ML20003G674

From kanterella
Jump to navigation Jump to search
Testimony on Behalf of Util on Bishop Contentions 4,5,7,9 & 10 Re Tx Electric Svc Co 24-inch Natural Gas Pipeline & Pipelines Crossing Brazos River Upstream from Facility.Prof Qualifications Encl
ML20003G674
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 04/20/1981
From: Carnes W, Iotti R, Mercurio W
EBASCO SERVICES, INC.
To:
Shared Package
ML20003G672 List:
References
NUDOCS 8104300478
Download: ML20003G674 (41)


Text

@t U YPf 4-20-81 4 00 0 g

~

1 UNITED STATES OF AMERICA 3\g --

NUCLEAR REGULATORY COMMISSION p?% G BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 g 4 In the Matter of )

)

5 HOUSTON LIGHTING & POWER COMPANY ) Docket No. 50-466

)

6 (Allens Creek Nuclear Generating )

Station, Unit No. 1) )

7 )

8 TESTI;10NY OF ROBERT C. IOTTI, WILLIAM S. CARNES AND WILLIAM F. MEFCURIO ON BISHOP CONTENTIONS 4, 5, 7, 9 9 AND 10 RELATING TO THE TEXAS ELECTRIC SERVICE CO.'s 24" NATURAL GAS PIPELINE AND PIPELINES CROSSING THE 10 BRAzOS RIVER UPSTREAM OF ACNGS 11 12 O. Dr. Iotti, please state your name and business address.

13 A. My name is Robert C. Iotti and my business address is 14 Ebasco Services, Inc., 2 World Trade Center, New York, 15 N.Y.

16 Q. What is your position with Ebasco?

17 A. I am the Chief Engineer for Applied Physics.

18 Q. Please describe your education and professional qualifi-19 cations.

20 A. A statement of my education and professional qualifi-21 cations is attached to this testimony as Exhibit RCI-1.

1 22 Q. Mr. Mercurio, please state your name and business address.

23 A. My name is william F. Mercurio, and my business address 24 is Ebasco Services, Inc., 2 World Trade Center, New York, i

4 25 N. Y.

26 Q. What is your position with Ebasco?

l 27 A. I am the Supervising Soils and Foundation Engineer.

28 .,

8104 3009 h76 _

i 1  ;

3 Q. Please describe your education and professional qualifi-2l 3! cations? ,

4 A. A statement of my education and professional qualifi ,

5- cations is attached to this testimony as Exhibit WFM-).

6l Q. Mr. Carnes, please state your name and business address.

b 7 A. My name is william S. Carnes. My business address isli 8

Ebasco Services, Incorporated, 160 Chubb Ave., Lyndhurlst, New Jersey.

9l In what position are you employed by Ebasco Services, 10: Q.

11 Incorporated?

12 A. I am the. Lead Balance of Plant Systems Engineer for [

13 ACNGS.  !

14 Q. Please describe your education and professional qualifi-15 cations. ,

16 A. A statement of my education and professional qualifi-17 cations is attached to this testimony as Exhibit WSC-l.

18 Q. Dr. Iotti, what is the purpose of your testimony?

19 A. The purpose of my testimony is to address Intervenor 20 Bishop's Contentions 4, 5, 7 and 9, all of which relate 21 to the relocated Texas Electric Service Co.'s (TESCo) 22 24" natural gas pipeline. In Contentions 4 and 5, kJ Mr. Bishop alleges.that Applicant has not adequately 24 analyzed the risks to the population of Simonton and 25 valley Lodge subdivision from a rupture of this pipe-26 line. Mr. Bisacp further contends that because of the 27 instability of the Brazos River bank, the probability 28 of a pipeline rupture has been increased. (That portion W

v

1 2 of Mr. Bishop's contention will be addressed by Mr.

Mercurio). In Contention 7, Mr. Bishop al-3 4 leges that a rupture of the relocated 24" natural gas 5 pipeline could cause a breach of the cooling lake dam re-6 sulting in the release of water from the cooling lake.

7 Finally, in Contention 9, Mr. Bishop alleges that the Ap-g plicant has underestimated the risks to the plant from 9

detonation of a gas cloud due to a rupture of this pipe-10 line. My testimony will respond to these four contentions.

11 Q. Dr. Iotti, will you explain where the 24" natural gas 12 pipeline will be relocated?

13 A. Yes. This pipeline now runs through the center of the 14 Proposed ACNGS cooling lake. In order to avoid the 15 cooling lake, the pipeline will be relocated to a point 16 approximately 700 feet east of the cooling lake dam, 17 between the cooling lake dam and the Brazos River. At 18 its closest point, the line will pass approximately 9300 19 feet northeast of the nearest Category I structure, the 20 ultimate heat sink. (PSAR S 2.2.3.2.)

21 Q. What materials are transported in this pipeline?

22 A. The TESCo pipeline has been in existence for nearly 23 20 years and has, throughout this period, carried 24 only natural gas (90% methane). As the attached letter 25 from TESCo confirms (Exhibit RCI-2), the line presently 26 carries only processed natural gas with at least 90%

27 methane. The existing contract with the line operator, 28 the LoVaca Gathering Company, is to carry only natural gas

l j

i 1 3

2 and runs through the year 1990. There are no existing 3 plans to carry any other materials in the line, and no 4 changes are anticipated in the foreseeable future. It 5  : should also be recognized that the size of the existing i

i line, 24" in diameter, makes it extremely unlikely that 6[.  !

7- ' liquified products would be carried in it, since because.

b l 8 I of their smaller volumes, they can be most economically piped in smaller 6" to 8" pipelines.

9l 10 o. , will TESCo take any steps to prevent leakage or rupture 11 of the gas pipeline as it passes close to ACNGS?

12F A.  :

TESCo will provide an industry standard cathodic protec-13l  ! tion method for the line in order to inhibit the forma-14  : tion of rust. Cathodic protection through electrical 15 means, prevents oxidation (corrosion) which consist,s of 16 p rust, by preventing loss of metallic ions from the pipe i

17  !

wall to the surrounding electrolyte (soil, water, etc. ) .

18"i Such protection will be provided along the segment of the

i 19 line that is to be relocated.

20

0. ,l What measure has TESCo taken to detect a possible leak 21 in this pipeline and subsequently to deactivate a I 22 leaking section of the pipeline?

23 A. Since the TESCo line will be located in close proximity 24 to the Allens Creek cooling lake, which will be utilized 25 as a recreation area for fishing, sailing, swimming and 26 other recreational activities, federal and state regula-E tions require TESCo to install an isolation valve close to the lake in order to prevent the escape of significant 9

O l

1 2 quantities of natural gas. (49 CFR Part 192.179(4).)

