ML19261C350

Intervenor Tx Pirg First Set of Interrogatories to Houston Lighting & Power Co

ML19261C350
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/05/1979
From:	Jeffrey Scott TEXAS PUBLIC INTEREST RESEARCH GROUP
To:
References
NUDOCS 7903220308
Download: ML19261C350 (3)

Text

,;'

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

'Oshp z <

" 6-

- MAR 1 2"w 1 -

, In the Matter of NRC pp' ,

X -

- . 1993A .,

X HOUSTON LIGHTING AND POYIER COMPANY ' XU W Docket No. 50-466 g S'rg;",,,

.," ., !g Ia 7

(Allenn Creek Nuclear Gen Station) X m TMX PIRG'S FIRST SET OF INTERROGATORIES TO HOU, IAP%N.Ykh, ,o .

4-Purcuant to 10 CFR 2,740(b) , Texas Public Interect Research ,, Am,

.. ' ,. m.

Group : requests. that the attached Interrogatories be fully answeredp; yn I in writt'ing,by Mr., 'D)D![ Jordan ~and,any other of ficiers or employees ^

, . . . . . 'M of the Applicant who ~ have' personal knowledge w

7thereo f or are the clsectC o

"".- / . . . ,

.' .L -

to having personal knowledge th. '-

ereo f, Vlho ever; answers 'chould their name and title and show which Interrogatorica he or che l'sy:1

.a t.a ,sets

, y b ,3 ~

..Z 6. .

responsible for. answering. *

,, ,.;f[. - y;,y Each question is to be answered in.6 parta, ac follows:  : . ,I. '

- Answer to Question #

(A) Direct answer,4(B) List all documents ,//k

' '" . I , and ctudiec , with page numberc, relied upon by the Applicant, nowlor in the pact, which cerve as~ the bacio for the answer. A copy may be- .

'? furnished now, (C) List all documents and studies, with page numbers, ,

examined but not relied upon, which pertain to the subject matter. quest .

ioned,(D) List by name, title and affiliation each employee or consultanty.

', that has the expert knowledge required to' cupport the ancwer to the. -

quection,(E) Explain whether the Applicant intends to do any furth'er ,

research or work which may affect the Applicant's answer, Identify: , ' ' fj ,

cuch research or work,.and who ic to do it,(F) Identify the expert (s),. M

}; ifany,whomtheApplicantintendotohavetestifyonthecubject.{ .

,d, ,_ matter,, qu{ctioned. State the qualifications of each cuch expert, .

W ' y

,1, g V! hat is comp the Nuclear 1sted?YouPower Plant Siting? Study?Y/ho4did / it? Vihon I' it' started.and may sendyascopy;now, jhh.~:-

I 2. Vihat wWrthe names and locationc of. 'each .of the citos studiedi;byf the'.c )

,. Applicant before the'; Environmental Report was submitted to the NRC?1 ; '

3,How many acres of land' would be needed for.!each site consideredias('.g

?

.w an alternative to the Allens Creek cite? Vihat. is the present market,,A ", c-- _

value of each cite? ,

[N m

4. On a map or drawing for each cite show the locations of the plant,c }[;

cooling lake or tovier, prime or unique farmland, coil classes I,II,and : "', '

III,and cropa or cattle use. areas, ,

U' 5, For each cite, wha + .would be the cource of cooling water, and the

^

1[,[

annual nced? '

a 1, -

7 0 03220 3 0 $

@ + _,

, 6 Jhat in the average annual flow (acre feet) of tue irin;ty, Brazos,

s. + Co lb rado , San Bernard, and San Jacinto Rivers at the point clocent to

.v

, one of the propoced cites for a nucl 'ar plant? q

,[ 7. What ic the planned location (pathn), lenrths, c;idths, and acreagcc  ;,

,- o f the nececcary trancaiccion t in u for the twa uni t ;outh Texaa project? '

.7111 it connect to the prec_ nt Hounton aru a trancmincion cyntem? J2 ca, t i,t where?What are the voltages, heights of wirec above ground, andcorridorll

