ML19296C502

Answers to Applicant Second Set of Interrogatories & Request for Production of Documents.H Saxion Retained as Expert Witness.Documents Re Applicant Error in Future Water Supply Projection Available for Insp.W/Certificate of Svc

ML19296C502
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	01/28/1980
From:	Hinderstein C, Saxion H AFFILIATION NOT ASSIGNED
To:	HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8002260367
Download: ML19296C502 (6)

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RELUED COMSMNDENCE 0/- T -3 UNITED STATES OF AMERICA 99,9 NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOA C N. -O . i /

In the Matter of S S -

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 -

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(Allens Creek Nuclear Generating S Station, Unit 1) S CARRO HINDERSTEIN'S ANSWERS TO APPLICANT'S SECOND SET OF INTERROGATORIES AND REQUESTS .

FOR PRODUCTION OF DOCUMENTS In response to the second set of interrogatories propounded by Applicant, Houston Lighting & Power Company, Carro Hinderstein, Intervenor, answers as follows:

A. Hinderstein Contention 5 {

l. State whether you have retained Mr. Howard Saxion as an expert witness. If the answer is yes, answer Interrogatory

2. (a) - (e) of the First Set of Interrogatories and Requests -

for Production of Documents from Houston Lighting & Power Company to Carro Hinderstein with regard to Mr. Saxion and his testimony.

ANSWER: Howard Saxion has been retained as an expert witness. The answers to the following interrogatories cover the answers to the First Set of Interrogatories and Requests for Production of Documents from Houston Lighting & Power to the ~

extent the answers are known at this time.

2. Identify those portions of the document titled " Water  !

for Texas" dated December, 1974, or the document titled " Water for Texas" dated 1976 you will rely on in this proceeding.

ANSWER: I do not plan to use the aforementioned documents.

3. Produce all studies and documents showing that Applicant's projections for future water supply from or demand on the Bracos River are in error.

ANSWER: The documents are as follows:

" Population Proj ections for Texas, State, County, State  !

. Planning Region and 208 Water Quality Designated Area, August 1979," Texas Department of Water Resources, Austin, Texas. ,

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" Water Resources Data for Texas, 1977," U.S. Geological Survey, Water Year 1977, Volume 2. fi

" Continuing Water Resources Planning and Development for f Texas," Volume 1 and 2, Texas Water Development Board, _

Austin, Texas, May 1977.

"208 Water Quality Management Plan for the Brazos River Basin and Adj acent Coastal Areas -- Draf t," Volume 1, Basic Data, September 1977, prepared for the Texas Depart-

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ment of Water Resources by the Brazos River Authority of Texas.

- " Preliminary Analysis and Views of the NRC on.the Recommendations of the President's Commission on the Accident at Three Mile Island," November 9, 1979. .m k

10 CFR, Part 100, $100.1-100.10 and Appendix A.

" Texas Water Plan," Texas Water Development Board, Austin, Texas, 1968.

"The Nation's Water Resources," U.S. Water Resouces Council, Parts I-V and Appendices, Washington, D.C., 1978. F M"

" Final Supplement to the Final Environmental Statement Related to the Construction of Allens Creek Nuclear Generating Station, Unit 1 and 2, Houston Lighting and Power Company," August 1978, Docket No. 50-466, U.S.

Nuclear Regulatory Agency, Washington, D.C.

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" Texas Coastal Management Program -- Hearing Draft," h General Land Office of Texas, Austin, Texas, June 1976. E i

"Matagorda Bay Proj ect -- Draft Environmental Impact s Statement," Federal Power Commission, July 1977. i Public Law 91-190.

R. John Taylor and Constance Taylor, " Multipurpose.Use of Reservoirs," Annual - Oklahoma Academy of Sciences, No. 5, 1976, pp. 106-112 The aforementioned documents give an insight as to why  ;

the Allens Creek site is the least preferable site for a nuclear generating station. Future population and land use trends, environmental constraints and precluding future options make the Allens Creek site unacceptable. See response to A.4-5.

Copies of the aforementioned documents are available at any Federal / State document depository. Intervenor is prepared to produce copies of the aforementioned documents at the rate of 25 cents per page.

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4. Produce all studies and documents showing that n conversion from ground water to surface water within the Houston -

area will place demands on the Brazos-River.

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ANSWER: Population densities are too great in a 50-mile radius of the proposed Allens Creek Nuclear Generating Station.

Year 2000 population proj ections indicate increasing urbanization of counties in a 50-mile radius of the Allens Creek site.

Recommendations by the Kemeny Commission has advocated remote =~

of nuclear generating stations away from major urban siting areas (A.6 Remote Siting of New Power Plants). Urbanization in the Houston SMSA has trended north and west which could result in the unacceptability of the Allens Creek site.

