ML19347B388
| ML19347B388 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 09/29/1980 |
| From: | Vansickle D TURNER COLLIE & BRADEN, INC. |
| To: | |
| Shared Package | |
| ML19347B383 | List: |
| References | |
| NUDOCS 8010140566 | |
| Download: ML19347B388 (44) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE 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 DONALD VANSICKLE My name is Donald VanSickle.
I am a vice president in the firm of Turner Collie & Braden, Inc.
A copy of my curriculum vitae is attachad.
My firm has been employed as a consultant to the City of Houston at various times since 1964 to undertake comprehensive studies of the City's municipal water system.
The most recent study was completed in January, 1980.
The City of Houston currently obtains grcundwater from well fields in the Houston area and surface water from the San Jacinto River Basin and the Trinity River Basin.
t The City's records show that average municipal use for 1979 was 341.4 million gallons per day (mgd).
Appro::imately 40 percent of the water supplied to the municipal system during 1979 was treated surface water from the San Jacinto River Basin (138 mgd).
The remaining 60 percent (203 mgd) was sapplied from wells located throughout the service area.
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Houston's groundwater is supplied by 169 wells located in 10 major well fields (ranging in size from 5 to 11 wells), 10 secondary well fields (2 to 3 wells), and 60 minor (1 well) fields.
Two well fields, having a total of, l
3 wells, discharge directly to the distribution system.
l Houston's surface water is supplied from three reservoirs.
Lake Houston and Lake Conroe, constructed l
l primarily for municipal supply, are both located in the San l
Jacinto River Basin.
Lake Houston has 146,700 acre-feet of
(
storage occupying 12,240 acres of land with an estimated i
firm yield of 170 mgd.
The City of Houston is entitled to approximately 120 mgd from Lake Houston.
Lake Conroe has a storage capacity of 430,260 acre-feet and an estimated firm yield of 75 mgd.
The City has perpetual right to two-thirds of the yield, a supply of about 50 mgd.
However, due to the l
projected effects of future sedimentation, Houston's future allocations of surface water from Lake Houston and Lake Conroe are 108 mgd and 45 mgd, respectively.
The third surface water source for the City of Houston is Lake Livingston, located in the Trinity River Basin.
This reservoir has a storage capacity of 1,750,000 acre-feet, with an estimated firm yield of 1,150 mgd.
The City has a perpetual right to 70 percent of this yield, or l
l a dependable supply of 806 mgd.
The City also supplied an average of 147 mgd of untreated surface water to large industrial customers.
In general, industrial customers now purchase untreated surface water from the City of Houston.
The Coastal Industrial Water Authority (CIWA) now operates a systam of conveyance and distribution facilities to provide this untreated surface water from the Trinity River (Lake 1/
~
1 Livingston) to industrial customers in the Houston area.
In 1968, the Texas Legislature created CIWA as a conservation and reclamation district.
CIWA was invested with powers to transport and deliver water, to acquire and construct facilities necessary for such purposes, and to issue revenue bonds supported by water conveyance contracts.
The. Authority and the City entered into a contract in 1968 (amended in 1977), authorizing CIWA to finance and construct facilities to transport untreated water from the Trinity River to the Houston area, in return for payments from the
' City from gross revenues of its water system.
In 1976, CIWA substantially completed construction of conveyance and distribution facilities discussed previ-ously.
Although the City was originally responsible for the 1/
CIWA was one of two governuent: 1 agencies created to combat subsidence problems.
,s a result of the CIWA system, groundwater levels in the southern half of Harris County have increased 20 to 50 feet and this rebound is expected to continue.
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4 4
operation and maintenance of the Trinity River conveyance system pursuant to an operating agreement with CIWA, the i
agreement was terminated by mutual consent in August, 1977, allowing CIWA to oversee all aspects of the project.
By mid-1977, as industrial customers began relying j
on the CIWA system, the City saw a decrease of approximately 20 mgd in the untreated surface water demand of industry on Lake Houston.
This decrease has provided the City with i
additional surface water supply for municipal uses.
As the CIWA system is completed and additional industrial customers 1
~
finalize the transfer to CIWA, industrial use of Lake Houston water is expected to be sharply reduced, further increasing i
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the available municipal raw water supply.
Our studies indicate that Lakes Conroe, Houston i
and Livingston can supply surface water to meet the City's projected demands through approximately the year 2000.
i This conclusion is primarily a result of the fact that previously Lake Livingston water was intended for i
industrial use only; however, due to decreased industrial demand water should also be available for domestic use, enabling the existing reservoirs to meet projected demands i
to almost the year 2000.
However, since no new reservoirs seem to be economically justifiable at the present time within the San Jacinto Basin projected demands beyond the I
l
_4_
year 2000 will require additional surface water supplies.
l Our analyses indicate that it would be more economical to turn directly to existing or proposed East Texas reservoirs i
for additional surface water supplies.
The East Texas reservoirs investigated are Toledo 1
I Bend in the Sabine Basin, and Sam Rayburn and Rockland in the Neches Basin.
The nearest to Houston of these reservoirs is Rockland Reservoir, which has been proposed for some time but never constructed.
If constructed, the reservoir would have a firm yield of approximately 600 mgd.
Houston could 1
presumably obtain 70 to 75 percent of this yield--420 to 450 mdg--by participating in its construction, thereby meeting l
or very nearly meeting the Municipal Water System needs of the City through the year 2010.
