ML19330A715

Response to Potthoff First Set of Interrogatories.Objects to Majority of Interrogatories on Basis of Irrelevancy. Applicant Has Not Commissioned Study on Marine Bio Farm Feasibility to Provide Synthetic Gas.W/Certificate of Svc

ML19330A715
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	07/23/1980
From:	Copeland J, Newman J HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Potthoff AFFILIATION NOT ASSIGNED
References
NUDOCS 8007290082
Download: ML19330A715 (7)

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fj USNno UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION '

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JUL 2 51980 >

Officeof theSecretary BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docketing & Sen!ce g

$ &nch CD In the Matter of S S

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

(Allens Creek Nuclear Generating S Station, Unit 1)

APPLICANT' S I3SPONSE TO POTTHOFF'S FIRST SET OF INTERROGATORIES In response to the First Set of Interrogatories propounded by Potthoff, Houston Lighting & Power Company (Applicant) answers as follows:

INTERROGATORY NO. 1: .

How does Applicant intend to get uranium fuel for ACNOS? Name all companies to be engaged, contracts signed, etc.

ANSWER:

Applicant objects that this interrogatory is not relevant to the. question of whether a biomass farm is a viable alternative to ACNGS. Nonetheless, Applicant does answer that Applicant has acquired the uranium for the initial core loed from Atlas Minerals Corporation. Appli-cant anticipates its additional uranium requirements over the life of the plant will be purchased in the open market.

INTERROGATORY NO. 2: -

Are the companies from who [ sic] Applicant intends to secure uranium fuel independent companies? Wholey-owned (sic] subsidiaries?

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ANSWER:

Applicant objects that this interrogatory is not relevant to the question of whether a biomass farm is a viable alternative to ACNGS. Nonetheless, Applicant does answer that it has no corporate relationship with Atlas Minerals Corporation.

INTERROGATORY NO. 3: .

How much does Applicant plan to spend on fuel during the lifetime of ACNGS?

ANSWER:

Applicant objects that this interrogatory is not relevant to the question of whether a biomass farm is a viable alternative to ACNGS. Nonetheless, Applicant does answer that Applicant has provided the estimated fuel costs for ACNGS in Chapter 9 of the ACNGS-ER Supplement, and in pages SH-105 through SH-122 of Appendix SH to the ACNGS-ER Supplement.

INTERROGATORY NO. 4:

By what methods will the companies engaged by Applicant mine uranium ore? At what sites will this are be mined?

ANSWER:

Applicant objects that this interrogatory is not relevant to the question of whether a biomass farm is a viable alternative to ACNGS. Nonetheless, Applicant does answer that the Atlas Minerals Corporation's uranium has already been mined. Applicant has no idea as to where uranium purchased on the open market will be mined.

INTERROGATORY NO. 5:

If the method to be used to mine ore is strip-mining, about how much area at the sites will be mined? Do the companies engaged in tend to return the site to its original state after mining? Will the companies keep all topsoil separate from other layers of soil mined?

ANSWER:

Applicant objects that this interrogatory is not relevant to the question of whether a biomass farm is a viable alternative to ACNGS. Nonetheless, Applicant does answer that the uranium purchased from Atlas Minerals has al-r'eady been mined. Applicant does not know anything about the mining plans for any uranium which it may purchase in the future.

INTERROGATORY NO. 6: --

At all sites, how much prime farm land will be displaced? Ranchland? Homes? Businesses? Industries?

ANSWER:

See answer to Interrogatory No. 5.

INTERROGATORY NO. 7: -.

At all sites, how much water will be used in mining?

Where will such water come from?

ANSWER:

See answer to Interrogatory No. 5.

INTERROGATORY NO. 8:

Has Applicant ever commissioned a study on the feasibility of a marine biofarm to supply synthetic natural gas to replace natural gas burned in existing generating plants? If so, what was the conclusion of such a study? If not, why not?

ANSWER:

Applicant has not commissioned such a study be-cause it is obvious to Applicant without any study that a marine biomass farm is not a feasible alternative to ACNGS.

Respectfully submitted,

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J' OF COUNSEL: J. rego@ - peYand C homas ddle, Jr.

BAKER & BOTTS C rles G. Thrash, Jr.

3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 1

LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.

Washington, D. C. 20036 Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY i

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STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Paul A. Horn, who upon his oath stated that he has answered the foregoing Houston Lighting & Power Company's Response to Potthoff's First Set of Interrogatories in his capacity as Project Manager for Houston Lighting &

Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.

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p b , k.%s SUBSCRIBED AND SWORN TO BEFORE ME by the said Paul A. Horn, on this of.2 W ay of M, - , 1980.

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bd 7.7) k Notary Publfd in and for Harris County, Texas DOROTHY M. CUR Notary Pub;!c, Stato cf Tc .as My Commission Expires I'/[' N I

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6 D.TEgo UNITED STATES OF AMERICA Rc i. i NUCLEAR REGULATORY COMMISSION U d, b 2 S g p' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

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In the Matter of S c31\~ l 5 l HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 '

S (Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE __ __

I hereby certify that copies of the foregoing Applicant's Response to Potthoff's First Set of Interroga-tories in the above-captioned proceeding were served on the i postage  ;

prepaid, or by hand-delivery this JJa/ day offollowing by deposit in.the United States:

1980. ( / I Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing- Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville,. Texas 77418 Mr. Gustave A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety and Licensing Mr. Chase R. Stephens Appeal Board Docketing and Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D. C. 20555 of the Commission U.S. Nuclear Regulatory Commission Steve Schinki, Esq.

Washington, D. C. 20555 Staff Counsel U.S. Nuclear Regulatory Commission Richard Lowerre, Esq. Washington, D. C. 20555 I

Assistant Attorney General for the State of Texas P. O. Box 12548 Capitol Station Austin, Texas 78711

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Mr. Bryan L. Baker D. Marrack 1118 Montrose 420 Mulberry Lane Houston, Texas 77019 Bellaire, Texas 77401 J. Morgan Bishop Brenda McCorkle 11418 Oak Spring 6140 Darnell Houston, Texas 77043 Houston,-Texas 77074 Stephen A. Doggett W. Matthew Perrenod P. O. Box 592 4070 Merrick Rosenberg, Texas 77471 Houston, Texas 77025 John F. Doherty F. H. Potthoff 4327 Alconbury 7200 Shady Villa, No. 110 Houston, Texas 77021 Houston, Texas 77055 Robert S. Framson Wayne E. Rentfro Madeline Bass Framson P. O. Box 1335 4822 Waynesboro Rosenberg, Texas 77471 Houston, Texas 77035 James M. Scott Carro Hinderstein 13935 Ivy Mount 609 Fannin, Suite 521 Sugar Land, Texas 77478 Houston, Texas 77002

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