ML18016A819

Affidavit of G Thompson Re Application by CP&L for Amend to FOL NPF-63 & NRC Review of Application & Proposes to Determine That Amend Request Involves No Significant Hazards Consideration

ML18016A819
Person / Time
Site:	Harris
Issue date:	02/12/1999
From:	Thompson G INSTITUTE FOR RESOURCE & SECURITY STUDIES
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ML18016A818	List: ML18016A817 ML18016A819
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FRN-64FR2237 NUDOCS 9902230110
Download: ML18016A819 (26)

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February 12, 1999 UNITEDSTATES OF AMERICA NUCLEARREGULATORYCOMMISSION BEFORE THE NRC STAFF In the Matter of CAROLINAPOWER Ec LIGHT (Shearon Harris Nuclear Power Plant)

Docket No. 50-400 DECLARATIONOF DR. GORDON THOMPSON I, Gordon Thompson,'eclare as follows:

A. Introduction

l. I am the executive director ofthe Institute for Resource and Security Studies (IRSS), a nonprofit, tax-exempt corporation based in hfassachusetts.

Our office is located at 27 Ellsworth Avenue, Cambridge, MA02139.

IRSS was founded in 1984 to conduct technical and policy analysis and public education, with the objective ofpromoting peace and international security, efficient use ofnatural resources, and protection ofthe environment.

2. This Declaration pertains to an application by Carolina Power and Light (CPAL) for an amendment to Facility Operating License No. NPF-63, which covers the Shearon Harris nuclear power plant. The staff ofthe Nuclear Regulatory Commission gvRC) has reviewed CPS.L's application and proposes to determine that the amendment request involves no significant hazards consideration.

The NRC has sought public comments on the proposed determination.'hrough this Declaration, I offer comments on the NRC staffs proposed determination. I have prepared these comments pursuant to an agreement by IRSS to provide technical information and other services to Orange County, North Carolina.

B. My Professional Background

3. I received an undergraduate education in science and mechanical engineering at the University ofNew South Wales, in Australia. Subsequently, I pursued graduate studies at Oxford University and received Rom that institution a Doctorate ofPhilosophy in mathematics in 1973, for analyses ofplasmas undergoing thermonuclear fusion. During my graduate studies I was associated with the fusion research program ofthe UKAtomic Energy Authority.

i Federal Register: January 13, 1999 (Volume 64, Number 8), pages 2237-2241.

9902230ii0 990216 PDR ADGCK 05000400 P

PDR Li

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4.

During my professional career, I have performed technical and policy analyses on a range ofissues related to international security, energy supply, environmental protection, and sustainable use ofnatural resources.

Since 1977, a significant part of my work has consisted oftechnical analyses ofsafety and environmental issues related to nuclear facilities. These analyses have been sponsored by a variety of nongovernmental organizations and local, state and national governments, predominantly in North America and western Europe. Drawing upon these analyses, I have provided expert testimony in legal and regulatory proceedings, and have served on committees advising US government agencies.

MyCV is provided here as Attachment A.

C.

Scope ofMyReview

5. In preparation ofthis Declaration, I reviewed the NRC's Federal Rey'ster notice for the proposed license amendment, the Final Safety Analysis Report for the Shearon Hams Nuclear Power Plant, the Final Environmental Statement related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2 (NUTMEG-0972, October 1983), and CPS'.L's application for the proposed license amendment.

I also reviewed various correspondence and technical documents relating to the propose license amendment and to risks ofspent fuel storage, which are identified below.

6. The information that has been provided by the flRC and CP8:L to date does not contain all ofthe detail that I would need to provide a complete, final statement about the hazards associated with the proposed license amendment.

I would expect to review the fullbody ofdetailed evidence and present my final evaluation in the context ofa hearing.

However, even the limited information provided so far is adequate to permit me to identify serious safety concerns which preclude the NRC Gom making a "no significant hazards" determination.

These issues should be addressed through the systematic, public process that a prior licensing hearing can provide.

D. The "No Significant Hazards" Standard

7. The NRC has stated its standard for determining that a license amendment request involves no simificant hazards consideration.~

The standard is met ifoperation ofthe facilityin accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences ofan accident previously evaluated; or (2) create the possibility ofa new or different kind ofaccident Rom any accident previously evaluated; or (3) involve a significant reduction in a mary'n ofsafety.

