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PMT.japan Resource April 29 roadmap analysis Rev7.docx April 29 roadmap analysis Rev7.docx

All, Attached is the final Consortium approved Roadmap analysis. Chuck Norton RST BWR Analyst

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The United States Consortium of Industrial and Governmental Organizations* analysis of the adequacy of the Tokyo Electric Power Company (TEPCO) Roadmap for the purpose of achieving near term plant stability goals established by the Consortium Introduction: The United States Consortium of Industrial and Governmental Organizations associated with nuclear energy suggests near and long term goals for the stabilization of the damaged Fukushima Daiichi nuclear units. This document is not an official position of the U.S. Nuclear Regulatory Commission or associated industrial or governmental entities. It is meant as technical insights to the Government of Japan on the TEPCO Roadmap. It is understood that the responsibility and decisionmaking regarding meeting these goals is the responsibility of TEPCO and the Japanese regulatory body. Purpose: As requested, the purpose of this analysis is to evaluate ifthe TEPCO Roadmap will accomplish the near term actions necessary to minimize radiological releases and reestablish safety functions. The consortium considers these functions to be reasonable to support long-term efforts that will be needed to achieve a safe end state. Note: The TEPCO Roadmap is included as an attachment to this document. Background: The consortium has established five essential functions necessary for achieving the near term (TEPCO's Step 2 (6 to 9 months)) goal of establishing plant conditions that provide reasonable confidence that unanticipated conditions will not require increased Protective Action measures. These five essential functions are as follows: 1. Remove decay and chemical heat from reactors, containment, and spent fuel pools. 2. Maintain reactors and spent fuel pools subcritical and adequately shielded. 3. Ensure structural integrity for all units (e.g. containment and spent fuel pools). 4. Provide reliable indication of essential parameters. 1

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5. Terminate (or render insignificant) uncontrolled radioactive releases. Factors used to evaluate the status of the essential functions are as follows: 1. Remove decay and chemical heat. a. Establish reactor pressure vessel (RPV) water level, reliably maintained, above top of the active fuel (TAF). If unable to maintain RPV water level, establish and maintain containment water levels covering the RPV lower head. Reduce RPV temperatures to less than 100 degrees Celsius. b. Provide functional and reliable backups, including power sources, for each of the systems being used; ensure backups can be employed in time to maintain adequate cooling. c. Establish a functional and clean water source of sufficient capacity to ensure adequate on-site cooling water. d. Establish the ability to reliably add makeup water to each spent fuel pool and maintain spent fuel pool temperatures less than 100 degrees Celsius. 2. Maintain reactors and spent fuel pools sub-critical and adequately shielded. e. Establish reliable means, either chemical or geometric, to maintain each reactor and each spent fuel pool sub-critical. f. Establish adequate shielding or zone of protection around reactors and spent fuel pools to allow for the safe execution of Roadmap countermeasures. 3. Ensure structural integrity for all units (e.g. containment and spent fuel pools). g. Preclude detonation in primary containment atmosphere by establishing a noncombustible atmosphere in the primary containment. h. Establish reasonable assurance of Reactor Pressure Vessel, Primary Containment, and Spent Fuel Pool integrity. 4. Reliable Indication of essential parameters.

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-OfficiUse-Only-- Sensitive Internal Information L Establish reliable means to determine key parameters associated with actual or potential large releases. i. Instrumentation to confirm reactors and spent fuel pools are sub-critical, ii. Area Radiation, gaseous and liquid release detectors, iii. Reactor Pressure Vessel/Drywell/Suppression Pool (RPV/DW/SP) level, RPV/DW/SP pressure indications, RPV/DW/SP temperatures iv. Spent fuel pool level, temperature indications 5. Terminate (or render insignificant) uncontrolled radioactive releases j. Establish the means for containment of significant external leakage (e.g. primary containment leakage) for portions of the plant (spent fuel pools or reactor units) with credible potential for energetic releases of significant quantities of radioactive material. k. With regard to activities in close proximity to the site, consider measures to minimize further spread of contamination (e.g., covers or resin spray over significant sources of loose contamination at the plant).

