L-98-152, Forwards Assessment of Best Estimate of Risk Re Operation of Commercial Airport at Homestead Air Force Site W/Regard to to Safety at Turkey Points 3 & 4

Forwards Assessment of Best Estimate of Risk Re Operation of Commercial Airport at Homestead Air Force Site W/Regard to to Safety at Turkey Points 3 & 4

ML17354A987
Person / Time
Site:	Turkey Point
Issue date:	06/15/1998
From:	Hovey R FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-98-152, NUDOCS 9806230364
Download: ML17354A987 (100)

Text

JUN 15 1998 L-98-3.52 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555 Re:

Turkey Point Units 3 and 4

Docket Nos.

50-250 and 50-251

Response

to Request for 1nformation Regarding the Xmpact of a Commerc al Airoort at Homestead Ai" Force Base Site on Safety v Do' 4

On December 9,

1997, the Friends of the Everglades sent a letter to the NRC questioning whether the proposed conversion of the Homestead Air Force Base to a commercial airport represented a risk to the Turkey Point Nuclear plant.

The NRC has subsequently issued a request for "information regarding the Air Base conversion to Florida Power and Light Co.

(FPL), with a response requested within 60 days.

The enclosed response provides our best estimate of risk related to the operation of a commercial airport at the Homestead Air Force Base site.

This risk estimate is based on data currently available to us regarding proposed number of operat'ons, flight paths, and proposed fl'ght mix (i.e., military versus commercial versus general aviation) for single runway operation in the year 2014.

Our commun'cat'ons with the Homestead Air Force Base Conversion Agency and with the Federal Aviation Administration indicate that the number of operations, flight paths, and mix of operations is currently under review as part of development of a Supplemental Environmental "mpact Statement (SE1S)

Miami-Dade County officials have indicated that, due to an order limiting growth at the proposed Homestead Regional Airport issued by the State of Florida, aircraft act'vity w'll be limited to approx'mately 50 operat'ons pe day through the year 2005.

Accordingly, the information presented here is subject to change based on the development of new information in the SEXS.

When this informat'on becomes available to us, we will reevaluate this issue and inform you of any changes.

When the proposed disposition of the Homestead Air Force Base is finalized, we will update our Final Safety Analysis Report, as appropriate, to reflect these changes.

FPL also agrees that the commercialization of the base would have an impact on the offsite emergency preparedness program.

Evacuations and the effects of the growth 'n the Emergency Planning Zone are aspects of emergency preparedness that must be addressed jointly by FpL, the State of Florida, and Dade County.

We continue to communicate with local and state authorities on this matter in orde" to ensure that the issues coming "rom the commercialization of the base are identif'ed, that the offsite emergency preparedness p ogram to address these issues is appropr'ately

revised, and to ensure the Fede al Eme gercy Management eaoeascsze eeoe~s POR ADQCK 05000250 P

