ML19270H154
| ML19270H154 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/24/1979 |
| From: | Baker D, Keane S FOLEY & LARDNER |
| To: | |
| References | |
| NUDOCS 7906230077 | |
| Download: ML19270H154 (4) | |
Text
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NRC PUIitC LCUMEN1' ROOM I
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,,O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f
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BEFORE THE ADMINISTRATIVE LAW JUDGE
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In the Matter Of
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Docket No. 50-305
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WISCONSIN PUBLIC SERVICE CORPORATION
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License No. DPR-43 (Kewaunee Nuclear Power Plant)
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ANSWER TO NOTICE OF HEARING Pursuant to the Rules of the Nuclear Regulatory Commission, 10 C.F.R. 52.705, Wisconsin Public Service Corporation ("WPSC") by its undersigned counsel, hereby answers the Notice of Hearing dated April 30, 1979.
(1)
The nature of WPSC's defense or other position is that the Notice of Violation is in error, that no violations occurred, and that no civil penalty can properly be imposed.
(2)
WPSC controverts both issues specified in the Notice of Hearing, contending that no violations occurred as stated in the Notice of Violation and that the Order Imposing Civil Penalties cannot be sustained.
(3)
WPSC does plan to appear and present evidence.
No material facts are alleged in the specification of issues except the ultimate conclusions noted above.
WPSC 2247 299 79062300 7 7
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i denies the commission of any violations and the propriety of any civil penalty.
Dated this day of May, 1979.
STEVEN E. KEAIE DAVID A. BAIGR By fu n [
DAVID A. BAKER Attorneys for Wisconsin Public Service Commission OF COUNSEL:
FOLEY & LARDNER 777 East Wisconsin Avenue Milwaukee, Wisconsin 53202 271-2400 (414) 2247 300 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter Of
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Docket No. 50-305 WISCONSIN PUBLIC SERVICE CORPORATION
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(Kewaunee Nuclear Power Plant)
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License No. DPR-43 AFFIDAVIT OF MAILING STATE OF WISCONSIN
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SS.
CTNTY OF MILWAUKEE
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DIANNE M.
KLOMAN, being first duly sworn on oath deposes and says that she is a resident of the State of Wisconsin in the County of Milwaukee, and is an employee of the law firm of Foley & Lardner, attorneys at law; that on the 24th day of May, 1979, she served the annexed pleading as follows:
she deposited a true copy of said papers in a United States Post Office Box in the City of Milwaukee, Wisconsin, enclosed in a postpaid envelope duly addressed to the following persons at the following addresses:
Executive Legal Director U.S. Nuclear Regulatory Commission
.iashington, D.C.
20555 Mr. James P. Murray Director and Chief Counsel Rulemaking and Enforcement Division
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Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Mr. Stephen G.
Burns U.S.
Nuclear Regulatory Commission Of fice of Executive Legal Director Washington, D.C.
20555 Mr. James Lieberman U.S. Nuclear Regulatory Commission Of fice of Executive Legal Director Washington, D.C.
20555
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Of J jp,, ;c DIANNE M.
KLOMAN Subscribed and sworn to before me this 24th day of May, 1979.
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"0TARY P.UBLIC State of Wisconsin
.'il:aukee County My Commission expires 12/14/80.
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