ML19343B846

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Testimony on Behalf of Util Re Hinderstein Contention 5 Concerning Coastal Sites
ML19343B846
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 12/18/1980
From: Vansickle D
TURNER COLLIE & BRADEN, INC.
To:
Shared Package
ML19343B832 List:
References
NUDOCS 8012300723
Download: ML19343B846 (10)
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I DIRECT TESTIMONY OF -

S DONALD VANSICKLE ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY HINDERSTEIN CONTENTION 5/ COASTAL SITES l

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B012coe 793

DIRECT TESTIMONY OF DONALD VANSICKLE RE COASTAL SITES 1

Q. Please state your name and position.

A. My name is Donald VanSickle. I mn a vice presi-3 dent in the firm of Turner Collie & Braden, Inc.

4 Q. Please describe your educational background.

3 A. I received a Bachelor of Science in Civil Engineer-6 ing at the University of Texas in 1954 and a Master of 7 Science in Civil Engineering at the University ofrTexas in 3 1958. I worked as a research engineer and lecturer at the 9 University of Texas between 1954 and 1957. I left.the 10 University in 1957 and joined Turner Collie & Braden.

13 Q. Are you a Registered Professional Engineer?

12 A. Yes, I am a Registered Professional Engineer ir 13 the State of Texas. ,

14 Q. Are you a member of any professional and civic 15 organizations?

16 A. I am a member of the American Society of Civil 17 Engineers, the American Institute of Consulting Engineers, 18 the Consulting Engineers Council, the American Water Re-19 sources Association, the American Waterworks Association, 20 the American Geophysical Union, the Engineering Institute of 21 Canada, the International Association for Hydraulic Re-22 search, the Houston Engineering and Scientific Society, and 23 the Houston Chamber of Commerce. I served.as' Chairman of 24 the Houston Chamber of Commerce Flood Control Committee in zr

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1971, and in 1973 I served as Chairman of the Harris County 2

Flood Control Task Force.

3 Q. Have you published any articles?

4 A. I have published a number of articles in the area 5

of drainage design for storm runoff. I have also given 4 l

6 number of lectures to the U. S. Army Corps of Engineers con-7 cerning the effect of urban development on various components 8 I have also lectured at both of the hydrologic system.

9 Texas A & M University and the University of Houston on 10 water resource planning.

11 Q. What is yc/;r area of expertise at Turner Collie &

12 Braden?

13 A. I specialize in the areas of river basin planning, i

14 water resources planning, water quality management, drain-15 age, flood control, flood plain management, water supply 16 treatment and distribution, wastewater collection, treatment 17 and disposal, land development, coastal and estuary en-13 gineering, land reclamation and irrigation, hurricane pro-19 tection, and land subsidence.

20 Q. What is the purpose of your testimony?

21 A. My firm has been employed as a consultant to the 22 City of Houston on a continuous basis since 1964 to under-23 take comprehensive studies of the City's municipal water 24 system. The work we do for the City is an ongoing effort to

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study the City's water needs on an annual basis. I also 2

serve on a Mayor's advisory committee which has the respon-3 sibility of advising the Mayor about the City's water system 4

needs. Because of my experience with the City I am very l -

familiar with all aspects of Houston's water supply and on-6 P

going plans to assure an adequate supply for the future.

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I have been asked by Houston Lighting & Power Company to 3

testify on Hinderstein Contention No. 5 which alleges that 9 HL&P should build a plant at a coastal site rather than at 10 Allens Creek because there is expected to be a shortage of 11 fresh water in the Bra =os River basin. Mr. Saxion, Ms.

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Hinderstein's expert witness, has asserted that the cause of 13 the alleged shortage of water in the Brazos River is due to 14 the fact that the City of Houston will have to import water l

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3 from the Brazos River basin. As I will explain below, this 1

6 assertion is in error.

l 17 Q. lease describe the City's current water supply l 13 situation.

l l 19 A. The City of Houston currently obtains groundwater 20 from well fields in the Houston area and surface water from .

21 the San Jacinto River Basin and the Trinity River Basin.

22 The City's records show that average municipal use for 1979 l

23 was 341.4 million gallons per day (mgd). Approximately 40 l

1 24 percent of the water supplied to the municipal system during i

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1 1979 was treated surface 'Jater from the San Jacinto River 2 Basin (138 mgd). The remaining 60 percent (203.mgd) was 3 supplied from wells located throughout the service area.

4 Houston's groundwater is supplied by 169 wells 5 located in 10 major well fields (ranging in size from 5 to 6 11 wells), 10 secondary wc11 fields (2 to 3 wells), and 60 7 minor (1 well) fields. Two well fields, having a total of 3 8 wells, discharge directly to the distribution system.

9 Houston's surface water is supplied from three 10 reservoirs. Lake Houston and Lake Conroe, constructed 11 primarily for municipal supply, are both located in the San 12 Jacinto River Basir.. Lake Houston has 146,700 acre-feet of 13 storage occupying 12,240 acres of land with an estimated 14 firm yield of 170 mgd. The City of Houston is entitled to 14 approximately 120 mgd from Lake Houston. Lake Conroe has a 16 storage capacity of 430,260 acre-feet and an estimated firm 17 yield of 75 mgd. The City has perpetual right to two-thirds 18 of the yield, a supply of about 50 mgd. However, due to the 19 projected effects of future sedimentation, Houston's future 20 allocations of surface water from Lake Houston and Lake 21 Conroe are 108 mgd and 45 mgd, respectively.