POR

~~~ <~~43 ~(.33 Eae1osure 1

L-98-152 Page 2

Agency s in concurrence with tne revisions to the orogram.

Ne will continue to meet with the aoorooriate local and state authorities to ensure that these issues are addressed in a timely manner.

Should there be any auestions on this recruest, olease contact us.

Ve~ truly yours, Oil Vice President Turkey Point Plant OiH Attachment cc:

Reg'nal Adminis"rator, Region XZ, USNRC Sen'or Resident Tnsaector, USNRC, Turkey Point

Attachment to L-98-152 Page 1

RZSK ASSESSMENT OF T~

TURKEY POINT UNZTS 3

AND 4 NUCLEAR POWER PLANT FROM AZRCRAFT OPERATZONS AT TEE MZAMZ-DADE COUNTY HOMESTEAD REGZONAL AZRPORT 1.

Scope In response to the NRC letter dated 14 April 1998, ent'ied "Request for Information Regarding the Impact or. a Commercial Airport at the Homestead Air Force Base on Safety at Turkey Point Un'ts 3 and 4," this risk assessment has been prepared., Th's assessment prov'des a scop'nc estimate of tne risk of aircraft operations to facilities at Turkey Point Units 3 and 4 based on a site specific model and conservative assumptions.

2. Applicability This risk assessment estimates the risks with potential radiological consequences from aixc aft crashes to those cr'tical structures at Turkey Point Units 3 and 4 associated w'th aircraft operations at the Miami-Dade County Homestead Regional Airport.

This risk assessment does not address aircraft related hazards f om the Turkey Point On-site Hel'port or other airports in the vicinity of Turkey Point such as the Kendall-Tamiami Executive Airport and the M'am'nternational Airport or other airports outside a 30-mile radius from Turkey Po'nt Units 3 and 4.

Furthermore, Terminal Radar Approach Control air traffic, medium altitude, and high alt'tude ope ations in the regional area of the Turkey Point Nuclear Facility are not addressed, since potential aircraft accidents impact'ng Turkey Point Units 3 and 4 from these aircraft operations provide negligible contributions to the total risk.

The Turkey Point Units 3 and 4 structures that contain safety systems which may be damaged by an a'rcraft crash were evaluated as part of th's assessment.

These structures include the containment buildings, auxil'zy building, emergency diesel generator buildings, spent fuel buildings, intake structure, contzol building, and turbine building.

3. Description of Miami-Dade County Homestead Regional Airport and Projected Aircraft Operations A detailed description of the projected aircraft classificat'on by

types, past and projected annual aircraft operations, and percentage distributions of these ope at'ons assumed for the proposed Miam'-Dade County Homestead Regional A'rport was extracted from the Final Environmental Impact Statement (FEIS, Rererence

5).

A'rc aft operations data provided for the year 1994 (Military operations) were used to assess the current risk associated w'th Homestead Air Force Base.

Projected aircraf" operations for the year 2014 from the FEIS were used to assess the risk of future operation of the proposed M"ami-Dade County Homestead Regional Airport, and include both military and c'vilian

Attachment to L"9S-152 Page 2

flight operations.

The aire aft operat'ons projected o

20lc are higher than the current aircraft ope ations at the existing Homestead Air Force Base.

4. Methodology for Performing Risk Assessments of the Tu key Point Nuclear Plant Units 3

& 4 from Potential Aircraft Crash Acc'dents (Reference 2)

The DOE methodology for assessing the risk of aircraft crashes to nuclear plants is based upon estimating the annual crash frequency for the affected structures as follows f =N*P*A*F wnere annual frequency of aircraft crashes to designated structures annual flight operat'ons at the Miami-Dade County Homestead Regional Airport by a'rcraft category and fl'ght phase in flight crash rate per mile for aircra t by aire aft category and flight phase, effective facility (structure) area in square miles by a'rcraft category and flight phase, crash probability density over area A by'ircraft ca"egory and flight phase.

The area presented by a facility to an aircraft during an acc'dent sequence represents a proportional'y with the aircraft crash location condit'onal probability.

Normally, the area presented by a facility consists of a fly-in area, A., and a skid-in area, A,.

These "epresent the probability that a given category of aircraft will flyd'ctly into the facility, and the probability that an aircraft will hit t. e ground first, then skid into the facil'ty, respectively.

The total effective area A

for each a'rcraft category,

's given by P

A.=Ai+A For a rectangular facility of length L, width W, and height H, tl e fly-in

area, for each aircraft category, is (f om Refe ence 2):

A.= (NS+R) *H*cotO

+ (2*L*WS) /R

+ (L*N)

The skid area, for each aircraft cat go~, is (from Re "erence 2)

(2)

A,= (WS+R) *S.

where WS L

W a'craf t facility fac'lity d'agonal wingspan, for each category a'rc"aft,

'ength, w'th, dimension o

the fac'lity = (O'. N'):,

Attachment to L-98-152 Page 3

cot facility he'ght, q>

=

mean cotangent of each category ai c aft at impact angle y, mean skid length for each category aircraft.

For each of the critical structures

analyzed, the a'rcraft impact probability is then multiplied by conditional core damage probabil'ty, and conditional containment fa'lure probability to obtain the probability of exceeding 10 CFR Part 100 exposure.

Probabil'stic Safety Assessment insights a e used

.to develop an upperbound of the conditional core damage probability and condit'onal containment failure probability.

Zt 's conservatively assumed that f containment fa's, the rad'ological consequences would exceed 10 CFR Part 100 exposure guidelines.

5.

Results FPL has performed a scoping estimate of the aircraft impact frequency (number/year),

the cond'tional core damage probability, the condit'onal containment failure probability, and the 10 CFR Pa t 100 exposure exceedance requency for the critical structures o

the Turkey Point Units 3 and 4.

The risk of exceed'ng 10 CFR Part 100 exposure guidelines associated with aircraft operations in 1994 (current risk of military operations) has been conservat'vely calculated to be 4.91E-7/vear.

The expected rate of occurrence of potent'al exoosures in the year 2014 in excess of the 10 CFR Part 100 guidelines has been conservatively calculated to be 8.11E-7/year, which is less than 1.0E-6/year.

The NRC's Standard Review Plan (SRP) states at. Section 2.2.3 (Reference

6) that:

"The probability of occurrence of the in'tiating events leading to potential consequences

'n excess of 10 CFR Par" 100 exposure guidel'nes should be estimated using assumptions that are as representat've of the spec'fic site as is practicable.

1n

addition, because of the low probabilities of tne events under consideration, data are often not available to permit accurate calculat'on of probabilities.

Accordingly, the expected rate of occurrence of potential exposures in excess of 10 CFR Part 100 guidelines of approximately 10'er year is acceptable if, when combined with reasonable qualitative arguments, the realist'c probability can be shown to be lower."

The following reasonable qualitative factors not directly addressed in the risk estimates are provided below to show that the realistic probability of exceeding 10 CFR Part 100 guide'nes will be lower than 8.11E-7/year.:

Because of Turkey Point's distance from the Homestead Reg'onal Airport, local flight operations in the locar traf ic pattern around the Homestead Regional Airport should not approach the p'nt.

This may reduce the risk estimat s by a factor of 2.

Attachment to L-98-152 Qag e Shielding by adjacent structures or heavy machinery, and barr'ers such as the canal and the fossil units are not fully credited.

Th's may reduce the risk estimates by 20:.

The conditional core damage probability and conditional conta'nment failure probability are not based on more detailed assessment of s"ructural capab'ity or all available equ'pment.

Fo

example, Sandia National Laboratory tests have 'ndicated that the containment structures do not experience perforat'on damage.

n addition the steel liner is effective in preventing concrete from scabbing.

This may reduce the risk to varying degrees for different structures but 's not readily auantifiable.

6. Conclusions Based on the results of a conservative

study, the expected rate of occurrence of aircraft accidents leading to potent'al exposures in excess of the 10 CFR Part 100 guidel'nes is 8.11E-7/year for the year 2014.

Qualitative factors that will lower the estimated probability of the aire aft risk exist in the study, which would be acceptable in accordance with SRP Section 2.2.3.

7. References

Kimura, C.

Y. and R.E. Glaser, "Estimate of Aircraft Crash Hit Freauencies on the Facil'ties at the Lawrence Livermore Nat'onal Laboratorv (L~IL) Site 200",

UCRL-XD-127761 Rev 0, Lawrence Livermore National Laboratory, Livermore, CA, July 3, 1997.

"Accident Analysis for A'rcraft Crash into..azardous Facilities",

DOE Standard DOE-STD-3014-96, U.S. Department of Energy, Washington, DC, October 1996.

Sanzo, D.,

R. Bolig, and D. Stack, "ACRAM Modeling Technical Support Document",

LA-UR-96-2460/TSA-11-95-R112, Los Alamos National Laboratory, Los Alamos, NM, September 1996.

Kimura, C.v., Ronald E. Glaser, Richard W. Mensing, Tom Lin, Timothy A. Haley, Andrew B. Barto, and Mart'n A. Stutzke, "ACRAM Data Development Technical Support Document",

UCRL-ZD-124837, Lawrence Livermore National Laboratory, Livermore, CA, August 1996.

Final Environmental Impact Statement, Disposal and Reuse of Homestead Airforce Base, Florida," February

1994, Department of the Air Force.

NUREG-0800, Rev.

2, NRC Standard Review Plan, Sect'on 2.2.3, "Evaluation of Potentia Accidents."

r '

- ~~As

~V4~W".~<i'~~km,(c:~A'."..'.s~.>'B P 12 UNITED STATES OF AMERICA NUCLEAR REGULATORY CQMMISS ION ATOMIC SAFETY AND LICENSING BOARD 8-Before Administrative Judges:

Peter B. Bloch, Chairman Dr. Oscar H. Paris Frederick J.

Shon DQ f.

7cp Pt I:1 2 In the Matter of:

CONSUMERS POWER COMPANY (Big Rock Point Nuclear Power Plant)

Docket No. 50-155-OLA March 6, 1984 MEMORANDUM AND ORDER (Reopening Record On 8-52 Somber Crash Probabilit

)

O'NeHl Contention II-0 states:

The licensee has not adequately provided for the protection of the public against the increased release of radioactivity from the expanded fuel pool as a result of the breach of containment due to the crash of a 8-52 bomber.

This contention was accepted as an issue in controversy because the United States Air Force (USAF) conducts low altitude simula ed bombing runs in the vicinity of the Big Rock Plant, on a training course known as the Bayshore route.

On at least one occasion, in 1979, a Bayshore plane overflew the Big Rock Point Plant at a low altitude, and in 1971 there was an crash of a 8-52 bomber near the plant.

(Supplemen al Testimony of Lt. Col. Gary P.

Setourne On O'Nei'1l Contention II-0 (Betourne Suppl.

Testimony) ff. Tr. 4464, at Z, 3.)

We denied motions for summary disposition of this contention in LBP-82-8, 5

NRC 299, 3Z6-30 (1982) and found that there were genuine issues of fact about the risk of a B-52 crash at the plant.

In its motion for summary disposition of this contention, the Licensee presented the deposition of Maj.

(now Lt. Col.) Gary Betourne, USAF, along with an analysis prepared by him in 1980 estimating the probability of a 8-52 crash at the Big Rock Point Plant (1980 USAF analysis).

The 1980 USAF analysis was prepared in response to a request from the NRC Staff for validation of the results of a 1971 estimate prepared by the USAF.

Lt. Col. Betourne testified during the 1983 hearings, addressing the questions posed by the Board in LBP-82-8.

(Betourne Suppl.

Testimony.)

Because of changes in USAF practices with respect to, the Bayshore route, intended to reduce the risk of a 8-52 crash at the Big Rock Point plant, Lt. Col. Betourne per ormed another analysis of the probability of a 8-52 crash at the plant, based on data from 1982 (1982 USAF analysis),

and included it in his supplemental testimony.

(Betourne Suppl.

Testimony at 7-9.)

Lt. 'Col.'Betourne was cross-examined on that testimony during the 1983 hearings.

Ouring this cross-examination it was revealed by the NRC Staff that there was a conceptual error in the probability formulations of the 1982 USAF analysis.

(Tr. 4550-53.)

As a result the

.1982 analysis underestimated the probability of a 8-52 crash at the plant by a factor of 23,667.

(Tr. 4554.)

Lt. Col. Betourne, after an extended period of The 1980 USAF analysis was discussed by us in LBP-82-8, sunra, at 327-30.

deliberation, accepted Staff's position and corrected his estimate.

(Tr.

4557-62. )

Intervenor O'eil 1, in John O'eill '

Proposed Findings of Fact and Conclusions of Law for Contention II-O, Aircraft Hazards (O'eill Findings) dated February 7,

1984, pointed out what amounts to another conceptual error in the 1982 USAF analysis. 2 In their proposed findings both Licensee and Staff base their conclusions on findings from the 1980'SAF analysis rather than on the 1982 USAF analysis understandably.

Staff witness Or. Kazimieras M.

Campe used the 1980 analysis as the basis for his prepared testimony in the 1983 hearings (NRC Staff Testimony of Kazimieras M. Campe on Aircraft Hazards with Respect to the Big Rock Point Nuclear Plant (Campe'estimony),

ff. Tr. 4655);

he testified that "Our review and 2

This "conceptual error", although not a true error in a mathematical

sense, introduced an unnecessarv step in the series of calculations by Lt. Col. Betourne and tended to obscure the fact that the 1982 USAF analysis was actually quite simplistic.

The point made by O'eill appears to have been recognized by Staff at the hearing (Counsel Goddard at Tr. 4552) but seems not to have been recognized, or if recognized not accepted, by Lt. Col.

Betourne (Tr. 4560, where the witness erroneously calculated an adjusted value for step 3 of the calculations; Tr. 4563, where the witness corrected this error; and Lt. Colonel Gary Betourne's Revised Gross Analysis of B-52 Crash Risk to the Big Rock f Point Plant] 1982, ff. Tr. 4736, at 1, where step 3 is retained in the revised calculations.)

There is no logical need for step 3, and it cancels out when the arithmetic is done.

As succinctly stated by Mr. Goddard,

"[T]he way to reach the probability of a crash at Bayshore is to take the probability of a crash [per run] anywhere times the total number of runs at the Bayshore facility ***".

(Tr. 4552.)

Yet, inexplicably, Staff seems to accept the step 3

calculation in its NRC Staff'esponse to Intervenor John O'Neill's Proposed Findings of Fact on ***Aircraft Hazards Contentions dated March 1, 1984.

verification of'he Air Force Analysis led us to conclude that it was reasonable and provided an adequate basis for the B-5Z crash risk estimates."

(Campe Testimony at 5.)

But Lt. Col. Betourne was responsible for the 1980 USAF analysis as well as for the 1.982 USAF analysis.

Given the obvious problems that Lt. Col. Betourne had with the.

rather simple 1982 analysis, we are reluctant to accept the more complex 1980 analysis on the basis of the superficial assurance by Or.

Campe, quoted above, that it was reasonable and adequate.

While we do not, intuitively, believe that a B-5Z crash poses a significant hazard for the Big Rock Point Plant, we are obligated to reach a decision with respect to this and other contentions on the basis of the record developed during this proceeding, not on our intuition.

In view of the problems encountered with the 1982 USAF analysis, we 'need documented assurance that the Staff has conducted a detailed, line-by-line and calculation-by-calculation, review of the 1980 analysis (including a review of the method by which the USAF collected its crash data and

'erived its crash-per-run probability); we must be assured that Staff finds it not only reasonable and acceptable, but conceptually and mathematically correct as well.

We note with some uneasiness the fact that the corrected 1,982 analysis shows a much higher probability of crash than did the 1980 analysis adopted by Staff and Licensee, despite the fact that the bomb run had been changed in the interim to produce a lesser risk.

Accordingly, we are reopening the record in this proceeding with respect to the B-52 crash contention.

We are requesting the Staff to provide us with a detailed, critical review of the 1980 USAF analysis.

That review shall be filed, in the form of an affidavit, within 30 days.

Licensee and intervenors may respond to the Staff'iling within 15 days.

Should the Staff find problems in the 1980 analysis which throw the results into question, we shall expect Staff to propose an acceptable means for obtaining a more adequate record with respect to this issue. 4 Although we do not anticipate adopting Or. Schwartz's vieir about statistical uncertainty in the context of the regulatory scheme for air crash hazards (Evidentiary Oeposition of Or. Arthur Schwartz taken November 16, 1983; See Standard Review Plan 2.2.3 at 2.2.3-2),

we find Staff's comments on the O'eill Findings with respect to Or. Schwartz to be troubling.

In its response to O'Neill's proposed findings on aircraft hazards,'dated March 1, 1984 Staff noted what while it is generally true that the accuracy of probabilistic estimates is linked to sample size, this was--in Staff s viewnot a deficiency in the USAF analysis.

It explained this position in the following way:

The portion of Lieutenant Colonel Betourne's USAF analysis involving statistical data is limited to B-52 crash data and 3-K abort data.

(Betourne's revised gross analysis, following Tr. 4735.)

The probability of a crash at Bayshore is estimated to be about 0.018 per year.

The probability of an overflight, based on 3-K abort statistics, is estimated to be about 0.0042.

The question of s.atistical sample size is applicable to these ~robability values, and not to the final result of 5.3 x 10 (emphasis supplied If the Staff means what it has said here, we find its conclusion ludicrous.

