|
---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence ML20010G0731981-08-24024 August 1981 First Set of Interrogatories Directed to NRC Re Contention 21.Certificate of Svc Encl.Related Correspondence ML19343B7071980-12-0505 December 1980 Response to First Set of Interrogatories & Request for Production of Documents from Util on Health Effects of Low Level Radiation.Certificate of Svc Encl.Related Correspondence ML19340C3141980-11-10010 November 1980 Response to W Schuessler Request for Addl Answers to First Set of Interrogatories.Applicant Is Not in Possession of Data Analyzing Hypothetical Significant Offsite Radiological Releases.Certificate of Svc Encl ML19339C0471980-11-0606 November 1980 Response to W Schuessler Second Set of Interrogatories & Requests for Production of Documents.Describes Discussions W/Austin County,Tx Sheriff Dept Re Evacuation Analysis. W/Affidavit,Prof Qualifications & Certificate of Svc ML20008E3971980-10-22022 October 1980 First Set of Interrogatories & Requests for Production of Documents Directed to E Cumings,R Griffith,L Johnston & R Lemmer Re Consolidated Contention on Effects of low-level Radiation.W/Certificate of Svc.Related Correspondence ML20062J4311980-10-20020 October 1980 Informal Request for Addl Responses to First Set of Interrogatories & Requests for Production of Documents,In Lieu of Motion to Compel.Includes Second Set of Interrogatories Directed to Util.Related Correspondence ML19347C1851980-10-14014 October 1980 Amended Response to First Set of Interrogatories.Info Includes Identity of Individuals Directing Site Selection. Certificate of Svc Encl.Related Correspondence ML19332B1801980-09-24024 September 1980 Response to Intervenor Schuessler First Set of Interrogatories & Requests for Production of Documents. Requested Documents & Certificate of Svc Encl ML19347A6951980-09-22022 September 1980 Response to Fh Potthoff Third Set of Interrogatories.Objects to All Questions Due to Irrelevancy.Affidavits & Certificate of Svc Encl.Related Correspondence ML19332A8501980-09-0909 September 1980 Further Response to Tx Pirg 16th Interrogatories.Discusses Future Prices of Gas,Nuclear & Coal Energy,Personnel Qualifications,Control Room Design,Safety Relief Valve Setpoints & Hydrogen Explosion.Certificate of Svc Encl ML19351D1451980-09-0505 September 1980 First Set of Interrogatories & Request for Production of Documents Soliciting Info Re Results of Accident at Site, Emergency Plan & Demographics.Certificate of Svc Encl. Related Correspondence ML19344D8731980-08-18018 August 1980 Response to Potthoff Second Set of Interrogatories. Percentage of Electric Generation by Natural Gas Will Be 68% & 21% by 1985 & 1990,respectively.Objects to Remaining Interrogatories.Certificate of Svc Encl ML19327A5091980-08-0101 August 1980 Second Set of Interrogatories Directed to Applicant. Questions Feasibility of Marine Biomass Farm as Alternative to Facility.Certificate of Svc Encl ML19327A5021980-08-0101 August 1980 Response to Applicant First Set of Interrogatories. Intervenor Has No Intention to Call Expert Witnesses at Present Time ML19327A2261980-07-28028 July 1980 Response to Financial Qualifications Intervenors Fourth Set of Interrogatories.Discusses Program Improvements Made as Result of South Tx Project Incidents,Prefiling Package & H Dean Testimony.Affidavit & Certificate of Svc Encl ML19330B2061980-07-25025 July 1980 Response to Jm & M Bishop 800705 Interrogatories & Requests for Production of Documents.Identifies Witnesses & Summarizes Substance of Testimony.Certificate of Svc & Prof Qualifications Encl.Related Correspondence ML19321B2591980-07-25025 July 1980 Response to 800709 Interrogatories & Request for Production of Documents.Includes Info Re Natural Gas Alternative, Conservation & Interconnect,Error in Computer Program & Technical