temperature
not its intended purpose, the NRC previously determined that this limit provides a
conservative safety margin from an area of Zircaloy cladding oxidation behavior known
as the autocatalytic regime. An autocatalytic condition occurs when the heat released
1. Under 10 CFR 50.46(c), LOCAs are hypothetical accidents that would result from the loss of
reactor coolant, at a rate that exceeds the capability of the reactor coolant makeup system, from
breaks in pipes in the reactor coolant pressure boundary.
2. Criterion 35 of Appendix A to 10 CFR Part 50, “General Design Criteria” further requires that a
system to provide abundant emergency core cooling shall be provided and that the system safety
function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate
such that: (1) fuel and cladding damage that could interfere with continued effective core cooling is
prevented; and (2) the cladding metal-water reaction is limited to negligible amounts.
5
by the metal-water reaction of zirconium with steam is greater than the heat that can be
transferred away from the Zircaloy cladding. This causes the Zircaloy cladding
temperature to increase, thereby increasing the diffusion of oxygen into the metal, which
in turn increases the rate at which the zirconium-steam oxidation reaction occurs. As the
metal-water reaction rate continues to increase, the temperature of the Zircaloy cladding
excursion. The petitioner asserted that data from cited experiments indicate that such
involving Zircaloy cladding have occurred at temperatures below 2,200 degrees F. The
petitioner provided this assertion as evidence that the 2,200-degree-F limit is not
conservative, and requested the NRC to amend 10 CFR 50.46 to require that the
calculated maximum fuel element cladding temperature not exceed a limit based on data
10 CFR 50.46(b)(1).
range of postulated LOCAs of different sizes, locations, and other properties sufficient to
3. Regulatory Guide (RG) 1.157, “Best-Estimate Calculations of Emergency Core Cooling System
Performance,” issued May 1989, states that “the term ‘evaluation model’ refers to a nuclear plant
system computer code or any other analysis tool designed to predict the aggregate behavior of a
reactor during a loss of coolant accident. It can be either best estimate or conservative and may
contain many correlations or models.”
6
provide assurance that the most severe postulated LOCAs are evaluated. On
September 16, 1988 (53 FR 35996), the NRC amended the requirements of
10 CFR 50.46 and 10 CFR Part 50, Appendix K, “ECCS Evaluation Models,” to reflect
requirements. Under 10 CFR 50.46(a)(1), licensees or applicants may use one of two
model4; or (2) a conservative evaluation model. Each ECCS evaluation model option is
summarized below.
model must include sufficient supporting justification to show that the analytical
technique realistically describes the behavior of the reactor system during a LOCA.
identified and assessed so that the uncertainty in the calculated results can be estimated
to: (1) compare the calculated ECCS cooling performance to the criteria specified in
10 CFR 50.46(b); and (2) determine the probability of exceeding these criteria.
and methods that are generally acceptable to the NRC staff for meeting the
4. RG 1.157 states that “the terms ‘best-estimate’ and ‘realistic’ have the same meaning. Both terms
are used to indicate that the techniques attempt to predict realistic reactor system thermal-hydraulic
response.”
5. RG 1.157 states that “the term ‘model’ refers to a set of equations derived from fundamental
physical laws that is designed to predict the details of a specific phenomenon.”
6. RG 1.157 states that “the term ‘correlation’ refers to an equation having empirically determined
constants such that it can predict some details of a specific phenomenon for a limited range of
7
requirements for: (1) a realistic or best-estimate calculation of ECCS cooling
performance during a LOCA; (2) estimating the uncertainty in that calculation; and (3)
10 CFR 50.46(b) to assure a high probability that the criteria would not be exceeded.
Other models, data, model evaluation procedures, and methods can be considered if
for identified sources of heat— including the metal-water reaction rate—in performing
generation, and Zircaloy cladding oxidation from the metal-water reaction of zirconium
with steam should be calculated in a best-estimate manner using one of two procedures,
(1) If the cladding temperature is less than or equal to 1,900 degrees F, correlations
against a set of relevant data; and (2) recognize the effects of steam pressure,
(2) If the cladding temperature is greater than 1,900 degrees F, the Cathcart-Pawel
equation and the underlying empirical data used to derive it are considered
acceptable for calculating the rates of energy release, hydrogen generation, and
cladding oxidation.
conditions.”
