ML19347B398
| ML19347B398 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 10/01/1980 |
| From: | Schlicht F HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML19347B383 | List: |
| References | |
| NUDOCS 8010140602 | |
| Download: ML19347B398 (20) | |
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-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5
5 HOUSTON LIGHTING &~ POWER COMPANY S
Docket No. 50-466 S
-(Allens Creek Nuclear Generating S
Station, Unit 1)
S AFFIDAVIT OF DR. FRANK G.
SCHLICHT I
I.
My name is Frank G. Schlicht.
I am Principal Scientist in the Environmental Protection Department of Houston Lighting & Power. Company _ (HL&P), a position I have held for more than ten years.
I am responsible for all ecological monitoring and research conducted by HL&P.
I have the additional responsibility of advising the Company how to treat particular ecological problems that occur from time to time.
A statement of my experience and qualifications is attached as Exhibit A.
-During this period, I have never receited a report of waterfowl losses due to collision with any of our trans-mission ' lines.
Moreover, our 345 kv system is inspected annually, typically in the early part of the year, and these inspections have never indicated problems due to waterfowl collisions.
During the past four years there have been four 3
8 010140 hd?Ihs
---,,c.
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-w.va,,-
i i
l reports of dead " heron-type" birds observed during these system inspections.
For approximately fifteen years EL&P leased lands j
i at the W. A. Parish Generating Station to rice farmers.
These rice fields were situated to within one-fourth mile of Smithers Lake, a 2,400-acre cooling pond owned by HL&P.
Smithers Lake has historically been utilized for feeding and roosting by migratory waterfowl.
When rice-fields were also on the property, waterfowl freely moved back.and forth between the lake and fields.
There are no known reports of waterfowl collisions with any of the facilities at this generating station.
In my capacities with EL&P, I have spent many hours in the field, some of which have been spent along or in c1cse proximity to ouritransmission system, much of which is near I
water and/or culNivated fields utilized by waterfowl.
I have never seen a bird collide with any of our lines nor have I ever found a dead bird of any kind along the rights-of-way that I have visited.
For more than thirteen years, EL&P has sponsored ongoing research projects at two of its power plants situated on the Galveston Bay system.
These projects have been conducted by personnel and graduate students of the Department of Wildlife and Fisheries Sciences at Texas A & M
University and Southwest Research Institute.
The laboratcry facilities at one of these power plants are adjacent to the discharge canal, the opposite side of which is paralleled by a 345 kv transmission line.
This area of the canal frequently has ducks on it during the winter.
During the many thousands of man-hours spent in the field by personnel associated with these projects, these :esearchers have never reported a bird collision with these transmission lines.
Waterfowl hunting is a major hunting activity in the immediate Houston vicinity.
Hunters come from all over the United States and Canada to enjoy the excellent hunting in the area and have been doing so for many years.
With the degree of hunting in the area and in view of the fact that j
HL&P has transmission lines in some of the areas hunted, it would seem reasonable to expect reports from the hunters or the professional guides if waterfowl collisions with these lines were a common occurrence.
HL&P has no record of having ever received a report or claim of this nature.
In sum, HL&P has never had a significant problem with waterfowl collisions with its transmission system.
II.
In 1973, the NRC requested EL&P to quantify expected waterfowl losses due to collisions with the transmission line segment proposed to cross ~the cooling lake.
A concerted.
effort was made to locate literature relevant to the issue, but very little was found in the literature addressing waterfowl collisions with transmission lines and towers.
This is borne out by the fact that only two of the papers cited by Dr. Marrack in the " References" to his motion-are dated prior to 1973.
Ivo papers brought to the attention of EL&P at that time were those by Stoddard (1962) and Stoddard and Norris (1967).
These latter two papers were, and still are, of little value in assessing waterfowl mortality due to trans-mission lines and towers.
They deal with mortalities due to striking a lighted TV tower-and its guy-wires.
Furthermore, after five and one-half years of study, Stoddard (1962)
~
reported only 43 waterfowl deaths out of a total of 15,251 casualties.
After eleven years of study at this site, Stoddard and Norris (1967) reported only 75 waterfowl casualties out of a total of 29,451.
This research found
...much evidence to indicate that guy-wires are very deadly."
This vast majority of birds involved were such species as warblers, vireos, etc. -- birds generally classified as passerines.
