ML20210E490
| ML20210E490 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 07/20/1999 |
| From: | Matthews J AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20210E474 | List: |
| References | |
| 97-732-02-ISFSI, ISFSI, NUDOCS 9907280246 | |
| Download: ML20210E490 (25) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGUI.ATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of:
)
Docket No. 72 22-ISFSI
)
PRIVATE FUEL STORAGE, LLC
)
ASLBF No. 97-732-02 ISFSI (Independent Spent Fuel
)
Storage Installation)
)
July 20,1999 DECLARATION OF MAJOR GENERALJOHN MA'ITHEWS, U.S. AIR FORCE, (RETIRED) REGARDING MATERIAL FACTS IN DISPUTE WTTH l
RESPECT TO CONTENTION K i
l Under penalty of perjury,I, Major General John L Matthews, U.S. Air Force l
(retired), declare as follows:
1.
I am the Military Advisor to the Governor of the State of Utah. As military advisor for the State of Utah,I am familiar with the military operations in the state, including l
operations at Dugway Proving Ground (DPG), Hill Air Force Base (HAFB), the Utah Test and Traning Range (LTITR), and Utah National Guard. I was a member of the.
Air Force for 4 years where I flew various military aircraft and was an Air Force flight instructor. I was also a member of the Utah Air National Guard for almost 36 years.
From 1979 to 1981, I served as Commander of the Utah Air National Guard which included overseeing the Air National Guard's duty to control and manage the air traffic over the UTTR. During 1984 to 1992,I served as the Adjutant General of the j
Utah National Guard. As Adjutant GeneralI also oversaw the management of both l
the Utah Army and Air Force National Guard, including UTTR sir traflic control.
', My other duties as Adjutant Generalincluded management of attack helicopter troops, artillery, special forces, engineering, medial, and linguist operations. As the former Adjutant General I am familiar with the various types of military training activities i
that occur on the UTTR, including the types of weapons and target areas. During my years of military service, I have flown F-16s, T 33s, F-86s, C 97, KG97s, C124s, KC 135s, B 52s, EC 135s, AH-64s and C-130s, including nume.ous flight training missions initiating out of HAFB on the UTTR. I have also flown in the Sevier B Military Operating Area, which is directly over the proposed ISFSI. A copy of my resume is attached.
2.
I am the State of Utah's expen witness on Utah Contention K, regarding credible accidents involving aircraft, air launched weapons, and military training activities. I am familiar with the State's position regarding Utah Contention K with the respect to 9907290246 990722 PDR ADOCK 07200022 C
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JUL-eu-A m A(.4A t'. UJ ponn ennews - mannewsuct-ca.wpa pyg risks from aircraft and military activides.
3.
I am familiar with Private Fuel Storage, L.L.C.'s ("PFS's") Safety Analysis Repon in this proceeding reguding analysis of military and industrial facilities.8 4.
I am also familiar with PFS's February 10,1999 response to RAI No. 2, SAR and PFS's June 30,1999 Submittal of Commitment Resolution Letter #7 Information.
5.
I have reviewed the Applicant's Motion for Panial Summary Disposition of Contention K-In dequate Analysis of Credible Accidents, as well the Statement of Material Facts Not in Dispute, the declaration ofJames Cole Jr., and the affidavit of George Carruth, and materials submitted in support of the motion.
6.
The Ap'j: ant's expen, General Cole, recognizes that commercial aircraft utilizing high altkode airwayJ-56 pass within 10 miles of the proposed ISFSI at approximately 50 statute miles from the Salt Lake City International Airpon. Applicant's Motion for Panial Summary Disposition for Utah Contention K, Cole Dec., Exhibit 2 at 3,5. In assessing the likelihood of commercial aircraft crashes during flights on this path, Generd Cole only considers the probability of an airplane crash during in-flight / cruises. Id at 6. He does not consider the risks from descent from cruising altitudes. Id. When planes are making descents, they have a higher risk of crashing than when they arein-flight.
7.
