ML20065J117

Request for Production & Copy of Certain Documents. Documents Should Be Delivered within 15 Days in Order to Avoid Prejudicing Intervenors in Subsequent Proceedings

ML20065J117
Person / Time
Site:	Waterford
Issue date:	09/29/1982
From:	Groesch G JOINT INTERVENORS - WATERFORD
To:	Federal Emergency Management Agency, LOUISIANA POWER & LIGHT CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20065J098	List: ML20065J094 ML20065J117 ML20065J134
References
NUDOCS 8210050372
Download: ML20065J117 (2)

Text

. . .- - . . . . - - . - -- ..

.: i 2

<. i l

UNITED STATES ,

NUCLEAR REGULATORY' COMMISSION In the Matter of ) I

- LOUISIANA POWER & LIGiff CO. ) ,

e 0-382 (Waterford Steam Electric Station,) [

Unit 3) , )  !

i REQUEST FOR THE PRODUCTION AND COPYING dF DOCUMENTS i

• Now comes Joint Intervenors into court to request the following

' I documents from Applicant, Staff, or FEMA:  ;

(1) all documents evaluating evacuation procedures or establishing  !

schedules for such evaluation f i f (2) all documents evaluating the siren warning system or establishing i schedules for such evaluation (3) all documents pertaining to any and all teaching methods or f sessions concerning evacuation procedures including names and curricla j vita of those individuals doing the instruction.

[

4 (4) all standard operating procedures and/or implementing procedures [

I for removal of individuals during a nuclear accident including but .not limited to the special categories of individuals named in Joint ,

l Intervenors contentions. [

j -(5) all documents relating to any agreements reached by Applicant [

with adjacent parishes for buses or other special vehicle transportation i for categories of individuals named in Joint Intervenors contentions.  ;

(6) all documents relating to the installation or testing of comund- l cation equipment in the Waterford facility which would interface with j l any and all state or local agencies. i (7) Joint Intervenors request any and all NRC documents relating to the Indian Point evacuation proceedings  !

i

. With request #7 Joint Intervenors will show that a double stand-ard is being applied to the Indian Point vis-a vis the Waterford l

3 facility. The evacuation procedures around Indian Point are much  !

stricter in protecting the citizens of New York and surrounding states than the same, procedures protecting the citizens of Louisiana.

i . .

pgagggge, r .-

l

< o m .

a .

h These documents should be delivered to the address of Joint Intervenors acting counsel within 15 days. Failure to receive these documents may -

^

prejudice Joint Intervenors in any subsequent proceedings. =

t 1 .

O A A A

A _

1. ca 'T. Groesch [ ,

int Intervenors  !

P i

i i

l 2

r k

l h

a L

r h

i i

i

.