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)

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UNITED STATES NUCLEAR REGULATORY' COMMISSION In the Matter of

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- LOUISIANA POWER & LIGiff CO.

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(Waterford Steam Electric Station,)

Unit 3)

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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

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(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.

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

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

Intervenors contentions.

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

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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.

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

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prejudice Joint Intervenors in any subsequent proceedings.

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