ML20062F939

Interrogs Propounded by St of Wi to NRC Staff.Interrogs Concern Staff'S Position Re Tech Merit of Each of Intervenor'S Admitted Contentions

ML20062F939
Person / Time
Site:	Kewaunee
Issue date:	11/30/1978
From:	Walsh P WISCONSIN, STATE OF
To:
Shared Package
ML20062F936	List: ML20062F932 ML20062F939 ML20062F943
References
NUDOCS 7812220029
Download: ML20062F939 (4)

Text

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v UNITED STATES OF AMERICA 'SY $.d NUCLEAR REGULATORY CCMMISSION

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In the Matter of Wiscensin Public Service

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Corporation, Wisconsin

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Power and Light Company, ) WK..,6 3 .. /

,j' and Madison Gas and Electric )

Docket No. 50- 5' Company, License No. DPR-43 )

(Kewaunee Nuclear Power Plant, )

Application to Modify Spent )

l Fuel Pool) ) p INTERRCGATORIES PROPOUNDED BY THE STATE OF WISCONSIN -

TO THE NUCLEAR REGULATORY COMMISSION STAFF -

Pursuant to 10 C.F.R. sec. 2.720 (h) (2) (ii) , the presiding -

officer is requested to order the Nuclear Regulatory Com-mission staff to answer the following interrogatories and serve the answers thereto upon Patrick Walsh, Assistant Attorney General, 114 East, State Capitol, Madison, Wisconsin 53702.

INSTRUCTIONS

1. Answer each interrogatory separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection must be stated in lieu of answer.

2. An evasive or incomplete answer is deemed to be a failure to answer under sec. 804.01, Stats.

3. You are under a continuing duty to seasonably supple-l l ment your response with respect to any questions directly addressed to the identity and location of persons having knowledge of discoverable matters, and the identity of each person expected to be called as an expert witness at trial.

Further= ore, you are under a similar duty to correct any incorrect response when you later learn that it is incorrect.

7812226028

4. The following terms are defined as follows for the purpose of these interrogatories.

A. Whenever in these interrogatories a request is made to " list," " describe," or " identify" documents, those terms shall be interpreted as a request to sur,sply as to each document the following information where such information is appropriate for each , document.

(1) The type of dccument (.e.g, letter, memorandum, report, study, etc.) ;

(2) The date of the document; (3) The date on which the document or copy thereof came to the staff's attention; (4) The name(s) of the signer (s) of the docu-ment, and the author (s) if different from the signer (s) ;

(5) The name (s) , if any, of the person (s) to when the document is addressed; (6) The present whereabouts of the document i or copy thereof and the name and address of the custodian thereof; j (7) Whether the document requested in these t

interrogatories was in existence or available to the staff but is no longer available or in existence; (8) Whether the staff claims that the document is privileged or otherwise not subject to discovery;

(9) A brief summary of the subject matter of the document; and (10) Whether the staff is willing to produce the dccument.

B. As used in these interrogatories, the term

" document" is used in a comprehensive sense and includes, without limiting its generality of meaning, all written, typed, printed, recorded, transcribed or graphic materials, however produced, copied or reproduced, of every kind and description.

C. Whenever in these interrogatories a request is made to state any facts, basis and/or information, in addition to stating the requested facts, basis and/or informa-tion, identify the natural person (s) most knowledgeable as to each such fact, basis and/or information and list all documents which relate to any such fact, basis and/or information.

5. All portions of these " instructions" shall be deemed to be a part of these interrogatories.

INTERRCGATOR!IS

1. Briefly state the staff's position as to the tech-

nical merit of each of the intervenor's admitted contentiens in this proceeding.

2. For each answer to inter:cgatory #1 above, please l state the witness and/or witnesses expected to testify at the bearing on behalf of the staff regarding the staff's position. -

3. For each answer to interrogatory #1 above, please state the technical report and/or reports or other documents relied upcn by the staff in formulating its position.

MM //- 3C - N BRONSON C. LA FOLLE*TE Attorney General O '

c uk /$/b PATRICK WALSH Assistant Attorney General 114 East, State Capitol Madison, Wisconsin 53702 (608) 266-7344

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