There a number of formulas used to determine when to start irJtial descent. Each formula has similar resuks. One formula commonly used to determine the distance to initiate ones descent in miles from the designated airport is equal to three times the thousands of feet of the aircraft's altitude plus ten (inidate descent in miles from airpon - (thousands of feet of altitude x 3) +10)).
8.
General Cole incorrectly states that airwayJ-56 has a minimum enroute altitude of
. 33,000 feet. Applicant's Motion, Cole Dec. at 3. In fact, high altitude airwayJ.56 has a minimum en route altitude of 18,000 feet MSL; IFR Enroute High Altitude - US map.
j One could calculate when an aircraft should initiate descent into the Salt Lake International Airpon by multiplying the altitude in thousands of feet (18) times three then add ten. Thus, an aircraft would initiate its descent at 64 miles from the Salt Lake International Airpen, about ten to fifteen miles beyond the proposed ISFSL 9.
If General Cole were correct that a minimum altitude of J-56 is 33,000 feet, an aircraft would begin its descent 109 miles from the Salt Lake City International Airpon, which is an even greater distance before reaching the vicinity of the ISFSI 3 Consisting of approximately three and a third pages, SAR 2.2-1 to 4.
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10.
Colonel Carruth, the Applicant's expen, asserts that military ground training exercises at Dugway Froving Ground would not impact the proposed ISFSI because munitions are fired away from the proposed ISFSI and the range of munitions will not reach the ISFSI. Applicant's Motion, Carruth Aff at 18. The U.S. Army and various National Guard units conduct training exercises in the northeastern portion of Dugway Proving Ground (DPG), near Wig Mountain. See Applicant's Motion, Carruth Aff., Exhibit 2.
The northeastern border of DPG is approximately 8 miles southwest of th: proposed ISFSI. Id. at 14.
11.
Colonel Carruth argues that stray munitions could not reach the proposed ISFSI
~
.. because the range of rnunitions fired near Wig Mountain do not exceed 11 miles and the firing positions would be further than 15 miles away. However, various Army and National Guard units fire a multiple launch rocket system with an unclassified range of 30 kilometers or 18.64 miles at the Wig Mountain targets.2 Thus, there is a potential that a multiple launch rocket system may misfire and impact the proposed ISFSI.
12.
Skull Valley and the proposed ISFSI it located within the Sevier B MOA. See Applicant's Motion, Cole. Dec., Exhibit 2, map follovdng page 9. The Sevier B MOA begins at 100 feet above ground level to 9,500 feet mean sea level. See Exhibit 1, Memorandum for Air Force Representative, Annual Operating Area Usage Report.
The activities conducted in the Sevier B MOA include low altitude (LOWAT) training, cruise missile testing, anil major exercises. Id In federal fiscal year 1998, 3,878 air operations occurred in Skull Valley. Id The following aircraft are allowed to operate in the Sevier B MOA: F15, F16, F111, F4, B52, B1, A10, KC135, EC135, EC135, RC135, C130, C141, A4, F18, F117, A6, A4, H1, C117 and B2. Id.
13.
In my professional view, the Applicant has not adequately examined the risk that aircraft will drop live or inert ordnance on the ISFSL The Applicant argues that the military aircraft overflight over the proposed ISFSI is limited to flighu to and from i
Michael Army Air Field.. However, there is a considerate potential that military
,,, aircraft ingressing and egressing the UTTR will also overfly the proposed ISFSI.
Aircraft en route to the UTTR South range from Hill AFB ingress the range through the Sevier B Military Operating Area (MOA). Aircraft egressing fom both the UTTR North and South ranges may recover to Hill AFB through the Sevier B MOA using i
the Stansbury/Moser Recovery See Exhibit 2, Applicant's Response to RAI 8-2, Attachment D. The Stansbury/Moser Recovery traverses directly through Skull Valley.
2 Telephone conversation with Mike Merrit, Dugway Proving Ground and Major Paul Harrell,
)
Division of Plans and Training. Utah National Guard on July 20,1999.
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The Applicant cidms that "[a]ircraft en route to the UlTR South Area from Hill AFB fly down the east side of Skull Valley, approximately five miles from the PFSF."
