ML19256B826

Tx Pirg Supplemental Responses to Applicant Interrogatories Per ASLB 790712 Order

ML19256B826
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	07/27/1979
From:	Clay Johnson TEXAS PUBLIC INTEREST RESEARCH GROUP
To:
References
ITHR-790727, NUDOCS 7909200062
Download: ML19256B826 (16)

Text

-

U.S. NUCLEAR REGULATORY COMMISSION Defore the Atomic Safety & Licensing Boars In the Matter of I

Docket #50-466s cT,11 rev Wifr$

59' IIOUSTON LIGIITING AND POWEP CO.

6

'b I

Y gl i~

(ALLEN' CREEK UNIT 1) h

+7 4

TEXPIRG8S FURTi!ER RESPONSES TO INTERROGATORIES AS h

DIRECTED BY TIIE BOARD'S ORDER OF JULY 12, 1979 D

+

4 Si%

q 1".

On July 12, 1979, the Licensing Board entered an order in this proceeding relating to the substantive content of interrogatory replies proferred by TexPIRG, an intervenor in the proceeding.

In compliance with the Order, TexPIRG submits the following supplemental 8

responses to Applicant s interrogatories, referenced by the numerical citing contained in that order.

II.

1.

(Re: Site suitability comparison)

TexPIRG points out the following damages and deficiencies in the pres-eut siting proposal:

(a.) SAFETY. Both STP and ACNGS w?ll emit radiation; and though com-pliance with technical regulations may be achieved, a radioactive residual risk remains inherent in the operation of the plants.

Whatever the risk of latent health effects, and the particular vulnerabilities of segments of the population, the size of the potential health damages from that risk is a function of population exposure.

Class 9 accidents, and low r design basis accidents,can result i.n the release of rad ation in amounts larger than planned. (The experience of Three Mile Island Power Plant illustrates this possibility)

The latent health effects possible from design basis accidents increase with population exposure; and the dimensionr of a Class 9 " disaster" have been drastically reduced with lower population exposur e.

Certainly, lower population exposures and accompanying reduced infrastructure problems, lessen the difficulties 1224 208 790920006h (7

M--

~

L of preparing required er ; ion plans.

During the life of ACNGS, approximately 4 million people will live within 50 miles of Allen's Creek, compa o noi;more than 1 million people that close to Bay City.

In summary,=

ation densities will increase steadily eastward and south of the Allen's Creek site.

Without the growth factor of a nearby metropolitan area, population densities will remain rela-tively constant in the region of South Texas.

(The completion of the South Freeway from Ilouston to the Brazoria crea will intensify s,outhward development, while Houston's growth pattera has a shown a clear westerly movement along I-lO for at least ten years)

Thus, population dosages will be higher at ACNGS, vis a vis, STP.

Though of a lessor order of risk, TexPIRG would note safety concerns inherent in the transit of radioactive materials to and from the site.

Higher population densities usually are accompanied by greater congestion of transportation routes.

Furthermore, massive indus-trial development west and south of Allen's Creek, compared to lessor suct.

development near Bay City, results in more frequent transit of hazardous or flammable material on ACNGS-area routes.

As such, population dosages on routes to and from ACNGS are higher than STP, and the risk of major accident in transit somewhat higher.

The ACNGS proposal exceeded informal staff guidelines for projected population exposure in a 40-mile radius at the end of plant-life at the time the initial selectinn of site was made. (N.R.C. Working Paper, " Population DistrLhution AroundPlant Sites," April.17, 1973).

The STP site selection 122/

209 1!34

^4?

conformed to those guidelines.

i (b.) CONSTRUCTION.

Construction of ACNGS will cause disruption in the social structure of the immediate community, requiring upgrading of police and fire protection and educational facilities, increasing retail prices, and increasing the crime rate.

Bay City has, and is, undergoing

3 such dislocation, and as such, will be better prepared to continue or stabilize that dislocation if construction phases are temporally extended.

Construction of ACNGS entails the flooding of 5,000 acres of land, which is valuable for farming and future urbanized usage, and such flooding and loss of land will not occur in upgrading STP.

The total project site will result in the removal of 9,000 acres of wildlife habitat at ACNGS, removing habitat for such mammals as coyotes, raccoons, deer, rabbits, squirrels, gophers, arma dillos, and oppossums, and that similar loss of habitat will not be caused by the addition of a third unit at STP.