3 TESco has committed to provide pressure sensors 4

which will send a signal to close the valve 5 upon a drop of 50 psi / minute at the point of the valve.

6 This valve closure system will operate automatically.

7 The use of these sensors and the isolation valve make it g extremely unlikely that a rupture and detonation of sig-g nificant quantities of natural gas could occur in the 10 vicinity of the cooling lake.

11 Q. Dr. Iotti, although you state that it is extremely un-12 likely that a detonation of significant quantities of 13 natural gas could occur from a rupture of the 24" gas 14 pipeline, has the Applicant nonetheless performed an 15 analysis of potential effects of a rupture of the line 16 and detonation of the escaping natural gas?

17 A. Yes. Appendix 2.2-A of the PSAR contains an analysis 18 of the potential effects of a rupture of the gas line 19 and subsequent detonation of the escaping gas. This 20 analysis utilizes several conservative assumptions and 21 demonstrates conclusively that the plant's category I 22 structures will not suffer any adverse consequences from 23 a line rupture and subsequent detonation of the emitted 24 gas.

I 25 O. Would you describe Applicant's analysis as it is set l

26 forth in the PSAR?

l 27 A. The analysis includes a calculation of the anticipated 28 flow rate out of the line assuming a double-ended rup-t L

1 2 ture of the 24" pipe and gas escaping from both open 3 ends. It does not ake into account the operation of 4 the isolation valve discussed above. The analysis demon-5 strates that for the first 2.5 minutes following a break, 6 it can he conservatively assumed that the two open ends 7 -of the pipe will together discharge natural gas at a 8- rate of 9600 lb./sec. Thereafter, only the pumped end will 9 discharge, and at a rate of approximately 108 lbs./sec.

10 (assuming operability of the pumps at the nearby pump 11 stations). These rates are calculated under the conserva-12 tive assumptions that sonic flow would continue to exit 13 the break until the line is depressurized, and there-14 after the pump would continue to operate. In reality, 15 this is very conservative because upstream pressure 16 will decrease with time, and because friction effects 17 have not been accounted for, both of which decrease 18 the rate flow out of the break.

19 The rate of flow calculated above is only one 20 factor which determines the size of the largest detonable 21 cloud of gas that can be realistically postulated --

22 another factor is the atmospheric conditions chosen.

23 Applicant's analysis evaluates cloud size for a stable 24 atmosphere characterized by a constant, invariant wind 25 speed of 2.6 ft./sec. The assumption of stable at-26 mospheric conditions with low wind speeds leads to 27 the prediction of larger detonable clouds which extend 28 further from their sources than is likely to be the l _

L

~

1 2 case if more realistic assumptions are used. Thus the 3 clouds are assumed to be closer to the plant.

4 To further conservatively estimate the maximum 5 credible detonable cloud, as well as the closest dis-6 tance to the plant which the cloud could reach, the Ap-7 plicant has taken no credit for the effects of buoyancy 8 of methane, the material which comprises most of the 9 natural gas. The analysis also takes no credit for the 10 initial momentum of the jet escaping the assumed break, ex-11 cept for the initial period after the break during which 12 these momentum effects in particular are very significant.

13 To artificially create the configuration of a large, low-14 lying detonable cloud of gas travelling toward the plant, 15 the analysis assumes a constant mass output from the break 16 with zero upward velocity, which realistically cannot occur.

17 Realistically, the velocity of the flow of gas at the 18 rupture, combined with the buoyancy of methane, will 19 propel the gas away from the surface so that a small 20 amount of gas, less than 500 lbs., is expected to remain 21 within the flammable limits near the surface. By ig-22 noring both initial momentum and buoyancy effects for 23 the long-term discharge, the Applicant has calculated a 24 worst detonable cloud size of approximately 21 million 25 cubic feet (PSAR Appendix 2.2-A, p. 2.2.A-14), the 26 farthest reaches of which are 4200 feet from the assumed 27 break (PSAR Appendix 2.2-A, Fig. 3.3a).

28 6

.v -

~

1 2 Under realistic conditions, because of buoyancy 3 and jet flow, any detonation of gas flowing from the 4 ruptured line would occur very close to the point cf 5

the rupture and the size of the detonable cloud would be much smaller than that assumed in this analysis.

6l" There are no reported instances where a methane cloud 7

8- has drifted any significant distance from the point of 9- a break before detonating, and the probability of such 10 cloud movement, which the analysis postulates for con-11 servatism, is extremely remote, if not impossible.

12 Utilizing the hypothesized non-buoyant detonable 13 cloud described above, and the closest point of detona-14 tion, the PSAR analysis calculates the effects from detonation on ACNGS Category I structures. The analysis 15 16 further conservatively assumes a detonation yield from the 17 methane of 50% in computing the blast wave and seismic 18 parameters in the plant site. Experimental work referred 19 to in the PSAR (Appendix 2.2-A, p. 2.2.A-14) indicates 20 that the yield is much lower, more on the order of 7 to 21 20%. The plant's critical structures are shown to with-22 stand the effects of the detonation of the postulated 23 worst cloud. (PSAR' Appendix 2.2-A, p. 2.2.A-15.)

24 Q. Did the PSAR analysis also look at the effect of missiles 25 generated by the assumed detonation?

26 A. Yes it did. This analysis conservatively demonstrates 27 that postulated missiles pose no hazard to the plant.

28 m

r - , - _ _ , _

1 2 I To analytically assess the potential that damaging 3 missiles could be created, the Applicant equated 4 the capability of generating missiles from a 5 hypothetical detonation of a dispersed cloud with the 6 generation of missiles from a localized surface burst 7 of equivalent energy. (PSAR Appendix 2.2-A, p. 2.2.A-15).

8 Applicant made this comparison because data on missile 9i generation from a surface burst exists, whereas none i

10 exists for dispersed clouds of gas. Applicant then 11 assumed that the entire mass of all missiles would be 12 concentrated into one missile. Utilizing these conserva-13 tive assumptions, the analysis shows that missile impact 14 energy is insufficient to damage plant structures impor-15 tant to safety. (PSAR Appendix 2.2.A, p. 2.2.A-15.)

16 Q. Does the PSAR analysis you have just described depend 17 upon the ability to detect a leak in the gas line and 18 stop the flow of gas?

19 A. No .' As described above, the analysis contained in the 20 PSAR assumes a constant flow of gas from the ruptured 21 natural gas pipeline.

22 Q. What would be the effect of adding leak detection sensors 23 and isolation valves to the line?

24 A. The PSAR analysis assumes that this flow has con-25 tinued for a long enough time so that the same amount 26 of methane is added to the detonable volume by at-27 28

1 2 mospheric dispersion as the amount of methane which is 3 dispersed to less than detonable concentrations 4 (equilibrium cloud size). The addition of sensors and 5 isolation valves will reduce the time of flow and the 6 quantities discharged. Shorter flow times may not per- .

