ML20205B210

Comment on Potential Impacts of Patuxent River Complex Flight Operations on Calvert Cliffs Nuclear Power Plant

ML20205B210
Person / Time
Site:	Calvert Cliffs
Issue date:	03/18/1999
From:	Tanya Smith NAVY, DEPT. OF
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
References
FRN-64FR11071 64FR11071-00004, 64FR11071-4, SER-75-528, NUDOCS 9903310175
Download: ML20205B210 (4)

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S9 DEPARTMENT OF THE NAVY NAVMR STATION RECEIVED 22268 CEDAR POINT ROAD C G w/P PATUXENT RIVER. MARYLAND 20670-1154 1999 f!AR 22 M 8: 30

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5726 Ser 75/528 [hgd f /f77 W I 8 l999 Y Ms. Shirley Ann Jackson, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Dear Ms. Jackson:

A member of my staff received a copy of a letter that Dr. Gerald Mazetis sent you regarding the potential impacts of Patuxent River Complex flight operations on the Calvert Cliffs Nuclear I Power Plant. Dr. Mazetis also expressed his concerns in a formal comment to our Final Environmental Impact Statement for increased Flight and Related Operations in the Patuxent River Complex (FEIS). The following background information and specific observations relative to Dr. Mazetis' comments may help the Nuclear Regulatory Commission in reviewing this case.

The Patuxent River Complex consists of the test areas under the exclusive control and scheduling authority of the Naval Air Warfare Center, Aircraft Division (NAWCAD). The complex includes the Naval Air Station, Patuxent River Outlying Field (OLF) Webster Field, and the Chesapeake Test Range (CTR). The test areas include flight and ground test facilities, runways, special use and restricted airspace, aerial and surface firing range, and three targets in a restricted area of the Chesapeake Bay.

We undertook the Environmental Impact Statement (EIS) analysis to determine how we could meet our environmental stewardship mission while optimizing use of the current ranges and facilities that make up the Patuxent River Complex. The current range boundaries were designated by the Federal Aviation Administration in 1942. Our facilities, which we want to use I(

even more efficiently, are in place now that the Department of Defense (DOD) Base Realignment and Closure (BRAC) moves are complete. The BRAC process considered costs, benefits and global defense needs in consolidations DOD-wide. We summarized all of our operational projections, as identified in the Integrated Management Plan, in Table 2-9 of the FEIS. If you would like a copy the FEIS, I would be happy to forward one to you.

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E, The three alternatives considered in the FEIS focus on the efficient use of existing facilities and personnel in the Patuxent River Complex and provide for the continuation of and increase in l l RDT&E flight and related ground operations, and additional support for military training l activities. The preferred alternative (Operational Workload Alternative III) could accommodate l up to 24,400 flight hours per year. Operational Workload Alternatives I and II could I accommodate up to'20,700 and 22,600 flight hours per year, respectively. Implementation of any alternative would do three things. First, implementation would maintain existing boundaries i

' of the special use airspace and restricted surface areas in the CTR. Second, implementation

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would continue airfield daily operating hours at current, or slightly modified operating hours. I Third, implementation would require neither additional permanent and transient employees at NAS Patuxent River and OLF Webster Field nor construction of major new facilities beyond those constructed as a result of BRAC decisions, i

Our Record of Decision included a brief discussion of the Calvert Cliffs Nuclear Power Station.

However, as we explained to Dr. Mazetis in our FEIS response letter to him, the power station is outside of the Chesapeake Test Range. I have enclosed a map of the Chesapeake Test Range that l shows our proximity to the power plant. Patuxent River-based aircraft that might be seen in the vicinity of power plant would be doing standard take-offs and landings. Our prototype aircraft testing is done in restricted areas of the Chesapeake Test Range, such as near Hannibal and Tangier targets.

l In our letter to Dr. Mazetis, we explained that the power plant owner, Baltimore Gas and Electric (BG&E), has completed and submitted risk assessment reports to the Nuclear Regulatory Commission on aircraft-associated safety risks. BG&E submitted the first study, entitled l

Individual Plant Examination ofExternal Events, in August 1997. This study found tk probability of an aircraft crashing into the power station, including aircraft from the Patuxent 4

River Complex, to be 1.1x10 per year. BG&E identified about 25 percent of this low risk to be associated with our operations. In a second report to the Nuclear Regulatory Commission, called

Region Nos. 50-317/97-06, BG&E confirmed that Patuxent River Complex aircraft posed no safety hazard to the power station. BG&E is also conferring with us in their own EIS, which they are undertaking as part of their power station re-licensing application.

l Recently, we also learned from BG&E that the power plant's critical containment vessels were

! designed and built to withstand natural disasters, as well as the impact of a crash from a fully laden, fully fueled Boeing 707 airplane. The vast majority of aircraft tested at Patuxent River are considerably smaller than a Boeing 707.

I The Navy has tested prototype aircraft at Patuxent River since the mid 1940s. The types of test flights flown today and anticipated for the future are very similar to the test flights we conducted during the decades of the 1970s and 1980s. The main difference today is the extensive use of computer simulation and specialized ground test facilities prior to flight test. This approach has led to fewer flights and improved flight safety records. In fact, the annual flight hour rates for the 1970s and early 1980s were in excess of 30,000 flight hours per year, considerably higher than the preferred Alternative 111 of 24,400 flight hours per year. Because we use these new technologies and improved flight test techniques, our flight safety record for the decade of the 1990s is significantly better than the records from the 1970s and 1980s.

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l The Military Training Routes (MTRs) referred to in Dr. Mazetis' letter are not part of the *

• Patuxent River Complex. The MTRs are established and controlled by the U.S. Air Force and are available for all military services to use. Any changes to the MTRs would have to come from the U.S. Air Force and the Federal Aviation Agency.

1 I hope you find this infomiation helpful in responding to Dr. Mazetis' letter. I would welcome an opportunity to meet with you or your staff to discuss these issues in more detail. i Sincerely,

-l 'M ilMOTNY 5NMITH Executive Director

Enclosures:

CTR Map Copy to: Chief, Rules Review and Directives Branch, NRC Hon. Steny Hoyer, House of Representatives Cdr. Michael Waters, Office of Legislative Affairs i

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