8
Option 2: Conservative ECCS Evaluation Model
with the required and acceptable features of 10 CFR Part 50, Appendix K. Under
Appendix K, evaluation models are required to account for various sources of heat
during LOCA conditions that are identified in Subpart I.A., including the metal-water
requires use of the Baker-Just equation to calculate the rates of energy release,
hydrogen generation, and Zircaloy cladding oxidation from the metal-water reaction of
zirconium with steam, assuming that the reaction is not steam limited.
The petitioner asserted that data from multirod (assembly) severe fuel damage
experiments indicate that equations used to calculate the metal-water reaction rate in
ECCS evaluation models that the NRC has determined to be acceptable for use in
evaluating ECCS cooling performance are not conservative. In particular, the petitioner
asserted that data from cited experiments indicate that use of the Cathcart-Pawel
evaluation models would: (1) overestimate the temperature at which autocatalytic metal-
water oxidation reactions would occur during a LOCA; and (2) underestimate the rate of
Zircaloy cladding oxidation from the metal-water reaction of zirconium with steam and,
therefore, underestimate the heatup, heatup rate, and maximum temperature of the
Zircaloy cladding during a LOCA. Therefore, the petitioner requested the NRC to amend
9
RG 1.157 and 10 CFR Part 50, Appendix K, to require that the rates of energy release,
hydrogen generation, and Zircaloy cladding oxidation from the metal-water reaction of
zirconium with steam considered in evaluation models used to calculate ECCS cooling
performance be calculated based on data from cited experiments, instead of using the
The regulation at 10 CFR 50.46(b) does not include criteria for calculated ECCS
cooling performance pertaining to the core reflood rate following postulated LOCAs.
The petitioner asserted that a constant core reflood rate of approximately 1 inch
per second or lower would not, with high probability, prevent Zircaloy cladding from
exceeding the 2,200-degree-F limit in 10 CFR 50.46(b)(1) if, at the onset of reflood, the
cladding temperature was greater than or equal to 1,200 F. In particular, the petitioner
asserted that: (1) although reflood rates would vary throughout the reactor core during a
LOCA, local reflood rates could be approximately 1 inch per second or lower; and (2)
extrapolation of data from cited experiments indicates that a constant core reflood rate of
approximately 1 inch per second or lower would not, with high probability, prevent
Zircaloy cladding from exceeding the 2,200-degree-F limit, if the cladding temperature
10
was greater than or equal to 1,200 F at the onset of reflood.7 Therefore, the petitioner
requested the NRC to issue a new regulation that requires minimum allowable core
125 individual comments. The NRC reviewed and considered all 125 comments in its
evaluation of the petitions. Table I identifies the number of comment submissions and
categories are used only to facilitate presenting a high-level summary and counts for the
comments that different stakeholder groups submitted; the NRC staff used the same
submitted them. The paragraphs that follow provide a high-level overview of each
category of comments.
7. Extrapolation of the experimental data was necessary because the referenced tests were started
with relatively low initial cladding temperatures. The petitioner hypothesized that, if these tests had
started with higher initial cladding temperatures, autocatalytic oxidation and failure of the Zircaloy
cladding would have occurred with high probability.
11
Table I. Number of Comment Submissions and Individual Comments by Category
that closed on November 26, 2010. Although not required to do so, the NRC also
considered all the comment submissions that were submitted after the public comment
period closed.
submissions after the comment period closed. The NRC considered all 13 comment
the petitions by either: (1) repeating information that had already been provided;
(2) providing additional details to clarify specific issues; or (3) citing other references that
the petitioner believed further substantiate the arguments in the petitions. In some
comments, the petitioner identified additional technical issues that were relevant to the
subject matter, but were not directly related to the requested changes to the NRC’s
regulations. As discussed in Section III, the NRC addressed these additional technical
12
The Nuclear Energy Institute (NEI) provided two comment submissions that
oppose PRM-50-93 and PRM-50-95. Overall, NEI recommended that the NRC deny
substantiate the assertions or requests made in the petitions. NEI further provided
additional experimental evidence that indicates the NRC’s regulations and associated
regulatory guidance on ECCS acceptance criteria and evaluation models are adequate.
and PRM-50-95, stating that: (1) it did not consider the proposed amendments to the
Beyond Nuclear, and Union of Concerned Scientists (UCS)) each provided one
individual comments provided high-level statements of support for the petitions, without
PRM-50-93 and PRM-50-95. In general, these individual comments also provided high-
level statements of support for the petitions, without citing relevant evidence to
about the NRC’s regulations or practices that the NRC staff determined to be outside the
13
Robert Leyse, a relative of petitioner Mark Edward Leyse, provided four comment
submitted a related petition for rulemaking (PRM-50-76) that the NRC denied on
PRM-50-95 and either repeated information provided in the petitions or expressed his
view that the NRC did not appropriately consider all relevant information in its denial of
PRM-50-76.
