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Category:AFFIDAVITS
MONTHYEARML20023C6971983-05-12012 May 1983 Affidavit of DB Goldstein Supporting NRDC Motion for Summary Disposition of Contention 1 Re Need for Power.Four Forecasts for Energy Needs Refute Need for Power Justification Developed by Util.Prof Qualifications Encl ML20070L4901982-12-27027 December 1982 Affidavit of Mv Stimac Supporting Applicant Answer to Yakima Indian Nation Motion for Reconsideration.Describes Plant Site & Location of Casements.Certificate of Svc Encl ML20070D1181982-12-10010 December 1982 Affidavit of R Jim Supporting Yakima Indian Nation Brief on Admissibility of Nation Reworded Proposed Contention 10 & Motion for Reconsideration.Nation Has Right to Pasture Horses & Gather Roots Even Though Us Holds Title to Land ML20063M2581982-08-27027 August 1982 Affidavit of Rv Myers Supporting Motion for Summary Disposition of Coalition for Safe Power Contention 26. Seismic Category I Electrical Equipment Will Be Qualified Per IEEE 344-1975 & Reg Guide 1.1.W/Certificate of Svc ML20063H1111982-07-0909 July 1982 Affidavit of L George.Columbia River Inter-Tribal Fish Commission Does Not Represent Columbia River Treaty Tribes ML19312E9321980-05-23023 May 1980 Affidavit in Support of Applicants' Reply Objecting to Skagitonians Concerned About Nuclear Power 800508 Motion to Dismiss Application.Explains Applicants' Efforts to Locate Suitable Site.Certificate of Svc Encl ML19250C2921979-10-16016 October 1979 Affidavit Attesting That Time Schedule Re Expert Witness Presentations for Geology & Seismology Issues Is Impossible to Meet.Time Restraints Affect Quality of Preparation. Certificate of Svc Encl ML19254D7271979-09-21021 September 1979 L Gittleman Affidavit,Correcting Typographical Error in Testimony Re Util Net Income for CY78.Net Income Changed from $26.1 Million to $36.4 Million ML19254E9321979-09-13013 September 1979 Affidavit of JB Read on 790913 Re Recent A6 Aircraft Crash Experience.Crash Rate Was Conservative.Aircraft Hazards Need to Be Considered as Basis for Design ML19259D6891979-08-30030 August 1979 Affidavit Attesting That Significant Design Change Must Be Made by Applicant,Contrary to Info Disclosed in Psar,Fes, SER & Hearing Transcripts.Certificate of Svc Encl ML19224D7871979-07-0202 July 1979 Affidavit of Svc for Amend 14 to Application 1983-05-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7881983-11-23023 November 1983 Withdrawal of OL Application.Certificate of Svc Encl ML20082F7771983-11-23023 November 1983 Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding ML20080L9431983-09-28028 September 1983 Second Request for Addl Extension Until 840115 to Answer Intervenor Motion for Summary Disposition of Contention 1. Portland General Electric Co Expects to Decide on Plant Termination by End of 1983.Certificate of Svc Encl ML20080G0731983-09-13013 September 1983 Request for Extension Until 831014 to Answer Intervenor Motion for Summary Disposition of Contention 1.Motion May Be Moot If Other Owners Concur W/Util Decision to Terminate Proceeding.Certificate of Svc Encl ML20071Q7201983-06-0303 June 1983 Response Opposing Applicant 830525 Request for Extension Until 830930 to Answer Motion for Summary Disposition of Contention 1.No Good Cause Demonstrated.Certificate of Svc Encl ML20071M0781983-05-25025 May 1983 Request for Extension Until 830930 to Answer NRDC Motion for Summary Disposition of Contention 1.Time Needed to Consider Implications of Final Northwest Conservation Electric Power Plan & Licensing Alternatives.Certificates of Svc Encl ML20023C4571983-05-12012 May 1983 Memorandum of Points & Authorities Supporting Intervenor Motion for Summary Disposition Since Contention 1 No Longer Controversial Issue.Certificate of Svc Encl ML20023C3741983-05-12012 May 1983 Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1 ML20023C3691983-05-12012 May 1983 Motion for Summary Disposition of Contention 1 Re Calculation of Demand for Electrical Energy Negating Need for Plant.No Genuine Issue of Matl Fact Exists ML20023C6971983-05-12012 May 1983 Affidavit of DB Goldstein Supporting NRDC