Applicant's Motion, Applicant Statement of Mat. Facts for Hill Air Force Base, the Utah Test and Training Range, and Michael Army Air Field at t 6. First, the Applicant's statement contradicts its response to RAI No. 2, SAR 8-2 paragraph (b) which states "[t]he Aircraft departing Hill AFB use the Island 420 Departure (IR 420) for the South Range low level missions." See Exhibit a at 1. The coordinates for IR 420 follow a path to the middle of Skull VaUey, near t'he proposed ISFSI, A91 along the east side of the valley. Second, the Applicant's expect witness stated "[t]here is no fixed corridor that they [F-16's] fly through." See, Exhibit 3, Cole Dep. at 41, line 11 and 12.
Moreover,in describing his analysis in which he assumed the F-16s flew down the east side of Skull Valley, the Applicant's expert stated that "I had to put them into an anificial pipe that they don't fly in"Id, at 45, line 11 and 12. The Applicant's expert also stated that assuming that the F.16's fly down the east side of Skull Valley "doesn't realisticaUy reflect where the airplanes actually fly." Id. at 46 line 3,4. Also, military aircraft en route to the Sevier B MOA may be allowed to fly under visual flight rules or anywhere within Skull Vaucy.' Although military aircraft may, they don't always fly down the east side of Skull Valley. In fact, the aircraft may directly overfly the proposed ISFSI:ite.
The military aircraft en route to the UTTR South range for training missions may 15.
carry either live or inert weapons.' Live ordnance includ 2,000 lb Mk 84s (net explosive weight of 945 lbs),1,000 lb Mk 83s (net explosive weight of 445 lbs), and 500 lb Mk 82s (net explosive weight of 192 lbs). See Exhibit 2 at 2. Inert weapons are designed to simulate the size and weight oflive weapons. Thus, inert weapons consist j
of 2,000,1,000, and 500 lb concrete bombs. Many of the inert weapons are fitted with steel nose cones designed to penetrate concrete and steel.
16.
The majority of military aircraft flying in the Sevier B MOA are F-16 fighter jets.
F-16s may reach a maximum speed of approximately 1,600 miles per hour. It is reasonable to assume that F-16's transiting the Skull Valley will travel at least at a speed of 600 miles per hour.
17.
The Applicant argues that " aircraft overflying Skull Valley are not allowed to have j
their armament switches in a release capable mode." Applicant's Motion, Cole Dec.,
Exhibit 2 at 22. It is true that standard operating procedure require the armament l
.) Telephone conversation with MajorJohn Teter,299 Range Control Squadron on July 8, 4
1999 that military aircraft often will be allowed to fly under visual flight rules at any point along flight path IR 420, prior to entering Skuu Valley. See Exhibit 3. Attachment C.
JUL-20-1999 17:23 P.06 ponn mennews - mannewsuce-M ewpo
_ _ Paga 5 l switches to be a position not to allow a munition release. However, the Applicant has failed to address the very real potential for equipment failure and/or pilot error. In addition, emergency procedures during an F-16 engine problem require the pilot to immediately pull up and jettison all stores, including fuel tanks and munitions. Thus, because of the number of en5 ne problems that F-16s have recently experienced there is i
a potential that live, inen, or other objects may be dropped on the proposed ISFSI.
18.
The UTTR South range conduct a number of cruise missile tests. Several of the cruise missiles have crashed. See Exhibit 4, Missile Crashes Between 1 January 1988 and 31 December 1998 and Applicant's Motion, Cole Dec., Exhibit 3. Although cruise missiles which leave Department of Defense property must have flight termination systems, there is still the potential for human error or equipment malfunction. See Applicant's Motion, Cole Dec., Exhibit 3 which provides an example in which human error allowed a cruise missile to destroy civilian property.
19.
The technical facts presented above are true and correct to the best of my knowledge, and the conclusions drawn from those facts are based on my best professional judgment.