Transmission lines are neither lighted nor are the towers guyed.
Therefore, the physical structures studied by these authors are not comparable to an electric transmission line system.
Furthermore, these TV towers were 673 feet and -
1,010 feet in height, whereas 345-}cv transmission towers are normally 135 feet in height.
_The TV towers were lighted with three sets of'1,000 candlepower blinker lights and a large (unspecified) number of much weaker three-light installations, all of which apparently tended to attract migrating passerines on occasion, thus enhancing the-likelihood for collisions.
Since 1976, several papers that treat waterfowl collisions with transmission lines have~ appeared in the literature.
The first of these is the work of Stout and Cornwell (1976), who reported on nonhunting mortalities of waterfowl for the period 1930-64.
They recorded 2,108,880 mortalities during this time period, of which 3,015 deaths were attributed to collision, including collisions with automobiles, aircraft, telephone and power. lines, TV and radio towers, farm machinery, fences and buildings and "other objects".
Of these 3,015 collision related deaths, which represented 0.1 percent of the total sample, only 1,487 were due to telephone and power line collisions over the entire thirty-four year period.
This represented about.07 percent J
of the total nonhunting deaths.
Kroodsma (1977) studied non-hunting waterfowl deaths in the vicinity of a power plant near Red Wing, Minnesota and reported that less than one percent of the losses were due to power line colliaion.
(See Willard, 1978).
Anderson (1978) conducted fall studies from 1973 to 1975 of the waterfowl casualties at the Kincaid Power Plant in Illinois. 'This coal-fired plant is situated be-tween two arms of Lake Sangchris and a slag (bottom ash) pit is adjacent to the plant.
Two 345 kv lines generally parallel one arm of the lake and cross the slag pit.
The lake and the slag pit are used extensively by waterfowl-each year, with as many as 111,000 birds reported during the 1
month of November, gradually decreasing to a population of 10,000 birds or less during the winter.
These birds move extensively between the lake (2,154 acres) and the slag pit (79 acres), which supports a lush growth of acquatic vegeta-tion during the summer and fall and provides both food and grit for waterfowl.
Only 343 birds were reported to have collided with these lines durir.5 the three-year study.
This l
represents at most only 0.4 percent of the maximum number of l
birds present and utilizing the area.
Banks (1979) reported on human-related mortality l
of birds in the United States.
He found that only 0.64 percent of the total lossec. were due to collisions with "TV towers and 1
similar obstacles", which category would include transmission lines._ Speaking specifically of fences, electrical transmission i
lines, aircraft and "...almcst anything else that man places in the air", he concluded, "Annus' mortality from all of these 1 '
factors must be rather low."
His data do not indicate what portion of these losses were waterfowl.
In 1978 the U. S. Fish and. Wildlife Service sponsored a three-dty workshop at Oak Ridge, Tennesse, to examine the issue of bird collisions with transmission lines.
Representa-tives frcm fish and wildlife agencies, academia, conservation groups and the utility industry attended.
Proceedings of this workshop were edited by Avery (1978).
The following excerpts and summaries are from papers presented at this workshop.
i Willard (1978) stated that "...it appears that dead bird studies, even of game species, are inconclusive enough to limit their usefulness as predictive tools."
He further i
1 states, "While the literature tells us there is an agency which records the falling of each sparrow, that agency has not{seen fit to make its/his/her data available to me.
It i
is safe to say most nongame bird deaths are unrecorded, j
Again, I cannot quantify further."
Hoover (1978) said, "The overall impact of trans-mission lines on bird movements, however, is not fully understood, although it has been the subject of an increasing amount of research in recent years.
While there are many documented cases of birds of prey, waterfowl, and other large birds found dead or injured near transmission lines and towers,
-the exact cause of death or injury has often been indeter-minable." - _.. -
Fowler (1978) stated the Tennessee Valley Authority (TVA) knew of very,few documented bird collisions with its transmission system.
He went.on further to say that TVA had received no reports from biologists, the public or other agencies to indiJate the existence of a serious problem.
He pointed out that TVA biologists pay particular attention to transmission lines "...that pass near waterfowl refuges and other sensitive habitats...".
Amend (1978) said, " Biological significance, while no doubt an overall issue of considerable importance, is, I think, not likely to be demonstrable in relation to a single powerline,-except in rare cases."
