ML19347B387

Affidavit Re Site Evaluation.Util Analysis Looks Only to Cost,Not to Benefit.Curriculum Vitae Encl

ML19347B387
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/30/1980
From:	Hussey J DAMES & MOORE
To:
Shared Package
ML19347B383	List: ML19347B382 ML19347B385 ML19347B386 ML19347B387 ML19347B388 ML19347B389 ML19347B390 ML19347B392 ML19347B393 ML19347B394 ML19347B396 ML19347B398
References
NUDOCS 8010140557
Download: ML19347B387 (12)

Text

C's V

UNITED STATES OF AMERICA 5

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of S

l 5

HOUSTON LIGHTING & POWER COMPANY S

Docket No. 50-466 5

(Allens Creek Nuclear Generating S

Station, Unit 1)

S j

AFFIDAVIT OF JAMES R.

HUSSEY l

I.

My name is James R.

Hussey.

A copy of my cur-riculum vitae is attached.

II.

r4 Dames & Moore has been primarily responsible for the evaluation of the Allens Creek site from the standpoint of environmental and site suitability factors.

This has 1

been a continuing responsibility dating back to 1972.

I am J

now the senior representative of Dames & Moore in charge of this continuing responsibility.

i I have been asked to review the motion for summary disposition filed by TexPirg and to comment on several points raised in the affidavit of Mr. Clarence Johnson.

As an overall comment, it must be emphasized that TexPirg's motion does not even approach a thorough environmental 01 0149

analysis.

An analysis of alternative sites must include a weighing of costs and benefits.

TexPirg's analysis looks only at the cost side of the ledger.

Additionally, TexPirg's analysis fails to put those costs in perspective by examining their relative significance.

III.

My first comment relates to land use.

As the NRC Licensing Board determined in 1975, the amount of land taken out of agricultural production would be an insignificant portion of the total amount of agricultural land available for production in ths United States.

I an unaware of any-thing which would change in this conclusion.

Subsequent to the hearings in 1975, the Soil Conservation Service (SCS) adopted new criteria for classi-fication including the " prime" and " unique" soil classifica-tions.

Because of the changes in the classification system i

there'is some difficulty in developing an' exact data base.

Nonetheless, we did provide information on the new soil classifications in the ER Supplement (pp. SH-57 to SH-61).

Using that information, and other information which they developed, the NRC Staff prepared Section S4.1.3 of the FES Supplement.

As noted by the Staff, the SCS has rated the majority of soils occurring on the ACNGS property as either

]

' prime-1 or prime-2 farmlands.

The Staff concluded that apprcximately 4,650 acres of prime-1 farmland will be in-undated by the cooling lake and associated structures, and 277 acres of prime-1 and prime-2 farmland and 89 acres of unique farmland will be affected by construction of the station and ancillary structures.

Although a detailed inventory of prime farmlands at the local, state, and n,ational levels is not yet complete, it is estimated that 16.8 million acres of prime farmland are present in Texas (ER Supp., p. SH-57).

Using this figure, the Staff concluded that the area of prime farmland which would be removed from potential agricultural produc-tion during the lifetime of the ACNGS development is ap-i proximately 0.029% of the prime farmland in the state.

There is little data available on the amount of unique farmland in the State of Texas.

The Staff also decided that since the majority of unique farmland in the Houston area is rice land they would assume that the 89 acres of unique farmland to be lost were used for rice production.

This area would represent 0.02% of the total area in Texas planted to rice in 1975.

It is clear that development of ACNGS will have an insignificant impact on the total amount of prime farmland available in Texas.

It is obvious the impact measured on a nationwide basis would be infinitesimal. -_

4 l

IV.

]

In its decision issued in 1975 the Licensing Board also determined that the present worth of the lost agri-4

)

cultural production would be $240,000.

(PID 170).

Section 1

S8.2.3.1 of the ER Supplement contains an updated analysis i

of the costs associated with taking the land out of agri-cultural production.

This analysis shows that the value of agricultural production in Austin County has actually de-creased since 1975.

Our updated analysis shows that there would have actually been a negative return on production on 1

the Allens Creek site in 1977.

This would result in a i

i calculated negative market value with respect to agricultural production.