The product of uncertain probability values does not gain imunity from the uncertainties associated with the multiplier and multiplicand by the act of multiplication.

guite the contrary; the product suffers from the uncertainties of both.

ORDER For all the foregoing reasons and based upon a consideration of the entire record in this matter, it is, this 6th day of March 1984 ORDERED 1.

That Staff shall file no later than April 5, 1984 a detailed review of the 1980 USAF analysis.

If Staff finds that the analysis contains error or for any other reason is inadequate, Staff shall propose a means of developing an adequate record on this issue.

2.

Consumers Power Company and the intervenors may file responses to Staff's review by April 20, 1984.

THE ATOMIC SAFETY ANO LICENSING BOARD eter B oc, airman AOMINISTRATIVE JUDGE scar

. Parss ADMINISTRATIVE JUDGE

Bethesda, Maryland redenck J.

S AOMINISTRATIV JUDGE

JAN-13-2908 11: 45 L"99"253.

U. 5. Nuclear Regulatory Commission Accn: Documert Control Desk Rash agtan, D.C.

20$ $ 5 Gentlemen:

Tu icy Paint Units 3

a 4

Docket Ãas.90-250 and 50-25%

Response

co Request for Information Rega ding the Xmpact of a Commercial Pi~art at Homestead Air Farce Base Site on Safety a" Turke Pain" Units 3 and 4

On August 23,

1999, the Aix Force notified the NRC chat a supplemental Environmental Tmpacc statement was being pxepared fo the Homestead Ai" Force Base conversion project ta (a) reflect updated air traf ic infarmatian aSSOCiated With a "NaXimum USe One RunWay" (MUOR) projection, (b) ref'ect a3.tenace flight trac3c configurations currently undex consideration or noise abatement, and (c) evaluate the environmental impact associated with the optional use of the facility as a commercial spaceport.

The NRC subsequently issued a request co Flarida Power 6, Light (FPL) co assess the impact of the pxoposed c.'mr.ges on the previously s'ubmitted risk assessment documented by FPL lettex L"98-152 dated June LS, '998, and ta inform the 0RC of any changes within 60 days.

FPL has completed the assessment of the impact of the proposed changes and detexmined that the ove all isk to Turkey Po'nt from an aircra

=

accident decreases from the previously estimaced S.ll.E-7lyr ta 3.63E" 7/yr based on the new projections and MUOR conditions.

ccmpazison of the or'ginal ai~arc conversion plan flight projection=

with the latest Federal Av'ation Administration (FAA) flight praject'ons indicates chat, the total number of flight operations has remained relatively constant between the two fo ecasts.

The oziginal data (Table

1) fo ecasted a maximum of 246,700 flight operations in the yea

2014, while the current projection (Table

2) forecas"s 231,274 flight operations under HUOR cond'tions, The projected mix of flight operations at the airpo ", however, has changed in che latest FAA submittal.

As ind. cated in the attached tables, the evised flighc data includes a decrease in Projected military air craff'c and a coxresponding inc ease in civilian air traff'c.

This change in the projc"" d -...'.". cf flight operations ac. the aixpoc does

'mpact che risk assessmcnc previously cransmicted ta you in suppoxt of the F'ml Envizonmencal Tmpact Statemenc.

As revealed in the previous analysis, the risk of ar. ai craf" impact ac Turkey Point. is dominated b mil'ary a'r traffic.

TM.s dominance is due in part to the face that. che probability o an acc'denc per flight operation is much higher for military aire"aft than for commercial or general aviation aire afc.

oa FPL Group corn pony Zaclosure 3

JAN-13-2888 11: 45 P. 82 L-99-251 Page 2 of 5 Th's is due to ehe highex pexceneage of h'gh-risk ace'vic's associated with mi'itary flighcs, e.g., t aining, high-speed maneuvering.

The dom'nance is also due to the fact that che p obabiliey of an aire aft accident occux=ing in the immed'ace vicinity of the aixporc is much higher fo military a'rcraft than fo" conznercial or general aviation aircraft.

That 's, mosc commercial or general aviation flights leave the airport area afcex takeoff.

when land ng, they axe mosc often ar iv'ng f om places a considerable distance fiom the a'rport.

awhile che same can be said fox some military air traffic, a high percentage of ehe military flights consist of training exercises near ehe airport, leading eo a highe probability eha" if an accident does occu, ic will be in ehe vicinity of ehe home aixpo=t.

The latest FAA flight projections indicate chat che decrease in large military aircraft txaff'c is seven-fold.

For small military aircraft, the decrease is 28.1%.

Despite che fact that the amount of comme "ial jumbo jet operations (Class A ai carriers) in ehe laeest forecast 's over three times chat of the original farecast, the overall'risk eo Turkey poine from an aircrafe accident decreases fxcm 8.11E-7/yx to 3.63E-7/y unde MUOR conditions as a consequence of the px'ed'cted decx'ease in military air traff'c.

This xepresents a

55% x'educt'on in che frequency of aircxafc accidents ac the site having ehe potential to generate exposures in excess of 10 CFR 100 limits.

Xt is also well be3.ow 1E-6/yr significance threshold spec'fied in Section 2.2.3 of NUREG 0800.

Thc following reasonab3.e qualitative factors nat directly addressed in the risk estimaee axe provi.ded below to shaw that the realistic probability of exceeding 10 cFR '00 guidelines due ta an aire aft impact will be lower et~ the revised risk estimate of 3.63E-7/y-for Tu key Point.

1. Shieldingby adjacent scructures or heavy machinery, and ba ie s such as the canal and the fossil unics are not fully credited.

This may educe the risk by 20%.

Z. The conditional core damage probabi,liey and 'conditional conta'nme-.e failure probability are noc based on more detailed assessment of stxuctuxal capability or all available equipmene.

For example.

Sandia Nacional Laboratory tests have indicated that che containment structures do not experience pexfoxacion damage.

Zn addic'on.

the steel line is effeccive in preventing concrete from scabbing.

Th' may educe

=he isk to varying deg ees for different structures bu" is noc x'eadily ~manci 'able.

L-99-251 Page 3 of 5 The structu es at ~key Point considered to be czitical structures foz the puzpose af the z'sk assessment were the containment build'ngs, tu=bine build'ng, control building, aeciliazy bu'lding, spent fuel bu'ld'egs, emezgency d'esel generator buildings, intake structure, and the foes'1 un'" chimneys.

With respect to the spaceport

option, FPL did not perform a speci ic analysis co gratify the effects of potent'l launch vehicle failures at the base due to the limited number of flight operations projected o

such a facy.

The potential impact o a spaceport at the Homestead A'r Fo ce Base location would be bounded by the impact associated with a commercial. airport.

As indicated in our previous correspondence on this subject, FPL continues to corrmxnicate with local and state authorities on this matter in o der to ensure that the 'ssues coming f om the comme cialization of the base are identified, chat the offsite emergency pzeparednese p ogram to address these issues is appropriately revised, and to ensure tho Federal Emergency Nanagement Agency is in concurrence with the rev'sions to the program.

Once the proposed dispositicn of the Homestead Air Fo ce Base is finalized, FPL will update our F'nal Safety Analysis Report, as appropria e, to reflect these changes.

Should there be any cuestions on this submittal. please contact us.

e truly yours, 4/A x

R. J.

H Vice President Tu=key Point Plant OH/MG cc:

Regioral Administrator, Region EI, USNRC Senior Resident Inspector, USNRC, Turkey Paint Plant Floz.'da Department of Health and Rehabilitative Services

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A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants Manuscript Completedt hprll 1997 Date Published: huguat 1997 Prepared by R. J. Travll, R. E. Davis, E. J. Grove, M h. hzarm Brookhaven National Laboratory Upton, NY 11973 G. J. Mencinlky, NRC Program Manager Prepared far; Division of Regulatory Applications OQice ofNuclear Regulatory Research V.S. Nuclear Regulatory Commission Washington, DC 20555-0001 NRC Job Code L2590

EXECUTIVE The long-term availability of less expensive power and the increasing plant modification and maintenance costs have caused some utilities to reexamine the economics of nuclear power.

As a result, several utilities have opted to permanently shutdown their plants.

Each licensee of. these permanently shutdown (PSD) plants has submitted plant-specific exemption requests for those regulations that they believe are no linger applicable to their facility. The preparation and subsequent review of these exemption requests represents a large level of effort for both the licensees and the NRC staff. This experience has indicated the need for an explicit regulatory treatment of PSD nuclear power plants.

This report presents a regulatory assessment for generic BWR and PWR plants that have permanently ceased operation in support of NRC rulemaking activities in this area.

. After the reactor vessel is defueled, the traditional accident sequences that dominate the operating plant risk are no longer applicable.

The remaining source of public risk is associated with the accidents that involve the spent fuel.

Previous studies have indicated that complete spent fuel pool drainage is an accident ofpotential concern. Certain combinations of spent fuel storage configurations and decay times, could cause freshly discharged fuel assemblies to self heat to a temperature where the self sustained oxidation of the zircaloy fuel cladding may cause cladding failure.

Spent Fue1 Configurations This study has defined four spent fuel configurations which encompass all of the anticipated spent fuel characteristics and storage modes followingpermanent shutdown. Spent fuel which (due to a combination of storage geometry, decay time, and reactor type) can support rapid zircaloy oxidation is designated as Spent Fuel Storage Configuration 1 - "Hot Fuel in the Spent Fuel Pool." Configuration 1 encompasses the period commencing immediately after the offload of the core to a point in time when the decay heat of the hottest assemblies is low enough such that no substantial zircaloy oxidation takes place (given the pool is drained), and the fuel cladding will remain intact (i.e., no gap releases).

After this point, the fuel is considered to be in Configuration 2 - "Cold Fuel in-the Spent Fuel Pool."

The fuel can be stored on a long-term basis in the spent fuel pool, while the rest of the plant is in safe storage or decontaminated

{partial decommissioning).

Alternatively, after decay heat loads have declined further, the fuel can be moved to an ISFSI (designated as spent fuel storage Configuration 3). This would allow complete decommissioning of the plant and closure of the Part 50 license.

Spent fuel storage Configuration 4 assumes all spent fuel has been shipped offsite. This configuration assumes the plant Part 50 license remains in effect only because the plant has not been fully decontaminated and cannot be released for unrestricted public access.

A representative accident sequence was chosen for each configuration.

Consequence analyses were performed using these sequences to estimate onsite and boundary doses, population doses and economic costs.

ix HUREG/CR-6451

Regulatory Assessment After a plant is permanently shutdown, awaiting or in the decommissioning

process, certain operating based regulations may no longer be applicable.

A list of candidate regulations was identified from a screening of 10 CFR Parts 0 to 199.

The continued applicability of each regulation was assessed within the context of each spent fuel storage configuration and the results of the consequence analyses.

regul:itions that are no longer fully applicable to the permanently shutdown plant are summarized below:

The yet +f regulations that are designed to protect the public against full power and/or design basis accidents are no longer applicable and can be deleted for all spent fuel storage confiigurations of the permanently shutdown plant.

These regulations include combustible gas control (50.44),

fracture prevention measures (50.60, 50.61), and ATWS requirements (50.62).

Other regulations, although based on the operating plant, may continue to be partially applicable to the permaiiently defueled facility. This group of requirements includes the Technical Specifications (50.36, 36b), the fire protection program (50.48) and Quality Assiirance (50.54(a) and Part 50 Appendix B).

The rapmements for emergency preparedness (50.47, 50.54(q) and (t), and Part 50 Appendix E),

onsite'roperty damage insurance (50.54(w)) and offsite liability insurance (Part 140), were evaluated using the accident consequence analysis.

Since the estimated consequences of the Configuration 1 representative accident sequence approximate those of a core damage accident, it is recommended that all offsite and onsite emergency planning requirements remain in place during this period, with the exception, of the Emergency

Response

Data System requirements of Part 50, Appendix E.

Subject to plant specific confirmation, the offsite emergency preparedness (EP) requirements are expected to be eliminated for Configuration 2, on the basis of a generic boundary dose calculation.

Part 50 offsite EP requirements can also be eliminated for Configurations 3 and 4 because the spent fuel has been transferred to an ISFSI (subject'to Part 72 requirements) or transported offsite. Without spent fuel, the plant is not a significant health risk. It is recommended that the onsite property damage and the offsite liability insurance levels remain at operating reactor levels for the duration of Configuration 1. The consequence analyses support reduced insurance requirements for the remaining configurations (2,3, and 4).

HUREG/CRM51

4 RESULTS OF THE CONSEQUENCE ANALYSES The MELCOR Accident Consequence Code System, MACCS' was used in this study to model offsite consequences.

The principal phenomena considered in MACCS are atmospheric transport, mitigative actions based on dose projection, dose accumulation by a number of pathways (including food and water ingestion), early and latent health effects, and economic costs.

The prediction of onsite consequences (occupational doses) has traditionally been estimated through deterministic calculation of dose rate(s), dose(s) and contamination level(s), generally of a scoping or bounding character.

Typical of these methods, was the guidance provided by Regulatory Guide 1.25,

'Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel'Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors."~

A typical application of this method wa's documented in NUREG/CR-5771.~

1 In this study, a variety-of deterministic methods were applied These include'd the standard method as.

~

outlined in relevant Reg. Guides, and/or alternate methods, such as the Ramsdell model,~ for estimating the concentration of material entrained in the building wake.

The methods are important for predicting on-site consequen~,

a region generally not modelled adequately by the MACCS 'code.

4.1.. Configuration 1. - Resultt A series of MACCS code calculations were performed to,quantify the postulated. accidents cases for the Configuration 1 conditions described in Section 3.1.

For each accident, Cases 1 through 4, and each generic reactor type, two calculations were performed: one using the set of high release fractions (H) and a second employing the set of low release fractions (L). The latter generally included a DF of 10 for particulates to reflect potential for retention of activity in structures.

The results are tabulated in Table.

4.1 and 4.2.

A case by case comparison of the results for Configuration 1 indicates that the generic PWR and BWR results are very similar.

Generally, the results are within 20 percent of one another, althou'gh in a few compyrisens the differences may be somewhat larger.

This similarity would be expected on the basis of ideruical site assumptions, weather conditions, interdiction criteria, and source term fractional releases adopted for both reactor evaluations.

PWR inventories were generally larger than corresponding BWR inventories.

The higher PWR consequences were attributable to the assumed higher burnup, the inclusion of the last normal refueling discharge in cases where the last core discharge was considered, and the relatively larger PWR pool size in the cases that considered full pool involvement.

NUREG/CRM51

u 1%

4 Results of thc Consequence Analyses Table 4.1 Mean PVfR Consequences Acodect btrenrory Disamee

0nlles).";

. Prompt "

'.Pataltles;

~

~ *'

'vcS

'odetal'Dose 0

~~4;(person-rent:xIW ~A <Fisalltles~

~ Cootlentnett ~

"<9q. relies) "~

Total.<

(Sx10')~

Case IH ttttl pool Case LL tttti pool use 38 50% pool Case 3L 50% pool last cote~

0-50 0-500 0-50 0-500 0-SO 0-500 0-50 0-500 0-50 0-500 0-50 0-500 70 95 1.2 1.2 29 33 0.3 0.3 0'0

'6 0

74 339 62 130 81 226 42 70 32 48 4

5 31,300 143,000 25,300 S3,800 33,200 94,600 16,800 28,800 2,4$

3,400 10,100 15,40

',500

',300 467 2790 297 869 156 188 15 15 287 566 100 117 186 274 56 59 15 15 0.8...

.0.8

• Thc 'Last core'lso includes thc Last normal refueling discharge.

• • excludes health elrects A limited comparison can be made of the results obtained in this effort with those of previous investigations.

The consequence estimates obtained here are generally higher.

For example, the societal dose comnlitnlent (0 to 50 lniles) for the worst case accident (fire, full pool involvement, high release fractions) reported by Sailor'as 2.6 millioa persoa-rem; Jo'eported 25.6 million person-rem; while in the present work 75.3 million persoa-rem (BWR) was obtained.

As discussed'in Appendix A, these early efforts used identical inventory and source term assumptions.

The differences observed were primarily due to the population assumptioas.

The average populatioa density (0-50 miles which includes the large city) used herein was about l800 persoas per square mile. This would support an approximate increase of a factor of two over the dose reported by Jo.