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afor t3e'neralf Matthews
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U.S. Air Fo (Retired)
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Dated: July 20,1999 00 TOTR P.06
John L. Matthews Major General USAF (Ret) 116 State Capitol Salt Lake City, UT 84114 801538-1640 (W)
Present Assignments MILITARY ADVISOR TO THE GOVERNOR OF UTAH DEFENSE CONSULTANT Career Summary General Matthews retired on 30 September 1994 after nearly 40 years ofservice.
He was commissioned a 2nd Lieutenant in the United States Air Force on 17 December 1954. He graduated from Flight School in June of 1956 and was assigned as an Instructor Pilot at Laredo AFB, Texas. During his flying career he flew T-33s, F-86s, C-97s, KC-97s, C-124s, KC-135s, and had brief experiences flying B-52s, EC-135s, F-16s, AH-64s, and C-130s. His flying career took him throughout the world, and included an assignment as Aircraft Commander of an around the world flight. His last assignment was Adjutant General of Utah, which he held from 1982-1994, serving under three different governors. During that period he was elected President of the Adjutants General Association of the United States and later President of the National Guard Association of the United States. He served as Chairman, Board of Advisors, of the A.ir National Guard Professional Military Education Center in Knoxville, Tennessee. He received several appointments from the Secretary of Defense, including:
Ch airman, Air Reserve Forces Pol!cy Committee; Readiness Chairman, Reserve Forces Policy Board; Advisor to the DOD Task Force on Quality of Life; and a member of the Army Offsite Committee on Force Structure. He led the National Guard Delegation at the 50th anniversary commemoration of D Day in France which included a personal presentation to President Francois Mitterand at the Elysee Palace in Paris. Following his retirement he was appointed by President Clinton as a Commissioner, Commission on Rolls and Missions of the Armed Forces.
GeneralMatthews holds a Masters Degree from Brigham Young University and is a graduate of the Air War College. He presently serves as Chairman of the Citizen's Advisory Commission for the Tooele Chemical Demilitarization Facility and Chairman of the Dugway Technical Review Committee.
His 21 medals include the Air Force Distinguished Service Medal, Legion of Merit, Republic of Vietnam Service Medal, and the Utah Medal of Merit. He has recieved the Distinguished Service Award and the Eagle Award from the National Guard Bureau and the Legion de Lafayette from the National Guard Association.
He holds a TS SBI clearance.
f 30 November 1998 l
MEMORANDUM FOR AIR FORCE REPRESENTATIVE (ANM-900)
FAA Nonhwest Mountain Region 1601 Lind Avenue. S.W.
Renton WA 980554056 FROM: 388 RANS/AM 6067 Boxelder Lane Hill AFB UT 84056-5811
SUBJECT:
Annual Military Operating Ares Usage Repon
- 1. Sevier A Military Operating Area 1 October 1997 through 30 September 1998
- 2. Period of Report:
1200 ZULU to 0300 ZULU. Man Sat, other times by NOTAM
- 3. Published Hours of Operation:
J. Published Altitude: 100 feet AGL to 14.500 feet MSL.
- 5. Activities
- a. Aircraft Operations F15. F16. F111. F4. B52. Bl. A10. kcl 35, ECl35. RC l3 5. C130.
(1) Aircraft Type:
Cl41. A4. FIS. Fil7A. A6. A4. Hl.Cl17. and B2 14.500 feet MSL (2) Maximum Altitude: Flight Level:
Air to-air training LOWAT training, cruise missile testing, (3) Activities Conducted:
major exercises.
(4) Supersonic operations are not authorized.
/,V
- b. AnilleryMonarMissile (1) Type: Cruise missile. advanced cruise missile. unmanned vehicles (2) PurposeMission: Test. evaluation. and training.
6, AreaCoverage Available:
118.45.121.5.122.9.134.1.138.05.139.6.142.3.
- a. Communications (Frequencies Available):
I 225.3.226.0.229.2.233.4.238.9.243.0.254.4.266.3.271.1.271.35,275.9,279 I.
286.25,287.0.295.8.297.1.298.0.298.6.301.7.308.
)
388,1.389.8.398.1.
