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02i16i99 09:45 HARMON+CURRAN+SPI ~ 919 644 0246 N0.093 D08 <br />.~. <br />C. The Staff Fails to Show Tbat the Operation of the Facility In Accordance <br />With the Proposed License Amendment Would Not Il4volve a Significant <br />Redncdon in a Margin of Saf€ty. <br />The Staff s conclusion that the operation under the license amendmcnt would not involve <br />a reduction in a safety margin is without merit. The information provided in the license <br />amendment application clearly demonstrates that the plant's safety margin would be significantly <br />reduced by the proposed license amendment, As discussed in the Thompson Declaration, <br />Section I, activation of pools C and D will create an additional heat load on the existing CCW <br />system. CP&L proposes to meet this load in the short term by exploiting the margin in the CCW <br />system. The safety margin will be reduced even further if, during a LOCH, the operators must <br />divert water from the RHR to the spent fuel pools. This will increase stress on the operators and <br />create opportunities for human error. Thus, the reduction in the CCW safety margin caused by <br />the increased heat load is significant. Certainly, the NRC has provided na reason to conclude <br />that it is not sigttificant.3 <br />The Staff fails to address the impact on the margin of safety caused by CP&L's proposal <br />to use a cooling system for pools C and D using piping that will not satisfy ASME code <br />requirements. See Thompson Declaration, pars. 23 and S0. As Dr. Thompson observes, this <br />action could potentially cause a significant reduction in mazgins of safety for pool coaling. <br />CP&L's alternative analysis has not been subjected to any public scrutiny or rigorous review. It <br />deserves, at the least, thorough consideration at a licensing hearing before the license amendment <br />3 Moreover, as pools C and D become filled and the reactor receives a power <br />uprate, the load on the CCW system will increase further. CP&L offer no assurance that the <br />present margin of safety will be restored by upgrading the CCW system to accommodate these <br />burdens. <br />