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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 . 14 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 Harris plant. 17 In addition, CP &L has submitted a similar analysis (an IPEEE) for " external " initiating events . 18 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 cesium437 is one important indicator of the hazard potential posed by a nuclear facility . This isotope has a half- 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 cesium437 to the atmosphere , which accounted for most of the offsite radiation exposure attributable to that accident : 14 License amendment application, Enclosure 8 . I 15 Attachment D is a portion of a set of viewgraphs (titled " 1 OCFR50 . 55a 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 21, NUFEGm0972 , 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 .