ML19246C340
| ML19246C340 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/25/1979 |
| From: | Ostrander F, Redden J OREGON, STATE OF |
| To: | |
| References | |
| NUDOCS 7907240310 | |
| Download: ML19246C340 (9) | |
Text
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h3C EWLIC DOCUllENT RCLOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TFE ATCMIC SAFETY AND LICENSING SOARD In the Metter of
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Docket No. 50-344 PORTLAND GENERAL ELECTRIC
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(Control Building
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Proceeding - Phase II)
(Troj an Nuclear Plant)
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STATE OF OREGON RESPONSES
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TO NRC STAFF INTERROGATORIES iv, g, /
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JAMES A. REDDEN Attorney General FRANK W.
OSTRANDER, JR.
Assistant Attorney General 500 Pacific Building 520 SW Yamhill Portland, Oregon 97204 lelephone:
(503) 229-5725 Attorneys for State of Oregon June 25, 1979.
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STATE OF OREGON RESPONSES TO NRC STAFF INTERROGATORIES 1NTERRCGATORY G-1.
" State whether or not you intend to call any person or persons as witnesses in this proceeding to testify wi-a re-gard to
"(a) the contentions which were admitted by the Licensing Board in its Prehearing Conference Order of April 12, 1979
"(b) the general issued (sic) in Phase II of this proceeding with regard to the scope a2.d timeliness of the mociiications required by the NRC Order of May 26, 1978, and provide the names, addresses, educational background, and professional qualifications of those persons you intend to call."
RESPONSE TO INTERROGATORY G-1.
At this time, the State of Oregon believes that it will call at least one witness to testify in this proceeding.
De-pending on the information developed by the NRC Staff Safety Evaluation, the discovery process, and Oregon's investigations, additional witnesses may be called by Oregon.
Because the in-formation generated to date in the proceeding is incomplete, the scope of any testimony cannot be determined.
At this time, Oregon believes that it will call Professor Harold I.
Laursen, 1520 NW 13th, Corvallis, Oregon, 97330.
3h 1 - STATE OF OREGON'S RESPONSES TO NRC INTERROGATORIES
Professor Laursen's qualifications were present :d during Phase I of this proceeding, and appear on pages 1 thraugh 4 of his Direct Testimony.
INTERRCGATO?Y G-2
" Indicate whether those persons identified in response to Interrogatory No. G-1(a) and (b) will appear voluntarily or under subpoena."
RESprNSE TO INTERROGATORY G-2 Professor Laursen will appear voluntarily.
INTERROGATORY G-3
" Provide summaries of the views, positions, or proposed testimony of all persons named in response to Interrogatory G-1 that you intend to present as witnesses during this pro-ceeding on
"(a) each admitted contention as to which you will present testimony
"(b) the general issue as to the scope and timeliness of the modifications required by the NRC Order of May 26, 1978."
RESPCNSE TO INTERROGATORY G-3 This material will be provided when sufficient information is available cn which to base Oregor 's testimeny.
360 32.3 2 - STATE 7e CREGCN'S RESPONSES TO NRC INTERROGATORIES
INTERROGATORY G-4.
" Identify by author, title, date of publication and pub-lisher, all books, documents, and papers that you intend to rely upon in presenting your direct case on
"(a) those admitted contentions as to which you will present testimony
"(b) the general issue es to the scope and timeliness of the modifications, if you intend to present a direct case on thio matter, and provide copies of, or make available for Staff inspection and copying, these items."
RESPONSE TO INTERROGATORY G-4.
See Response to Interrogatory G-3, above.
INTERROGATCRY G-5.
"If the views, positions or summary of proposed testimony set forth in response to Interrogatory G-3 are based in whole or in part on any documents prepared by the Licensee or NRC Staff which you contend are deficient, specify which dccuments, and the particular portions thereof, you regard as deficient and explain why they are deficient."
RESPONSE TO INTERROGATORY G-5.
"ee Response to Interrogatory G-3, above.
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3 - STATE OF OREGON'S RESPONSES TO NRC INTERROGATORIES
INTERRCGATORY G-6.
"(a) Have you undertaken or do you intend to undertake any analysis, evaluation, study or review of the proposed mod-ifications either in preparation for the hearing in Phase II of this proceeding or in connection with the State of Oregon's own regulation of the Trojan facilitj?
"(b) If the answer to (a) is
'yes", please
"(i) identify the person or persons who are engaged in such analysis, evaluation, study or review and give their professional qualificaticns
'(ii) describe the nature and extent of the analysis, evaluation, study or review (e.g. what aspects of the modifications is it directed to; are independent calculations or tests being per-formed, does your investigation include inspections of the Troj an plant)
"(iii) summarine the results of the analysis, evaluation, study or review to date and your position on the proposed modifications based on your work done to date
"(iv) provide copies of any reports, dccuments, or other written materials generated thusfar as a result of your analysis, evaluation, study or re-view of the modifications or make such items available for NRC Staff inspection and copying."