I 32558 nec noene L
Long Range FAA radst from Banle Mountain NV. Cedar City UT. snd Francis
- b. Radar Type:
Peak UT; Gap Filler Air Force Radst som Cedar Mountain UT. Trout Creek UT, and Bosine Mountain UT.
- c. ATC Senices: Closer Control Air Traf6c Control Facility.
- 7. Utilization:
- a. Air Operations: 3.871
- b. Totsi number of days ares was Scheduled: 325 Activated: 325 Utilized: 325
- c. Total number of hours area was:
Scheduled: 4585 Actissted:'4585 Utilized: 4562
- 8. Released to Controlling Agency for Public Use:
- a. Total hours released:'4199
- b. Number of weekday s ares was not activated: 10
- c. ' Number of weekend. holiday days are was not activated: 27
- 9. Current chart is spplicable.
JET TRAINOR 388 FW Airspace Manager 4
PFS-22697 '
32559
F l
l l
SAFETY ANALYSIS REPORT l
CHAPTER 8-ANALYSIS OF DESIGN EVENTS l
SECTION 8.1 ACCIDENT ANALYSIS 8-2 Regarding " hanging bombs," the following information is needed:
(a)
The number of training flights that the National Guard and Air Force conduct per year with live ordnance.
(b)
The flight paths or routes of these training flights.
(c)
The net explosive weight of the typical ordnance used.
(d)
The probability of occurrence of live ordnance failing to release.
(e)
The mechanism for failure to release.
(f)
The emergency or contingency plans for failure to release live l
ordnance.
(g)
The probability that a failure could result in an unintentional release of live ordnance over the PFSF ISFSI and result in impact to the facility.
(h)
The consequences of such an impact if found to be credible.
RESPONSE
Responses to this RAI were prepared based on information provided to PFS by J.L. Cole of the National Air Traffic Controllers Association, Washington D.C.
(a)
Training flights are conducted by the Department of Defense, which includes the U.S Air Force, U.S. Navy, U.S. Army, U.S. Marine Corps, and other nation's forces, in the UTTR (Utah Training Range). According to the U. S. Air Force, aggregate aircraft sorties flown in the UTTR for Fiscal Year 1998 (October i 1997 through September 301998) totaled 8,711.
Approximately 15% carried live ordnance. Consequently approximately 1,000 to 1,500 flights per year carry live ordnance.
(b)
According to the U.S. Air Force, aircraft departing Hill AFB, Utah use the DEVLIN I Departure (See attachment A) for transition into both the North (R-6404) and South (R-6402,5,6, and 7) UTTR ranges (See attachment B) for medium and high altitude missions. Only the South Range is of interest since it lies near the PFSF. The Aircraft departing Hill AFB use the Island 420 Departure (See attachment C) for the South Range low level missions.
F 16 aircraft departing from Hill AFB bound for the South UTTR range transition to Visual Meteorological Conditions (clear of clouds) at the north PFSF Safety RAI No. 2, SAR 8-2 Page 1 of 3 l
I l
end of Skull Valley and transit the valley fiom north to south en route to the ranges.
J All other flight plans do not pass over or near the PFSF. U. S. Navy and
{
U. S. Marine Corps aircraft flying from Fallon Naval Air Station, Nevada, enter the UTTR from the west. B-52 and other aircraft missions originating from bases other than Hill AFB depart their home bases and proceed direct to the UTTR via flight plan routes and enter the UTTR range from low level flight routes. These B-52 entries to the UTTR are usually from the north and west with coordination and clearance from Clover Control Air Traffic Control Facility.
Aircraft departing the Ranges for egress to Hill AFB use the Stansbury/Moser Recovery (See attachment D) or the Causeway Recovery (See attachment E). Of these two egress routes, aircraft only fly over or near the PFSF when using the Stansbury/Moser return route (c)
According to the U.S. Air Force, typical live ordnance consists of Mk 82 500 lb. (net explosive weight (NEW): 192 lb.) or Mk 831,000 lb. (NEW:
445 lb.) or Mk 84 2,000 lb. (NEW: 945 lb.) bombs.