The rapidly increasing cost of any new reservoirs, as well as the growing environmental 1
opposition to such new facilities, makes reliance on Rockland Re~servoir for long-term supply somewhat questionable.
From a review of data presented in the Texas Water Plan it appears that a significant amount of surplus presently exists in the Neches River Basin.
By the year 2000, approx-imately 440 mgd are projected to be surplus.
Based on needs increasing within the basin, surplus is expected to decline to 356 mgd by the year 2010.
The major source of supply in this 1
i basin-is Sam Rayburn Reservoir.
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Toledo Bend Reservoir, located on the Texas-Louisiana border, is the most distant of the East Texas reservoirs.
This reservoir is the major source of supply in the Sabine River Basin.
Approximately 780 mgd are projected in the i
Texas Water Plan to be surplus to the Sabine Basin in the j
year 2010.
It therefore appears that both of the existing i
East Texas reservoirs, Sam Rayburn and Toledo Bend, presently have surplus supplies adequate to meet the projected year 2010 water supply needs of the Municipal Water System.
Therefore, it is recommended that the City of Houston turn to the major East Texas reservoirs as a source of supply for the Municipal Water System beyond the year 2000.
Use of the Brazos River Basin has been investigated on a number of occasions as a possible source of supply for the City of Houston.in the future, but has always been i
rejected for a number of reasons.
Among these are:
1.
Relatively poor quality of the Brazos River water in comparison with the relatively high quality of 4
the San Jacinto, Trinity, Neches and Sabine.
This lower quality is attributable in large measure to upstream salt' formations.
The absence of a large reservoir in the lower basin to average out the fluctuations in quality, and the apparent in-4
. feasibility of implamenting measures to reduce I
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salt contamination, make it unlikely that these quality problems can be alleviated in the near future.
2.
Past policy of the State of Texas indicates that trans-basin diversions from west to east are not liekly to be permitted, and that such diversions will be from the water surplus areas in the east, to water deficient areas in the west.
3.
Construction of additional reservoirs would be required to make a firm supply available, the
~
probable reservoirs being Millican and Navasota 4
on the Navasota River.
Diversion directly from these reservoirs to obtain higher quality water would probably not be possible since the flow is
.d needed to provide dilution and improve the quality of run-off from the. upper basin and such diversions would result in significant deterioration of the 4
quality of flow in the lower basin.
4.
In addition to the usual problems encountered in any new reservoir construction, these reservoirs face the additional constraint that lignite de-posits have been discovered in the reservoir areas and construction would probably be delayed until the lignite is mined and the surface restored..
Because of these and other problems, we do not consider the Brazos River as a potential long-range water supply source for the City of Houston and have never recommended that the City look to the Brazos basin for additional water supplies.
To the best of my knowledge, the City has never considered the Brazos as a source of supply in any of its planning efforts.
Donald R.VanSickle Senior Vice President Technical Services Rf. -
M Education Effects of Watershed Changes on Streamflow, University Bachelor of Science in of Texas,1969.
e*-
C Civil Engineei,ng, University of Texas at Representative Papers Austin,1954; Master of
" Urbanization of Houston and Its Effect upon Stormwater Science in Civil Engineer-Drainage," winner of the ASCE Daniel W. Mead Prize, ing,1958.
Texas Section and Houston Branch,1958. "Eftects of Urcan Development on Storm Runoff," winner of the Registration ASCE Award for Meritorious Technical Paper,1962, Texas No.17121; published in The Texas Engineer,1962. "E vperience with Ontario, Canada.
Evaluation of Urban Effects for Drainage Oesign," pub-lished in The Effects of Watershed Changes on Streamfic.v.
Professional Affiliations University of Texas,1969.
American Society of Civil Engineers; American Institute of Consulting Engineers; Consulting Engineers Council; Ameri-Representative Lectures can Water Resources Association: American Water Works U.S. Artny Corps of Engineers - Donald VanSickle has Association; American Geophysical Union; Engineering in-been and continues to be a guest lecturer for the U.S. Army j
stitute of Canada; international Association for Hydraulic Corps of Engineers at its Hydrologic Engineering Center, J
Research; Houston Engineering and Scientific Society:
Davis, California, for training courses in Urban Hydrology.
Houston Charrber of Commerce.
Effects of Urbanization on the Hydrologic System -
Effect of urban development on the various compori n *s of Duties and Activities the hydrologic system; definition of terminology used M Develops and directs technical operations of the profession-describing urban systems; types of drainage systems; over-al services of the firm in the field of planning, particularly view of hydrologic and hydraulic differences between in the areas of water resources, environmental controls, natural and urban watersheds; dual drainage system con-traffic and transportation systems, economics systems.
cept; and pervious versus impervious area.
and other special study areas.
Elfects of Urbanization on the Volume, Peak and Timing of Runoff-Analysis of quantity of runoff in urban areas; Experience identification of the most influential components in urban Member of the firm since 1957, and principal since 1968.
systems with respect to volume, peak, and timing of flow; Resoonsible for planning studies in water resources; water review of results of previous studies.
quality management; drainage; flood control; flood plain Texas A&M University - Guest lecturer, Feeruary,1968.
management; water supply, treatment, and distribution; Training course in Water Quality Aspects of Water Resource i
wastewater collection, treatment, and discosal; land devel-Planning.
opment; coastal and estuary engineering; land reclamation University of Houston - Seminar guest lecturer, January, j
and irrigation; hurricane protection; land subsidence; 1971. Water Resources Planning for the Houston-Galveston regional sewer systems; and river basin planning. Directed Region.
feasibility studies, master planning, and preliminary design planning for a broad variety of projects.