Qualifications.Certificate of Svc Encl ML19321B2641980-07-25025 July 1980 Response to 800706 Interrogatories & Requests for Production of Documents.Includes Info Re Movement of Brazos River Toward Proposed Pipeline Route & Max Peak Overpressure for Each Critical Structure.Certificate of Svc Encl ML19330A7151980-07-23023 July 1980 Response to Potthoff First Set of Interrogatories.Objects to Majority of Interrogatories on Basis of Irrelevancy. Applicant Has Not Commissioned Study on Marine Bio Farm Feasibility to Provide Synthetic Gas.W/Certificate of Svc ML19330C5521980-07-0909 July 1980 Response to First Set of Interrogatories.Lists Documents Relied Upon in Study of Effect of Power Transmission Lines on Migratory Waterfowl & Identifies Experts.Affidavit, Resume & Certificate of Svc Encl.Related Correspondence ML19320C3151980-07-0909 July 1980 Response to Intervenor D Marrack 800508 Interrogatories. Identifies Expert Witnesses Expected to Be Called in Support of Consolidated Rentfro Contention 2.Affidavit & Certificate of Svc Encl ML19320C5611980-07-0909 July 1980 Interrogatories & Request for Production of Documents Directed to Nrc.Requests Factual Basis of Anticipated Testimony Re Natural Gas Use as Fuel & Subsequent Costs of Electricity.W/Certification of Svc.Related Correspondence ML19320C9271980-07-0909 July 1980 First Set of Interrogatories Directed to Houston Lighting & Power.Requests Factual Info Re U Fuel Sources,Costs,Method of Mining & Stripping,Site & Extent of Mining & Feasibility of Marine Biofarm for Synthetic Natural Gas Supply ML19320C2691980-07-0808 July 1980 Response to Applicant Second Set of Interrogatories & Request for Production of Documents Re Intervenor Pleadings Before ASLB & Aslab.Certificate of Svc Encl ML19330A3501980-07-0808 July 1980 First Set of Interrogatories Directed to NRC Re Financial Qualifications,Hearing Expectation & Witnesses Intended to Be Called ML19330A3421980-07-0808 July 1980 Fourth Set of Interrogatories Directed to Util Re Financial Qualifications.Includes Questions on Disciplinary Actions & Role of Houston Industries.Related Correspondence ML19320C2651980-07-0808 July 1980 Response to Applicant First Set of Interrogatories & Request for Production of Documents Re Impact of Transmission Lines & Fes ML19320C2701980-07-0808 July 1980 Response to D Marrack First Set of Interrogatories.Includes Statements Re Transmission Lines & Alternative Transmission Sites & Routes.Prospective Witness Fj Schlight Prof Qualifications,Affidavit & Certificate of Svc Encl ML19330B2091980-07-0606 July 1980 Interrogatories & Request for Documents Directed to Util. Requests Most Recent Population Projection Data & Methodology Used for Updating Projection.Related Correspondence 1982-06-15
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20042B2451982-03-15015 March 1982 Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041B5381982-02-22022 February 1982 Reply to Intervenors Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence 1982-07-02
[Table view] |
Text
. . -.
LIC nocuyENT ROOM ~ :i '.
UNITED STATES OF AMERICA ,
," / E' NUCLEAR REGULATORY COMMISSION ,,
/'s
',, (
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .._ -
'N J' In the Matter of S S
HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S
(Allens Creek Nuclear Generating S Station, Unit 1) S APPLICANT'S ANSWERS TO HINDERSTEIN'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS In response to the interrogatories and requests for production of documents propounded by Carro Hinderstein, Houston Lighting & Power Company (Applicant) answers as follows:
T'1TERROGATORY NO. 1: What are the additional hurricane and I;ooding precautions and what are the extimated (sic] costs per item, in 1978 dollars, that would be involved with building a coastal site as compared with the Allens Creek site?
