Outline of the Fukushima Daiichi Accident. Lessons Learned and Safety Enhancements

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EPJ Web of Conferences 153, 08001 (2017) DOI: 10.1051/ epjconf/201715308001 ICRS-13 & RPSD-2016 Outline of the Fukushima Daiichi Accident. Lessons Learned and Safety Enhancements Masashi Hirano * Nuclear Regulation Authority, Japan Abstract. On March 11, 2011, an earthquake and subsequent tsunamis off the Pacific coastline of Japan s Tohoku region caused widespread devastation in Japan. As of June 10, 2016, it is reported that a total of 15,894 people lost their lives and 2,558 people are still unaccounted for. In Fukushima Prefecture, approximately 100,000 people are still obliged to live away from their homes due to the earthquake and tsunami as well as the Fukushima Daiichi accident. On the day, the earthquake and tsunami caused severe damages to the Tokyo Electric Power Company (TEPCO) s Fukushima Daiichi Nuclear Power Station (NPS). All the units in operation, namely Units 1 to 3, were automatically shut down on seismic reactor protection system trips but the earthquake led to the loss of all off-site electrical power supplies to that site. The subsequent tsunami inundated the site up to 4 to 5 m above its ground level and caused, in the end, the loss of core cooling function in Units 1 to 3, resulting in severe core damages and containment vessel failures in these three units. Hydrogen was released from the containment vessels, leading to explosions in the reactor buildings of Units 1, 3 and 4. Radioactive materials were released to the atmosphere and were deposited on the land and in the ocean. One of the most important lessons learned is an importance to prevent such large scale common cause failures due to extreme natural events. This leads to a conclusion that application of the defense-in-depth philosophy be enhanced because the defense-in-depth philosophy has been and continues to be an effective way to account for uncertainties associated with risks. From the human and organizational viewpoints, the final report from the Investigation Committee of the Government pointed out so-called safety myth that existed among nuclear operators including TEPCO as well as the government, that serious severe accidents could never occur in nuclear power plants in Japan. After the accident, the Nuclear Regulation Authority (NRA) was established on September 19, 2012. The NRA very urgently developed and issued the new regulatory requirements on July 8, 2014, taking into the account the lessons learned from the accident. It is noted that the NRA issued the Statement of Nuclear Safety Culture on May 27, 2015 which clearly expressed the NRA s commitment to break with the safety myth. This paper briefly presents the outline of the Fukushima Daiichi accident and summarizes the major lessons learned having been drawn and safety enhancements having been done in Japan for the purpose of giving inputs to the discussions to be taken place in the Special Invited Session Fukushima, 5 years after. * Corresponding author : masashi.hirano@nsr.go.jp The Authors, published by EDP Sciences. This is an open access article distributed under the terms of the Creative Commons Attribution License 4.0 (http://creativecommons.org/licenses/by/4.0/).

0 Fukushima Special Session "Fukushima, 5 years after" Outline of the Fukushima Daiichi Accident, Lessons Learned and Safety Enhancements Masashi HIRANO and Harutaka HOSHI Nuclear Regulation Authority (NRA) The joint conference of the 13 th Int. Conf. on Radiation Shielding (ICRS-13), and 19 th Topical Meeting of the Radiation Protection and Shielding Division of ANS - 2016 (RPSD-2016) October 3-6, 2016, Paris, France

Contents 1 Introduction Current Status of Nuclear Regulation in Japan Outline of the Accident Earthquake and Tsunami Accident Progression Source Term Evaluation Lessons Learned Safety Enhancements Creation of NRA New Regulatory Requirements Summary

Current Status of Nuclear Regulation in Japan 2 NRA was established in Sep. 2012 and developed the new regulatory requirements for NPPs which came into force in July 2013. All the 48 units had been shut down since Sep. 2013. So far, a total of 26 units (17 PWRs and 9 BWRs) have applied for conformance review. In Sep. 2014, NRA first approved the applications from Sendai Units 1 and 2. As of Aug. 2016, NRA has granted permission to 7 PWRs of which four units have restarted (Sendai Units 1,2 and Takahama Units 3, 4) The IAEA IRRS mission s review was taken place in Jan. 2016. Y. Shimizu, IAEA Effective Nuclear Regulatory Systems (April 2016)

Outline of the Accident 3

North America Plate Tohoku-District off the Pacific Ocean Earthquake Occurred at 14:46 on March 11, 2011 9.0 Mw: largest ever recorded in Japan Rupture duration: 170 sec Epicenter: 38 o 10 N and 142 o 86 E, 23.7km in depth Reverse fault type near the Japan Trench Source area of the earthquake Japan Trench 4 Onagawa NPS Fukushima- Daiichi and Daiichi Daini NPS NPS Tokai Daini NPS Pacific Plate Edited to figure in 1 st Government Report (June) 2011) Observed max. acceleration of seismic ground motion at Fukushima-Daiichi exceeded that of the design basis by 26%.

