ML20052G124
| ML20052G124 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/10/1982 |
| From: | Hickey W OHIO, STATE OF |
| To: | |
| Shared Package | |
| ML20052G119 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8205140329 | |
| Download: ML20052G124 (13) | |
Text
.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
) Docket No. 50-155-OLA CONSUMERS POWER COMPANY
) (Spent Fuel Pool
)
Modification)
(Big Rcck Point Nuclear Power Plant)
)
TESTIMONY OF CAPTAIN WILLIAM P.
HICKEY, JR.
My name is William P. Hickey, Jr.,
I am.a captain in the Ohio Air National Guard ("OANG" ) assigned with.180th Tactical Fighter Group stationed at Toledo-Express Airport, Swanton, Ohio.
I received a Bachelor of Science Degree in Mathematics from Lawrence Institute of Technology, Southfield, Michigan, in 1976.
I have also received extensive under-graduate training in physics.
My current position within the OANG is that of an instructor pilot in the A-7D fighter aircraft at the 180th Tactical Fighter Group.
I completed U.S.
Air Force under-graduate flying training in December 1972, and I achieved l
combat-ready status in the F-100 aircraft in July 1973.
I became an instructor in flying the A-7D ground attack fighter in 1978 at the tactical fighter school in Tucson, Arizona.
My cumulative flying time is approximately 3,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, of which 8205140329 820510 PDR ADOCK 05000155 PDR y
. 1,728 hours0.00843 days <br />0.202 hours <br />0.0012 weeks <br />2.77004e-4 months <br /> involved flying time in jet fighter aircraft.
My military aeronautical rating is Senior Pilot.
I have a number of duties in addition to my responsi-bility as an instructor.
These include Weapons and Tactics Officer, Electronic Combat Pilot, and Manager of Special Use Airspace.
I have also served previously as Group Flying Safety Officer.
As Weapons and Tactics Officer, I have per-formed various probability analyses of weapons effectiveness.
I have also performed probability analyses with respect to defense penetration under wartime conditions.
I manage the use of the airspace within which our unit conducts flying training as required by the Tactical Air Command of the U.S. Air Force.
I received formal training in Airspace Management from the Tactical Air Command.
The Wcl-verine Military Operations Area
(" Wolverine MOA"), as well as several military training routes, were established by me in my capacity as Airspace Manager.
They remain under my management to the present time.
Based upon my educational background and work expe-i rience, I believe I am qualified to answer O'Neill Content. ion l
IID as it pertains to the Ohio Air National Guard.
I r
. THE WOLVERINE MOA.
The Wolverine MOA was established in November 1981, and as shown on Exhibit A to my testimony, it is roughly a 45-mile square.
Exhibit A is a tactical pilotage chart, and it is required as a navigational aid whenever the Wolverine MOA is used.
Charlevoix Airport is within the Wolverine MOA and, as a consequence, a 5,000 feet no-fly area was estab-lished'to protect air traffic from the airport.
The no-fly area is annotated on Exhibit A.
The no-fly area is enscribed by a circle five miles in radius centered on the Charlevoix Airport, with an upper limit of 5,300 feet above mean sea level.
A normal no-fly area consists of a three-mile radius from the airport of interest.
However, the area was extended to five miles in the case of the Charlevoix Airport in order to include the Big Rock Point plant.
The plant is located about one mile inside the eastern perimeter of the no-fly l
area.
Three military training routes pass through the i
Wolverine MOA.
The VR 1634 and VR 1636 training routes, which were established by me in October 1981, pass the Big Rock Point plant at their closest points at 5.2 and 33.4 statute
(
miles, respectively.
The IR 601 military training route is i
under the management of the U.S. Air Force, and it passes at i
its closest point to the plant at 11 nautical miles.
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, s s
s
, ~.., gha primary reason for A-7D aircraft training in the Wolverine MOA is to challenge the radar tracking equipment at the Bayshore ' radar site with the A-7D special electronic gear.
s The 1801h Tactic'al Fighter Group of the OANG is the only fighter' unit in'the region (active or reserve) that possesses this equipnient.
A military operations area provides the nec-essary maneuvering environment that cannot be obtained by the use of the more constraining area of a military training route.
A tactical fighter's greatest asset, both for attack and de-fense purposes, is its excellent maneuverability.
- Hence, training areas like the Wolverine MOA are needed to provide needed space for fighter pilot training.
Moreover, pilots of A-7D's must train over fixed land reference points in order to practice precision navigation and weapons delivery.
The Bay-shore ~ site is such a reference point.
Training over open water, such as that employed by the U.S. Air Force's use of IR 601 for the B-52 bombers, will not meet the requirements for t
training A-7D pilots in precision navigation and weapons de-livery.
