ML19330C552

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

ML19330C552
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	07/09/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Marrack D MARRACK, D.
References
NUDOCS 8008080490
Download: ML19330C552 (11)

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REL.iTED connESPONDENCH .

s C3t$.7 g7 D SM p %!I UNITED STATES OF AMERICA {fSefL* fatty ,, . I NUCLEAR REGULATORY COMMISSION y g.h3DC3 Y j maj i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4/ / g y \~ ' j l

In the Matter of 5 5- .

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

(Allens Creek Nuclear Generating 5 Station, Unit 1) 5 HOUSTON LI M ING & POWER COMPANY'S RESPONSE ~ fj TO MARRACK'S FIRST SET OF INTERROGATORIES d TO ECUSTCN LIGHTING & POWER COMPANY In response to the interrogatories propounded by D. Marrack, Houston Lighting & Power Company (" Applicant")

answers as follows:

INTERRCGATORY NO. 1:

Clearly identify, including title, name of author (s),

date and literature reference, of [ sic] all documents you are relying on in your analysis and studies of the impact (s)

- of power transmission lines on migratory waterfowl.

ANSWER:

(a) Avery, M. L., 1978. " Impacts of Transmission Lines on Birds in Flight." FWS/OBS-78/48. U. S. Fish &

Wildlife Service, Dept. of Interior, Washington, D. C.

(b) Scott, R. E., et al, 1972. " Bird Deaths from Power Lines at Dungeness." British Birds, 63,, No. 7, July, p. 273.

(c) Anderson, S. H., 1979. " Changes in Forest Bird Species Composition caused by Transmission Lines Corridor Cuts."

American Birds, 33, No. 1,.Jan., p. 3. C> $

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800.8080  ;

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(d) Cornwall, G., Hochbaum, H. A., 1971. " Collisions with Wires-- A Source of Anatid Mortality." The Wilson Bull.,

83, 3 No. 3, Sept., p. 305.

(e) Stout, J., Cornwall, G. W., 1976. "Non-Hunting Mortality of Fledged North American Waterfowl." J. Wildl.

Manage., 40,,-No. 4.

.( f) - " Human Related Mortality of Birds in the United States." Richard C. Banks, United States Dept. of the Interior, Fish and Wildlife Service, Special Scientific Report Wildlife No. 215, Washington, D. C., 1979.

(g) " Waterfowl Studies at Lake Sangcris." DRAFT, Final Report Sept. , 1974 - April, 1975 Completed May 17, 1975, W. L. Anderson of Ill. ' Natural History Survey, Urbana.

(h) " Relation of Birds to Certain Power Transmission Lines in Central North Dakota." J. F. Cassel, Nov., 1979, Zoology Dept. North Dakota St. Univ.

(i) Copies of Manuscript submitted to Wildlife Society Bulletin, Feb. 21, 1977, " Waterfowl Collisions with Power Lines." William L. Anderson, Illinois Natur.1 Historic Survey, Urbana, 61801.

~ INTERROGATORY NO. 2:

Provide the full names, addresses and CV's of all those, on whose evidence you intend to rely, in support of your claim and position in the matter of Ccatention 2C.

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' ANSWER: '

Applicant at this time intends to rely upon the I

' testimony of Dr. Frank G. ' Schlicht, Principal Scientist, t

Environmental Protection Department,-Houston Lighting &

Power Co., P. O. Box 1700, Houston, Texas 77001. His resume is attached.

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-INTERROGATORY NO. 3: 1 State for persons named in 2./ the particular ,

qualifications which given them expertire in the area of the evidence from them, en which you are relying. .

ANSWER:-

As' the principal scientist of the Environmental Protection Department Dr. Schlicht is familiar with all environmental aspects of Applicant's power plants and associated transmission lines. As such, he is particularly. qualified to testify as to Applicant's experience with respect to the l

effect of its transmission lines on migratory waterfowl. I i

INTERROGATORY NO. 4:

l 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 transmission lines, of those sections, if -

any, of Applicant's power' transmission lines on which Applicant has conducted studies providing evidence or other data,

- relating to the matter of Contention 2C.

ANSWER:

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Houston Lighting: and Power Company has many miles of transmission lines which have been in existence for

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-several decades. These lines are regularly inspected for maintenance pur70ses. Applicant has no indication that 1

there have ever been any significant bird losses along any of its transmission routes and, therefort, has had no reason to conduct an analysis of the type described in this interrogatory.

INTERROGATORY NO. 5:

Provide the full 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 they used, the literature (title, authers [ sic] and reference by journal title, vol.,

page, date) consulted by those persons to establish the validity, or otherwise, of all methods each person used in the conduct of their- [ sic] part of the study, the quality control proceedures [ sic] they each used in conducting F'is study.