Furthermore, surrounding land will be at a reducedvaluation, relative to what it would be without construction of ACNGS, during future urbanization prior to the end of the plant's lifetime.

Any land valuation reductions surrounding STP, if indeed urbanization does occur there, will not be affected one way or another by a third unit.

Finally, of/

the loss Allen's Creek itself, as a result of constructing the pond associated with ACNGS, will result in the destruction of 8.5 miles of spawning area for acquatic life, which may also be avoided by use of the STP site. Obviously, the flooding of land at ACNGS will submerge and destroy trees.and other flora, as well as any wildlife on the land area to be ponded; and such loss will not occur during the construction of a third unit at STP.

(c.) FRESHWATER. STP third unit operation would consume an estimated 17,700 acre /ft. per year, for a net savings of 22,600 acre /ft. annually compared to ACNGS freshwater usage.

2. (Re: Water use at STP) 2

.~~

=

Page 10-7 of the STP FES states that the first two units will consume 2.6 % of the Colorado River's annual flow, and page 5-22 of the report shows that this is based upon the diversion of 54,000 acre-ft.

same per year.

At page s.9-ll of the ACNGS Final Supp./FES, the staff estimates the hhird unit would cause an additional 17,700 acre-ft. loss annually, or on1 0.85 % of annual flow (17,000/54,000 x 2.6%=.85 %).

4 At 5-22 of the STP FES, 102,000 acre-ft. per year is said to be the allowable rate; and since the Applicant applied for a 102,000 acre-ft. per year permit from the state, we interpret this term " allowable rate" to mean permitted rate.

3. (a.) (Re Cite for crops)

Page S.2-5 of the Final Supp./FES for ACNGS.

5.

(Re: information on subsidence-caused Brazos water conversion)

TexPIRG has studied the question of subsidence in the Houston area, but has published no reports; and has access to only one document specifically referring to the required conversion to Brazos River water; that document is Ch. 284, VATS Water Table Aux. Laws (table III) (also, ref. as H.B. 552, 64th Legis.), which sets terms under which the Harris-Galveston Coastal Subsidence District must conrider the available surface water in conditioning or granting well water permits.

However, TexPIRG does possess documents on the question of subsidence in the area generally. (not sought in the question, apparently)

TexPIRG would note that the Applicant may inspect six permits on file with the Harris-Galveston Coastal Subsidence District which condition the permits for well water on the ennversion to Brazos River water.

Also, Appli-cant may be aware of the fact that Houston Lighting and Power is a member of a consortium of industries that has converted to Brazos River water usage, in Galveston County.

I224 211

6. (Re: crops grown in ACNGS area)

TexPIRG does not know what crops are grown specifically on that site, since the intervenor has not yet been granted the right to inspect the site.

TexPIRG believes that precise question is not entirely relevant since HL&P owns the land and can control its use,

f![l

' A /,!

5 However, what is relevant is what crops can be grown on the land.

The Agricultural Extension agent in Austin County indicates that the land there is historically and naturally suited to growing rice, sorghum, corn, hay, peanuts, and watermelon.

The most commonly grown crop is peanuts, and the County is second in the stat.: in hay production.

TexPIRG does not know specifically which of these crops will or have been imported from California.

8. (re: heavy metal concentrations)

TexPIRG can only identify the types of heavy metals that may be expected in the water discharges; but TexPIRG does not know what the concentrations will be.

These metals are identified as mercury, zinc, copper, cadmium, and nickle.

9.

(re: source of cold shock information)

Most biologists familiar with this area of literature wodld agree that such factors are important to cold shock.

Honever, two articles,

cited below indicate varied synergistic effects are factors in fish cold shock and thermal shock, and suggest the sort of variability inherent in examining such phenonoma.

" Effects of Temperature, Copper, and Chlorine, on Fish During Simulated Entrainment in Power Plant Condenser Cooling Systems" Hoss, Coston, Baptist, and Engel, at p. 519.

and " Aquatic Physiology of Thermal and Chemical Discharges," Thatcher, Wolf, and Hunt, at p. 547; both in SYMPOSIUM ON THE PHYSICAL AND BIOLOGICAL EFFECTS ON THE ENVIRONMENT OF COOLING SYSTEMS AND THERMAL DISCHARGES AT NUCLEAR POWER PLANTS.

Vienna, 1975.

