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[7590-01-P]

NUCLEAR REGULATORY COMMISSION

10 CFR Part 50

[Docket Nos. PRM-50-93 and PRM-50-95; NRC-2009-0554]

Calculated Maximum Fuel Element Cladding Temperature

AGENCY: Nuclear Regulatory Commission.

ACTION: Petitions for rulemaking; denial.

SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is denying two related

petitions for rulemaking (PRMs), PRM-50-93 and PRM-50-95, submitted by Mark

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

aspects of the NRC’s regulations on emergency core cooling systems acceptance

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

closed on [INSERT DATE OF PUBLICATION IN THE FEDERAL REGISTER].

ADDRESSES: Please refer to Docket ID NRC-2009-0554 when contacting the NRC


about the availability of information for this action. You may obtain publicly-available

information related to this action by any of the following methods:

• Federal Rulemaking Web Site: Go to http://www.regulations.gov and

search for Docket ID NRC-2009-0554. Address questions about NRC dockets to Carol

Gallagher; telephone: 301-415-3463; e-mail: Carol.Gallagher@nrc.gov. For technical

questions, contact the individual listed in the FOR FURTHER INFORMATION

CONTACT section of this document.

• NRC’s Agencywide Documents Access and Management System

(ADAMS): You may obtain publicly-available documents online in the ADAMS Public

Documents collection at http://www.nrc.gov/reading-rm/adams.html. To begin the

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

(PDR) reference staff at 1-800-397-4209, 301-415-4737, or by e-mail to

pdr.resource@nrc.gov. For the convenience of the reader, instructions about obtaining

materials referenced in this document are provided in Section IV, “Availability of

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.

FOR FURTHER INFORMATION CONTACT: Daniel Hudson, Office of Nuclear

Regulatory Research, telephone: 301-415-2411, e-mail: Daniel.Hudson@nrc.gov and

Daniel Doyle, Office of Nuclear Material Safety and Safeguards, telephone:

301-415-3748, e-mail: Daniel.Doyle@nrc.gov. Both are staff of the U.S. Nuclear

Regulatory Commission, Washington DC 20555-0001.

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SUPPLEMENTARY INFORMATION:

I. Background and Summary of the Petitions

II. Public Comments on the Petitions

III. NRC Technical Evaluation and Reasons for Denial

IV. Availability of Documents

V. Conclusion

I. Background and Summary of the Petitions

Subpart 2.802 of Title 10 of the Code of Federal Regulations (10 CFR), “Petition

for Rulemaking—Requirements for Filing,” provides an opportunity for any interested

person to petition the Commission to issue, amend, or rescind any regulation. On

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,

2010 (75 FR 3876).

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

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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

reflood rates in the event of a loss-of-coolant accident (LOCA).

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

a notice of consolidation of PRM-50-93 and PRM-50-95 in the Federal Register (75 FR

66007) and requested public comment.

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

the petitioner made to address each issue.

Issue 1: Calculated Maximum Fuel Element Cladding Temperature Limit

Background for Issue 1

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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

LOCAs1 conforms to the criteria specified in 10 CFR 50.46(b).2 Under 10 CFR

50.46(b)(1), the calculated maximum fuel element cladding temperature shall not exceed

2,200 degrees Fahrenheit (F). In addition, 10 CFR 50.46(b)(2) through (b)(5),

respectively, contain requirements for calculations involving: maximum cladding

oxidation, maximum hydrogen generation, changes in core geometry, and long-term

cooling.

Petitioner’s Arguments and Requests Related to Issue 1

The petitioner asserted that data from multirod (assembly) severe fuel damage

experiments indicate that the calculated maximum fuel element cladding temperature

limit of 2,200 degrees F specified in 10 CFR 50.46(b)(1) is not conservative. Although

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.

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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

continues to increase, eventually resulting in an uncontrolled reaction and temperature

excursion. The petitioner asserted that data from cited experiments indicate that such

autocatalytic metal-water oxidation reactions and uncontrolled temperature excursions

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

from cited experiments, instead of the 2,200-degree-F limit specified in

10 CFR 50.46(b)(1).

Issue 2: Metal-Water Reaction Rate Equations for ECCS Evaluation Models

Background for Issue 2

To evaluate conformance with the criteria specified in 10 CFR 50.46(b), ECCS

cooling performance must be calculated using an acceptable evaluation model3 for a

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.”