Thompson (1978) addressed transmission line mitigation through engineering design and habitat modifica-tion.
He points'out that high-risk situations cannot now be predicted, a requisite for mitigation.
He questions, however, whether wire strikes are even biologically significant, when he says:
"A biologically significant impact is one which is long-term and which results in a measurable change in carrying capacity or ultimate population size.
In this respect, the impact of wire strike mortality on bird populations can be Judged biologically significant only if it exceeds the compensatory response capability of the population and thus results in a measurable population decline.
That this is the case with any waterfowl species is highly doubtful, l
1 since waterfowl populations are able to compensate for substantial hunting mortality, which is much greater than collision mortality (Anderson and Burnham 1976.'."
Lee (1978) reported on transmission line collision studies conducted by the Bonneville Power Administration (BPA) and concluded "...that birds at times collide with conductors or overhead groundwires.
To date, however, I am not aware of situations where BPA transmission lines represent a sigt.ificant avian mortality factor."
In their report on routing of transmission lines through waterfowl habitat in. California, Colson and Yeoman (1978), of P0cific Gas and Electric quoted Mr. Phillip Arend, their consultant, as stating:
"' Electric power transmission lines mounted on steel towers cause very minor avian loss,
)
and their adverse ecological impact on avian populations is negligible'."
Colson and Yeoman concluded, "The concern that transmission lines may pose a threat to some avian species has been raised periodically in California since 1970.
However, until recently little data existed to indi-cate that bird / power line interactions were worthy of specific study."
They added, "Even now, with an estimated 100,000 circuit. miles of transmission lines located in all repre-sentative habitats across the nation and with millions of resident and migratory birds, incidents of bird losses have seldom been-reported." -
4 Cornwell and Hochbaum (1971) reported on waterfowl collisions with wires.
They persons 11y observed only one collision with a barbed-wire fence and one with a trans-mission line.
They also cited two other reported collisions, again one with a barbed-wire fence and one with a telephone line.
This paper, like many others, is of no value in estimating waterfowl losses due to transmission line collisions, as no data are presented on the number of birds using the area or f,1ying in the vicinity.
in Scott, et al. (1972) reported only fifteen waterfowl deaths out of a total of 1,285 bird casualties at a transmission line passi-
.nrough a bird reserve adjacent to the Dungeness nuclear,cwer station over a six-year period.
This consitutes about one percent of the total losses.
Again, this paper does not present data on the total number of birds using the area during the study period and, therefore, it is useless for pre'dicting losses at other locations.
The paper by Anderson (1979) referenced by Dr.
Marrack is not germane to the issue.
It deals solely with changes in species composition that occur when a forested area is cleared for transmission right-of-way.
Neither waterfowl nor collisions are discussed.
It is my professional judgment that the extant literature does not reflect significant problems of waterfowl s
l ;
collisions associated with transmission lines.
All studies where the losses are compared to population indicate that less than one percent of the population is apt to be-lost due to collisions.
This is a biologically insignificant loss.
As Banks (1979) concluded, after reviewing hunting and all other human-related bird mortality:
"A relatively few species account for most of this mortality but continue to maintain large, harvestable populations, suggesting that the numbers of most bird species are er,sentially unaffected by'the human _ activities discussed."
III.
Dr. Marrack states that we have demonstrated a 4
lack of awareness of the potential problem of waterfowl collisionswithtransmissibnlines.
This allegation is simply not warranted.
As I discussed earlier, we have experienced no actual problem with collisions on our ex-isting transmission lines.
When we selected our original transmission routes for Allens Creek, a segment of one of the routes was to cross the cooling lake.
In the original Environmental Report we pointed out that this segment could cause some waterfowl mortalities during adverse weather conditions.
It was our opinion, however, that the number of losses would be insignificant.
The NRC Staff then asked us to quantify the expected number of losses.
In response we. -
made a literature search and determined that there was no literature demonstrating that there was a significant prob-lam with waterfowl collisions and there was no method of developing a dependable model that could be used to quantify predictable losses.
As a result of our research we were able to develop the factors that should be considered f.1 evaluating the potential for waterfowl collisions.
Based on these factors, we concluded that the number of collisions would be insignificant (ER Section 5.6.4).