The reason TexPIRG originally cited p. S.5-13 (FS-FES ACNGS) is that we were attempting to respond to the original question requesting our basis for concern over thermal shock; and Applicant may note in Table s.5.8 on that page that few Texas game fish are indicated to be unaffected when temp-eratures exceed 90 degrees, F.

h

~

6

11. (re: GCWDA waste project)

TexPIRG does not know the answer to the following subparts:

(3), (4), (5), (6), (7), (8), (10).

The answers tothe remainder are as fo7 lows:l(feedstock) raw municipal refuse; 2 (source of feedstock) City of Houston waste through Browning and Ferris Corporation; 9 (suppl. fuel source) none.

In elaboration on several of the unknown question-responses, TexPIRG would note that this plant is not intended for electrical production, but rather industrial steam usage nearthe plant in Bayporty though the concept could 2 rtainly have been applied to electrical production.

Since the primary goal in the design was to dispose of waste, with a secondary goal of power production, the plant is a simple and a relatively inexpensive one that utilizes mass refuse burning, without processing. (That would lead us to assume that the answer to #10 is very low)

However, this design is not the most efficient for energy production, and we would expect indicators of thermal efficiency to register accordingly.

But, the point is that this design reflected a satisfaction for the demand of power the GCWDA could find at the time of feasibility consideration.

1 }' " '}.}} 3

16. (re: solid waste combustion)

Support for the 80 % combustibility factor comes from many sources, includ-ing the HANDBOOK OF SOLID WASTE DISPOSAL (which indicates urban refuse is com-posed of over 50 % paper; and approximately 30%, other combustible materials such as food waste); experience at Browning-Ferris' Industrial Recovery Facility does not indicate that Houston's refuse. differs greatly from that in other urban areas. The 40 % efficiency facter i a general conversion figure derived from a discussion with Dr. Jack Matson, Engineering Professor, Univ. of IIouston.

17. (re: sources on underground siting / concrete thickness) alvin Moon of the NRC staff was the source of the information on containment hickness and the way in which Applicants normally increase protection against ir crashes, when needed; while two books provide some information on under-

. +. 7 grbund siting: "On the Design and Containment of Nuclear Power Stations Located in Rock" (Carblom, Von Ubisch, Holmquist, and Hultgren) in TECHNOLOGY, ENERGY, AND SAFETY SERIES, IV, VOL. 2, Pergammon-Press, 1960. " Underground Siting of Nuclear Power Reactors," Karpenko and Walter, SITING OF NUCLEAR FACILITIES, Proceedings of the Intl. Atomic Energy Agency, Vienna, 1975. Interroga tory #20 (Re: information on industrial self-generation) A summary document indicating, in part, the need and potential for self-generation and co-generation of electrical energy by utilities is the " Rate Des;gn Study" (Interim Report, Public Utility Commission of Texas). TexPIRG possesses a copy of this report, but is further confident Applicant also holds a similar copy. That report, at p.166, notes that CAM, a consortium of petro-chemical industries in Texas City, are presently working toward 'sel f- . generation of electricity. Texas City is served by Community Public Service, which purchases power from HL&P's grid. Beyond replying to the precise question of what documents TexPIRG possesses on this subject, Applicant implies in its Motion to the Board that TexPIRG is also responsible for discussing factors that may l'ead to this industrial conversion. The Board does not address this point in its Order, but TexPIRG will nonetheless attempt to respond here. The PUC document cited above notes one such factor in the use of co-generation: ...as a result of current escalating electricity costs, a growing public interest in conservation and the environ, ment, and the phasing out of natural gas as a boiler fuel, interest in co-generation has been renewed." (at 163) 1224 214 A O

-~

7a Several factors exist in the Houston area specifically that en-courage the use of co-generation and other forms of self-generation: (1) an expanding industrial sector (this is important, since co-generation is not generally " retro-fitted"); (2) industries' highly predominant in the Houston-area, namely, paper mills, petroleum re-fining, and petrochemical processing, have characteristics favorable to co-genera tion; e.g. use of high steam loads, need for low pressure steam, large requi rements for thermal energy, and good balance between steam and electrical loads; and (3) the existence of several high load factor industries in the Houston area, which are the most likely to find self-generation econciaically feasible. Prabable changes in rate structures during the next decade will speed the use of self-generation. It is presently the position of the U.S. Department of Energy to favor marginal cost pricing for electric rates; and TexPIRG believes such a rate design is eventually inev.itable in Texas. Accordingly, the Public Utility Commission of Texas appears to be moving away from declining block rates that favor industrial users and states in its rate design study: "No declining block rate form is justified unless specifically and empirically related to cost, otherwise a flat rate is indicated..." (at p.