8. In my professional opinion, based on the preliminary evidence provided by the NRC and CPAL, operation ofthe Shearon Harris plant in accordance with the license amendment proposed by CPSL willviolate all three ofthe conditions set forth in the preceding paragraph.

Therefore, the NRC staff should reverse its position and should

determine that CP &L's license amendment request does not involve no simificant hazards consideration.

E. The License Amendment in Context - Spent Fuel Management at Harris

9. Before discussing my concerns about the safety implications ofthe proposed license amendment, I provide here some background information about spent fuel management at the Harris plant and CPSs proposal to increase the spent fuel storage capacity at Harris. Unless specified otherwise, the information presented here is drawn &om CP2L's license amendment application or Rom CP2L's Final Safety Analysis Report (FSAR) for the Harris plant.

10. The Harris plant features one pressurized-water reactor (PWR). The core ofthis reactor contains 157 fuel assemblies, with a center-center distance ofabout 8.5 inches.

The Hams plant was to have four reactors but only one was built. A fuel handling building was built to serve all four reactors.

This building contains four fuel pools (A, B, C, D), a cask loading pool and three fuel transfer canals, all interconnected but separable by gates.

Pools A and B contain fuel racks.

Pools C and D are flooded but do not contain racks.

The cooling and water cleanup systems for pools C and D were never completed.

11. Pool A now contains six PWR racks (360 fuel assembly spaces) and three BWR racks (363 spaces), for a total pool capacity of723 fuel assemblies.

Pool B contains twelve PWR racks (768 spaces) and seventeen BWR racks (2,057 spaces),

and is licensed to store one additional BWR rack (121 spaces), for a total pool capacity of2,946 fuel assemblies.

Thus, pools A and B now have a combined capacity of3,669 fuel assemblies.

The center-center distance in pools A and B is 10.5 inches for PWR fuel and 6.25 inches for BWR fuel.

12. Pools A and B store spent fuel from the Harris reactor and from CPS:L's Brunswick plant and Robinson plant. The Brunswick plant has two boiling-water reactors (BWRs) while the Robinson plant has one PWR. Shipment ofspent fuel from Brunswick and Robinson to Harris is said by CP8cL to be necessary to allow core offload capacity in the pools at Brunswick and Robinson.

13. CPAL seeks an amendment to its operating license so that it can activate pools C and D at Harris. By activating these pools, CPEcL expects to have sufficient spent fuel storage capacity for all four CP8cL reactors (Harris, Robinson and the two Brunswick reactors) through the end oftheir current operating licenses.

14. CPAL plans to install racks in pool C in three campaigns (approximately in 2000, 2005 and 2014), to create 927 PWR spaces and 2,763 BWR spaces, for a total pool capacity of3,690 fuel assemblies.

Thereafter, CP&;L plans to install racks in pool D in two campaigns (approximately in 2016 and at a date to be determined), to create 1,025 PWR spaces.

Thus, the ultimate capacity ofpools C and D willbe 4,715 fuel assemblies.

The center-center distance willbe 9.0 inches for PWR fuel and 6.25 inches for BWR fuel.

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15. The PWR racks in pools C and D have a smaller center-center distance than the racks in pools A and B (9.0 inches instead of 10.5 inches). This arrangement allows more PWR fuel to be placed in a given pool area but also means that PWR fuel in pools C and D is more prone to undergo criticality. In response, CP&:Lproposes to include in the Technical Specifications forHams a provision that PWR fuel willnot be placed in pools C and D unless it has relatively low enrichment and high burnup.3 F. Some Technical Safety Issues Raised By the Proposed License Amendment

16. CP&L's plan for the activation ofpools C and D raises a variety oftechnical safety issues.

This section ofmy Declaration describes some ofthose issues.

Later parts ofthe Declaration relate these issues to the NRC's standard for a "no significant hazards" determination.

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.'hat 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 ofthe first unit. This system already provides cooling to pools A and B and serves other, important safety functions.

Attachment B provides supporting information.>. It should be noted that CP&L considered, but has not pursued, the option ofcooling pools C and D by a new, independent system that could have had dedicated emergency diesel generators.

Attachment C provides information in support ofthis point.< Three significant safety issues are raised by the fact that the spent fuel pool cooling arrangement originally designed for pools C and D ofthe Hams plant was not completed.