Therefore, calculating present discounted pro-i l

ductivity in accordance with the formula presented by Mr.

t l

Johnson (described at pages 4 and 5 of his affidavit) would also result in a negative market value.

This, of course, is inappropriate.

As indicated in S8.2.3.1, the present valub of production based on 1977 calculated total fixed and variable costs is $34 million.

V.

I have also examined Mr. Johnson's analysis of the question of socio-economic impact.

It is not a true analysis because it fails to account for all of the costs and benefits from a socio-economic standpoint.

f.-

Again, this is a matter that was previously ad-dressed by the NRC Licensing Board in its decision in 1975.

When we prepared the Environmental Report Supplement in 1978 we reexamined this issue and concluded that the socio-economic impacts of the project would be lessened because of (1) a reduction in the size of the project, and (2) the employment and income effects are anticipated to be more widely diffused within the region than we originally pro-jected.

The reason for this latter change is explained in detail in Section S8.1.3 of the ER Supplement.

We concluded that no local communities would receive a sufficiently large growth stimulus to cause major new community expenditures, or to overload existing facilities.

In short, our updated analysis indicates minimal, if any, adverse socio-economic impact to the local communities.

Weighed against this is the fact that the local communities will reap substantial tax benefits (see ER Supp. Sec. S8.1.5.) and should not have to make any significant expenditure to accommodate the ACNGS work force.

Given this fact, this site would obviously compare favorably with any other site on the question of socio-economic impact.

VI.

Mr. Johnson also refers to the adverse impact of f

constructing a barge unloading facility.

This is a matter L..

I which was thoroughly investigated by Dames & Moore in a report submitted to the NRC in March 1980.

Based on'this report, it is my opinion that the construction of the barge slip will have an insignificant impact.

Whatever minor impacts may result from such construction are easily mitigated.

The impacts associated with this activity are extremely insignificant in the overall context of the project and, therefore, play a minimal role in comparison of the alterna-tive sites.

Nonetheless, it is worth bringing to the Board's attention that Mr. Johnson's unsupported assertions are completely contrary to the findings in our report:

(a)

The excavation required for construction of the barge slip is minimal.

Construction of the slip will in-j volve the excavation and dredging of approximately 15,000 i

cubic yards of clay and silty sand.

The bulk of this ex-cavation will take place in the " dry" behind the existing l

riverbank, which will be left temporarily as a construction dike.

A backhoe, clamshell, dragline and suction dredge will be used at the contractor's option for this phase of the excavation.

After excavation of the inland portion of the slip has been completed, the construction dike will be removed using a clamshell and possibly a suction dredge.

A minor amount of dredging of the riverbed will also be re-quired to connect the barge slip with the river channel.

1 I

6 m

i This will be accomplished using a clamshell and/or suction dredge working codtinuously to minimize the duration of increased turbidity levels in the water.

The San Bernard River is a Corps of Engineers navigation project to a point l

just upstream from the proposed barge location.

The channel is maintained at a depth of 9 feet for a width of 100 feet.

l The natural channel slopes to the dredge channel from the i

bank.

l (b)

The creation of a " pit" to dispose of excavation material is an appropriate construction procedure to minimize environmental impacts.

It is presently planned for all ex-i cavated materials to be stored at the site adjacent to the i

barge slip.

Dry materials excavated from above the water table will be used to form the walls of sediment ponds, which in turn will be used for storage of all saturated materials.

Water removed from the slip area during con-struction or restoration will not be allowed to flow di-rectly into the river, but will be pumped into a sediment l

I pond.

This sediment pond, incorporating an appropriate wier structure, will be used to achieve removal of most suspended solids.

t (c)

There is no " wetland habitat" affected by the barge slip.

The construction of the barge slip and re-storation of this area will cause a temporary localized - -

O C

increase in the turbidity of the San Bernard River at this location.

Some turbidity vill occur during dredging at the entrance of the barge slip, to a lesser degree during con-struction of the slip, and later when the slip is restored by the replacement of fill soils.

At the time of initial excavation, the duration of increased turbidity will be minimized by maintaining a dike at the riverbank, between onland excavation and the river.

Increased turbidity in the river would only occur during the latter stages of exca-vation when the dike is removed and the channel is dredged between the barge slip and the river channel.

The area to be excavated for the barge slip is a zone of deposition.