9) and "the appeal of marginal cost analysis is sufficient to merit further development by utilities and PVC staff" (at p. 7).

Marginal cost rates will shift rate burdens to those users whose additional consumption increases the system cost; and large expanding industrial facilities will fit into that category. This higher rate burden will increase industrial self-generation. E l e c t r i c'a l energy is an increasing cost industry; and TexPIRG believes that lower capacity utilization efficiencies resulting from the Applicant's increasing re-liance upon building new plants which are large and/or nuclear fueled will make the increasing cost of new power production facilities even higher in cost. Faced with such costs, industries will turn to conservation to reduce present consumption, and sel f-generation to fuel futu're consump-tion. Industrial energy consumers testified in the Generic Rate Design Hearings of the PUC that marginal cost-based rates might spur the use 11224 2P5

e 7b of other forms of energy in substitite for electrical energy among Texas manufacturers. And, indeed, HL&P's rate consultant, Robert Sarikas, stated in prepared testimony for that hearing that marginal cost-based rate designs might encourage industries to shift to forms of ' energy other than electricity. Applicant somewhat rhetorically asks how industries can generate electricity more cheaply and reliably than HL&P. The reply to that question is that smaller scale facilities may be more efficient, there is little loss of energy due to trasmission distances, electricity may be a higher-grade form of energy than is actually needed, and the in-dustrial consumer need not be concerned either with cross-subsidization or the Applicant's profit margin. Furthermore, many of the major in-dustries in Houston possess their own coal resources--Exxon owns 'sub- .s tanti al ou t-o f-s ta te coal lands, and Dow owns the rights to lignite-rich Texas land (at 07e time part of a joint venture with HL&P)--and may attempt to consume those resources directly if fuel charge rise sufficiently. / e e e e e 4 1224 216

e 8

24. (Objections to Chlorine Minimization approach)

TexPIRG8s substantive objection to the approach stated by Applicant is that may result in chlorine levels at a concentration of 2.2 ppm. On pages S. 5-16 through 5-19, charts reflect that such levels have subtantial impact on acquatic life. Particularly, Fig. S.5.2 indicates acute mortality at that lev 61 (Pages cited from Final Supp./FES for ACNGS) On advice of counsel, TexPIRG also has legal objections to such an appcoach. TexPIRG is highly supportive of NEPA, and the plan outlined by Applicant does not provide for a measurement of costs and benefits of alt-ernatives prior to operation of the facility, as required by that law.

25. (Re: prior studyof chlorine levels)

TexPIRG would suggest that multi-stage statistical analysis of Southern power plants with cobling ponds and the various chlorine concentrations nsed therein, should be conducted such that all the variables can be factored and seperately examined, as to effect on fish and aquatic popul cions. In the alternative, TexPIRG would suggest a comprehensive analys, is and comparison of scaled down ponds controlled to simulate the conditions at ACNGS, with an independent variable of chlorine concentrations manipulated. Applicant must reme' ber that TexPIRG is not committed to ACNGS being m recreational facility, and thus would not oppose the elimination of the ond as such, if the studies revealed the chlorine problem unsolveable. la. (Assumptions--barge contention)

122q, 217 The assumptions requested are as follows:

--The reactor is 74 ft. x 22 ft., and the vessel when fully nousted weight 1,052 tons. --The last Corps of Engineer study (June, 1979) indicated the channel to be as shallow as 7 ft. down the middle, and six feet to either side. }]72 "., n