7 mit achieving this steady state condition and therefore 8 may result in smaller clouds, cxtending a staller dis-l 9 tance downwind.

10 Q. What percentage of methana did the PSAR analysis assume 11 the pipeline carried?

12 5. Applicant's analysis of a rupture and detonation of the 13 24" natural gas pipeline assumed that it contains 100%

14 methane. This assumption, as discussed below, is con-15 servative, and bounds the analysis of potential impacts 16 from detone. tion. Based upon information from TESCo, 17 the line presently carries processed natural gas which j

18 is approximately 90% methane. The remaining constituent l

19 materials consist of impurities including hydrogen, 20 nitrogen and sulfur dioxide. In addition, the line often 21 contains trace amounts of some hydrocarbons other than 22 methane, including propane and butane. Because the 23 materials constituting the 10% non-methane portion are 24 either non-detonable or, if detonable, are either more 25 buoyant or have more restrictive detonable limits 26 than methane, the analysis in the PSAR actually over-l 27 predicts the potential yield from detonation of the l.

28 line.

f l

l

~

1  !

Q. Dr. Iotti, please turn your attention to Mr. Bishop's 2lF 3 Contention 7 which alleges that the ACNGS cooling lake

4. dam is inadequately designed to withstand an explosion or erosion from a rupture of the 24" natural gas pipeline.

5lh 6.i Has the Applicant performed an analysis of the potential 7ll effect on the cooling lake dam from an explosion or 8 erosion from rupture of the 24" natural gas pipeline?

9j A. Yes. Applicant has analyzed the potential effect of 10l! ,

detonation of the line under expected conditions and lilj utilizing reasonable assumptions as to yield, amount 12:

i of detonable gas, and point of detonation. This 13 analysis, was done to provide data used in the design 14 of the cooling lake dam. Therefore, the dam will not 15 be endangered by detonation of the line. ,

16 Q. Would you please describe this analysis?

17 A. The potential hazards to the dam have been assessed 18 by examining the detonation of the jet escaping the 19 postulated break, since explosions of natural gas i 20 jets are known to have occurred. For the largest 21 break in the line the amount of flammable gas in the 22 jet that would be generated after the earth covering 3 23 the pipe flies up, is computed to approximately 7500 ft. .

24 The detonation of this quantity of flammable mixture is 25 taken very conservatively to be equivalent to the 26 detonation of 325 lb. of TNT.

27 This detonation produces peak overpressures of 28 approximately 4.0 psi at a distance of 150 ft. and 6

1 2 overpressures of 1 psi 300 ft. away. The exact amount 3 of flammable material that would detonate is of course 4 uncertain. To account for this uncertainty a ten-fold 5 increase in the quantity detonated has been assumed.

6 For this quantity, peak overpressures of 2.1 psi are 7 reached at 300 feet. The cooling lake dam is designed to withstand such an overpressure. In fact, the TESCo 8

9 pipeline will be over 700 feet from the cooling lake dam 10 at its closest point. Since a detonation of methane gas 11 released from the line would occur at or very close to 12 the point of the rupture, the line poses no threat to 13 the integrity of the dam.

14 Q. Does this analysis take into account the operation of 15 the sensors and isolation valve, discussed above? -

16 A. No. The analysis does not assume that the sensors 17 and isolation valve are in operation.

18 Q. Has the Applicant considered the potential effect on t

i 19 the cooling lake dam from missiles generated 20 by the assumed detonation of the gas from a rupture of 21 the pipeline?

22 A. Yes, the Applicant has analyzed the potential hazards 23 to the plant posed by the creation of missiles generated 24 during a postulated detonation of methane gas from a 25 rupture in the pipeline. Applicant has made assumptions 26 designed to estimate the largest missiles that would be 27 generated and the force with which they could be pro-28 pelled toward the plant. Applicant chose to estimate M

- - . + , , ,, w- --,

~

1 2 this hazard by relating the explosion of the hypo-3 thetical cloud of gas with the explosion of an 4 equivalent amount of TNT. Data on missiles 5 generated by TNT explosions exist and this data 6 demonstrates that the size of generated missiles 7 and their ejection force can be estimated by analyzing 8 the mass of a missile ejected during the formation of a 9 crater at the location of a TNT explosion. As a result 10' of this analysis, Applicant concluded that there was no 11 risk of damage to the dam from postulated missiles.

12 In its PSAR analysis, Applicant estimated that the 13 TNT equivalent of the conservatively assumed naximum gas detonation would create a crater 97 ft. in diameter 14 15 and 18 ft. deep. From this figure (PSAR 2.2. Appendix 16 A, Fig. 1. 3 . ) , Intervenor has postulated that a gas ex-17 plosion could seriously damage the cooling lake dam.

18 The crater postulated in the PSAR was considered 19 only for the purpose of analytically estimating missile l

20 hazards to plant Category I structures and was not in-l l 21 tended as an estimate of the size of the crater that 22 could actually be generated by methane gas explosion.

23 A dispersed cloud of gas will not generate a crater in 24 the manner that a TNT charge at ground level generates .

l 25 a crater. This is because energy release densities i

26 created during a detonation of a gas cloud are several l

27 orders of magnitude lower than that of solid explosives l 28 I

e 6

1 ,

such as TNT. In fact, no substantial cratering is an-2 3 ticipated to result from detonation of gas released from 4 the TESCo pipeline.

5 Q. Have you performed an analysis of the risks to the com-6 munities of valley Lodge and Simonton from a rupture of 7 the 24" gas pipeline?

8 A. Yes. As discussed above, the TESCo 24" natural gas 9, pipeline is expected to carry only methane during the i

life of the plant. Methane is a buoyant gas which will 10' 11 disperse upwards into the atmosphere and diffusa to 12 less than detonable or flammable concentrations very 13 shortly after being released from a postulated rupture 14 of the line. This rapid diffusion and dispersal of the 15 gas is enhanced by the expected jet-like flow out of the 16 pipe. Methane cannot form a low-lying cloud and travel 17 significant distances along the ground before dissipating.

18 Consistent with these properties of methane gas, there 19 are no recorded instances of delayed natural gas detona-20 tion in the open air.

21 The valley Lodge subdivision and Simonton are located 22 approximately 2.5 to 3.0 miles and 4.0 to 4.5 miles, re-23 spectively, from the closest approach of the relocated 24 TESCo pipeline. Utilizing the same conservative as-25 sumptions of yield and volume of detonable gas as 26 were utilized to determine the potential impact of 27 detonation on plant structures, it can be conclusively 28 M

1 2

shown that this pipeline poses no hazard to 3

the nearby communities of Valley Lodge and Simonton.

