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5 <br />system, in a manner not yet specified, so as to accommodate an additional heat load of <br />15.6 million BTU/hour. The CCW upgrade must also accommodate an increase in the <br />rated power of the Harris reactor. Attachment B indicates CP&L's expectation that the <br />design of the CCW upgrade will commence in mid-1999 and will be completed in early <br />2001, one year after pool C enters service. <br />21. In order to avoid exceeding the available margin in the existing CCW system while <br />cooling pools C and D, CP&L may be obliged to require its operators to divert some <br />CCW flow from the residual heat removal (RHR) heat exchangers during the <br />recirculation phase of a design-basis loss-of-coolant accident (COCA) event at the Harris <br />reactor.9 This raises a safety issue because, during the recirculation phase of a COCA, <br />operation of the RHR system is essential to keeping the reactor core and containment in a <br />safe condition. Both CP&L and the NRC have identified the proposed additional heat <br />load on the Unit 1 CCW system as an "unreviewed safety question," i.e., a safety <br />question that has not been previously reviewed by the NRC Staff.10 It should be noted in <br />this context that exploitation of the margin in the existing CCW system may involve <br />changes in design assumptions that include fouling factors and tube plugging limits. See <br />Attachment C. The discussion of CCW capability which is provided in Enclosure 9 of <br />CP&L's license amendment application is insufficient to determine the nature and <br />significance of the assumptions made by CP&L. <br />22. Backup diesel generators. The cooling systems for pools C and D will draw <br />electrical power from the electrical systems of the existing Harris plant. If electricity <br />supply to the cooling pumps for pools C and D is interrupted, the pools will heat up and <br />eventually boil. CP&L says that pools C and D will begin to boil after a time period "in <br />excess of 13 hours", assuming a bounding decay heat load of 15.6 million BTU/hour.il <br />To prevent the onset of pool boiling in the event of a loss of offsite power, the Harris <br />operators may be obliged to provide electrical power to pools C and D from the <br />emergency diesel generators, which also serve pools A and B and the reactor. In the <br />present license amendment application, CP&L does not address the ability of the <br />emergency diesel generators to meet the additional electrical loads associated with pools <br />C and D. CP&L does mention in the Harris FSAR the potential for connecting "portable <br />pumps" to bypass the pool cooling pumps should the latter be inoperable.12 However, the <br />characteristics, capabilities and availability of such portable pumps are not addressed in <br />the present license amendment application. Meeting the electrical load of pools C and D <br />from the systems of the existing Harris plant is a safety issue because it could increase the <br />probability of design-basis or severe accidents at the Harris reactor or at pools A through <br />G. <br />23. Lack of QA documents. Activation of pools C and D will require the completion of <br />their cooling and water cleanup systems, and the connection of their cooling systems to <br />the existing CCW system. CP&L states that approximately 80% of the necessary piping <br />was completed before the second Harris reactor was cancelled.13 However, some of the <br />9 License amendment application, Enclosure 9. <br />to Ibid; Federal Register notice for this application. <br />11 License amendment application, Enclosure 7, page 5-8. <br />12 Harris FSAR, page 9.1.3-4, Amendment No. 48. <br />13 License amendment application, Enclosure 1, page 4. <br />