Agenda - 02-16-1999 - 3 - Laserfiche WebLink

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02i16i99 09:45 HARMON.CURRAN.5P1 ~ 919 644 0246 N0.093 D05 -4- "no significant hazards considerations: ' The NRC standard for making a No Significant Hazards determination is found in l0 C.F.R. § 50.92, which provides that the NRC may make find that a license amendment poses no significant hazards considerations if it would not: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. As discussed in the attached Declaration of Dr. Gordon Thompson, none. of these criteria is satisfied by the proposed license amendment. A. Tate Staff Fails to Show That the Operation of the Facility In Accordance With the Proposed License Amendment Would Not Involve a Significant lacrense ie the Probability or Consequences of an Accident Prtvionsly Evaluated. In the Federal Register notice, the Staff concludes that operation of the Harris facility in accordance with the proposed license amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated. As discussed in the Thompson Declaration, this claim is false, for several reasons. Activation of pools C and D will roughly double the total number of fuel handling operations to be conducted at Hams. Assuming that the general nature of fuel handling operations continues as before, the probability of a fuel assembly drop or misloaded fuel assembly, integrated over the entire period of the Harris operating license, will increase significantly, by a factor of two. If probability is integrated over the remaining period of the Harris operating license, rather than over its total duration, then activation of pools C and D will more than double the probability of a fuel assembly drop or a misloaded fuel assembly. The probability of a criticality accident will also be more than doubled, and the consequences of a criticality accident may also be significantly increased. Thompson Declaration, par. 42.