Accompanied Tsunami 5 A huge tsunami was generated due to a large slip, more than 56m, near the Japan Trench. Estimated slip distribution GSI Japan (2011) Seismic gap area Sugino, et al., NRA, 24 Feb, 2016 100m 20m Inundation height 33 20 10 0 Multi-segment rupture including seismic gap area (no seismic record) Strain accumulated Recoil generateed tsunami Tokai Daini NPP tsunami Epicenter Fukushima Daini NPP Onagawa NPP Fukushima Daiichi NPP Higashidori NPP IAEA Fukushima report, Technical Volume 1/5 (2015) Due to rupture of the bonded interface, the North America Plate recoiled and the strain energy was released, which generated the huge tsunami.

Consequences of Natural Hazards and the Accident Casualties due to earthquake/tsunami (as of Dec.1, 2011) Deceased: 15,840 Injured: 5,951 Unaccounted for: 3,547 Damaged buildings: 1,009,074 As of June 2016, the number of evacuees has been reduced from 470,000 to 155,000. Still 51,000 people live in temporary housing. In Fukushima Prefecture, approx. 100,000 people are still obliged to live away from their homes due to the earthquake/tsunami as well as the Fukushima Daiichi accident. (website of the Fukushima Prefecture) Evacuation order: (1) Return is difficult (red), (2) Habitation is restricted (yellow), (3) Preparing for lifting orders (Green) Yellow and Green areas will be lifted no later than March 2017. Interim Report from Government s Investigation Committee (Dec. 2011) Current Status of Reconstruction and Challenges, June 2016, Reconstruction Agency 6

Tsunami Heights at four Different Sites Onagawa: Not flooded Site level Seawater pump Actual height of tsunami Assumed height of tsunami 7 (unit: m) Onagawa Epicenter Fukushima Daiichi: Flooded destructively Fukushima Dai-ichi Fukushima Dai-ni Tokai Dai-ni Fukushima Daini: Seawater pumps were flooded. Buildings were damaged slightly. Seawall height: 10 m Seawall (height: 10m) Tokai Daini: Seawall Seawater pumps were not flooded due to breakwater wall. Tsunami at Fukushima Daiiichi NPS Yasui, METI, Causes and Countermeasures, March, 2012.

Loss of Offsite Power by Earthquake and Common-Cause Failures by Tsunami Units 1 to 3 automatically scrammed on seismic reactor protection trips. The earthquake led to loss of offsite power. All the emergency diesel generators (EDGs) automatically started. Then, about 40 min. later, the tsunami arrived at the site. In Units 1 to 4, all the EDGs became inoperable (SBO) together with loss of DC power.* It also caused 1 Loss of offsite power due to the earthquake LUHS as well. In Unites 5 and 6, an air-cooled EDG of Unit 6 survived and it supplied AC Run-up: Tsunami attack ~5 m power to both units. *DC power was available in Unit 3. Seawater pumps for residual heat removal became inoperable Loss of Ultimate Heat Sink (LUHS) Seawater level Seawater level Seawater Pump Elevation: about 10m Turbine Building EDGs D/G ground level: ~ 10m Reactor Building Grid Line 8 EDGs became inoperable due to Tsunami Station Black Out (SBO)

Unit 1 Unit 2 Unit 3 ICs (Isolation Condensers) operated manually Major Chronology of Events 14:46 on Mar. 11: Shutdown due to earthquake LOOP: Loss of off-site power Loss of AC and DC power RCIC (Reactor Core Isolation Cooling System) started manually EDGs started automatically 15:27 on Mar. 11: Tsunami arrived Source: IAEA DG Report and Technical Volumes 1 (2015): RCIC started manually Loss of AC power (DC power available) 9 ICs and HPCI were not operable March 12 PCV venting at about 14:30 Hydrogen explosion at 15:36 Seawater injection at 19:04 RCIC operated for about 70 hours without DC power March 14 RCIC stopped until ~12: 30 Operators opened SRV at 18:02 Seawater injection at 19:54 March 15 Possible PCV failure March 12 RCIC stopped (11:36) and HPCI started (12:35) March 13 HPCI was shut down remotemanually from MCR at 2:42 SRVs opened at 9:08 (ADS conditions met). Fresh water injection at 9:25 March 14 Hydrogen explosion at 11:01

