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5 system, in a manner not yet specified, so as to accommodate an additional heat load of 15 . 6 million BTU/hour. The CCW upgrade must also accommodate an increase in the rated power of the Harris reactor. Attachment B indicates CP &L ' s expectation that the design of the CCW upgrade will commence in mid- 1999 and will be completed in early 2001 , one year after pool C enters service , ilable margin in the existing CCW system while 21 . In order to avoid exceeding the ava cooling pools C and D , CP &L may be obliged to require its operators to divert some CCW flow from the residual heat removal (RHR) heat exchangers during the recirculation phase of a design-basis loss - of-coolant accident (LOCA) event at the Harris reactor . 9 This raises a safety issue because , during the recirculation phase of a LOCA, operation of the RHR system is essential to keeping the reactor core and containment in a safe condition. Both CP &L and the NRC have identified the proposed additional heat load on the Unit 1 CCW system as an " unreviewed safety question, " i . e . , a safety question that has not been previously reviewed by the NRC Staff. 10 It should be noted in this context that exploitation of the margin in the existing CCW system may involve changes in design assumptions that include fouling factors and tube plugging limits . See Attachment C . The discussion of CCW capability which is provided in Enclosure 9 of CP &L ' s license amendment application is insufficient to determine the nature and significance of the assumptions made by CP &L . 22 . Backup diesel generators . The cooling systems for pools C and D will draw electrical power from the electrical systems of the existing Harris plant . If electricity supply to the cooling pumps for pools C and D is interrupted, the pools will heat up and eventually boil . CP&L says that pools C and D will begin to boil after a time period " in excess of 13 hours " , assuming a bounding decay heat load of 15 . 6 million BTU/hour . I I To prevent the onset of pool boiling in the event of a loss of offsite power, the Harris operators may be obliged to provide electrical power to pools C and D from the emergency diesel generators , which also serve pools A and B and the reactor. In the present license amendment application, CP &L does not address the ability of the emergency diesel generators to meet the additional electrical loads associated with pools C and D . CP &L does mention in the Harris FSAR the potential for connecting "portable pumps " to bypass the pool cooling pumps should the latter be inoperable . 12 However, the characteristics , capabilities and availability of such portable pumps are not addressed in the present license amendment application . Meeting the electrical load of pools C and D from the systems of the existing Harris plant is a safety issue because it could increase the probability of design-basis or severe accidents at the Harris reactor or at pools A through C . 23 . Lack of QA documents . Activation of pools C and D will require the completion of their cooling and water cleanup systems , and the connection of their cooling systems to the existing CCW system . CP &L states that approximately . 80 % of the necessary piping was completed before the second Harris reactor was cancelled. 13 However, some of the 9 License amendm6nt application, Enclosure 9 . 10 Ibid; Federal Register notice for this application . 11 License amendment application, Enclosure 7 , page 54 . I 12 Harris FSAR, page 9 . 1 . 34 , Amendment No . 48 , I 13 License amendment application, Enclosure 1 , page 4 .