Self-Powered Decay Heat Removal for Nuclear Spent Fuel Pools

This paper addresses a scenario it terms a Level 5 Blackout: the simultaneous occurrence of a Station Blackout (SBO), Loss of Ultimate Heat Sink (UHS), and catastrophic grid degradation due to HEMP or severe GMD. This compound scenario invalidates the 7-day fuel supply assumptions inherent in current FLEX strategies, the transport infrastructure required for portable equipment, the electronic ignition systems on which portable pumps depend, and the digital logic controllers downstream of any restored power source. The result is an indefinite coping requirement with zero external support. The NRC’s May 2025 denial of PRM-50-96 represents a definitive statement of the current regulatory position. This paper contends that the technical basis for that denial warrants re-examination.