Tuesday, February 20, 2007

Mr. Chairman, tell me about those more than 50 tests, please.

Of course, these entries are brief, however, a total disclosure of the facts would be quite lengthy. Anyway during the past eight years or so, I've submitted several Petitions for Rulemaking to the NRC and they have all been denied. But the record is there, including letters of derision from various vendors, operators and lobbyists. (More on all that in future entries to this blog.)

In the early 1970's there was a lengthy set of hearings run by the AEC in the matter of emergency core cooling systems. About the best assertion by the Commissioners is that more tests with Zircaloy are necessary to "... overcome the impression left from run 9573."

One of my petitions was docketed as PRM-50-76 and the NRC spent a few dollars on a document of refutation, ML041210109, April 29, 2004.

The following is extracted from that document:

Mr. Leyse states that:

"Petitioner is aware that more experiments with Zircaloy cladding have not been conducted on the scale necessary to ... overcome the impression left from run 9573."

In the early 1980's, the NRC through Pacific Northwest Laboratories (PNL) contracted with National Research Universal (NRU) at Chalk River, Canada to run a series of LOCA tests in the NRU reactor. More than 50 tests were conducted to evaluate the thermal-hydraulic and mechanical deformation behavior of a full length 32-rod bundle during the heatup, reflood and quench phases of a large break LOCA. ... The NRC is reviewing the data from this program to determine the value of using it to assess the current generation of codes such as TRAC-M, now renamed TRACE.

Well, it has been almost three years since our NRC issued that analysis, but I have yet to find documentation of those more than 50 tests from the early 1980's. Moreover, there is no reference to those "... more than 50 tests ..." in the great "Compendium of ECCS Research for Realistic LOCA Analysis," NUREG 1230, December, 1988. And, if the NRC has ever gotten around to determining the value of whatever meager data may exist, they have likely found that it has no value although they have not openly documented that.

Repeating, the NRC staff issued its document of refutation, ML041210109 on April 29, 2004. Almost one year later, the NRC notified me of its denial of petition for rulemaking (PRM-50-76). In her cover letter, (ML052220454), the Secretary of the Commission, Annette L. Vietti-Cook, a designated authority in these matters, informed me:

Contrary to your assertion that there has not been appropriate testing to address the issues raised by run 9573, the NRC has continued to study complex thermal hydraulic effects on ECCS heat transfer processes during accident conditions related to LOCAs consistent with Commission direction. As part of that initiative, the NRC funded more than 50 Zircaloy clad nuclear fueled bundle reflood experiments at the National Research Universal (NRU)reactor. These experiments evaluated fuel rod and heat transfer behavior but did not include metallurgical examination to evaluate oxidation behavior. The NRC is continuing to conduct and evaluate experimental and analytical programs on fuel cladding behavior.

Maybe the Secretary is using tricky language. She says the NRC funded more than 50 tests, but in contrast to the report of her staff, she does not assert that more than 50 tests were conducted. In any case, there are no more than 50 tests in any record, and the NRC is practicing fraud and falsification.

Bernie Ebbers of Worldcom fame disclosed that he knew what he did not know and that he knew nothing about technology or financial accounting. He is in jail and will likely be there for for a long time!

1 comment:

Steve Schulin said...

Dear Mr. Leyse -

I see that you asked NRC Chairman Klein for a list of the more than fifty tests in an email last October. Has NRC acknowledged or answered your request?

How many LOCA tests do you contend were conducted at NRU in the early 1980s? In your quoting from the the NRC/RES refutation, you choose to use elipses rather than publicize the 2 references to Chalk River experiments provided. I note that a search of ADAMS for either of those report numbers show hit in that great compendium you mention.

This morning, I left a voice mail for one of the NRC staffers listed as contacts for the refutation, asking about the basis for the more than 50 tests comment. If he calls back, I'll share whatever info he provides.

I'm not an expert in the matters raised by your petition. That you make an issue here on your blog out of the Secretary signing letter for the Commission tends to show you as straining to emphasize silly stuff. The Federal Register notice signed by Secretary listed separate NRC/NRR contact name and number for further info. The memo presenting the refutation listed name and number for three NRC/RES contacts for questions or comments. I would be respectfully skeptical of your assertions about fraud and falsification even if you hadn't included the apparent inanity about the role of the Secretary.

Very truly,

Steve Schulin
http://www.nuclear.com

P.S. I came to your blog after seeing your email amongst yesterday's new ADAMS releases. That condenser report was full of interesting stuff. Thanks for highlighting it.