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4 <br />17. NRC regulations require that spent fuel storage pools must be cooled by safety grade <br />cooling systems. When the Harris plant was designed, the intention was that pools C and <br />D would be cooled by the component cooling water (CCW) system for the second unit of <br />the Harris plant a That unit was never built, and therefore the Unit 2 CCW system does <br />not exist. In the absence of a second CCW system, CP&L plans to cool pools C and D <br />by connecting their cooling systems to the CCW system of the first unit. This system <br />already provides cooling to pools A and B and serves other, important safety functions. <br />Attachment B provides supporting information.5 It should be noted that CP&L <br />considered, but has not pursued, the option of cooling pools C and D by a new, <br />independent system that could have had dedicated emergency diesel generators. <br />Attachment C provides information in support of this point.6 Three significant safety <br />issues are raised by the fact that the spent fuel pool cooling arrangement originally <br />designed for pools C and D of the Harris plant was not completed. These issues relate to <br />the heat loading of the existing CCW system, the load on the existing emergency diesel <br />generators, and the loss of some important quality assurance documentation for cooling <br />piping at pools C and D. <br />18. Heat load. According to CP&L's license amendment application, the bounding heat <br />load from. the fuel in pools C and D will be 15.6 million BTU/hour:~ At present, the <br />CCW system cannot absorb this additional heat load. Thus, CP&L proposes to include in <br />the Technical Specifications for Harris an interim provision that the heat load in pools C <br />and D will not be allowed to exceed 1.0 million BTU/hour.8 CP&L claims that an <br />additional heat load of 1.0 million BTU/hour can be accommodated by the existing CCW <br />system, and that the fuel to be placed in pools C and D will not create a heat load <br />exceeding 1.0 million BTU/hour through 2001. <br />19. Apparently, CP&L contemplates a future upgrade of the CCW system, so that the <br />CCW system can accommodate an additional heat load of 15:6 million BTU/hour from <br />pools C and D. This contemplated upgrade is not described in the present license <br />amendment application. Attachment C indicates that CP&L plans to perform the upgrade <br />of the CCW system concurrent with a power uprate for the Hams reactor. Apparently, a <br />4.5 percent power uprate will be associated with steam generator replacement, and there <br />will be a subsequent further power uprate of 1.5 percent. A chart in Attachment C shows <br />that the projected CCW heat load, including the reactor power uprate and the use of pools. <br />C and D, will substantially exceed the capability of the present CCW system. <br />20. To summarize, CP&L's short-term plan (through 2001) for cooling pools C and D is <br />to exploit the margin in the existing CCW system, so as to accommodate an additional <br />heat load of 1.0 million BTU/hour. CP&L's longer-term plan is to upgrade the CCW <br />4 The Harris pools have their own closed-circuit cooling systems, which can transfer heat to the relevant <br />CCW system through heat exchangers. <br />5 Attachment B is a portion of a set of viewgraphs (titled "Harris Spent Fuel Pool 'C' and 'D' Activation") <br />shown by CP&L representatives during a meeting with NRC staff on 16 July 1998. ~ <br />6 Attachment C is an NRC staff memo about a meeting between CP&L representatives and NRC staff on 3 <br />March 1998, together with a portion of a set of viewgraphs (titled "HNP Spent Fuel Pool'C' and'D' <br />Activation") shown by CP&L during that meeting. ~ <br />~ License amendment application, Enclosure 7, page 5-16. <br />s License amendment application, Enclosure 5. <br />