ML20031D597
| ML20031D597 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/02/1981 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20031D553 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8110130526 | |
| Download: ML20031D597 (13) | |
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TESTIMONY OF THOMAS C. BORDINE CONCERNING O'NEILL CONTENTION IIC The following testimony is a response to O'Neill Contention IIC which states:
Licenaee's plan which provides for makeup water to replace water being lost from the pool at rates of up to 200 gallons per minute, is deficient because it does not consider the impact of the lost water on health and safety or on the en-vironment.
(J~3 This contention assumes that a makeup capacity of 200 gallons per minute is necessary to replace water lost from the spent fuel pool; this assumption is erroneous.
In actuality, the maximum makeup capacity needed is 11 gpm; this figure was calculated by Consumers Power Company in its April 23, 1979 submittal " Spent Fuel Rack Addition Des-cription and Safety Analysis".
The contention represents a misinterpretation of another statement from the Safety Analysis at pages 2-1, 2-3:
" Fuel pool makeup water is supplied from the Treated Radwaste System.
A secondary backup supply of water is available from the fire systems.
This would be utilized to replenish the fuel pool water inventory in the event of loss of pool water up to 200 gpm."
8110130526 811005 PDR ADOCK 05000155 T
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The 200-gpm 4'-
3 simply reficcts existing available water capacity for t.ie fire system.
This capacity was designed for fire-related purposes, not for the rate at which water could be lost from the fuel pool.
The correct figure for water loss from the pool f 11 gpm, reflects an evaporation rate of the pool water during boiling in the unlikely event that emergency power is not available, such that both spent fuel pool cooling loops fail to operate.
The analysis assumes that this event occurs during the peak heating period when a full reactor fuel core is off-loaded into the expanded pool and the pool
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is filled to capacity.
The figure of 11 gpm for the maximum capacity needed is also supported by the conclusion in the NRC Staff's May 15, 1981 Safety Evaluation Report, which states at pages 3-4:
" Based on our review, we find that the Licensee's commitment to provide the capability to supply 11 gpm of makeup water to the spent fuel storage pool, actuated from outside containment, is acceptable."
With respect to the impact of the lost water, the 11 gpm of water lost from the pool will not escape to the environment but will remain within the containment enclosure.b Upon condensation, the water will be collected by the en-
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closure sump.
The 50-gpm capacity of the enclosure sump is c1 5
7.,,
V more than adequate to handle the 11-gpm boil-off rate.
The collected water will then be processed through the radwaste system under applicable plant procedures which reflect the requirements of Title 10 of the Code of Federal Regulations, Part 20 and Part 100.
Because the water lost from the pool will remain within containment and then be processed through the plant's radwaste system, such water poses no environ-mental hazard.
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O'NEILL CONTENTION IID A.
THE CONTENTION The Licensee has not adequately provided for the protection of the public against the increased release of radioactivity from the expanded fuel pool as a re-sult of the breach of the con-tainment due to the crash of a B-52 bomber.
B.
MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD 1.
A B-52 Air Force bomber overflew the Big Rock Point plant on July 5, 1979 (Deposition of Major Betourne and Mr. Thomas, dated July 13, 1981, (hereinafter referred to as the "Betourne/ Thomas Depo."), Tr. 94 ; Exhibit #3, Jaly 30, 1979, letter, Lancaster to Silver).
2.
As a result of the July 5, 1979, overflight, the Air Force was requested to update their previous analysis of the risk associated with an accident involving a U.S. Air Force aircraft using the low-level training route and the Big Rock Point nuclear power plant, and such an analysis was performed by Major Gary P. Betourne and Mr. Clayton Thomas on i
l
. January 2, 1580.
(Betourne/ Thomas Depo., Tr. 9-10; 4
p k-]
Exhibit #1, January 9, ISSO, letter, Nichols to Kantor and attached January 2, 1980, Risk Analysis).
3.
