ML19270H705
| ML19270H705 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/14/1979 |
| From: | Axelrad M, Rachel Johnson LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, PORTLAND GENERAL ELECTRIC CO. |
| To: | Mccollom K, Mark Miller, Paxton H Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8001020644 | |
| Download: ML19270H705 (4) | |
Text
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LAW O F riC E S LoWENSTEIN NEWM AN, REIs, AxEnnAn & TOLL 10 2 5 CO N N E CTI C U T AV E N U E, N. W.
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PETE4 o.FLvNee WILLIAM J.FAANut'N
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December 14, 1979 oo L
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.crN Marshall E. Miller, Esq., Chairman Dr. Hugh C. Paxton Atomic Safety and Licensing Board 1229 - 41st Street U.S. Nuclear Regulatory Commission Los Alamos, NM 87544 Washington, D. C.
20555 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture & Technology Oklahoma State University Stillwater, OK 74074 RE:
Portland General Electric Company, et al.
(Trojan Nuclear Plant)
Docket No. 50-344 (Control Building Proceeding)
Gentlemen:
Licensee has received a copy of the Board's Notice of Hearing on Trojan Interim Operation Motions and Order (December 12, 1979).
Licensee will appear at the special hearing scheduled on December 28, 1979, extending to December 29, 1979, if necessary, and will be prepared to provide such testimony, if any, as the Board may deem necessary to clarify, supplement or update previously filed informa-tion.
As the Board is aware, Licensee has always been prepared to provide all information deemed by the Board to be necessary in the discharge of its obligations in this proceeding.
Licensee will con-tinue to do so throughout this proceeding.
Licensee notes that the Board is treating as a motion the Li-consee's request in its letter of December 8, 1979 */ for a further order removing the prohibition on resumption of operation.
(Notice of Hearing, p.
3).
Licensee urges the Board to consider removing
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That letter forwarded Licensee's response to the Board's request for an "immediate" report.
In order to assure that the Board (Footnote continued on next page)
/
1672 085 8001 oco 6
LowEN sTrc tw, N EWM AN, H EIS, AXELHAu & TOLL Marshall E. Miller, Esq.
Dr. Hugh C.
Paxton Dr. Kenneth A. McCollom Page Two December 14, 1979 the prohibition on resumption of operation prior to the December 28 hearing.
The critical need for electricity at this time from the Trojan facility was described in the affidavit of Robert H.
- Short, President of PGE, attached to the. letter of December 8 and each day is of vital importance under the current circumstances in the North-west.
If, on the basis of the submittals by Licensee and those of the NRC Staff (including any response filed by the NRC Staff to the Licensce's request of December 8), the Board is assured that any alleged health and safety question relating to interim operation has been resolved to the Staff's satisfaction, it would unfairly penalize PGE and its consumers to require Trojan to remain shutdown unnecessarily until the hearing.
If the Board does not act as to resumption of Plant operation prior to the December 28 hearing, Licensee urges that it be prepared to rule on this subject at that session in view of the critical need for energy from the Trojan facility.
Respectfully submitted, Q. Aw(
h-c MAURICE AXELRAD, ESQ.
ALBERT V.
CARR.,
JR.,
ESQ.
Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue Washington, D.
C.
20036 RONALD W.
JOHNSON, ESQ.
Corporate Attorney Portland General Electric Company 121 S.
W.
Salmon Street Portland, OR 97204 (Footnote continued from page 1)
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and the parties receive such information as quickly as possible, in addition to service by mail, Licensee arranged for personal delivery to the Board and the parties by messenger on December 10, 1979.
1672 086
UNITED STATES OF AMERICA MUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPANY, )
Docket No. 50-344 et al.
)
-~ ~~
)
(Control Building Proceeding)
(Trojan Naclear Plant)
)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the attached letter from Maurice Axelrad to the Atomic Safety and Licensing Board in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, this 14th day ~of December, 1979:
Marshall E.
Miller, Esq., Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U.
S.
Nuclear Regulatory Commission U.
S.
Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D.
C.
20555 Dr. Kenneth A. McCollom, Dean Docketing and Service Section Division of Engineering, Office of the Secretary Architecture & Technology U.
S. Nuclear Regulatory Commission Oklahoma State University Washington, D.
C.
20555 Stillwater, OK 97074 (Original & 20 copies)
Dr. Hugh C.
Paxton Columbia County Courthouse 1229 - 41st Street Law Library, Circuit Court Room Los Alamos, NM 67544 St. Helens, OR 97051 1672 087
Joseph R.
Gray, Esq.
Atomic Safety and Licensing Counsel for NRC Staff Appeal Board U.
S. Nuclear Regulatory Commission U.
S.
Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D.
C.
20555 Ms. Nina Bell Ronald W.
Johnson, Esq.
728 S.
E.
26th Street Corporate Attorney Portland, OR 97214 Portland General Electric Company 121 S.
W.
Salmon Street Mr. Eugene Rosolie Portland, OR 97204 Coalition for Safe Power 215 S.
E.
9th Avenue Frank W. Ostrander, Jr., Esq.
Portland, OR 97214 Assistant Attorney General State of Oregon Mr. David B. McCoy Department of Justice 348 Hussey Lane 500 Pacific Building Grants Pass, OR 97526 520 S. W. Yamhill Portland, OR 97204 Mr. John A.
Kullberg Route One Williant W.
Kinsey, Esq.
Box 2500 Bonneville Power Administration Sauvie Island, OR 97231 P.O.
Box 3621 Portland, OR 97208 Ms.
C.
Gail Parson P.O.
Box 2992 Kodiak, AK 99615 1
l/ \\%i t'%<_.
I.
4 Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, NW Washington, D.
C.
20036 (202-862-8400)
Dated:
December 14, 1979 1672 088