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SUBJECT: COMMENTS ON NRC PROPOSED RULE ...

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2.2.5 Spent Fuel Pool<br />

L I<br />

If sabotage actions disable the spent fuel pool cooling system,<br />

for the PWR example, over G h~urs is required to reach boiling<br />

temperatures even at the highest possiale decay heat levels (Ap-<br />

pendix A). OqJer 12 hours is required to boil off three feet of<br />

water. Thus, it is judged that spent fuel pool cooling systems<br />

may be completely protected by damage control means since cooling<br />

,,.... ,-, , ,~ ,...<br />

of some sort could undoubtedly be restored within 12 to 24 hours<br />

and the decay heat level is likely .to be less than t.h.at used in<br />

this analysis. Although not specifi:

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