ML20062G145

Notifies Intervenor That They Failed to Address Section C of Interrogatories Relating to Bd Questions of 781109, Which Must Be Answered in Timely Writing

ML20062G145
Person / Time
Site:	Kewaunee
Issue date:	12/05/1978
From:	Evans D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Bast S AFFILIATION NOT ASSIGNED
References
NUDOCS 7812270037
Download: ML20062G145 (3)

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NUCLEAR REGULATORY COMMISSION

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Ms. Sandra A. Bast 1112 N. lith Street i-C 2

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WISC0flSIN PUBLIC SERVICE CORPORATION

1. G s-WISCONSIN POWER AND LIGHT COMPANY

1. N'F' AND MADIS0N GAS AND ELECTRIC COMPANY (Xewaunee Nuclear Power Plant)

Occket No. 50-305 Amendment to License No. DPR-43 (Increase Scent Fuel Storace Cacacity)

Cear Ms. Bast:

Pursuant to our telephone conversation this day, I am writing to confirm that in answering the Staff's Interrogatories of November 9,1978, the Intervenors failed to address section "C" which dealt with "Interrog-atories Relating to Board Questions." As we discussed, there were two such questions in that section, a copy of which you will find attached.

Since you assured me that this omission was simply an oversight on the part of the Intervenors, the Staff will not seek a formal Motion to Compel Discovery from the Atomic Safety Licensing Board, which it would have otherwise sought at this time.

I would remind you that these Interrogatories must be answered separately and fully in writing, under oath or affirmation, as were your earlier responses.

On another matter, I find that I erroneously informed you on the telephcne this morning that the abbreviation used in the Board's second question, ALAPA, meant "As Low As Reasonably Fossible." Of course, the proper.

meaning is "As Low As Reasonabl you in formulating your answer.y Achievable." I hope I have not misled The Staff appreciates your willingness to informally solve this problem in a timely fashion. As I understood you on the telephone, you expect to respond to the Staff within a day or so. Please be sure that your responses to Interrogatories C(l) and C(2) are served on all parties en the Service List.

Again, thank you for your cooperation in this matter.

7incerely, S

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fM/W David J. Evans Counsel /for NRC Staff Enclosures as Stated cc: See Pace 2 7812270 0 37 fM

- cc (w/ encl.):

Robert M. Lazo, Esq.

Mr. Glenn 0. Bright Dr. Oscar H. Paris Mrs. Wend Schaefer Ms. Mary Lou Jacobi Patrick Walsh, Esq.

Steven E. Keane, Esq.

Atomic Safety and Licensing Appeal Board Atcmic Safety and Licensing Board Panel Docketing and Service Section G

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1. With respect to Board question tio.1

, do you contend that remedial action could not be'taken or that time w s

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to institute such action should total loss ould not 6e available of cooling capability occur?

2. With respect to Board question tio. 2 licensee's evaluation inadequately addresses th, do you claim i

e occupation'l dose associated with the installation or operation of th a

I If your response is other than an unqualified e pool as codified?

incl ding references relied upon.

no, provide your basis u

Respectfully submittad,

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wM Jeffrey F. Lawrence Counsel for flRC Staff Dated at Bethesda, Maryland t his 9th day of ?!avember,1978 i

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