Nonetheless, we ultimately agreed to move the line segment out of the cool-ing lake because of all of the Staff's concerns with the route.
These concerns included, in addition to potential waterfowl collisions, undesirable visual impacts and po-tential interference with recreational boating.
In my opinion, the l'atter two problems were the most compelling 3
1 d
reasons for taking the line segment out of the lake area.
Subsequent-review of the developing literature shows that our professional judgment was sound at the time.
The more detailed studies developed since 1973 show that there is no significant problem with waterfowl collisions, even at specific sites (such as Lake Sangchris) where one might expect a large number of collisior.s because of the particular circumstances at that site.
Now thct there is no line segment crossing the lake, there are no special or unique - - - - _ _
4 M
areas along the proposed rights-of-way that would have a greater tendency.to concentrate waterfowl than other sur-rounding areas.
With respect to the relocated portion of the South Texas Project (STP)-Dow-Velasco 345 kv line which Dr.
Marrack references, no real problem was ever demonstrated.
Again, this was a situation where HL&P voluntarily E7 reed to relocate a portion of this line to minimize potential fater-fowl impacts.
The Huntington Wells area on the Perry Ranch was reputed to be both a sanding area and roost for large numbers of wintering geese.
The proposed location for the 345.kv line was within a few hundred feet of Huntington Wells.
The issue arose as to whether this line would pose a significant threat to geese entering and leaving the area.
Of special concern was the~ fact that probably the largest concentration of Greater Canadian Geese, estimated at about j
100 birds, to winter on the Texas Coast does so at Huntington Wells.
The claimants recommended relocating the line to the
~
north to minimize potential impact on these birds.
When this matter was brought to my attention, I concurred that the line probably was too close to Huntington Wells and that relocation to the north would minimize risks.
However, I did not agree with the northernmost relocation route pro-posed by the claimants.
This would havg put the line as l..
close to the reported feeding area of these geese as our original location was to their sanding and roosting area.
Relocating the line to the south of Huntington Wells was not desirable as this would have put it on the northern edge of Perry Marsh, an area utilized by approximately 65,000 geese and several thousand ducks annually and therefore, present a greater potential risk to waterfowl than it would at the o-iginal location adjacent to Huntington Wells.
This issue was resolved by mutual agreement on a location approximately 2,500 feet north of Huntington Wells, or approximately half-way between the sanding-roosting area and the feeding araa, as I recommended.
I know of no comparable i
problems with the Allens Creek transmission routes.
IV.
I have examined the maps submitted by Dr. Marrack in his motion -- his figures marked II and III, that show the major areas utilized by waterfowl.
Based on these maps, there is no feasible way to relocate the proposed lines to avoid the areas utilized by waterfowl and their flight paths, as depicted on the maps.
The proposed plant site is to the
- west of these areas and the tie-points in our system are to the east.
Thus, these areas must be crossed at some point, if the plant is to:be tied into our system.
Relocation of the line to the south is of questionable value because the
l proposed line is currently on the southern fringe of the northern goose feeding and roosting area and to go south of the duck feeding and roosting area would still have the line in the flyway to the coastal marshes to the south.
As I discussed above, tnere is no problem with the present loca-tion of the line and there is no point in moving it to another location that would still cross these flight paths.
1
-.e --
Refe ences
- Anderson, S. H. 1979 whanges in forest bird species composition caused by transmission lines corridor cuts.
Am. Birds 33 (1) : 3-6.
Anderson, W.
L.
1978.
Waterfowl collisions with power lines at a coal-fired plant.
Wilul. Soc. Bull. 6 (2) : 77-83.
Banks, R. C.
1979.
Human related mortality of birds in the United States.
U. S. Dept. of Interior, Fish and Wildlife Service, Special Scientific Report - Wildlife No. 215.
Washington, D.
C.
16 pp.
Cornwell, G.
and Hochbaum, H. A.
1971.
Collisions with wires - a source of anatid mortality.
The Wilson Bull. 83 (3) : 305-306.
- Scott, R.
E.,
et al.
1972.
Bird' deaths from power lines at Dungeness.
Br. Birds 65 (7) : 273-286.
Stoddard, H.
L.,
Sr.
1962.
Bird casua2. ties at a Leon County, Florida TV cower, 1955-1961.
