Orange County NC Website
02i16i99 09:45 HARMON+CURRAN+SPI -~ 919 644 0246 <br />N0.093 D12 <br />-11- <br />Commissioner Asselstine also pointer out language in the legislative history indicating that <br />Congress did not intend the Sholly amendment to apply to the reracking of spent fuel pools. Id. <br />at 16. <br />Even assuming for purposes of argument that the No Significant Hazards criteria are met, <br />the circumstances of this case raise a number of potentially significant safety issues that should <br />be addressed in a public hearing before the license amendment is issued, including design <br />modifications that would add a significant demand load to safety cooling and electrical backup <br />systems, use of cooling pipe whose quality assurance documentation is missive, the lack of any <br />previous assessment of the impacts of partial drainage of the spent fuel pools vn an extremely <br />urge inventory of spent fuel. <br />,Moreover, there is no particular urgency to this license amendment. The pmposcd <br />changes are to take place over an extended period of time. Even if the changes are perceived by <br />CP&L as ur?ent, they could have been anticipated years before. Under the circumstances, there <br />is no justification for issuing the license amendment before a hearing can be conducted. <br />1V. IF THE STAFF 1SSUES A FINAL DETERMINATION OF NO SIGNIFICANT <br />IiA2ARDS CONSIDERATIONS, IT SHOULD STAY THE EFFECTIVENESS OF <br />THE DETERMINATION FOR TEN DAYS PENDING ORANGE COUNTY'S <br />APPEAL. <br />in the event that the Staff rejects these comments and decides to finalize the proposed No <br />Significant Hazards determination, Orange County requests the Staff to stay the effectiveness of <br />the finding for ten days, in order to maintain the status quo while Orange County prepares an <br />appeal of the determination. Orange County further requests that the Staff respond to this <br />request at least ten days before issuing the license amendment, so that Orange County may be <br />apprised of the aced to take appropriate alternative measures to preserve the status quo. <br />