22 The third surface water source for the City of 23 Houston -is Lake Livingston, located in the Trinity River 1

24 Basin. This reservoir has a storage capacity of 1,750,000 j

1 acre-feet, with an estimated firm yield of 1,150 mgd. The 2

City has a perpetual right to 70 percent of this yield, or a 3

dependable supply of 806 mgd.

4 The City also supplied an average of 147 mgd of un-5 treated surface water to large industrial customers. In 6

general, industrial customers now purchase untreated surface I

water from the City of Houston. The Coastal Industrial 3 Water Authority (CIWA) now operates a system of conveyance 9 and distribution facilities to provide this untreated surface 10 water from the Trinity River (Lake Livingston) to industrial 11 customers in the Houston area. By mid-1977, as industrial 12 customers began relying on the CIWA system, the City saw a 13 decrease of approximately 20 mgd in the untreated surface 14 water demand of industry on Lake Houston. This decrease has 15 provided the City with additional curface water supply for 16 municipal uses. As the CIWA system is completed and addi-17 tional industrial customers complete the transfer to CIWA,

~3 industrial use of Lake Houston water is expected to be 19 sharply reduced, further increasing the available municipal l 20 :. ater supply.

21 u. Does the City hava any present shortage in water 22 supplies?

l 23 A. No. Our studies indicate that Lakes Conroe, I 1

1 24 Houston and Livingston can supply surface water to meet the l

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1 City's projected demands through approximately the year 2000. However, the projected demands beyond the year 2000 3 indicate that the City will require additional surface water 4 supplies.

5 What are the best potential sources of future Q.

6 water supplies?

7 A. I have been studying this question for many years l 3 and it is my opinion that the most economical alternatives 9 are to import water from the existing or proposed East Texas 10 reservoirs. The existing East Texas reservoirs I am re-11 ferring to are Toledo Bend in the Sabine Basin, and Sam 12 Rayburn in the Neches Basin, which presently have surplus 13 supplies adequate to meet the projected year 2010 water 14 supply needs of the Houston Municipal Water System. Other l 15 resourses are availacle in East Texas for the years beyond 16 2010. Therefore, we have recomm?nded that the City of r

l 17 Houston turn to the major East Texas reservoirs as a source l

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20 Q. Is the Brazos River a likely source of future 21 water supply for the City?

l 22 A. No. Each time we have done a study for the City 23 we have evaluated the Brazos River Basin as a possible 24 source of supply for the City of Houston in the futura, and 1

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we have always rejected it as a potential source of water for the City.

3 Q. Would you explain why you have rejected the Brazos 4

River as a source of water for the City?

5 A. There are several reasons. The first reason is 6

that the Brazos River water is of poor quality in comparison ,

7 with the water in the San Jacinto, Trinity, Neches and 8

Sabine Rivers. The low water quality in the Brazos,is 9 attributable in large measure to upstream salt formations.-

10 This problem is pointed out in a report prepared by the 11 Texas Water Development Board in 1977, which is entitled 12 " Continuing Water Resources Planning and Development for 13 Texas." The report notes that:

14 At the present time, full utili-zation of the water resources of the 15 mainstem Brazos River is not possible because of the adverse effects of 16 natural salt pollution from sources l located within its principal upper 1 ,/ basin tributaries. The quality of

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the mainstem Brazos River water is 13 seriously degraded by emissions from major natural salt sources in the 19 upper Brazos River Basin downstream from the Caprock Escarpment. . . .

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. The location of the salt pollu-22 tion sources are such that they i adversely affect the mainstem Brazos 23 River throughout its entire length.

This is by far the most serious 24 water-quality problem in the Brazos l

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l 1 River Basin. Although the amount of water carrying dissolved minerals into the 2 main stem of the river is fairly l

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total amount of water the river empties into the Gulf of Mexico, it 4 is enough to make the water in the l _ river generally unsuitable for domestic 3

use. Also, higher quality tributory

, flows and tributary reservoir re-

  • leases become polluted as they enter

, the Brazos River.

I Id. p. II-94. The absence of a large reservoir in the l 8 r lower basin of the Brazos to average out the fluctuations 9

l in quality, and the apparent infeasibility of implementing measures to reduce salt contamination, make it unlikely I

that these quality problems can be alleviated in the near 12 future.

13 The second reason is the mast policy of the State of Texas which suggests that trans-basin diversions from 15

west to east (as would be required in exporting water from

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( the Brazos to Houston) are not likely to be permitted.

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17 Rather, such diversions will be from the water surplus 13 areas in the east to water deficient areas in the west.

19 The third reason is that construction of addi-20 l

tional reservoirs would be required to make a firm supply l 21 l available from the Brazos, the probable reservoirs being l

22 Millican and Navasota on the Navasota River. Diversion 23 directly from these reservoirs to obtain higher quality l

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water would probably not be possible since the flow is needed to provide dilution and improve the quality of run-3 off from the upper basin and such diversions would result 4

in significant deterioration of the quality of flow in the

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5 lower basin. In additien to the usual problems encountered 6

in any new reservoir construction, these reservoirs face 7

the additional constraint that lignite deposits have been 3

discovered in the reservoir areas and construction would 9 probably be delayed until the lignite is mined and the 10 surface restored.

11 In sum, we do not consider the Brazos River as a 12 potential long-range water supply source for the City of 13 Houston and have never recommended that the City look to 14 the Brazos basin for additional water supplies. To the 15 best of my knowledge, the City has never planned on the 16 Brazos as a source of supply in any of its planning efforts.

17 Q. Does this complete your testimony?

3 A. Yes.

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