Summary of US Technical Suggestions: The following are suggestions to enhance TEPCO's ability to achieve its stated Roadmap targets. They are suggestions that, if enacted, could better align the Roadmap to the Consortium's "stability" recommendations. The Roadmap contains the essential countermeasures for core and spent fuel cooling. Completion of these elements as quickly as possible will reduce the risk of further damages. Obstacles to flooding of the containments, e.g., radwaste processing should be given priority so that containment flooding can begin as quickly as possible. The equipment used to add water to the spent fuel pools (i.e., giraffes) are a single point of failure that could result in a loss of cooling function to the 1F1 and 1F4 spent fuel pools. The Consortium encourages TEPCO to provide independent, redundant backup means of cooling

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Official Use, O.y - Sensitive Internal Information the spent fuel pools 1 F1 and 1F4 that can be employed in time to provide adequate cooling should the primary means fail. Based on photographs of 1 F1 it is not clear to the Consortium that water is actually reaching the pool. The Consortium encourages TEPCO to pursue additional investigations to validate that the spent fuel in spent fuel pool 1F1 is being cooled. The consortium recommends that TEPCO consider adding a redundant means of adding water as a backup to the normal fuel pool cooling systems for the 1F2 spent fuel pool. Restoration of the cooling function of fuel pool cooling system would also increase reliability. The Consortium recommends redundant delivery systems with multiple points of injection to each of the seven fuel locations requiring emergency cooling to improve the reliability of the cooling function. In addition, installing pipes that are seismically supported, in place of fire hoses that are currently being used to carry cooling water may improve system reliability in case of aftershocks. The Consortium acknowledges the need to circulate water back to the RPVs to improve the waste-water generation situation. Coupling this action with redundant delivery systems to the fuel locations requiring emergency cooling would be highly beneficial. The TEPCO Roadmap is silent on maintaining the fuel sub-critical. Fuel movement and structural degradation have the potential to increase reactivity. Actions to further prevent or detect inadvertent criticality, such as adding borated water to spent fuel pools, would improve confidence that inadvertent criticality will not inhibit recovery actions. The fuel configuration in 1 F1, 1F2, and 1 F3 spent fuel pools has not been verified. Verification of actual conditions in the spent fuel pools would help inform the proposed countermeasures contained in the Roadmap. The Consortium encourages continued prevention of a hydrogen explosion by implementing nitrogen injection into the Primary Containment Vessels (PCV) for 1F2 and 1 F3.

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TEPCO Roadmap structural concerns related to spent fuel pools are primarily focused on the 1F4 spent fuel pool. However, the structural integrity of reactor building 3 also appears to be degraded from the explosions. Although 1 F4 spent fuel pool may have more significant consequences because the full core was offloaded from 1F4 reactor core, the consortium also encourages TEPCO to assess the structural integrity of the 1F3 spent fuel pool, and confirm the structural integrity of spent fuel pools 1F1 and 1F2. Instrumentation is showing signs of degradation and will continue to degrade with time. Investigation and development of alternate instrumentation systems will be necessary to ensure critical parameters will continue to be monitored, and that the data will be accurate. Also, recovery of installed instrumentation, where possible, will be helpful. Consideration should be given to the issues of biological growth within the reactor vessels, primary containments, and the spent fuel pools. It is likely that sea water used for emergency cooling included some life forms capable of enduring temperatures and radiation doses currently present much as was the case at Three Mile Island (TMI). It is likely that seawater also provides nutrients for such life forms. Growth of the life forms could at a minimum reduce visibility in the waters again as was the case at TMI. In a worst case, growth of life forms could affect coolability of the fuel either by reducing flows or reducing heat transfer coefficients from surfaces. Analysis: The analysis that follows assesses the adequacy of the TEPCO Roadmap countermeasures and risk considerations. It addresses the factors necessary to satisfy the five Consortium identified essential functions necessary to provide reasonable confidence that unanticipated conditions will not require increased protective action measures. Understandably, the TEPCO Roadmap presents a high-level strategy with timeframe goals and is not a project plan and schedule. It addresses key objectives such as shifting to recirculation and heat exchanger based cooling, flooding the primary containment vessels to improve core cooling, stopping the containment water leakage that is preventing containment flood up, and radioactive waste water reprocessing. The Roadmap lays out a path that accomplishes the stated objectives. However, the practicability of achieving the step 1 and step 2 objectives in

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Official Use Only - Sensitive Internal Information the indicated timeframes cannot be reliably assessed considering the tremendous challenges involved in achieving some of the pivotal goals. For example, flooding the 1 F2 core depends on having an intact RPV or stopping the suspected leak in the suppression pool. Considering the lack of access to the damaged area it is impossible to accurately assess the feasibility and timeframe for such a repair. For such items, further details developed by TEPCO will enable a more meaningful assessment of the planned actions. Thus, we suggest that the countermeasures be prioritized, further defined, and scheduled so a clearer view of site activities can be gained. Those priorities will guide specific action plans and specific actions as TEPCO progresses through recovery.

