Agenda - 02-02-1999 - 9e1 - Laserfiche WebLink

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11 47. Severe accidents at some or all of the Harris pools could lead to offsite radiation exposure an order of magnitude larger than the exposure from the Chernobyl accident. Activation of pools C and D could significantly increase both the probability and consequences of such accidents. Thus, CP&L's proposed license amendment poses a "significant hazazd" by any reasonable definition of that term. J. Significant Reductions in Margins of Safety. 48. Activation of pools C and D will create an additional heat load on the existing CCW system. CP&L proposes to meet this load in the short term by exploiting the margin in the CCW system. In my professional opinion, the reduction rn the CCW safety margin caused by the increased heat load is significant. Both the NRC and CP&L have also recognized that increasing the heat load on the CCW system constitutes an unreviewed safety question. The safety margin will be especially reduced if, during a LOCA, the operators must divert water from the RHR to the spent fuel pools. This will increase stress on the operators and create opportunities for human error. 49. As pools C and D become filled and the reactor receives a power uprate, the load on the CCW system will increase further. CP&L offers no assurance that the present margin of safety will be restored by upgrading the CCW system to accommodate these burdens. 50. CP&L proposes to activate pools C and D using cooling systems that will not satisfy ASME code requirements. This action could potentially cause a significant reduction in mazgins of safety for pool cooling. CP&L's Alternative Plan has not been subjected to any public scrutiny or rigorous review. It deserves, at the least, thorough consideration at a licensing hearing before the license amendment is issued. 51. CP&L proposes to provide electrical service to pools C and D from the existing (Unit 1) electrical system at Harris, having rejected the option of dedicated emergency diesel generators to serve pools C and D. The existing diesel generators already serve the safety systems in Unit. l and spent fuel storage pools A and B. By adding pools C and D to the load carried by the Unit 1 diesel generators, CP&L would add stress on the diesel generators and on the plant operators. In the event of a loss of offsite power, these effects could significantly reduce the margin of safety at the Harris reactor and the fuel pools. L. Environmental Review 52. As discussed above, the original design of the Shearon Hams plant called for cooling of spent fuel pools C and D by the Unit 2 CCW system. The FEIS for the operating license presumably based its conclusions on this design. I have seen no analysis by the NRC Staff, erther in the 1983 FEIS or in a subsequent Environmental Impact Statement or Environmental Assessment, of the environmental impacts of altering the Shearon Harris design to provide for cooling of pools C and D by the Unit 1 CCW system. M. Conclusions 53. From the preliminary evidence presented by the NRC and CP&L, I conclude that operation of the Shearon Harris plant in accordance with the license amendment proposed by CP&L will violate all three of the NRC's conditions for a determination of "no significant hazards." Therefore, the NRC staff should reverse its position and should determine that CP&L's license amendment request does not involve no significant hazards consideration.