ML19261D297

Answers C Hinderstein'S Second Set of Interrogatories & Requests for Production of Documents.Affidavit & Certificate of Svc Encl

ML19261D297
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	04/17/1979
From:	Copeland J, Culp R, Newman J BAKER & BOTTS, LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
References
NUDOCS 7906020107
Download: ML19261D297 (9)

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UNITED STATES OF AMERICA ,

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .._ -

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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.

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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.

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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.

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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.

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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.

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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

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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.

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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

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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.

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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

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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/. -

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