Hydrogen Explosion at Units 1, 3 Hydrogen leaked from RPV to PCV and then to the RB, and exploded there. Analyses were done by the former JNES with FLUENT and AUTODYN. It was assumed that hydrogen leaked at: Top flange gasket at Unit 1 Sealing of hatch or penetrations at 1 st floor at Unit 3 Unit 1 Ignition point Unit 3 10 Browns Ferry -1 under construction https://en.wikipedia.org/wiki/file:browns_ferry_un it_1_under_construction.jpg Pressure (t = 20 ms) Pressure (t = 300 ms) Ignition point

Hydrogen Explosion at Unit 4 11 Hydrogen generated at Unit 3 might have been transported to Unit 4 through SGTS piping and exhaust ducts. The exhaust stack was shared. The valves of unit4 SGTS were open. Reactor Building of Unit 4 stack Unit 4 Unit 3 Analysis done by former JNES WWW.nsr.go.jp/archive/jnes/content/000125907.pdf 5F 4F 3F 2F 1F 4 th floor east exhaust duct SGTS SGTS 4 th floor west exhaust duct Stack stack from Unit 3 Source: Added to The impact of Tohoku-Chihou Taiheiyo-Oki Earthquake to Nuclear Reactor Facilities at Fukushima Daiichi Nuclear Power Station (Sep. 9, 2011, revised Sept. 28, 2011, Tokyo Electric Power Co., Inc.) Unit 3 Unit 4 Reverse flow SGTS: Stand-by Gas Treatment System Unit 4 2 nd Government Report Stack Unit 3

End States of Units 1 to 3: OECD/NEA BSAF Project Phase I OECD/NEA CSNI launched the BSAF (Benchmark Study of the Accident at the Fukushima Daiichi NPP) Project in Nov. 2012. 16 organizations from 8 countries (France, Germany, Korea, Russia, Spain, Switzerland, the United States, and Japan) participated. Phase I Summary Report (March 2015) Qualitative description of the plausible end states after comparison of the best estimate case analyses Unit 1 Unit 2 Unit 3 12 RPV failure Every calculation predicted that extensive damage occurred. No RPV failure The majority of calculations do not predict RPV failure Split into two groups: a) No RPV failure b) RPV failure and temporary MCCI scenario

Source Term Evaluation 13 The IAEA collected / compared the source terms evaluated by various organizations with different methods and assumptions. Technical Volume 1 of the IAEA Fukushima report: The total amount of aerosol based fission product releases from all of the Fukushima Daiichi units was about one order of magnitude smaller than that from the Chernobyl accident. 137 Cs releases (PBq) Chernobyl accident Evaluated with MELCOR by former JNES: 7.3 13 PBq (Forward estimates) IAEA Fukushima report, Technical Volume 1/5 (2015) Publication [14]: HOSHI, H., HIRANO, M., Severe Accident Analyses of Fukushima - Daiichi Units 1 to 3, Side event by Government of Japan at 56 th IAEA General Conference, Vienna, 2012, JNES (2012), Publication FIG. 1.4 4. Estimated atmospheric releases of 137Cs

SA Progression and Source Terms The former JNES has conducted a SA progression analysis with MELCOR developed by U.S.NRC. The NRA continues to do it. Release timings are in good agreement with the monitoring data. The largest peak in the morning on March 15 was probably caused by PCV failure at Unit 2 Hirano, Hoshi and Homma, Presented at U.S.NRC RIC, March 2013. Mar. 12 0.00 Comparison between the source terms by MELCOR and monitoring data 1st Vent (Unit 1) Mar. 16 0.00 Mar. 13 0.00 Mar. 14 0.00 Monitoring data at Main Gate Mar. 15 0.00 14 Mar. 16 0.00 Mar. 12 0.00 Unit 2 Mar. 13 0.00 RPV and CV pressure transients at Unit 2 Plant Records Heat removal from S/P suppressed D/W pressure MELCOR MELCOR D/W Mar. 14 0.00 RPV PCV leakage assumed Plant records Mar. 15 0.00 PCV leakage assumed Thermal stratification of S/P ( subcooled water remained) suppressed D/W pressure PCV leakage (Unit 1) 2nd Vent (Unit 1) Unit 1 Vent (Unit 3) From Unit 2 MELCOR Unit 3 Unit 2

