ML20024A688
| ML20024A688 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/13/1983 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8306220057 | |
| Download: ML20024A688 (5) | |
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EA% RED CORRESPONDENcp 8
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{0l YMy g UNITED STATES OF AMERICA g
1 NUCLEAR REGULATORY COMMISSION 3@ i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- 8 In the Matter of
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N: i mUSTON LIGHTING AND POWER
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Docket Nos. 50-498 OL COMPANY, ET AL.
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50-499 OL
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(South Texas Project,
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Units 1 and 2)
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CITIZENS CONCERNED ABOUT NUCLEAR POWER (CCANP)
SUPPLEMENTAL ANSWER TO APPLICANTS' SEVENTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
,7 I. INTRODUCTION In a filing dated May 31, 1983 CCANP provided responses to Applicants' seventh set of interrogatories. Subsequent to that filing, CCANP received additional information relevant to those interrogatories.
CCANP herein supplements its initial answers. See also Attachment 1.
As stated in the initial answers, CCANP does not accept the premise that the present location of the South Texas Nuclear Project is or can
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be an acceptable site for the placement of a nuclear power plant. At h
'the same time, CCANP is answering the Applicants' interrogatories as if the inquiry to be made by the licensing board is a meaningful inquiry.
All documents relied upon are available for inspection and. copying in Austin, Texas or, if Applicants so desire, CCAN?'will resnond to
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requests for copying of particular documents.
l II.SUPPLEMENTALAhhERS 5
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- 1. Hurricane Allen in 1980 was one of the most spectacular and dangerous l
hurricanes yet recorded. "On three separate occasions - and for at least
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I 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> each time - Allen mustered sustained winds of at least 170 miles
'n per hour, qualifying the storm as a '5','on the Simpson scale of 1 to x
l 5 (with the highest number denoting the gre'ai:est intensity). When Allen s
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, passed north of the Yucatan Peninsula on the morning of August 7, the mammoth storm's mass virtually covered all of'the western half'of the
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Gulf of Mexico.... What is more, its central pressure had bottomed out l
l at an incredible 26.70 inches, and sustained winds near the center were
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gaged at an astounding 183 miles per hour."I l
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- e Allen " inexplicably but fortuitously weakened a few hours before it roared ashore just south of Port Mansfield," demonstrating again the highly unpredictable nature of these storm systems.
- 2. While most hurricane spawned tornadoes are smaller in width and travel shorter distances than non-hurricane generated tornadoes, there are exceptions. "[M]any of Allen's tornadoes were especially significant because of their strength, longevity, and movement through several heavily-populated areas of South Central Texas."3 One tornado had a width of 600 feet and traveled 47 miles.
- 7. Hurricanes and tropical storms bring heavy rains. Hurricane Fern in September 1971 brought up to 26.0 inches of rain to the Coastal Bend area of Texas.5 Ntropicalstormin1981droppedsomuchraininthedrainagebasin of the Lavaca River that the flood crest reached 41.2 feet.0 A resulting concern is the cumulative effect of heavy rains in the Colorado River drainage basin while a storm surge prevents the river emptying into the Gulf. The consequent flooding of the area around STN? would be more severe than that caused by the storm surge
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or the river flooding alone; the flooding river would add its overflow to the storm surge waters moving across the land.
i FOOTNOTES
- 1. Bomar, George W., "1980: When Scorching Heat Gripped Texas," Texas Department of Water Resources, LP-187, January 1983'at 72.
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- 2. Id. at 71.
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- 3. Id.. at 99.
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- 4. Id. at 99, 100
- 5. Storm Data, U.S. Dept. of Commerce /NOAA, Vol. 13, No. 9, 1971 at 169; Climatological Data: National Summary, U.S. Dept. oc Commerce /NOAA, l
Vol. 22. No. 13 1972 at 749.
- 6. Bomar, George W.,
"1981: A Year of Torrential Downpours," Texas i
Department of Water Resources, LP-183, December 1982 at 71.
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.. 10. All answers are by Lanny Alan Sinkin.
