ML20003G675

Testimony on Behalf of Util on Tx Pirg Contention 6 (Mccorkle Contention XI) Re Aircraft Hazards.Prof Qualifications Encl

ML20003G675
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	04/20/1981
From:	Woodward K PLG, INC. (FORMERLY PICKARD, LOWE & GARRICK, INC.)
To:
Shared Package
ML20003G672	List: ML20003G671 ML20003G673 ML20003G674 ML20003G675 ML20003G676 ML20003G677 ML20003G678
References
NUDOCS 8104300480
Download: ML20003G675 (12)

Text

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UNITED STATES OF AMERICA 40 1

NUCLEAR REGULATORY COMMISSION ,

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3 BEFORE THE ATOMIC SAFETY AND LICENSING BOl@ @[g\hy ]-

oJ 4 In the Matter of ) @

! ) 4 HOUSTON LIGHTING & POWER COMPANY ) Docket No. 50-4 A 5

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6 (Allens Creek Nuclear Generating )

Station, Unit No. 1) )

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8 TESTIMONY OF Kr.ITH WOODARD ON BEHALF OF HOUSTON LIGHTING & POWER CO. ON TEXPIRG 9 CONTENTION 6 (McCORKLE CONTENTION XI)

RELATING TO AIRCRAFT HAZARDS) 10 11 Q. Please state your name and place of employment.

12 A. My name is Keith Woodard and I am employed by Pickard, 13 Lowe and carrick, 1200 18th Street, NW, Washington, DC 14 20036.

15 Q. Please state your education and professional qualifi-16 cations.

17 A. Astatchentofmyeducationandprofessionalqualifica-18 tions is attached to this testimony as Exhibit KW-1.

19 0 What is the purpose of your testimony?

l 20 A. The purpose of my testimony is to address TexPirg 21 contention 6 (and McCorkle contention XI) which alleges 22 that:

23 The maximum credible accident has not been considered because the present safety and environmental analyses 24 do not consider the effects of a large airplane, such as a Boeing 747, crashing into the containment vessel.

26 The bases for TexPirg's contention are (1) that large plane 27 traffic has increased at least 30% in the last three years 1

28 and will be several percent higher before the plant is 1

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1 2, closed in about 40 years and (2) new airports capable of 3

handling such large airplanes have been proposed to be built closer to the site than present airports.

4 5 O. Will you describe the large aircraft activities in 6

the region in which ACNGS will be located?

7 A. Yes. Large commercial aircraft are present in the region g primarily in the vicinity of the large airports near Houston 9

and along airways designated by the FAA.

10 0 In its contention, TexPirg refers to a "large airplane" gg such as a Boeing 747. What type of aircraft have you 12 included in the category of large commercial aircraft?

13 A. Generally speaking the large commercial aircraft 14 are jets and include, for example, the B737, B707, B727, 15 DC9, DC8 and Bill. The very large jets such as the B747, 16 L10ll and DC10 are also included and are referred to as I

17 " heavy" aircraft.

18 Q. Where are the present locations of airports within 19 the Houston area which are capable of handling large air-20 craft including the Boeing 747?

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21 A. The Houston Intercontinental Airport in the largest 22 airport in the Houston region, and with its 12,000 foot 23 runway is the closest airport from the plant site capable 24 of handling large aircraft including the Boeing 747. Houston 25 Intercontinental is located about 47 miles northeast of 26 the ACNGS site. The Houston Hobby Airport, located about 27 48 miles east of the site, has a maximum runway length'of 28 7600 feet and, P.hus, cannot accommodate operations by

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1 2 aircraft much larger than the Boeing 727. There are 3 currently no other airports within a 50-mile' radius of 4 the ACNGS sita which are capable of handling large commercial 5 aircraft.

6 Q. Please describe the number of aircraft movements at 7 Houston Intercontinental and Hobby airports of the various 8 sized aircraft.

9 A. Presently there are about 335,000 aircraft operations 10 annually at Houston Intercontinental. About 60% of this 11 total are commercial air carrier type aircraft, and about 12 4% of the total are " heavy" jets over 300,000 pounds (e.g.,

13 like the Boeing 747 or the DC 10) . At Hobby, there are 14 about 350,000 operations annually of which only about 20%

15 are commercial air carriers up to the B727 size.

16 Q. Under NRC criteria, is an analysis with respect to 17 the probability of accidents of large aircraft landing and 18 taking off from Houston Intercontinental and Hobby airports 19 required for ACNGS?

