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6 quality assurance documentation for the completed piping is no longer available. Much of the completed piping is embedded in concrete and is therefore difficult or impossible to inspect. To address this situation, CP&L proposes an Alternative Plan to demonstrate that the previously completed piping and other equipment is adequate for its purpose.ia Nevertheless, the cooling systems for pools C and D will not satisfy ASME code requirements. Attachment D provides supporting information.15 Failure to satisfy ASME code requirements could increase the probability of design-basis or severe accidents at pools C and D. G. The Degree of Hazard Posed by Spent Fuel Storage at Harris 24. The NRC and CP&L have performed and published site-specific analyses which provide information about potential severe accidents at the Harris reactor. However, to my knowledge neither NRC nor CP&L has performed any site-specific analysis which examines potential severe accidents affecting any of the Harris fuel pools,. including pools C and D. 25. The NRC examined severe reactor accidents in its Final Environmental Statement for the Harris plant.16 Site-specific consequence modelling was performed by the NRC for hypothetical accidents that released as much as 82 percent of the inventory of cesium isotopes in the reactor core. CP&L has submitted to the NRC an Individual Plant Examination (IPE) for the Hams plant.~~ In addition, CP&L has submitted a similar analysis (an IPEEE) for "external" initiating events.lg The IPE and IPEEE studies examined the potential for severe reactor accidents that could release substantial amounts of radioactivity. 26. In the absence of similar studies for the Harris pools, one must perform scoping calculations to indicate the degree of hazard posed by spent fuel storage at Harris. The degree of hazard is important when one considers the relevance of a safety issue to a determination of "no significant hazards". If preliminary evidence about a safety issue suggests the potential for accidents with either high probability or large consequences, then the NRC staff should not make a determination of "no significant hazards". 27. The radioisotope cesium-137 is one important indicator of the hazard potential posed by a nuclear facility. This isotope has ahalf--life of 30 years, emits intense gamma radiation, and is released comparatively readily during severe accidents. The 1986 Chernobyl accident released about 90,000 TBq (27 kg) of cesium-137 to the atmosphere, which accounted for most of the offsite radiation exposure attributable to that accident. la License amendment application, Enclosure 8 15 Attachment D is a portion of a set of viewgraphs (titled "1OCFRSO.SSa Alternative Plan") shown by CP&L representatives during a meeting with NRC staff on 16 July 1998. 16 NRC, Final Environmental Statement related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2, NUREG-0972, October 1983. 17 CP&L, Shearon Harris Nuclear Power Plant, Individual Plant Examination Submittal, Final Report, 31 August 1993. 18 CP&L, Shearon Harris Nuclear Power Plant Unit No. 1, Individual Plant Examination for External Events Submittal, June 1995.