4 Even if one conservatively assumes that escaping methane 5

gas could form a cloud and move, under worst-case meteoro-6 logical conditions, in ihe direction of Valley Lodge, the 7

nearest fringes of the flammable cloud to this subdivision i

g would be more than 62001 feet. If one were to assume that g a detonation is centered at this closest point, overpres-10 h sure would be less than 0.4 osi. overpressures genera-11 ted by this hypothetical worst case detonation would be 12 of the magnitude which would result in glass breakage, but no other substantial damage.

13 14 The TESCo pipeline also poses no danger to Valley 15 Lodge or Simonton residents due to possible asphyxiation 16 from released gases. Due to the buoyancy of methane, 17 anygasreleasedfromdhelinewilldisperserapidlyinto 18 the atmosphere. The concentrations of methane that could 19 occur at distances of 2 or more miles from the line are 20 very small. For instance, neglecting buoyancy one would 21 compute methane concentrations at this distance of less 22 than 2 percent. With buoyancy, the concentration would 23 be significantly lower. Methane is classified as a simple asphyxiant gas. Gases of this type have no 24 25 specific toxic effect, but they act by excluding oxygen 26 from the lungs. The effect of simple asphyxiant gases 27 is proportional to the extent to which they diminish 28 the amount (partial pressure) of oxygen in the air

j 1 2'l that is breathed. The ox" gen may be diminished to two-3lI ' thirds of its normal percentage in air before appreciable 4' symptoms develop and this in turn requires the presence 5l of a simple asphyxiant in a concentration of 33 percent 6 in the mixture of air and gas. When the simple asphyxiant Ti reaches a concentration of 50 percent, marked symptoms I

8 can be produced. A concentration of 75 percent is fatal 9] in a matter of minutes.

I 10l concentrations will be far below that needed for 11 asphyxiation by a simple asphyxiant and also far below E the concentrations given as threstald for discomfort for 13 the alkanes i.e., 5 percent or more by volume.

14 Q. Mr. Mercurio, in his Contentions 4 and 5, Mr. Bishop ex-15 pres-es concern about possible erosion of the Brazos 16 River bank near the relocated 24" natural gas pipeline 17 which he alleges will increase the risk that the pipeline 18 will rupture. Has the Applicant e.xamined the potential 19 for erosion of the Brazos River bank?

20 A. Yes. As shown in the PSAR, Section 2.4.9, Brazos River 21 channel diversions near the site have been analyzed 22 23 24 25 26

  • / Source: "Dangetsui, eperties of Industrial Materials,"

N. Irving Sax.

27 28 er

I Figures 2.4-5A and 2.5-5B using historical data.

show that the Brazos River has experienced some bank erosion and resulting movemer. c.f the river channel near 5 the proposed relocated section of the TESco pipeline, be-6 tween the River and the cooling lake dam. This data 7 indicates the potential for additional bank erosion during 8 the life of the plant. Any such movement of the river channel is anticipated to occur slowly, however, and 9lh, 10! there will be ample warning of the bank's approaching i

11' the relocated natural gas pipeline.

12 Q. How close will the relocated TESCo pipeline be to the 13 Brazos River bank?

14 A. At the present time the proposed new route will place 15 the line over 500 ft. from the existing river channel.

16 Q. Are you aware of any discussions between the Applicant 17 and the State of Texas concerning the potential erosion 18 of the Brazos River bank?

19 A. Yes. Farm to market road 1458 lies between the proposed i

20 pipeline route and the River. This improved road was 21 washed away on two occasions between 1939 and 1957 and 22 was therefore relocated a greater distance from the river 23 bank. (PSAR S 2.4.9.1.2.) The State of Texas is con-24 cerned that due to potential erosion, the River may 25 again approach and undercut the road, and has consulted 26 Houston Lighting & Power regarding the possibility of 27 jointly undertaking to stabilize the River near the 20 site. (See Exhibit NFM-2.)

M

1  ! 1 2' O. What solution to the erosion potential has been prc-3 posed?

4 A. The Texas Department of Highways and Public Trans-5 portation has obtained a plan and cost estimate for 6 stabilizing the river bed from " Hold That River, Inc.",

7- a company with significant expertise in this area.

8 " Hold That River" states that it "can provide the 9 solution to eliminate further erosion and protect the 10' highway" using a system of permeable jetties designed 11 to catch and accumulate materials as they impinge upon 12 the river bank at points close to the road and the 13 pipeline.

14 Q. Has Ebesco performed an analysis relating to protection 15 of the Brazos River bank from erosion? .

16 A. Yes. A detailed study was conducted by Ebasco in 17 "Brazos River Bank Erosion Protection" (1978).

18 The study identified the potential erosion problem and 19 recommended, similar to the proposal by " Hold That 20 River", the employment of a system which included a 21 combination of approximately 4000' cf permeable jetties 22 in the reach along the riverbed and 1000' of armor-type 23 protection in the vicinity of the makeup intake structure.

24 Q. Would you explain how the jetty system works?

25 A. Jetty systems function by ensnaring debris frcm the 26 river and creating a network of barriers to the river 27 flow, thus providing a better resistance to the erosive 28 river velocity in the area in which the jetties are O

w

i 1 2 installed. The_ increase in resistance to erosion 3 will subsequently reduce the river velocity in the 4 protected area and in turn shift the higher velocities i, toward the middle of the river. Since the capability il 6!I of a river to erode and transport bed material varies 7 as the sixth power of the current velocity, the size 8 and amount of the sediment that can be transported is 91 drastically reduced. This has two desirable effects:

(1) prevention of further erosion, and (2) deposition 10l-Ili of transported material during periods of high water.

i 12 The latter effect will, over time, result in the jet-13 ties becoming clogged with river-borne materials, wh1ch ,

14 will form a new and stable bank for the river.

15 Q. How does the system proposed by Ebasco compare with the 16 proposal submitted to the State of Texas by " Hold That 17 River"?

18 A. Basically, the system recommended by Ebasco will per-19 form the same function as the " Hold That River" system.

l i

20 The " Hold That River" system has been employed in the 21 vicinity of the general area and has proved to be very 22 effective for bank stabilization. The Applicant con-s 23 siders that either plan will adequately protect the a i 24 river bank from erosion.

l 25 o. what have been the results of the discussions with the 26 State of Texas with respect to the proposal by " Hold 27 That River"?

28 A. Negotiations with the State and Applicant are continuing.

1

-l

1 2' IIowever, Applicant commits to the installation of the 3 jetty system, either alone or in conjunction with the 4 State of Texas in order to ensure the integrity of 5 the relocated TESCo 24" gas pipeline. The jetties 6 will be constructed and placed on the river during 7 construction of ACNGS.