_I should emphasize that all weapons delivery within s
thd Wolverine MOA is simulated.
No actual weapons are used.
i i
OSE OF THE WOLVERINE MOA.
1 1
The use of-the Wolverine MOA is limited by the l
Federal' Aviation Administration because of the potential for l
l
. operational interference with general aviation aircraft operating under instrument rules of flight.
The Wolverine MOA can be used no more than twice a day with each use limited to 20 minutes.
Actual figures show that the Wolverine MOA was used 40 times (involving 99 aircraft) in 1980* and 23 times I
(involving 66 aircraft) in 1981.
The 180th Tactical Fighter Group was almost the exclusive user of the Wolverine MOA during 1980 and 1981.
The U.S. Air Force 87th Fighter Inter-coptor Squadron and the Indiana Air National Guard, 122nd Tactical Fighter Wing used the Wolverine MOA twice, and the Michigan Air National Guard, 127th Tactical Fighter Wing and the Minnesota Air National Guard, 149th Tactical Reconnais-sance Group used the Wolverine MOA once during these two years.
The use of the Wolverine MOA requires clearance from the Minneapolis Air Route Traffic Control Center (ARTCC) of the FAA.
Other units desiring to train within the Wolverine MOA must first contact the 180th Tactical Fighter Group of the OANG.
The 180th Tactical Fighter Group would then schedule I
The 1980 figures are more representative of future use than the 1981 figures because the Wolverine MOA was not used during 1981 FAA Air Controllers' strike.
Data prior to 1980 has not been retained by the 180th Tactical Fighter Group.
t
. the training request with the ARTCC, but only after the FAA/
Military Letter of Agreement and restrictions "aferred to earlier have been sent to the requesting unit with this infor-mation conveyed to the unit's participating L. embers.
- Finally, I should note that the training routes cannot be used by others while the Wolverine MOA is in use.
TIIE JULY 22 FLIGHT.
On July 22, 1981, I briefed and led a flight of two A-7D aircraft on a tactical training mission in the Wolverine MOA.
This mission was part of the formal qualification train-ning in the A-7D aircraft for my wingman.
The wingman was himself a highly qualified tactical pilot, formerly an instruc-tor in F-lll fighter aircraft and presently employed as an airline pilot flying Boeing 727 aircraft.
This mission began with an extensive briefing that commenced two hours prior to takeoff.
Included in this brief-ing was a review of the FAA/ Military Letter of Agreement which governs the Wolverine MOA and delineates associated restric-l tions and hazards.
The nuclear power station at Big Rock Point was one of these points of concern that received speci-fic attention.
The plant was visually characterized to my wingman as a large blue dome on the Lake Michigan shoreline about five miles west of the Bayshore Strategic Training
. Range, with coordinates 45' 21" north, 85' 12" west.
During the briefing, I stated that the plant, as shown on the tacti-cal pilotage chart, was in a five-mile no-fly area, centered on Charlevoix Airport, with an upper limit of 5,000 feet above mean sea level (about 4,200 feet above the plant).
The July 22 flight entered the Wolverine MOA from the north on the IR 601 low-level training route for the purpose of conducting a training mission in connection with i
the U.S. Air Force radar site at Bayshore, Michigan. From Isle Aux Galets, we proceeded south in a direct line toward Bay-shore at an altitude of 500 feet.
At about seven miles from Bayshore, we made an evasive turn west of our course.
This maneuver was prompted by a signal from the radar site.
We headed back toward the Bayshore site at the conclusion of this maneuver.
We were about five miles from the nuclear power plant at this point in the flight, and I pointed out the plant to my wingman.
He acknowledged visual contact, and we soon passed to the east of the Big Rock Nuclear Power Plant on a southwest heading.
Our altitude was about 500 feet above ground level and climbing.
My aircraft passed no closer than 1-1/2 miles from the plant.
My wingman, who was about 4,000 feet to my right and rear, stated that he did not come closer than a mile to the plant.
At no time did we overfly the Big Rock plant at
. low altitude.
The entire flight time from the Isle Aux Galets to Bayshore was approximately two minutes and 25 seconds.
After overflying the radar site at Bayshore, we made a climbing left-hand turn to 6,000 feet and headed to a posi-tion west of Charlevoix.
From this point and altitude, the flight commenced several runs against the radar site which may have placed our flight path over the power plant, but at an altitude of about 6,000 feet, 1,000 feet above the no-fly zone.
The flight then exited the Wolverine MOA and returned to Toledo.
THE ADDITIONAL NO-FLY AREA.
As a result of conversations with Consumers Power Company personnel after the July 1981 flight, the no-fly area around Charlevoix Airport was enlarged by extending the no-fly area, using Big Rock Point as the center point of reference, in a two-mile arc east of the plant with a ceiling of 1,500 feet above ground level.