Consequently, the combination of de-posited materials and reduced river current could make this a desirable habitat for spawning some fish and nursery for other juvenile fishes.

A small portion of this habitat would be temporarily removed by dredging the barge channel to the existing navigation channel.

The length of river directly affected is expected to be about 200 to 300 feet on one side, or less than 0.10 percent of the estimated 50 to 75 miles of similar habitat.

When compared to the total habitat of the San Bernard River, the impact is considered insignificant.

The area should rehabilitate naturally within 3 to 5 years after abandonment.

e (d)

Overland transport of the reactor vessel will have an insignificant impact.

Traversing the overland portion of the route will involve crossing a number of creeks.

Most of the bridges or culverts which presently span these creeks can be matted and/or shored and used to support the loaded transporter.

However, the concrete bridge on State Highway 36 which crosses Varner Creek cannot be satisfactorily shored and consequently must be bypassed.

This will require the construction of a short, temporary bypass road and s

culvert beside the existing bridge.

The bypass required at the Varner Creek bridge on Highway 36 will result in a temporary disturbance of ap-proximately 0.9 acres of land.

An additional area of ap-prcximately 0.4 acres may be disturbed as work space adja-cent to the temporary road bed.

This impact is insignif-i icant..-

Curriculum Vitae J AM ES R.

HUSSEY Title Partner Expertise Geotechnical Engineering and Project Management Experience Project Manager With Firm

. Several petroleum industry projects in Iran, including evaluation and monitoring of preloading of a tani farm for LPG facilities, a foundation investigation for a refinery, and innstigation for tank farm and jetty in Persian Gulf area.

• Studies of several alternate sites for petroleum handling facilities in northeastern U.S.

• Comprehensive foundation investigation for a fertilizer complex in Indonesia.

• Major foundation investigation for petrochemical complex in Louisiana.

• Comprehensive site evaluation for proposed Allens Creek Nuclear Generating Station in Texas. Directed and coordinated efforts of multidiscipline project team, including specialists in engineering geology, seismology, foundation engineering, hydrology, meteorology, demography, and land use. Responsi-bilities included: preparation of site characteristics chapter of Preliminary Safety Analysis Report and supplement to the environmental report:

submittal of responses to review questions posed by AEC.

• Managed preparation of revised biological and radiological monitoring programs for final environmental report and development of environmental technical specifications for South Texas Nuclear Project.

• Preparation of environmental report for offshore, crude oil unloading, monobuoy system, including supervision of multidiscipline team of ir.vestigators in field of biology, geology, land use and population studies, and hydrology.

~

• Assessment of site characteristics for nuclear power plant proposed in Iran, involving detailed site evaluations and comprehensive geotechnical and hydrological studies. Coordinated activities of over 100 professionals working from several offices in different countries.

• Prepared detailed scope, initiated project planning for site validation studies for proposed nuclear power plant near Isfahan, Iran.

• Detailed investigations in the areas of geotechnical evaluation, flooding

• studies, and development of ground water sources for large manufacturing / community complex in Iran.

Participant in two major studies pertaining to development of tidelands in San Francisco Bay area Major participation in the design and development of a job reporting system for Dames & Moore Dames & Moore

2 Academic B.S. and M.S. in civil engineering (majoring in soil mechanics), University of

Background

California, Berkeley Profesional Av..rican Society of Civil Engineers; International Society of Soil Mechanics and Affiliations Foundation Engineers; Atomic Industrial Forum; American Nuclear Society Registration Professional engineer, California and Texas s

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3EFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S

S HOUSTON LIGHTING & POWER COMPANY S

Docket No. 50-466 5

(Allens Creek Nuclear Generating 5

Station, Unit 1)

S AFFIDAVIT OF JAMES R. HUSSEY l

STATE OF TEXAS S

S COUNTY OF HARRIS S

I, James R.

Hussey, first being duly sworn, upon my oath certify that I have reviewed and am thoroughly i

familiar with the statements contained in the attached 1

affidavit and that all my statements. contained therein are true and correct to the best of my knowledge and belief.

h se " ' _,'

JaAes R. Hussey#

Subscribed and sworn to befo e me by the said Hussey on this.3tht/., day of MM 1980.

James R.

' W AJ CA /nl Najary Public in and for Harris County, Texas l

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