8 Q. Mr. Carnes, what is the purpose of your testimony?

9 A. The purpose of my testimony is to address Mr. Bishop's 10 Contention 10 which alleges that pipelines crossing the 11 Brazos River upstream from the ACNGS may rupture releasing 12 flammable or corrosive materials into the Brazos River.

13 These materials, it is alleged, would enter the cooling 14 lake and damage plant structures.

15 Q. Do you believe that there is a risk of damage to plant 16 structures resulting from a postulated rupture of 17 pipelines upstream of ACNGS?

18 A. In my opinion, there is little, if any, risk of damage 19 to plant structures resulting from a postulated rupture 20 of pipelines upstream of ACNGS.

21 Q. Would you explain the basis for your opinion?

22 A. Yes. County pipeline maps show that pipelines which cross

. 23 the Brazos River upstream of the ACNGS plant to a distance 24 of 25 miles carry either crude oil, natural gas or unpro-25 cessed natural gas liquid. It is very unlikely that any 26 of these materials, if postulated to be released in the 27 Brazos River by a pipeline rupture, could ever get into the 28 ACNGS cooling lake and cause any damage to niant structures.

M

I 1 2 Q. Why would these materials not pass into the ACNGS 3 cooling lake?

4 A. First, it is necessary to understand how Brazos River 5 water is pumped into the cooling lake.

6 The ACNGS heat dissipation system includes a make-7 up pumping station along the banks of the Brazos River 8 which is designed to pump river water into the cooling 9 lake at designated intervals. HL&P intends to periodi-10 cally monitor the diversion of make-up water'into the 11 cooling lake while the make-up pumps are in operation.

12 Pumping can be halted if any contamination of the river 13 is reported.

14 The make-up pumping station will consist of two 15 bays, each equipped with a trash rack and stop logs.

16 The make-up station will include two 37,000 cpm pumps.

17 The pumps will be vertical, centrifugal, wet pit type 18 pumps taking suction frcm the bottom of the intake 19 struct. ure . Make-up water from the Brazos River is 20 drawn into the pumping system from the bottom of the 21 River. Water enters the make-up pumps at an elevation 22 of 62 ft. MSL, which is approximately 12 ft. below the 23 normal surface level of the river. Any substances l

24 floating on the River, or located near the surface, 25 will not enter the pumps and therefore will not enter 26 the cooling lake. The very low inlet velocity into 27 the intake structure (less than 0.5 ft./sec.)..will 28

, l -

i 1:i: 11 2! preclude the surface turbulence necessary to mix 0

3. ' and bring the floating contaminants to the pump l

sunction bell.

O. Does the design of the cooling lake intake structure 5l'l i

6?; which you have just described affect whether postulated li.

qij releases of raaterials from upstream pipelines could ti 8 enter the cooling lake?

9 A. Yes. The only materials escaping from a hypothetical 4

10  ; ruptured pipeline that could realistically pass through 11 the make-up system are materials with a density very 12' close to water such that they might be suspended through-13 -1 out the vertical plane. I am not aware of any such i

14 l materials which would be carried in pipelines that cross

.i 15h the Brazos River upstream from the ACNGS. The liquid N

hydrocarbons which would be carried in pipelines in the 16 ]

17 plant region are lighter than water and would float 18*l past the make-up pump opening.

19 i Q. If you assume that some contaminants from a postulated 20 ruptured upstream pipeline may enter the cooling lake, 21 what would be the effect on the plant safety?

A. If contaimments from a ruptured line on the Brazos l

l

' 23 River were to get into the main cooling lake, it is 24 extremely unlikely that any auch material could 25 The only safety-related plant endanger the plant.

26 equipment that these contaminants could 27 come in contact with are the heat exchangers in the

, 28 Essential Services Cooling Water System and the spent

1, I

g fuel pool cooling water system. However, the heat 3 exchangers would experience fouling only after a sig-nificant build-up of foreign materials. Even a postu-4 5 lated build-up of foreign matter would be detected by 6 a decrease of heat exchanger performance during normal 7 plant operation and corrected as necessary during 3, routine maintenance or prior to unacceptable de-9 gradation.

10 C. Does that conclude your testimony?

11 A. Yes.

12 13 14 15 .

16 17 18 19 20 21 22 23 24 25 26 27 28 W

1 Exhibit RCI-l 2 EDUCATION AND PROFESSIONAL QUALIFICATIONS 3 Robert C. Iotti 4 Born Karisruhe, Germany 5 Member American Nuclear Society Subcommittee 6

ANS 55.2 on Protection Against the Effects 7 of Pipe Whip; 8 Member Atomic Industrial Forum Ad-Hoc 9 Committee on Pipe Whip 10 Professional 11 Licenses Professional Engineer, New York State, 12 No. 053262 13 Education Kansas State University - Ph. D. in 14 Nuclear Engineering (Physics and Applied 15 Mathematics); ,

16 M. S. in Nuclear Engineering (Applied 17 Mechanics);

18 B. S. in Nuclear Engineering (Mechanical 19 Engineering) 20 Experience Ebasco Services, Incorporated, New York 21 Office 22 1974 - Chief Engineer, Applied Physics:

23 Responsible for planning and directing all 24 engineering efforts toward shielding and 25 radiation monitoring of nuclear installa-26 tions; responsible for the planning, 27 direction, and performance of studies of 28 transient effects in containments and 3 e

1 Experience (Cont'd) 2 enclosures resulting from high energy pipe 3-breaks, wind loadings, detonations; studies of transient fluid flow phenomena; and heat 4

5 transfer studies. Developed and directed work in establishing a methodology for 6

7 evaluation of piping vibrations during 8 steady state and transient loading condi-9- tions. Developed a methodology for sim-ulation of transients in power plants and 10 11 a computer program to describe the boilerc 12 implosion phenomenon. Managed the effort 13 of a special group of engineers dedicated to an in-house research and development I 14 15 program on solar energy use which ranged 16 from the basic physics of the insolation, 17 to the design of thermal, thermo-electric 18 and photovoltaic systems. Responsible for 19 technical review and direction of radiation 20 transport activation and damage : studies, 21 thermal hydraulic studies, and fluid 22 heating and cooling design of the Tokamak Fusion Test Reactor. Directed work per-23 24 formed by consultants for a group of 25 utilities owning CE reactors and another 26 group owning s&u reactors to assess 27 probability of pipe ruptures. In this 28 capacity, acted as consultant to SAI in M

1 Experience (Cont'd) 2 the required probabilistic and fracture 3 mechcnics studies. j 4 Directed and performed work requi ed for 5 the complete analyses of the reactor vessel i

6 supports of a PWR plant under LOCA condi-f 7 tions resulting in asymmetric pressure l  !

loads inside the reactor vessel and the 8

9 reactor cavity. Developed methodology for 10 design against hydrogen detonations.

11 Directed design modifications of main steam 12 lines isolation and check valves (to enable 13 them to withstand rupture transients.