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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

an improved understanding of ECCS performance during reactor transients that was

obtained through extensive research performed after promulgation of the original

requirements. Under 10 CFR 50.46(a)(1), licensees or applicants may use one of two

acceptable ECCS evaluation model options: (1) a best-estimate or realistic evaluation

model4; or (2) a conservative evaluation model. Each ECCS evaluation model option is

summarized below.

Option 1: Best-estimate or Realistic ECCS Evaluation Model

The regulation at 10 CFR 50.46(a)(1)(i) specifies that a best-estimate evaluation

model must include sufficient supporting justification to show that the analytical

technique realistically describes the behavior of the reactor system during a LOCA.

Comparisons to applicable experimental data must be made and uncertainties must be

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.

RG 1.157 describes models,5 correlations,6 data, model evaluation procedures,

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
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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)

including uncertainty in the comparisons of the calculated results to the criteria of

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

they are supported by appropriate experimental data and technical justification.

To be considered acceptable under RG 1.157, evaluation models should account

for identified sources of heat— including the metal-water reaction rate—in performing

best-estimate calculations. In particular, the rates of energy release, hydrogen

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,

depending on the cladding temperature:

(1) If the cladding temperature is less than or equal to 1,900 degrees F, correlations

to be used to calculate metal-water reaction rates should: (1) be checked

against a set of relevant data; and (2) recognize the effects of steam pressure,

pre-oxidation of the cladding, deformation during oxidation, and internal oxidation

from both steam and uranium oxide fuel.

(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.”

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Option 2: Conservative ECCS Evaluation Model

Alternatively, a conservative evaluation model may be developed in conformance

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

reaction rate. In particular, Subpart I.A.5, “Metal-Water Reaction Rate,” of Appendix K

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.

Petitioner’s Arguments and Requests Related to Issue 2

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

equation in realistic evaluation models or use of the Baker-Just equation in conservative

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

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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

Cathcart-Pawel or Baker-Just equations.

Issue 3: Minimum Allowable Core Reflood Rate

Background for Issue 3

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.

Petitioner’s Arguments and Requests Related to Issue 3

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

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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

reflood rates in the event of a LOCA.

II. Public Comments on the Petitions

II.A. Overview of Public Comments

The NRC received a total of 33 comment submissions that collectively included

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

individual comments submitted, grouped by three main categories of comments. These

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

approach for addressing all submitted comments, regardless of category or who

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.

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Table I. Number of Comment Submissions and Individual Comments by Category

Number of Comment Number of Individual


Category
Submissions Comments
Comments from the Petitioner 13a 97a
Comments from Nuclear Industry
3 9
Representatives
Comments from Public Interest
Groups or Other Interested 17 19
Individuals
Total 33 125
a The petitioner provided nine comment submissions after the public comment period

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.

Category 1: Comments from the Petitioner

Petitioner Mark Edward Leyse provided a total of 13 comment submissions in

support of PRM-50-93 and PRM-50-95. He provided nine of these comment

submissions after the comment period closed. The NRC considered all 13 comment

submissions in its evaluation. In general, the petitioner’s comments further supported

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

issues in its final technical safety analysis report.

Category 2: Comments from Nuclear Industry Representatives

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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

PRM-50-93 and PRM-50-95 because the experiments identified in the petitions—

whether considered individually or in conjunction with other experiments—do not

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.

Exelon Corporation provided one comment submission that opposes PRM-50-93

and PRM-50-95, stating that: (1) it did not consider the proposed amendments to the

NRC’s regulations or associated regulatory guidance to be necessary; and (2) it agreed

with the comments that NEI submitted.

Category 3: Comments from Public Interest Groups or Other Interested Individuals

Individuals representing three public interest groups (Don’t Waste Michigan,

Beyond Nuclear, and Union of Concerned Scientists (UCS)) each provided one

comment submission in support of PRM-50-93 and PRM-50-95. In general, the

individual comments provided high-level statements of support for the petitions, without

citing relevant evidence to substantiate the petitions.