20 A. No. Accidents associated with aircraft takeoffs and 21 landings, as well as "in-flight" operations, have been 22 the suoject of many statistical studies. From these studies, 23 it is wall-known that the accident rate decreases as distance 24 from an airport increases. It also follows that the higher 25 the number of operations at an airport, the greater the 26 chance of an accident. Based on the available accident 27 statistics, the NRC has developed criteria related to 28 distance and traffic for determining whether an aircraft

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2 accident probability analysis should be undertaken. The NRC L

3 criteria as set forth in its Standard Review Plan, Section 4 3.5.1.6 requires a statistical analysis for the following:

5. a. Any airport located within five miles of the 6 site.

7 b. An airport with projected operations greater 8 than 500 d2 movements per year located within 9 ten miles of the site.

10 c. An airport with projected operations greater 11 than 1000 d2movements per year located beyond 12 ten miles from the site, where "d" is the 13 distance in miles from the site.

14 The major airports (Mcuston Intercontinental and Hobby) are 15 both more than 45 miles from the ACNGS site, and both have 16 aircraft movements less than 2,000,000 which is approxi-2 17 mately the figure resulting from the 1000 d criterion.

18 Thus, under NRC criteria, an accident probability analysis 19 is not required for either airport.

20 Q. Have you. reviewed the projections for growth in air 21 traffic at both Houston Intercontinental and Hobby airports?

22 A. Yes. As previously stated, currant operations stand at 23 about 335,000 at Houston Intercontinental and at about 24 s50,000 at Hobby. The FAA in its " Terminal Area Forecasts" 25 dated February 1981, projects the 1992 traffic to increase 26 to about 526,000 and 494,000 for Houston Intercontinental 27 and Hobby, respectively. Commercial air carrier operations 28 of which only a small fraction are of the " heavy" type are

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expected to increase by less than a factor of two.

2l' Q. Assuming the increase in aircraft movements wh! h you 3

4 have just described, what effect do these projections have 5 on your analysis?

6 A. None. The projected figures still fall well below the 7 2,000,000 number of operations required by the NRC for a 8 probabilistic accident analysis. In addition, aircraft 9 safety has an established trend toward improvement which 10 reduces the risk even though the traffic is increasing. For 11 example, in the past 10 years the accident rate for commercial .

12 aircraft decreased by about a factor of 2 while the number .

13 of hours flown increased by only 20%.

14 Q. Have you reviewed the airways which pass within the 15 vicinity of ACNGS?

16 A. Yes. Inspection of aeronautical charts show that two airways occupy airspace near the proposed plant. These are 17 shown on Figure 1 attached. One is Victor Airway (designated 18 19 Vl98) which is utilized by aircraft flying below 17,000tt.

20 and the other.is " jet" route (designated J138) utilized by 21 aircraft operating above 18,000ft. There are several other 22 Victor and Jet routes also shown on Figure 1; however, the 23 closest approach of these routes is =cre than 5 miles from 24 the site.

25 Q. Do you have information on the number of large aircraft 26 flights which use J138 and V1987 27 A. Yes. The FAA estimates the current use of these airways 28 nearest the site to be about 34,000 annually'of which about O

o 1 2 40% are large commercial air carriers and less than 1% are 3' of the " heavy" type. This information supplied by the FAA 4 shows that,most (98%) of the flights along Vl98 and J138 are 5 eastbound, many of which are descending into Hobby Airport.

6 Very few are flying westbound along this airway. Heavy 7 aircraft would not be descending into Hobby since the runway 8 length cannot accommodate such large aircraft; therefore, 9 the " heavy" aircraft would pass over the site at altitudes 10 greater than 18,000 feet.

11 The J138 route is used primarily at very high altitudes 12 by jet traffic in level flight between the navigational aids 13 located at San Antonio and Hobby.

14 Q. Have you performed an analysis related to the probability 15 of "in-flight" aircraft accidents along these routes?

16 A. Figure 1 located all designated airways in the site 17 vicinity that are used by large commercial aircraft. The 18 FAA estimate of aircraft traveling along Vl98 and J138 are 19 all flying IFR (instrument flight rules) and therefore 20 include all commercial aircraft which are required to fly

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21 under such rules. The FAA estimates the actual number of 22 " heavy" commercial aircraft traveling along these airways to 23 be about 280 per year, and the number of large commercial 24 jets to be about 14,000 per year.

25 Since the airports are a considerable distance from the 26 ACNGS site, accidents associated with landing and takeoff E activities would not occur near the site. Therefore, the

-10 20 "in-flight" accident rate statistic of 7 x 10 accidents

1 2 per mile 51own is appropriate. We calculate the probability 3 (P) of an accident affecting the plant using the following 4 relationship from the NRC's Standard Review Plan (Section 5 3.5.1.6):

6 P=R*N*AN 7 In this equation R is the "in-flight" accident rate, N 8 is the number of large commercial or heavy aircraft flights 9 along the airway, 7 is the area of critical plant structures 10 and W is the width of the airway:

-10 11 P = (7 x 10-10) (280) (0.01) /9.2 = 2.1 x 10 per year

'9' 2 P = (7 x 10-10) (14,000) (0.01) /9.2 =

large commercial aircraft 1.0 x 10-8 per year 14 Thus, the probability of a large aircraft accident affecting 15 the ACNGS facility is extremely low, and under NRC criteria, 16 need not be furthered considered.