(d)
According to the U.S. Air Force, approximately 15% of the 8,711 sorties flown in Fiscal Year 1998 carried live ordnance. Michael Army Air Field is the designated primary airfield for aircraft landing with live hung ordnance that has failed to release. According to the U.S. Army, there were only five hung ordnance aircraft diversions / recoveries into Michael Army Air Field during 1998. Since only approximately 15% of the aircraft sorties carry live ordnance, a total of only five hung ordnance recoveries in 1998 for a total of 1,000 to 1,500 sorties (approximately 15% of 8,711) produces a probability for failing to release of approximately one in two hundred to one in three hundred. A failure to release does not mean there will be an inadvertent release or an inadvertent release and explosion. The UTTR has not experienced any unanticipated munitions releases outside of designated launch / drop / shoot boxes.
(e)
According to the U.S. Air Force, the most common mechanism (cause) for failure to release is a malfunctioning cart, which is a small cartridge that separates the bomb from its mount. Bombs can also fail to release due to a mechanical hang-up or becoming stuck in the mount. Electrical malfunctions in the armament wiring circuits can also cause a failure to release. Bombs will also fail to release if safing pins are not removed on the ground prior to departure for the UTTR.
(f)
According to the U.S. Air Force, the first priority is to maintain circraft I
control and then assess the situation and take appropriate action. Pilots f
contact Clover Control Air Traffic Control Facility and advise them of the l
PFSF Safety RAI No. 2, SAR 8-2 Page 2 of 3
1 situation. When hung ordnance is encountered, the pilot has the option of either jettisoning the rack and n nion on the range,if able, or recovering to base. Michael Army Air Field e ihe designated primary recovery base for hung ordnance. Pilots request clearance to Michael Army Air Field for a hung ordnance recovery / landing. Pilots maintain a stable flight path and remain in Visual Meteorological Conditions by avoiding clouds. Clover Control provides assistance as required and ensures Michael Army Airfield is prepared to receive the aircraft to include fire fighting equipment and medical personnel standing by. The pilot maneuvers the aircraft to the northwest of Michael Army Airfield, avoiding rapid or steep turns i
abrupt climbs or descents. Test facilities in the UTTR or any populated areas are avoided. Since the approach is from the northwest, west of the Cedar Mountains, Skull Valley is also avoided. A long straight-in approach with a shallow rate of descent is established to a full stop landing on runway 12 (to the southeast). Runway 12 is 13,125'long and 200' wide with a barrier cable at the end. After landing, Dugway Proving Ground explosive ordnance disposal personnel will inspect and safe the bombs.
)
(g)
Based on information provided by the U.S. Air Force, the UTTR has not experienced any unanticipated munitions releases outside the designated launch / drop / shoot boxes within the UTTR. In addition, aircraft overflying the Skull Valley are not allowed to have their armament switches in a release capable mode. All switches are " Safe" until inside Department of Defense land boundaries within the UTTR. Master Arm switches are not actually armed until the aircraft are on the ranges within the UTTR where the bombs are to be dropped. In addition, each weapon tested on the UTTR has a run-in headirig established during the safety review process.
Footprints, time of fall, altitude at release, and release airspeed dictate the headings allowed. No run-in heading is currently over the Skull Valley area.
There has never been an unintentional release of live ordnance in Skull Valley or at the Skull Valley reservation. Procedures do not allow the potential for equipment to release ordnance over Skull Valley, only 15% of all missions carry live ordnance, and missions that experience hung ordnance are directed to Michael Army Airfield in a flight path that is not near Skull Valley. In addition, the possibility of future hung ordnance will continue to be reduced due to technological improvements, weapons reliability and training that has improved over time. Therefore, the probability of an unintentional release of live ordnance over Skull Valley is basically zero.
(h)
Since an unintentional release of live ordnance over Skull Valley is not possible, as stated above in (g), an impact into the PFSF is not a credible event and would not result in any consequences.