This new no-fly area is shown on Exhibit A, and it is in addition to the previous one which is still in effect and requires direct overflights of the plant l
l to be above 5,000 feet mean sea level.
The specific purpose I
of the new no-fly area is to keep low-level aircraft more than two miles away from Big Rock Point.
This action was taken 1
because, as a matter of policy, the 180th Tactical Fighter
(
l
_9 Group, as a good neighbor, desires to cooperate fully to alleviate concerns of the public.
The new no-fly area cannot exceed the two nautical miles radius due to flight safety and operational limitations.
Specifically, at least five miles visibility must prevail before flying below 1,500 feet is permitted.
In such a circumstance, the pilot of an A-7D has three miles to identify the plant and to turn safely before it would encroach upon the two nautical mile no-fly zone.
If the no-fly zone were expanded, a pilot would have less than three miles to avoid the zone, a difficult maneuver to achieve without incurring a risk of overstressing the aircraft or jeopardizing flight safety.
Users of the Wolverine MOA are made aware of the new no-fly area during briefings prior to flight.
Briefings are based on the FAA/ Military Letter of Agreement and attachments which are furnished to all users.
The applicable provisions of the Letter of Agreement with attached flight restrictions must be reviewed by each aircrew prior to flight within the j
Wolverine MOA.
Each unit is responsible for enforcement of all flight directives, regulations and restrictions.
The military values highly the limited airspace privileges that it uses; and therefore, violation of these rules is viewed with seriousness by the unit commanders.
Disciplinary actions that l
l
l j may be taken are loss of aeronautical rating, loss of commis-sion and/or additional punitive measures.
CONCLUSION.
I believe the activity in the Wolverine MOA is a safe operation.
There has never been a crash involving a fighter aircraft in this airspace.
Nevertheless, I will analyze the potential for an accident.
To analyze the annual risk potential of such a catastrophy requires two quantities:
low-altitude overflight probability of the plant and the probability of an accident involving the plant, given an overflight.
No low-level altitude overflights of Big Rock Point have occurred during the four-year existence of the Wolverine MOA.
Moreover, the likelihood of an overflight by an A-7D is much less than that for a B-52 bomber.
This is true because l
B-52 bombers fly all-weather, low-level missions u:ing elec-tronic navigational equipment.
On the other hand, the Wol-verine MOA is used only in the daytime, and A-7D's fly below l
1,500 feet only when prevailing weather conditions permit at least five miles of visibility.
In addition, the pilot of an A-7D uses visual contact with the ground when flying below 1,500 feet as the primary means of orientation.
Nevertheless, for purposes of conservative analysis, I will assume that the
. July 22 flight constituted a low-level altitude overflight.
I will also assume, again for the sake of conservatism, that there has been one similar overflight for each of the three previous years the Wolverine MOA has been in operation.
This then would establish a highly conservative low-level altitude overflight rate of one per year.
The low altitude flying major accident rate of the A-7D aircraft, operated and maintained by the Air National Guard, is reported to be one per 300,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.
This figure was obtained from the National Guard Bureau Safety Office.
The Ohio National Guard, which has three squadrons of A-7D's, has never had a major accident with this aircraft while conducting low-altitude training.
Although I have never been a member of an accident investigation team, I have observed at close hand the sites of several fighter crashes.
In my opinion, it would take vir-l tually a direct impact or impact just short of the reactor to inflict serious damage to it by a high-speed fighter-sized aircraft with a shallow impact angle.
Ground impact beyond, left, or right of the building, shculd not cause critical damage to any substantially constructed surface structure because the high-energy debris fans out beyond the impact crater in a narrow wedge-shaped projection (as viewed from above).
However, I will assume a critical length for impact i
=_
- beginning one nautical mile in front of and continuing to the power plant.
Any A-7D having a flight path along this line would transcend it in 8.6 seconds at tactical airspeeds.
The probability P of an accident involving the g
plant given a low altitude overflight would in this case be:
accidents hours P
=
g X
X critical flight flight hours seconds time
-8 A"
X X
8.6 =
1 x 10 300,000 3,600 In other words, there is less than one in a one t
hundred million chance that such an accident could occur.
This figure should remain conservative in the future due to trends in the two quantities that determine it.
First, tha actions taken to expand the no-fly area around the site can only serve to lower the already conservative prediction.
Second, the overall accident rate for fighter aircraft, in-cluding the A-7D, is declining.
The accident rate for the U.S. Air Force in general is the lowest since safety records began in 1926.
The A-7D as operated by the Air National Guard has the lowest accident rate on record, in fact lower than those years it was in use by the regular Air Force.
This low accident rate can be attributed to the experience and profes-sionalism of Air Guard members.
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