Motion for Summary Disposition of Contention 1 Re Need for Power.Four Forecasts for Energy Needs Refute Need for Power Justification Developed by Util.Prof Qualifications Encl ML20064N6681983-02-10010 February 1983 Motion to Suspend Health & Safety Prehearing Schedule Pending Adoption of Final Regional Energy Plan or Until Conclusion of Evidentiary Hearings on Need for Power. Applicant Appears Ready to Absorb Facility Costs ML20071A6671983-02-10010 February 1983 Certifies Svc of Intervenor Motion to Suspend Safety & Health Schedule on 830210 ML20070T0661983-02-0404 February 1983 Motion for Order Suspending Health & Safety Prehearing Schedule,Pending Adoption of Final Regional Power Plan & Further Order of Aslb.Suspension Would Be in Best Interest of All Concerned.W/Certificate of Svc ML20083N8101983-01-31031 January 1983 New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20083N1991983-01-26026 January 1983 Notice of Appeal & Exceptions to ASLB 830118 Memorandum & Order.Memorandum & Order Fails to Recognize Yakima Indian Nation Sovereignty & Treaty Rights Which Are Supreme Law of Land.Affidavit of Svc Encl ML20028F1831983-01-25025 January 1983 Notification of Intent to File New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20028E9701983-01-19019 January 1983 Reply to NRC & Applicant Response to Natl Wildlife Federation/Or Environ Council,Columbia River Inter-Tribal Fish Commission & Coalition for Safe Power 821213 Motion to Clarify & Amend Certain Contentions.W/Certificate of Svc ML20072A6731983-01-18018 January 1983 Motion for Extension of Time Until 830210 to File Answer to Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Parties Attempting to Settle Matter by Informal Agreement.Certificate of Svc Encl ML20028C9581983-01-0505 January 1983 Memorandum Supporting Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Applicants Misinterpreted 10CFR2.740(b)(1) Relevancy Std.Discovery Requests Are Relevant.W/Certificate of Svc ML20028C9501983-01-0505 January 1983 Motion to Compel Applicants to Respond in Full to Natl Wildlife Federation/Or Environ Council 821201 Interrogatories & Request for Production of Documents ML20028C3221983-01-0303 January 1983 Suppl to DOE 821126 Limited Appearance Statement.Doe Position Is That Hanford Site Is Not Open,Unclaimed Land as Defined in 1855 Treaty W/Yakima Indian Nation,Article Iii. ASLB Is Wrong Forum for Resolving Issue ML20070L5411982-12-27027 December 1982 Answer Opposing Yakima Indian Nation 821210 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Suppl to Petition to Intervene.Aslb Rejection of Contentions 7,8 & 9 Well Founded ML20070L4901982-12-27027 December 1982 Affidavit of Mv Stimac Supporting Applicant Answer to Yakima Indian Nation Motion for Reconsideration.Describes Plant Site & Location of Casements.Certificate of Svc Encl ML20079J6021982-12-23023 December 1982 Response Supporting Intervenor 821213 Motion to Clarify & Amend Contentions 7 & 8.Quantification of Environ Impacts Not Practicable Due to Subjective Nature.Certificate of Svc Encl ML20023B3081982-12-20020 December 1982 Response to 821201 Discovery Requests.Certificate of Svc Encl ML20079H3711982-12-13013 December 1982 Motion to Clarify & Amend Contentions 7 & 8.Contentions Should Be Reorganized to Facilitate Coordinated Evidentiary Presentations for Environ Matters ASLB Set Out as Contentions 4,7 & 8.Certificate of Svc Encl ML20070D1181982-12-10010 December 1982 Affidavit of R Jim Supporting Yakima Indian Nation Brief on Admissibility of Nation Reworded Proposed Contention 10 & Motion for Reconsideration.Nation Has Right to Pasture Horses & Gather Roots Even Though Us Holds Title to Land ML20070C9121982-12-10010 December 1982 Notice of Counsel New Law Firm Affiliation,As of 820901 ML20070C8181982-12-10010 December 1982 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Yakima Indian Nation Contentions 7,8 & 9.Nation Right to Enjoy Reservation Peacefully Given by 1855 Treaty Should Be Protected by ASLB ML20070C7981982-12-10010 December 1982 Brief Supporting Admissibility of Yakima Indian Nation Reworded Proposed Contention 10.Attempt to Terminate