Res ectfully submitted,
%.y N
~ E LannyAlanSinkin Counsel for Intervenor Citizens Concerned About Nuclear Power 2207 D Nueces Austin, Texas 78705 (512) 478-3290 Dated: June 13, 1983 STATE OF TEXAS
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COUNTY OF TRAVIS
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hEFOREME,theundersignedauthority,onthisdaypersonally appeared LANNY ALAN SINKIN, who upon his oath stated that he has supplemented hir answers to Applicants' Seventh Set of Interrogatories and Requests for Production of Documents to CCANP in his capacity as counsel for Citizens Concerned About Nuclear Power, Inc. and that all statements contained therein are true and correct to the best of his knowledge and belief.
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LANNY ALAN SINKIN SUBSCRIBED AND SWORN TO BEFORE ME by the said LANNY ALAN SINKIN on this 14th day of June 1983.
M d-Notary Public in and for Travis County, Texas My Commission expires:
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e ATTAC101ENT 1 5 12 Austin American statesman Monday, June 13, 1983 e
Storms, ancie:nt zur' is tracea State's fear of hurricanes follows long, turbulent past Hurricanes y.K",'*7y',{4, -.,g.g g g(,g., y &y**7
".~'pl Carla killed 34 Texans, despite the GALVESTON (AP) q.'
evacuation of 250,000 coastal residents.
h'.ve killed thousands of Texans this cen-g.
,. 47 ;' Property damage was estimated at $200 tury, and damage from the violent tropi-w d.yg :bry 3 4,O-a million, and crop losses were put at $100 cal cyclones is estimated at hundreds of Lq d
millionsof dollars.Butweatherresearch-w.
ers say hurricanes have plagued man-h d' p
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4 p;,G:s Carla's wind custs were clocked at 175 kind long before there was an Alamo.
fr (IU.%, $~g % M'.% 1.[i'P nmn. It was tne largest and most mtense Even the name " hurricane"is ancient.
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Gulf Coast hurricane in many years, with hN Experts report the Mayans feared the much of the damage attributed to unusu-GhMQ,]M / ". -/. rg[T*\\. f,M-Q g@,f ally prolonged W
,g ferocious "hunrakin," while Indians in 5m @fyA'wAar Guatemala talked of the devastation t *s flooding.
from a "hurakan." The Carib Indians
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HURRICANE BEULAH was next to
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~~, ' $$ arrive in Texas. It moved ashore called the storms "urican," "aracan," or
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, hulranvucan.
Weather records show more than 100 k) 4.wg? t..h,. *i p%,-d Brownsville Sept. 20.1~67
.V b people in South Texas before turning hurricanes have hit Texas since 1766. But..
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- T Q southward into Mexico the next day. Five cnly 19 are classified as major storms.
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The deadliest struck Galveston Island ( '\\
h ~ $#.W of the deaths came from the record tium-in September 1900. Called the worst na-
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- ber of tornadoes - 115 - spun off from 8i w
Beulah. Property losses were estimated j
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tural disaster in U.S. history, the power-7M
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r3 at $100 million, with crop damage from 6
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fut storm claimed at least 6.000 lives and caused damage estimated at $30 million ' k' Mg,M jJ Jg I. ' flooding estimated to be $50 million.
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Three years later, in 1970, Corpus c
13 $40 million' wW
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M'f i. Christ! was the target of Hurricane C J
TPE ACTUAL DEATH count was nev-h struck the coast Aug. 3 and moved
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er determined, but records show the toll u.- p jy g g j % westward.
could have been as high as 8,000.
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Celia roared schere with 130 mph Mj 1
Flfteen years later, another hurricane hit Galveston - this time in August.
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winds eusttne to 161, killmg 11 people and YJs7I% QMy causing $50 million in damage.
%~,7# ~.8 i *'k'.';jg"o"@o The official death toll was estimated at 5
275, much lower than the great 1900 Then began a more tranquil' decade.