These issues relate to the heat loading ofthe existing CCW system, the load on the existing emergency diesel generators, and the loss ofsome 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 Qom the fuel in pools C and D willbe 15.6 millionBTU/hour.7 At present, the CCW system cannot absorb this additional heat load. Thus, CP&L proposes to include in 3 License amendment application, Enclosure 5.

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 ofa set ofviewgraphs (titled "Hams Spent Fuel Pool 'C'nd 'D'ctivation")

shown by CP&L representatives during a meeting withNRC 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 ofviewgraphs (titled "HNP Spent Fuel Pool 'C'nd

'D'ctivation"

) shown by CP&L during that meeting.

7 License amendment application, Enclosure 7, page 5-16.

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the Technical Specifications for Hams an interim provision that the heat load in pools C and D willnot be allowed to exceed 1.0 millionBTU/hour.s CPAL claims that an additional heat load of 1.0 millionBTU/hour can be accommodated by the existing CCW system, and that the fuel to be placed in pools C and D willnot create a heat load exceeding 1.0 millionBTU/hour through 2001.

19. Apparently, CP8cL contemplates a future upgrade ofthe CCW system, so that the CCW system can accommodate an additional heat load of 15.6 millionBTU/hour Rom 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 ofthe CCW system concurrent with a power uprate for the Hams reactor. Apparently, a 4.5 percent power uprate willbe associated with steam generator replacement, and there willbe 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 ofpools C and D, willsubstantially exceed the capability ofthe present CCW system.

20. To summarize, CP8: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 millionBTU/hour. CPS:L's longer-term plan is to upgrade the CCW system. in a manner not yet specified, so as to accommodate an additional heat load of 15.6 millionBTU/hour. The CCW upgrade must also accommodate an increase in the rated power ofthe Harris reactor. Attachment B indicates CP &L's expectation that the design ofthe CCW upgrade willcommence in mid-1999 and willbe completed in early 2001, one year after pool C enters service.

21. In order to avoid exceeding the available mary'n in the existing CCW system while cooling pools C and D, CPAL may be obliged to require its operators to divert some CCW flow from the residual heat removal (RHR) heat exchangers during the recirculation phase ofa desi'-basis loss-of-coolant accident (LOCA) event at the Harris reactor.i 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 CPAL 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.<< It should be noted in this context that exploitation ofthe 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 ofCCW capability which is provided in Enclosure 9 of CP&;L's license amendment application is insufficient to determine the nature and si~ficance ofthe assumptions made by CPZcL.

22. Backup diesel generators.

The cooling systems for pools C and D willdraw electrical power Rom the electrical systems ofthe existing Harris plant. Ifelectricity 8 License amendment application, Enclosure 5.

~ License amendment application, Enclosure 9.

tO Ibid; Federal Register notice for this application.

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supply to the cooling pumps for pools C and D is interrupted, the pools willheat up and eventually boil. CP&L says that pools C and D willbegin to boil after a time period "in excess of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />", assuming a bounding decay heat load of 15.6 millionBTU/hour.>>

To prevent the onset ofpool boiling in the event ofa loss ofoffsite power, the Harris operators may be obliged to provide electrical power to pools C and D Gom 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 ofthe emergency diesel generators to meet the additional electrical loads associated with pools C and D. CP &Ldoes mention in the Harris FSAR the potential for connecting "portable pumps" to bypass the pool cooling pumps should the latter be inoperable.'2 However, the characteristics, capabilities and availability ofsuch portable pumps are not addressed in the present license amendment application. Meeting the electrical load ofpools C and D Rom the systems ofthe existing Hams plant is a safety issue because it could increase the probability ofdesi'-basis or severe accidents at the Harris reactor or at pools A through C.

23. Lack of QA documents.

Activation ofpools C and D willrequire the completion of their cooling and water cleanup systems, and the connection oftheir 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.>>

However, some of the quality assurance documentation for the completed piping is no longer available. Much ofthe completed piping is embedded in concrete and is therefore difficultor 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.i4 Nevertheless, the cooling systems for pools C and D willnot satisf'y ASME code requirements. Attachment D provides supporting information.'> Failure to satisfy ASME code requirements could increase the probability ofdesi'-basis or severe accidents at pools C and D.

G. The Degree ofHazard Posed by Spent Fuel Storage at Harris

24. The NRC and CP &Lhave 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 &Lhas performed any site-specific analysis which

'icense amendment application, Enclosure 7, page 5-8.

'2 Harris FSAR, page 9.1.3-4, Amendment No. 48.