Note: For clarity US Consortium items will be non-italicized; TEPCO countermeasuresand risks will be italicized Note: Because it may not be possible to accomplish some proposed actions in the near future, individual assessments of each reactor unit and spent fuel pool may be necessary to demonstrate that the five essential functions are accomplished without necessarily complying with each individual factor. Factors used to evaluate Essential Function 1 (Remove decay and chemical heat) a. Factor: Establish reactor pressure vessel (RPV) water level, reliably maintained,

above top of the active fuel (TAF). If unable to maintain RPV water level, establish and maintain containment water levels covering the RPV lower head. Reduce RPV temperatures to less than 100 degrees Celsius. (Unit FI and Unit F3) Countermeasure[9]: Flood the primary containment vessel (PCV) up to the top of active fuel (TAF). Countermeasure[10]: Reduce the amount of radioactive materials(utilization of standby gas treatment system (filter), etc.) when PCV venting (release of steam containing radioactivematerials into the atmosphere).

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Countermeasure[11]: Continue preventing hydrogen explosion by injecting nitrogen into the PCV. Risk [4]: Increase in water leakage into the turbine building in the process of flooding the PCV. Countermeasure[12]: Considerationand implementation of measures to hold down water inflow (e.g., circulating the water back into the RPV by storing and processingthe accumulated water in the turbine building.). Countermeasure[13] Considerationof recovering heat exchange function for the reactor (installingheat exchangers) Risk [5]: Possibilityof prolonged work in high dose level area (keep countermeasures[9] and [12])

(Unit 2)
Countermeasure[14]: Continue cooling by current minimum injection rate. Countermeasure[16]: Continue considerationand implementation of sealing measure to damagedlocation. Implement cooling measures similarto those for Units F1 and F3 once the damaged location is sealed. Risk [2]: Possibilityof prolonged work sealing the damaged location (continue countermeasures[12] and [14] Factor a. analysis: Countermeasure [9] will satisfy Factor a. Obstacles to flooding of the containments, e.g., radwaste processing should be given priority so that flooding can begin as quickly as possible.

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b. Factor: Provide functional and reliable backups, including power sources, for each of the systems being used; ensure backups can be employed in time to maintain adequate cooling. Countermeasure[8]: Install interconnectinglines of offsite power soon Countermeasure[22] Continue water injection by "Giraffe", etc (reliabilityimprovement (enhanceddurabilityof hoses)/switch to remote-controlledoperation) Factor b. analysis: Countermeasures [8] and [22] address redundancy. The Consortium encourages TEPCO to provide backup means of cooling, including backup power sources, that can be employed in time to provide adequate cooling should the primary means fail. TEPCO may consider using probabilistic risk assessment to determine countermeasures that provide the greatest risk reduction. c. Factor: Establish a functional and clean water source of sufficient capacity to ensure adequate on-site cooling water. Countermeasure[12] Considerationand implementation of measures to hold down water inflow (e.g. circulating water back into the RPV by storing andprocessing the water in the turbine building) Countermeasure[23]: Add cooling function to normal fuel pool cooling system and continue injecting water for unit F2. Countermeasure[24]: Examination for and implementation of restorationof normal cooling system for units F1, F3, and F4. Factor c. Analysis: Stabilization countermeasures are appropriate for this Factor. However TEPCO should also assess the reliability of the ultimate fresh water source including the delivery system 8