(c) Pro' ride 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 evidence from them, on which you are relying in the matter of Contention 2C.

ANSWER:

See answers 2 and 3 above.

I. INTERROAGORY NO. 6:

Provide all the records, field notes, draft docu-ments, memoranda, work notes, notations or other records made by all persons' involved in the matter of 4./; the L Applicants '[ sic] studies of the impact of transmission lines on migratory waterfowl. State the conclusion, if any, drawn from the study.

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i ANSWER:

See answer 4 above.

INTERROGATORY NO. 7:

What alternative sites and routes were considered for transmission lines from the proposed plant site and alternate plant sites? Provide a full description of these alternate routes and the assessment of each of these alternative routes / sites, transmission lines impact in the matter of Contention 2C and the date each assessment was made.

ANSWER:

The alternative transmission routes are shown in Chapter 3.of Applicant's Environmental Report and Environmental Report Supplement. The alternative sites evaluation is contained in Chapter 9 of Applicant's Environmental Report and Supplement. Neither Chapter 3 nor Chapter 9 contains a specific. comparison of sites according to impact of transmission routes on migratory waterfowl.

Respectfully submitted, OF COUNSEL:

B- WA J. Gregory Copeland C. Thomas Biddle, Jr.

BAKER & BOTTS Darrell Hancock 3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp l 1025 Connecticut Ave., N.W.

1025 Connecticut Ave., N.W.

Washington, D. C. 20036 Washington, D. C. 20036 ATTORNE'IS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY DH:03:G

RESUME Name:' SCHLICHT, FRANK G.

Title:

Principal Scientist, Environmental Protection Department, Houston Lighting & Power Company Academic: B.A. in Biology, Texas Christian University, 1960 M.S. in Zoology, Texas A&M College, 1963 Ph.D. in Zoology, Texas A&M University, 1969 Professional Experience: 1970 - Principal Scientist, Environmental Protec -

tion Department, Houston Lighting & Power Company 1969-1970 - Chief Biological Oceanographer, Oceanonics, Inc., Houston, Texas 1967-1969 - Instructor of Biology, San Jacinto College, Pasadena, Texas 1965-1967 - Graduate Fellow, Texas A&M University 1960-1965 - Research Assistant, Texas A&M University 1960 (Sn=mer) - Research Assistant, Institute of. Marine Science, Port Aransas, Texas 1958-1959 - Assistant Marine Biologist, Texas Game and-Fish Commission Scientific Societies: National Shellfisheries Association American Fisheries Society Sigma Xi, Associate Member Since joining Houston Lighting & Power in 1970, I have supervised the various ecological pro-grams conducted by the company. These programs have included studies on the overall impact of  :

onch-through cooling systems on the environment, )

mariculture associated with a once-through 1 cooling system, and effects of saltwater drif from cooling towers on territorial vegetation. I In addition to supervising these projects, I have been responsible for incorporating the findings of these and other studies into the design and operating practices of new and existing power plants in the HL&P system.

These include, but are not limited to, intake 1

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.I structure design, biocide selection and application, and impinged organism by-pass handling systems. J i

I was responsible for the ecological monitor-  !

ing programs at Allens Creek and South Texas Project nuclear sites and for the review of .

those sections ~of the respective Environmental Impact Statements that dealt with non-radi-ological ecological monitoring. I was also responsible for the development of a recre-ational plan, to include fishery management, for the Allens Creek Project cooling reservoir.

I have-served on the Electric Reliability Council of Texas ad hoc Water Quality Committee that represented the industry before the Texas Water Quality Board when new state standards l were being developed in accord with PL-92-500.

I have also served on the Edison Electric Institute (EEI) Water Quality Group a_d_ hoc committee that drafted the EEI comments on the PL-92-500 316(a) c' raft guidelines docu-ment. I was a member of the EEI RP-49 Steering Commirtee. I served as a member of the Elec-tric Power Research Institute's Energy Systems, Environment and Conservation Division, Task Force on Environment for six years, the last two as Vice Chairman.

I.was the principal environmental witness for EL&P before the Atomic Safety and Licensing Board for both the Allens Creek and the South Texas nuclear power plant projects.

? Publications: Schlicht, Frank G., 1959. First Records of the Mountain Mullet, Aqcnostomus monticola (Bancroft), in Texas. Texas Jour. Sci.,

11:181-182.

Little, John W., S. H. Hopkins and F. G. Schlicht, 1966. Acanthoparvphium spinulosu,m (Trematoda: Echinostomatidae) in Oysters at Port Isabel, Texas. Jour. Parasit.,

52:663.

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M*, a.eB-Schlicht, Frank G. and Wm. N. McFarland, 1967.