License amendment application, Enclosure 1, page 4.

i4 License amendment application, Enclosure 8.

i5 Attachment D is a portion ofa set ofviewgraphs (titled "10CFR50.55a Alternative Plan") shown by CPS:L representatives during a meeting with NRC staff on 16 July 1998.

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examines potential severe accidents affecting any ofthe Harris fuel pools, including pools C and D.

25. The NRC examined severe reactor accidents in its Final Environmental Statement for the Harris plant.t6 Site-specific consequence modelling was performed by the NRC for hypothetical accidents that released as much as 82 percent ofthe inventory ofcesium isotopes in the reactor core. CPAL has submitted to the NRC an Individual Plant Examination (IPE) for the Harris plant.t> In addition, CPAL has submitted a similar analysis (an IPEEE) for "external" initiating events.ts The IPE and IPEEE studies examined the potential for severe reactor accidents that could release substantial amounts ofradioactivity.

26. In the absence ofsimilar studies for the Hams pools, one must perform scoping calculations to indicate the degree ofhazard posed by spent fuel storage at Harris. The degree ofhazard is important when one considers the relevance ofa safety issue to a determination of"no significant hazards". Ifpreliminary 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 cesium-137 is one important indicator ofthe hazard potential posed by a nuclear facility. This isotope has a half-lifeof30 years, emits intense gamma radiation, and is released comparatively readily during severe accidents.

The 1986 Chernobyl accident released about 90,000 TBq (27 kg) ofcesium-137 to the atmosphere, which accounted for most ofthe offsite radiation exposure attributable to that accident.

Officialestimates indicate that this exposure willcause 50-100 thousand extra cancer fatalities worldwide over the next 70 years.>>

28. The core ofthe Harris reactor contains 157 PWR fuel assemblies.

At shutdown, this core contains about 155,000 TBq (47 kg) ofcesium-137.2o When a spent fuel assembly is discharged from the reactor, it willcontain more cesium-137 than the average assembly at shutdown. CP&L plans an eventual, aggregate capacity in the Harris pools of3,080 PWR assemblies and 5,304 BWR assemblies.

Note that the cesium-137 content in each BWR assembly willbe about one quarter the cesium-137 content in each PWR assembly, t~ NRC, Final Environmental Statement related to the operation ofShearon Hams Nuclear Power Plant, Units 1 and 2, NUREG-0972, October 1983.

t~ CP&L, Shearon Hams Nuclear Power Plant, Individual Plant Examination Submittal, Final Report, 31 August 1993.

t8 CP8cL, Shearon Harris Nuclear Power Plant UnitNo. 1, Individual Plant Examination for External Events Submittal, June 1995.

t9 Allan S Krass, Consequences ofthe Chemobyl Accident (Cambridge, Massachusetts:

Institute for Resource and Security Studies, December 1991).

2o NRC, Final Environmental Statement, page 5-50.

ifboth assemblies have been discharged for an equal period.-'> After discharge, the content ofcesium-137 in a fuel assembly willdecay exponentially with a lialf-lifeof30 years.

29. As a s>mplified illustration, assume that all fuel assemblies in the Harris pools have been discharged for an equal period. Further assume that all four pools are full and contain 3,080 PWR assemblies and 5,304 BWR assemblies.

The pools willthen contain as much cesium-137 as 4,406 PWR assemblies.

(3,080

5,304 x 1/4 = 4,406) Note that 4,406 PWR assemblies represent 28 cores ofthe Harris reactor.

30. Ifan accident can be postulated that releases to the environment a significant &action ofthe cesium-137 in the Harris pools, then it is clear that the consequences ofthis accident would be large. The offsite radiation exposure could be an order ofmagnitude larger than the exposure Rom the Chernobyl accident. Activation ofpools C and D could lead to an accident which creates offsite radiation exposure as much as bvo times higher than the exposure that would arise Rom a similar accident involving only pools A and B.

H. Loss of~Vater from Spent Fuel Pools at Harris

31. Loss ofwater from one or more of the Harris pools could initiate a release to the environment ofa significant fraction ofthe cesium-137 in the pools. This potential exists because the cladding ofPWR or BWR fuel is a zirconium alloy which can react exothermically with air or steam.

Thus, ifthe water in a fuel pool is removed and the fuel is partially or totally uncovered, one must be concerned about the possibility ofa runaway air-zirconium or steam-zirconium reaction.

