ML20054L533
| ML20054L533 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/30/1982 |
| From: | Wilt D SUNFLOWER ALLIANCE |
| To: | NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20054L534 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8207080218 | |
| Download: ML20054L533 (2) | |
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UNITED STATES OF AMERICA 3
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NUCLEAR REGULATORY COMMISSION 0111C605 e
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BEFORE THE ATOMIC SAFETY & LICENSING BOA DodB@I h
Bvr V sat IN THE MATTER OF:
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CLEVELAND ELECTRIC ILLUMINATING
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i CO.,
et al.,
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Docket Nos. 50-440-OL
[ Perry Nuclear Power Plant,
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50-441-OL Units 1 & 2]
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THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO NUCLEAR REGULATORY COMMISSION TO EXECUTIVE DIRECTOR FOR OPERATIONS NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C.
20555 Pursuant to 10CFR $2.744, Sunflower Alliance, Inc., et al.,
an intervenor in this proceeding, requests the Nuclear Regulatory Commission to produce and either furnish copies of or permit intervenors to inspect and copy any of the following documents responsive to this request which are in the possession. custody or control of the Commission.
This Request for Production of Documents is also continuining in nature anc the Nuclear Regulatory Commission must produce immediately any additional documents the NRC obtains which are responsive to the request.
STATEMENT OF PURPOSE One of the admitted contentions in this proceeding deals with emetgency response plans of the applicant.
The following documents relate to emergency planning and are discoverable under the rules of the Commission.
Sunflower ip a recent Motion to Compel Discovery discusses the breadth of the discovery rules and Sunflower incorporates into this request the argument set forth in the Motion to Compel.
Further, some of the documents are of general interest and while they don't relate to any particular contention are discoverable under the rules cf the Commission.
8207080218 820630
$DRADOCKOSOOO DOCUMENTS TO BE PRODUCED PD 1.
NUBEG-0348, " Demographic Statistics Pertaining to Nuclear Power Reactor Sites", October 1979;
'D503
e 2.
" Examination of Off Site Radiological Emergency Measures for Reactor Accidents Involving Cormelt", June 1978, Sandia Laboratories; 3.
NUREG-0771 " Regulatory Impact of Nuclear Reactor Accident Source Term Assumptions", June 1981; 4.
NUREG/CR-0388 " Accident Response for Emergency Response Exercise Scenarios", November 1978, Sandia Laboratories; 5.
Letter dated August 14, 1980, from Dr. William R.
Stratton of Los Alamos Scientific Laboratory and Drs. A. P.
Malinauskas and D. O. Campbell of Oak Ridge National Laboratory to NRC Chairman John Ahearne, re:
Iodine Source Term; 6.
SECY-80-504, November 13, 1980.
Report to Commission on Iodine Source Term;
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7.
NUREG-0885, Issue 1, "U.
S. Nuclear Regulatory 4
Commission Policy and Planning Guidance-1982";
8.
NUREG/CR-0400, " Risk Assessment Review Group Report to the U. S. Nuclear Regulatory Commission", September 1978.
Respectfully submitted s
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Dpniel D.
Wilt 7301 Chippewa Road Brecksville, OH 44141 Attorney for Sunflower Alliance, t
Inc.
PROOF OF SERVICE A copy of the foregoing Third Requ t For Production of to Staff has by (L/sent to all rsons on the attached Documents on this A
day of _ M i 1982.
Service List f
I D<
iel D. Wilt /
torney for Sunflower Alliance, Inc.
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