ML19343B831

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Forwards Applicant Direct Testimony in Environ Phase of Proceeding Scheduled to Begin 810112.Testimony Addresses Issues Re Cooling Lake,Energy Alternatives,Transmission Lines,Alternative Sites & Barge Slips
ML19343B831
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 12/18/1980
From: Copeland J
BAKER & BOTTS
To: Cheatum E, Linenberger G, Wolfe S
Atomic Safety and Licensing Board Panel
Shared Package
ML19343B832 List:
References
NUDOCS 8012300654
Download: ML19343B831 (5)
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Text

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BAKER & BOTTS ONE SMELL eL4za MouSToN, TEXAS 77oo2 wa S a'NGTCN O F'tCE TELEX 76 2779 i701 s t N N S YLV ANI A AVE.. N. N.

f ELECC M M U NICATIC N ma5MINGTON. 3 020006

7131229*tS23 WOUSTON TELEPwCNE.2021457 5 50 0 (202) 457-5534 wa5M4NGTCM, D. C.

December 18, 1980 Os Sheldon J. Wolfe, Esq., Chairman

'~

3 Atomic Safety and Licensing

[

n,, ^ p ',. f Board Panel i_

h q,., f* % }

U. S. Nuclear Regulatory Commission Ofr Washington, D. C.

20535

" 2?c,9" D Ce Dr. E. Leonard Cheatum 4

Route 3, Box 350A

/

to 9

J Watkinsville, Georgia 30677 Mr. Gustave A. Linenberger

~

Atomic Safety and Licensing Soard Panel U.

S. Nuclear Regulatory Connission L i, Washington, D. C.

20555 I

w Re:

In the Matter of Houston Lighting & Power Company-(Allens Creek Nuclear Generating Station, Unit 1)

Docket No. 50-466

Dear Members of the Board:

Enclosed herewith are copies of Applicant's direct l

testimony in the environmental phase of the proceeding l

scheduled to begin on January 12, 1981.

Copies of exhibits g503 i

referenced in the testimony are included with the testimony.

5 I

Applicant intends to present its witnesses in the following order:

lf l

A.

Cooling lake issues.

1.

Dr. Schlicht will be th9 Applicant's lead witness on the panel of witnesses to be presented on these l

issues.

Dr. Schlicht will testify as to the ex-pected productivity of the cooling lake, the effect of excluding the northern bluff area from the lake, the expected lack of thermal shock and the details of Applicant's chlorine minimization study.

S D123 ug (p Q

SAKER & SoTTs Page 2 2.

Dr. Tischler will testify that the water quality of the lake will not preclude the lake from being a viable recreational lake.

His testimony will cover the areas of chlorine releases, sewage discharges and heavy metals.

3.

Dr. Armstrong will testify that there is no risk f

to humans from ingestion of fish taken from the l

lake and/or ingestion of water from nearby water wells.

The testimony by this panel will cover TexPirg Contention i

Nos. 2 and 4 and Bishop Contention Nos. 12 and 21. 1/

3.

Energv Alternatives, 1.

Dr. Guy will be the Applicant's lead witness on the panel of witnesses to be presented on these l

' issues.

Dr. Guy will provide the Board with a description of Applicant's current load forecast and the current plans for new plant additions.

He will explain that nuclear, coal and lignite plants are the only alternatives available to the Appli-cant to meet its expected load and he will explain why the Company is attempting to include each of these three types of plants in its generation mix.

2.

Applicant will present two witnesses from NIRA.

j Dr. Anderson will present an independent load forecast.

Dr. Perl will testify that TexPirg's allegations with rcspect to conservation retro-fits, self-generation, peak load pricing, and passive solar heating and cooling do not alter the need for the Allens Creek project.

Dr. Perl will also testify on the cost of nuclear power as l

compared with western coal, Texas lignite, and natural gas.

l 1,/

Applicant has referred only to the contention numbers listed for the lead party on consolidated contentions.