Other Professional Activities Chairman, Harris County Flood Control Task Force,1973.
Served as research engineer and lecturer at the University Chairman, Houston Chamber of Commerce Flood Control of Texas at Austin for three years pr;or to joining the firm.
Committee,1971.
Publications Representative Assignments "The Effects of Urban Development on Storm Runoff,"
Donald R. VanSickle is a nationally recognized authority The Texas Engineer,1962: " Interior Drainage for Hurri-in the field of hydrology, drainage and flood control. All cane Protection Projects." Proceedings ASCE, Journal of company assignments in hydraulics / hydrology have been the Hydraulics Division, March,1968; " Experience with accomplisned under VanSickle's direct supervision er were Evaluation of Urban Effects for Drainage Design,"in The heavily dependent upon his consulting expertise.
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UNITED STATES OF AMERICA MUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear Generating S
Station, Unit 1)
S AFFIDAVIT OF DONALD VANSICKLE STATE OF TEXAS S
S COUNTY OF HARRIS S
I, Donald VanSickle, first being duly sworn, upon my oath certify that I have reviewed and am thoroughly familiar with the statements contained in the attached 4
affidavit and that all my statements contained therein are j
true and correct to the best of my knowledge and belief.
j l'
Donald VanSickle Subscribed and sworn to bef *e me by the said-Donald Vansickle on this6L41A, day of W
1980.
NM.ary Public in and for Harris County, Texas
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1 JOHNSON DEPOSITION OF December 18, 1979
t 4
e 1
CLARENCE JOHNSON
'1' 2
was called as a witness by the respondents and, 3
being first duly sworn, testified as follows:
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DIRECT EXAMINATION QUESTIONS BY MR. COPELAND:
-p 6
4 Could you state your name for the record, l
9 7
please?
l l
8 A
My name is Clarence Lee Johnson.
9 4
All right, Mr. Johnson, could you please r-10 provide us with your current address?
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11 A
7368 Fairway, Houston, 77017.
12 4
All right, sir, and what is your present
]f 13 job?
14 A
I am Executive Director of the Texas Public 15 Research Group.
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16 G
Is that a paid position?
l'7-A Yes.
18 g
Do you have any other jobs?
l 1
19 A.
No.
l 20 G
'All right, sir, and how long have held that l
21 position?
h 22 A
Well, somewhat intermittently for about t
1 23 two years.
I A
l 24 G
Mow, could you give ne your educational i
f 25 background, beginning with the time that l
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h 1
you got out of high school?
~
2 A
I received a Bachelor of Science in Political 3
Schience, University of Houston.
S G
What year did you get your degree?
3 A
It was 1975, I believe.
6 G
Did you take any post-graduate courses?
~
7 A
Yes, I have taken approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> B
in the graduate program of open studies.
9 I'm scheduled to receive my Master of 10 Arts in Urban Studies from the University 11 of Houston in the spring.
12 G
Okay, what courses have you taken in your 13 graduate work?
14 A
It's
~
15 G
Just in general terns.
16 A
It's primarily an inter-disciplinary 17 social science program.
The emphasis is 18 on economics.
I have taken courses in 5
19 urban economics,'and public finance, and 20 microeconomics, and some geography, urban 21 spacia'l relations, some architecture, land-L 22 use planning.
That's'the general kind of F-L 23 background.
5 24 G
Your courses in economics, dre they '. aught L
23 from the School of Economics?
i i
i P
I
7-1 A
Yes, in fact, the head of the graduate 2
program, Louis Stern, is professor of ll 3
economics in the economic department.
4 G
Your economics courses include, for example, in urban studies, do you include 5
l 6
mathematical models in your course studies?
~
7 A
Yes, to some degree.
8 4
Eave you taken courses in mathematical 9
computation in the field of economics?
(C 10 A
Mot other than in undergraduate level B
i 11 I took a microeconomics course that l-o.ll 12 included some mathematical theory.
C 13 I've taken graduate statistics courses la in the pol.itical science department.
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13 4
okay, have you done any computer modelling I'"
16 in the field of economics?
17 A
No.
18 G
All right, after you graduated from the 1
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19 University of Houston.in 1975., did you I
20
' continue going to schcoL at that time or 21 did you get a j o b.,
or what happened there?
22 A
I got a job, I was a news reporter for 23 the Daily Sun in Texas City, and I was i
24 also later a news reporter for the New g
25 citizen in clear Lake..
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7 1
4 All right, and how long were you a 1
2 reporter?
ll 3
A well, I began =y reporting on a part-time 4
basis for the Daily Sun, well, I was still 5
an undergraduate, and all in all, something
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in the o=de= of lixe th=ee ree=e es e reporter.
8 G
All right, and that was from 19 9
beginning when?
r 10 A
From about '73 to about
'76.
11 G
All right, and some time during 1976, s
12 you ceased being a reporter?
13 A
Yes, and I took a position as staff person 14 with TexPIRG, my title was Research 15 Coordinator, and then within about two o
16 years or about a year and a half, our g
17 Executive Director resigned and I was 18 promoted into her position.
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19 G
Okay, so other than your employmen as l
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20 a news reporter, your only employment il 21 since graduating.from college has been
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j 22 through TexPIRG?