The second major reasoa the consequences are greater is the radionuclide inventory used here.

The assumptions made for reactor power, end of plant life fuel burnup and fuel pool capacity, resulted in an inventory which has substantially higher quantities of the long lived radionuclides thaa previous studies.

For example, the total BWR pool inventory of Cs-137 was about a factor of 3 greater than developed by Sailor for the Millstone plant.

Thus, the limited comparisons would indicate that the consequences determined in this study were geaerally higher than the former studies.

The consequences are consistent with earlier work, when gross differences in the tUIderiying assumptions are taken into account.

NUlKGICRM5l

4 Results of the Consequettce Attalyscs Table 42 Mean BAR Consequences

Acddeat

~ '

..c 91stsLaee

~(mlles) '

" Prom pt",..

r

~

'::"Socletat Dose...

'. Lateat

-..(persoa~" x10'-.,"Fatalldes.

Con deauied

".(st. maes) ;

~Total '".i

'.$x!0.,

~e stH full pool Case 1L fullpool 74 101 1.3 1.3 0.2 0.2 75 327 58 120 81 207 38 62 31,900 138.000 23,600 49,800 33,000 86,400 15,300 25,700 456 2170 286 784 262 521 140 159 280 546 97 113 167 234 48 51 Case 3H 50% pool 0-50 0-500

.0 0

29 45 12,200 18,900 Case 3L 50% pool 0

0 5.

7 2,100 3,000

. 2' 1.0 1.0 Case 4H hst cote

,0, 0

20 30 8,300 12.700 13

'13 12 '

12 Case 4L last cote 0

0 1,300 1,900 0.7'.7

• 'xdudes hedth eQ'ects The total costs of fuel pool accidents observed in this study were found to rise more sharply than the societal dose.

This reflects the tradeofB of protective (interdictioa and relocation) actions.

These actions are, of course, iateaded to limit public exposure to the released radioactivity, but at the increased cost of primarily popuhtion dependent interdiction aad relocation expenses.

Again the major obvious factors, which wHl drive costs up in comparison to earlier studies, are the larger population at risk and the larger inventory of material considered in this study.

This observation is supported by a comparison of the condemned land.

Comparing Case 1H ia Table 4.1 or 4.2 with case 1A of Table A.2, it can be seen that the condemned area has doubled.

Although, Table A.2 ideatifies this as interdicted area, which might be subject to a different interpretation given the usage of this term by the MACCS code, the text of the Sailor study clearly stated

... iaterdicted area (the area with such a high level of radiatioa that it is assumed that it cannot ever be decontaminated)."

Condemned land is defined as farmland permaneatly removed from production, as such it does aot account for the populatioa affected area.

However, the condemned area for case 1H ia the present study clearly indicates a more extensive contataiaatioa of all lands when compared to the former study.

This increase translates into increased costs.

NUEMGICR-6451

4 Results of the Conscquencc Analyses Table 42 PWR Core Melt Accident Results RZl wig evacuation RZl no evacuation 3800 Mwt core 3800 Mwt core Distance

. (tnoes)

,,Prompt

,:FataUtfes:,

88 160 SadetaJ Dose xl(Pj 70.

220.

35,000 110,000 Condemned (sq.'.mlles); t

'oses that werc not reported, have been estimated Qom the number of latent fatalities and the BEIR-V recommended risk coel5cient of 5.0E< fatalities per person-rem.

(Reproduced Rom Reference 14)

For perspective, it is interesting to provide some comparison to core melt accidents.

A major core melt accident (RZI, large early release) was selected from the results reported in Reference

14. This study eruployed many. of the assumptions, i.e., population 'distribution aad weather conditions, that were employed in the present analysis, thus allowing for reasonable comparison.

The core melt accident source term was 100% of the noble gases, 'P% of the iodine group, 21% of the cesium group, 10% of the tellurium group, 12%-of the barium'and strohtium groups, 0.52% of the rutheaium group, 0.2% of

- the lanthanum group and 0.6% of the cerium group.

Table 4.3 summarizes the reported results.

The core melt accident results are provided for two emergency protective actions:

oae ia which a representative evacuation was modelled along with long term protective actions; and a ao evacuatioa, no long term protective anion case.

The later case, while unrealistic, provides a very conservative bounding estimate of the consequences.

A case with promtive actions identical to this study was not reported.

However, the results of such an analysis would have provided results intermediate to those reported (with the exception to condemned land which is not affected by emergency response).

Comparison with the results shown in Tables 4.1 and 4.2 clearly indicates that for worst case assumptions, i.e., full pool involvement and large source term, the postulated Configuration I speat fuel pool accident may have cornparhble'consequences to a major core melt accident.

Previous studies have elected to quantify the risks and costs of fuel pool accidents using either Case 1

or Case 2 results.

In their final analysis, Sailor, et al.,'hose the last refueling offload/maximum source term accident results.

In Jo, et al.,'

worst case (fuQ pool/maximum source term accident) and a best estimate case (last refueling/maximum source term accident) were explored.

For the preseat evaluation, BNL recommends that the estitnated consequences for case 2L be used.

This case assumes that the accident is limited to the last full core discharge (plus the last normal refueling discharge in the case of a PNR} and the lower release fractions, that refiect some credit for fission product retention.

This recommendation has been made for the followiag reasons.

As discussed in NUREG/CR4982, there is a large degre" of uncertainty associated with the fire propagation throughout the entire pool.

Additionally. mitigative opuons such as rack modifications,~ (i.e.,

increased hole size) aad fuel HUREG/CR-6451

Reactor Spent Fuel Storage Reactor Spent Fuel Storage 44 Spent Fuel Pool and Full Core OfQoad Capability Note: This data is based on unevaluated information provided to the NRC by licensees.

It is current as of November 4, 1998.

Plant Name Arkansas 1

968 Core Size Capacity l

777 Spent Fuel Pool Assemblies Stored 818 Remaining Capacity 150 Gun ent Ucense Expires 2014 Lose Full Core ONoad Capability LOST Dry Cask Storage' YES Arkansas 2 177 988 701 287 2018 1999 YES Beaver Valley 1 Beaver Valley 2 Braidwood 1 Braidwood 2 Browns Ferry 1 Browns Ferry 2 157 1627 1088 193 193 764 3471 3133 2353 157

+870 756 392 1054 1864 2116 1588 871 696 1816 1607 1355 1879 2016 2027 2026 2027 2013 2014 2016 2018 2012 2010 2010 2013 2006 NO NO NO NO NO NO Brunswick 2 Byron 1 Byron 2 560 i

580 1767 1767 1020 1278 783 747 1503 2016 2014 2024 2026 2000 1999 2010 NO Callaway Calvert Cliffs 1 Calvert Cliffs 2 Catawba 1

Catawba 2 1340 217 217 193 193 1418 1418 183 1830 829 1362 705 686 511 468 622 695 2024 2014 2016 2024 2026 2004 2006 2006 NO YES YES Clinton Comanche Peak 1

Comanche Peak 2 624 193 193 2515 556 735 1124 765 1381 526 2026 2030 2033 2006 2002 NO Cooper Crystal River 3 Davis-Besse D.C. Cook 1 D.C. Cook 2 177 2366 1357 718 i

177

~~3843 1340 680 601 2015 1026 677 117 1598 2014 2016 2017 2014 2017 2004 2011 Lost in 1998 2011 2011 YES NO NO Diablo Canyon 1

Diablo Canyon 2

!Dresden 3 193 193 724 724 1324 1317 3537 3536 640 660 2562 2380 657 975 1156 2021 2025 2006 2011 2006 2007 2002 2003 NO NO Duane Arnold

,Fariey 1

Farley 2 Fermi 2 388 l

2411 1s7 l 14o7 l

157 l

1407 2383 1648 662 593 1296 763 527 1087 2014 2017 2021 2025 2003 2006 2010 2001 NO NO lFitzPatrick Fort Calhoun 560 2797 133 1

1083 2080 706 717 377 2014 2013 2007 NO NO l of3 I/28/00 4:04 PM

Reactor Spsnt Fuel Stongc hnp//www.nrc.gov/OPA/drycask/sfdata.htm

[Ginna Grand Gulf 1 Hatch 1

Hatch 2 Hope Creek 121 1879 4348 764 4006 600 I

660 6946 879 2488 4884 1708 435 1860 1062 2298 2009 2022 2014 2018 2026 2005 2000 2000 2008 NO NO Indian Point 2 193 1374 917 457 2013 2006 NO Indian Point 3 Kewaunee LaSalle 1

LaSalle 2 Limerick 1 Limerick 2 193 1345 990 764 764 2832 3921 121 I

1992 672 780 3076 1701 1893 655 210 4852 1131 2028 2015 2013 2022 2023 2024 2029 2011 2009 2013 2013 2006 2006 NO NO McGuire 1 McGuire 2 Millstone 2 Millstone 3 Monticello Nine Mlle Point 1 Nine Mile Point 2 North Anna 1 North Anna 2 Oconee 1

Oconee 2 Oconee 3 Oyster Creek Palisades Palo Verde 1

Palo Verde 2 Palo Verde 3 Peach Bottom 2 Peach Bottom 3 Perry 1 Pilgrim Point Beach 1

Point Beach 2 Prairie Island 1

Prairie Island 2 Quad Cities 1 Quad Cities 2 River Bend Robinson Salem 1

Salem 2 San Onofre 2 San Onofre 3 Sea brook Sequoyah 1

Sequoyah 2 193 193 217 193 532 157 157 177 177 177 560 241 241 241 748 560 121 121 724 724 624 157 193 193 217 217 193 193 193 1351 1425 1263 756 2209 2776 4049 1737 1312 1312 825 2645 771 1205 1205 1205 3819 3819 4020 3859 1386 3657 3897 2680 544 1632 1632 1542 1542 1236 2091 871 1039 868 416 1094 2200 1400 1505 1094 1094 552 2420 657 2720 2777 1504 1974 1347 1237 1933 2943 1400 302 772 870 918 376 1295 480 386 423 340 1115 576 2649 169 218 218 273 180 101 557 561 541 1099 1042 2516 1885 155 125 1724 954 1280 242 850 1038 672 624 860 796 2021 2023 2015 2025 2010 2009 2026 2018 2020 2013 2013 2014 2009 2007 2024 2025 2027 2013 2014 2026 2012 2010 2013 2013 2014 2012 2012 2025 2010 2016 2020 2013 2013 2026 2020 20214 2002 2001 2002 2001 2006 1999 2010 2013 2013 2014 LOST LOST 2004 2003 2003 2000 2001 2011 2007 2007 2002 2003 2006 2012 2016 2006 2006 2010 2004 2004 NO NO NO NO NO NO YES YES YES YES YES YES YES NO NO NO YES YES YES YES NO NO YES NO NO NO Shearon Harris 1 South Texas 1

',South Texas 2 St. Lucie 1 St. Lucia 2 157 193 1969 I

193 1

1969 217 I 1706 217 1076 720 PWR and 1841BWR 428 400 1128 692 336 PWR and 557 BWR 1529 1556 578 384 2026 2027 2028 2016 2023 2024 2025 2006 2001 NO NO 1

NO 2of3 I/28/00 4:04 PM

Reactor Spent Fuel Storage http://www.nrc.gov/OF A/drycask/sfdata.htnt jSummer Surry 1 Surry 2 Susquehanna 1

Susquehanna 2

157 157 157 764 1276 1044 2840 2840 637 854 2655 1762 567 2022 None 823 2022 2024 2012 190 f

2013 2006 NA 2000 2000 YES YES YES YES Three Mile Island 177 1338 755 583 2014 Turkey Point 3 Turkey Point 4 Vermont Yankee Vo9tle 1

Vogtle 2 WNP 2 157 157 193 193 1395 1389 2883 1475 1998 2654 808 770 2331 1081 1703 587 619 532 2012 2013 2012 2027 f

2029 2392 2023 2009 2009 2001 2015 2015 1999 NO Waterford 3 Watts Bar 1 WolfCreek 217 193 193 2398 1612 1327 700 80 664 1698 1530 2024 2035 2025 2018 2018 2008 3 of3 i/28/00 4:04 PM

D ~

TMENTOF TEE AIRFORCE 482D HGHTER%2fo (hBRES) 2S Mar 96 MEMORANDUMFOR: SEE DISTRIBUTION PROM 482PV/)E 29050 Coral Sea Blvd., Box 37 Homestead ARB, H, 33039-1299

SUBJECT:

Minutes of 18 Mar 96 BirdHazard%orMng Group {BHWG) 1.

The Homestead AirReserve Station Bird EGumd%'orhn Group met 18 March 1996, 0900, 3360, 482 FW Safety Conference Room.

e llowingpersonnel attended; Col Steve Fulghum Lt Col Joe Dunaway Andy Bobick Dwight Hegge BQI Comber Mike Handrahan Ray Talbird Connie Dodson 482 OG/CC, Chairman, X7459 482 PV/SE, Facilitator, X7333, 482 SPTG/CEV, X7344 482 OG/QSAT, X7510 482 OG'OSA, X7072 DCAD Operations, 238-6093/Fax 23S-9180 482 SPTG/BCF X7476 Scribe, X7063 2.

INTRODUCTIONS were made as attendees arrived.

3.

REVIEW OF BASHPLAN: The HAZS BASHPlan was b~eQy reviewed.

This program is a ~1 priority in the AirPorce Reserve.

The Plan outlines responsibiHties and procedures of aH concerned with bird hazard reduction at HARS.

4.

PERSPECTIVE ON BIRD PROBLEM:

The Air Force loses an average of two aircraft yMyd 1'I

'k L~244 I

E d CAB, 'UU*~

h f A%ACS aircrait So far, 57 people have been gled in AirForce aircraR due to bird strikes between 1985 and 1995.

Fart ofthe problem at HARS is that the birds are not re e

the former strong smell of JP-8, and the large amount ofjet noise that characterized the airfield enviro ent ore e

umcane.

Our"

>s also gro g to suc a

e ee at we avemore e

an ever rawnto thearea o

aroun our t

e, runway, and base, EXHiBiT

7:87I=M KEi ICA L TellANl: B<ECUTIVEA:RPT.

HO.F87 P.Bib S.

DIME'IONOF~ PROBLEM a.

Habitat Change:

Our airfield drainage ditches and culverts have become so ove~wn and clogged that: they support more natural vegetation.

This habitat attracts more birds. Our bird population has drastically increased due to the plentful food supply.

b.

Mount Trashmore; Naturally, our proximity '.o this monument to human garbage puts us in the path ofguHs and vultures tra~ to and Rom MtTrashmore, c.

Proximity to Bay/Ocean:

Another habitat oflarge and s~i birds in our Qying area, 6.

SU1V&dMY OF ACTIONS TAKETO DATE:

a.

Wing Safety Ofhce.

(1) The Bird AircraitStrike-&sard Reduction (BASH) plan was published in February.

(2) The E3A ANACS mishap was briefed in d pth to aH assigned/a~bed pilots as required by the ALSAFCOM.rnsg.

(3) A bird hazard environment survey by the USDA Animal Damage Control Division Chief was requested and was accompHshed 23 Feb 96.

Report dated 4 Mar 96 has be n received. (Attachment 1)

(4) Close coordination has be.n estabHshed with BCE Environmental Flight to formulate suey'es for restoring our airfield drainage canals to functionality.

(5) Conducted BHWGthis date.

b. Airneld Management/Tower.

{I)Chief, Airfield Management has appointed and ~ed the Bird Scare Group.

Newer, more state ofthe art scare equipment is being order d ior the group, (2) Integrated light bar with horns, sirens, speakers are being ordered to equip Base Ops vehicle, ivfako $OF vehicle, and OG vehicle.

(3) Bird Watch conditions have been reviewed along with the procedures to establish/change them.

(4) Tower Chief has reviewed Bird Natch conditions/procedures with his personnel.

(5) Numerous training sessions/Qight safety brieQngs have covered lessons!mrned from the deficiencies in the Elmendorf mishap.

(6) The Tower Controllers are doing a good job observing/repo~g bird sighting withn the limitations oftheir visibBityRom the temporary tower cab.

c.

BCE Environmental Flight, (I) BCE Environmental participated in a recmt working visit by an AFRES/CE scientific contractor to develop an Integrated 5'aturai Resources Plan forHomestead ARS.

This Integrated Natural Resources hhnagement plan wiQ have an impact on our BASH program.

The BASH Program may have to be revised to comply with some ofthe provisions or this plan when it is published.

(2) The once has made contact with both DERN and CORPS Wetland folks regarding the need to acquire permits to clean our the drainage canals near the runway. Both

. 'R ~ Cs9 a.996 7:CPM Is'. ~CALs TAs'tZAMJ EX'T VE AINT.

vo,GS7 P.4i9 oQices iadicated the:e should be ao problems restoring the canals to their earlier, func:ioaal stare.

(3) The once has been workiag on a Statement of Work ror he restoration of the canals to their c!eaa aad functional state.

Inc!uded in the Statement OfWork is the cleaning ofthe culverts thar. cross under the runway ta connect with other canals for drainage.

I d.

Wing Stan EvaL (1) A-thorough review of Supervisor oi Hying proc:dures relating to bird hazard conditions aad procedures has ben conducted.

(2) Local, Chapter 8, MCI11-F-16V3 contained autdared dermitions of Red Watch conditions.

A change will be published to this publicanon reQecting the latest wording.

7.

POSSIBLE SOLUTIONS:

a. We must get invoived with esture iandglls/power piants to ensure dtejj are not in our flight parhs.

It was nared that, had EARS be a a civilian airport, Mt. Trashmore would never have been built where it is.

4~~~ ~/ u~slt

b. Retain the services ofa WildlireBialogist to assist in management ofaur bird problem and to caaduct the research necessary upon which to base long term bird management dec!sions

c. We must identify the ma~tude of the problem Identify the birds and their habits, We ne.d help f'rom US national wildlire professionals in this area.

Gen Turner has said we need people smarter than us in these areas to assist.

BASH people do not go on the road anymore; we go to them for training. There wi0 be an AERIES BASH Inspection tewwn here we !: after next k to look at our program.

cL We must get somethiag done with the canals and culverts very saaa.

The culvert areas are lakes now; and the rainy seas'on is on the way, Hoodiag willclose the aimeld.

This was brought to the BCA,'s attention quite some time ago, aad they were to "look into it". Mr. Mitchell, CE Environmental

shop, has contacted DEEM and natural reso~

people; it is reasonable that permits for clean-up willbe granted, but it is a slow pramss.

e. We need to equip 3-4 vehicles with "scare" weapons, including a PA system and a tape player.

iVrr. Comber thinks for $1200-1300 per vehicle we can have lights, horns, whistles, etc.

The vehicles selected will probably be the Base Ops vehicle, OG Vehic!e, and the Mako SOF truck. QSA has a Bird Hazard Conditions OI which wiQ be updated.

0

f. We need to specify the quantity of birds est make "fow", "moderate" and "severe" acavity. This inrormatioa willbe updated in the 482 righter Wing Bash Plan.

A ~ C5 ~ L>)b k+0 h8 f

z. Mr. Handrahan, DCAD:

Check with Dade County Solid Waste and any other Dade County sources regarding the future status ofMt. Trashmore; location oi a new landGll in South Dade; and a new power plant in @is area.

b. Mr, Comber, OSA.'esearch the costs to set up the Hase Ops/SOP/OG vehicles with weapons for scaring birds. OG/CC willnnd the money.

c. Mr. Comber, OSA:. Prepare and publish 3OTQW to advertise known and projected bird patterns to all involved military and civilian aircraft/personneL

d. Mr. Bobick, BCE Eavironmental to Mr. Fernbacker.'ind out exactly what clean-up was to be done for the canals/culverts/infield, orig'nally to be funded by BCA.

e, Mr. Comber, OSA and Mr. Talbird, BCE; Determine the cycle ofmowing along/around the airneld; where are personne! when aircmR are on Se move (when birds are fo11owing the mowers), etc.

i err. Hegge, AT and 482 OGV:

Determine ifwe ne d. an earlier turnout to avoid Mt.

Trashmore.

g, 93 FS/CC; Review phase training and low-leve! weapons events relative to bird activities.

h. Lt Col Dunaway:

BriefBrig Gen Turner on the ne d to re~ a %'ildlife Biologist to assist in managing our bird problem and formulating long term solutions,.