Bull. No. 1, Tall Timbers Research Station, Tallahassee, Fla. 94 pp.
- Stoddard, H.
L.,
Sr. and Norris, R. A.
1967.
Bird casualties at a Leon County, Florida TV tower:
an eleven year study.
Bull..No. 8, Tall Timbers Research Station, Tallahassee, Fla.
104 pp.
Stout, Jr. and Cornwell, G. W.
1976.
Non-hunting mortality of fledged North American waterfowl.
J. Wildl. Manage.
40 (4): 681-693.
The following papers are found in:
Proceedings of a workshop, Impacts of transmission lines on birds in flight.
M. L. Avery (ed.).
1978.
Oak Ridge Associated Universities, Oak Ridge, Tenn.
151 pp.
- Amend, S.
Response to keynote address:
10-11.
Colson, E.
W.
and Yeoman, E. H.
Routing transmission lines through water bird habitat in California:
87-90.
- Fowler, D.
K.
Response to keynote address:
8-9.
t
RESUME Name:
SCELICHT, 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 (Summer) - Research Assistant, Institute of Marine Science, Port Aransas, Texas 1958-1959 - Assistant Marine Biologist, Texas Game and Fish Commission 3cientific 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 tne Company.
These programs have included studies on the overall impact of once-through cooling systems on the environment, mariculture associated with a once-through cooling system, and effects of saltwater drift from cooling towers on territorial vegetation.
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 oi new and existing power plants in the EL&P system.
These include, but are not limited to, intake 1
C
.)
- c
t structure design, biocide selection'and application, and impinged organism by-pass handling systems.
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 Pro. ject 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 were being developed in accord with PL-92-500.
I have also served on the Edison Electric Institute (EEI) Water Quality Group ad hoc committee that drafted the EEI comments on the PL-92-500 316(a) draft guidelines docu-ment.
I was a member of the EEI RP-49 Steering Committee.
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 iullet, Agonostomus monticola (Bancroft, in Te'xas.
Texas Jour. Sci.,
11:181-182.
Little, John W.,
S.
H. Hopkins and F.
G.
- Schlicht, 1966.
Acanthocarvuhium spinulosum (Trematoda: Echinostomatidae) in Oysters at Port Isabel, Texas.
Jour. Parasit.,
52:663.
, D
r 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 Labyrinthomyxa sp. from Diseased Oysters Crassostrea vircinica (Gmelin).
Texas Jour. Sci., 14:397.
Schlicht, Frank G.
and J. G.
Mackin, 1968.
Hexamita nelsoni sp.n.
(Polymastigina:
Hexamitidae) Parasitic in Oysters.
Jour.
Invert. Path. 11:3S-39.
Goldstein, R.
J.,
R. N. Henson and F. G.
- Schlicht, 1969.
Acanthobothr1um lintoni sp.n.
(Cestoda: Tetraphyllidea) from the Electric Ray, Narcine Brasiliensis (Olfers) in the Gulf of Mexico.
Zool. Anreiger, 181:435-438.
Skutnik, 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, Mel~ville, N.Y.
Mackin, J..G. and Frank G.
Schlicht, 1976.
A Proteomyxan Amoeba Stage in the Develop-ment of Labyrinthomyxa pat'1xent (Hogue)
Macking and Schlicht, with Remarks on the Relation of the Proteomyxids to the Neo-plastic Diseases of Oysters and Clams.
Mar. Fish Rev. 38 (10):16-18.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
the Matter of S
S HOUSTON LIGHTING & POWER S
COMPANY S
Docket No. 50-466 5
(Allens Creek Nuclear S
Generating Station, S
Unit No. 1)
S AFFIDAVIT THE STATE OF TEXAS S
S COUNTY OF HARRIS S
I, FRANK G.
SCHLICHT, first being sworn certify that I have reviewed and am thoroughly familiar with the statements contained in the attached affidavit addressing intervenor Dr. David Marrack's contention 2 (c} on waterfowl and transmission lines and that all statementa contained therein are true and correct to the best of my knowledge and belief.
Frank G.
Schlicht SUBSCRIBED AND SWORN TO before me on this the
/dday of d6alov 1980.
[~ ~'
- ggg,
/
Notary Public in and for Harris County, Texas v
My Commission Expires 3 9-8'-l