I l-23 A
Yes, other than in this past spring and 24 early part of this summer, took a leave 25 of absence from TexP'IRG and I was employed l
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as a legislative coordinator for Texas Consumer' Association.
2 3
4 And was that a paid position?
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4 A
Yes.
I think you said, as 5
o oc you currently 6
I understood it, you don't hold any jobs 7
right now other than Executive Director S
of TexPIRG?
v g
A No, I don't hold any other jobs.
10 4
Now, just as a preliminary matter today, 11 we are going to get into a lot of very g
12 technical areas and I want to make it 5
l 13 clear to you that if you don't understand 1
14 the question I am asking you, I want you g
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l 15 to please stop me and tell me that, and
!l 16 tell me you don't understand the' question.
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1 17 A.
Okay.
1 18 4
And I'll try my best to rephrase it.
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19 secondly, don't try to anticipate m
20 my question and answer it before I complete
,E 21 it.
If you would just let me finish my ll-22 question and I'll try'my best to let you l
23 finish your answers.
That way the trans-24 cript will come out much clearer, and be 25 much easier on the court reporter today.
M-____ _
l 1
unit there, but if that were the case, 2
you are correct, it would.
3 4
well, have you done any analysis to 4
determine whether the local community l
3 in South Texas could, in' fact, absorb 6
additional construction workers?
7 A
. No, I haven't.
8 4
All right.
1 9
A But I guess my point is is that there 10 is -- that my contention is is that if 11 more likeLy that it would just be the 12 work force that's there continually.
13 4
That's your position?
14 A
Yes.
13 2
And do you recognize that if the site
-l 1
16
-- if this unit were moved to the South 1
17 Texas site, there would be a loss of 2
13 revenue to'the community at the Allen's 19 Creek site?
20 A
I think that's true.
21 0
And that would be something that would 22 have to offset whatever adverse effects 23 were there from the presence of the work 24 force?
2:
A I'm not certain I follow that.
What i s' l
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1 the board didn't refer to that analysis.
I 2
MR. NEMMAN:
Are you aware 3
that the Appeal Board has affirmed 4
that decision?
5 A
Yes.
f 6
QUESTIONS SY MR. COPELAND:
7 4
Well, as of right now, though, you cannot
)
8 say that there will be insufficient crop 9
land available to meet projected agri-10 cultural needs in the United States 11 through the year 2020?
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)
12 A-As far as I know.
f 13 4
All right, sir.
{
f 14 A
I mean, I don't have any other documents r
15 at the present time to indicate otherwise.
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16 4
You say in this same paragraph that 17 Allen's Creek, the construction of the t
18 pond, will result in the destruction of i
19 8.5 miles of spawning area for aquatic i,
I 20 life.
How can that be?
21 A
Secause I took that statement out of 22 the Environmental Report.
23 4
What is the effect of that, is it relevant?
f i
24 A
Well, if there is a, loss of spawning 25 area for the acuatic life, and if our i
i id
ml 228 1
deal with the Brazos River availability.
2 O
Other than what's in the State of Texas' 1
3 answers to interrogatory, do you know of i
i 4
any document?
i i
i I
g A
No, and I as I mentioned, subsidence j !
i l 4
6
-- I don't know if I mentioned here or
[,
7 not, the Subsidence District is doing a 8
study right now on subsidence as it g
relates to the various river basin 10 water availability, and it is not 11 completed yet, but I will be keeping 12 in check with them to see if I can get 13 it as so6n as it's ready.
i 14 G
Okay, let'.s go to your contention on 15 the barge.
l 16 MR. NEWMAN:
Before we leave 17 that,~could I just ask a few la questions?
19 MR.'COPELAND:
Yes, sir, please 20 do.
21 QUESTIONS BY MR. NFWMAN:
1 i
l 22 G
Just sort of a general wrap-up.
Has
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23 TexPIRG performed or relied on any studies 24 which support the allegation that the 25 S.T.P.
site is an obviously superior l,
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alternative to the Allen's Creek site?
l i
2 A
We have not performed any studies.
The H;
h 3
only studies I know of that compare in 1
l l
4 terms of using the word, " obvious super.-
l 5
iority", of the two sites is the N.R.C.
6 study.
! (
l 7
4 Is that the docu' ment that you are relying
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upon?
1 9
A We've relied upon the N.R.C.
study for a 10 great deal of our information, but they
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11 did not conclude that.
l
)
12 G
Do you mean the F.E.S.?
l 13 A
Yes.
t 14 0
Yes, now, -in answer to an interrogatory 15 that was transmitted to TexPIRG in March l
16 on 1979, you were asked-to state whether
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l 17 you have performed or
-a'4ad upon any l l f
18 studies which support the allegation that i
19 the South Texas Project-~ site is an obviously l
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20 superior site to Allen's Creek and the
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21 subal, legations thereto, and produce any a
22 such study, and the answer was yes, you 23 have them.
I guess we need an identification, h i, 24 then, of the studies which you are l
t 25 referring to.
230 A
Well, it's basically pointing out the 1
2 fact that we're using, to a great 3
extent, relying on the information in 4
the Final Environmental Statement.
5 g
Is that the study that your answers 6
refers to, then?
7 A
Yes, that and the Environmental Report, 8.
information in the Environmental Report.
l I
g MR. NEWMAN:
Thank you.
s 10 QUESTIONS SY MR. COPELAND:
11 g
Do you have your contention before you 12 on the barge issue?
]
~
13 A
I d n't think I do.