The January 2, 1980, Risk Analysis indicates that, based on conservative assumptions, the probability of a crash of an Air Force aircraft within the 3-nautical-miles square enclosing the Big Rock Point plant is less than one in a hundred million per year. (Bet urne/ Thomas Depo., Exhibit #1, January 9,
1980, letter, Nichols to Kantor, p.
1, and i
attached January 2, 1980, aisk Analysis, p. 2).
4.
The probability of "less than one in a hundred million" is somewhat larger than the value of 1.47
-10 X 10 given in the original Risk Analysis per-formed by the U.
S. Air Force in 1971. (Betourne/
Thomas Depo., Exhibit #1, January 2, 1980, Risk Analysis, p.
2; and Exhibit #2, May 19, 1971, letter, Col. Campbell to Campbell and attached Risk Analysis dated April 26, 1971); nevertheless, there is no appreciable change in risk to the Big Rock Point plant. (Betourne/ Thomas Depo., Tr. 34).
5.
The 1971 Risk Analysis was prompted by the crash of an Air Force B-52 aircraft in Lake Michigan near the general vicinity of the Big Rock Point l
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plant.
(Betourne/ Thomas Depo., Exhibit #2, April 4
j 26, 1971, Risk Analysis, pp. 4-5).
6.
The January 2, 1980, Risk Analysis updated the i
1971 Risk Analysis, and there, focus concerned Air Force flights of B-52's and FB-lll's over the S.A.C.
Bayshore Strategic Training Range. (Betourne/
Thomas Depo., Tr. 32-34).
7.
The S.A.C. Bayshore Strategic Training Range is a i
low-level navigation training route used by the U. S. Air Force to train aircraft in low-level bombing missions. (Betourne/ Thomas Depo., Tr. 23-24).
8.
The Big Rock Point plant, at the time of the January 2, 1980, Risk Analysis, was located near the end of the Buyshore route with Air Force aircraft passing 5.7 nautical miles east,of the plant.
(The Air Force radar tracking and scanning l
site called Bayshore is located 4 nautical miles east of the Big Rock Point plant.)
(Betourne/ Thomas Depo., Tr. 25-26, 28).
9.
B-52's and FB-lll's are the only Air Force aircraft that use the Bayshore route, and they come from various air bases in the United States.
(Betourne/
Thomas Depo., Tr. 23-24).
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10.
U. S. Airforce aircraft using the Bayshore route are tracked by radar from the Bayshore tracking l
station, and if the aircraf t deviatcs from the center line of the route beyond 4 nautical miles, the mission is considered a failure, and the pilot is told to abort the mission, climb to a higher altitude, and exit the route.
(Betourne/ Thomas Depo., Tr. 59-61).
11.
The January 2, 1980, Risk Analysis, for conserva-tism, defined the Big Rock Point plant as a 3-nautical-miles square with the plant in the center of the square; and it was assumed that any crash within the square caused damage to the plant.
(T;etourne/Thorcas Depo., Tr. 38-45).
12.
Based on material facts 8, 10, and 11, an Air Force aircraft that deviated 4.2 nautical miles west of the center line of the Bayshore route and also failed to abort the mission and depart the area by gaining altitude would overfly the eastern end of the 3-nautical-mile square.
(The deviation would have to be 5.7 nautical miles to overfly the plant itself.)
(Betourne/ Thomas Depo., Tr. 38-45 and 59-61).
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d,, 13.
The January 2, 1980, Risk Analysis used bomb run data at 1979 of 2,986 runs, and it was determined that 60 instances of gross navigational error (breaking the 4-nautical-miles barrier) occurred in 1979.
(Betourne/ Thomas Depo., Tr. 50-55).
14.
Although thu 60 gross navigational errors occurred in both directions, i.e.,
in the direction of Big Rock Point and in the opposite direction away from the plant, all 60 errors were assumed to have occurred in the direction of the plant for purposes of the Risk Analysis.
(Betourne/ Thomas Depo., Tr.
52-55, 62).
J 15.
Gross navigational errors generally are caused by navigator error; but for purposes of conservatism, the Risk Analysis took no credit for navigational aids that could enable a erring navigator to correct the course.