Other interested individuals provided a total of 10 comment submissions on

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

substantiate the petitions. In addition, several comments identified unrelated concerns

about the NRC’s regulations or practices that the NRC staff determined to be outside the

scope of PRM-50-93 and PRM-50-95.

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Robert Leyse, a relative of petitioner Mark Edward Leyse, provided four comment

submissions in support of PRM-50-93 and PRM-50-95. Robert Leyse had previously

submitted a related petition for rulemaking (PRM-50-76) that the NRC denied on

September 6, 2005.8 In general, Robert Leyse’s comments supported PRM-50-93 and

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.

II.B. NRC Response to Public Comments

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

addressed in the grouped comments, including a listing in parentheses of the unique

identifiers for individual comments that were assigned to the bin; and (2) the NRC’s

response to the grouped comments, including—if appropriate—a high-level summary of

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).

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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

position. A separate document consolidates all 33 comment submissions and 125

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 submission that were identified as distinct individual comments. Information

about how to access this consolidated document is provided in Section IV.

1. General support for petitions without providing rationale

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

provides additional details to support the NRC staff’s position.

2. General opposition to petitions without providing rationale

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

provides additional details to support the NRC staff’s position.

3. Comments related to PRM-50-76

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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

the development of metal-water reaction rate equations—well-characterized isothermal

tests are more important than considering the effects of complex thermal-hydraulic

phenomena. The suggested use of complex thermal-hydraulic conditions would be

counterproductive in tests to experimentally derive reaction rate correlations because

temperature control is required to develop a consistent set of data for correlation

derivation. Isothermal tests provide this needed temperature control. Section 1.1,

“Similar Petition Previously Considered by NRC (ML041210109),” of the final technical

safety analysis report provides additional details to support the NRC staff’s position.

4. Peak cladding temperature limit is not conservative

Comment: Data from cited experiments indicate that autocatalytic metal-water oxidation

reactions and uncontrolled temperature excursions involving Zircaloy cladding have

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

evidence of temperature escalation rates that demonstrated the occurrence of

autocatalytic or runaway oxidation reactions below 2,200 degrees F under LOCA

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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.

5. Baker-Just and Cathcart-Pawel equations are not conservative

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-

Pawel equation generally results in sufficiently accurate calculations of the metal-water

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

additional details to support the NRC staff’s position.

6. Need for a minimum allowable reflood rate

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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,

26-7, 26-9, 32-6)

NRC response: The NRC disagrees with the comments because the NRC staff has

determined—using simulations of a Zircaloy cladding bundle with the geometry and

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

report provides additional details to support the NRC staff’s position.

7. Issues related to National Research Universal (NRU) full-length high-

temperature (FLHT) in-reactor tests

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

temperatures reached approximately 2,200 degrees F. This provides additional

evidence indicating that the regulatory limit of 2,200 degrees F is not conservative.

(21-5, 26-4, 26-8, 28-3, 29-1, 29-4)

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

to National Research Universal (NRU) full-length high-temperature (FLHT) In-reactor

Tests,” of the final technical safety analysis report provides additional details to support

the NRC staff’s position.

18
8. Eutectic behavior at temperatures below 2,200 degrees F

Comment: In a design-basis LOCA, eutectic reactions9 between various fuel assembly

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

types of materials interactions: (1) degradation of boiling-water reactor (BWR) control

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

not supported by available experimental evidence. In its review of available information,

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

assumed in a design-basis LOCA. Section 3.2, “Eutectic Behavior at Temperatures

below 2,200 degrees F (1,204 degrees C),” of the final technical safety analysis report

provides additional details to support the NRC staff’s position.

9. TRAC/RELAP10 Advanced Computational Engine (TRACE) code simulation of

(Full Length Emergency Cooling Heat Transfer) FLECHT run 9573

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,

FLECHT run 9573 was a low-reflood-rate experiment in which thermocouple

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

details to support the NRC staff’s position.