[
la G
All right,. see if I can 15 A
Yes, I do.
16 g
All right, do you have your further 17 answers to interrogatories before you?
18 A
Yes.
19 G
Answer to 31-a, you set forth some.assump-i 20 tions about the length, width, of the B
,1 21 vessel, and how much it would weigh when t
f 22 it's fully loaded.
Where did you get 23 those numbers?
i i
24 A
I believe it was H.L.&P.
response to i
^
l 25 Einderstein's interrogatories.
l l
l h,
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269 1
extent that it's true, you can mitigage g
or can't mitigate it, I think that has 3
their effect.
4 4
Let's go back to this question, then, 5
about the uniqueness of this land.
Is 6
there any unique habitat here for any-7 thing that you know of, on the Allen's 8
Creek site, a n'; animals that 9
A I don't know, it's not 'unicue, but'I 10 don't think uniqueness is necessarily 11 a criteria.
12 G
Assuming that there is some displace-13 ment of terrestrial organisms, is it 14 TexPIRG's position that those organisms 15 cannot relocate somewhere else?
16 A
Well, I presume a number of them could.
17 I presume a number of them would be 18 flooded.
19 G
Like what?
~
20 A
'Well, just depends on how fast they can 21 move.
I don't know.
I guess -- see, 22 what did I say here in terms of the
'23 organisms?
24 0
Let's talk about that.
You talk about f
25 raccoons, deer, rabbits, squirrels, i
._J
270 1
gophers, armadillos, and opossums.
Is 2
there any unique habitat for any of those 3
animals?
4 A
It's not unique, I'll agree with that.
5 It's not a unique habitat.
There's a 6
lot of habitat like that on the Gulf 7
Coast.
8 G
Do you'know if any of those animals 9
that are an endangered species?
10 A
Mo, there is none that are endangered 11 species here.
12 4
And do you know of any of them that 13 would become endangered by the elimina-14 tion of this habitat?
15 A
No.
16 G
Okay.
Let's go off the record ~.
17 1
l 18 (Discussion had off the record.)
~
19 20 0
All right, so you would-agree, then, if 21 we are correct in terms-of what the 22 recreational benefits'would be at the 23
- Allen's Creek lake that that would weigh 24 heavily in favor of the-Allen's Creek 25 site in comparison to the south Texas l
i i
a 271 1
site?
2 A
Yes.
3 0
All right, and would you further agree 1
4 that if we're wrong that there is still.
~.
5 some doubt as to whether'that would be n
6 the determinant factor in the comparison S
7 between South Texas and Allen's Creek as P
8 alternate sites?
9 A
Yes.
i E
10 4
All right, now, let's talk about algae l
11 growth.
Is it your position that algae H
12 growth is going to affect the recreational 13 use of the lake?
14 A
Yes.
15 G
What is the source of that concern?
16 A
Well, first of all, the impact state-17 ment states that algae growth is likely 1
18 to occur.
j.
19 G
All right, anything else?
20 A
Well, none other than.just a general 21 knowledge that combinations of temperature h
22 and organic material,.such as that from 23 the sewage discharge, and just organic 24 material in the lake, the organisms that 25 are there, promote algae growth.
l t
d h
SAXION DEPOSITION OF February 14, 1980 l
wm i
=
11
- I 1
A.
- Yes, I am.
2 Q.
So you haven't reached a final 3
conclusion yet?
l.
4 A.
I have reached a final conclusion on the 5
well, on this particular topic I have pretty much l
6 completed my research.
I have reached 7
conclusions.
j-I 8
Q.
What is your conclusion?
i j.
9 A.
That the use of Allen's Creek for a 10 cooling reservoir for the proposed nuclear 11 generating station may preclude the opportunity 12 to use water in the Allen's Creek Basin as well 13 as portions of the Brazos River Basin for needed 14 municipal water supply sources.
15 Q.
Have you identified any municipal water 16 supply source that may go unserved?
I'm sorry.
1.7 Have you identified any particular municipality 18 whose water, whose availability of water from the 19 Brazos may be impacted by this plant?
i I
20 A.
Not in the Brazos River Basin is there 21 any community that would be probably impacted by 22 this plant per se.
The real question is the 23 Houston S.M.S.A.
and the large population there.
24 Q.
I understand then it's your position 1
25 that there are no municipalities within the
1 Brazos River Basin itself that you are concerned 2
- about, rather you are concerned th a t this may be 3
a supply of water for the Houston area, Houston 4
S.M.S.A.?
5 A.
To qualify that, I wouldn't say the 6
entire Brazos River Basin, but in the project 7
area, proposed project area, I really don't have 8
any concerns that the siting of this power plant 9
would preclude the opportunity to use water 10 supply sources.
The critical question is outside 11 the sources'.
~
12 As I stated earlier in some of my 13 studies that I have been doing which are 14 associated with my employer, the mid-basin area 15 of the Brazos is in a rather severe problem right 16 now because of mining of ground water so, you 17 know, there may be an opportunity for more 18 diversions upstream of the proposed site.
19 Q.
But you haven't reached any conclusion 20 on that?
21 A.
No, I haven't, not except the fact that 22 there is a water supply p r o.b l e m.
23 Q.
In the mid-basin?
24 A.
In the mid-basin.
25 Q.
Are you familiar with th e total amount i
~_-
i that indicated that the South Texas project site 2
would be suitable.
3 Q.
Have you read the environmental impact 4
statement for the Allen's Creek project?
