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

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02i16i99 09:45 HARMON+CURRAN+SPI -~ 919 644 0246 N0.093 D07 _6. According to the Federal Register notice, the only kind of accident that might conceivably be considered new is the accidental drop of a fuel rack; but that accident was already considered in relation to pool B. 64 Fed. Reg. at 2?39. Thus, the Staff concludes that the proposed license amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. As discussed in Section J of the Thompson Declaration, this conclusion is incorrect, for several reasons. First, it does not appear that there has been any site-specific evaluation of the probability or consequences of severe accidents at pools A and B at Harris. The NRC has performed evaluations of accidents involving loss of water from fuel pools, generically and for sites other than Hams. However, these evaluations aze seriously deficient because they failed to consider partial uncovering of fuel. See Thompson Declaration, Sections G and H. Thus, at pools A and B there exists the possibility of new or different kinds of accident from any accident previously evaluated. The same possibility will exist at pools C and D if these are activated. Severe accidents at some or all of the Harris pools could lead to offsite radiation exposure an order of magnitude Larger than the exposure from the Chernobyl accident. Second, the addition of pools C and D to the Unit 1 cooling system creates the possibility of a new accident that was not previously considered. As Dr. Thompson poinu out, the IPE and IPEEE studies performed for Harris did not address the provision of backup electrical power and CCW service to pools C and D. As Dr. Thompson points out, the need to provide cooling to pools C and D will place increased stress on the CCW system and backup diesel generators as well as the plant operators during a design basis loss of coolant accident ("LGCA'~, thereby creating the possibility of a new accident.