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(water piped from nearby reservoir and the onsite delivery system to the reactors and spent fuel pools). The consortium recommends that TEPCO consider adding a backup means of adding water to the normal fuel pool cooling systems for the 1 F2 spent fuel pool. Restoration of the cooling function of fuel pool cooling system would also increase reliability. The Consortium recommends redundant delivery systems to each of the seven fuel locations requiring emergency cooling. The Consortium acknowledges the need to circulate water back to the RPVs to improve the waste-water generation situation. When recirculation methods are put into place, there will be increased risk of debris in re-circulated water interfering with cooling. TEPCO should address this concern in design of the recirculation systems. A once-through water addition method should still be maintained as a backup. TEPCO should also address the possibility of biological fouling of reactors, spent fuel pools, containments, water recirculation systems, and water delivery systems. d. Factor: Establish the ability to reliably add makeup water to each spent fuel pool and maintain spent fuel pool temperatures less than 100 degrees Celsius Countermeasure[22]: Continue water injection by "Giraffe", etc (reliabilityimprovement (enhanced durabilityof hoses)/switch to remote-controlledoperation.) Factor d. analysis: It is not clear how TEPCO is reliably adding water to the 1F1 spent fuel pool and the basis for concluding that adequate cooling is occurring. It is our understanding that reported temperatures are based on thermography from above, which indicates only the surface temperature of the first obstacle encountered. This would not seem to be a reliable indicator of actual spent fuel pool temperature. Also, the basis for determining how much water is actually being added to the 1F spent fuel pool is unclear, considering the almost complete obstruction by the collapsed roof shown in photographs.

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TEPCO might consider countermeasures to establish reliable temperature indication for the spent fuel pools. Factors used to evaluate Essential Function 2 (Maintain reactors and spent fuel pools sub-critical and adequately shielded) e. Factor: Establish reliable means, either chemical or geometric, to maintain each reactor and spent fuel pool sub-critical. Factor e. analysis: This factor is not satisfied. The TEPCO Roadmap is silent on maintaining the fuel sub-critical Fuel movement or structural degradation may potentially increase reactivity. Actions to further prevent or detect inadvertent criticality would improve confidence that inadvertent criticality will not inhibit recovery actions. TEPCO may consider establishing countermeasures that will assure the fuel in 1 F1, I F2, and 1 F3 reactors is subcritical. The fuel configuration in 1 F1, 1F2, and 1 F3 spent fuel pools has not been verified. One cooling water sample on the 1F4 spent fuel pool indicated that criticality had not occurred in the pool. Additional samples would enhance the validity of this single sample. Visual observations indicate that the fuel is intact in the racks. f. Factor: Establish adequate shielding or zone of protection around reactors and spent fuel pools to allow for safe execution of the Roadmap countermeasures. Factor f. analysis: This factor is not satisfied. The Roadmap considers dose rates at or beyond the site boundary. There is little consideration in the Roadmap for providing shielding to the workers on site. 10

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Factors used to evaluate Essential Function 3 (Ensure structural integrity for all units (e.g. containment and spent fuel pools) g. Factor: Preclude detonation in primary containment atmosphere by establishing a non-combustible atmosphere in the primary containment Countermeasure[15]: Continue prevention of hydrogen explosion by nitrogen injection into the PCV. Factor g. analysis This factor is satisfied for 1F1 and should be continued. This factor is not satisfied for 1 F2 and 1F3. Given that TEPCO has reported that normal injection paths may be unavailable, it becomes necessary to evaluate alternate methods for injecting nitrogen into 1F2 and 1F3 PCVs. When evaluating paths for injecting nitrogen into 1 F2 and 1F3 PCVs, the consortium recommends against considering the RPV water addition flow path for nitrogen injection, as a nitrogen blanket in the RPV would reduce steam cooling of the core material. If nitrogen injection and containment atmospheric sampling are not feasible, verify analytically the steam inerting and/or leakage is sufficient to not have an explosive mixture. h. Factor: Establish reasonable assurance of Reactor Pressure Vessel, Primary Containment, and Spent Fuel Pool integrity Countermeasure[20]: tolerance evaluation is especiallyneeded for F4. A certain level of seismic tolerance has been confirmed. Factor h. analysis

