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3 <br />10. The Harris plant features one pressurized-water reactor (PWR). The core of this <br />reactor contains 157 fuel assemblies, with acenter-center distance of about 8.5 inches. <br />The Harris plant was to have four reactors but only one was built. A fuel handling <br />building was built to serve all four reactors. This building contains four fuel pools (A, B, <br />C, D), a cask loading pool and three fuel transfer canals, all interconnected but separable <br />by gates. Pools A and B contain fuel racks. Pools C and D are flooded but do not <br />contain racks. The cooling and water cleanup systems for pools C and D were never <br />completed. <br />11. Pool A now contains six PWR racks (360 fuel assembly spaces) and three BWR <br />racks (363 spaces), for a total pool capacity of 723 fuel assemblies. Pool B contains <br />twelve PWR racks (768 spaces) and seventeen BWR racks (2,057 spaces), and is licensed <br />to store one additional BWR rack (121 spaces), for a total pool capacity of 2,946 fuel <br />assemblies. Thus, pools A and B now have a combined capacity of 3,669 fuel <br />assemblies. The center-center distance in pools A and B is 10.5 inches for PWR fuel and <br />6.25 inches for BWR fuel. <br />12. Pools A and B store spent fuel from the Harris reactor and from CP&L's Brunswick <br />plant and Robinson plant. The Brunswick plant has two boiling-water reactors (BWRs) <br />while the Robinson plant has one PWR. Shipment of spent fuel from Brunswick and <br />Robinson to Harris is said by CP&L to be necessary to allow core offload capacity in the <br />pools at Brunswick and Robinson. <br />13. CP&L seeks an amendment to its operating license so that it can activate pools C and <br />D at Harris. By activating these pools, CP&L expects to have sufficient spent fuel <br />storage capacity for all four CP&L reactors (Harris, Robinson and the two Brunswick <br />reactors) through the end of their current operating licenses. <br />14. CP&L plans to install racks in pool C in three campaigns (approximately in 2000, <br />2005 and 2014), to create 927 PWR spaces and 2,763 BWR spaces, for a total pool <br />capacity of 3,690 fuel assemblies. Thereafter, CP&L plans to install racks in pool D in <br />two campaigns (approximately in 2016 and at a date to be determined), to create. 1,025 <br />PWR spaces. Thus, the ultimate capacity of pools C and D will be 4,715 fuel assemblies. <br />The center-center distance will be 9.0 inches for PWR fuel and 6.25 inches for BWR fuel. <br />15. The PWR racks in pools C and D have a smaller center-center distance than the racks <br />in pools A and B (9.0 inches instead of 10.5 inches). This arrangement allows more <br />PWR fuel to be placed in a given pool area but also means that PWR fuel in pools C and <br />D is more prone to undergo criticality. In response, CP&L proposes to include in the <br />Technical Specifications for Harris a provision that PWR fuel will not be placed in pools <br />C and D unless it has relatively-low enrichment and high burnup.3 <br />F. Some Technical Safety Issues Raised By the Proposed License Amendment <br />16. CP&L's plan for the activation of pools C and D raises a variety of technical safety <br />issues. This. section of my Declaration describes some of those issues. Later parts of the <br />Declaration relate these issues to the NRC's standard fora "no significant hazards" <br />determination. <br />s License amendment application, Enclosure 5 <br />