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02i16i99 09:45 HARh~N+CURRAN+SPI ~ 919 644 0246 N0.093 D09 <br />-g- <br />1S 1SSlied. <br />The margin of safety is also affected by CPBtL's proposal to provide electrical service to <br />pools C and D from the existing Unit 1 system. which includes the Unit 1 dedicated emergency <br />diesel generators. These diesel generators already serve the safety systems in Unit 1 and spent. <br />fuel storage pools A and B. By adding pools C and D to the load carried by the Unit 1 diesel <br />generators, CP&L would add stress on the diesel generators and on the plant operators in the <br />event of a-loss of offsite power. These effects could significantly reduce the margin of safety at <br />the Hams reactor and the fuel pools. <br />iI. THE PROPOSED NO SIGNIFICANT HAZARDS FINDING FaiLS TO MEET <br />THE NRC'S STAND 4RD FOR AN EXEMPTION FROM THE PROCEDURAL <br />REQUIREMENTS OF NEPA. <br />The Federal Register notice makes no mention of NEPA or its requirements to issue an <br />EIS or EA in support a proposed federal action that may significantly affect the quality of the <br />human environment. Presumably, the Staff bclicves that it is exempt from the requirement to <br />prepare an EIS or EA under 10 C.F.R. § 51.?2(c)(9)(i). This provision allows the NRC to forego <br />preparation of an EIS or EA "with respect to installation or use of a facility component located <br />within the restricted area, es defined in part 20" of NRC regulations, if, inter alfa, the amendment <br />"involves no significant hazards consideration." <br />As demonstrated in Dr. Thompson's Declaration, the proposed amendment fails to satisfy <br />any of the criteria for a finding of No Significant Hazards considerations. Therefore. the NRC <br />Staff en ed in relying on the exemption. <br />Moreover, an EIS or EA must be prepared because the proposed license amendment <br />entails more than redesigning the Hams plant and installing and activitating a spent fuel coaling <br />