(Betourne/ Thomas Depo., Tr.
56-57 and 64-66).
16.
It was assumed for purposes of the Risk Analysis that a total communications failure with the training aircraf t occurred simultaneously with the occurrence of a gross navigational error in the direction of the Big Rock Point Plant.
(Betourne/
Thomas Depo., Tr. 61).
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-s-17.
The Risk Analysis, again for purposes of conserva-tism, took no credit for the possibility of course correction, even assuming radio failure, that might result from the availability of a back-up radio at Bayshore, back-up power sources at Bayshore, or substitute communications from the Air Traffic Control Center at Minneapolis.
(Betourne/ Thomas Depo., Tr. 67-72).
18.
The Risk Analysi.s used representat!.ve crash data accumulated since the April 26, 1981, Analysis.
(Betourne/"tomas Depo., Tr. 45-50).
19.
Based on material facts 10-18, the January 2, 1980, Risk Analysis determined the probability of a crash of either a B-52 or FB-lll at the Big Rock Point plant to be one in a hundred million per year, an extremely low probability and highly unlikely event.
(Betourne/ Thomas Depo., Tr. 84-85).
20.
The U. S. Air Force, since the July 5, 1979, overflight of the Big Rock Point plant, has taken a number of corrective actions to further assure that overflights of Air Force aircraft will not occur in the future.
(Betourne/ Thomas Depo., Tr.
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94-95).
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The principal corrective action taken by the Air Force was to change the Bayshore route from one over land passing within 5.7 nautical miles east of Big Rock Point to a route over Lake Michigan passing at the nearest point 11.5 nautical miles northwest of the plant.
(Betourne/ Thomas Depo.,
Tr. 95-98, and Exhibit #5).
22.
No credit was take~ in the January 2, 1980, Risk Analysis for the corrective actions taken by the U.
S. Air Force, including the change ir. the Bayshore route indicated in material fact 21; and as a result, the probability of a crash at Big Rock Point is even less than one in a hundred million per year, perhaps one in a billion per year.
(Betourne/ Thomas Depo., Tr.98-100).
C.
DISCUSSION The January 2, 1980, Risk Analysis performed by Major Betoorne and Mr. Thomas on behalf of the U.
S. Air Force, as further explained in their joint Deposition, amply demonstrates that the probability of a crash at Big Rock Point (10-8) is so low that such an event poses no hazard to the safe operation of the Big Rock Point plant.
The Betourne/
Tatemas Risk Analysis was performed, as indicated in the Ci i
y
^ U statement of material facts, in a rigorous and conservative manner; and because of the various conservatisms used the Risk Analysis overstates the risk to the safe operation of the plant.
If there was any doubt on this score, it was completely erased when the Air Force moved the Bayshore route.
The present Bayshore route passes 11.5 nautical miles northwest of the plant over Lake Michigan as compared to the previous route analyzed by the Betourne/ Thomas Risk Analysis, namely, an overland route passing 5.7 nautical miles east of Big Rock Point.
No incidents involving U. S. Air Force aircraft flying over Big Rock Point have occurred since July 5, 1979.
However, on July 22, 1981, three flyovers occurred.
It wac later determined by Consumers Power Company and confirmed by the U. S. Air Force at the Bayshore tracking site, that the aircraft were not Air Force planes.
The planes were identified as belonging to the Ohic Air National Guard (see memorandum dated July 23, 1981, from R. M. Marusich, which is attached hereto).
No factual issue has been raised by Mr. O'Neill which controverts the facts established in the Betourne/ Thomas Risk Analysis and their joint Deposition; and accordingly, Licensee is entitled to summary disposition of the Contention as a matter of law.