Incidence of Trypanorhynchan Plerocercoids in Some Texas Coast Sciaenid Fishes.

Contr.' Mar. Sci., 12:101-112.

Schlicht, Frank G. and J. G. Mackin, 1967. A Method for the Isolation and Culture of Labvrinthomvxa sp. -from Diseased Oysters Crassostrea vircinica (Gmelin). Texas Jour. Sci., 14:397.

Schlicht, Frank G. and J. G. Mackin, 1968.

Eexamita nelsoni sp.n. (Polymastigina:

Eexamitidae) Parasitic in Oysters. Jour.

. Invert. Path. 11:35-39.

Goldstein, R. J., R. N. Eenson and F. G. Schlicht, 1969. Acanthobothrium lintoni sp.n.

(Cestoda: Tetraphyllidea) from the Electric Ray, Narcine Brasiliensis (Olfers) in the Gulf of Mexico. Zool. Anzeiger, 181:435-438.

Skunnil., Edmund J. and Frank G. Schlicht, 1976.

Recreational Planning: Private Develop-ment of a Regional State Park. Engineer-ing Bulletin. 48:31-42.

Schlicht, Frank G., 1976. Impingement and Entrainment: An Overview for the State

. of Texas. In: Third National Workshop on Entrainment and Impingement. Sec-tion 316(b) - Research and Compliance.

Loren Jensen ed.' Ecological Analysts, Melville, N.Y.

! Mackin, J. G. and Frank G. Schlicht, 1976.

A Proteomyxan Amoeba Stage in the Develop-  ;

ment of Labyrinthomvxa patuxent (Hogue) I Macking and Schlicht, with Remarks on the i Relation of the Proteomyxids to the Neo- '

plastic Diseases of Oysters and Clams.

Mar. Fish Rev. 38 (10):16-18.

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a THE STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, THE' UNDERSIGNED AUTHORITY, on this day personally appeared Frank G. Schlicht, who upon his oath stated that he has answered-the foregoing Houston Lighting &

Power Company's Response to Marrack's First Set of Interroga-tories to Houston Lighting & Power Company in his capacity as Principal Scientist, Environmental Protection Department, Houston Lighting & Power Co. , and all statements contained therein are true and correct to the best of his knowledge and belief.

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Frank G. Schlicht SUBSC2 "*n AND SWORN TO BEFORE ME by the said Frank G. Schlicht, on this ffj day of O;du ,

1980. -

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Rotary ublic in anc, for Harris County, T e x a s My Conetssion Expires: l 1 9 m W b l- l f f 0 MARY E. MESSERSMITH Nelary Public in and for Harris County, Toxx 1

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. 7: SED > c UNITED STATES OF AMERICA Cf6 DS =,, [

NUCLEAR REGULATORY COMMISSION q

km{g ;;;( Q BEFORE THE ATOMIC SAFETY AND LICENSING BOARD / ~. #

b j ig In the Matter of 5 5

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

(Allens Creek Nuclear 5 Generating Station, Unit 5 No. 1) 5 G TIFICATE OF SERVICE I hereby certify that copies of the foregoing Houston Lighting & Power Company's Response to Marrack's First Set of Interrogatories to Houston Lighting & Power company were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 4 441 day of _ 3L lu , 1980.

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Sheldon J. Wolfe, Esc., Chairman 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. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing l Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 l Mr. Chase R. Stephens l Docketing and Service Section Atomic Safety and Licensing i Office of the Secretary of the Appeal Board I Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 1

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Jack R. ~ Newman, Esq. D. Marrack Lowenstein, Newman, Reis, 420 Mulberry Lane Axelrod & Toll Bellaire, Texas 77401 1025 Connecticut Avenue, N.W.

Washington, D.C. 20037 Ms. Brenda McCorkle 6140 Darnell Steve Schinki, Esq. Houston, Texas 77074 Staff Counsel U . S ~. Nuclear Regulatory Commission Mr. W. Matthew Perrenod Washington, D. C. 20555 4070 Merrick Houston, Texas 77025 Mr. J. Morgan Bishop 11418 Oak Spring Mr. Wayne E. Rentfro Houston, Texas 77043 P. O. Box 1335 Rosenberg, Texas 77471 Stephen A. Doggett, Esq.

P. O. Box 592 Mr. James M. Scott Rosenberg, Texas 77471 13935 Ivy Mount Sugarland, Texas 77478 Mr. John F. Doherty 4327 Alconaury Houston, Texas 77021 Robert S. Framson '

Madeline Bass Framson 4822 Waynesboro

. Houston, Texas 77035 Atomic Safety and Licensing Board Panel

~U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Carro Hinderstein 609 Fannin, Suite 521 Houston, Texas 77002 ,

CLAALbl. -]Md Darrell Hancock l

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