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02i16i99 09:45 HARMON+CURRAN.SPI ~ 919 644 0246 N0.093 D06 <br />•5• <br />Moreover, activation of pools C and D will add to the electrical load and CCW heat load <br />of existing Harris systems. It will also add to the burden of work on the Harris operators. These <br />effects will increase the probability of two categories of accidents. First, they will significantly <br />increase the probability of accidents associated with the Harris reactor, because the reactor's <br />CCW and electrical systems and iu operators will be under greater stress. Second, they wilt <br />significantly increase the probability of accidents at the Harris pools that aze attributable to <br />interruprions in cooling and electricity supply and to increased operator stress. Thompson <br />Declaration. par. 43. <br />The Staff is also incorrect in stating that the consequences of accidents will not increase. <br />To the extent that severe accidents have been previously evaluated, their consequences will be <br />significantly increased by the activation of pools C and D. The fuel storage capacity of these <br />pools will roughly double the storage capacity at Hants, creating the potential for a doubled <br />inventory of radioactivity. Severe accidents could affect some or all of the Harris pools. Thus, <br />the potential doubling of radioactivity in the pools could signifrcantiy increase the consequences <br />of such accidents. Thompson Declaration, paz. 44. <br />B. The Staff Fails to Show That the Operation of the Facility Ia Accordance <br />Witb the Proposed I.iceast Ameadtpeat Would Not Create the Possibility of <br />a New or Different Kind of Accident From Aay Accident Previously <br />Evaluated. <br />Under its regulations, the NRC may not make a no significant hazard determinations if it <br />finds that a proposed license amendment would create even the possibility of a new or different <br />kind of accident not previously evaluated. The Staffmay not rationalize the amendment by <br />addressing the merits of how likely the accident is to occur. San Luis Obispo Mothers jor Peace <br />v. (~S. NRe, 799 F.2d 1268 (9'~ Cir. 1986). <br />