ML19326D646

Interrogatories & Requests for Production of Documents Re Intervenor Contention 2E That EIS Do Not Address Power Line Impacts on Migratory Waterfowl.Certificate of Svc Encl

ML19326D646
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	06/11/1980
From:	Marrack D MARRACK, D.
To:	HOUSTON LIGHTING & POWER CO.
Shared Package
ML19326D644	List: ML19326D643 ML19326D646
References
NUDOCS 8007030029
Download: ML19326D646 (5)

Text

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/ UNITED" STATES OF AMERICA -

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,BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _ ,

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. 1m;the* Matter of .-

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

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' 93 Station, Unit 1)

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' REQUESTS JOR PRODUCTION. QE. DOCUMENT _ - moi H5.:

INTERROGATORIES AND  : .= -

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TO HOUSTON LIGHTING & POWER COMPANY _

g E. l Pursuant to 10 CFR 52.740(b) and 52.741, Intervenor n

E David Marrack propounds the following Interrogatories

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and Requests for Prod'uction of Documents to Houston Lighcing

& Power Company, hereinafter called " Applicant". Each inter-rogatory should be answered separately ind, fully in writing under oath of affirmation by the person'or persons making ._

chem no later than 14 dayc af ter service of these Inter-rogatories and Requests for Production, and each document F

requested should be produced no later than 30 days after service of these Interrogatories and Requests for Production.

.g within the limits of the City of Houston for inspection and copying.

Each question is instructed to be answered in 8 parts ,

except where i.napplicable, as follows: ,

A. Provide the direct answer to the quastion.

}!t Identify all documents and studies, and the particular i B. ~~

parts ther$of, relied upon by the Applicant, now or in the past, which serve as the basis for the answer. Provide copies of any such documents.

C. Identify all documents and studies , and the .particular parts thereof', examined bte not relied upon by the Applicant, which pertain to the sub' ject matter ,

questioned. Provide a copy of each such document and study.

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.',, l3. ( y; D. Id:ntify by namr, title and effiliation cech Appliccnt .

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. ?.y  ;.saployee, consultant, contractor or subcontractor 2 ,. ,

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1 ;. 4 .. a , ~~ that has the expert knowledge required to support ..

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y the answer to 'the question. Identify by name',' '~

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..y-g ,<g. ~. ,yg,.y;, title and affiliation each person, as described . .;t.. .

'i above, who answers each question of these Interro-gatories.

E. Explain whether the Applicant is presently engaged or intends to engage in any further'research or work which may affect the Applicant's answer. ,

Identify such research or work. - -

F. Identify'the witnesses, expert or non-expert, if _

any, whom the Applicant intends to have testify -

on the suoject matter questioned. State the quali-fications of each suci- witness.

G. Provide a summary of the testimony each witness in part F above, is expected to offer and state the-factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

H. Identify all documents p ep.ned by, for, or under j the supervision of each such expert witness as ..

l identified in par,t F above. Include work papers, perliminahoutlinesandmemorandaandcommunicatinns between such expert and Applicant that are relied upon by such expert in formulating the expert's .

opinions and conclusion. Provide copies of any such documents.

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i Intervenor. D. Marrack's Interrogatories and Request for

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Documents relating to Contention 2C. "Ihat neither the Original FEIS or the Final Supplement EIS addresses the

,, impact of_ power lines on miers'.ory waterfew1. "

l 1- Clearly identify, including title, name of author (s), date and .

literature reference, of all documents you are relying on in your analysis and studies of the i.: pact (s) of power transmission lines

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on migratory waterfN1.

2- Provide the full names, addresses and CV's of all those,on whose evidence you intend t6 rely,in support. ofpur claim and position in the matter of Contention 2C.

3- State for persons naned in 2./ the particular qualifications which give them oxpertise in the area of the evidence from them, on which you are relying.

h- State the location, lengths, height above ground, number of lines, lateral distance apart of the transmission lines, voltage carried, distance between support towers, terrain below the transnission lines, of those sections, if any, of Applicant's power transmissien lines on whi:5 Applicant has conducted studies providing evidence, or other data, relating to the matter of Contention' 2C.