ANSWER:
1.A. Differential costs have not been calculated in 1978 dollars. Differential costs have been previously esti-mated and are discussed in the ACNGS ER Section 9.2.1.3.4, page 9.2-5. Cost differentials are also considered in the site rankings in the " Nuclear Power Plant Siting Study" (December 1975) - Teknekron Energy Resource Analysts, l.B. See response to Interrogatory No. l.A.
1.C. None.
1.D. F. J. E. Storey, Manager of Projects, Ebasco Services, Inc, l.E-H. Applicant has retained Teknekron Energy Resource Analysts (TERA) to prepare testimony related to Hinderstein Contention 5 and to assist HL&P in responding to questions from the NRC Staff related to the Staff's ongoing alterna-tive sites analysis. Accordingly, TERA is presently doing further work related to this interrogatory, and Applicant intends to present testimony on this subject through Mr.
Edwin E. Schoenberger, Vice President of TERA. Mr.
2306 023 Y9060203g7
Schoenberger is expected to testify that there is no coastal site which is obviously superior to the Allens Creek site.
The documents he will be relying on in the formation of his expert opinion are as follows:
- 1. " Nuclear Power Plant Siting Study" (Dec.
1975) - TERA.
- 2. " Site Evaluation, Site BZ-1, Follets Island" (Jan. 1979) - TERA.
- 3. Letters of February 22, 1979 and March 9, 1979 from W. F. McGuire to R. W. Froelich.
Items 1 and 2 are available for inspection and copying at the Sealy Public Library or at the Applicant's Energy Development Complex in Houston. Copies of Item 3 have already been pro-vided to Intervenors. Any further documents or workpapers which are developed will be listed and produced for inspec-tion and copying within 30 days from the date of this request for production of documents.
INTERROGATORY NO. 2: What are the comparison points and weighting analyses comparing the Matagorda County site and the Allens Creek site that you used in site evaluation? Pro-duce the Environmental Report and Preliminary Safety Analysis Report referred to on p. 9.2-6 and 9.2-6A, Applicants ER, Vol. 3, of the Matagorda County site.
ANSWER:
2.A. The Allens Creek site was not compared with a specific site near the Gulf of Mexico. As stated in Section 9.2.1 of the ACNGS ER, the region near the Gulf of Mexico using saltwater was judged to be less desirable than one in the Brazos River Basin for the reasons described therein.
The Environmental Report and Preliminary Safety and Analysis Report for the South Texas Project, which is referred to on
- p. 9.2-6 and 9.2-6A of the ACNGS ER, is available for inspec-tion and copying at the Public Document Room, Matagorda County Court House, Bay City, Texas, or at the Applicant's Energy Development Complex, 12301 Kurland, Houston, Texas.
R.B. ACNGS Environmental Report, Section 9.2.1; letter incerning alternative site evaluation for ACNGS - E. A.
. rner (HL&P to R. L. Ballard (NRC), July 12, 1978; Applicant's response to questions 1 and 3, First Set of Interrogatories from Carro Hinderstein to Houston Lighting & Power Company.
2.C. None.
}
2.D. W. D. Patterson, President, Envirosphere Company.
R. M. McCuistion, Vice President, Houston Lighting
& Power Company.
2.E-H. See answer to Interrogatory No. 1.E-H.
INTERROGATORY NO. 3: Produce the document from the Office of the (Texas) Governor, Electric Power in Texas, Division of Planning Coordination, November 1972, referred to in the Final Environmental Statement, p. 9-5.
ANSWER:
3.A. The requested document is available for inspection and copying at the Applicant's Energy Development Complex, 12301 Kurland, Houston, Texas.
3.B-H. Not applicable.
INTERROGATORY NO. 4: Was lack of applicable technology ever considered in analyzing the desirability of a Gulf Coast site?
If so, give details.
ANSWER:
4.A. No.
4.B-H. Not applicable.
INTERROGATORY NO. 5: Give the approximate weight, length and greatest width'and depth of the reactor pressure vessel that is proposed to be barged up the San Bernard River.
ANSWER:
5.A. Reactor Pressure Vessel:
Weight: 892 tons without head Length: 74 feet with skirt Diameter: 22 feet Mounted on rig for shipping, total weight will be 1052 tons.
