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4 17 . NRC regulations require that spent fuel storage pools must be cooled by safety grade cooling systems . When the Harris plant was designed , the intention was that pools C and D would be cooled by the component cooling water (CCW) system for the second unit of the Harris plant . 4 That unit was never built, and therefore the Unit 2 CCW system does not exist . In the absence of a second CCW system, CP &L plans to cool pools C and D by connecting their cooling systems to the CCW system of the first unit . This system already provides cooling to pools A and B and serves other, important safety functions . Attachment . B provides supporting information , 5 It should be noted that CP &L considered, but has not pursued , the option of cooling pools C and D by a new, independent system that could have had dedicated emergency diesel generators . Attachment C provides information in support of this point . 6 Three significant safety issues are raised by the fact that the spent fuel pool cooling arrangement originally designed for pools C and D of the Harris plant was not completed . These issues relate to the heat loading of the existing CCW system, the load on the existing emergency diesel generators , and the loss of some important quality assurance documentation for cooling piping at pools C and D . 18 . Heat load. According to CP&L ' s license amendment application, the bounding heat load from the fuel in pools C and D will be 15 . 6 million BTU/hour : 7 At present, the CCW system cannot absorb this additional heat load . Thus , CP &L proposes to include in the Technical Specifications for Harris an interim provision that the heat load in pools C and D will not be allowed to exceed 1 . 0 million BTU/hour . g CP &L claims that an additional heat load of 1 . 0 million BTU/hour can be accommodated by the existing CCW system, and that the fuel to be placed in pools C and D will not create a heat load exceeding 1 . 0 million BTU/hour through 2001 . 19 . Apparently , CP &L contemplates a future upgrade of the CCW system, so that the CCW system can accommodate an additional heat load of 15 :6 million BTU/hour from pools C and D . This contemplated upgrade is not described in the present license amendment application. Attachment C indicates that CP &L plans to perform the upgrade of the CCW system concurrent with a power uprate for the Harris reactor . Apparently , a 4 . 5 percent power uprate will be associated with steam generator replacement, and there will be a subsequent further power uprate of 1 . 5 percent . A chart in Attachment C shows that the projected CCW heat load, including the reactor power uprate and the use of pools C and D , will substantially exceed the capability of the present CCW system . 20 . To summarize , CP &L ' s short-term plan (through 2001 ) for cooling pools C and D is to exploit the margin in the existing CCW system , so as to accommodate an additional heat load of 1 . 0 million BTU/hour. CP &L ' s longer-term plan is to upgrade the CCW 4 The Harris pools have their own closed- circuit cooling systems, which can transfer heat to the relevant CCW system through heat exchangers . 5 Attachment B is a portion of a set of viewgraphs (titled " Harris Spent Fuel Pool ' C ' and 'D' Activation " ) shown by CP&L representatives during a meeting with NRC staff on 16 July 1998 . 6 Attachment C is an NRC staff memo about a meeting between CP&L representatives and NRC staff on 3 March 1998 , together with a portion of a set of viewgraphs (titled " HNP Spent Fuel Pool ' C' and 'D' Activation ") shown by CP&L during that meeting . 7 License amendment application, Enclosure 7 , page 5 - 16 . I 8 License amendment application, Enclosure 5 .