9 --TexPIRG is, at the moment, uncertain of the means and location of loading the barge. Assuming the vessel is lowered on to the barge from a large ship at sea, the barge will not enter the mouth of the river without dredging, assuming a depth of 2 to 3 feet at that point (the river's mouth). With regard to a route involving direct use of the intercoastal waterway into the San Bernard River, TexPIRG is still examining and studying the matter to reach a more definitive conclusion as to whether channelization would be avoided in that circumstance. 26. (Re temperature changes required to induce thermal shock) This question is fairly vague. It requests information with respect to all game fish in Texas lakes; yet not all of those fish will inhabit ACNGS cooling facilities. Basically, such information specific to each specie is not available, to the best of TexPIRG's knowledge. TexPIRG has requested such information from the N.R.C. staff, which analyzed the effects of the pond on biota, and the State Parks and Wildlife Department, which will stock the pond; and neither party indicated they knew the answer. Another factor that makes this informa-tion difficult to obtain is that many factors may be involved, and no one calculation is adequate. Finally, " thermal shock" should be defined. If possible chronic effects of thermal shock, and " ecological deaths" in which temperature change cay reduce the fish's resistance to predators or disease, are all considered, then the liklihood of arriving at single values of permissibl temperature changes for each specie is remote. Temperature rises of 5-6 degrees (c.) over 2 to 3 hours are respon-sible for most of the thermal shock fish kills associated with power plants, according to Parker and Krenkel in THERMAL POLLUTION, 1969, Vanderbilt Univ., }22i 218 III-20.

32. (re: stress, corrosion and cracking pipes) pj-7 ;

-}i--

10 TexPIRG does not specifically know why the metal content at ACNGS' piping will not meet the criteria. The basis c: the contention is that such pipe problems are chronic with both nuclear power plants and other industrial facilities. Since the pipes are composed of metal, inferentially TexPIRG concludes that the present metal content is not adequate. TexPIRG has no certainty that it is presently possible to designs pipes that meet that criteria in such a way as to provide for the public's safety, since stress corrosion and cracking of pipes occurs not only in nuclear facilities, but also in conventional steam facilities, and such problems have not been resolved over the years so far.

33. (re: flow-induced vibration contention)

TerPIRG cannot fully respond to this interrogatory until expert witnesses have been retained on this point. However, TexPIRG would note that ACNGS core area is of a form unlike other operational plants. The number of fuel rods is greater than other operating BWR's, and the core geometry is therefore different. TexPIRG suggests that full-scale testing and analysis' of a design identical to ACNGS should be conducted at a remote site to evaluate and assess the effects of flow-induced vibration. TexPIRG does not know if the feedwater spargers which failed at other BWR,'s are exactly the same as those planned for ACNGS; however, TexPIRG assumes that such spargers remain very similar, if not identical. -.-n, ,t n s c 1.224 219

y bl$) (Re: Wend3 34. (b) A Manning Roughness Factor (n) of 0.015 ethich was used was taken from the suggested value for Cast Iron as shown in Table 5.2 on page 252 of the Fourth Edition of a book titled " Fluid Mechanics" written by Victor L. Streeter, a Professor of Hydraulics at the U. o f Michigan and published by McGraw-Hill.h could have used the value of 0.018 which i;ould have been even more unfavorable to the Applicant even though it is for riveted steel. (c)During the LOCA the pressure,within the drywell generated from the massive release of very hot steam which is generated at the rate of 3,758El, increases very rapidly and will soon exceed the design amounts allowed for the drywell(in a few seconds) Unless the steam can escape through the vents into the supression pool before it exc.ceds the 30 psi design limits the drywell will be shattered so that the radioactive steam can rapidly cause the pressure of the containment vessel and the shield building to be exceeded. All the water above the vents held between the weir wall and the drywell wall (26" or 2.178 )must go through the vents (27.5" diameter or 1.146' radius).The 40 sets of 3 vents are placed on the drywell wall at a distance of 5.65'and the second vent is placed under appx. 12 ft of water. Therefore that volume of water must pas, through the vents before the pressure inside the drywell is able to be 3 reduced. That volume is 2.17' x 5.65' x 12.0': 147.1 f t. Also the water vrithin the vents must be removed v;hich is an additional 3 volume o f 3 x 3.14 x(1.146')2x 6'(length of vent)n?4.1 ft for a total 3 o f 221.2 ft. The Mannings formula, Q 1.49/n(cross-sectional area)(hydraulic radius area / wetted perimeter)2/3(slope of flow)l/2can be used to calculate how much(Q) water can be forced through the vent per second. Tg(3,;77)1/2 ThereforeQ 1.49/.015(3.14x1.146)fi3.1hx1,th6 2 2-or110.9 ftfsec.It therefore takes 221.2If16.$*N1*he)lb8dodds to remove the water from the vents so that the steam can escape. Using Figure 6-2 of the Safety evaluation for Allens Creek (page6-9) one can see that the absolute pressure will have risen to at least 51 psi which is equal to a differential pressure of at least 51-16 or 35 psi. This is not sufficient because the drywell is designed (after last change) for only 30 psi. 1221 220 _: :: E'

