ML20062E203

NRC Request for Production of Documents from & Interrogs to State of Wi Re Planned Testimony & Witnesses

ML20062E203
Person / Time
Site:	Kewaunee
Issue date:	11/09/1978
From:	Lawrence J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Shared Package
ML20062E194	List: ML20062E191 ML20062E203
References
NUDOCS 7812050252
Download: ML20062E203 (3)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION v.

BEFORE THE ATCMIC SAFETV AND LICENSING BOARD In the Matter of WISCONSIN PUBLIC SERVICE CORPORATION Docket No. 50-305 WISCONSIN POWER AND LIGHT COMPANY Amendment to License AND No. CPR-43

• MADISON GAS AND ELECTRIC COMPANY (Increase Spent Fuel Storage Capacity)

(Kewaunee Nuclear Power Plant)

NRC REQUEST FOR PRODUCTION OF DOCUMENTS FROM AND INTERROGATORIES TO THE STATE OF WISCONSIN The Nuclear Regulatory Commission (NRC) Staff hereby requests that the State of Wisconsin, pursuant to 10 CFR 12.740, answer separately and fully, in writing under oath or affirmation, the following interroga-tories within 14 days from the date of mailing of this document.

For each response to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of the response.

If additional information becomes available with respect to one or more of the answers after the State has answered these interrogatories, C

the Staff requests that the answers be amended in a timely manner to

_ provide such additional information.

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. .. r s The NRC Staff further requests that the State, pursuant-to 10 CFR-12.741, provide copies of, or make available for Staff inspection and copying, the documents designated by the State in response to certain of the accompanying interrogatories.

1. State whether you intend to present any witnesses or -

testimony in this proceeding on the subject of any admitted contentions or Board questions. Please answer separately for each such question or contention.

2. Provide the names, addresses, complete educational back-ground, all related professional experience and qualifications of those witnesses whom you intend to present with respect to contentions or questions identified in interrogatory 1.

3. Provide summaries of the views, positions, or proposed testimony which you intend to present with respect to admitted contentions or Board questions.

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4. Identify by author, title, date of publication, publisher, and section or page number all books, documents, and papers that you intend to employ or rely upon in presenting your positien, if any, with respect to admitted contentions or Board questions. Please provide copies of, or make available for Staff inspection and copying, these items.

5. Do you intend to take a position that any document prepared by the Applicant or NRC Staff is deficient? If so, please specify l

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... , o which documents and the particular portions thereof you regard as ,being-deficient and explain why they are deficient.

6. Identify by author, title, date of publication, publisher and section or page all books, documents, or papers 'th'at you intend to employ or rely upon in conducting your cross-examination of witnesses ,

who may testify in connection with admitted contentions or Board questions.

7. Identify any and all experts whom you expect to conduct cross-examination or to aid in the conduct of the State's cross-examination of Staff, Licensee, or Intervenor witnesses with respect to any admitted contention or Board question. Provide the addresses, complete educational background, all related professional experience and qualifications of such experts.

Respectfully submitted,

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. Jeffrey F. Lawrence Counsel for NRC Staff Dated at Bethesda, Maryland this 9th day of November,1978 e

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