ML20207M484

Comments on NPP Draft Suppl to Generic Environ Impact statement,NUREG-1437,suppl 1

ML20207M484
Person / Time
Site:	Calvert Cliffs
Issue date:	03/02/1999
From:	Mazetis G AFFILIATION NOT ASSIGNED
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM), NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR11071, RTR-NUREG-1437 64FR11071-00001, 64FR11071-1, NUDOCS 9903190098
Download: ML20207M484 (3)

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l March 2,1999 Chairman Shirley Ann Jackson 5$

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SUBJECT:

REQUEST FOR COMMENT OF CALVERT CLIFFS NUCLEAR POWER PLANT DRAFT SUPPLEMENT TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT, NUREG-1437, Supplement 1 Thank you for sending a copy of NUREG-1437, Supplement 1 dated February 1999.  ;

As a private citizen, former naval officer, and retired NRC employee, I have no bias '

against commercial nuclear power stations, and believe in a strong national defense.

Notwithstanding these views, I ask that the NRC work with the U.S. Navy to reassess their estimate of the current risk to the environment of an aircraft crash at the Calvert i

Cliffs Nuclear Power Station (CCNPS) for the following reasons:

+ The Navy has recently proposed increasing aircraft tests and pilot training in the environment of CCNPS (see the " Final Environmental Impact Statement For l Increased Flight and Related Operations in the Patuxent River Complex," dated  ;

December 1998). FEIS Table 2-2 makes it clear that these aircraft tests include determining "...the edges of the safe flight envelope..."for prototype aircraft.

The Navy gives no quantitative analysis of the potential for, or consequences of, an aircraft crash into CCNPS.

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+ USNRC NUREG-1437, Supplement 1 makes no mention of the increased risk to \

I CCNPS due to the increased frequency of military aircraft flights. The CCNPS site is distinctive...it is uniquely bordered by the Military Training Routes (MTR) about 10 miles to the northwest and the Chesapeake Test Range (CTR) a couple miles to the southeast (see the enclosed map).

+ Previous judgments by the NRC on the potential for an aircraft crash during the construction and operation of CCNPS should now be re-examined due to the increased funneling of test pilots and new or experimental aircraft from closed military bases to PAX the past 8-10 years (see FEIS page 1-2, "DoD is currently implementing more than 500 decisions of the Base Closure and Realignment Commission [BRAC) to realign or consolidate military activities, or to close military

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' 1 installations"). Such activities are expected to continue and are outlined in the '

Navy's Integrated Management Plan (IMP) for the Patuxent River Complex.

i The NRC and the Navy have an obligation to work together to quantify such risk increases to CCNPS. To be credible, such an analysis must consider actual flight crash data for the tri-state area (Virginia, Maryland, Delaware). Such a database could be similar to the sample crash data included in the document to Ms. Kelly Burdick, " Comments on the Final Environmental Impact Statement," dated January 1 11,1999 by G.R. Mazetis. GAO reviewed all military aircraft accidents and found that the frequency of aircraft Class "A" mishaps' is about 76 per year, translating to .

1.5 per 100,000 flying hours (GAO/NSIAD-96-69 BR). It then follows that as the i frequency of flight operations (total flying hours) increases at the Patuxent River Complex, the frequency of crashes could increase. Since full disclosure of significant  !

environmentalimpacts is required by federallaw, the NRC and Navy should combine their expertise to demonstrate that the risk to the environment from an aircraft crash at CCNPS is acceptable for the remainder of the current Sense, and for the extended renewal period.

It is clear that military aircraft crashes are a fact. Two contrasting types of in-flight aircraft accidents are particularly relevant. In the first example, which begins as a total engine failure in an F-16 jet fighter, the pilot does not eject and proceeds to land his aircraft safely. In the second example, which also begins as a total engine failure in an F-16, the pilot ejects. This unmanned, out-of-control F-16 jet fighter then 4 proceeds to travel a significant distance before crashing. The points to be made in  !

these two examples are that air conidor restrictions, while helpful during normal j maneuvers, completely vanish when an aircraft is out of control. Second, while the latter example would appear in the data as a Class "A" mishap for a risk assessment, I the first exarnple would not. A more rigorous investigation is needed by the analyst I to consider such "close calls", which cannot be ignored in a credible risk study. l The military would acknowledge that the NRC retains the greater appreciation for the true magnitude of the radiological consequences that could be involved from an aircraft crash into the CCNPS reactor building or spent fuel pool building. The NRC sh% recommend that the Navy hold up their proposed increases in flight I opt.ations until these crash data are collected, the risk analysis is performed, and independent reviews ave _been completed.

Respectfully, f )

/ 61 W Dr. Gerald R. Ma tis Cc: Ms. Kelly Burdick, Office of Legal Counsel, Patuxent River

' Class "A" aircraft mishaps are defined as those irwolving a fatality, permanent disability or at least

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