Two main factors influenced the NRC’s approach to developing and documenting
its response to public comments submitted on PRM-50-93 and PRM-50-95: (1) the
substantial number, length, and complexity of the comments that were submitted; and
(2) the limited availability of NRC resources due to competing, higher-priority work. In
this approach, individual comments that addressed similar subject categories were
grouped into one of 16 high-level comment bins. The following paragraphs provide for
each bin of comments: (1) a high-level summary of the main subject category
identifiers for individual comments that were assigned to the bin; and (2) the NRC’s
8 Robert Leyse petitioned the NRC on May 1, 2002, requesting the NRC to amend Appendix K of 10
CFR Part 50 and RG 1.157 to correct asserted technical deficiencies in the Baker-Just and
Cathcart-Pawel equations used to calculate the metal-water reaction rate in ECCS evaluation
models. The NRC denied PRM-50-76, determining that: (1) none of the specific technical issues
raised by the petitioner showed safety-significant deficiencies in the research, calculation methods,
or data used to support ECCS cooling performance evaluations; and (2) the NRC’s regulations and
regulatory guidance on ECCS cooling performance evaluations were based on sound science and
did not need to be amended (70 FR 52893).
14
the basis for the response and reference to the relevant section(s) of the NRC’s final
technical safety analysis report that provide(s) additional details to support the NRC’s
individual comments, and provides the following information: (1) a table that lists the
unique identifier and ADAMS accession number assigned to each comment submission
document; and (2) markings that clearly assign unique identifiers to portions of each
Comment: The NRC should initiate rulemaking to address the issues raised in the
petitions. (5-1, 6-1, 7-1, 8-1, 9-1, 10-1, 11-1, 12-1, 15-1, 19-1, 23-1)
NRC response: Because these comments generally supported the petitions without
providing a rationale to substantiate this support, the NRC’s overall response to the
petitions applies to this bin of comments. The final technical safety analysis report
Comment: The requested amendments to NRC’s regulations are not necessary. (18-1)
NRC response: Because this comment generally opposed the petitions without
providing a rationale to substantiate this opposition, the NRC’s overall response to the
petitions applies to this bin of comments. The final technical safety analysis report
15
Comment: As stated in PRM-50-76, the Cathcart-Pawel and Baker-Just equations are
not conservative because they were not developed to consider how complex thermal-
hydraulic phenomena would affect the metal-water reaction rate in the event of a LOCA.
(2-1, 17-2)
NRC response: The NRC disagrees with the comments. Consistent with the technical
safety analysis that was performed for PRM-50-76, the NRC staff determined that—for
tests are more important than considering the effects of complex thermal-hydraulic
derivation. Isothermal tests provide this needed temperature control. Section 1.1,
safety analysis report provides additional details to support the NRC staff’s position.
Comment: Data from cited experiments indicate that autocatalytic metal-water oxidation
occurred at temperatures below 2,200 degrees F, indicating the regulatory limit of 2,200
degrees F is not conservative. (2-6, 2-10, 3-1, 4-1, 14-5, 14-7, 14-11, 16-2, 16-4, 20-1,
20-5, 20-6, 20-10, 20-14, 20-15, 21-4, 21-14, 23-2, 24-1, 25-1, 26-11, 32-1, 32-7)
NRC response: The NRC disagrees with the comments because the NRC staff
reviewed experimental data and information from the cited experiments and found no
16
conditions. Section 2.1, “Peak Cladding Temperature Limit is Nonconservative,” of the
final technical safety analysis report provides additional details to support the NRC
staff’s position.