5.B-D. " Feasibility Study for Transporting Nuclear Pressure Vessel" (1974), submitted to the General Electric Company by American Rigging & Construction, Inc. and Marks Crane & Rigging Company. A copy of this document will be made available for inspection and copying at the Applicant's Energy Development Complex in Houston.
2306 025 5.E-H. The Applicant has retained Dames & Moore to prepare an environmental impact assessment of transporting the reactor pressure vessel to the Allens Creek site. This assessment will be presented through the testimony of an employee of Dames &
Moore; however, the specific witness has not been identified at this time.
INTERROGATORY NO. 5 (a) : State the approximate size of the barge needed to carry it, including width, depth and how much depth of the barge will be below the surface of the water.
ANSWER:
5.A. Length: 204.0 feet Broadth: 43.5 feet Depth: 12.7 feet Calculated Mean Drafts (fresh water) of Loaded Barge: 6.77 feet 5.B-H. See response to 5.B. and 5.E-H.
INTERROGATORY NO. 5 (b) : What is the cross section of the San Bernard at the proposed landing site? Include the depth of the water and the width of the channel at intervals meaccred close enough so as to give an accurate cross-section of the river bed.
ANSWER:
5.A. A cross section drawing at the proposed landing site is not available. The channel is maintained at 9' by 100' to river mile 27. The proposed off loading site is slightly downstream of this point.
5.B-H. See response to 5.B. through 5.H.
INTERROGATORY NO. 5 (c) : State whether items of this size and weight are barged up the San Bernard River as far as FM 522.
Give examples of other cargos, their weights, barge size, and submerged barge depth that are normally barged at this point of the River.
ANSWER:
5.A. Barge traffic frequents the river the total distance to FM 522. The largest barge has been 45 feet wide with a 7.5 foot draft.
5.B-H. See response to 5.B through 5.H.
2306 026 INTERROGATORY NO. 6: Have you applied for a permit from the Army Corps of Engineers, or otherwise informed them of your desire to barge the reactor pressure vessel up the San Bernard River? Produce any letters or documents relating to this question, dates and parties of any conversations pertaining thereto.
ANSUER:
6.A. No application for a permit from the Corps of Engineers regarding the transporting and off-loading of the reactor pressure vessel has been filed. The subject has been discussed by letter correspondence with the Corps of Engineers, who have stated that the proposed dock facility for unloading the vessel in the San Bernarc River does not appear to involve undue environmental problems.
6 .' B . Letter dated September 18, 1974 from Corps of Engineers to Mr. Paul Storm, American Rigging and Construction Company.
This letter is appended to the document identified in the response to Interrogatory No. 5.B.
6.C-H. See response to 5.C. through 5.H.
INTERROGATORY NO. 7: Have you entered into any agreement with the State of Texas regarding barging the reactor pressure vessel?
If so, give details as dates, what the agreement covered, etc.
ANSWER:
7.A. The only " agreement" the Applicant has made with the State of Texas is the commitment stated in Mr. D. R. Betterton's letter dated March 9, 1979 to Mr. Charles D. Travis, Texas Parks
& Wildlife Department, provided to all intervenors by Mr. J. G.
Copeland's letter dated March 12, 1979 to the Atomic Safety &
Licensing Board.
7.B. See response to 7.A.
7.C-H. Not applicable.
INTERROGATORY NO. 8: State your plans to disassemble the loading facility for the reactor pressure vessel, and to restore the San Bernard River bank in that area.
ANSWER:
8.A. Applicant has not finalized any plans regarding the disposition of the off-loading facility following delivery of the reacto': pressure vessel.
2306 027 8.B-H. Not applicable.
INTERROGATORY NO. 9: State *he date, and by whom and why the decision was made to definitely commit yourself to the use of the San Bernard for barging the reactor pressure vessel.