17 Q. Have you considered the-projected increase in flights 18 along these airways?

19 A. Yes.

20 Q. How does,this projected increase affect your analysis?

21 A. The FAA projects that for the year 1992, the commercial 22 aircraf t traffic is projected to double in the Houston area.

23 Therefore, if all other assumptions (including airway routing 24 and accides.t rates) remain unchanged, the probability of an 25 accident would double yielding 4.2 x 10-10 per year and 26 2.0 x 10-8 for heavy and large commercial aircraft, 27 respectively. The probabilities of an accident remain extremely 28 low and still well within NRC criteria requiring no further v, - - --- . - ,

1 2 consideration.

3 0 Have you examined the question of whether additional 4 airports will be built in the vicinity of ACNGS which would 5 be capable of handling large commercial aircraft?

6 A. Yes I have. Over the past several years, the FAA has 7 received applications for various sized airports to be 8 located generally 15-20 miles east of the site. Apparently, 9 the intent of several developers is to build " reliever" 10 airports in the Houston area to relieve congestion at Houston 11 Intercontinental and Hobby. Two proposals for such a 12 reliever airport included new airports in the vicinity of 13 Katy and Rosenberg approximately 15-18 miles east to northeast i 14 of the site. These airports would handle mostly privately 15 owned small planes with possibly 10% being twin-engine aircraft 16 operated by commercial air carriers. However, these applica-17 tions have now expired.

18 About two years ago, an application was filed with the 19 FAA for a larger airport referred to as "Hou-West." It 20 would also be. located about 15 miles east of the site.

21 However, the FAA reports that there is some uncertainty 22 as to whether the facility as currently proposed will be built.

23 The FAA estimates that, if built, this airport could have 24 100,000 to 200,000 operations annually most of which would 25 be general aviation with some commercial operations.

26 o. would a probability accident analysis for a hypothetical 27 airport located in the Katy-Rosenberg area be required under 28 NRC criteria?

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2 A. No. If a large airport (e.g., Hou-Wes t) were to be 3 located in the Katy-Rosenberg area about 15 miles from the 4 site, NRC criterion (c) would apply only if the airport 5 had 1000 d 2 operations or about 225,000 annual operations.

6 Since the FAA projects 100,000 to 200,000 operations annually 7 for such a facility, a detailed accident probability analysis 8 would not be required by the NRC.

9 Q. What are your conclusions?

10 A. Based on this evaluation, the current aircraft operations 11 in the ACNGS site region do not pose a safety hazard. Few 12 large B747 type " heavy" aircraft currently use airspace near 13 the site and there is no reason to expect that the number of 14 large commercial operations combined with accident rate 15 statistics would lead to an accident probability at the site 16 high enough to justify plant design changes to accommodate 17 the effects of such an accident.

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1 Exhibit KW-1 2 EDUCATION AND PROFESSIONAL QUALIFICATIONS 3 Keith Woodard 4 I am a nuclear engineer with 17 years experience in 5 engineering consulting, safety analysis, and nuclear power 6 plant siting evaluation. I am presently employed by Pickard, 7 Lowe and Garrick, Inc. of Washington, DC and Irvine, California.

8 My office address is 1200 18th Street, N.W., Suite 612, 9 Washington, DC, 20036. Pickard, Lowe and Garrick, Inc. has 10 provided consulting services to electrical generating 11 utilities concerning all aspects of nuclear power development 12 since 1956. A considerable portion of the firm's work is 13 related to siting studies and, in particular, evaluation of 14 environmental impacts due to power plant operation a'nd 15 evaluation of outside activities to determine their potential 16 for affecting safe plant operations.

17 I received a Bachelor of Arts degree in Physics at 18 Occidental College, Los Angeles, California in 1961. I 19 received a Master of Science degree in Nuclear Engineering 20 from UCLA in 1963. From 1963 to 1967 I was a project leader 21 with the U.S. Atomic Energy Commission, Division of Reactor 22 Licensing, where I was responsible for safety and siting 23 reviews of nuclear facilities. Since 1967 I have been 24 employed by Pickard, Lowe and Garrick, Inc., where I have 25 been responsible for nuclear safety and siting analyses. I 26 have conducted a number of studies which considered hazards to 27 nuclear plants due to man-made activities including ~a number of 28 aircraft accident probability studies. I am a member of the m

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1 American Nuclear Society, the Air Pollution Control Association 2 and the American Meteorological Society.

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