Comment: Data from cited experiments indicate that the Baker-Just and Cathcart-Pawel
equations used to calculate the metal-water reaction rate in ECCS evaluation models
that the NRC has determined to be acceptable for use in evaluating ECCS cooling
performance are not conservative. (1-1, 2-5, 14-1, 14-8, 14-9, 14-10, 14-12, 14-13,
14-14, 16-1, 20-4, 20-7, 20-8, 20-9, 20-11, 20-12, 20-16, 20-17, 21-3, 21-10, 21-13,
24-2, 26-1, 27-1, 27-3, 28-2, 29-3, 29-5, 29-6, 30-1, 30-2, 32-2, 32-9)
NRC response: The NRC agrees in part and disagrees in part with the comments. The
NRC agrees that the Cathcart-Pawel equation is generally not conservative. However,
consistent with its intended use, the NRC staff has determined that use of the Cathcart-
reaction rate that are appropriate for realistic ECCS evaluation models. The NRC
disagrees that the Baker-Just equation is not conservative. Consistent with its intended
use, the NRC staff has determined that use of the Baker-Just equation results in
sufficiently conservative calculations of the metal-water reaction rate that are appropriate
for conservative ECCS evaluation models. Section 2.2, “Baker-Just and Cathcart-Pawel
Equations are Nonconservative,” of the final technical safety analysis report provides
17
Comment: Extrapolation of data from cited experiments indicates that a new regulation
that requires minimum allowable core reflood rates in the event of a LOCA is necessary
to prevent Zircaloy cladding from exceeding the regulatory limit of 2,200 degrees F
under certain conditions. (2-2, 2-3, 2-4, 16-3, 20-2, 20-3, 20-13, 20-18, 21-2, 24-3, 26-2,
NRC response: The NRC disagrees with the comments because the NRC staff has
design that was used for the cited experiments—that steam cooling would be sufficient
to maintain Zircaloy cladding temperatures below the 2,200-degree-F limit. Section 2.3,
“Need for a Minimum Allowable Reflood Rate,” of the final technical safety analysis
Comment: In the FLHT-1 test, the test conductors were unable to prevent a temperature
excursion and runaway oxidation by increasing the coolant flow rate when peak cladding
evidence indicating that the regulatory limit of 2,200 degrees F is not conservative.
NRC response: The NRC disagrees with the comments because the NRC staff
determined that excessive heatup rates were not experienced during the FLHT-1
experiment until temperatures exceeded 2,420 degrees F. Section 3.1, “Issues Related
Tests,” of the final technical safety analysis report provides additional details to support
18
8. Eutectic behavior at temperatures below 2,200 degrees F
components (the Zircaloy cladding, control rods, and spacer grids) at temperatures
below 2,200 degrees F could significantly reduce the safety margins for the following
blades due to the eutectic reaction of boron carbide (B4C), stainless steel, and Zircaloy;
(2) degradation of pressurized-water reactor (PWR) cladding due to the eutectic reaction
between Inconel grids and Zircaloy cladding; and (3) degradation of PWR control rods
that contain silver (Ag), indium (In) and cadmium (Cd). (21-1, 21-6, 21-7, 21-8, 21-9, 24-
4, 26-10)
NRC response: The NRC disagrees with the comments because these assertions are
the NRC staff was unable to find any evidence that loss of a coolable geometry had
occurred at temperatures below 2,200 degrees F. Test results and analyses have
shown that insignificant eutectic reactions occur for times and maximum temperatures
below 2,200 degrees F (1,204 degrees C),” of the final technical safety analysis report
9 In this context, a eutectic reaction is a reaction in which two materials in contact with one another at
relatively high temperatures can liquefy at a temperature that is lower than the melting
temperatures of the two individual materials.
10 TRAC: Transient Reactor Analysis Code. RELAP: Reactor Excursion and Leak Analysis Program.
19
Comment: NRC’s TRACE simulations of FLECHT Run 9573 are invalid because they
did not simulate the section of the test bundle that incurred runaway oxidation.