Such a reaction could release cesium-137 and other radioisotopes Rom affected fuel into the fuel building. That building was not designed to contain radioisotopes released during a vigorous exothermic reaction in the pools, and it can be assumed that most ofthe volatile radioisotopes entering the building from the affected fuel would be released Rom the building as an atmospheric plume.

32. Several reports prepared by or for the NRC have examined the conditions under which a runaway zirconium reaction might occur."-" However, these reports have concentrated almost entirely on a postulated condition ofinstantaneous, complete loss of water Rom a pool. Such a condition is unrealistic in any scenario which preserves the conQguration ofthe spent fuel racks. Ifwater is lost by drainage or evaporation and no makeup occurs, then complete loss ofwater willalways be preceded by partial The ratio ofone quarter derives from the parameters shown in the license amendment application,, page 5-15.

~ Relevant reports include: VL Sailor et al, Severe Accidents in Spent Fuel Pools in Support ofGeneric Safety Issue 82, NUREG/CRA982, July 1987; E D Throm, Regulatory Analysis for the Resolution of Generic Issue 82, "Beyond Design Basis Accidents in Spent Fuel Pools", NUREG-1353, April 1989; and R J Travis et al, A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants, NUREG/CR-6451, August 1997.

I uncovering ofthe fuel. Ifmakeup is considered, the water level could fall, rise or remain static for long periods.

33. Partial uncovering ofthe fuel willoften be a more severe condition than complete loss ofwater because, during partial uncovering, convective heat loss is suppressed by the residual water at the base ofthe fuel assemblies.

As a result, longer-discharged fuel with a lower heat output may undergo a runaway steam-zirconium reaction during partial uncovering while it would not undergo a runaway air-zirconium reaction ifthe pool were instantaneously emptied.

34. I am aware ofonly one instance in which reports produced by or for the NRC address the hazard posed by partial uncovering, namely in a report prepared for the NRC by Sandia Laboratories and published in 1979.3 Part ofthis report did address a situation of partial uncovering, but used a crude heat transfer model and neglected to consider the onset ofa steam-zirconium reaction. Nevertheless, the report found (page 76) that

"......an incomplete drainage can potentially cause a more severe heatup problem than a complete drainage, ifthe residual water remains near the baseplates". A portion ofthe 1979 Sandia report is provided here as Attachment E. An internal NRC memo mentions the consideration ofpartial uncovering in the 1979 Sandia report.-'"'. Otherwise, it appears that the NRC has ignored the hazard posed by partial uncovering. This hazard was not reflected in the regulatory analysis whereby the tttRC purportedly resolved Generic Issue 82.>>

35. In a situation offalling water level, a fuel assembly might first undergo a runaway steam-zirconium reaction, then switch to an air-zirconium reaction as water falls below the base ofthe rack and convective air flow is established.

In this manner, a runaway air-zirconium reaction could occur in a fuel assembly that is too long-discharged (and therefore produces too little heat) to suffer such a reaction in the event ofinstantaneous, complete loss ofwater. Conversely, a rising water level could precipitate a runaway steam-zirconium reaction in a fuel assembly that had previously been completely uncovered but had not necessarily suffered a runaway air-zirconium reaction while in that condition. The latter point is highly significant in the context ofemergency measures to recover control ofa pool which has experienced water loss. Inappropriate addition of water to a pool could exacerbate the accident.

36. The NRC's failure to consider partial uncovering offuel should be borne in mind when one reviews NRC-sponsored reports that purport to address the hazard posed by water loss &om a fuel pool. This hazard should be re-analyzed through detailed modelling. The modelling should consider both partial and complete uncovering and the

~3 Allan S Benjamin et al, Spent Fuel Heatup Following Loss ofWater During Storage, NUREG/CR-0649, March 1979.

Internal NRC Memorandum from J T Han to M Silberberg, "Response to a NRR request to review SNL studies regarding spent fue) heatup and burning following loss ofwater in storage pool", 21 May 1984.

>> E D Throm, op cit.

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10 transition Rom one ofthese states to the other. Also, the modelling should cover. (1) thermal radiation, conduction, and steam or air convection; (2) air-zirconium and steam-zirconium reactions; (3) variations along the fuel rod axis; and (4) radial variations within a representative fuel rod, including effects ofthe pellet-cladding'gap.

Experiments will probably be required to support and validate the modelling.

