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8 <br />concentrated almost entirely on a postulated condition of instantaneous, complete loss of <br />water from a pool. Such a condition is unrealistic in any scenario which preserves the <br />configuration of the spent fuel racks. If water is lost by drainage or evaporation and no <br />makeup occurs, then complete loss of water will always be preceded by partial <br />uncovering of the fuel. If makeup is considered, the water level could fall, rise or remain <br />static for long periods. <br />33. Partial uncovering of the fuel will often. be a more severe condition than complete <br />loss of water because, during partial uncovering, convective heat loss is suppressed by the <br />residual water at the base of the fuel assemblies. As a result, longer-discharged fuel with <br />a lower heat output may undergo a runaway steam-zirconium reaction during partial <br />uncovering while it would not undergo a runaway air-zirconium reaction if the pool were <br />instantaneously emptied. <br />34. I am aware of only one instance in which reports produced by or for the NRC address <br />the hazard posed by partial uncovering, namely in a report prepared for the NRC by <br />Sandia Laboratories and published in 1979.23 Part of this report did address a situation of <br />partial uncovering, but used a crude heat transfer model and neglected to consider the <br />onset of asteam-zirconium reaction. Nevertheless, the report found (page 76) that <br />"......an incomplete drainage can potentially cause a more severe heatup problem than a <br />complete drainage, if the residual water remains near-the baseplates". A portion of the <br />1979 Sandia report is provided here as Attachment E. An internal NRC memo mentions <br />the consideration of partial uncovering in the 1979 Sandia report.24. Otherwise, it appears <br />that the NRC has ignored the hazard posed by partial uncovering. This hazard was not <br />reflected in the regulatory analysis whereby the NRC purportedly resolved Generic Issue <br />82.25 <br />35. In a situation of falling water level, a fuel assembly might first undergo a runaway <br />steam-zirconium reaction, then switch to anair-zirconium reaction as water falls below <br />the base of the rack and convective air flow is established. In this manner, a runaway alr- <br />zirconium reaction could occur in a fuel assembly that is too long-discharged (and <br />therefore produces too little heat) to suffer such a reaction in the event of instantaneous, <br />complete loss of water. Conversely, a rising water level could precipitate a runaway <br />steam-zirconium reaction in a fuel assembly that had previously been completely <br />uncovered but had not necessarily suffered a runaway air-zirconium reaction while in that <br />condition. The latter point is highly significant in the context of emergency measures to <br />recover control of a pool which has experienced water loss. Inappropriate addition of <br />water to a pool could exacerbate the accident. <br />36. The NRC's failure to consider partial uncovering of fuel should be borne in mind <br />when one reviews NRC-sponsored reports that purport to address the hazard posed by <br />water loss from a fuel pool. This hazard should be re-analyzed through detailed <br />J Travis et al, A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown <br />Nuclear Power Plants, NUREG/CR-6451, August 1997. ~ <br />23 Allan S Benjamin et al, Spent Fuel Heatup Following Loss of Water During Storage, NUREG/CR-0649, <br />March 1979. ~ <br />24 Internal NRC Memorandum from J T Han to M Silberberg, "Response to a NRR request to review SNL <br />studies regarding spent fuel heatup and burning following loss of water in storage pool", 21 May 1984. ~ <br />25 E D Throm, op cit <br />