Reserved Rights of Yakima Indian Nation Violates Fifth Amend.Land Cannot Be Taken by Inverse Condemnation ML20070C7691982-12-10010 December 1982 Certifies Svc of Brief on Admissibility of Reworded Proposed Contention 10,motion for Reconsideration of ASLB 821029 Memorandum & Order,R Jim Affidavit & Notice of Counsel Law Firm Change on 821210 ML20028B9251982-12-0101 December 1982 Brief Re Admissibility of Yaking Indian Nation Proposed Contention 10.Clarification Needed on Procedural Rule of Commission & Scope of Contention.Certificate of Svc Encl ML20028B8971982-12-0101 December 1982 Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence ML20028B2631982-11-26026 November 1982 Limited Appearance Statement.Hanford Site Is Not Part of Yakima Indian Nation Reservation Established by 1855 Treaty. Indian Privilege of Hunting,Gathering Roots & Berries & Grazing Animals Does Not Extend to Hanford Site ML20066L0101982-11-22022 November 1982 Motion to Amend Accepted Contention 3.Proposed Amends Would Conform Contention 3 to Earlier Admitted NRDC Contention on Which Contention 3 Is Partially Based.Certificate of Svc Encl ML20066K9761982-11-22022 November 1982 Motion to Alter Lead Party Designation Established for Contention 3 in ASLB 821102 Memorandum & Order.All Intervenors Concur That NRDC Should Be Designated Lead Party,Since NRDC Demonstrated Greatest Expertise on Issue ML20023A8301982-10-15015 October 1982 Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence ML20023A8141982-10-14014 October 1982 Response to Yakima Indian Nation 820930 Suppl to Petition to Intervene,Containing List of Contentions.Objects to Contentions 4-10.Certificate of Svc Encl ML20027C1591982-10-0606 October 1982 Response to 820917 First Set of Interrogatories ML20063P4011982-10-0606 October 1982 Response to Columbia River Inter-Tribal Fish Commission 820923 Notice of Appeal of ASLB 820903 Memorandum & Order Denying Intervention.Applicants Will Not Oppose Appeal in Order to Maintain Schedule for Proceeding ML20071N3791982-10-0404 October 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20069F9491982-09-23023 September 1982 Notice of Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene.Supporting Brief Encl ML20069F9541982-09-23023 September 1982 Memorandum Supporting Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene or Alternatively, to Remand Petition to ASLB for Further Clarification on Question of Standing.Certificate of Svc & Exhibit Encl ML20137F8001982-09-17017 September 1982 Amended Subagreement 2 Between State of Wa Energy Facility Site Evaluation Council & NRC Re Protocol for Conduct of Joint Hearings on Facility Project ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5571982-09-15015 September 1982 Motion for Extension of Time Until 821004 to Respond to Applicant Interrogatories.Counsel Was Unavailable When Interrogatories Arrived. Certificate of Svc Encl 1983-09-28
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UNITED STATES OF !."Er,ICA NUCLEAR REGULATORY COMMISSION BEFCRE THE ATCMIC SAFETY AT cICENSI!S BOARD In the Matter of
)
)
PUGET SOUND POWER & LIGHT COMPA?.Y, , ) Occket Mos. STN 50-522 ET AL. ) STN 50-523
)
(Skagit Duclear Power Project, )
Units 1 and 2) )
RECENT A6 AIRCRAFT CRASH EXPERIENCE AFFIDAVIT GF JACCUES B. J. READ I, Jacquen 8. J. Read, being duly sworn do depose and state that:
In a previous affidavit, dated July 15, 1976, I stated that 10-4 per hour was an appropriately conservative crash rate to assume .applic,ble to A6 .
aircraf t to be operated en low level training routes fron. Whidbey Island Naval Air Station. This rate was developed for use in Standard Review Plan
.,Section 3.5.1.6 and was calculated from an analysis of 2136 United States Navy (USN),' Marine Corps (USMC) and Air Force world-wide :ccibents- during.
theperiod19$3to1973ofwhit.n56accidentsinvolvedtheA6aircraftor variationY thereof. After examining the low-level training routes from Whidbey Island Naval Air Station and their proximity to the proposed Skagit site, it was my opinion t:at this crash rate was an appropriately conserva-tive one to assume in the Skagit aircraft risk analysis.