Environmental Consequence Analysis Unit 1 Unit Unit 2 2 Unit 3 Hirano, Hoshi and Homma, Presented at U.S.NRC RIC, March 2013. By using the source terms with MELCOR, an environmental consequence analysis was done in JAEA with OSCAAR developed there. Total sum Total Total Cs-137 Concentration measured by MEXT (Nov. 5, 2011) 15 Major findings: The release from Unit 2 on March 15 had dominant contribution to the inland contamination. The release from Units 1 and 3 mostly spread to the ocean. Sum of the release well reproduced the characteristics of the measured distribution of contamination. (Bq/m 2 )

Wind was whirling clockwise on March 15, 2011. Ref.: Hirano, Presented at IAEA IEM9, 20 24 April 2015 During the accident, the SPEEDI simulation had been done every hour assuming a unit release (1 Bq/hour) since the source terms were not available. The results were equivalent to the meteorological data. 16 9:00 10:00 11:00 12:00 13:00 14:00 SPEEDI calculations Mar. 15, 2011 15:00 16:00 17:00 18:00 Source: M. Chino, JAEA, May 2013 Precipitation (Rainfall) 6:00 15:00 15:00 21:00 Final Report from Government s Investigation Committee (July 2012) http://www.aec.go.jp/jicst/nc/iinkai/teirei/siryo2013/siryo18/siryo1.pdf

Some Lessons Learned 17

Lack of Defense-in-Depth against external hazards 18 Large scale common cause failures (CCFs) by external hazards should have been prevented/mitigated. We should have been prepared for Low frequency, high consequence events beyond design basis. Actually, the Defense-in-Depth (DiD) had not been taken into consideration for external events. Watertight doors were not implemented, Seawater pumps were not protected. AM measures were not effective, Training / drills assuming external events had not been conducted. DiD has been and will continue to be an effective way to account for uncertainties. Effective independence between different layers of defense More diversity and independence rather than redundancy

Tsunami risk had been recognized : Lack of Agility The Seismic Design Review Guide was revised in 2006 and a requirement was newly introduced against tsunami. So-called backcheck was in progress, but its progress was very slow. Uncertainty allows for wishful thinking + Safety myth Lack of agility, lack of safety culture Diet Report Diet`s Report: NAIIC : The National Diet s Fukushima Nuclear Accident Independent Investigation Commission, Reported to the Diet in July 2012 As the regulatory agency was aware of TEPCO s delaying of countermeasures, but did not follow up with any specific instructions. Nor did they properly supervise the back-check progress. When new findings indicate the possibility of a tsunami exceeding previous assumptions, the operator is required to quickly implement countermeasures, rather than taking time to clarify the scientific basis for that possibility through studies of sediment... 19

TEPCP s Trial Calculations of Tsunami New findings / minor opinion In 2002, HERP* pointed out the possibility of a tsunami earthquake occurring anywhere along the Japan Trench including the gap area could not be ruled out. In 2008, TEPCO did hypothetical calculation assuming a M 8.2 earthquake occurring off the coast of Fukushima Pref. Max. ~15.7 m TEPCO also conducted a Jogan (869)-type tsunami simulation Max. ~9.2 m IAEA Fukushima report, Technical Volume 2/5 (2015) Seismicity Gap Area (no record of large earthquake): Major opinion: Majority of scientists believed the shallow plate boundary along the Japan trench was not able to store a large amount of strain (coupling is weak). *Headquarters for Earthquake Research Promotion However, TEPCO decided only on a plan to ask JSCE* for investigation such as tsunami deposit survey, rather than take any immediate measures. *JSCE : Japan Society of Civil Engineers 20

Regulatory Aspects: Regulatory Capture Pointed out in the Diet s Report 21 Diet s Report (July 2012) Message from Chairman this was a disaster Made in Japan. Its fundamental causes are to be found in the Japanese culture: our reflexive obedience; our reluctance to question authority; and our insularity. Organizational issues actual relationship lacked independence and transparency, In fact, it was a typical example of regulatory capture, Lack of expertise the two incorporated technical agencies advising NISA, namely, JNES and JAEA, have been too rigidly tied to NISA. Conclusions The lack of expertise resulted in regulatory capture, They avoided their direct responsibilities by letting operators apply regulations on a voluntary basis.