Increased demands on surface water resources is a very evident trend in the Houston SMSA. Subsidence and saltwater intrusion into ground water has forced many municipalities and industry to convert from groundwater to surface water resources. r' Major watersheds north and east of Houston are substantially developed and a gradual conversion to surface water resources from ground water resources has occurred and will accelerate as e overdraft of the Gulf Coast Aquifer creates more subsidence and  !

saltwater intrusion into fresh water bearing aquifers. .

As the population increases in a 50-mile radius of the Allens ,

Creek site increased demand for fresh water will occur.

Recognizing the existing constraints on groundwater use in the Houston SMSA, it is obvious industry, municipal government and other water purveyors will have to look at surface water resources.

Forced evaporation from the proposed Allens Creek Nuclear Generating Station Unit 1 would <upply enough water for more than 200,000 persons based on 100 gped based on data supplied by Houston Lighting & Power. The sustained yield from this reservoir was not provided by the Applicant nor was there any indication that the proposed reservoir for Allens Creek Nuclear Generating Station would be an optimization of the site. Based on preliminary data, the proposed reservoir could prove to be an important water supply source. The siting and construction

- of a nuclear electric generating facility at the Allens Creek site would preclude the use of Allens Creek Reservoir as a water supply source.

. Data by the Water Resources Council indicates water use-will exceed water supply in the year 2000 in the Brazos River Basin by some 780 mgd. River basin outflow indicates a deficit of 245 mgd. This figure is based on reduced per capita water consumption rates. If this data proves to be' correct, water supply deficier.cies would affect the operation of the proposed Allens Creek Nuclear Generating Station.

The Texas Water Plan and other subsequent documents by the Texas Department of Water Resources indicate increased declines in the water level of the Gulf Coast Aquifer and a need for increased reliance on surface water supply sources. The Brazos River Basin is an obvious choice for meeting water supply needs in the Houston SMSA.

5. Have you identified any alternative coastal site where the population density is lower than the population density within the 50-mile radius surrounding the Allens Creek site? If so, produce all studies and documents relating to the lower population density site.

ANSWER: This question it inappropriate. However, the South Texas Nuclear Generating Station site is obviously superior based on current and proj ected population densities in a 50-mile radius and the opportunity to use seawater as a collant media.

Also, the environmental impact and human infrastructure impact would be lessened constructing additional units at the South Texas site-since theue is construction activities proceeding there.

6. Have you identified a specific coastal site which you assert is obviously superior to the Allens Creek site? If so, identify the exact location of this site, specify in detail the criteria used to establish its superiority, and produce all studies and documents you will rely upon to evidence its superiority.

ANSWER: This is not an appropriate que'stion.

Respectfully submitted, MA/> $]rsdw k Carro Hinderstein

' 8739 Link Terrace Houston, Texas 77025 THE STATE OF TEXAS CCUNTY CF DALLAS BEFORE E , THE UNDERSIGNED AUTHORITY, on this day personally appeared, HO'ilARD SAXICM, who upon his oath stated that he has answered the foregoing Houston Lighting and Power Company's interrogatories to Intrevenor,Carro Hinderstein, dated 3 July 1980 in his. capacity as Expert Vlitness and all statements contained herein are true and correct, 10a Ld5 Howard Saxion SUBSCRIEED AND SWORM TO BEFORE ME, by the said Howard Saxion on this eff2 day of January,1980.

k)l! 0 Notary F) blic in and for -

Dallas County, Texas AUDROf MEROLL; Nctay P' Sic Dallas Ccar; Tx.

f4 Coctissica Epitcs 12/21/S0 f?y Commission Expires

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing CARRO HINDERSTEIN'S ANSWERS TO APPLICANT'S SECOND SET OF INTER-ROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS , in the above captioned proceeding were served on the following my deposit in the United States mail, postage prepaid, this 31st day of January, 1980.  !

i Sheldon J. Wolfe, Chair J. Gregory Copeland Atomic Safety and Licensing 3000 One Shell Plaza Board Panel Houston, Texas 77002 U. S. Nuclear Regulatory Commission Jack R. Newman Washington, D. C. 20555 1025 Connecticut Ave., N.W. ..

Washington, D. C. 20036 [

Dr. E. Leonard Cheatum E Route 3, Box 350A James Scott, Jr. I Watkinsville, Georgia 30677 8302 Albacore r Gustave Linenberger ,

Atomic Safety and Licensing Brenda McCorkle Board Panel 6140 Darnell -

U. S. Nuclear Regulatory Houston, Texas 77074 Commission Washington, D. C. 20555 John Doherty .

4327 Alconbury Street Docketing and Service Section Houston, Texas 77021 Office of the Secretary of the Commission Wayne E. Rentfro Nuclear Regulatory Commission P. O. Box 1335  :

Washington, D. C. 20555 Rosenberg, Texas 77471  ;

E Richard Lowerre Assistant Attorney General .

?- the State of Texas P. O. Box 12548 Capitol Station Austin, Texas 78711 RELATED CORRESPoxyg 91 7 4

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CARRO HINDERSTEIN i_

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