ML19263C419
| ML19263C419 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/19/1979 |
| From: | Redden J, Socolofsky J OREGON, STATE OF |
| To: | |
| References | |
| NUDOCS 7902220085 | |
| Download: ML19263C419 (4) | |
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UNITED STATES OF AMERICA c(9 k-:s
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2 NUCLEAR REGULATORY COM'1ISSION h
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3 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BbAR kL).'
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In tne Matter of
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6 PORTLAND GENERAL ELECTRIC
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Docket No. 50-344 COMPANY, et al
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(Control Building) 7 (TROJAN NUCLEAR PLANT)
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8 ANSWER OF THE STATE OF OREGON (IN OPPOSITION TO PETITION FOR STAY) 9 10 The Coalition for Safe Power has filed a Petition for 11 Stay of the Partial Initial Decision of the licensing board 12 in this matter which has authorized interim operation of the 13 Trojan plant pending permanent modifications.
14 To eliminate the possibility that no response from the 15 State might be interpreted as indifference to the Petition, 16 the State of Oregon hereby files this Answer in opposition to 17 the request for a stay of the licensing board's decision.
18 It is the position of the State that issues in this proceeding 19 which were framed by the Order for Modification of License, 20 dated May 26, 1978, have been more than adequately resolved 21 in favor of interim operation.
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'j j g 22 This intervenor filed no proposed findings w'th the
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It presented no direct testimony.
It has O
e go;;24 not demonstrated by its Petition that it has even a remote
" I ] 25 4!a6 likelihood of prevailing on the merits, let alone the Page Answer in Opposition for stay 7 9 0 2 2 2 0 0 f5
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" strong showing" required by 10 CFR 2.788 (4 ) (e).
2 On the other hand, the State has, independently of the 3
NRC staff, determined that it knows of no safety reasons 4
which should preclude the resumption c" cperations of this 5
facility.
The public interest of the State of Gregon definitely 6
is not served by the continued shutdown of this facility which 7
supplies such a large portion of the State 's power requirements.
8 Dated this 19th day of January, 1979.
9 Respectfully submitted, James A.
Redden 10 g
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12 John H.
Socolofsky Assistant Attorney General 13 of Counsel for the state of Oregon 14 15 16 17 18 19 20 21
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25 Page 2 - Answer in opposition for stay
CERTIFICATE OF SERVICE I hereby certify that on this 19th day of January, 1979, I served the within Answer of the State of Oregon to Petition for Stay of the Coalition for Safe Power upon all parties of record, by then depositing in the United States Post Office at Salem, Oregon, a full, true and correct copy thereof, addressed to the said parties of record, at the following addresses and prepaying the postage thereon.
Marshall E. Miller, Esq., Chairman Mr. Stephen M. Willingham Atomic Safety and Licensing Board 555 N. Tomahawk Drive U.S. Nuclear Regulatory Commission Portland, Oregon 97217 Washington, D.C.
20555 Mr. Eugene Rosolie Dr. Kenneth A. McCollom, Dean Coalition 17r Safe Power Division of Engineering, 215 SE 9th Avenue Architecture & Technology Portland, Oregon 97214 Oklahoma State University Stillwater, Oklahoma 74074 Robert Lowentstein, Esq.
Lowenstein Newman, Reis Dr. Hugh C.
Paxton
& Axelrad 1229-41st Street Suite 1214 Los Alamos, New Mexico 97544 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 Mr. John A.
Kullberg Route One Mr. David B. McCoy Box 2500 348 Hussey Lane Sauvie Island, Oregon 97231 Grants Pass, Oregon 97526 H.H.
Phillips, Esq.
Ms. C. Gail Parson Vice Prerident, Corporate 800 S.W.
Green #6 Counsel a.3d Secretary Portland, Oregon 97526 Portland G?.neral Electric Company 121 S.W.
Salmon Stren t William W.
Kinsey Portland, Oregon 97204 U.
S. Department of Energy Bonneville Power Administration Ms. Nina Bell P.O.
Box 3621 632 SE 18th Portland, Oregon 97208 Portland, Oregon 97214
Gregory Kafoury, Esq.
Counsel for Columbia Environmental Council 202 Oregon Pioneer Building 320 S.W.
Stark Street Portland, Oregon 97204 Robert M. Johnson, Esq.
Assistant Attorney General 100 State Office Building Salem, Oregon 97310 Elizabeth Scott 203 South 1st Street St. Helens, Oregon 97051 Joseph R.
Gray, Esq.
Counsel for NRC Staff U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C 2^555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary U.S.
Nuclear Regulatory Commission Washington, D.
C.
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,3,,, 1 '.4 ![ t John,H. Socolofsky Assistant Attorney General and Counsel Of Attorneys for the State of Oregon