Human / Organizational Aspects: Myth of Safety Pointed Out in the Government s Report Myth of Safety Final Report from Government s Investigation Committee (July 2012) a fundamental problem of the inability to capture such crises as a reality that could happen in our lives; this, in turn, is the result of a myth of safety that existed among nuclear operators including TEPCO as well as the government, that serious severe accidents could never occur in NPPs in Japan. Basic Assumption in the IAEA DG Report Because of the basic assumption that NPPs in Japan were safe, there was a tendency for organizations and their staff not to challenge the level of safety. The reinforced basic assumption among the stakeholders about the robustness of the technical design of NPPs resulted in a situation where safety improvements were not introduced promptly. 22

Complacency together with Bureaucracy allowed Safety myth to prevail, having let Continuous improvement cease. 23 Cognitive bias Safety myth prevailed Institutional failures Bureaucracy Lack of independence Complacency Isolation Continuous improvement ceased Lack of agility Missed the chances T. Fuketa, OECD/NEA Safety Culture Workshop (June 2015) Discount the future Sending later Collapse

Safety Enhancements 24

NRA: Nuclear Regulation Authority Established in Sept. 2012 Independence Nuclear regulation and nuclear promotion were clearly separated, and the NRA was established as an independent commission body defined by law* affiliated with MOE (Minister of Environment). * a council-system organization based on Article 3 of the National Government Organization Act, ensuring its independence without any control or supervision by other organizations. Integrated Nuclear regulation functions regarding safety, security, safeguards, radiation monitoring and radioisotopes were integrated into the NRA. T. Fuketa, NRA, presented at U.S.NRC RIC2013, March 13, 2013: http://www.nsr.go.jp/data/000067048.pdf NRA Integrated and Independent AEC : Atomic Energy Commission METI : Ministry of Economy, Trade and Industry MEXT : Ministry of Education, Culture, Sports, Science and Technology MOE : Ministry of the Environment NISA : Nuclear and Industrial Safety Agency (abolished) NSC : Nuclear Safety Commission (abolished) 25

New Regulatory Requirements: Structure http://www.nsr.go.jp/data/000067048.pdf 26 Requirements for B-DBA DEC: Design extension conditions defined in IAEA SSR-2/1 <Pre-existed> Natural phenomena Fire Reliability Reliability of power supply Ultimate heat sink Function of other SCCs Seismic/Tsunami resistance 4 th Layer of DiD 3 rd Layer of DiD <New> Suppression of radioactive materials dispersal Specialized Safety Facility Prevention of CV failure Prevention of core damage Natural phenomena Fire Reliability Reliability of power supply Ultimate heat sink Function of other SCCs Seismic/Tsunami resistance (Severe Accident Measures) NEW Reinforced Reinforced

More Stringent Standards on Tsunami Enlarged Application of Higher Seismic Resistance New Regulatory Requirements: Enhanced Measures against Tsunami It is required to define design basis tsunami that exceeds the largest in the historical records and to take protective measures such as breakwater wall based on it. SSCs for tsunami protective measures are classified as Class S equivalent to RPV etc. of seismic design importance classification. Example of protective measures against tsunami (multiple measures) Breakwater wall for prevention of inundation to the site Tsunami gate for prevention of water penetration into the building 27 http://www.nsr.go.jp/data/000067048.pdf

Mountain side New Regulatory Requirements: Measures against Intentional Aircraft Crash, etc. http://www.nsr.go.jp/data/000067048.pdf Specialized Safety Facility 28 Specialized Safety Facility is required to mitigate release of radioactive materials after core damage due to intentional aircraft crash. Emergency control room Power supply CV spray pump CV spray CV Reactor building Filtered venting Water source Molten core cooling pump Water injection into reactor Core sea For example, 100 m * System configuration is an example. Water injection into lower part of CV 28 For BWR, one filtered venting for prevention of containment failure and another filtered venting of Specialized Safety Facility are acceptable solution. Filter