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.Offieal.Use Only - Sensitive Internal Information TEPCO Roadmap structural concerns related to spent fuel pools are primarily focused on the 1 F4 spent fuel pool. However, the structural integrity of reactor building 3 also appears to be degraded from the explosions. Although spent fuel pool 1F4 may have more significant consequences because the full core was offloaded from 1F4, the consortium also encourages TEPCO to assess the structural integrity of the 1F3 spent fuel pool, and confirm the structural integrity of spent fuel pools 1 F1 and 1F2. TEPCO is encouraged to consider adding a corrosion control countermeasures to preserve the integrity of the RPV primary containment, and spent fuel pools. Vessel materials have been exposed to water chemistry that can accelerate stress corrosion cracking (SCC) and general corrosion in the RPV. This is a particular concern for materials and welds in the RPV which are known to be susceptible to failure by SCC. While guillotine fractures due to SCC are not expected if stress levels are low, a circumferential SCC crack could increase susceptibility to failure in a transient or seismic event. The Consortium is not aware of any attempts to characterize or control the chemistry of water injected into the RPV to mitigate corrosion. Actions to characterize the corrosion environment and countermeasures to reduce risk of corrosion failures (e.g., pH adjustment or addition of specific corrosion inhibitors) should be considered. Factor used to evaluate Essential Function 4 (Reliable Indication of essential parameters) L Factor: Establish reliable means to determine key parameters associated with actual or potential large releases
i.

Instrumentation to confirm reactors and spent fuel pools are sub-critical,

ii. Area Radiation, gaseous and liquid release detectors, iii. RPVIDW/SP level, RPV/DW pressure indications, RPV/DW/SP temperatures iv. Spent fuel pool level, temperature indications Countermeasure[57]: Monitoring seawater,soil and atmosphere within the site boundary (25 locations) Countermeasure[58]: Monitoring the radiationdose at site boundary (12 locations)

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Countermeasure[59]: Considerationof monitoringmethods in evacuation order! planned evacuation/ emergency evacuation preparationareas. Countermeasure[60] Considerationand implementation of monitoring methods in evacuationorder/plannedevacuation/emergency evacuationpreparationareas (in cooperation with national/prefectural/municipal governments) Countermeasure[61]: announce accuratelymonitoringresults of long half life residue radioactivematerialssuch as cesium 137 Countermeasure[62]: Monitoring of homecoming residences (in cooperation with national/prefectural/municipal govemments) Countermeasure[63]: Examination and implementation of necessarymeasures to reduce radiationdose (decontaminationof homecoming residences and soil surface) (in cooperation with national/prefectural/municipal governments) Factor i. analysis This factor is not satisfied. The Roadmap places an emphasis on radiation readings off site but little emphasis on determining essential parameters to monitor the state of the reactors and spent fuel pools. TEPCO should evaluate what instrumentation indications are essential to successfully completing stabilizing actions (e.g., SFP level and temperature, RPV/PCV water level, temperature, pressure) and determine what backups or contingency plans are necessary should these indications fail. The Roadmap countermeasures focus on radiation measurement, but do not address instrumentation necessary to take proper plant stabilization actions. Also, the recovery of inoperable installed instrumentation should be sought. Factors used to evaluate Essential Function 5 (Terminate (or render insignificant) uncontrolled radioactive releases)

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j.

Establish the means for containment of significant external leakage (e.g. primary containment leakage) for portions of the plant (SFPs or reactor units) with credible potential for energetic releases of significant quantities of radioactive material. Countermeasure[29]: identify leakage path and examine and implement preventative measures Countermeasure[30]: Transferringaccumulated water to facilities that can store it (condenserand Centralized Waste Treatment Facility) Countermeasure[31]: preparing decontaminationand desalt of transferredaccumulated water Countermeasure[32]: preparing to install tanks Countermeasure[33]: Preparingto store with tanks and barges Countermeasure[34]: Preparingfor decontamination and desalt of contaminated water Countermeasure[35]: Preparingto installreservoir Countermeasure[36]: Preparingto decontaminatesub-drainagewater after being pumped up. Countermeasure[37]: Utilization of "CentralizedWaste Treatment ", to store water Countermeasure[38]: Install water processing facilities; decontaminate and desalt highly contaminatedwater and store in tanks. Risk [7]: Possibility of delay in installing water processing facilities or poor operating performance of the facilities. Countermeasure[39]: Examinationand implementation of backup measures (installment of additionaltanks or pools or leakage prevention by coagulator,etc) 14

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Countermeasure[40]: Increase storage capacityby adding tanks, barges, Megafloat, etc. Countermeasure[41]: Decontaminatingcontaminatedwater using decontaminatesto below acceptable criteria Countermeasure[42]: Expansion of additionaltanks to store high radiationlevel contaminatedwater Countermeasure[43]: Continuation and reinforcement of decontamination and desalt of high radiationlevel water Countermeasure[44]: Continuation and reinforcement of decontamination and desalt of low radiationlevel water. Countermeasure[45]: Reuse of processedwater as reactorcoolant.