12. It should not be inferred that the simple calculation done here is the final or best calculation of the actual differential drywell precoure generated during a LOCA, but i' is instead the minimum pressure that would be reached.The actual pressure would be higher because of several factors not accounteu for in the simple calculation. Come of these are: (a)Mo accounting of thefrictional forces caused by the flow o f the water between the weir wall and the drywell wall was made;(b) The increased resistance to flow caused by the right angle turn that the water must make to go through the vent pipes;(c)The roughness factor will increase as the plant is operated and the pipes (vents) get rougher;(d) The increased resistance to flow caused by the contraction and expansion loss coefficients that represent losses upon entering and leaving the vents; and (e)The steam pres;ure is not released until the steam travels from the vent through the suppression pool,a minimum of 7.5 ft. (e) As soon as the drywell is breached such that the massive amounts of steam generated within the pressure vessel go directly into the containment without the condensation effects of passing through the suppression pool, then the pressure within the containment will very rapidly rise. According to Table 1-1 of the SER the steam flow rate (and generation rate) is 15.396 x 1c" pounds / hour or 4,276.7 lb/sec. The saturated steam tables in the Handbook of Physics 2 and Chemistry shows that steam when under a pressure of 30.664 lb/in 0 3 and at a temperature of 122 0 weighs 0.0743 lb/ft Therefore,the reactor generates enough steam to generate 4,276.7/.0743 or 57,560 3 ft of steam at a temperature of 122 C and over 15 psig in only one 6 3 second.Since the total containment free volume is 1.16 x 10 ft, it would take only 20.15 seconds to fill the containment with steam to such a value as to exceed the containment design pressure of 15 psig. (f) Page 6-16 of the Safety Evaluation for Allens Creek states that the design pressure of the containment vessel is 15 psig. In (e) above we have shown that this pressure will be exceed within about 20 seconds of the main steam line break, Certainly the total amount of steam released during the accident without suppression pooling that was effective would by many times be sufficient to " crack" the containment vessel. .c ' ij 521 221

a., e e l, l

35. (re: redundant scrams)

First, the SER, page number is i.C.J. i ll' '. 7?s ~ ~ Secondly, TexPIRG suggests the incorporation of a diverse, redundant, automatic scram system. One possibility could include a high-capacity automatic boron injection system as the redundant system, if such system adequately to/ can be shown scram the reactor in timely enough manner. Another possibility would involve a major redesign of the core and reactor, so that horizontally motile control rods would automatically scram the reactor in the event that the normal vertically situated control rods fail. III. WHEREFORE, PREMISES CONSIDERED, Intervenor TexPIRG requests that the Board enter this instrument into the records as fully complying with the Order of July 12, 1979. Reppectfully Submitted, b,W Clarance Johnson Executive Director,TexPIRG Dated on this the 27th day of July. 1979 in the County of Harris, Texas. I CERTIFICATE OF SERVICE I, Clarence Johnson, herein certify that this document has been served by deposit in the U.S. Mail on July 27, 1979 upon the Secretary to the Nuclear Regulatory Commission, and the following. individuals: J.G. Copeland, Sheldon Wolfe, E.L. Cheatum, Gustave Linenberger, Richard Lowerre, R. Gordon Gooch, Stephen Sohinki, John Doherty, Carro Hinderstein, Brenda McCorklc, Wayne Rentfro, F.H. Potthoff III, Kathryn Paaker, Madeline Framson, David Marrack. 1 2( & 2,c } l p - ~ l224 222 w, 4,./1.-, -

t Strce of Texas ) ) County of Harris ) BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Clarence Johnson, who upon his oath stated that he has answered the foregoing TexPIRG's Response to Houston Lighting & Power Company's Interrogatories to TexPIRG in his capacity as Executive Director for TexPIRG, and all statements cc tained therein are true and correct. S k h" Clarence Johnson SUBSCRIBED AND SWORN TO BEFORE ME by the said Clarence Johnson, on this M N ay of ZV 1979. b _f_D. _ve _ Notary Public in and for s. Harris County, Texas JOHN V/. oVERTCN ' -t:ry Putn: m anc f or H rris County, Texas !.;y cernmasi:n Expret January 31,1$.

1. L:<.yers Sarcty Corp.

Conded by heaandct L:.e: ~,;,, 1224 223}}