Therefore, since NRC’s conclusions regarding the reflood rate are based on its TRACE
simulations of FLECHT Run 9573, these conclusions are also invalid. (31-4, 32-3, 32-5,
33-1)
NRC response: The NRC disagrees with the comments because the NRC staff
determined that the experimental data from FLECHT run 9573 do not show evidence of
runaway oxidation below 2,200 degrees F, despite its low reflood rate. In addition,
measurements were taken at five elevations. All five elevations were included in the
NRC’s TRACE simulation of FLECHT run 9573. Section 3.3, “TRACE simulation of
FLECHT run 9573,” of the final technical safety analysis report provides additional
Comment: The heat transfer coefficients used in Appendix K ECCS evaluation models
are based on data from thermal-hydraulic experiments conducted with stainless steel rod
bundles and therefore should not be used to infer what would happen in a reactor core
with Zircaloy bundles in the event of a LOCA. (2-9, 22-1, 26-3, 26-5, 26-6, 32-4)
NRC response: The NRC disagrees with the comments because the NRC staff
determined that models for convective heat transfer are dependent upon the properties
of the fluid—not the material properties of the heat transfer surface. Therefore, the
based on the experimental data. Section 3.5, “Stainless Steel and Zircaloy Heat
20
Transfer Coefficients,” of the final technical safety analysis report provides additional
Comment: Oxidation models are unable to predict autocatalytic oxidation reactions that
occurred below 2,200 degrees F in the PHEBUS B9R-2 test. (32-8, 32-10)
NRC response: The NRC disagrees with the comments because the NRC staff
determined that data from the cited PHEBUS B9R test does not demonstrate that an
Section 3.6, “Issues Related to the PHEBUS B9R Test,” of the final technical safety
analysis report provides additional details to support the NRC staff’s position.
NRC response: The NRC disagrees with this comment because the NRC staff
examined the cited report and found no data to support a determination that runaway
oxidation occurs at cladding temperatures less than 2,200 degrees F for experiments
simulating conditions for design-basis accidents. Section 3.7, “Issue Related to Whether
Runaway Oxidation Temperatures Start at 1100°C (2012°F),” of the final technical safety
analysis report provides additional details to support the NRC staff’s position.
11. Committee on the Safety of Nuclear Installations, Nuclear Energy Agency, Organisation for
Economic Co-operation and Development. Degraded Core Quench: Summary of Progress 1996-
1999. NEA/CSNI/R(99)23. Paris, France: Organisation for Economic Co-operation and
Development; 2000. Available at: http://www.oecd-nea.org/nsd/docs/1999/csni-r99-23.pdf.
21
13. Experimental methods used to derive the Baker-Just metal-water oxidation
reaction correlation
using experimental data from inductive heating experiments that included radiative heat
losses. These radiative heat losses would affect the oxidation behavior such that the
experiment is not representative of reactor behavior in the event of a LOCA and would
cause the Baker-Just equation to be not conservative. (13-1, 14-2, 14-3, 14-4, 14-6,
17-1, 27-2)
NRC response: The NRC disagrees with the comments because the NRC staff
determined that the subject experimental data is consistent with data obtained using
other methods and concluded that radiative heat losses are not relevant in correlating
the data to develop the metal-water reaction rate equation. The NRC staff further
calculations of the metal-water reaction rate that are appropriate for conservative ECCS
evaluation models. Section 3.9, “Experimental Methods Used to Derive the Baker-Just
Metal-Water Oxidation Reaction Correlation,” of the final technical safety analysis report
Comment: The Cathcart-Pawel and Baker-Just equations are unable to determine the
increased hydrogen production that occurred in the CORA and LOFT LP-FP-2
NRC response: The NRC neither agrees nor disagrees with the comments. The cited
22
accident conditions. Increased hydrogen production under such beyond-design-basis
Just equations when used in evaluations of ECCS cooling performance for design-basis
LOCAs. Section 3.10, “Issues Related to Cladding Oxidation and Hydrogen Production,”
of the final technical safety analysis report provides additional details to support the NRC
staff’s position.
15. Issues related to the Fuel Rod Failure (FRF) tests conducted in the Transient
Comment: Data from the FRF-1 experiment for the TREAT facility indicate that ECCS
This means that ECCS evaluation models would underpredict the amount of hydrogen
produced in the event of a LOCA and therefore are not conservative. In addition, neither
Westinghouse nor the NRC applied the Baker-Just equation to metallurgical data from
the locations of FLECHT run 9573 that incurred autocatalytic oxidation in their
application of the Baker-Just equation under LOCA conditions to evaluate its suitability.