A complete listing of the consolidated contentions is l

contained in Attachment C to the Staff's letter of l

July 18, 1980.

I

,,... ~...

sAnca & soTTs Page 3 3.

Dr. Hamilton will testify about the comparative health risks of lignite, coal and nuclear plants. 2/

4.

Dr. Woodson will testify that the generation of electricity by burning solid waste is hot a feasible alternative to the Allens Creek project.

5.

Mr. Simmons will explain that the construction of new interconnections does not present a possibility for reducing reserve margins and thus obviating the need for the Allens Creek project.

This castimony will cover TaxPirg Contention Nos. 5, 7 (a)-

(c), 7 (d), AC 8, AC 12, and Doggett Contention 1(b).

This testimony will also cover Board Question Nos. 1 and 13.

3/

C.

Transmission lines.

1.

Dr. Michaelson will testify that there is no health hazard to humans or animals living near the EHV transmission lines associated with the Allens Creek project.

This testimony will cover Rentfro Contention No. 2.

2..

Dr. Schlicht will testify that HL&P has had no adverse experience with waterfowl collisions with its transmission lines and that the literature on this subject indicates that the nanbar of water-fowl collisions with power lines is not biologically significant.

This testimony will cover Marrack Contention No. 2c and Board Question No. 11.

l D.

Barce slip.

i 1.

Mr. Hussey will testify that construction of the barge slip for unloading the reactor pressure vessel and the transportation of the RPV over land 2/

Dr. Hamilton's testimony will be mailed today from Washington under cover of a separate letter.

i l

3/

These Board questions are contained in,the order of July 31, 1980.

SAKER & SoTTs Page 4 will not create any significant envircr; mental impacts.

This testimony will cover TexPirg Con-tention No. AC 1, as well as the questions raised by the Board in its order of March 30, 1979.

E.

Alternative sites.

1.

Mr. McCuistion will be the Applicant's lead wit-ness on the panel of witnesses to be presented on these issues.

He will testify that EL&P has no right to construct its own unit at the STP site.

He will also testify that there is considerable uncertainty as to whether there 1.s an adequate supply of fresh water for a third unit at the STP site.

He will also testify that the Allens Creek site is a desirable site for construction of power plants and that the site will be used for that purpose even if a nuclear plant is not constructed on the site.

Mr. McCuistion will testify that the differences in impacts from transmission routes from the two sites are insignificant.

Finally, he will testify as to the cost and delay associated with moving ACNGS Unit 1 to the STP site.

2.

Mr. Finley will testify that the Allens Creek pro-ject will not adversely impact water supply in the Brazos River basin.

3.

Mr. VanSickle will testify that the City of Houston has no plans to import water from the Brazos River Basin.

4.

Mr. Hussey will testify that the preemption of the land at the Allens Creek site is not significant from the standpoint of agricultural productivity or terrestrial habitat.

5."

Mr. White will provide a review of the Applicant's prior population projections and compare those projections with more recent population studies.

6.

Mr. Schoenberger will testify that there are no available coastal sites which are obviously superior to the Allens Creek site.

aAxca & acrTs Page 5 7.

Dr. Hamilton will evaluate the comparative health risk to surrounding populations at the Allens Creek site and the STP site.

The testimony by this panel will cover TexPirg Contention No. 1, Hinderstein Contention No. 5 and Bishop Contention No. 1.

he Environmental Report is already in the record as Applicant Exhibit No.

2.

We will update the record by placing the Environmental Report Supplement into evidence.

Respectfully submitted, m M/

OF COUNSEL:

J.

regory o

anE C

Thoma 34 die, Jr.

BAKER & BOTTS rrell 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 1025 Connecticut Ave., N.W.

David Raskin Washington, D. C.

20036 1025 Connecticut Ave., N.W.

Washington, D. C.

20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY cc:

All parties Chase R. Stephens Atomic Safety and Licensing Appeal Board Atomic Safety and Licensing Board Panel (w/ copies of testimony and exhibits)

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