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10 the entire period of the Harris operating license , will double if pools C and D are activated . If integrated over the remaining period of the operating license , the probability will more than double . 42 . The PWR racks in pools C and D will be safe against criticality for a comparatively narrow range of fuel enrichment and bumup . Thus , assuming that the general nature of fuel movement continues as before , the probability of a criticality accident will be significantly increased if pools C and D are activated . This probability will increase on a per-movement basis , so it will more than double when integrated over the entire period of the Harris operating license . The consequences of a criticality accident may also be significantly increased . 43 . Activation of pools C and D will add to the electrical load and CCW heat load of existing Harris systems . It will also add to the burden of work on the Harris operators . These effects will increase the probability of two categories of design-basis or severe accidents . First, they will significantly increase the probability of accidents associated with the Harris reactor, because the reactor' s CCW and electrical systems and its operators will be under greater stress . Second, they will significantly increase the probability of accidents at the Harris pools that are attributable to interruptions in cooling and electricity supply and to increased operator stress . Also , the inability of cooling piping at pools C and D to meet ASME code requirements could significantly increase the probability of design-basis or severe accidents at these pools . 44 . As mentioned in paragraph 24 above , to my knowledge there has been no site- specific analysis of severe accidents affecting any of the Harris pools . To the extent that such accidents have been previously evaluated, their consequences will be significantly increased by the activation of pools C and D . The fuel storage capacity of these pools will roughly double the storage capacity at Harris , creating the potential for a doubled inventory of radioactivity . Severe accidents could affect some or all of the Harris pools . As I have discussed in paragraph 30 above , the potential doubling of radioactivity in the pools could significantly increase the consequences of severe accidents . J. Possibility of New or Different Kinds of Accident from any Accident Previously Evaluated 45 . To my knowledge , there has been no site - specific evaluation of the probability or consequences of severe accidents at pools A and B at Harris . A variety of severe accidents are possible and should be subjected to the kind of systematic analysis that is performed in an IPE and IPEEE . The NRC has performed evaluations of accidents involving loss of water from fuel pools , generically and for sites other than Harris . However, these evaluations are seriously deficient because they failed to consider partial uncovering of fuel . To summarize , at pools A and B there exists the possibility of new or different kinds of accident from any accident previously evaluated . The same possibility will exist at pools C and D if these are activated . 46 . Provision of electrical power and CCW service from the existing Harris plant to pools C and D could introduce the potential for design-basis or severe accidents that are new or Jdifferent from any accident previously considered . The IPE and IPEEE studies performed for Harris did not address the provision of electrical power and CCW service to pools C and D . As an example of the potential for new or different accidents , the need to provide cooling to pools C and D will place increased stress on the CCW system and the plant operators during a design-basis LOCA .