37. Until the problem ofwater loss is re-analyzed in this manner, there is no basis for determining when fuel has been discharged for a sufficiently long period that itwillnot suffer a runaway zirconium reaction in the event ofwater loss. Ifthe problem were to be properly analyzed through validated models, such a determination could be made within some margin oferror, but the determination should consider site-specific factors. For example, the detailed design of a rack might be an important site-specific factor.

38. No determination ofthis kind has been made for pools C and D at Harris, nor does the methodology now exist to make such a determination. In any case, there is nothing in the license amendment application and its proposed modifications to the Hams Technical Specifications which prohibits the placing of freshly discharged fuel in pools C and D.

Reports previously prepared for the NRC concede that freshly discharged fuel can experience a runaway air-zirconium reaction in the event ofcomplete water loss.

39. A variety ofevents, alone or in combination, could lead to partial or complete uncovering ofspent fuel in the Harris pools. This class ofevents should be subjected to the kind ofsystematic analysis that is performed in an IPE and an IPEEE. Relevant events include: (1) an earthquake, cask drop, aircraft crash, human error, equipment failure or sabotage event that leads to direct leakage Rom the pools; (2) siphoning of water Rom the pools, through accident or malice; (3) interruption ofpool cooling, leading to pool boiling and loss ofwater by evaporation; and (4) loss ofwater Rom active pools into adjacent pools or canals that have been gated offand drained.

Interactions with the Harris reactor should be considered.

For example, a reactor accident might release radioactivity that precludes personnel access to the plant for purposes ofmaintaining or restoring pool cooling.

I. Increased Probability or Consequences ofAccidents Previously Evaluated

40. The Federal Register notice ofthis license amendment application claims that the probability ofa spent fuel assembly drop or a misloaded fuel assembly is not significantly increased ifthe license amendment is approved and pools C and D are activated.

This claim is false, because activation ofpools C and D willroughly double the total number offuel handling operations to be conducted at Harris. Assuming that the general nature offuel handling operations continues as before, the probability ofa fuel assembly drop or misloaded fuel assembly, integrated over the entire period ofthe Harris operating license, willincrease significantly, by a factor oftwo. This point has been made by David Lochbaum ofthe Union ofConcerned Scientists, in a 22 January 1999 letter to the NRC Commissioners.

A copy ofhis letter is provided here as Attachment F. Ifprobability is integrated over the remaining period ofthe Harris operating license, rather than over its total duration, then activation ofpools C and D willmore than double the probability ofa fuel assembly drop or a misloaded fuel assembly.

41. A spent fuel assembly drop or a misloaded fuel assembly are members ofa broader class ofaccidents that could arise during the movement offuel fiom other CP2L stations to Harris, and during fuel movement within Harris. This class ofaccidents willinclude desi'-basis accidents and severe accidents.

Assuming that the general nature offuel movement continues as before, the probability ofaccidents in this class, integrated over the entire period ofthe Harris operating license, willdouble ifpools C and D are activated. Ifintegrated over the remaining period ofthe operating license, the probability willmore than double.

42. The PWR racks in pools C and D willbe safe against criticality for a comparatively narrow range offuel enrichment and burnup. Thus, assuming that the general nature of fuel movement continues as before, the probability ofa criticality accident willbe significantly increased ifpools C and D are activated.

This probability willincrease on a per-movement basis, so it willmore than double when integrated over the entire period of the Harris operating license.

The consequences ofa criticality accident may also be significantly increased.

43. Activation ofpools C and D willadd to the electrical load and CCW heat load of existing Hams systems.

It willalso add to the burden ofwork on the Harris operators.

These effects willincrease the probability oftwo categories ofdesign-basis or severe accidents.

First, they willsi~ficantly increase the probability ofaccidents associated with the Harris reactor, because the reactor's CCW and electrical systems and its operators willbe under greater stress.

Second, they willsiyuficantly increase the probability ofaccidents at the Hams pools that are attributable to interruptions in cooling and electricity supply and to increased operator stress.

Also, the inabilityofcooling piping at pools C and D to meet AS'ME code requirements could significantly increase the probability ofdesi'-basis or severe accidents at these pools.

44. As mentioned in paragraph 24 above, to my knowledge there has been no site-specific analysis ofsevere accidents affecting any ofthe Harris pools. To the extent that such accidents have been previously evaluated, their consequences willbe signifiicantly increased by the activation ofpools C and D. The fuel storage capacity of these pools willroughly double the storage capacity at Hams, creating the potential for a doubled inventory ofradioactivity. Severe accidents could affect some or all ofthe Harris pools.