10. Stainless steel and Zircaloy heat transfer coefficients

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

heater rod material used in the experiments is irrelevant to developing correlations

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

details to support the NRC staff’s position.

11. Issues related to the PHEBUS B9R test

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

autocatalytic oxidation reaction occurred at temperatures below 2,200 degrees F.

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.

12. Whether runaway oxidation begins at 2,012 degrees F

Comment: Information in a report about degraded core quench experiments11 indicates

that temperatures at which temperature excursions associated with runaway oxidation

occur range from 1,922 degrees F to 2,012 degrees F. (2-7)

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

Comment: The Baker-Just equation is not conservative because it is partly derived

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

concluded 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 3.9, “Experimental Methods Used to Derive the Baker-Just

Metal-Water Oxidation Reaction Correlation,” of the final technical safety analysis report

provides additional details to support the NRC staff’s position.

14. Issues related to cladding oxidation and hydrogen production

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

experiments. (29-2, 31-3)

NRC response: The NRC neither agrees nor disagrees with the comments. The cited

experiments were performed to better understand reactor behavior under severe

22
accident conditions. Increased hydrogen production under such beyond-design-basis

conditions is not relevant in determining the suitability of the Cathcart-Pawel or Baker-

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

REActor Test (TREAT) facility reactor

Comment: Data from the FRF-1 experiment for the TREAT facility indicate that ECCS

evaluation models underpredicted the amount of hydrogen produced in that experiment.

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

sufficient conservatism in applying the Baker-Just equation to LOCA conditions. (2-8,

21-11, 21-12, 28-1)

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.

16. Issues raised at the public Commission meeting in January 2013

Comment: An NRC document12 states that runaway zirconium oxidation would

commence at 1,832 degrees F in a postulated station blackout scenario at Grand Gulf

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

experiments13 states that runaway oxidation would commence if fuel-cladding

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

temperatures below the 2,200-degree-F limit. (31-1, 31-2)

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.

III. NRC Technical Evaluation and Reasons for Denial

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

reevaluate more than 40 years of severe accident and thermal-hydraulic experimental

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

the Fukushima Dai-ichi Nuclear Power Station in Japan.

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

regulations that were raised in either the petitions or in subsequent communications

(e.g., submitted public comments, e-mail messages, letters, and oral statements in a

public meeting with the Commission).

Overall, the NRC is denying the petitions because 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 on ECCS acceptance

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.

Issue 1: Calculated Maximum Fuel Element Cladding Temperature Limit

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

of temperature escalation rates that demonstrated the occurrence of autocatalytic or

runaway oxidation reactions at Zircaloy cladding temperatures less than

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

temperature excursions involving Zircaloy cladding have occurred at temperatures less

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

2,200-degree-F limit in 10 CFR 50.46(b)(1) provides an adequate margin of safety to

preclude autocatalytic metal-water oxidation reactions.

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

experiments, instead of the 2,200-degree-F limit in 10 CFR 50.46(b)(1). Section 2.1,

“Peak Cladding Temperature Limit is Nonconservative,” of the final technical safety

analysis report provides additional details to support the staff’s position.

Issue 2: Metal-Water Reaction Rate Equations for ECCS Evaluation Models

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

equation results in sufficiently conservative calculations of the metal-water reaction rate

27
that are appropriate for conservative ECCS evaluation models. The final technical

safety analysis report also cites several independent studies that provide further support

for these findings.

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

which an autocatalytic or runaway oxidation reaction involving the Zircaloy cladding

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

applied to a specific test facility.

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

that—for the development of metal-water reaction rate equations—well-characterized

isothermal tests are more important than the complex thermal hydraulics suggested in

the petitions. The suggested use of complex thermal-hydraulic conditions would be

counterproductive in tests to experimentally derive reaction rate correlations because

temperature control is required to develop a consistent set of data for correlation

derivation. Isothermal tests provide this necessary temperature control. However,

previous studies have applied the derived correlations to transients that include complex

thermal-hydraulic conditions to verify that the proposed phenomena embodied in the

28
correlations are limiting. These studies showed that (1) use of the Cathcart-Pawel

equation results in conservative or best-estimate calculations of the metal-water reaction

rate and (2) use of the Baker-Just equation results in conservative calculations of the

metal-water reaction rate.