14 Engineered and designed novel neutron 15 streaming shields for application in 16 existing PWR plants. ,

i 17 1971 - 1974 Engineer / Senior Engineer / Principal Engineer /

18 supervisor, Applied Physics 19 Responsible for shielding design of nuclear 20 electric generating plants; engineering of 21 state-of-the-art radiation monitoring 22 systems for a2 clear plants; development and 23 implementation of theory and computerized 24 models describing the transient effects in 25 systems and enclosures resulting from high 26 energy pipe breaks; studies on turbine, 27 detonation and tornado driven missiles; 28 development of models predicting blast or M

1 Experience (Cont'd) 2 wind loadings from detonations or tornadoes 3 and/or hurricanes at critical structures; 4 studies on potential hazards to nuclear 5 islands resulting from breaks in nearby 6 pipelines; development of models and codes l 7 describing transient fluid effects such as l

8 steam hammer effects on main eteam and dump 9 lines, pressurizer relief lines; studies on 10 fin temperature distribution for a molten 11 salt reactor plant heat exchanges.

1970 - 1971 Kansas State University, Manhattan, Kansas 12 13 Assistant Professor, Department of Nuclear 14 Engineering 15 Teaching Mathematical and Nuclear Physics, 16 Basic Nuclear Engineering, Applied 17 Mathematics, Radiation Shielding.

18 1967 - 1970 Instructor, Department of Nuclear 19 Engineering 20 Teaching Nuclear Physics, Radiation Effects 21 on Materials, Heat Transfer, Basic Nuclear 22 Engineering, research in Theoretical 23 Nuclear Physics (neutron-proton cross-24 sections) and radiation shielding (roof 25 scattered radiation from infinite fallout 26 fields); Assistant Director Professional 27 Advisory Service Center for Fallout 28 Shelter Development in Kansas.

- - - - - _ r-, .

,- -,a, , n..

1 Exoerience (Cont'd) 1965 Coordinator and Participant 2

Kansas State University-OCD International 3

4 Summer Institute of Fundamental Radiation 5

Shielding Problems as Applied to Nuclear Defense Planning.

6.

7 Publications A. Papers - Iotti, R.C., W. J. Krotink, and D. R.

8l deBoisblanc, "

Hazards to Nuclear Plants 9

From, On (or Near) Site Gaseous Explosions"~,

10 11 Proccedings of Salt Lake City, ANS Meeting 12 on Light Water Reactor Safety, CONF-730304 USAEC, Salt Lake City, Utah, 1973.

13 14 Iotti, R.C., et al., " Scattering of Fallout 15 ,

Radiation from Ceilings of Protective 16 17 Structures", Final Report under Department l

18 of Defense Contract No. OCK-OS-63-74, l

19 Kansas Engineering Experiment Station, 20 Special Report No. 72, July 1966.

21 22 Iotti, R.C., et al., " Design of Structures 23 for Protection from Window-Collimated, i

l 24 Ceilings - Scattered Fallout Radiation",

i 25 Presented at the Denver Meeting of the l

l i 26 American Nuclear Society, Trans-American 27 Nuclear Society, 9, 1, pp. 150-151, 1966.

i r

_ _ , _ ._ .,,g- .-- . m , m., .. .-. - , , - .,..._%. m -

1 Publications (Cont'd)

~

2 Iotti, R.C., et al., " Solution of the 3 Ceiling Shine Problem in Structure Shielding 4 Design and Analysis", presented at the 5-Pittsburgh Meeting of the American Nuclear 6 Society, Trans-American Nuclear Society, 7 9, 2, pp. 346-347, 1966.

8 9 Iotti, R.C. and H.J. Donnett, " Interaction 10 of Neutrons with Helium 3", Acta Physics 11 Austriaca, 44, pp. 7-26, 1976.

12 13 Iotti, R.C., and H.J. Donnert, " Finite 14 Differences Method of Solution for the 15 Two-Channel Reaction Problem", Acta,Physica 16 Austriaca, 44, pp. 27-32, 1976.

17 18 Iotti, R.C., " Design Basis Velocities of l

19 Tornado-Generated Missiles", Trans-American i 20 Nuclear Society, 21. pp. 202-203, 1975.

l 21 22 Iotti, R.C., " Impact of Pipe Break on the 23 A/E", presented in a Panel Discussion at 24 the Second National Conference on Piping l

25 and Pressure Vessels, San Francisco, 26 California,' June 1975.

27 l

28 Heifetz, J. and R.C. Iotti, " PLAST -

l O

0 -

1 Publications (Cont'd) 2 Advanced Code for Dynamic Pipe Whip 3: Analysis", Trans-American Nuclear Society, 4 21,, pp. 202-203, 1975.

5 6 Yang, T.L. and R.C. Iokti, " Reactor Cavity I

7 Fast Neutron Streaming Calculation and I

l 8 Shielding Design by Monte Carolo Techniques" ,

9 Trans-American Nuclear Society, 22,, pp. 106 .

10 807, 1975. ,

i 11 12 Iotti, R.C. et al., " Analysis and Upgrading 13 of Swing-Type Steam valves", Trans-American 14 Nuclear Society, 22, pp. 561-562, 1975.

15 l

16 Iotti, R.C., R. Hensler, and R. Scully, i

l 17 " Thermal Analysis of Reactor Support i

18 Systems", Trans-American Nuclear Society, 19 23, p. 415, 1976.

1 l

20 ,

16 21 Iotti, R.C. et al., " Determination of N 22 levels for an Operating Boiling Water

(' 23 Reactor", Trans-American Nuclear Society, 24 23, pp. 598-599, 1976.

25 26 Iotti, R.C., " Establishing Loadings for 27 Containment Design, Including Choice of 28 Particular Loads, Their Magnitude, Combina-

{

1 Publications (Cont'd) tion and Time History, and Economics of 2

Containments", Winter Annual Meeting of the 3

Society of Mechanical Engineers, New York, 4

1976.

5 6.

Iotti, R.C., " Velocities of Tornado 7

Generated Missiles", Proceedings of the g,

Symposium on Tornadoes, Assessment of 9'

Knowledge and Implications for Man, pp.

10 585-599, June 1976.

11 12 Iotti, R.C., " Neutron Streaming - The 13 Problem and Engineered Solution", Best 14 Paper Award, ANS M&C and RP&S Divisions -

15 ORNL/RSIC-4 3, 1978.

16 17 Iotti, R.C., " Regulatory Guides and Their 18 19 Impact on Engineering Analyses", ASME/Pi'P Conference, San Francisco, California, 20 August 1980.

21 22 i

Iotti, R.C., "The TMI Accident - The Impact 23 24 on Design", ASME Winter Meeting, Chicago, Illinois, November 1980.