5 A.
Would you show me the title?
6
.Q.
This is the one that 7
A.
I have excerpts out of it.
I do not 8
have the entire document, although I have read 9
the final ER supplement.
10 Q.
All right.
Have you read Section 5.2 of 11 the November 1974 F.E.S.?
12 A.
I have to look at that page.
13 Q.
All right.
14 A.
- Yes, I have read that section.
15 Q.
All right.
Have you concluded that that 16 section is in error?
17 A.
Yes.
18 ~
Q.
Can you specify how it is in error?
19 A.
Let me see the document again.
20 Q.
Okay.
21 A.
I have on my work notes those areas that 22 I disagree with.
23 Q.
- Okay, 24 A.
Are you specifically citing 5.21 or just 25 the entire section?
51 1
Q.
Well, I was thinking about 5.21 at this 2
time.
3 A.
- Well, this is basic flow data and I 4
retract my earlier statement.
I do not have any 5
disagreement with 5. gl.
6 Q.
All right.
Where is your area of 7
disagreement within Chapter 57 8
A.
Well, one of my areas of disagreement is 9
thermal stratification of the reservoir.
f 10 Q.
I'm talking now about limiting the 11 nuestion to the water supply issue.
12 A.
To water supply?
13 Q.
To tn e _.ex te n t that you have any 14 disagreement with that analysis, that is c'rrect?
I 15 reflected in your notes; is that o
\\L 16 A.
Looking at the section on background 17 data on water quantity and quality, I don't have 18 any basic disagree;ent with it.
19 Q.
Okay.
Let me see that.
On Page 5.2, 20 the next to the last paragraph of Section 5.21, 21 it states th a t the B.R.A.
has assured the 22 applicant of adequate water supply.
In addition, 23 studies by the applicant show that an adequate 24 water supply would have been available during the 25 severest drought on record.
I take it then that
58 O
1 adequate water in the Gulf Coastal Aquifer in-2 land from the coast 50 to 60 miles, which I guess 3
is about the approximate location of Allen's 4
Creek.
5 Q.
Page 28 of Miss H i n d e r s t e i.n ' s deposition, 6
and I'll show this to you, she said as far as she 7
was aware, that while there was a great demand C
for water in the Houston area, the projections as 9
to where the water would come from are all to the 10 east and northeast of Houston.
I'll let you take 11 a look at that.
I paraphrased what she said.
12 A.
I haven't read her entire deposition and 13 I really don't know what context this is taken 14 out of, but 15 Q.
Taking that in any context, is it 16 basically your understanding that as of right now 17 all of the projections as to additional water-18 supplies from Houston are assuming that that the 19 water will come from the east or northeast of 20 Houston?
21 A.
Well, projections by who?
The City of 22 Houston?
23 Q.
Well, by anybody?
i 24 A.
Well, as I stated earlier, the i
25 Department of Water Resources has looked at l
syr t
I 1
potential water resources development in the 2
Brazos River Basin and there is an indication 3
that if water supplies are available in the 4-Brazos, that they could be used for tiouston.
5 I am aware that the City of Houston 6
is primarily looking east and northeast to the 7
Trinity River Basin.
8 Q.
All right.
Other than that one study, 9
do you know of any other possible studies or 10 projections concerning the possibility of using 11 the Brazos River water in Houston?
12 A.
Well, the Presidential Commission Report i
13 which I can give you the citation for.
l 14 Q.
All right.
I wish you would.
15 MR.
COPELAND:
Could we take abcut 16 a two minute break to talk with th e se gentlemen 17 here?
18 19 (Short recess.)
20 21 Q.
(By Mr. Copeland)
Continuing with this specific 22 contention, have ou identified a 23 coastal site which you contend is superior to the 2,4 Allen's Creek site?
25 A.
Well, I contend that the South Texas
w-- - -
60 1
project site is superior to Allen's Creek.
2 Q.
You consider that a coastal site?
3 A.
Yes.
4 Q.
All right.
So it is your position then 5
that if the Allen's Creek unit were to be moved 6
to the South Texas project site, that salt water 7
would be the source of cooling for the third site?
8 A.
Well, the use of sea water is a 9
potential coolant media for a third unit at South 10 Texas.
11 Q.
And how would that be accomplished?
I'm not an engineer, 12 A.
Well, one would 13 but basically as far as I know two large diameter 14 pipeline; would have to be laid out into the Gulf.
15 Q.
All right.
And would the water be used 16 in a cooling tower or in the existing cooling 17 lake?
18 A.
Well, I just don't know.
19 Q.
Are you doing any analysis of that?
20 A.
No.
It's not in my area of expertise of 21 use of coolants for nuclear power plants.
22 Q.
So you would have no knowledge as to the 23 mechanism for getting the water there, the cost 24 involved and th e way in which it would be used?
25 A.
- Well, I have read the ER final
t 1
supplement where there is some analysis done in i
2 that report, looking at South Texas as an 3
alternate site, and I don't have any opinion 4
about that because I'm not an exert in that, 5
although it appears to be a feasible engineering 6
end and money-wise.
7 Q.
Well, are you aware what the cooling 8
source is for the two units at South Texas?
t 9
A.
It's run-of-the-river water pumped into 10 a cooling pond.
11 Q.
All right.
And is it your idea that the 12 cooling pond would then be filled with salt water 13 instead of run-of-the-river?
i 14 A.
No.
i 15 Q.
Well, I am just t r y ir.g to visualise how 16 you would 17 A.