PFSF Safety RAI No. 2, SAR 8-2 Page 3 of 3 l
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EMD STANSBURY/MOSER RECOVERY
.. s OGD ASSIGNED VECTOR STANSBURY RECOVERY CH 104 HEADING 16.000 MSL 8
OR ASSIGNED R 6404A HIF CH 49 R 6404B s
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IAF PEERC HE 152024 MOSER RECOVERY Aircraft shall depart the MOSER Fix (Michael's R-35012 DME) at 15,000 MSL heading 051 direct the HIF R-180 30 DME. Intercept the HIF 30 DME ARC southeast of HIF TACAN to intercept the HIF R-152 to PERRC Initial Approach Fix (IAF).
l STANSBURY RECOVERY Aircraft shall exit the southeast corner of R6404 at 16,000 MSL, or assigned by ATC, on a vector heading to intercept and proceed via the HIF 30 DME ARC southwest of HIF TAC AN to PEERC IAF.
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1 1
UNITED STATES OF AMERICA l
2 NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD x
4 5
In the Matter of:
- Docket No. 72-22 6
PRIVATE FUEL STORAGE, L.L.C.
- ASLBP No.
7 (Private Fuel Storage Facility)
- 97-732-02-ISFSI g
x 9
Washington, D.C.
10 Thursday, May 20, 1999 11 Deposition of JAMES L.
COLE, a witness 12 herein, called for examination by counsel for the -
13 State of Utah in the above-entitled matter, 14 pursuant.to agreement, the witness being duly 15 sworn by CATHERINE S.
BOYD, a Notary Public in 16 and for the District of Columbia, taken at the 17 offices of Harmon, Curran, Spielberg & Eisenberg, 18 L.L.P.,
1726 M Street, N.W.,
Suite 600, 19 Washington, D.C.
20036, at 2:05 p.m.,
- Thursday, 20 May 20, 1999, and the proceedings being taken 21 down by Stenotype by CATHERINE S.
BOYD and 22 transcribed under her direction.
l l
23 24 25 l
ALDERSON REPORTING COMPANY, INC.
(2021289 2260 (800) FOR DEPO 1111 14th ST., N.W., 4th FLOOR / WASHINGTON, D.C. 20006 l
I 41 1
fly away from the proposed site.
They actually 2
fly up against the mountains during terrain l
3 masking three, four miles east of the site.
l 4
Q.
You know, I'm going to get the map 5
again, and I want to ask you to show me on the 6
map.
7 A.
Sure, where they fly?
okay.
8 Q.
Yes.
There is more copies there.
I'll 9
try not to cover the court reporter's material 10 again.
l 11 A.
Speaking in general terms, well, this 12 thing is pretty -- there is a desert peak in 13 here.
That's 11,031 feet high.
14 Skull Valley is about roughly ten miles 15 wide.
l 16 They come into the valley, and from the 17 proposed site, they fly up against these 18 mountains right here generally.
19 Now they don't have to.
20 Q.
You're referring to these?
Is that 21 A.
Stansbury; the thing is a little 22 Q.
So you're talking about the mountains 23 on the east side?
24 A.
Yes.
They are not in the mountains, 25 but from the site, they fly east of the site ALDERSON REPORTING COMPANY, INC.
(202)289-2260 (800) FOR DEPO 1111 14th ST., N.W., 4th FLOOR / WASHINGTON, D.C., 20005
1 Q.
General Cole, what were the results of 45 2
these bounding calculations that you did?
3 A.
Well, again, bounding calculations that 4
are artificially constrained, you know, I got a 5
number that frankly to me did not mean very much 6
because it was not realistic with the way the 7
airplanes fly.
8 I used the methodology in there.
9 Q.
You thought it was too conservative?
10 A.
I did, simply because, you know, to 11 make a calculation, I had to put the aircraft l
12 into an artificial pipe that they don't fly in, 13 so I mean the number was conservative on the safe 1-4 side, and it would be even safer as they are is spread out.
16 Q.
And what was the number?
17 A.
I frankly cannot specifically recall 18 because I didn't take the calculations beyond 19 just, you know, frankly stubby pencil work.
20 I just felt I had to have something, 21 you know, to deal with and start with.
22 ~
Q.
So you haven't prepared a calculation 23
'that is on a piece of paper?
l 24 A.