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storm because storm-wary residents had Texas was hit by several tropical storms
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raised the grade of the island and had Lessons from hurricanes, like the and had minor brushes with hurricanes.
built a seawall to protect them from surg-ne that hit Galveston in 1961, help. It wasn't until 1980 that the Lone Star ing tides blamed for most of the fatalities keep injuries and damages down.
State was again threatened by a major from any hurricane. Damage from the hurricane.
1915 storm was set at $50 million.
IN THE 1950s, meteorologists began IT WAS CALLED Allen and was billed Another coastal city was unable to sur-calling hurricanes by women's names.
vive the onslaught of killer hurricanes. The first storm so designated to hit Texas "the storm of the century."
Indianola, once a flourishing port, was arrived in 1957.
Satellite pictures showed M].tB illlD8 f
Ebandoned after being leveled by storms Hurricane Audrey was blamed for 10 the entire Gulf of Mexico. Its winds b 1875 and 1886.
deaths in Southeast Texas June 27. The reached 185 mph. But Allen stalled off This century, storms hit Freeport in storm then cut diagonally across Louist.
Brownsville and weakened, finally mov-July 1909. Corpus Christi in August 1916; ana and Alabama.
. Ing ashore Aug. 9 at an unpopulated area south of Corpus Christi in September of the lower coast.
1919; north of Brownsville in September From Sept.11 to 13,1961, Hurricane Two drownings were reported'in Cor-1933, Matagorda Bay in August 1942, east Carla assalted Texas. The storm struck Cf Galveston in July 1943, Port O'Connor the coastal bend and moved directly pus Christi and damage was estimated at in August 1945 and Freeport in October north. Even though its strength dimin- $55 million as high winds, rain and tidal 1949. These storms claimed 417, lives. Ished ever land, remnants of the storm surges affected cities-along the entire Damage was at least $100 million.
managed to cross Canada. -
coast!!ne and inland for many miles.
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UNITED STATES iF AMERICA
[, k, NUCLEAR REGULATORY C0:! MISSION
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BEFORE Tile ATOMIC SAFETY AND LICENSING E0ARD CERTIFICATE OF SERVICE C$,
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'L I hereby certify that copies of CITIZENS CONCERNED ABOUT NL POWER (CCANP) SUPPLEMENTAL ANSWER TO APPLICA':TS' SEVENTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS was served by in the United States Mail, first class postage paid to the deposit following individuals or entities on the 14th day of June 1983.
tharles seennoeter, tsq.-
Will'iam S. Jordan, Esq.
Chief Administrative Judge Harmon and W'iss a
Atomic Safety and Licensing 1725 I Street, NK Board Panel Suite 506 U. S. Nuclear Regulatory Commission Washington, D.C. 20006 Washington, D.C. 20555 Jack R. Newman, Esq.
Dr. J ames C. Lamb, III Lowenstein, N'ewman, Reis &
Administrative Judge Axelrad 313 Woodhaven Road 1025 Connecticut Avenue, NW Chapel Hill, NC 27514 Washington, D.C. 20036 Ernest E. Hill Robert G.
Perlis Administrative Judge Office of the Executive Lawrence Livermore Laboratory Legal Director University of California U.S. Nuclear Regulatory Commissior P..O.
Box 808, L-123 Washington, D.C.
20555 Livermore, CA 94550 Mrs. Peggy Buchorn Atomic Safety and t.feensing Board Executive Director U. S. Nuclear Regulatory Comm.
Citizens for Equitable Washington, D.C. 10555 Utilities Route 1. Box 1684 Atomic Safety and Licensing Brazoria Texas 77411 Appeal Board U. S. Nuclear Regulatory Comm.
Brian Berwick, Esq.
Washington, D.C. 20555 Assistant Attorney General for the State of Texas Docketing ano Service Section Environmental Protection Office of the Secretary U. S. Nuclear Regulatory Comm.
Division P.O. Box 12548, Capitol Station Washington, D.C.
20555 Austin, Texas 78711 Tom Hudson, Esquire Baker and Botts LannySinkin One Shell Pla::a Ilouston, Texas 77002 e
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