For this reason, it was incorrect for Westinghouse and the NRC to conclude that there is
NRC response: The NRC disagrees with the comments. The NRC considered the
information about the FRF-1 experiment in the TREAT facility in the 1971 Indian Point
Unit 2 licensing hearing and determined that the ECCS evaluation models were
adequate. In addition, while it is true that the Baker-Just equation has not been applied
to metallurgical data from the locations of FLECHT run 9573 that incurred autocatalytic
oxidation, these data were not collected at the time of the experiment, and therefore do
23
not exist. However, the NRC staff has determined that the inability to apply the Baker-
Just equation to such data is an inadequate basis for asserting that it was incorrect for
Westinghouse and the NRC to conclude that there is sufficient conservatism in applying
the Baker-Just equation to LOCA conditions. Several independent studies have shown
that use of the Baker-Just equation results in sufficiently conservative calculations of the
metal-water reaction rate under design-basis LOCA conditions. Section 3.11, “Issues
Related to the FRF Tests Conducted in the TREAT Reactor,” of the final technical safety
analysis report provides additional details to support the NRC staff’s position.
Nuclear Station, which indicates the regulatory limit of 2,200 degrees F is not
conservative. In addition, a report about best-estimate predictions for the LOFT LP-FP-2
temperatures were to start increasing at a rate of 3.0 K/s. Since an analysis in support
of the NRC staff’s interim evaluation of the petitions showed heatup rates of 10.3 K/s
and 11.9 K/s at 2,199 degrees F, this indicates that runaway oxidation has occurred at
NRC response: The NRC disagrees with the comments. First, a station blackout is a
severe accident that involves conditions that are beyond the design basis, and it is
12. Haskin FE, Camp AL. Perspectives on Reactor Safety. NUREG/CR-6042 (SAND93-0971).
Washington, DC: U.S. Nuclear Regulatory Commission; 1994. Available at:
https://www.nrc.gov/docs/ML0727/ML072740014.pdf.
13. Guntay S, Carboneau M, Anoda Y. Best Estimate Prediction for OECD LOFT Project Fission
Product Experiment LP-FP-2. OECD LOFT-T-3803. Idaho Falls, ID: EG&G IDAHO, INC.; 1985.
Available at ADAMS Accession No. ML071940361.
24
inappropriate to evaluate the regulatory limit of 2,200 degrees F for design-basis LOCAs
using information obtained from models of severe accidents, which model conditions that
are more severe than those of design-basis accidents and therefore do not provide
information about how fuel cladding would respond to high temperatures under design-
basis LOCA conditions. Second, the NRC staff has determined that the runaway
oxidation described in the cited LOFT LP-FP-2 report was initiated because of the high
temperature (2,870 degrees F), not because of the heatup rate of 3.0 K/s. Therefore,
the NRC staff concluded that there is no basis for the assertion that runaway oxidation
has occurred at temperatures below the 2,200-degree-F limit because heatup rates of
more than 3.0 K/s have been observed at lower temperatures. Section 3.12, “Issues
Raised at the Public Commission Meeting in January 2013,” of the final technical safety
analysis report provides additional details to support the NRC staff’s position.
The NRC staff used a special review process to evaluate these petitions. It did
this for three main reasons: (1) additional time and resources were needed to
data from more than 200 technical references to address all arguments in the petitions;
(2) to promptly respond to any significant safety issues, if any were to be identified; and
(3) to keep the public informed and to publicly address any stakeholder concerns about
the adequacy of the NRC’s regulations following the accident that occurred in 2011 at
As part of this special review process, the NRC made a series of draft interim
reports available to the public. These reports informed the public of NRC’s progress in
25
evaluating the petitions and included the NRC staff’s initial evaluation of specific issues
and relevant data that were prioritized to determine the order in which they would be
evaluated. Information about how to access these draft interim reports is provided in
Section IV.
The NRC staff completed its technical evaluation of the petitions and prepared a
final technical safety analysis report that documents the official technical basis for the
staff’s evaluation. This final technical safety analysis report includes the NRC staff’s
evaluation of: (1) each of the three main issues raised in the petitions; and (2) additional
technical issues that are not directly related to the requested changes to the NRC’s
(e.g., submitted public comments, e-mail messages, letters, and oral statements in a
Overall, the NRC is denying the petitions because the petitioner did not present
the NRC disagrees with the arguments in the petitions and concludes that the requested
criteria or evaluation models are not necessary. The remaining paragraphs of Section III
summarize the staff’s evaluation of each of the three main issues identified in the
petitions and identify the relevant section of the NRC’s final technical safety analysis
report that provides additional details to support the NRC’s position. Information about
how to access the final technical safety analysis report is provided in Section IV.