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D Wi)uchman, P-2h-121A It E Ci: AVED MHoffmn, P-2k-ll8A HW31nderman, P-2h-115B JUL 29 1981' k((}ll NUCLEAR UCENSING 00Ei IU
((U' RM".aru:ich, P-2h-110 e'
[,'u =a m-rn wl DATc July 23, 1981 gggjjpgjjy Ohio Air National Guard-Flyover of Big Rock Point Plant l as T t mN A L Comarspohoacc 7
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RNM 81-2h cc SEP 1 a 1981 o'
CRAbM, Big Rock Point Plant 6
U ul On Wednesday, July 22, the Ohio Air National Guard conducted three
" fly-overs" of Big Rock Pcint Plant.
The incident cecured at e. bout 2:25pm.
't Col Robert Rajevski (pronounced Ra-cu-ski) of the Bayshore Tracking Station (61st Squadron, telephone (616)3h7-8731) determined that the flyover was conducted by tne Ohio Air htional Guard who were in training at Camp Grayling.
Captain Hickey of the Ohio Air National Guard (headquartered at Toledo Airport, telephone (h19)S66-2036) confirmed that it was their planes.
He said that the first flyover was at lov altitude using the fighter section of the bomber corridor 5 5 miles east of the plant.
The jet fighter recticn is an arch (te didn't mention it's vidth) on either side of the bomber corridor. The lcw flyover used the plant side of the jet area.
The second and third flyovers vere directly over the plant but at an elevation of greater than 6000 feet.
Captain Hickey believes that both of tnese corridors are acceptable for his use. Both he ar.d Lt Col Rajevski are avare that Big Rock Point Plant is a nuclear power plant an2 that they should not get close to it.
Both also understand our concern about their flyovers.
Lt Col Fajevski stated that the Air Force now uses a corridor over Lake Michigan (from West of Charlevoix to Beaver Island to Mackirac Isle.nd) for their training runs.
This corridor has been used since May, 1980.
Lt Col Rajevs ;i does not knew of a publiched minimum altitude for flyovers over Big Rock Point Plant.
The Big Rock Point Plant staff t. aid that the planes vere er.tremely 1 cud
("they sounded like they were just above the trees").
The plant staff who saw the planes out their vindows believed their rltitude to be much lower than 6000 feet. Bob Schrader said that it sounded like they were coming through the vindow, and that pecple saw them through their vindows.
He stated that they could not have seen the plancs if they were at 6000 feet.
I confronted Captain Hickey with the above statements on Thursday, July
- 23. He stated that he was the leader of the three planes and was in one of them. They came in over the lake. At about 7 miles from the plant, he cautioned the others to stay away fron the plant.
His number two man peeled off and c:une in at 500 feet,115 miles east of the plant.
The
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others came in over Charelvoix.
They met and went back over the plant
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at 6000 fect.
Bayshore has no record of the altitude or location of g
the flyover.
l DEPARTMENT OF THE AIR FORCE W ' /A HEADQUARTERS UNITED STATES AIR FORCE WASHINGTON, O C.
20330 q.
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!T'.'I JACL 2 8 SEP 1981 Witnesses' Pen and Ink Corrections to Record of Deposition Isham, Lincoln & Beale Counselors a t Law ATTN:
Mr. Gallo 1120 Connecticut Ave., N.W.
Suite 325 Wa shington, D.C.
20036 On 13 July 1981, two Air Force employees, Major Gary P. Betourne and Mr. Clayton Thomas, were deposed in conjunc tion with Docket No. 50-155-oLA (Spent Fuel Pool Expansion) before the Nuclear Gegulatory Commission.
The original record of this deposition was forwarded to me in order to obtain the review and signature of the above witnesses to the record.
On 24 August 1981, I verified tha t the above witnesses had made pen and ink corree-tions to the record prior to entering their signa tures on the record.
Major Betourne had made red pen and ink changes on pages 7 - 9, 15, 19, 22, 25, 29, 31 - 32, 56 - 58, 62 - 66, 71, 76, 79, 88, 90, 92 - 93, 96, 39, 112 - 114, and 119.
Mr. Thomas had made a blue pen and ink change on page 83 In each case, the witnesses made these correc tions prior to signing the deposition on 24 August 1981, i
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TITRUD, Ca pta in, USAF embe M Genera 1 Litiga tion Division Office of The Judge Advocate General i
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