From: Sent: To:

Shea, James Wednesday, March 23, 2011 5:57 PM RST01 Hoc; RST07 Hoc; RST05 Hoc

Cc:
Subject:

Brown, Michael; Norton, Charles; Brown, Eva; Ruland, William; Nelson, Robert; Plasse,
Richard; Brittner, Donald; James Shea; Reckley, William; Holahan, Gary What We would Do (The US BWR Operating Community)

As former Operators / STA / SRO, CRO at Oyster Creek NGS and Emergency Director at JAF, we could not help but watch in horror as our sister plants were destroyed following the earthquake and tsunami. Knowing the challenges the operators faced I and my BWR colleagues at the NRC are thinking how we would have responded to these incredible beyond design basis events. Also we should start formulating a basis of lessons learned that could be shared with the US BWR fleet as well as all nuclear plants to potentially advise our licensees and all U.S. stakeholders on these events and how the U.S. Fleet would or could cope in this situation. As listed in our talking points developed by the RST team last week some of the engineered systems that the US plants have available may have prevented this event. These include: 1) Multiple AC power supplies available from On-Site and Off-Site including AC sources required by SBO rule 50.63. EDGs with protected fuel supply required by Technical Specifications. Gravity feed from main fuel oil tank with double pipe protection and leak detection capability. 2) Diesel Driven Fire-Pumps that could be lined up to Core Spray System (probably taken out in tsunami). However, if in the US a plant needed to replace the Diesel Driven Fire Pumps our guess is that they could have been sent to a stricken site within a 24 hr time frame. 3) Hardened Vent to vent containment outside the Reactor Building, to prevent catastrophic explosion inside the reactor building which affects the structural viability of the spent fuel pools. 4) EOPs / SAMGs to ensure that the containment(s) Primary and Secondary is protected. 5) B5b pumps and equipment readily available from on-site or off-site nuclear plants.

Potential Operator Actions in the US Given that the Fuchishima Diiachi (FD) plants may have not had some of the features listed above (hardened vent ect.) and since the AC power failed catastrophically these are actions we believe the US operators would have taken based on extensive training for these type events including training on BDBE that involve the SAMG procedures. These are actions that operators may have taken in lieu of the above mitigative features to prevent extensive fuel damage or containment failure. These actions assume that all rod entered the core to an extent greater than position 04, which would by definition mean that reactor is Shut-Down. A) Remove Shutdown Decay Heat Using ISO Condenser Operation or RCICI HPCI Operation to prevent core damaae.
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Isolation Condenser in FD Unit I - Operators would have attempted to fill ISO Cond. which would have cooled the Rx to approximately 350F or hot shutdown or when Rx pressure is reduced below 25 psig. Reactor Power would be less than 1-2% after ten minutes and less than 1% after two hours. Fill Iso. Condenser by any means, which would have prevented any fuel damage and therefore H2 generation, in the following order: a. ISO-Condenser Initial Inventory (Designed to remove 6% Rx Power and has an inventory of at least 2 hours and realistically would last for additional time (several hours) given the low energy requirement after shutdown. Manual or DC operation of Condensate Valve as necessary to preserve water inventory. It appears as though FD Unit 1 was able to cool in this manner for several hours past the design basis conservative design basis.

b. B5b Pumps could have provided the necessary flow to ISO Cond. approximately 100gpm after 2 hrs and approx 15 gpm after several hours. Suction from various sources including CST, Torus, Condenser and Sea Water. c. Run Sandpiper (air operated pump) pumps with available air header pressure could possibly tap into condenser inventory near the Air Compressor Header.

d. Continue to run sandpiper pumps from available N2 bottles used for overpressure on Clean-up system surge tank CRD accumulator make up bottles. Additional bottles could have been available at all the FD sites. e. Any other means feasible. 2) RCIC/HPCI System Operation for Units 2 & 3 a. RCIC/HPCI ran for several hours at FD Units 2 & 3 this system in the US has local manual procedures to operate the governor. No power needed: use mech. yarway vessel indicators and an operator disconnects certain linkages from RCIC then manually open steam admission valve. As long as reactor has motive steam RCIC should keep the vessel covered as long as a source of water to the RCIC/HPCI Turbine is available. (Reference from Operation at Fitzpatrick NGS. This EOP operation mode may have extended the cooling at FD Units 2& 3 if the manual procedures were in place and baring other complications that could have failed the turbines mechanically. In the Japan case they may have not had this manual EOP mode of operation in which they would depend on station vital battery power lasting approximately 6-8 hrs to run the turbine governors, unless somehow replenished. Reports were coming in on a call for batteries at these Units during the early part of the event.