NRA s Statement of Nuclear Safety Culture Issued on May 27, 2015 29 NRA s Mission Statements The NRA s Core Values and Principles T. Fuketa, OECD/NEA Safety Culture Workshop (June 2015) The Statement of Nuclear Safety Culture The Code of Conduct on Nuclear Security Eight Traits of Nuclear Safety Culture in NRA s Statement 1. Priority to Safety Break with safety myth 2. Decision-making prioritized by safety 3. Fostering, sustaining and strengthening safety culture 4. Learning organization Seek out opportunities for improvement 5. Communication Get rid of isolation / self-righteousness 6. Questioning attitude Avoid complacency 7. Rigorous and prudent judgment and action with agility 8. Harmonization with nuclear security

Summary 30 One of the most important lessons learned is Lack of Defense-in-Depth against external hazards. We need to continuously enhance DiD since DiD has been and will continue to be an effective way to account for uncertainties. We need to keep reminding that Complacency together with Bureaucracy allowed Safety myth to prevail, having let Continuous improvement cease. Commissioner Fuketa of NRA stated in the OECD/NEA SC Workshop*: We, however, acknowledge we are oblivious. Numerous sprouts of safety myth reappear already. We must incorporate lessons-learned into the institutional memory of the NRA. We must create an environment where a gene letting us think safety first can survive. * T. Fuketa, OECD/NEA Safety Culture Workshop (June 2015)

References 31 1 st Government Report (June 2011): Report of the Japanese Government to the IAEA Ministerial Conference on Nuclear Safety, Nuclear Emergency Response Headquarters, Government of Japan, June 2011 2 nd Government Report (September 2011): Additional Report of the Japanese Government to the IAEA (Second Report), Nuclear Emergency Response Headquarters, Government of Japan, September 2011 Diet s Report (July 2012): The Official Report of the Fukushima Nuclear Accident Independent Investigation Commission (NAIIC), the National Diet of Japan, 2012 Interim Report from Government s Investigation Committee (Dec. 2011): Interim Report, Investigation Committee on the Accident at Fukushima NPS of TEPCO, Dec. 26, 2011 Final Report from Government s Investigation Committee (July 2012): Final report, Investigation Committee on the Accident at Fukushima NPS of TEPCO, July 23, 2012 IAEA DG Report and Technical Volumes 1 to 5 (2015): The Fukushima Daiichi Accident, Report by the Director General and Technical Volumes 1 to 5 (2015) T. Fuketa, OECD/NEA Safety Culture Workshop (June 2015): OECD NEA/CNRA/ CSNI/CRPPH Joint Workshop on Challenges and Enhancements to Safety Culture of the Regulatory Body, Paris, June 3, 2015 Y. Shimizu, IAEA Effective Nuclear Regulatory Systems (April 2016): Y. Shimizu, Lessons Learned from the Fukushima Daiichi Accident, Actions Taken and Challenges Ahead, presented at IAEA International Conference on Effective Nuclear Regulatory Systems, Vienna, Austria, April 11-15, 2016

Appendix Key: It was difficult to open Air-Operated Valves (AOVs) For seawater injection by fire engines, it was necessary to depressurize RPV by opening SRVs. It was needed to open AOVs in the venting system to prevent PCV failure. AOVs need: DC power to open the pilot valve (solenoid valve) Car batteries Compressed air Mobile compressor, nitrogen gas cylinders Mobile compressors Nitrogen gas cylinders Instrument Air (IA) system Car battery Venting System Rupture Disk To Stack MOV AOV Solenoid valve Water injection Safety Relief Valve (SRV) 32 Primary Containment Vessel (PCV) Reactor Pressure Vessel (RPV) Steam To turbine Dry Well (D/W) Sub-cooled water https://upload.wikimedia.org/wikipedia/commons/2/25/mark_i_ Containment.jpg Suppression Pool(S/C) or Wet Well (W/W)

Appendix Example of Use of Mobile Equipment: Measures against Station Blackout (SBO) 33 Install both mobile alternate power sources (power vehicle, batteries, etc.) and permanent alternate AC power sources. Batteries for 8 hours without load shedding + 16 hours with load shedding Alternate onsite AC power supply for 7 days External support from offsite by the 6th day Alternative MC, PC, MCC It is also required to install the third station battery system. Alternative onsite AC power (Power Vehicle)