Countermeasure[46]: Decontaminationto the level below criterialevel. Factor j. analysis: When put in place these water management countermeasures should satisfy this factor. k. Factor: With regard to activities in close proximity to the site, consider measures to minimize further spread of contamination (e.g., covers or resin spray over significant sources of loose contamination at the plant) Countermeasure[47]: Inhibit scattering of radioactivematerialsby full-scale dispersion inhibitorafter confirming its performance by test. Countermeasure[48]: Prevent rainwatercontaminationby dispersion inhibitor Countermeasure[49]: Removal of debris

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Countermeasure[50]: Examination and implementation of basic design for reactorbuilding cover full fledged measure (containerwith concrete roof and wall, etc.) Countermeasure[51]: Considerationof solidification,substitution and cleansing of contaminatedsoil (mid-term issues) Countermeasure[52]: Improvement of work condition by expandingapplication and dispersionof inhibitorsto the ground and buildings. Countermeasure[53]: Continue removal of debris. Countermeasure[54]: Begin installing reactorbuilding cover (with ventilation and filter) Risk [8]: Considerablereduction in radiationdose is a prerequisiteto launch construction. Countermeasure[55]: Complete installing reactorbuilding covers (Units 1, 3, and 4) Countermeasure[56]: Begin detailed design of full-fledged measure (containerwith concrete roof and wall, etc.) Factor k. analysis: When completed these countermeasures could be effective in satisfying the factor. Organizational Risks and Considerations: Understandably TEPCO did not include organizational risks and considerations in their Roadmap. The Roadmap is primarily a technical document. Nevertheless, the NRC has included suggestions regarding organizational issues that, ifconsidered, may enable more efficient and effective implementation of the Roadmap. These organizational suggestions may also improve the safety of the facility.

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Offtise-Only- Sensitive Internal Information Organizational issues associated with the Roadmap are directly related to safety. Those organizational issues are: 1) ensuring a safety culture is maintained throughout the stabilization and recovery at the site and 2) providing independent oversight. As the site transitions from crisis conditions to stable conditions, it will require a focus on maintaining a safety culture at the site, especially with the influx of a large non-nuclear trained workforce. Minimizing human error is essential for both public safety and the safety of workers at the site. Human conditions for workers are highly important to ensure safe work practices. Human error can be further minimized by the development and use of procedures, by training workers, and practicing work activities on mock ups before the activities are actually carried out in the plants. As Fukushima Daiichi transitions from crisis conditions to stable conditions, providing strong independent oversight is essential. Activities that could affect criticality, emergency response, core conditions, heat removal, radiation exposure, structural stability and other safety elements must be rigorously reviewed through independent oversight that includes written safety evaluations. A special licensing and safety review process will likely be needed. This process may include separation of regulatory activities for Fukushima Daiichi in order to avoid any adverse impacts on operating Japanese reactors. Keeping accurate records of activities will be necessary to help with the ultimate decommissioning of the site. In the long term developing and approving a Safety Analysis Report and technical specifications would be beneficial. TEPCO will need to ensure organizational reliability within their own organization so that there remains a safety focus on Fukushima Daiichi while continuing safe operations of the other Japanese nuclear sites.

The United States Consortium of Industrial and Governmental Organizations was established

to provide advice and assistance to the people of Japan in an effort to stabilize and improve conditions at the Fukushima Daiichi Reactor Site following the earthquake and tsunami on March 11, 2011. The Consortium includes: General Electric Hitachi Institute of Nuclear Power Operations 17

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Officia Use -Only - Sensitive Internal Information Naval Reactors US Department of Energy/Nuclear Energy United States Nuclear Regulatory Commission

To view the TEPCO Roadmap follow the link below: httr:llwww.tepco.co.*ip/en/press/corp-com/release/l 1041707-e.html

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