B)

Maintain Adequate Core Coolincq(ACC) for as long as possible Using the above method(s) (A), as per EOP should enable adequate core cooling (ACC) as long as no other complication occurs such that reactor water inventory could not be determined or indication that water level (such as containment pressure increase indicating LOCA condition) could not be maintained above the point of Steam Cooling

example at OC would be -30in TAF. At that point operators would have opened EMRVs to get last shot of steam cooling. Emergency Depressurize and inject any source of water to vessel including low pressure fire water as available. [ Note if ACC is maintained for greater than 2 hrs following shutdown the possibility of a breach of Rx Vessel is greatly reduced. If ACC could be maintained for several days such as in the case of DP unit 2 on RICI followed by any amount of feed the probability of Vessel Breech is miniscule. Once ACC is lost inject to depressurized vessel with anything at hand while simultaneously injecting water into containment to mitigate fuel release x-vessel. Exit EOP and enter SAMG (Containment Flooding) C) Protect Primary and Secondary Containment Integrity and maintain the Vessel depressurized If the reactor could not maintain ACC and restoring On-Site and Off-Site power was not imminent then Operators would have started a process to ensure containment integrity by following the SAMG's Entry into SAMGs would be directed by H2 / 02 sample from the Primary Cont control EOP and Level/Power Control EOP would direct operators into a General Emergency and entry into the SAMGs where primary containment flooding would proceed. Vent the Primary Containment using hardened Vent regardless of off-site dose consequence to ensure containment integrity (priority would be from the Torus to scrub the radioisotopes), flood the containment by any means to cool vessel and prevent release of molten materials from the reactor vessel. Shed battery loads to ensure that maximum battery use for the EMRV (to maintain vessel depressurized - this appears to be the primary issue at FD Unit-2 battery power failed which tripped the RCIC/HPCI System and failed closed the EMRVs. D) 10CFR 50.54x Possible Actions (10 CFR 50.54(x) states that a licensee may take reasonable action that departs from a license condition or a technical specification in an emergency) Given the extreme conditions seen on-site at FD, and the assumption that they did not have hardened vents, an alternate make-up to ISO Condenser or a manual non-battery power procedure to run RCIC/HPCI System the following are some speculative actions that US Operators may have taken to Preclude the loss of the Reactor Building(s) and subsequently the spent fuel pool which appears to be the primary source of the radioactive release for the FD site. 3) Crack open Containment Vents immediately after Black-Out to ensure a continuous vent path (Hardened Vent not Available) Consider venting from Rx Bid to Containment Vacuum Breaker which is near railway roll-up door to burp in small amounts the H2 and mix with outside air. Much of the particulate aerosol should be scrubbed by the Torus.

4) 5) 6)

7) 8) 9)

Purge the Rx bid. by any means including break the H2 inserting line inside Rx building to purge building with N2 Vent Rx bid. by all and any means. Make hole (s) in top of building refuel floor, open all doors natural air circulation (This looks like what they did at FD Unit-2) Line up alternate cooling from multiple sources to all fuel pools, using fire hose from on-site (use Rad waste connections in Rad Waste Bid to Cast Drop Protection System if available allows distance from vent red release) use water from intact CST (1/ million gallons) (make sure sucker dumper valve isolated after loss of AC). Last option use Sea Water. Line up Fire Water using b5b pumps to one train of Core Spray After several days (U4) highest heat load you could start from remote locations adding water or spraying SFPs as necessary. Get Off-Site Power back on by any means possible! Unit 2 CRD pumps appear to be a priority due to failed EMRV.

Short term/ Long term Actions to investigate at U.S.

Plants.
Review the current SAMGs and determine what may be added to include cases where AC power is not available for extended periods (i.e. beyond 50.63 SBO coping strategies loss of Rx Bid Ventilation was fatal for the FD reactor building) Strategies to Vent Rx Building or Purge with N2 stored on-site if hardened vent is unavailable or damaged to maintain Rx Bid structure. Additional means or emphasize on the Containment Flooding Procedure using all means available including Intake water as source. Investigate if Sea Water to Vessel makes any long term sense since a rock that insulates the corium would form on lower head and prevent cooling long term and possibly cause melt thru the vessel where no water may prevent melt using Vessel Cooling from Containment Flooding Procedure. Sea Water to Containment using Flooding Procedure may prevent corium loss to containment after some hours if cooling to vessel was maintained by RCIC/HPCI or IsoCondenser during initial 6-10 hour period which appears to be the case for FD. Limiting Sea Water to Rx Core may be better for long term heat xfer options once clean water became available for injection into the Rx Core. Strengthen the STA position to give Shift personnel better decisions regarding BDBE mitigation strategies. Spent Fuel Pool Cooling SAMGs need to be developed to determine how to best refill SFP in boil-off condition or Dry. The RST team provided the NRC in-country Japan team an expert panel procedure on best options to refill an empty SFP. We may want to refine this into better planned procedure. Some of the wild ideas included Liquid Argon, and Fire Foam into the SFP these all have merit and should be explored to inform possible future SFP SAMG. Should BDBE Equipment such as the Pumping System developed by the RST team be staged by INPO or by NRC? I would suggest YES!! How and where should be considered.

Jim Shea Don Brittner former Ops / CRO/ SRO OCNGS Rick Plasse former Fitzpatrick Emergency Director.