' idtha for the linec between South Texas and the Irecent nyctem cerving s

2 the Hounton area? !S if B. What in the decign rated voltace, current, . o 'r. o r f a c to r, and power t(

for the South Texas trancmiccion lines to the present Houcton area I cyctem? Shen is conctruction of thoce lines to start and to be completidY 9, 0 hat additional coct, corridor ;!dth, corridor 3 ength, and acres  ; A.

riould be nececcary to trancmitt the power from on lillent Creek unit j' .

located at the South Texan cite to the areas to be cerved by the ll

,1 Allena Crock cite unit? State the accumptions uced? li

,e 10, What are the expected trancmir,nion line loccen of power cent from 'l ,

the South Texac cite to San Antonio in terms of M loca ane additional f dI' coct of power? ,p 11 What are the names and locations of the variouc dara located on the ;

Colorado River? When were they built? What hac the aver me ctorage $

amounto of each of these lakes been cince they were firnt filled? -

12 How far upstream from the mouth of the Colorado River ir it tidal?'1 13 What is the average calt content of the Colorado River at the )

intake to the Couth Texas cite?

14. What was the ,. annual Colorado River flow for the years cince 1971 at the Bay city station?

15, List all the owners and locations of all permito to divert .-

Colorado River water between Auctin and the South To::a- <itei.ihat is ,

the to tal divercion allowed for each such permit? J, hat ic the total net diversion of water between the two locationc? , N

16. What ic the expected annual Colorado River flow at Bay City- to be) in 1990,2000,2010,2020,2030,2040, and 205C? _ [

17. What basic was used to justify designing the South Texac cite, lake, etc,to handle 4 units when a much smaller lake woulI be cufficient to cool the two unita now under conctruction? How much aiiitional forced evaporation will two unite cauce when added to the two units already there?

2 .

18, What vrill the total construction cost. of the approximately 20 '

e miten o f embankment around the cooling lake?

19, '!!hera in relation to the two unita now under construction wouldj P the next two units be placed (at the .. . t :c m :n te)? .-

20, i:ow many acren would be is acto ! by conctruction activitiec ! "6 a cco ciate ri with conctruction > f on . adli tional unit (3ra unit) tt the S, Texac cite? 'lihat would thin im;act be, and where would it take place?

21, '! hat cropc are now being crown on that lano that woulu be impacted?

22, !! ave any of the precent partncrc to the S. Tc: ar project refuced to allow Houcton L & F to build a third unit at the .;. J e xa .~ cite? Is cuch refucal in writing? Vihat date was it written? Have any o f the precent partnero been ack if they would like to take part in the building o f alditional units at the a. Texan ::ite?

23, ll hat would be the length o f ana coct of a pireline or ditch to allow the uce of calt water for cooling of a thirti unit at the S. Texas cite?

24, For both the 3 Texac and Allena Creek citec, for both July and' Jan,,

what is the estimated dictribution of temperaturen (i.rofile) near the conter of the lakec?(ac 90 F at :urface and 85 F at 10 fact and 80 F at 20 ft.),

25, Since 1960, lict the dates that the Brazos R. flood waters covered the area of the Allens Creek cooling lake with water o f at least 100 ft above cea level? Above 110 ft*/

26. How much would it coct to build a levee to protect the Allens Creek area fro- the 110 f t floc a (with 3 ft freeraarti)?

27. lihat conctfuction has been done at the Allenn Creek cite prior to receiving a construction permit from the URC? I rom the Te..aa PUC( cert- ,

ificate of nececcity and convience)?

2S, '!! hen doec applicant plan to ctart and complete their ..nvironmental Rc70rt for the Operating Licence of the 5, Texar unitc?

29,'!! hen did applicant start and complete the Supplement to the Environ-mental Report for Allens Creek?

" arch 5,1979 Respectfully submitted, .J

% '-Je>, ch$A . ,,

J ame s Mo rgn r. .cntt, J r. ';

Tex PIRG attorney  ! :l 8302 Albacore

!!ouston, Texas 77074 f (713) 771-7606 _ !E f

3.

4 e