Well, as I said earlier, I am not an 18 exert in this area.
I am aware that cooling sea water could be used as a coolant 19 could be 20 and it could be a once-through system, I assume.
21 0
Other than the South Texas site, have 22 you identified any other specific site?
23 A.
No.
24 0
Or has Miss Hinderstein asked you to do 25 so?
eram
@s O
1 construction impact of the area, all ~ those things 2
have taken place or, you know, are currently 3
taking place, and since there is this rather 4
large facility going in and documents produced by 5
NRC and others indicate that there is enough 6
physical land space for another two units at 7
South Texas project site, that makes sense to me 8
that the South Texas site is sup.erior.
9 Q.
Have you reduced your conclusions to 10 writing at th i s point or prepared any other work 11 papers relevant to this contention?
12 A.
W e.' '
I have prepared some papers on 13 population,,ajections i. that area, land use 14 projections.
15 Q.
All right.
Those would all be in your
\\
/
16 work papers?
17 A.
Yes.
18 Q.
Are you continuing to do work on this 19 contention?
20 A.
No, I have pretty much done all the data 21 finding that I plan to do on it.
22 Q.
Okay.
Do you know of anything which is 23 based on your review which would lead you to 24 conclude th a t the Allen's Creek site is 25 environmentally unique?
66 1
A.
Well, as s e a.t e d in the ER supplement, 2
final supplement, there are unique and prime j
i 3
agricultural lands.
I am not aware of any I
4 critical habitat of any endangered species, with 5
the exception of some water prairie chicken 6
transients in the area.
But to the best of my 7
knowledge I am not aware that this is an 8
ecologically unique area.
9 0
As a lawyer, I just have to chuckle at l
10 the idea of a transient prairie chicken, but 11
- Well, is it your understanding that i
12 there is unique agricultural land on this site 4
13 that it is not duplicated anywhere else in 14 substantial quantity?
la A.
- Well, it is unique in that as the Soil j
16 Conservation Service defines it, that unique farm
{
17 lands are just that; they occur in only certain 18 areas and are not widespread.
I believe in this 19 case they refer to unique farm lands as being 20 able to support rice.
21 Q.
On the Allen's Creek site?
22 A.
Yes.
l l
23 Q.
Is it your understanding that rice is l
24 being grown in that site now?
25 A.
I am not aware that rice is being grown
i l
SAXION DEPOSITION i
OF June 17, 1980
47 1
Q.
All right.
2 A.
Ye s.
It wo uld be could be out of 3
zone 5,
but Allens Creek is out of zo n e 6.
4 Q.
Could they ta ke wa te r from 57 Co uld 5
Ho us ton take wa te r from 57 l
6 A.
I a ssume they could if there was a 7
reservoir, or if they had wa ter rights.
8 Q.
Ho w about 47 9
A.
Mr. Copeland, they could ta ke it 10, anywhere if they had the money to make pi pe l in e s 11 or water rights and were able to procure the 12 water.
13 Q.
Well, what I'm trying to find out is 14 where you think that the City of Houston is going 15 to get some wa te r from the Brazos River?
)
16 A.
Well, there's a couple of reservoirs
)
)
R 17 that are proposed on the Brazos, I believe.
l 18 Q.
These would be proposed reservoirs?
19 A.
Yes.
The size of Allens Creek.could be l
l 1
20' optimized for water supply purposes rather than l
21 for cooling.
22 Q.
Where are the other. reservoirs that you 23 have in mind?
24 A.
Well, there's a couple of f ed er ally 25 authorized projects on the Navasota River.
"[~
48 1
Millikin and Nava so ta.
2 0
All right.
When are those due to come 3
on line?
4 A.
Those are Corp of Eng i n e e r projects.
5 I'm not sure what the status of planning is on 6
that.
)
7 0
Do you know how much wa t e r will be 8
available from them?
9 A.
Yes.
10 0
All right.
11 A.
Millikin would have a yield of 144,100 l
12 acre feet per year.
Nava so ta would have a yield 13 of 129,200 acre feet per year.
j 14 0
All right.
Do you know whether any of l
15 the wa te r from those projects is committed to any 16 con tr ac t?
17 A.
I'm not sure.
Both of these reservoirs 18 are planned for future development, so I don't 19 know wh a t the allocation of wa te r would be at I
1 20 this time.
21 0
Do you know if plans show them to be 22 developed be f o re the year 2000?
23 A.
No.
24 0
All r ig ht.
25 A.
No t that I'm aware of.
\\
t
1 Q.
When are they due?
2 A.
Well, in the case of Na v a so ta, ! !' s 3
p roj ec ted to be built to meet demands in the year 4
2030.
And the case of Millikin, it's projected 5
to be built to meet demands in the year 2000.
6 Q.
Okay.
7 A.
Those are both federally funded projects.
8 Q.
Well, let's back up then.
What I need 9
to know is ex ac tly how much short fall the City 10 of Houston is going to have that you calculated, i
11 and were you think they would get the wa te r from.
12 Which zone in the Bra zo s?
13 Le t's take the year 2000.
Do you think 14 Houston is g o i ng to have a short fall of wa te r in 15 the year 20007 16 A.
Yes.
I belfeve they will.
According to 17 this document and testimony that I heard that was 18 presented in the Wallisville case.
19 Q.
All right.
Who testified in tha t?
20 A.
I d on' t recall the man's name.
He 's 21 deceased, but he was head of Ho u s to n 's Public 22 Works De pa r tm e n t.