360 3n<3 4
4 - STATE OF OREGCN'S RESPONSES TO NRC INTERRCGATORIES
RESPONSE TO INTERROGATORY G-6.
See Response to Interrogatory G-3, above.
At this time, Professor Laursen and the staff of the Cregen Department of Energy are reviewing the information provided to date by the NRC staff and the Licensee.
As necessary, independent stud-ies or evaluations by Oregon may be undertaken in the future.
INTERROGATORY G-7.
" Identify by author, title, date of publication and pub-lisher, all books, documents or papers that you intend to employ or rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in connection with the proposed modifications. "
RESPONSE TO INTERROGATORY G-7.
See Response to Interregatory G-3, above.
Respectfully submitted,
%~%u, QY FRANK W.
OSTRANDER, JR.
Assistant Attorney General Of Attorneys for State of Oregon
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5 - STATE OF OREGON'S RESPONSES TO NRC INTERRCGATORIES
UNITED STATES OF AMERICA NUCLEAR REG'tLATORY COMMISSION EFFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket No. 50-344 PORTLAND GENERAL ELECTRIC
)
)
(Control Building
)
Proceeding - Phase II)
(Troj an Nuclear Plant)
)
AFFIDAVIT OF FRMIK W.
OSTRANDER, JR.
STATE OF OREGON
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County of Multnomah )
Frank W.
Ostrander, Jr.,
aeing duly sworn, deposes and says that he is the Assistant Attorney General representing the State of Oregon, and that the ansvers contained in State of Oregon's Responses to NRC Interrogatories dated June 25, 1979 are true and correct to the best of his knowledge and belief.
f A)e I FRANK W.
OSTRANDER, JR.
Assistant Attorney Ge'eral n
SUBSCRIBED AND SVOPR TO before me this
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day of June, 1979.
Sotary P' blic for Gregon My Commission Expires.
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1 - AFFIDAVIT OF FRANK W.
OSTRANDER, JR.
CERTIFICATE OF SERVICE I,
Frank W.
Ostrander, Jr.,
hereby certify that on this 15 day of Juna, 1979, I served the within " State of Oregon Responses to NRC Interrogatories" upon the following parties of record by then depo _iting in the United States Post Office at Portland, Oregon, full, true, and correct copies thereof, addressed to the said parties of record at the following ad-dresses listed below, and prepaying the postage thereen:
Marshall E.
Miller, Esq., Chair.
Mr. David B. McCoy Atomic Safety and Licensing Board 348 Hussey Lane U.S.
Nuclear Regulatory Comm'n Grants Pass, Oregon 97256 Washington, D.
C.
20555 Ms.
C.
Gail Parson Dr. Kenreth A. McCollom, Dean 800 SW Green # 6 Division cf Engineering, Portland, OR 97206 Archite<:4.ure & Technology Oklahoma Ctate University Ronald W.
Johnson, Esq.
Stillwater, Oklahoma 74074 Corporate Attorney Portland General Electric Dr. Hugh C.
Paxton 121 SW Salmon Street 1229-41st Street Portland, OR 97204 Los Alamos, New Mexico 97544 William W.
Kinsey Mr. John A.
Kullberg 1002 NE Holladay Route One, Box 2500 Portland, OR 97232 Sauvie Island, Oregon 97231 Ms. Nina Bell Columbia Environmental Council 632 SE 13th 203 S.
1st Street Pcrtland, Oregon 97214 St. Helens, Oregon 97051 Mr. Stephen M. Willingham Joseph R.
Gray 555 N.
Tomahawk Drive Counsel for NRC Staff Portland, Oregon 97217 U.S.
Nuclear Regulatory Comm'n Washingten, D.
C.
20555 Mr. Eugene Rosclie Coalition for Safe Pcwer
.'laurice Axelrad, Esq.
215 SE 9th Avenue Lcwenstein, Newman, Reis, Portland, OR 97214 Axelrad & Toll Suite 1214 1025 Connecticut Avenue NW Washington, D.
C.
20036 9n 360,3co a
1 - CERTIFICACE OF SERVICE
Dr.
W.
Reed Johnson Atomic Sa'ety and Licencing Atomic Safety and Licensing Appeal Board Panel Appeal Board U.S.
Nuclear Regulatory Comm'n U.S.
Nuclear Regulatory Comm'n Washington, D.
C.
20555 Washington, D.
C.
20555 Atomic Safety and Licensing Alan S.
Rosenthal, Esq.
Appeal Panel Atomic Safety and Licensing U.S.
Nuclear Regulatory Cc=m'n Appeal Board Washington, D.
C.
20555 U.S-Nuclear Regulatory Comm'n Washington, D.
C.
20555 Docketing and Service Section Office of the Secretary Dr. John H.
Buck U.S.
Nuclear Regulatory Comm'n Atcmic Safety and Licensing Washington, D.
C.
20555 Appeal Board U.S.
Nuclear Regulatory Comm'n Washington, D.
C.
20555
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FRAIU~ W. OSTRANDER, JR.
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Assistant Attorney General Of Attorneys for State of Oregon
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2 - CERTIFICATE OF SERVICE
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