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