23 Q.
All right.
Do you know how much short 24 fall there will be in Houston by the year 2000?
I can't recite a figure at 25 A.
I don't k
.50 I
this time.
2 Q.
Well, do you have just a ball park guess?
3 A.
Not at this time.
4 0
Is it more than the output of Millikin?
5 A.
Yes.
6 Q.
More than the output of Na va so ta and 7
Millikin together 8
A.
I'm not sure.
4 l
9 0
in the year 20007 10 A.
I'm not sure.
I 11 Q.
Let's assume then there is 160,000 acre 12 feet short fall in the year 2000.
Ho w would the 13 construction of the Allens Creek Plant interfere 4
14 with the ability of Houston to ob ta in the 160,000 15 acre feet that it would need from the Bra zos 16 River in the year 2000 if they could ta ke it from 17 Millikin or Navasota?
18 A.
Well, there is that possibility.
Those 19 are both f ed erally f und ed projects, and it's 20' uncertain whether they will be built.
If Allens 21 Creek is ouilt, i t's a closer supply source that 22 could potentially alleviate Houston's future 23 demands.
24 The documents that I p r e se n ted to you, 25 there is a report on the Pr e sid en t 's River Basin
51 1
Commission which ind ica ted an Allens Creek 2
reservoir being constructed fo r wa te r supply 3
purposes.
4 Q.
Well, I think that you must have missed 5
my question.
My question was:
If Allens Creek 6
is constructed, will it prevent Houston from 7
being able to get the wa te r it needs from the 8
Brazos River?
9 A.
Well 10 Q.
Yo u ' r e just saying it's a more 11 convenient loca tion for a reservoir?
12 A.
Yes.
But these two projects are federal 13 projects, and the uncertainty of getting those 14 funded and built what I'm trying to say is if 15 the r e s e rvo ir is needed to meet future demand i
I. '
16 that Allens Creek wo uld make better s e ?, s e, and 17 the more appropriate use wo uld be wa t er supply 18 rather than cooling.
19 Q.
Better sense then Millikin or Navasota?
20 A.
Yes.
21 Q.
Why is tha t?
22 A.
It's closer.
Pumping costs are less.
23 Q.
Ho w much less?
24 A.
I haven't done those calcula tions, but 25 it's based on distances and to pog ra ph y.
52 O
1 Q.
- Well, I mean is i.t e no ug h to worry about?
2 A.
I think it wo uld be.
2 C.
How much is it?
4 A.
I don't know.
5 Q.
So basically then the only way that 6
Allens Creek would in te r f e r e with the ability of 7
Houston to get whatever wa ter it needs from the 8
Brazos is simply because it would preempt a 9
better location for a reservoir?
10 A.
That's c o r r e c.t.
Q.
All right.
If you would, look at page 11 12 430 page Roman numeral IV '30 of the Continuing 13 Wa te r Resources document.
14 A.
Okay.
15 Q.
If you look at the column on the left-J l
16 hand side or the right-hand side of.that page, 17 there is a statement there that they do not 18 believe there will be a shortage up to and 19 including the year 2000 on the Brazos River.
20 Do you see that s ta tem en t?
21 A.
Yes.
I'm reading it.
22 Q.
Okay.
23 A.
Well, they say small deficiencies would 24 be experienced in d ro ug ht years.
25 Q.
All right.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE 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 S
Station, Unit 1)
S l
CERTIFICATE OF SERVICE l
I hereby certify that copies of the foregoing Applicant's Response to TexPirg's Motion for Summary Disposi-tion of TexPirg Contention 1 Re Allens Creek vs. South Texas Project Site Comparison in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 2nd day of' October, 1980.
Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek l
Atcmic Safety and Licensing Mayor, City of Wal-lis l
Board Panel P. O.
Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C.
20555 l
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 U.S. Nuclear Regulatory Commission Commission Washington, D.
C.
20555 Washington, D. C.
20555 l
Mr. Chase R.
Stephens Atomic Safety and Licensing l
Docketing and Service Section Appeal Board l
Office of the Secretary U.S. Nuclear Regulatory l
of the Commission Commission Washington, D. C.
20555 Washington, D. C.
20555 Susan Plettman Richard Black David Preister Staff Counsel Texas Attorney General's Office U.S. Nuclear Regulatory P. O.
Box 12548, Capitol Station Commission Austin, Texas 78711 Washington, D. C.
20555
e Bryan L.
Baker Brenda McCorkle 1118 Montrose 6140 Darnell Houston, Texas 77019 Houston, Texas 77074 J. Morgan Bishop W. Matthew Perrenod 11418 Oak Spring 4070 Merrick Houston, Texas 77043 Houston, Texas 77025 Stephen A. Doggett F.
H. Potthoff i
P.
O. Box 592 7200 Shady Villa, No. 110 Rosenberg, Texas 77471 Houston, Texas 77055 John F.
Doherty Wayne E. Rentfro l
4327 Alconbury P. O. Box 1335 l
Houston, Texas 77021 Rosenberg, Texas 77471 l
Carro Hinderstein William Schuessler l
609 Fannin, Suite 521 5810 Darnell l
Houston, Texas 77002 Houston, Texas 77074 l
D. Marrack James M.
Scott 420 Mulberry Lane 13935 Ivy Mount Bellaire, Texas 77401 Sugar Land, Texas 77478 M
J. gregwrgCc peigne t
I l
l l -
.