To determine whether th,, crash rate is still appropriate in light of more recent experience, I requested that the Department of the Navy Naval Safety Center compile and release A6 crash rates for more recent years, and have
]tiined from them the data set forth below.
1268 293 300R ORGINAL hh 7911050
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_2-CALE'iDAR A6 CPASHES A6 CRASHES ' DOSS INFLIGHT UNCERTAINTY YEAR PACIFIC-U.S. WORLD-WIDE CRASH PATE ESTIPATE
-(Yl'0 ) 4 (fiiN) 1968 3 10 1.11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> ) .35 hour4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />'3 1969 2 10 .98 .31 1970 -
2 9 .97 .32 1971 2 10 .f9 .31 1972 1 10 .84 .27 1973 4 6 .62 .25 1974 0 2 .20 .11 1975 0 5 .46 .21 -
1976 3 5 45 .20 1977 0 4 .35 .18 1978 0 9 .69 .23 11-year total 17 80 .69 .08
- The second column contains the number- of destroyed A6 aircraf t from accidents _
occurring wthin operational range (circa 1000 miles) of Whidbey Island. The Navy indicated that it could not provide information relative to the number ~of accidents involving A6 aircraft from Whidbey Island since the Naval Safety Centerdoe[notmaintaindata'toreadilyidentifythepointoforiginofflights-
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or the use of'l' w21evel-o routes. 'The' fourth' column contains the gross in-flight
. (
rate, i.e., all A6 crashes not involving landing and take-offs divided oy total hours aloft. The last column contains a Poisson estimator of the standard deviation of' the rate. This uncertainty estimata indicates that the decline . ,_
in crash rate in the more recent years is statistically significant, whereas the smaller increase during 1978 is not.
The gross in-flight accident rate is predominated by accidents which occur during simulated combat conditions, for example, simulated bombing runs at the Boardman, Cregon Navy Weapons System Trair.ing Facility. These accidents have occurred during siraulated assaults upon targets and the associated aporoaches and recoveries thich involve high speed and acceleraticn activities.
Accordingly, it is conservative to use the gross in-flight accident rate to 1268 294 300RORSNAL
describe flights in low level
- raining routes such as those that exist near the proposed Skagit site which (:3,not involve simulated combat conditions.
The magnitude of this conservatism is discussed for the A6 aircraft in Section 4 of the report " Aircraft Considerations, Pre-application Site Review by the Jirectorste of Licensing, U. S. Atomic Energy Commission, in the Matter of Portland General Electric Company, Boardman Nuclear Plant, Boardman, Oregon, Project No. 485," dated October 12, 197? (a copy has been previously supplied to SCANP)
Based on the foregoing data for the A6 aircraft for the years 19c8-73, it is my opinion that a crash rate of 10- per huur is an appropriately conservative assumption to be used in a risk analysis of the aircraft hazard at the Skagit site. These data refitct that the gross in-flight crash. rate during the 11- -
year period is 6.9 x 10-5 per hour and that there is a statistically significant decrease in this crash rate in more- recent years. Accordingly, the Staff -
still concludes, based on more recent data, that aircraft hazaris at the
-proposed'SkagitsitearesufficientlylowthattheyneednotIeconsidered --
.r .
as a basis for design.
di,o-., 0 uy4 ; .t ,
Jacques o. J. Keaa
\.\
i Subscribed and sworn to before me -
this/3~" day of September 1979
.A l
// l.
Notary Pub 1ic My Ccamission Evp;res: )- , /, ' ' 2 1268 295 P00R ORGINAL
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