i, 482 OGV: Pr~are the proper language for Chapter 8 regarding Bird Watch Conditions.

j. MrFernbacher, BCE: Deliver the engineering plan for the cleanup ofthe airQe{d canals and culvert by 15 April 1996.

9. AQ concerned personne!/ofEces willbe informed of the ne c meeting ofUu SHAG, We may need to meet soon after the 15 April 1996 suspense on the clean-up plan.

JOSEPH H. DUNA%'AYIO, Lt Col, USA'ecorder TE R. FULGHUM, Col, USAFR Chairperson

Attachment:

USDABird Survey Letter

"s-'R. ZB. 1956 7: GBPM gmak 1

KWDALL TAMKPPlj Q<ECUTiVE AiRPT i i0. c67 P, 7/9 United States

.~~

Department of Agriculture AnimaI and Plant Health Inspeclion Service Anima( Oamarie Conuol 2820 =apt Miva-s-<y Ave Gai=asvi1Ls,:L 3264 904/377-55o6 Na ch 4, 2996 Et. Col. uoe Qunaway 482nd SZ Homestead AM, FL 33039-2299

Dear Col,

Dunaway, Zt wh a pleasure getting tcgether with you, F1.ight Chief uchn N"'tchell and Fnvironmantal Specialist Mdy Bobick tc rav'ew tha bird pituation at.-.cmestead hG as 't relates to air t affic sa=ety.

" appreciate tha opportur-'ty to comment on the need for bird cont=ol "t the base.

The cu=sory inspection tou= of the airbase and par" of the surround'ng a~aa gave ma ar 'nd'cat'on of the macrr'uda and causa of the bird p=oblams you are experiencing.

Though

~ d'd. not sa large numbe s of bi ds on the a'"base, 2 noted sev ral = asons or the reported an essive bard act'vsty there

~s.he ma'n -easer 1 located th~pa miles moo} eca.so=

cbe end o= tba way is act=acbzng

'a=ye nnmbe=s of bi-ds, Ls drills i"s awizicial ann=ac"ants co bi ds because o=

the ccnstant supply of avail~&le food and the large exparse o=

open land for loaf'ng, As you a=e awa a, we observed hundreds of vultures and gulls cn the face of and. soar'ng above the landfill.

These twc groups cf bi ds ara especially hazardous t:o a'rcraft because of their size and, scaring habits.

Vu'ltu es weigh " cm 4

tc 5 pounds ard will soa" at g aat heights for several hours at a

t'me.

Gulls weigh 1 to 2 '

pounds and also soar for long par'ods of time.

Th's situaticn 's exacerbated by the fact -hat gulls using the land:ill roost in an ar a just south or southeast of the ai"base, According to base OPS personal, hundreds cf gulls fly through tha n ~way area each morning and even'ng Going tc and f om the landfill and roost'ng area.

Th's will ba ha=d tc prevent unless gulls a=e deterred from us'ng the landfill.

Ring-billed gulls ware observed using a water puddle on the hase.

Gulls hab'tually use standing water on ~ways, parki..a lots and other conc=ate su "aces after a "a'.

Ge 'ous problems occur when th's happens on or near sways.

Gulls and wad'ng birds w'll also f scient puddles in grassy areas ir search cf frogs, worms, 'insects and, othe sma' animals.

Other birds of concern at the ai hase ara w'ad'ng birds, (e.g.

egrets, herons, etc) ard diving birds

{6 g co iAorants, anh'ngas, AlsHIS-l'ro(sceng Amoricao Agricollurc

FR. -8 19 6 7: GSPH KEiIM'Ri'lZRNZ EXECUTZVE A1RPT.

T re.SS7 P.are etc,)

Some of these we a obsezved using the d ainage ditch and.

ma~shy a aa that parallels tha ~away.

The standing water and marshy g asses 'his a aa should be eliminated and measu as taken ta keep d ainage ditches ooen to rac'l'tata wat r flow and, keep water fzom pondinc Anothaz'onc rn is the r ported corg egating oz cattle g ats and gulls a aund the tracto

-mowe=s du=irg grass cutt'ng.

Th's commonly happens as birds are attracted.

to tha large number of

'nsects, frogs and other small pz'ay that became ava'abia when g ckss is cut

~

's prav'ously stated, the county land='ll locat d north-northeast oz Homestead ARB praser ts a major problem for air t af"ic using the base, The cou se of the n'~way di acts aiz trazfic almast d'ctly ove the landfill.whar bi d act'vity 's very heavy.

A3.so, bird numbers 'n the area will always be artificially hi because of tha birds at"racted to the landfill.

The-soarirc'abits of most of these birds 'radve=tently bzngs them ave= tha ai base and into air traf=ic lanes.

Contrail'ng b'rd, act'vity at airbase will be diff'cu - unless bird management is alsa implemented. at the landfill.l.

Because oi t'e complexities of bird usage at Homestead APD, and the urg rt ne d to educ bird activity 'n the ae oc

arne, Z

r cammand, that a biological assessment and hazard act'on analysis be conducted conc~'antly w'th an opa ational hazard control program.

This oreg am would determine oert'neht

=acts relat'e to bird use at Homestead.

ARB such as species cam osition, bird.

rumbers, daily and, seasonal activity and. ?~itat factozs that attract wildlife.

Zt would also implement new control stratag'as based on observations and evaluate the effect'veness of the cu = t b' cont ol program.

An assessment/ope ational orog am would, allow us to dave'op lorg-arge b' mar.agement plans for Homestead AR3.

This assessment/operational program would be 'n compliance with tha BASE Reduction plan zo Homestead ARS.

Anathez benefit that can be eal'zed from a bird control progz'am at Earnest ad ARE is con"roll'ng bizds in hargers a..d'othe@

ooen buildings.

Birds us'rg hangers for roasti g a.d nesting can cause p ohlams when the'anure and nesting debris gets

intooa, eng'ne parts or on airplane sur aces.

Bird manure, because oz the h'gh ac'd'c content, tends to caz ode tha body and. canopy of airplanes, and. manu e ard debzis can contaminate sans'tive mechanical and. electrical equipmant.

Zn fact, 't was stat d,

durirg ouz meeting when discuss'ng "his p oblam that reoa'nt'"g a-eas where bird manu-a has coz'raded.

the paint can be cgxite a lengthy and expansive process.

Z wan" to make you aware that Z met with the Pnvironma ta Engineer foz the Florida A' National Guard, Major David. voumans,

~R.28.lSSS i<0. 687 P. 9/9 and in"ormed h'm of the situat'on at Homestead AM.

Na or voumans said that he would recommerd that the A'= National Guard support any bird hazard management ooerations at iomestead.

As mentione'd at cur meetinc',

the

USDA, ADC, Wildlife Services has wildlife Biologists who are traired at assess' w'ldl'ife damage problems and 'mplementing operat'onal prog ams at a'rports and i~ilitary air installations.

Z would he happy to provide ass'stance to your agency or implementing a b'rd. haza"d assessme" t/ape ational program..

T. have enclosed the "wildlife Hazard. Prevention and Contra sect'n cf the ADC Airport Safety Manual.

This section exnounds on "he p-'nciples and guidelines set forth 'n the BASH Reduct'on Plan "or Homestead ARB.

X have also suhm'tted a draft Kiosk Plan and. budget fo the USDA, Hildlif Services to conduct a.

assessment/operational prog am for Homest ad ARB for"your cons'derat'on.

Contact me should. you have any n: stions o

wa c to ciscuss the subject of this letter.

Z look forward to hearing

=rom you soon.

Th's o= 'c

=ema'..s ready to serve vou should you need. ou assistance.

Rega ds, Bern ce U.

Const~~ tin State Director Znclosure.

CC'ohn B. Mitchel ~, Flight Chief, Homestead ARB And=ew i. Bohick, Znvi onmental Specialist, Homestead ARB Bart Vern*ce, District Off ce "AA, Airports

To:

From:

Subject:

Date:

Rick Busch Mike Handrahsn

.Bird Aircraft;Strike hazard December 16, L996 I mct with Jic BASH Vork Group earlier today and left with a feeling that the USAFRes +ants thc County (DCAD) to take on a more active role in eliminating the hazard.

q They continue in no uncertain terms to indicate that the. South Dade Landfill (2.'-!1'l2 miles away) woulddt be where it is, ifHST was a civilian airiMrt. While the USAF is aggressively pursuing the elimination of an oa. airport TERPS clear zone forested area, they still imply that the very close proximity ai the Landfil to HST is actually the real problem and that it presents a very attractive environment to ar=a gulls and vultures.

The BASH progr~ was re-prioritized by thc USAP as the result of the crash of an.E-3 which killed.all on. board.

Some USAF afric rs were later rclicved of duty as thc result oi not developing a mor'e pro-active program to minimiz the hazard.

Presently depending on the number of birds and sizes, the USAF restricts flying by either not allowing farmauons, low approaches or by simply closing the field.

awhile we are a technically a military-civilairport, the closure would affect civil operations ifwe are otherwise open for business.

Aiter the long term JUA and we become a civil-military airport, we would more than likely still want to follow their lead for liabilityrains and because they are our contract ATCT.

Thc USAP has contracted with thc USDA for bird deprivation and to help them develop a locally viable program.

The Birdman has obtained the n~sary killpermits, assisted the USAF with obtaining technical improvements, trained ATC and Base Ops personnel and developed theories on thc severity of thc problem.

The issue of the Land fillactivities came up at the Qrst meeting earlier this year.

E visitecl the site and made an informal presentation an conditions there.

To date E have be=a unable to locate any significant information other than some PAA stats on strikes and a flyer on hndfill locations.

As I have told the ~<up in the past, DCAD has not experienced a notable problem with bird strikes and effectively uses vehicle PA systems with horns and sirens and occasionally special bird shot to resolve the limitecl bird problems that we have experience.

I also obtained your approval to contact and work with Mr. Bruce Furlow a County Entomologist to investigate the situation and to work with the military to mitigate Ae problem.

The USAF birclman was apparently tasked with looking into die situation for the USAF and he has apparently validated their perception that the landfill is a significant contributor to the problem.

Hc has dissected gulls and other birds and dc~rmined. that insects they have eaten are founcl at the Landfill and would exist there because of dead animal remains (in plastic bags) which he has often se=n laying uncovered for hours and other similar conditions.

His opinions

Rick Busch Page 2 December 16, 1996 appear to have been validated by Mr. Constantine of USDA who has also visited the sites. The USDA Birdman also located and contacted a I " Casey, and German Hernandez of County Solid Waste and asked thetn to attend todays meeting.

After the meeting broke up, I introduced myself (o iver Casey and Mr. Hernandez and a Steve 3, their staff biologist and provided them with an overview of the situation. I toured the ~up around, the airfiel and discussed the overall issue with them.

They had already picked up on the USAF comments concerning the airport proximity to the landM and we agre+i that it is in the best interests ot all involved to took at incorporating some best management practicm at thc landfi11 to minimize the problem.

They will definitlcy stati the item up their chain of'command.

The following were among those in attendanc= at todays meeting, Col. Eustace (Commander),

L/Col Fulghum (Deputy), L/Col Dunaway (SAFE~, 482nd Pilots, Base OPS; ATC, CE shop Solid %'aste and myself.

I am concerned that the situation may get worse, be construed as a lack of safety awareness by DCAD, affect the FAR 139 application, go interdepartmental to fiscally resolve the who pays for fixing the situation sc nario or deteriorate to another unacc ptablc level.

Prior to the next SASH meeting planned for mid-January I wouM like to further discuss this issue and develop a better understanding of our options, and course oi action ifmy concerns appear well founded.

BASH meetings will now be held {seasonally) monthly through April.

Thank you for your cooperation.

c: GManion DShannon

U.S. Department of Transportation Federal Aviation Administration Orlando Airports 0<strict Office 9677 Tradeport Drive, Suite 130 Orlando, Florida 32827-5397 407-648-6582 May 28, 1996 Mr. Rick Susch Manager, General Aviation Airports Dade County Aviation Department P.O. Sox 592075 Miami, Florida 33159-2075

Dear Mr. Susch:

MA Air arise HAFT'e have recently been contacted by the United States Oepartmerit of Agriculture (USDA), Animal Damage Control that a county operated.-:.IandfiiL is.located within

..-.." three miles'of.the approach end or Runway 23 at Homestead AirForce Sase.

The USDA has completed an evaluation of'bird'-problems at the request of the AirForce. The USDA concluded that the landfill contributed substantially to this problem and recommended that the AirForce pursue a bird control program at Homestead, which would be conducted by the USDA Animal Damage Control.

The Dade County Aviation Department (DCAD) is encouraged to contact either the AirForce or the USDA directly to monitor the situation since OCAD is planning to acquire the facilityvia a public benefit conveyanc for public airport purposes.

Ifyou have any questions conc ming this matter, (407) 648-8583, extension 27.

Sincerely, 9'~~ H<QiQg Bart Vemace, P.E.

Airport Plans 8 Programs Manager CC:

FDOT/6

i'i0.867 fmc:aimila TRAN S M (TTAL fax 4:

date:

PGQQS!

Rick Busch HS7 USAF Bird Strike meeting March 28, 1996 9, including this cover sheet.

'Re attached iafo on thc USAF Bird Suike problem arrived ia today's mail.

( have already contacted a County Urban Entomologist, Bncc Furlow, to help filter some ofthis stuff out, provide direction and,protect our interests~ He has agreed to informally help ifaccdcd, until a formal rcqucst for his san iccs is made.

The USDA letter nom thc State Director ofAnimal Damage Control indicates that Mt.

=

Trashmore appears to be a bigger pit ofthe overall bird issue than orignally suspected.

l toured Mt. Trashmorc bcforc thc lcrtcr arrived aad made a local contact with Solid Waste.

Thcrc are a (oi of gulls aad vultures in, oa, and over thc laa&IL Mt,Trashmore is going to grow by current dcsiga and plans.

Closed Sites l Zc 2 are 147ft high by 2200 loag. They have started on N3, m ready for"4 and NS is available to dcvclop. A Rturc power plant is to bc sited just %fest oi the dump area.

iMote rcfcrcnccs to culvctts and canals and DERM.

How much emphasis does DCADwant to place oa this, suggested next step?

gg H ~-gs cram Mdaak at 1

Mike Handrahan

Malgar, ndall Tamlami Exoanivo Airport Oado County Aviation Oa paenant 12800 aW 137 Avo, iVfami, Fl. 33186 306 238. 6083 Fax:

2364180

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Turkey Point EXISTING GENERALIZED LAND USE PATTERN 0 - 10 MILE RADIUS EXISTING GENERALIZED LAND USE PATTERN PIG. 2.5-1

LEGEND Xndustrial and Business Residential Agriculture Homestead Air Force Base Qggg Parks and Recreation Vacant Land Biscayne Bay

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Turkey Point Plant Site USE@Ay g

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GENERALIZED LAND USE PATTERN 0 - 10 MILE RADIUS GENERALIZED LAND USE PATTERN PROJECTED TO 1985 FIG. 2.5-2

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264 STREE".

LEGEND Industrial and Business KR Residential Vacant and Agricultural Land Homestead Air Force Base K52 Parks and Recreation Biscayne Bay Tourists

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Item:

ADAMS Document Library:

ML ADAMS"HQNTADOl ID: 003678990

Subject:

Comment supports revised criteria for post accident sampling systems.

Body:

Docket:

05000250, Notes:

N/A Docket:. 05000251, Notes:

N/A Docket:

05000335, Notes:

N/A Docket:

05000389, Notes:

N/A Page 1

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Florida Power &Light Company, P. 0. Box 14000, Juno Beach, FL 33408-0420 PEcF t<<D d/H8D~b 2R gfg 2g Pll 9 JAN 7 2000 kc'v. gp /gpss H

L-2000-011 Us~Bc'y Mr. David L. Meyer, Chief Rules and Directives Branch U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemakings and Adjudications Staff

Subject:

Revised Criteria for Post Accident Sampling Systems November 24, 1999, 64 Fed. Reg. 6621 3

Dear Mr. Meyer:

Florida Power 8 Light Company (FPL), the owner and operator of the St. Lucie Nuclear Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, provides the following on the. above-referenced request for comments.

FPL supports the action taken by both the Combustion Engineering Owners Group (GEOG) and Westinghouse Owners Group (WOG) for the elimination of the current requirements for the Post Accident Sampling System (PASS).

The technical basis for eliminating the PASS developed by both the WOG and the GEOG underwent extensive regulatory review by the NRC. The Advisory Committee on Reactor Safeguards (ACRS), which is an independent regulatory review group, also reviewed the technical basis developed by both the WOG and the CEOG.

At the conclusion of their review, the ACRS recommended that the NRC eliminate the regulatory requirements for the PASS.

The WOG and the GEOG, as well as the ACRS have determined that there is no decrease in emergency planning effectiveness as a result of eliminating the regulatory requirements to maintain a dedicated PASS at each plant.

As a result, the information available to state and local emergency response organizations for formulating offsite radiological protection activities will not be adversely impacted by the elimination of the PASS.

The elimination of PASS requirements will result in reduced personnel exposure at the plant due to the elimination of maintenance and surveillance requirements associated with the system.

Additional benefits include the elimination of a potential post-accident leakage path and the availability of expert resources that would otherwise be diverted to PASS activities of marginal value.

, an FPL Group company

~ Dpi(<~

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Mr. David L. Meyer Page 2 FPL also endorses the comments submitted by the Nuclear Energy Institute.

We appreciate the opportunity to comment on the "Revised Criteria for Post Accident Sampling Systems."

Sincerely, P.

R. John Gianfrancesco, Jr.

Manager Administrative Support and Special Projects

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Total Copies:

Item:

ADAMS Document Library:

ML ADAMS"HQNTAD01 ID: 003678168

Subject:

Public Comments on the Pilot Program for the New Regulatory Oversight Program (64 Fed.

Reg.