Nothing that I wouldn't consider beyond 25 the realm of scratch paper, and once again, I l
l ALDERSON REPORTING COMPANY,INC.
l (202)289 2260 (800) FOR DEPO l
l 111114th ST., N.W.,4th FLOOR I WASHINGTON, D.C.,20005 l
L
F 46 1
will say that that was a notional bounding i
2 assessment, and it was artificially constrained, l
3 and since it doesn't realistically reflect where 4
the airplanes actually fly, it's nothing that I 5
would call a formal assessment.
6 Q.
Okay.
7 (There was a pause in the proceedings.)
8 MS. CURRAN:
Connie, unless you have 9
something else, I'm going to go to the RAI 10 responses.
11 BY MS. NAKAHARA:
12 Q.
I have a real quick clarification 13 question.
14 General Cole, you indicated at the very i
15 beginning of this section that you looked at real 16 risk versus possible risk.
17 Can you explain your terms for a real 18 risk and e. possible risk?
19 A.
well, that's a very broad question, 20' Connie.
21 Let me start by saying real risks are 22 ones that can result in loss of precious lives or 23 expensive equipment.
24_
Sometimes they are obvious.
Sometimes 25 they are not so obvious and you have got to look ALDERSON REPORTING COMPANY,INC.
(202)289-2260 (800) FOR DEPO 111114th ST., N.W.,4th FLOOR / WASHINGTON, O.C.,20006
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i Fcm Scott W 388 FW/SEF From:
James Banas [BANASJ@HILLWPOS. HILL.AF. MIL]
Sent:
Friday, January 08,1999 3:28 PM Tc::
James. wilson @ hill.af. mil; scott.fom@ hill.af. mil C::
banasj@hillwpos. hill.af. mil
Subject:
Missile Crashes requested in FOIA
=A Scott and Jim, Here's the best we could do by COB today. Mission Control Center (MCC) and/or Range Control Officer (RCO) log books were about our only sour::e for this info. Could not find logbuoks covering July 94 to Jan 96. They may be in BRACC files controlled by, I believe, Mr. Mike Dalton in your building. Sony it's not everything but it's the best I could do on short notice and by COB today. Let me know if you need more assistance next week. And by the way, charge time to this project a= follows: 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> GS-13 pay and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> GS-12 pay, Jim Banas 9
1
_m
r 7.-........
r l
l Missile Crashes Between 1 Jan 1988 - 31 Dec 1998 l
Missile Live Crash Crash Crash Cause Type Warhead?
Date Location j
Seek No 13 Sep 89 3 miles NE of Spinner Granite Peak ALCM No 27 Feb 90 165 degrees at 60 miles from DPG ACM No 4 May 90 25 miles SE of Ely, NV ALCM No 24 May 90 20 miles SW of DPG ALCM No 24 Jul 91 155 degrees at 10 miles from ENV VORTAC ALCM No 8 Oct 91 Near Highway 6 in Millard County UAV.MR No 5 May 92
~5 miles W of Granite Peak UAV.MR No 9 Sep 92
??
ACM Yes 16 Dec 92 SW of Granite Peak AQM-34 No 6 Jan 93
~6 miles SE of Callao UAV.MR No 25 Feb 93
-5 miles SW of S tip of New Foundland Mts ALCM No 20 Apr 93
-10 miles SW of Granite Peak CALCM Yes 23 Jul 93
-20 miles W-SW 4
ofWildcat CALCM Yes 29 Mar 94
-20 miles SW of Granite Peak UAV No 29 Jun 94 20 miles W of Granite Peak UAV No
-21 Jan 95 North of Wildcat ALCM No 14 Sep 95 SW of Grarute Peak??
ACM No 24 Jun 96 Sevier Dry Lake ACM No 10 Dec 97 SW Bench of Cedar Mt
)
CALCM Yes 9 Jun 98
~% mile NW of TS.2A Range Control Officer log books for Aug 94 through Jan 96 were not available in the time period given for this request. These log books may be available in BRACC files. The incidents shown between those dates were taken from alternate sources.
)
l l