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

cited experiments, instead of using the Cathcart-Pawel or Baker-Just equations. Section

2.2, “Baker-Just and Cathcart-Pawel Equations are Nonconservative.” of the final

technical safety analysis report provides additional details to support the NRC staff’s

position.

Issue 3: Minimum Allowable Core Reflood Rate

NRC calculations using simulations of a Zircaloy cladding bundle with the

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

to predict final cladding temperature is inappropriate because of increased radiative

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

information to support issuance of a new regulation that requires minimum allowable

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

support the NRC staff’s position.

IV. Availability of Documents

Table II provides information about how to access the documents referenced in

this notice. The ADDRESSES section of this notice provides additional information

about how to access ADAMS.

Table II. Information about How to Access Referenced Documents

ADAMS Accession
Date Document Number or Federal
Register Citation
Submitted Petitions

May 1, 2002 Petition for Rulemaking (PRM-50-76) ML022240009

November 17, 2009 Petition for Rulemaking (PRM-50-93) ML093290250

June 7, 2010 Petition for Rulemaking (PRM-50-95) ML102770018

30
ADAMS Accession
Date Document Number or Federal
Register Citation

Federal Register Notices

Denial of Petition for Rulemaking (PRM-50-


September 6, 2005 70 FR 52893
76)

Notice of Receipt of Petition for Rulemaking


January 25, 2010 75 FR 3876
(PRM-50-93)

Notice of Consolidation of Petitions for


October 27, 2010 Rulemaking and Re-Opening of Comment 75 FR 66007
Period (PRM-50-93 and PRM-50-95)

Consolidated Public Comments Document

Public Comments on Petitions for


November 21, 2017 Rulemaking: Calculated Maximum Fuel ML17325A007
Element Cladding Temperature

Draft Interim Reports

Draft Interim Review of PRM-50-93/95


August 23, 2011 ML112290888
Issues Related to the CORA Tests

Draft Interim Review of PRM-50-93/95


September 27, 2011 ML112650009
Issues Related to the LOFT LP-FP-2 Test
Draft Interim Review of PRM-50-93/95
Issues Related to Conservatism of 2200
October 16, 2012 degrees F, Metal-Water Reaction Rate ML12265A277
Correlations, and “The Impression Left from
[FLECHT] Run 9573.”
Draft Interim Review of PRM-50-93/95
March 8, 2013 Issues Related to Minimum Allowable Core ML13067A261
Reflood Rate

Final Technical Safety Analysis Report

Technical Safety Analysis of PRM-50-


August 19, 2016 93/95, Petition for Rulemaking on 10 CFR ML16078A318
50.46

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

existing regulations continue to provide reasonable assurance of adequate protection of

public health and safety.

Dated at Rockville, Maryland, this day of , 2018.

For the Nuclear Regulatory Commission.

Annette L. Vietti-Cook,
Secretary of the Commission.

32
FRN: CALCULATED MAXIMUM FUEL ELEMENT CLADDING TEMPERATURE
[ENTER DATE HERE]

ADAMS Accession No: ML14308A098 *Concurrence via e-mail

OFFICE NMSS/DRM/RRPB/PM NMSS/DRM/RRPB/PM NMSS/DRM/RRPB/RS NMSS/DRM/RRPB/BC NMSS/DRM/RASB/BC


NAME DHudson DDoyle GLappert MKhanna CBladey
DATE 12/19/2017 12/14/2017 12/18/2017 12/19/2017 12/28/2017*
OFFICE NMSS/DRM/D* RES/D* NRO/D OGC/GCLR/RMR NRR/D
NAME PHolahan MWeber, MCase for FBrown,JMonninger for MSpencer, SClark for BHolian, MEvans for
DATE 12/29/2017 01/11/2018 01/08/2018 02/01/2018* *

OFFICE EDO SECY

NAME VMcCree AVietti-Cook

DATE

OFFICIAL RECORD COPY

33

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