60244; November 4,

1999)

Body:

Page 1

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Florida Power& light ComPany, P.O. Box14000,Joan Beach, Fl33400 0430

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/815'ULES 8( DfR. BPANCH, U$ NRQ DEC,2,8 1999 L-99-282 Mr. David L. Meyer Chief, Rules and Directives Branch Division ofAdministrative Services Office ofAdministration Mail Stop T6D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 rll~ow nm

SUBJECT:

Public Comments on the Pilot Program for the New Regulatory Oversight Program (64 Fed. Reg. 60244; November 4, 1999)

Dear Mr. Meyer:

Florida Power &Light Company (FPL), the owner and operator ofthe St. Lucie Nuclear Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, hereby submits the following comments on the above-referenced pilot program for the new regulatory oversight program.

FPL has worked closely with the Nuclear Energy Institute (NEI) on this issue and fullyendorses the comments provided by NEI on behalf ofthe nuclear energy industry.

FPL appreciates NRC's continuing efforts in developing the new Regulatory Oversight Process.

We recognize that further refinements to the process willbe necessary as industry-wide participation identifies additional issues.

FPL willcontinue to support NEI and the industry efforts toward the implementation ofthis process Thomas F. Plunkett President Nuclear Division an FPL Group company ob>l:lVI4'K

Distribution Sheet Distri27.txt Priority: Normal From: Stefanie Fountain Action Recipients:

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Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 993500364

Subject:

Comment supporting the revision of the NRC Enforcement Policy.

Body:

PDR ADOCK 05000250 P Docket: 05000260, Notes: N/A Docket: 06000251, Notes: N/A Docket: 05000335, Notes: N/A Docket: 05000389, Notes: N/A Page 1

L-99-261 OEC - 3 1999 l999 OEC I tk AH 8: 26 Mr. David L. Meyer RULES 5 DIR. BRANCH Chief, Rules and Directives Branch US NRC Division of Administrative Services Office ofAdministration Mail Stop T6D59 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 FJ,FloridaPoweralightCompany, P.O.Boxl4000,Jano Beach,FL334080420 2/D'V, / Ippf Q-l9ogofJ~x4r" BEG E)VEG Re:

Id'lorida Power &Light Company Comments Revision of the NRC Enforcement Policy 64 Fed. Reg. 61142 (Nov. 9, 1999)

Dear Mr. Meyer:

Florida Power k, Light Company (FPL), the owner and operator of the St. Lucie Nuclear Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, hereby submits the followingcomments on the above-referenced revision to the NRC's Enforcement Policy.

In summary, FPL supports the NRC's transition to a process that more objectively focuses enforcement on the actual consequences of violations. Such a process will reduce the regulatory burden on licensees and willenhance safety by encouraging licensees to focus their resources on issues that have safety significance.

FPL supports the NRC's use of the concept ofpotential consequences as a consideration in the significance assessment process.

As revised, NRC will consider the realistic likelihood of a violation affecting safety, and willuse risk insights to determine the final enforcement sanction.

FPL believes that this will focus the enforcement process on those violations that could have credibly resulted in actual consequences for the public health and safety.

FPL supports the Commission's decision to eliminate the concept of "regulatory significance" in the context of assessing the significance ofviolatioris in the enforcement process.

FPL is concerned, however, with the retention of some of the concepts relating to "regulatory significance" as retaining some of the subjectivity that caused certain enforcement actions to focus on matters that had no actual or credible impact on the public health and safety.

For example, while FPL has no quarrel with NRC considering violations that ~actuatt impact the NRC's ability to carry out its statutory mission (i.erp violations of 10 CFR 50.59, 50.72 and 50.73), the retention of violations that could have the gotential to impact the NRC's ability to carry out its statutory mission is similar to the subjectivity inherent in the use of the term "regulatory significance." Such subjectivity allows for speculation and supposition concerning whether a violation might have created an impact on the regulatory process.

FPL recommends that such matters be addressed outside of the enforcement process.

pa p

/&os.](

/'tc,A>&63 6

Florida Power Ec Light L-99-261 Pg. 2 In this same regard, FPL suggests that NRC clarify and specifically list only those violations that NRC believes would directly affect its ability to carry out its regulatory mission. The revised Enforcement Policy provides examples of such violations, but does not purport to include a comprehensive list. This category of violations should be carefully constrained so it does not become a de facto catch-all category for those violations which involve no actual or potential safety consequences but would previously have been termed as having "regulatory significance."'PL is also concerned that NRC would consider enforcement for failure to "maintain a safety conscious work environment," as suggested at 64 Fed. Reg. 61143. In 1998, NRC declined to pursue rulemaking that would have codified the attributes of a safety conscious work environment.

The Commission concluded (63 Fed. Reg. 6235 (1998)) that existing requirements and policies were sufficient to address issues involving safety-conscious work environments.

FPL suggests clarification that alleged failures to maintain a safety-conscious work environment willnot be the subject of enforcement actions.

We appreciate the opportunity to comment on the revised NRC Enforcement Policy.

Sincerely yours, Thomas F. Plunkett President Nuclear Division

'PL provides the same comment for the interim enforcement policy for use during the NRC Power Reactor Oversight Process Pilot Plant Study (i.e., violations not evaluated by the SDP and those having actual consequences).

~ aL NOV 17 1999 L-99-251 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555 Gentlemen:

Re:

Turkey Point Units 3

& 4 Docket Nos.

50-250 and 50-251

Response

to Request for Information Regarding the Impact of a Commercial Airport at Homestead Air Force Base Site on Safety at Turke Point Units 3 and 4

On August 23,

1999, the Air Force notified the NRC that a Supplemental Environmental Impact Statement was being prepared for the Homestead Air Force Base conversion project to (a) reflect updated air traffic information associated with a "Maximum Use One Runway" (MUOR) projection, (b) reflect alternate flight track configurations currently under consideration for noise abatement, and (c) evaluate the environmental impact associated with the optional use of the facility as a commercial spaceport.

The NRC subsequently issued a request to Florida Power 6 Light (FPL) to assess the impact of the proposed changes on the previously submitted risk assessment documented by FPL letter L-98-152 dated June 15,

1998, and to inform the NRC of any changes within 60 days.

FPL has completed the assessment of the impact of -the proposed changes and determined that the overall risk to Turkey Point from an aircraft accident decreases from the previously estimated 8.11E-7/yr to 3.63E-7/yr based on the new projections and MUOR conditions.

A comparison of the original airport conversion plan flight projections with the latest Federal Aviation Administration (FAA) flight projections indicates that the total number of flight operations has remained relatively constant between the two forecasts.

The original data (Table

1) forecasted a maximum of 246,700 flight operations in the year 2014, while the current projection (Table 2) forecasts 231,274 flight operations under MUOR conditions.

The projected mix of flight operations at the airport,

however, has changed in the latest FAA submittal.

As indicated in the attached tables, the revised flight data includes a decrease in projected military air traffic and 'a corresponding increase in civilian air traffic.

This change in the projected mix of flight operations at the airport does impact the risk assessment previously transmitted to you in support of the Final Environmental Impact Statement.

As revealed in the previous analysis, the risk of an aircraft impact at Turkey Point is dominated by military air traffic.

This dominance is due in part to the fact that the probability of an accident per flight operation is much higher for military aircraft than for commercial or general aviation aircraft.

P~~ ~0~~(

an FPL Group company P q gg ggg

L-99-251 Page 2 of 5 This is due to the higher percentage of high-risk activities associated with military flights, e.g., training, high-speed maneuvering.

The dominance is also due to the fact that the probability of an aircraft accident occurring in the immediate vicinity of the airport is much higher for military aircraft than for commercial or general aviation aircraft.

That is, most commercial or general aviation flights leave the airport area after takeoff.

When landing, they are most often arriving from places a considerable distance from the airport.

While the same can be said for some military air traffic, a high percentage of the military flights consist of training exercises near the airport, leading to a higher probability that if an accident does occur, it will be in the vicinity of the home airport.

The latest FAA flight projections indicate that the decrease in large military aircraft traffic is seven-fold.

For small military aircraft, the decrease is 28.1%.

Despite the fact that the amount of commercial jumbo jet operations (Class A air carriers) in the latest forecast is over three times that of the original forecast, the overall risk to Turkey Point from an aircraft accident decreases from 8.11E-7/yr to 3.63E-7/yr under MUOR conditions as a consequence of the predicted decrease in military air traffic.

This represents a

55% reduction in the frequency of aircraft accidents at the site having the potential to generate exposures in excess of 10 CFR 100 limits. It is also well below 1E-6/yr significance threshold specified in Section 2.2.3 of NUREG 0800.

The following reasonable qualitative factors not directly addressed in the risk estimate are provided below to show that the realistic probability of exceeding 10 CFR 100 guidelines due to an aircraft impact will be lower than the revised risk estimate of 3.63E-7/yr for Turkey Point.

1. Shielding by adjacent structures or heavy machinery, and barriers such as the canal and the fossil units are not fully credited.

This may reduce the risk by 20%.

2. The conditional core damage probability and conditional containment failure probability are not based on more detailed assessment of structural capability or all available equipment.

For example, Sandia National Laboratory tests have indicated that the containment structures do not experience perforation damage.

In addition, the steel liner is effective in preventing concrete from scabbing.

This may reduce the risk to varying degrees for different structures but is not readily quantifiable.

~

~

L-99-251 Page 3 of 5 The structures at Turkey Point considered to be critical structures for the purpose of the risk assessment were the containment buildings, turbine building, control building, auxiliary building, spent fuel buildings, emergency diesel generator buildings, intake structure, and the fossil unit chimneys.

With respect to the spaceport

option, FPL did not perform a specific analysis to quantify the effects of potential launch vehicle failures at the base due to the limited number of flight operations projected for such a facility.

The potential impact of a spaceport at the Homestead Air Force Base location would be bounded by the impact associated with a commercial airport.

As indicated in our previous correspondence on this subject, FPL continues to communicate with local and state authorities on this matter in order to ensure that the issues coming from the commercialization of the base are identified, that the offsite emergency preparedness program to address these issues is appropriately revised, and to ensure the Federal Emergency Management Agency is in concurrence with the revisions to the program.

Once the proposed disposition of the Homestead Air Force Base is finalized, FPL will update our Final Safety Analysis Report, as appropriate, to reflect these changes.

Should there be any questions on this submittal, please contact us.

er truly yours, RTi~y R. J.

H y

Vice President Turkey Point Plant OH/MG cc:

Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Department of Health and Rehabilitative Services

L-99-251 Page 4 of 5 Table 1

Original Homestead Airport Traffic Forecast from Earlier Analysis Aircraft Classes Projected Annual Aircraft 0 erations CLASS A (Air carriers)

(MD-11,DC-10,B-767,B-737,F-100/

MD-80,CL600,DHC8) 1994 1999 520 2004 33870 2014 45890 (Large military Aircraft)

(C-130/ C-141 I P-3)

Subtotals CLASS B

(Small high-performance)

(F-15, F-16)

(General aviation jet)

(Learjet, Citation)

Subtotals CLASS C

(Air taxi)

(GA Turboprop)

(Metroliner, Cessna

206, Nomad)

(GA multi-engine)

(Piper 31)

(GA single engine)

(Helicopters)

(UH-60, H-3)

Subtotals Grand Totals 10388 10388 18230 3850 22080 1316 608 5118 7042 39510 10388 10908 18230 3850 22080 1316 34408 82000 9918 127642 160630 10388 44258 18230 5750 23980 1316 40208 99900 10418 151842 220080 10388 56278 18230 5650 23880 1316 44308 110400 10518 166542 246700

L-99-251 Page 5 of 5 Table 2

Updated Homestead Airport Traffic Forecast For MUOR projection Aircraft Class Pro'ected Annual Aircraft Operations CLASS A (Air carriers)

(MD 11 DC 10IB 767gB 737IF 100/

MD-80,CL600,DHC8) 1997 2000 2005 8700 2015 MUOR*

74140 154679 (Large military Aircraft)

(C-130,C-141,P-3) 1624 1624 1624 1624 1624 Subtotals CLASS B

(Small high-performance)

(F-15/

F-16) 1624 13100 1624 13100 10324 75764 156303 13100 13100 13100 (General aviation jet)

(Learjet, Citation) 900 2990 3450 4510 4510 Subtotals 14000 16090 16550 17610 17610 CLASS C

(Air taxi)

(GA Turboprop)

(Metroliner, Cessna

206, Nomad) 900 900 1940 900 900 (GA multi-engine)

(Piper 31)

(GA single engine) 900 11330 26304 13000 17160 21900 27993 33821 29000 (Helicopters)

(UH-60, H-3) 2400 4410 4890 5480 5561 Subtotals Grand Totals

• MUOR = Maximum Use, One Runway 4200 19824 42944 60658 47823 57361 57361 74697 150735 231274

Distri27.txt Distribution Sheet Priority: Normal From:

Esperanza Lomosbog Action Recipients:

NRR/DLPM/LPD2-2 K Jabbour B Clayton Internal Recipients:

RidsManager OGC/RP NRR/DSSA/SRXB NRile Center 0 m~

ACRS Copies:

1 1

1 Not Found Not Found Not Found OK Not Found Not Found Not Found Not Found Not Found External Recipients:

NRC PDR NOAC Not Found Not Found Total Copies; Item:

ADAMS Document Library:

ML ADAMS"HQNTAD01 ID: 993300037

Subject:

Lette responding to request for information regarding impact of commer cial Airport at Homestead Air Force Base site on safety at Turkey Poin t Unis 3 and 4

Body:

PDR ADOCK 05000250 P

Docket:. 05000250, Notes:

N/A Docket:

05000251, Notes:

N/A Page 1

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UNITED STATES NUClEAR REGULATORY COMMlSStON WASHINGTON, D.c. 2055&0001 August 05, 1998 Mr. Thomas Plunkett President - Nuclear Division Florida Power and Light Company P.

O. Box14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND4 - IMPACT OF THE CONVERSION OF THE HOMESTEAD AIR FORCE BASE ON SAFETY AT TURKEY POINT PLANT (TAC NOS. MA0848 AND MA0849)

Dear Mr. Plunkett:

By letter dated June 15, 1998, Florida Power and Light Company responded to the NRC staff's request for additional information (RAI) of April 14, 1998.

The request was related to the potential of converting the Homestead AirForce Base (HAFB) to a commercial airport, and the impact of this conversion on Turkey Point Units 3 and 4.

Your response provided your estimate of risk related to the potential conversion of the HAFB to a commercial airport. This risk estimate was based on available data regarding the proposed number of operations, flight paths, and proposed flight mix. In addition, your response addressed the actions you willtake regarding the offsite emergency preparedness program as a result of the potential commercialization of the base.

- Many of the attributes associated with the prospective regional airport are currently under review as part of the development of a draft Supplemental Environmental Impact Statement (SEIS). Accordingly, the information that you provided is subject to change based on development of the draft SEIS. You also stated that when the proposed disposition of the HAFB is finalized, you will update the Final Safety Analysis Report (FSAR), as appropriate, to reflect these changes.

Based on the currently available information, we believe that the spectrum of potential projects resulting from the conversion is still under examination and development. Therefore, we appreciate your updating the information provided in your June 15, 1998, submittal as the issues become more defined but before the FSAR is updated.

We appreciate your response to our RAI. Ifyou have any questions regarding this matter, please contact me at (301) 415-1496.

Sincerely, QQ~ > J Kahtan N. Jabbour, Senior Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251 cc: See next page Eac1osure 2

Mr. T. F. Plunkett Florida Power and Light Company TURKEY POINT PLANT CC:

M. S. Ross, Attorney Florida Power 8 Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 John T. Butler, Esquire Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Mr. Robert J. Hovey, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 County Manager Metropolitan Dade County 111 NW 1 Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Generating Station U.S. Nuclear Regulatory Commission P.O. Box 1448 Homestead, Florida 33090 Mr. WilliamA. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin ¹C21 Tallahassee, Florida 32399-1741 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Center view Drive Tallahassee, Florida 32399-2100 "Regional Administrator, Region II U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW., Suite 23785 Atlanta, GA 30303-3415 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant

'lorida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Mr. Gary E. Hollinger Licensing Manager Turkey Point Nuclear Plant 9760 SW. 344th Street Florida City, FL 33035 Mr. Leonard D. Wert U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415 Mr. John Gianfrancesco Manager, Administrative Support and Special Projects Florida Power & Light Company P. O. Box 14000

. Juno Beach, Florida 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P. O. Box 14000 Juno Beach, Florida 33408-0420

13./18/1999 E4: 45 385-248"685<.

L-99-251 U.

S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555 Gentlemen:

Re:

Turkey Point Units 3

6 Docket Nos.

50-250 and 50-251

Response

to Request for Information Regarding the Impact of a Commercial Airport at Homestead Air Force Base Site on Safety at Turke Point Units 3 and 4

On August 23,

1999, the Air Force notified the NRC that a Supplemental Environmental 1'mpact Statement was being prepared for the Homestead Air Force Base conversion project to (a) reflect updated air traffic information associated with a "Maximum Use One Runway" (MUOR) projection, (b) xeflect alternate flight track configurations currently under consideration for noise abatement, and (c) evaluate the envir'onmental impact associated with the optional use of the facility as a commercial spaceport.

The NRC subsequently issued a request to Florida Power

& Light (FPL) to assess the impact of the proposed changes on the previously submitted risk assessment documented by FPL letter L-98-152 dated June 15,

1998, and to inform the NRC of any changes within 60 days.

FPL has completed the assessment of the impact of the proposed changes and determined that the overall risk to Turkey Point fx'om an aircraft accident decreases fxom the previously estimated 8.11E-7/yr to 3.63E-7/yr based on the new projections and MUOR conditions.

A comparison of the original airport conversion plan flight projections with the latest Federal Aviation Administration (FAA) flight projections indicates that the total number of flight operations has remained relatively constant between the two forecasts.

The original data (Table

1) forecasted a maximum of 246,700 flight operations in the year 2014, while the current projection (Table 2) forecasts 231,274 flight operations under MUOR conditions.

The projected mix of flight operations at the airport,

however, has changed in the latest FAA submittal.

As indicated in the attached tables, the revised flight data includes a decrease in pxojected military air traffic and a corresponding increase in civilian air traffic.

This change in the project ".,'.. of flight operations at the airport does

'mpact the risk assessment previously tx'ansmitted to you in support of the Final Environmental Impact Statement.

As revealed in the previous analysis, the risk of an aixcraft impact at Turkey Point is dominated by military air traffic.

This dominance is due in part to the fact that the probability of an accident per flight operation is much higher for military aircraft than for commercial or general aviation aircraft.

an FPL Group company Xhclosure 3

L-99-251 Page 2 of 5 This is due to the higher percentage of high-risk activities associated with military flights, e. g., training, high-speed maneuvering.

The dominance is also due to the fact that the probability of an aircraft accident occurring in the immediate vicinity of the airport is much higher for military aircraft than for commercial or general aviation aircraft

~

That is, most commercial or general aviation flights leave the airport area aftex takeoff.

When landing, they are most often arriving from places a considerable distance from the airport.

While the same can be said for some military air traffic, a high percentage of the military flights consist of training exercises near the airport, leading to a higher probability that if an accident does occur, it will be in the vicinity of the home airport.

The latest FAA flight pxojections indicate that the decrease in large military aircraft traffic is seven-fold.

For small military aircraft, the decrease is 28.1%.

Despite the fact that the amount of commercial jumbo jet operations (Class A aix carriers) in the latest forecast is over three times that of the original forecast, the overall risk to Turkey Point fxom an aircraft accident decxeases from 8.11E-7/yr to 3.63E-7/yr under MUOR conditions as a consequence of the predicted decrease in military air traffic.

This represents a 554 reduction in the frequency of aixcraft accidents at the site having the potential to generate exposures in excess of'0 CFR 100 limits.

Xt is also well below 1E-6/yr significance threshold specified in Section 2.2.3 of NUREG 0800.

The following reasonable qualitative factors not directly addressed in the'isk estimate are provided below to show that the realistic probability of exceeding 10 CFR 100 guidelines due to an aircraft impact will be lower than the revised risk estimate of 3.63E-7/yr for Tuxkey Point.

1. Shielding. by adjacent structures or heavy machinery, and barriers such as the canal and the fossil units are not fully credited.

This may reduce the risk by 20%.

2. The conditional core damage probability and conditional containment failure probability are not based on more, detailed assessment of structural capability or all available equipment.

For example, Sandia National Laboratoxy tests have indicated that the containment structures do not experience perforation damage.

In addition, the steel liner is effective in preventing concrete fxom scabbing.

This may reduce the risk to varying degrees for different structures but is not readily quantifiable.

L-99-251 Page 3 of 5 The structures-at Turkey Point considered to be critical structures for the purpose of the risk assessment were'the containment buildings, turbine building, control building, auxiliary building, spent fuel buildings, emergency diesel generator buildings, intake stxucture, and the fossil unit chimneys.

With respect to the spaceport

option, FPL did not pexform a specific analysis to quantify the effects of potential launch vehicle failures at the base due to the limited number of flight operations projected for such a facility.

The potential impact of a spaceport at the Homestead Air Force Base location would be bounded by the impact associated with a commercial airport.

As indicated in our previous correspondence on this subject FPL continues to communicate with local and state authorities on this matter in order to ensure that the issues coming from the commercialization of the base are identified, that the offsite emergency preparedness program to address these issues is appropriately revised, and to ensure the Federal Emergency Management Agency is in concurrence with the xevisions to the program.

Once the proposed disposition of the Homestead Air Force Base is finalized, FPL will update our Final Safety Analysis Report, as appropriate, to reflect these changes.

Should there be any questions on this submittal, please contact us.

er truly yours, R4, Po wy R. J.

H Vice President Tuxkey Point Plant OH/MG cc:

Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Department of Health and Rehabilitative Services

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Mr. Thomas F. Plunkett President - Nuclear Division Florida Power and Light Company P.O. Box 14000

, Juno Beach, Florida 33408-0420 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205~001 September 16, 1999

SUBJECT:

REQUEST TO ASSESS THE POTENTIAL RISK OF THE PROPOSED CIVIL AIRCRAFTOPERATIONS AT HOMESTEAD AIR FORCE BASE ON THE TURKEYPOINT PLANT, UNITS 3 AND 4 (TAC NOS. MA6249 AND MA6250)

Dear Mr. Plunkett:

The U.S. Department of the AirForce has provided the enclosed information to support the assessment of the potential risk to Turkey Point Units 3 and 4 associated with the proposed civil aircraft operations at the Homestead AirForce Base.

It is our understanding that the AirForce provided you the same information.

The Department of the AirForce and the Federal Aviation Administration (FAA) are in the process of preparing a draft Supplemental Environmental Impact Statement (SEIS) to address the environmental impact of the proposal to develop a regional civil airport at the base, which would also continue to support military and government operations.

The draft SEIS willalso examine an alternative involving development of a commercial spaceport at the base.

It appears that the original design basis for Turkey Point did not consider the operation of a

'commerical airport in close proximity to Turkey Point Units 3 and 4.

In Title 10, Code of Federal Regulations (10 CFR) Subpart 100.10, the U.S. Nuclear Regulatory Commission (NRC) specifies, among other things, factors to be considered when evaluating sites for nuclear reactor facilities. It states that the reactors are expected to have an extremely low probability for accidents that could result in the release of significant quantities of radioactive fission products, and that, should an accident occur, the reactor facility should ensure a low risk of public exposure.

The staff interpretation of the regulation is described in NUREG-0800, NRC Standard Review Plan (SRP) 2.2.3.

In the case of aircraft hazards, SRP-3.5.1.6 outlines an approach acceptable to the NRC staff.

The modification of the Homestead AirForce Base Site to accommodate a commercial airport, in addition to its use for military and government operations, has the potential to increase aircraft hazards above the risks that are currently projected and could have an impact on the offsite emergency planning.

Hence, you are requested to assess the impact of the proposed changes and update the Turkey Point Units 3 and 4 Final Safety Analysis Report and other related documents when the proposal becomes more defined.

Enclosure 4

Thomas F. Plunkett This request has been discussed with Olga Hanek of your staff. A target date for your response has been agreed upon to be 60 days from your receipt of this letter. Should a situation occur that prevents you from meeting the target date, please contact me at (301) 415-1496.

Sincerely, Kahtan N. Jabbour, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

U.S. Air Force Information cc w/encl: See next page

Mr. T. F. Plunkett Florida Power and Light Company TURKEY POINT PLANT M. S. Ross, Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Robert J. Hovey, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 County Manager Miami-Dade County 111 NW 1 Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission 9762 SW. 344~ Street Florida City, Florida 33035 Homestead, Florida 33090 Mr. WilliamA. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin ¹C21 Tallahassee, Florida 32399-1741 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Cente view Drive Tallahassee, Florida.32399-2100 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Mr. Steve Franzone

,Licensing Manager Turkey Point Nuclear P.'ant 9760 SW. 344th Street Florida City, FL 33035 Mr. John Gianfrancesco Manager, Administrative Support and Special Projects P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

EPARTMENT OF THE AIR FORCE WASHINGTON, DC Office of the General Counsel August 23, 1999 Douglas J. Heady SAF/GCN 1740 AirForce Pentagon Washington D.C. 20330-1740 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C. 20555 Re:

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Homestead AirForce Base Property Disposal On behalf ofthe AirForce and the Federal Aviation Administration (FAA), I am forwarding the enclosed information to support the assessment ofthe potential risks associated with proposed civilaircraft operations at former Homestead AirForce Base to Florida Power and Light Company's Turkey Point Nuclear Reactor Facility Units 3 and 4.

The AirForce and FAA are in the process ofpreparing a Supplemental Environmental Impact Statement (SEIS) to address the environmental impacts ofMiami-Dade County's proposal to develop a regional civilairport at the former base, which would also continue to support military and government operations. Ifthe airport became successful quickly and grew vigorously, then by the year 2015 there might be as many as 14,670 people on site, and perhaps as many as 20,440 by the time the airport was fullydeveloped some time thereafter.

The SEIS willalso examine an alternative involving development ofa commercial spaceport at the former base. An initial draft ofthe SEIS is currently undergoing internal review by the lead and cooperating federal agencies.

Although the SEIS is still undergoing review and revision, we expect the projected aircraft operations to remain relatively stable.

The proposed flightpaths also represent FAA's thoughts on the most eQicient way to integrate Homestead air tragic into the regional routing structure.

Therefore, we feel this would be a good time to initiate the analysis to update the Safety Analysis Report for the Turkey Point units. We understand that some ofthe enclosed information willneed to be provided to appropriate staF at Florida Power and Light Company in order for them to effectively and efficiently complete the risk analysis.

The enclosed package also includes three alternative flighttrack configurations that are under consideration for potential noise abatemcig,.

':-;ll. 0 Rmlosure

We hope these data are helpful and satisfy your requirements. Ifyou have any questions, or require additional information, please feel &ee to call me at (703) 693-7314 or Ms; Robin Brandin, SAIC, at (505) 842-7933.

Sincerely, Douglas J. Heady Associate General Counsel (Installations &Environment)

WORKING DRAFT Proposed Aviation Operations at and in the Vicinityof Former Homestead AirForce Base Science Applications International Corporation (SAIC) is preparing a

Supplemental Environmental Impact Statement (SEIS) on behalf of the Air Force and the Federal Aviation Administration (FAA) to address reuse ofportions of former Homestead Air Force Base (AFB) as a civil airport (designated Homestead Regional Airport, or HST). The proposed airport would be operated by the Miami-Dade County Aviation Department and support existing AirForce, Air National Guard, and U.S. Customs aviation operations, as well as new commercial, cargo,-

maintenance, and general aviation operations.

A subcontractor to SAIC, Landrum and Brown,.has been working with FAA and Miami-Dade County to identify flight tracks and forecast civil aviation operations for analysis in the SEIS.

The results oftheir studies, summarized here, provide information that can be used to assess any increased risk associated with the Turkey Point Nuclear Reactor Facility. The data included in this summary provide information on types of aircraft and estimated number of operations by aircraft and flighttrack.

SAIC plans to summarize the results of safety analyses performed and approved by Florida Power and Light Company and the Nuclear Regulatory Commission (NRC), and the information herein is intended to facilitate this analysis. SAIC's understanding is that, according to NRC's Standard Review Plan (NUREG-0800), Paragraph 3.5.1.6 (Aircraft Hazards), Subparagraphs II 1 (a) through (c), risk from aircraft accidents is considered to be sufficiently low to require no further analysis ifthree conditions are met. These are:

~

The plant-to-airport distance (D) is between 5 and 10 statute miles and the projected annual number of operations is less than 500'D', or the distance is greater than 10 statute miles and the projected number ofoperations is less than 1000~D'.

~

The plant is at least 5 statute miles &om the edge ofmilitary training routes, including low-level training routes, except for those associated with a usage greater than 1000 flights per year, or where activities (such as practice bombing) may create an unusual stress situation.

~

The plant is at least 2 statute miles beyond the nearest edge of a federal airway, holding pattern, or approach pattern.

. The second condition is not at issue; there-are,no existing military training routes in close proximity to the Turkey Point facility and no plans for changes.

The information generated for the proposed regional airport at HST indicates that the first and third conditions willnot be met.

Former Homestead AFB lies between 5 and 10 miles &om the Turkey Point facility, and the airport could potentially support a maximum of 231,000 annual operations.

The airport is forecast to have as many as 150,000 annual operations by 2015.

The SEIS is also examining an alternative to the'proposed regional airport which would involve developing a commercial spaceport at former Homestead AFB. Very little is currently known

WORKING DRAFT about how spacecraft would operate from the spaceport.

The analysis in the SEIS will be based on two proposals received during the scoping process.

One proposal, &om Kelly Space and Technology, Inc., would involve a manned Astroliner towed into an aerial launch position by a Boeing 474. The two vehicles would return to base separately. The second, proposed by Space Access LLC, involves a new, unmanned vehicle still under development (aerospacecraft, or ASC). The ASC would launch one to two smaller vehicles, the reusable spacecraft (RSC) and the reusable orbital-transfer craft (ROC), also unmanned. They would be launched inside the ASC but return to base individually.

No flight tracks have been identified for these operations, but the current assumption is that they would depart on a relatively straight path to the northeast &om Runway 5. Space Access has indicated that they also expect most of the arrivals to come &om the northeast, landing to the southwest on Runway 23. For purposes of analysis, a maximum of three missions per week has been estimated, which would involve 9-10 operations (estimated total of 480 operations per year). The military and government operations would also continue.

To assist in performing a safety analysis for the Turkey Point plant, the following exhibits are attached:

