ML111670752
| ML111670752 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 03/15/1979 |
| From: | Ziemer P Wisconsin Public Service Corp |
| To: | Jennifer Davis NRC/IE |
| Shared Package | |
| ML111670754 | List: |
| References | |
| FOIA-92-510 NUDOCS 7905300004 | |
| Download: ML111670752 (2) | |
Text
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Ul ONSN PU L G" ERV CE COCRPO,:
~
P.O. Box 7200, Green y
Wisconsin 54305 CERTIFIED MAIL RET7RN RECEIT RECUESTED March 15.,
1979
- r. John G. Davis Acting Director Cice of 7-spection and Enforcement S. Nuclear Regulatory Com.ission ias.ington, D. C.
20555
Dear Mr. Davis:
On 7ebruar 22, 1979, your office issued an Order Iosing Civil Penalties aCan'sz Iisccnsin ?ublic Service Cornoration. cerators of the Kewaunee z.lear ?er
?lant, in regard to an incident which occurred or May 2, 1978.
O ur rasncnses referenced in the Order included snecific ointsof clarifica
.tions in regard to the May 2, 1978, even: which were absent from the NRC
.. nspection findings. Those clarifications cast sipificant doubt as to the accuracy of the NRC evaluation of the events of May 2, 1978.
We also noted that the cr::eria :or civil penal-ies issued by the NRC in Decenber of 1974 coes no: accress events such as the May 2, 1978, event and had recuested carizication from your office as to the svecific criteria considered avelicabie to these =2tzers.
Because we disagree with the NRC's evaluation of the cause of the event; because the NRC's investigation which led to the NRC conclusions was inconplete; because the NRC's interpretation of cur procedures is/was in error; because the NRC has not been able to identify the speciFic section of its own criteria for imposition of civil penalties which apply to the May 2,
- 1977, event; because the E Circular 76-03 which was providd -o licensees was inconlete and lacked detailed radiation field variation data known to the NRC; and because the actions constituting the May 2, 1978, event were taken on the basis of assuring safety of personnel and the plant; we hereby request a.hearing on this matter pursuant to 10 CFR 2.205(d).
Our Attorneys are filing under separate cover a formal request for the same.
SLicerely, resident 7 90 53 0 ftO/'.
P.O. tox 1200, Grc.n 54203 C
IIVIED MAIL o
y 1
TITETTRN, RE!CEIPT RIEOUESTED
- Eah15, 19 79 7-
--Z-1 0 - *c e-_
Mr. John G. Davis Acinrg Director e of Inspoction and Enforcev;ent E. Nuclear Regulatory Co:.mnission ahingtDon, D. C.
20555 "Ir Mr. Davis:
On Fabruary 22, 1979, your office issued zarn Order Imposing Civil Pcnalties saiwnst Uisconsin Public Service Corporation, operators of the I e
- uclear Pc;er Plant, in regard to an incident which occurred on May 2, 1978.
Our r-spons-s refernced in the Order included specific points of clarifica Lions in retard to the May 2, 1978, event uhich were absent from the NRC inspection findings.
Those clarifications cast significant doubt as to the accuracy of the NRC evaluation of the events of May 2, 1978.
We a1so noted at the criteria for civil penalties issued by the NRC in Decber of 1974 do'e not addrEss events such as the -May 2, 1978, event and had requested clzarification from your office as to the spacific criteria consid2red applicible to thac mtters. -Because e disagree with the NRC's evaluntion ot the cuse of the evcnt; because the NRC' s investigation which led to the 17C ccnclusionis was incomplete; because the NBC's interpretation of our procedures is/.as in error; bccause the NRC has not been able to identify the specific scction of its own criteria for imposition of civil penalties which apply to the Lay 2.
197E, event; because the IE Circular 76-03 which was provided to licensees incouplete and lacked detailed radiation field variation data kncn to c 7%-'; and because the actions constituting the May 2,
- 1976,
,v-nt wcr aban on the basis of assuring safety of personnel and the plant:
e h-reby request a hnaring on this matter pursunnt to 10 CYR 2.205(d).
Our Attorncv are filing inder separate cover a formalI request for the same.
Sinc'rely,,
s-den SD-~