25 l 26 i

Iotti, R.C. et al., " Dynamic Design of 27 28 Piping Systems", SMIRT-6, M 10/4, Paris, i

I

~ ,.

1 Publications (Cont'd) 2 France, August 1981 3

}

l 4 Iotti, R.C. and M. Badrian, "Non-Linear 5 Analysis of a Biological Shield wall under 6- LOCA Loads in a PWR Plant", SMIRT-6, J 5/3, l

j 7 August 1981.

8 9' B. Reports - Iotti, R.C. et al., " Potential Hazards to 10 the Allens Creek Nuclear Station for

! 11 Hypothetical Breaks in Proximate Natural 12 and Liquified Petroleum Gas Lines",

13 Ebasco Report, APTR-1, 1974.

14 15 Iotti, R.C. et al., " Steam Hammer Analysis",

16 Ebasco Report, APTR-4, 1974.

17 18 Iotti, R.C. et al., "St. Lucie 1 Dynamic l 19 Fluid and Stress Analysis of Main Steam 20 Isolation / Check Valves", Ebasco Report, 21 APTR-7.

22 23 Iotti, R.C. et al., " Measurements of E4 Effluent Activity at Steam Jet Air Ejector 25 of Millstone Unit 1", Ebasco Report, APTR-9.

26 27 Iotti, R.C., " velocities of Tornado Genar-EE ated Missiles", Ebasco Topical Report,

, e , , . , - ----,-c - -------v, a--- ,, -- , . , - - . . , -

i- -1 B.' Reports (Cont'd)

. . .2 ETR-1003, 1975.

8 4

5 6

l-7 .

8

9 10
11 e

i i 13 '

1

, 14 15 .

I 16 17 18 .

19 -

. E i .

E 24 26 i M m

I e

o-w w -+1- = m-e _.- e,--. --. . . . . . ,, ,. ----.-w- 3 ,. ._-,,-.,_,.,ye..,~,,4-...,. . -.,,w- y, .y - -- ,7%~. w~ - -- , , , - , .- ,. g =.

0 .

1 Exhibit WFM-1 2 EDUCATION AND PROFESSIONAL QUALIFICATION 3 WILLIAM F. MERCURIO 4

SUMMARY

OF EXPERIENCE 5 Total Experience - Fourteen years in civil engineering. Of this 6 one year is structural analysis and design, one year is hydraulic 7 analysis and design and twelve years are soils and foundation 8 engineering. The major portion of this experience has been 9 fossil, hydroelectric and nuclear power plants, although 15 10 percent has been for industrial plants and commercial buildings.

11 Approximately 20 percent has been spent in the field solving 12 soils and foundation construction problems.

13 Major Field of Interest - Soils and Foundation Engineering 14 Licensed - Professional Engineer - New York - 1971 15 Member - American Society of civil Engineers - 1967 16 Education - Master of Science - Polytechnic Institute of j

i 17 . Brooklyn - 1971 18 Bachelor of Science - Polytechnic Institute of 19 Brooklyn - 1967 20 Additional advanced courses in construction management, earth-21 quake engineering.

22 EBASCO EXPERIENCE 23 Soils and Foundation Engineer - 1967 to 1969; 1971 to Present

! 24 (11 Years) 25 Principal Soils and Foundation Engineer on various fossil, hydro-26 electric and nuclear power plants. Responsible for 27 the planning of site and subsurface foundation programs, inter-20 pretation of laboratory data and recommendations and design 6

I for types of foundations. This includes field and office 2 design and construction. The soils analyses for the power 3 plants and embankments has incorporated both static and 4 dynamic considerations (bearing capacity, settlement, slope 5 stability, liquefaction). Pile analysis, pile driving and 6 load test analysis are a speciality.

7 PRIOR EXPERIENCE 8 Haller Testing Labs, Inc., Plainfield, New Jersey:

9 Soils and Foundation Engineer - 1969 to 1971 (3 years) 10 Project Engineer for the planning and layout of site and 11 subsurface investigation programs. Accommendations for the 12 design of foundations as to allowable bearing capacities, 13 including settlement and stability requirements. Analysis 14 of drainage problems and preparation of earthwork and 15 construction specifications. Foundation feasibility studies 16 and recommendations. Pile foundation analysis and design.

17 Pavement analysis, design and recommendations. All phases 18 of soil engineering laboratory testing, inspection of, 19 footing subgrades, test borings an pile driving. Pile 20 load tests, plate load tests, california Bearing Ratio (CBR) 21 tests, and percolation tests. Field quality control of 22 compacted fill and backfill.

23 24 25 26 27 28

1 L.:hibit WSC-1 2 EDUCATION. AND PROFESSIONAL QUALIFICATION 3 WILLIAM S. CARNES 4 Born: Pittsburgh, Pennsylvania, October 11, 1950 5 Education: Mt. Lebanon High School, Pittsburgh, Pennsylvania-1969 6 General Motors Institute, Flint, Michigan, BSME-1974 7 University of Michigan, Ann Arbor, Michigan, BSEE-1976 8 University of Michigan, Ann Arbor, Michigan, BSCE-1976 9 Licensed: Engineer-In-Training in the State of Michigan 10 Memberships: Construction Specifications Institute TAU BETA PI 11 Experience: .

12 1981: Lead BOP systems engineer for Al. lens Creek NGS Unit 1.

13 Responsible for all BOP systems including SDD's, flow 14 diagrams, updating PSAR, design calculations, and 15 systems input to equipment specifications.

EBASCO SERVICES, INCORPORATED . Mechanical Engineer -

16 1980-1981 17 .

on the design of the Allens Creek Nuclear Generating 18 Station. Systems Engineer for the following: Conden-19 sate and Feedwater, Heater Drains and Vents, Extrac-20 tion Steam, Main Condenser Air Evacuation, and Diesel 21 Fuel 011. Responsibilities for the above Systems in-22 clude Flow Diagram and Design Description Preparation 23 and revision to assure that the System Configuration 24 will result in proper response for all modes of opera-25 tion.

Electrical Engineer 26 1978-1980 EBASCO SERVICES, INCORPORATED.

27 on the construction of the Waterford 3 Nuclear Genera-Taft, Louisiana. As Cable Pulling 20 ting Station,

Engineer, I was responsible for the control of the issuance of Cable Pull Forms to the Electrical Con-tractor Resolving Nonconformances on cable and race-3 ways, resolving cable routing and pulling discrepancies, 4 and to ensure that applicable codes and standards were 5 adhered to. As Electrical Engineer for the Reactor 6 Ausiliary Building, I was responsible for Raceway and 7 Electrical Equipment Installation, including resolu-tion of nonconformances and discrepancies. Duties in-8 9 cluded interfacing with Mechanical and Civil Depart-10 ments for design of seismic supports, Equipment Inter-facing and resolution of interferences. Also included 11 12 was interfacing with vendors to assure that necessary 13 equipment modification would not jeopardize Class IE 14 or seismic Qualifications.