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5 Provide the fu11' names and addresses and Cv's of all those persons who (a) took part in any way, or supervised, or analyzed data from the studies you refer to in 4./.

(b) State the contribution of each person named in 5.a/

to the study 4./, the methods ed, the literature-(title, authers and reference by journal title, vol., page, date) consulted by those persons to

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'(b) Continued $2 - .[-- - I . - - - - .

E.f ~' establish the validity, or otherwise, of all '. -

l methods each person used in the conduct of -

. . their part'#o ithe study, the quality control' i

d j proceedures theyfused in conducting this study.

(c) Provide CV's, cite the experience and any  !

special training, studies, or directives received by those persons referred to in 5.a/.

(d) State for the persons named in 5.a/ the -

particular qualifications which, give them expertise in the area of the @~. dence from them, on 4.ich you are relying in the matter of Contention 2C. '

6- Provide all the records, field notes, draft documents, memoranda, verk notes, notations er other records made by all persons involved in the matter of 4./; the Applicants studies of the impact cf transmission lines on nigratory waterfowl. State the conclusion, if any, drawn from the study.

7- Nhat alternative sites and routes were considered fer transmission lines from the preposed plant site and alternate plant siteg ?

Provide a full descriptien of these alternate routes and the assessment of each of these alternative routes / sites, transmission l

lines impact in the matter of Contention 2C and the date each assessment was made. ~

I Respectfully submitted ~

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9. M D. Earrack-Intervenor Date

,f f~ f /pg 420 Mulberry IAne Bellaire, Texas 77401 l ,,

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UNITED STATES OF AMERICA , N

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• NUCLEAR REGULATORY COMMISSION g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DOCGTED

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d . > mna 2j O JUN 171980 > C In the Matter of 5 .

'O 5 { ga m%sergce Dodating a HOUSTON LIGHTING'& POWER S Emch COMPANY . . , , _

$ ' Docket No. 50-466 1; 6W +

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(Allens Cre k Nuclear i Generating 'tation, Unit 5 No.I) S // ]yg CERTIFICATE OF SERVICE I. hereby certify that copies of the foregoir.g were served on the following by deposit in the United mail, postage. prepaid, or by hand-delivery.

Sheition J' Tolfe, Esq. - Chairman Richard Lowerre, Esq.

Atomic Safety and Licensing Assistant Attorney General.

Board Panel U.S. Nuclear Regulatory Commission

(. for the State of Texas P .W . Box 12548 Washington, D. C. 20555 Capitol Station -

1 Austin, Texas 78711 Dr. E. Leonard Cheatum , ,

Route 3, Box 350A Watkinsville, Georgia 30677 Stephen A. Doggett, Esq.

P. O. Box 592 .

Mr. Gustave'A. Linenberger Rosenl; erg, Texas 77471 Atomic Safety and Licensing Board Panel Mr. John F. Doherty U.S. Nuclear Regulatory" Commission 4327 Alconbury

, Washington, D. C. 20555 Fouston, Texas 77021 Mr. Chase R. Stephens Robert S. Framson Docketing and Service Section Madeline Bass Framson Office of the Secretary of the 4822 Waynesboro Commission Houston, Texas 77035 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Carro Hinderstein ordo occh, Esq.

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'1701 Pennsylvania Avenue, N. W.

Washington, D. C. 20006 - Ms. Brenda McCorkle 6140 Darnell Houston, Texas 77074 Atomic Safety and Licensing Mr. W. Matthew Perrenad Appeal Board 4070 Merrick, U.S. Nuclear' Regulatory Houston, Texas 77025 Commission Washington, D. C. 20555 Mr. Wayne E. Rentfro P. O. Box 1335 Rosenberg, Texas'77471 Steve Schinki, Esq.

Staff Counsel Mr. James M. Scott U.S. Nuclear Regulatory Commission 13935 Ivy Mount Washington, D. C. 205F5 Sugar Land, Texas 77478