As I have discussed in paragraph 30 above, the potential doubling ofradioactivity in the pools could significantly increase the consequences ofsevere accidents.

'J Z. Possibility ofNew or Different Kinds ofAccident from any Accident Previously Evaluated

45. To my knowledge, there has been no site-specific evaluation ofthe probability or consequences ofsevere accidents at pools A and B at Harris. A variety ofsevere accidents are possible and should be subjected to the kind ofsystematic analysis that is performed in an IPE and IPEEE. The NRC has performed evaluations ofaccidents involving loss ofwater Rom fuel pools, generically and for sites other than Hams.

12 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 ofnew or different kinds ofaccident &om any accident previously evaluated.

The same possibility willexist at pools C and D ifthese are activated.

46. Provision ofelectrical power, including power from emergency diesel generators, 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 different from any accident previously considered.

The IPE and IPEEE studies performed for Harris did not address the provision ofelectrical 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 willplace increased stress on the CCW system, the emergency diesel generators, and the plant operators during a design-basis LOCA.

47. Severe accidents at some or all ofthe Hams pools could lead to offsite radiation exposure an order ofmagnitude larger than the exposure from the Chernobyl accident.

Activation ofpools C and D could significantly increase both the probability and consequences ofsuch accidents.

Thus, CPAL's proposed license amendment poses a

- "significant hazard" by any reasonable definition ofthat term.

J. Significant Reductions in Margins ofSafety.

48. Activation ofpools C and D willcreate an additional heat load on the existing CCW system.

CPAL proposes to meet this load in the short term by exploiting the margin in the CCW system. In my professional opinion, the reduction in the CCW safety margin caused by the increased heat load is significant. Both the NRC and CP8cL have also recognized that increasing the heat load on the CCW system constitutes an unreviewed safety question.

The safety margin willbe especially reduced if, during a LOCA, the operators must divert water from the RHR to the spent fuel pools. This willincrease stress on the operators and create opportunities for human error.

49.

As pools C and D become filled and the reactor receives a power uprate, the load on the CCW system willincrease further. CP&;L offers no assurance that the present margin ofsafety willbe restored by upgrading the CCW system to accommodate these burdens.

50. CP8cL proposes to activate pools C and D using cooling systems that willnot satisfy ASME code requirements.

This action could potentially cause a significant reduction in margins ofsafety for pool cooling. CPEcL's Alternative Plan has not been subjected to any public scrutiny or rigorous review. It deserves, at the least, thorough consideration at a licensing hearing before the license amendment is issued.

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51. CP&L proposes to provide electrical service to pools C and D from the existing (Unit

1) electrical system at Harris, having rejected the option ofdedicated emergency diesel generators to serve pools C and D. The existing diesel generators already serve the safety systems in Unit 1 and spent fuel storage pools A and B. By adding pools C and D to the load carried by the Unit 1 diesel generators, CP&Lwould add stress on the diesel generators and on the plant operators. In the event of a loss ofoffsite power, these effects could significantly reduce the margin of safety at the Harris reactor and the fuel pools.

L Environmental Review 52.

As discussed above, the original design ofthe Shearon Harris plant called for cooling of spent fuel pools C and D by the Unit 2 CCW system.

The FEIS for the operating license presumably based its conclusions on this design. I have seen no analysis by the NRC Staff, either in the 1983 FEIS or in a subsequent Environmental Impact Statement or Environmental Assessment, ofthe environmental impacts of altering the Shearon Harris design to provide for cooling ofpools C and D by the Unit 1 CCW system.

M. Conclusions

53. From the preliminary evidence presented by the NRC and CP&L, I conclude that operation ofthe Shearon Harris plant in accordance with the license amendment proposed by CP&Lwillviolate all three ofthe NRC's conditions for a determination of"no significant hazards."

Therefore, the NRC staff should reverse its position and should determine that CP&L's license amendment request does not involve no significant hazards consideration.

54. The proposed license amendment raises serious safety concerns which deserve prior consideration at a licensing hearing.

I declare, under penalty of perjury, that the foregoing facts provided in my Declaration are true and correct to the best ofmy knowledge and belief, and that the opinions expressed herein are based on my best professional judgment.'xecuted on 12 February 1999.

Gordon Thompson

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