ANSWER:
9.A. This information is specified in the letter dated March 9, 1979 from Mr. D. R. Betterton (HL&P) to Mr. Charles D. Travis, Texas Parks & Wildlife Department. This letter was provided to all parties in this proceeding by the letter dated March 12, 1979 from Mr. J. G. Copeland to the Allens Creek Atomic Safety and Licensing Board.
9.B. See response to 9.A.
9.C-H. Not applicable.
INTERROGATORY NO. 10: State the method by which the nuclear pressure vessel is proposed to be taken from the barge and loaded onto a road vehicle.
ANSWER:
10.A. The reactor pressure vessel will be off-loaded from the barge to a road vehicle by using one or more Gantry Towers.
The proced'.e is similar to standard unloading practices used by the shipping industry.
10.B-H. See response to 5.B. through 5.H.
Respectfully submitted, OF COUNSEL: R Gregor C '.lanQ/ l BAKER & BOTTS rles G' ash 3000 One Shell Plaza 00 One he 1 Plaza Houston, Texas 77002 souston, Texas 77002 LOWENSTEIN, NEWMA14, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.
Washington, D. C. 20036 Washington, D. C. 20036 Attorneys for Applicant HOUSTON LIGHTING & POWER COMPANY 2306 028 STATE OF TEXAS S COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared D. R. Betterton, who upon his oath stated that he has answered the foregoing Houston Lighting
& Power Company's Answers to Hinderstein's Second Set of Interrogatories and Reciuests for Production of Documents in his capacity as Manager of the Environmental Protection Department for Houston Lighting & Power Company, and all statements contained therein are true cnd correct.
D. R. Betterton SUBSCRIBED AND SWORN TO BEFORE ME by the said D. R. Betterton, on this r7+A day of April, 1979.
$ 1 lu2lA $1 tbh '
Notarf Public' in and for Harris County, Texas A'.CELA ::!OMCLS S'.!iTri r:otary P;D 'c i.1 Fams Cot.n:/. Texas My Comm;s ten D.pires..MMMil8/k80 2306 029 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOuIC SAFETY AND LICENSING BOARD In the Matter of S S
HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S
(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicant's Answers to Hinderstein's Second Set of Inter-rogatories and Requests for Production of Documents in the above-captioned proceeding were served on the following by deposit in the United States mail, post ge prepaid, or by hand-delivery this /7d4 day of , 1979.
/ /
Sheldon J. Wolfe, Esq., Chairman L Richard Lowerre, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. LeRoy Valicek, Mayor Watkinsville, Georgia 30677 City of Wallis, Texas 77485 Mr. Gustave A. Linenberger Hon. LeRoy Grebe Atomic Safety and Licensing County Judge, Austin County Board Panel P. O. Box 767 U.S. Nuclear Regulatory Commission Bellville, Texas 77481 Washington, D. C. 20555 Atomic Safety and Licensing Chase R. Stephens Appeal Board Docketing and Service Section U.S. Nuclear Regulatory Office of the Secretary of the Commission Commission Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Atomic Safety and Licensing Board Panel R. Gordon Gooch, Esq. U.S. Nuclear Regulatory Baker & Botts Commission 1701 Pennsylvania Avenue, N. W. Washington, D. C. 20555 Washington, D. C. 20006 2306 030
Steve Schinki, Esq.
Staff Counsel U. S. Nuclear Regulatory Commission Wasnington, D. C. 20555 John F. Doherty 4438 1/2 Leeland Houston, Texas 77023 Madeline Bass Frams'on 4822 Waynesboro Drive Houston, Texas 77035 Robert S. Framson 4822 Waynesboro Drive Houston, Texas 77035 Carro Hinderstein 8739 Link Terrace Houston, Texas 77025 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401 Brenda McCorkle 6140 Darnell Houston, Texas 77074 F. H. Potthoff, III 1814 Pine Village Houston, Texas 77080 Wayne E. Rentfro P. O. Box 1335 Rosenberg, Texas 77471 James M. Scott, Jr.
8302 Albacore Houston, Texas 77074 SAATA/. -
land /
~
J Gregor Co 2306 031