~

Seven maps showing military/government flight tracks (east flow, west flow, and local patterns) and proposed civil flight tracks (east flow arrivals, east flow departures, west flow arrivals, and west flowdepartures).

~

Twelve maps depicting three possible alternative sets offlight tracks (Alternatives 1 through 3). These alternatives are under consideration for potential noise attenuation. They may or may not be used in lieu ofthe proposed flighttracks.

~

A description ofaltitude restrictions that would apply to departures and approaches at HST.

~

A summary table offorecast annual aircraft operations at HST.

~

Detailed tables ofaverage daily operations by flighttrack (designated by flix)for each aircraft ape forecast to use HST. These numbers need to be multiplied by 365 to obtain annual estimates.

~

Tables showing annual military/government operations at Homestead ARS.

~

A table showing projected annual space launch operations for the commercial spaceport alternative. Note that these must be added to military/government operations to obtain total projected operations.

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'2700 MSL JJ J jl s.- I= s.- ah NOTES: MIAAirspace routes were devrNoped from actual MlARADARData from 5/31 /SS -8/7/98 Future Proposed HST Airspace Routes were devehped in consultatke with Miami17tACON.

Base Map ls the Miami SecLonal Aerreauthel Chat, Febluay 28, 1998, publhhed by N85onal Oceanic Atmosphertc Admtn stratke forair navlga5on use.

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12 24 GRAPMIC SCALE IN NAUTICAL MILES HST EAST FLOW FUTURE PROPOSED

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ITINERANT MILITARY/ GOVERNMENT BACKBONE & DISPERSED FLIGHT TRACKS FileName:

PAMsAcGISQCA0$000-el law Mlldw9 Date: 0//27/99 0 I6:2l:05

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NOTES: MIAAirspace routes were devefoped from actual MIARADARData from M1IM-$7I98 Future Proposed HST Atrspeoe Routes were developed In consultation with hUaml TRACON.

Base Map ls the Miami Sectional Aeronau5cel Chart, February 26, 1998, published by Natonal Oceanic Atmosphertc AdmlnSttratlce for ett navlgathn use.

A est A

2 24 GRAPHIC SCALE IN NAUTICAL MILES HST VEST FLOW FUTURE PROPOSED

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12 24 NOTES: MlAAlrspaos routes were developed from actual MIARADARData from 513MN - 6/7/S8 0

Future Proposed HST Airspace Routes were developed e consultation with MiamiTRACON.

Base Map ls the Miami Sectional Aeronaut@el Chart, February 26, 1SSS, published by N05onat Oceanic Atmospheric Admtntstratke forair nevigatke use.

GRAPHIC SCALE IN NAU7ICAL MILES HST EXISTING 8c FUTURE LOCAL FLIGHT PATTERN TRACKS FilctfcmC: P:QHstCscic'CCCAD~OOO-Aow MIL.dwg Oate: 07/26/99 0

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Base Map h the Mlaml Sectional harcnaudcal Chart, February 26, 1988, pubthhed by Natkeal Ocean@ Atrnosphertc Adrnlnhtratke forair navlgatke use.

s GRAPHIC SCALE IN NAUTICAL MILES HST EAST FLOW ARRIVALS"*"

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Bass Map ls the Miami Sectional Aeronautkret Chart. February 20, 19S8, publhhed by National Oceanic Atmospheltc Admtntstratlon forair navigation use.

HST EAST FLOVI' DEPARTURES FUTURE PROPOSED CIVIL ITINERANT BACKBONE R DISPERSED TRACKS APNPmP': IsHslXG~ACAOXHST EXHIBITSQHST-WPROJ-TRKS.OWG Oote: 07/27/99 0 I I:50:56

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Future Proposed HST Airspace Rovtes were developed fn consultation with MiamiTRACON.

Base Map ls the MfamfSectfonaf Aelonautfcaf Chart, February 2e, 1998, published by Natfonaf Oceanfc Atmospherfc Admfnfstratfon for air navfgatfon use.

12 QRAPHIQ SQALE IN NAUTICAL.MILES 24 HST WEST FLOW ARRIVALS BACKBONE 4 DISPERSED TRACKS FIIENosTte: P:XHEIXCIACADXHST-EXHI8ITSXHST-WPROI-TRKS.DWC Dote: 07/27/99 0

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12 GRAPHIC SCALE IN NAUTICAL MILES NOTES: MIAAirspace routes were developed from actual MIARADARData from Future Proposed HST Atrspace Routes were developed In consuttatfon with fc0aml TRACON.

Base Map Is the Mlaml Secdonsl Aeronsuthal Chart, February 28, 1988, published by NSSonal Oossnlc Atmosphertc Admbtlstratlon for air navl0a8on use.

24 HST,WEST FLOW DEPARTURES BACKBONE R DISPERSED TRACKS ftleNOITIe: P:XHstXCACAOXHST-EXHIBITSRRHST-WPROJ-TRKS.OWC Oote: 07/27/9S 0 II:50:56

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Base Map ls the Miami Sectional Aemnau5cal Chart, February 25, 1998, published by Na5onal Oosanlo Atrnospheito Admintstra5on for atr navlya5on ues.

fileNolrse: P:QHstgcisgCADssHST-EXHIBiTS'tsHST-ALTt-TRKS.DWG Dote: 07/26/99 0 16:41:57 See Lofer Sderrega". Ef-A ALTl

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~ pubttshed by Nr18onsl Oceanic Atmosphertc Admln stratke forelr navlgn8on use.

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12 24 NOTES: MlAAlrspaoe routes were developed from actual MIARADARData from 5/31/98 - 8/7/98 Future Proposed HST Airspace Routes were developed ln consultation with MiamiTRACON.

Base Map ls the Miami Sectional Aeronau8ctd Chart, February 26, 1998, published by Natkaal Oceanic Atmosph<<tc Admtntstre5on for air navigation use.

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<<O 12 CFIAPHIC SCALE IN NAUTICAL MILES NOTES: MIAAirspace routes wore developed from actual MIARADARData from 501lSS - STN8 Future Proposed HST Airspace Routes were doveloped ln consultation with MiamiTRAGON.

Base Map ls the Miami Sectional Aeronaut@el Chart, Februaiy 28, 1998, published by Natkeal Qosanlc Atmospheric Administration forair navlyrtton use.

24 HST WEST FLOW DEPARTURES FLIGHT TRACKS ALTERNATIVE 3 FIICNatlte: P:ICHel'E,GIB,CADQHST-EXHI8ITSXHST ALT>-mICSOVIC Oate: 07/27/99 O 090809 See Layer Manager: wr-0 AQ$

WORKINGDRAFT HST Departure and ArrivalAltitude Restrictions In east flow, the following altitude restrictions would apply to departures:

Jet and turboprop departures to WINCO and HEDLY will turn right and climb along the flight path until reaching an altitude of 5,000 feet MSL. They willmaintain that altitude until crossing under the downwind approach from JUI~< and HEATTto Homestead. When clear of approach traffic, they may climb unrestricted to cross over the MIA approaches from FAMINand WORPP at 10,000 feet MSL or more. This course overflys the western portion ofBiscayne NP at 5,000 feet MSL.

Jet and turboprop departures to VALLYwillturn right and climb along the flight path until reaching an altitude of 5,000 feet MSL. They will maintain that altitude until crossing under the downwind approach from JUNUR and HEATT to Homestead.

When clear of approach traffic, they may climb unrestricted to cross over the MIA approaches from JUNUR and HEATT at 10,000 feet MSL or more.

This course overflys the western portion of Biscayne NP at 5,000 feet MSL.

Jet and turboprop departures to SWIIVMwillturn right and climb along the flight path until reaching an altitude of 7,000 feet MSL. They willmaintain that altitude until crossing under the JUNUR approach course to MIA. When clear of approach traffic, they may climb, unrestricted. This course overflys the center of Biscayne NP at 7,000 feet MSL.

Jet and turboprop departures to ELLEE and MNATE will turn right and climb along the flight path until reaching an altitude of 5,000 feet MSL. They willmaintain that altitude until crossing under the downwind approach from JUICE and HEATI'oHomestead. When clear of approach traffic, they may climb unrestricted. This course overflys the western portion of.

Biscayne NP at 5,000 feet MSL.

The following altitude restrictions would apply to east flow approaches:

Jet and turboprop approaches from WORPP will cross the fix at 9,000 feet and 5,000 feet MSL, respectively, and maintain that altitude until reaching FAIvGN. After passing FAhQN, they willdescend and enter the final approach course at 3,000 feet MSL.

Jet and turboprop approaches from FAIvGN will cross the fix at 9,000 feet and 5,000 feet MSL, respectively, join WORPP traffic and descend to enter the final approach course at 3,000 feet MSL.

Jet and turboprop approaches from HEATT the JOUR approach to MIAat 9,000 feet MSL, then descend to intercept the downwind segment of the Homestead approach at 6,000 feet MSL. They willthen descend to enter the final approach course at 3,000 feet MSL.

Jet and turboprop approaches from JUI'~< will cross the fix at 10,000 feet MSL and 8,000 feet MSL, respectively, and then descend to intercept the downwind approach at 6,000 feet MSL. They willthen descend taenter the final approach course at 3,000 feet MSL.

08/I9/99

WORKINGDRAFT When in west flow, the airspace restraints on climb and descent are slightly different than those of 'east flow. West flow altitude restrictions on departures are:

Jet and turboprop departures to WINCO and HEDLYwillclimb unrestricted to cross over the airport at or above 10,000 feet MSL and cross the MIA approaches from WORPP and FAME at or above 16,000 feet MSL.

Jet and turboprop departures to VALLYand SWQvfM willclimb unrestricted to pass abeam Homestead at 10,000 feet MSL and then climb unrestricted to 16,000 feet MSL and above.

Jet and turboprop departures to ELLEE climb and maintain 5,000 feet MSL to pass under VALLY/SViZYMdepartures from Homestead and then climb unrestricted to 16,000 feet MSL and above.

Jet and turboprop departures to MNATEclimb unrestricted to 16,000 feet MSL and above.

West flow constraints on approach operations are:

Jets, turboprop, and light general aviation prop aircraft will cross the WORPP fix at 10,000 feet MSL, 8,000 feet MSL, and 5,000 feet MSL, respectively, and maintain that altitude until reaching the FAMINintersection. They will then descend/fly level to intercept the left downwind approach at 5,000 feet MSL and the final approach course at 3,000 feet MSL.

Jets, turboprop, and light general aviation prop aircraft will cross the FAMIN fix at 10,000 feet MSL, 8,000 feet MSL, and 5,000 feet MSL, respectively, joining the inbound traffic from the WORPP fix. They will then descend/fly level to intercept the left downwind approach at 5,000 feet MSL and the final approach course at 3,000 feet MSL.

Jet and turboprop approaches from HEATT will cross the JU%JR approaches to MIA at 10,000 feet MSL. They willthen descend and flyover the top of Homestead Regional Airport at 9,000 feet MSL, then descend to intercept the downwind portion of the Homestead approach at 6,000 feet MSL. After intercepting the downwind approach, they will descend and intercept the final approach course at 3,000 feet MSL.

Jet and turboprop approaches from JUI~ will cross the fix at 9,000feet MSL and, 6,000 feet MSL, respectively, and then intercept the left base approach at 3,000 feet MSL.

They willthen flylevel to intercept the final approach course at 3,000 feet MSL.

Special departure and approach" profiles were developed for each aircraft type projected to operate at Homestead in future years.,The general rule for.,the development of these altitude-distance prof'"s was that an aircraft was assumed to climb or descend unrestricted until reaching the constrain.ag altitude, at which point it would transition to a level flight segment until beyond the area of constraint. This generally results in a stair-step altitude-distance profile.

08/19/99

~VORKIXGDRAFT Homestead Regional Airport Annual Aircraft Operations Forecast Summary Current

--FORECAST--------

~197 2000 2005 2015 Maximum Use Commercial Passenger V

Latin America, Caribbean, International Turboprop (Dash-S,ATR<2, SWM, SF3)

Regional Jet (CRJ, EM4)

Narrowbody Jet (B-737/500/300/900, A320)

Widebody Jet (MD-11, B-767)

Domestic Turboprop (Dash-8,ATR-42. S Will,SF3)

Regional Jet (CRJ, EM4)

Narrowbody Jet (B-737/500/300/900, A320)

B-757 (B-757)

Widebody Jet (MD-II, B-767)

TOTALMarket Driven Latin America, Caribbean, International Turboprop (Dash-S,ATR42, SWM, SF3)

Domestic Narroivbody Jet (B-737/500/300/900, A320, MD-80) I/

TOTALNiche Market TOTALCOMMERCIAL 0.

0 0

0 0

4,570 2dBQ

~7 7,610 22,130 7,260 4,460 660 1,490 760 1,410 380 22 39,060 7,300

~4~l 51,220 Qne Run a

4,500 28,500 17,500 660 2,500 11,500 13,500 4,000

~l 83,170 25,573

~7~47 126,243 General Arcuation Single engine Multi Engine Jet Helicopter TOTALGA (C150, C172)

(PA31)

(Lear, Citation) 26,304 10.430 2,090 0

40,834 27,993 12,100 2,550

~249 45,133 33.821 16.260 3,610

~0 56,771 29,000 21,000 3,610 56,771 Aircraft hlaintenance Turboprop (Dash-S.ATR-42, SWM, SF3)

Na~owbody Jet (B-737 series, A-320, MD-80, B.727)

Widebody Jet (MD-11, B-767)

TOTALhlAINTENANCE 330 120 129 570 620 410 4~4 1,470 430 600

~44 1,470 Cargo~xe~g~r Narrowbody Jet Heavy Jet Turboprop Narrowbody Jet TOTALCARGO hfilitary/Government U.S. AirForce

~

U.S. AirForce Trans tent Transient Transient Transient U.S. Customs U.S. Customs U.S. Customs U.S. Customs TOTALMILITARY (B-727, MD-80)

(B-757, B-767, MD-11)

(Cessna Caravan, IGng Air)

(B-727, MD-80)

F-16C F-15 C-141 (C-17 in 2015) 2/

C-5 P-3 H65 PA31 C206 H60 C550 12.000 12,000 1,100 1.100 104 104 20 20 1.500 1,500 1,500 1,500 900 900 900 900 900 900

~ 900 ggg 19.824 19,824 1,040 Z9 1,560 12,000 1.100 104 20 1,500 1.500 900 900 900 K9 19.824 12,570 6,280 0

LK9 21,450 12,000 1,100 104 20 1,500 1,500 900 900 900 K9 19,824 8,500 10,500 LRS 26,966 12,000 1,100 104 20 1.500 1,500 900 900 900 K9 19,824 TOTALOPERATIONS 19,824 60,658 74.697 150,735 Note: Representative aircraft are provided by category. Actual Qeet willdepend on the carriers operating at HST.

I/

MD-80 aircraft is assumed to operate in 2005 but not in 2015 under this category.

2/

C-141 is assumed to be replaced by the C-17 in 2015.

Prepared by Landrum &Brown, 1998.

231,274 08/19/99

Homestead Regional Airport SEIS Civilian Arrival Operations by Flight Track Average Daily Itinerant Traffic by Year FAMINFix East Traffic Flow Runwa 5 Track05FJor05FP I !WestTraffic Flow Runwa 23 Track23FJor23FP 2000 2005 2015 Maximum,f 2000 2005 2015 Maximum AircraftTypes Day Night Day Night Day Night Day Nighl )

Day Night Day Night Day Night Day Night A320 (A320) 8-727 (727EM2) 8-737/300 (737300) 8-737-500 (737500) 8-757 (757RR) 8-767 (767300)

CRJ, EM4 (CL601)

Lear, Citation (LEAR35)

MD-11 (MD11GE)

MD-80 (MD82)

Subtotal Jets ATR-42 (DHC830)

C150, C172 (COMSEP)

Cessna Caravan (CNA441)

Dash 8 (DHC8)

King Air(DHC6)

PA31 (BEC58P)

Rotorcraft SF3 (SF340)

SWM (DHC6)

Subtotal Props Total 0 erations 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.23 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00 1.21 1.44 0.08 0.10 0.23 0.02 0.00 0.00 0.83 0.05 0.00 0.00 0.00 0.00 0.00 0.00 0.32 0.02 0.07 0.00 0.00 0.00 0.00 0.00 0.01 0.00 0.05 0.01 0.01 0.00 0.01 0.00 0.00 0.00 0.01 0.00 0.00 0.00 0.27 0.03 0.01 0.00 0.05 0.01 0.43 0.05 0.52 0.03 0.91 0.06 0.11 0.01 0.52 0.03 0.11 0.01 0.39 0.03 0.08 0.01 0.52 0.03 0.52 0.03 0.66 0.07 1.56 0.17 0.66 0.07 0.66 0.07 0.64 0.07 0.51 0.05 3.10 0.33 0.46 0.05 0.51 0.05 1.56 0.17 10.32 1.11 3.30 0.22 1.19 0.08 0.00.

0.00 3.30 0.22 O.OO O.OO 0.57 0.04 0.11 0.01 3.30 0.22 3.30 0.22 2.53 0.27 0.00 0.00 2.53 0.27 2.53 0.27 1.08 0.12 0.72 0.08 12.18 1.31 0.70 0.07 0.72 0.08 3.38 0.36 26.37 2.83 3.36 0.22 1.60 0.11 0.00 0.00 3.36 0.22 0.00 0.00 1.16 0.08 0.18 0.01 3.36 0.22 3.36 0.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00

%RRSCSWRQF5"'l 0.00 0.00 0.08 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.03 0.00 0.01 0.00

.0.00 0.00 0.00 0.00 3.71 0.25 15.07 1.00 16.38 1.08 I 0.11 0.01 4.14 0.29 25.39 2.10 42.76 3.92 f 0.13 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.30 0.33 0.02 0.02 0.03 0.00

~WlliZCC>~v 0.04 0.00 0.08 0.00 0.01 0.00 0.04 0.00 0.01 0.00 0.04 0.00 0.01 0.00 0.04 0.00 0.04 0.00 0.05 0.10 0.05 0.05 0.04 0.04 0.25 0.03 0.04 0.10 0.01 0.01 0.01 0.01 0.00 0.00 0.03 0.00 0.00 0.01 1.21 1.97 0.08 0.16 0.76 0.08

ZVPW,

~t'.26 0.02 0.10 0.01 0.00

-0.00 0.26 0.02 0.00 0.00 0.05 0.00 0.01 0.00 0.26 0.02 0.26 0.02 0.20 0.00 0.20 0.20 0.07 0.05 0.97 0.05 0.05 0.23 0.02 0.00 0.02 0.02 0.01 0.01 0.10 0.00 0.01 0.02 1.34 3.36 0.09 0.31 2.03 0.22 IE!trll:57~':tii"-

0.27 0.02 0.14 0.01 0.00 0.00 0.27 0.02 0.00 0.00 0.10 0.01 0.02 0.00 0.27 0.02 0.27 0.02 Source:

Landrum & Brown traffic distributions, based on Airport/Airspace Planning Data, Technical Memorandum, Sections 1 and 3.

Homestead Regional Airport SEIS Militaryand Government Existing and Forecast Operations Distribution Local Operations - Closed Pattern Totala Oa Closed Patternin east Flow tnunway 5 Opcratens Da ctosr pauernin west Flow Runwa 23 operations Landrngrratreotl Cycles NC4 NC6 NC7 NCI0 SC4 SCS AircraftT s

I'-I5 F-l6 P-3 H6$

PA3I C206 II60 C$50 Total ttons 100 4.800 500 500 500 500 500 500 7,900 24.hour 0.14 6.58 0.68 0.68 0.68 068 0.68 0.68 10.82 Day Night 0.14 0.00 6.58 0 00 0.68 0 00 0.68 0.00 0.68 0.00 0.68 000 068 0.00 0.68 0.00 1082 000 Oay 0.11 3.09 0.32 0.00 063 0.63 0.00 0.63 SAO Oay 000 0.53 000 000 0.00 0.00 000 0.00 053 Oay 000 0.46 0.00 000 000 000 000 000

'046 Oay 000 099 032 063 000 000 063 000 2.56 Day 000 1,05 000 000 0.00 000 000 000

'1.05 Oay 0.00 000 000 000 000 000 000 0.00 0.00 Day 0.03 026 003 000 005 005 000 005 0.48 Oay-000 007 000 000 0.00 000 000 000 007 Day 000 007 0.00 0.00 0.00 000 000 0.00 007 Day 000 007 0.03 0.05 0.00 0.00 0.05 0.00 0.20 Homestead Regional Airport SEIS Local General Aviation Forecast Operations Dlstrlbutton Local Operations - Closed pattern Oa'tosedPatterntnfastBow Runwa 5

ratrons Mar tmum Use 2015 oa catsed pattern in west Flow Runwa 23 rations Marimum Use rulers flT s

NC6 NC2 NC6 NC2 NC6

'C2 NC6 SC2 SC6 SC6 SC2 SC6 SC2 SC6 COMSFP (C l50. CI72)

I)EC58P (PA3 I )

I.EAR3$ (Lear, Citation)

Rolorcra(t Total attons 2.41 1.75

'1.02 0.41 17.55 8A8 1.12 0.54 1.03 OAS 1621 7.06 0.15 0.11 15.

6A9 0.28 1.75 0.10 187 0.08 1.25 0.11 0.02 028 IA6 0.08 0.08 1.31 0.10 23.73 1.25 2458 1.57 27.49 1.75 4 43 0 2tt 1.5 I 1.57 1.75 0.11 0 20 0 02

Projected Annual Space Launch Operations Homestead Regional AirportSEIS Type of Space Access System ASC, RSC, ROC B-747, Astroliner Total Space Launch 2000 0

0 0

2005 160 0

160 2015 320 160 480 Full Buildout 320 160 480

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