26
The NRC staff reviewed experimental data and information from the multirod
(assembly) severe fuel damage experiments cited in the petitions and found no evidence
2,200 degrees F. Although some rapid temperature increases were observed in the
data from the cited experiments, the NRC staff disagrees with the assertion that these
data indicate that (1) autocatalytic metal-water oxidation reactions and uncontrolled
than the 2,200-degree-F limit under LOCA conditions and (2) the 2,200-degree-F limit is
therefore not conservative. The NRC staff has further determined that the
Therefore, the NRC concludes that the petitioner did not provide sufficient
information to support amending 10 CFR 50.46 to require that the calculated maximum
fuel element cladding temperature not exceed a limit based on data from cited
The NRC staff has determined that: (1) use of the Cathcart-Pawel equation
generally results in sufficiently accurate calculations of the metal-water reaction rate that
are appropriate for realistic ECCS evaluation models; and (2) use of the Baker-Just
27
that are appropriate for conservative ECCS evaluation models. The final technical
safety analysis report also cites several independent studies that provide further support
The petitioner relied on two main arguments to support the assertion that the
Cathcart-Pawel and Baker-Just equations are not conservative. The first argument was
that data from cited multirod (assembly) severe fuel damage experiments indicate both
equations are not conservative for use in analyses that calculate the temperature at
would occur in the event of a LOCA. However, the NRC staff disagrees with this
argument for two reasons: (1) autocatalytic or runaway oxidation does not begin at a
specific temperature; and (2) the petitioner made invalid comparisons between the
results of specific experiments and generic calculations that were not intended to be
The second argument was that the Cathcart-Pawel and Baker-Just equations
were not developed to consider how complex thermal-hydraulic phenomena would affect
the metal-water reaction rate in the event of a LOCA. However, consistent with the
technical safety analysis that was performed for PRM-50-76, the NRC staff determined
isothermal tests are more important than the complex thermal hydraulics suggested in
previous studies have applied the derived correlations to transients that include complex
28
correlations are limiting. These studies showed that (1) use of the Cathcart-Pawel
rate and (2) use of the Baker-Just equation results in conservative calculations of the
Therefore, the NRC concludes that the petitioner did not provide sufficient
information to support the revision of RG 1.157 and 10 CFR Part 50, Appendix K, to
require that the rates of energy release, hydrogen generation, and Zircaloy cladding
oxidation from the metal-water reaction of zirconium with steam considered in evaluation
models used to calculate ECCS cooling performance be calculated based on data from
technical safety analysis report provides additional details to support the NRC staff’s
position.
geometry and design that was used for the cited multirod (assembly) severe fuel
damage experiments disproved the petitioner’s assertions about the reflood rate. In
particular, calculations using simulations showed that steam cooling would be sufficient
to maintain the Zircaloy cladding temperatures below the 2,200-degree-F limit specified
in 10 CFR 50.46(b)(1). Moreover, the NRC staff determined that: (1) cooling of a fuel
rod bundle depends on several parameters and heat transfer mechanisms—rather than
on the reflood rate alone; (2) linear extrapolation of initial Zircaloy cladding temperatures
29
cooling at higher temperatures; and (3) extrapolation of experimental data does not
show “with high probability” that peak cladding temperatures will exceed 2,200 degrees
F.
Therefore, the NRC staff concludes that the petitioner did not provide sufficient
core reflood rates in the event of a LOCA. Section 2.3, “Need for a Minimum Allowable
Reflood Rate,” of the final technical safety analysis report provides additional details to
this notice. The ADDRESSES section of this notice provides additional information
ADAMS Accession
Date Document Number or Federal
Register Citation
Submitted Petitions
30
ADAMS Accession
Date Document Number or Federal
Register Citation
31
V. Conclusion
For the reasons cited in this document, the NRC is denying PRM-50-93 and
PRM-50-95. The petitioner did not present sufficient new information or arguments to
support the requested changes. In addition, the NRC disagrees with the arguments in
the petitions and concludes that the requested amendments to its regulations and
associated regulatory guidance are not necessary. Finally, the NRC reaffirms that its
Annette L. Vietti-Cook,
Secretary of the Commission.
32
FRN: CALCULATED MAXIMUM FUEL ELEMENT CLADDING TEMPERATURE
[ENTER DATE HERE]
DATE
33