15 .

16 1977-1978 WESTINGHOUSE ELECTRIC CORPORATION. Naval Reactors Facilities, Idaho Falls, Idaho. Nuclear Plant Engin-17 18 eer/ Engineering Of ficer of the Watch (EOOW) on a 19 Naval Nuclear Prototype. Responsibilities as Nuclear l

l 20 Plant Engineer included monitoring and scheduling 21 Crew Training Program; Chemistry and Radiological Con-l 22 trol Program Administration and Auditing; co-ordina-23 tion of maintenance work packages and material during 24 both plant shutdown and routine maintenance; standing 25 watches as EOOW; and direct training of naval person-I l 26 nel on the design and operating principles of all 27 plant Systems. Responsibilities as EOOW were to 28 assure safe operation of the Prototype during all

4 conditions, through direct supervision of crew.

I 2 Responsibility for entire plant required an in-depth 3 knowledge of Design Principles Systems-Interfaces, 4 and operating procedures.

Chevrolet Motor Division; 5 1975-1976 GENERAL MOTORS CORPORATION.

6 On educational leave of absence to obtain BSCE and 7 BSEE degrees at the University of Michigan, Ann g Arbor, Michigan.

Chevrolet Motor Division; g 1974-1975 GENERAL MOTORS CORPORATION.

10 Chevrolet - Saginaw Grey Iron Casting Plant; 1629 11 North Washington Ave., Saginaw, Michigan; Production Supervisor. Duties included the supervision of 12 13 26 nen on 18 Osborn Hot Box core machines, pro-14 ducing sand cores for automotive grey iron casting.

1973-1974 GENERAL MOTORS CORPORATION. Chevrolet Motor 15 16 Division, Chevrolet-Saginaw Grey Iron Casting Plant, 17 ,

1629 North Washington Ave., Saginaw, Michigan; 18 Fifth-Year Student Duties included time and methods 19 studies in the industrial Engineering Department 20 while compiling the plant specific thesis "An 21 Analysis of Cupola Material Handling and Yard i

22 Layout to Improve Charging Efficiency."

1969-1973 GENERAL MOTORS CORPORATION.

Chevrolet Motor Division, 23 24 Chevrolet-Saginaw Grey Iron Casting Plant, 1629 25 North Washington Ave., Saginaw, Michigan; Co-Operative l

! 26 Student. Assignments during the work sections (work 27 sections and school sections alternated every six-28 weeks), included Production Supervision, Quality Con-l m e

4-1 trol Engineer, Industrial Engineer, and Labor Rela-2 tions Investigator.

3 4

5 6'

7 8

9 10-11 12 13 14 15 .

16 17 18 19 20 21 22

' 23 i 24 25 26 27 28 e

E M

Exhibit RCI-2 OLD OCEAN 8UEL CONIPANY x=o,ev orrics anox sto Font Wonts Tai:xAss 78101 March 3, 1981 Mr. Paul Horn Project Manager, Allens Creek Nuclear Generating Station Houston Lighting & Power Company Post Office Box 1700 Houston, Texas 77001

Dear Mr. Horn:

I have provided the following information in response to your request regarding the 24-inch natural gas pipeline which currently passes through the area that will be converted into the Allens Creek cooling lake.

The pipeline is owned by Old Ocean Fuel Ccmpany, a wholly owned sub-sidiary of Texas Electric Service Company. The line will be relocated during construction of the Allens Creek facility to a location between the cooling lake dam and the Brazos River. This pipeline has been in operation for almost 20 years and has, throughout this period, carried only natural gas with a methane content of approxi=ately 90%. I have reviewed the gas analysis records for the past half year and these show that the lowest methane percentage carried in the line during this period was 88.8%.

l The pipeline is a major trunk line which receives gas from various suppliers for the account of Texas Utilities Fuel Company, affiliate company to Texas Electric, and delivers gas to various customers of Valero Trans-mission Company along the line from Ellis County to Brazoria County. The l

existing contract with the pipeline operator, the Valero Transmission Company, l

is to carry only natural gas and runs through September 1990. There are no l existing plans to carry any other materials in the line, and no changes are anticipated in the foreseeable future.

l You recognize that the size of the existing line, 24-inches in diameter, makes it highly unlikely that liquefied products would be carried in it, since because of the smaller volumes, they can be most economically piped in smaller 6-inch to 8-inch pipelines.

It should also be recognized that the design of the pipeline minimizes the possibility that the line could rupture. The line is designed with ,

cathodic protection in order to inhib.: the formation of rust. Cathodic

. Exh. WFM-2 l i .

CCvuissioN STATE DEPARTMENT OF HIGHWAYS ENGuvEE A-D' A t: TOR e o crataar a saw wa.cace cantauas AND PUBLIC TRANSPORTATION '

(('." ,C ,$""

P. O. Box 1386 Houston, Texas 77001 May 12, 1980 River Bank Erosion Protection p* atar atFEA TO l

Control 527-3 General "'"

Brazos River at FM 1458 in the vicinity of the Allens i Creek Nuclear Power Plant Site Austin County Houston Lighting & Power Company P.O. Box 1700 Houston, T exas 77001 i

Dear Sir:

This is to confirm the discussion in our recent meeting on May 1, 1980. In this meeting, we agreed the use of the " Hold That River" system (copy of the plan is attached) for the river bank protection at the subject location. The estimated construction cost for the whole system (49.50')

is $625,000. The cost for the control zone A-B section (as shown in the attachment) which is considered sufficient for highway protection, is

$350,000.

As for the cost participation between your Company and the State, we propose that HL&P should pay 50% of the cost for Control Zone A-B, and 100% for the portions outside of Zone A-B. This will make the State's portion of work amount to $175,000 and the HL&P's portion of work would be

$450,000.

If you concur with this method of participation, please advise so that we can tender an agreement to your office for signatures.

Very truly yours V

l A.

Omer F. Pool man District Engineer District No. 12 AC:vh Attachment RECEIVED MAY 15 G80 W. F. McGUIRE

s Mr. Paul Horn protection prevents oxidation (i.e., corrosion) which produces rust, through electrical means, by preventing loss of metallic ions from the pipe wall to the surrounding electrolyte (soil, water, etc.). Such protection will be provided along the segment of the line that is to be relocated near the ACNGS. In' addition, the line will be constructed and operated in accordance with the standards set forth by the Department of Transportation in 49 C.F.R.

Part 192. These standards bave been adopted by the Texas Railroad Commis-sion and are applicable to all pipelines located in the State of Texas.

Sincerely, Grady Langley i

Superintendent, Gas Operations GL:1w

-