ML19220A394
| ML19220A394 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/1978 |
| From: | Trowbridge G SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 7904170544 | |
| Download: ML19220A394 (6) | |
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BEI' ORE THE ATOMIC S AFET'i A:!D LICE:'SI!!G APPEAL EC;
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METROPOLITA:I EDISO'I COMPAN'i, ET AL.
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Docket.:c. 50-320 (Three Mile Island Nuclear Generating )
Station, Unit 2)
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- m., r._s _ I ov. e-During oral argument befor e -he Appeal Ecard 0:. March 23, 1978, Dr. Johnson addressed two cuesticn3 to the undersigned counsel for Applicants which, for lack of detailed familiarity with Applicants' FSAR and Staff SER, I was unable to answer.
I respectfully recucct leaze to supplement the record of the oral argument by adding the supplemental answers attached :
this mo-tien.
The supple ental answers are confined to material already contained in the record before the Licensing Board.
Respectfully submitted,
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Dated: March 31, 1978 3-atq k1
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March 31, 1973 SUPPLEME!TAL ANSWERS BY APPLICANTS' CCU::SEL TO APPEAL BOARD OUESTIO:IS Ouestion bv Dr. Johnson:
"Along that same line, the 511 number for 1976 was deter-mined to be 1.4 percent of the traffic at the airport for that year.
At the time of the FSAR a number was given for the traffic of heavier than 200,000-pound aircraft as being 5 percent of the total traffic, so that over the period of time between when that number was generated -- and it is a little difficult to say what year or years it related to -- and the time of 1976, there was a factor of three change in the relative frecuency of these heavy aircraft.
It went down.
"But was '76 an aberrational year or was the other deter-mination wrong, or has the pattern of use at the airport changed?"
(Tr. 75-6)
Surnlemental Answer:
The pattern of use at the airport has changed.
Dr. Johnson is correct in noting that Applicants' FSAR indicates at page 2.2-3 that in 1968 approximately 5 percent of total air carrier trafric consisted cf the Boeing 707, which is larger than the design basis aircraft, while Mr. Vallance testified that large aircraft in 1976 constituted only 1.4 percent of the traffic.
The Staff Safety Evaluation Repcr explains at page 2-3 that at the time the original Staff estinate of aircraft risk to TMI-l 44 160 was prepared in 1973 there was one scheduled flight per day by an air carrier using a commercial aircraft in excess of 200,000 pounds and occasicnal flights of military aircraft in excess of that weight, but that by the time of preparation of the Safety Evaluation Report for TMI-2 in 1976 there was no longer any scheduled commercial air service using aircraft above that weight, two flights per day by chartered jet air-craft of unspecified sise, and approximately once-weekly flights by military aircraft in excess of 200,000 pounds (Lockheed C-5A).
Of the chartered aircraft traffic, approx-imately one flight per month would be expected to be a Boeing 747-class aircraft.
Question by Dr. Jchnson:
"Mr.
Vallance's testimony in these hearings cites air-craft crash data in the vicinity of airports for the period 1968 through '75.
The data indicates that there were 46 crashes for about 80 million operations and results in a number of about
-6 0.5 times 10 crashes per operation.
"In the FSAR, the data for the period 1956 through '65 is used And during that period of time for roughly the same number of operations the total number of crashes in the proximicy of airports is 27, which gives a considerably lcwer value of crash per cperation.
"Now, I don't understand if as the testimony in the pro-ceeding indicates that the crash probability per operation is dl.5 '.# G.1 m-m
supposedly coming dcwn, the data for these tuo more or less equivalent periods show that the crash probability is going up per operation.
Do you have any feeling for why the dis-crepancy?"
(Tr. 82-3)
Supplemental Answer:
The accident rates shown in the FSAR for the period 1956-65 and in Mr. Vallance's updated probability estimates for the period 1968-75 are not comparable.
The accidents considered in the FSAR model, as tabulated in Table 2.2-4, included only accidents where one or more fatalities cccurred, excluded accidents occurring en the runway before a takeoff or after a landing, and excluded U.S.
air carrier accidents occurring outside the continental United States.
(F S AR, p.
2.2-4)
The accidents considered in Mr. Vallance's updated mcdel included all accidents where the aircraft was doctroyed, included accidents on the airport runway, and included acci-dents of U.S.
air carriers occurring abroad.
(Vallance Testi-mcny at p.
6 and Figure 2)
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.o e-T U;;ITED STAT": OF A:IRTCA
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METI'.0POLITA:I EDISO:! CCMPA rf,
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(Three Mile Island Unit
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I hereby certify that I have this day served the foregoing document (s) upcn each persen designated on the of ficial service list ec= piled by the Office of the Secretary of the Ccemission in this proceeding in accordance cith the requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the 1uclear Regulatory vemmission's Rules and Regulations.
Cated at Washington, D.C. this i-- -
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1TCLEAR REGL" ATORY COM'i!SSION In the Patter of
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MI3CPOLITA EDISCN COMPANT,
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Docket No. (s )
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(Three ' tile Island, Unit 2)
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Edward Luton, Esq., Chairnan Chauncey P. Kepford Atenic Safety and Licensing 2 card 1433 Criando Avenue U.S. ?,'uclear Regulatory Cc=issica State College, Pennsylvania 16801 Washington, D.C.
20535 Ecnoralle Karin W. Ca rter Mr. Gustave A. Licenberger Assistant Attorney General Atetic Safety and Licensing Board Departnent of Environ = ental Resources U.S. Nuclear Regulatory Co=sission 709 Realth and Welfare Building Washingten, D.C.
20555 Earrisburg, Pennsylvania 17120 Dr. Ernest O. Salo, Professor Miss Mary 7. Southard Fisheries Research Institute, W"-10 Citi: ens for a Safe Environnent College of Fisheries
?.0. Box 405 University of Washington Earrisburg, Pennsylvania 17108 Seattle, Washingten 98195 Dr.
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Reed Johnson Couns el f o r ','RC S taf f Atomic Safety and Licensing Appeal Cffice of the Executive Legal Director Board U.S. Nuclear Regulatory Cc=nission U. S. Nuclear Regulatory Co=issien Was hin g t en, D.C.
20535
- iashington, D.C.
20535 George ?. Trewbridge, Esq.
Shaw, Pitt_an, ?ctts & Trowbridge
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'Tashington, D.C.
20006 Alan S. Rosenthal, Esq., Chairman-afety and Licensing Appeal
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ashingten, D. C.
20535 Jerone-I. Sharinan, Esq.
At: ic Safety and Licensing Appeal Board U.S.
- ~uclear Regulator r Cc m ission
.iashin; ten, D.C.
20535 k.I ($ 4