ML20062F943

St of Wi'S Answers to NRC Staff'S First Set of Interrogs & Request for Production of Documents.St Does Not Anticipate Utilizing in Its cross-exam Any Documents Not Already Listed by Staff & Applicant Wips.Cert of Svc Encl

ML20062F943
Person / Time
Site:	Kewaunee
Issue date:	12/01/1978
From:	Walsh P WISCONSIN, STATE OF
To:
Shared Package
ML20062F936	List: ML20062F932 ML20062F939 ML20062F943
References
NUDOCS 7812220031
Download: ML20062F943 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION

's-J1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Ibe '

In the Matter of )

Wisconsin Public Service )

Corporation, Wisconsin ) Decket No. 50-305 Power and Light Company, ) Amendment to License and Madison Gas and Electric ) No. DPR-43 Ccmpany (Kewaunee Nuclear )

Power Plant) )

STATE OF WISCONSIN'S ANSWERS TO NRC STAFF'S FIRST SET OF INTERROGATORIES, AND REQUEST FOR PRODUCTION OF COCUMENTS IDa*%;;

The State of Wisconsin answers the interrogatories and#b, t request for production of documents propounded by the Nuclear Regulatory Commission staff as follows:

1. Answering interrogatory #1, at this time the State of Wisconsin has not employed any witnesses in this proceeding on the subjects of any of the contentions admitted in this action. A search for qualified witnesses is, however, under way, and should one or more be secured, the state will inform the parties to this proceeding i= mediately and previde the information requested.

2. Answering interrogatories (2, $3 and #4, the information sought therein is not directly applicable to the state at this time. Should the state 's positien change, as detailed above, the state will provide the necessary informatien at that time to all parties.

3. Answering interrogatory 45, the state is unable to answer interrogatory 45 at this time, since it dces not knew which documents prepared by the applicant er NRC 781222 003/

staff will be relied upon.

4. Answering interrogatory 46, the state does not at this time anticipate utilizing in its cross-examination any other documents besides those which will probably be listed by the staff and the applicant in their answers to interrogatories in this proceeding. Should the state determine that other documents not listed will be relied upon in cross-examination, the state will inform the other parties of this fact.

5. Answering interrogatory #7, no experts are expected at this time to be utilized in cross-examination.

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• PATRICK WALSH Assistant Attorney General Subscribed and sworn to before me this .#' day of December, 1973.

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BARBARA M. LIVICK, being first duly sworn, on odEh' s '

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deposes and says that on the 1st day of December, 1978, she served the attached Interrogatories Propounded by the State of Wisconsin to the Applicants, Interrogatories Propounded by the State of Wisconsin to the Nuclear Regulatory Commission Staff and State of Wisconsin's Answers to NRC's First Set of Interrogatories and Request for Production of Documents upon:

Jame Schaefer Steven E. Keone 624 Mayflower Avenue David A. Baker Sheboygan, Wisconsin 53081 Foley and Lardner, Law Offices 777 East Wisconsin Avenue . . .

Ms. Sandra A. Bast Milwaukee, Wisconsin 53202 1112 North lith Street Manitowoc, Wisconsin 54220 Ms. Mary Lou Jacobi Lakesbore Citizens for Victor Stello, Jr. 84fe Energy Director, Division of Operating 932 North 5th Street Reactors Manitowoc, Wisconsin 54220

' United States Nuclear Regulatory Robert M.-La:o, Esq.

Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Docketing and Service Section U.S. Nuclear Regulatory Com-Office of the Secretary mission U.S. Nuclear Regulatory Com- Washing ton, D.C. 20555 mission

Washington, D.C. 20555 Jeffrey F. Lawrence

! Office of the Executive Legal i Dr. Oscar H. Paris Director Atomic Safety and Licensing U.S. Nuclear Regulatory Ccm-l mission i

Board Panel l U.S. Nuclear Regulatory Cem- Washing ton, D.C. 20555 mission Washington, D.C. 20555 Joan Kaeiser 1552 South lith Street l Mr. Glenn O. 3right Sheboygan, Wisconsin 53031 Atomic Safety and Licensing Board Panel l '-

U.S. Nuclear Regulatory Com-Washi o C.C. 20555 d Ild- 6 k 3ARSARA M. LI7ICK l

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