ML20096B596

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FOIA Request for 12 Categories of Documents Re WPPSS Lwas, Cps,Safety of Design,Engineering,Const,Aslb & Commission Rulings,Ability to Finance Project & Antitrust Agreements
ML20096B596
Person / Time
Site: Columbia, 05000000, Washington Public Power Supply System, Satsop
Issue date: 07/20/1984
From: Cohen B
MEREDITH & COHEN, P.C.
To: Felton J
NRC OFFICE OF ADMINISTRATION (ADM)
References
FOIA-84-603 NUDOCS 8409040228
Download: ML20096B596 (3)


Text

_-. _ _ _ _ _ _ _ _ _ _ _

t Y 4 MEREDITH & COHEN, P. C.

ATTORNEYS AT LAW 22ND FIDOR-ARCHITECTS BUILDING 17TH & SANSOM STREETS PHILADELPh 4, PA.19903 (215) 564-5102 SUITE 300 JOEL C. M EREDITH TELECOPIER (215) 569-0958 tos TREMONT STREET BRUCEK. COHEN posTON MA oato8 STEVEN J. GREENTOGEL" (617) 453-0793

' ALSO MEMBER NASS.BAR July 20, 1984 J.M.

Felton, Director pg:gnnes y gg Division of Rules and Records g

United States Nuclear Regulatory Commission FoIAfgo3 M'd 7-23-2tl Washington, DC 20555 Re:

Freedom of Information Act Request

Dear Mr. Felton:

Pursuant to 5 U.S.C.

Section 552, we hereby request, on behalf of all plaintiffs its In Re Washington Public Power Supply System Securities Litigation (MDL No. 551, W.D.Wa.), an opportunity to inspect and/or copy records within your posses-sion, custody or control, including without limitation, all documents, handwritten notes or typed memoranda which refer, relate to or incorporate the following:

(1)

Applications for Limited Work Authorizations by the Washington Public Power Supply System (herein-after "the System") for its Project Numbers 1, 2, 3, 4 and/or 5.

(2)

Applications for Construction Permits by the Sys-tem for its Project Numbers 1, 2, 3, 4 and/or 5.

(3)

Applications for extensions of the completion date of G Construction Permit by the. System for its Project Numbers 1, 2, 3, 4 and/or 5.

(4)

Applications for a license by the System for its Project Numbers 1, 2, 3, 4 and/or 5.

(5)

To the extent not requested in sub-paragraphs 1-4 hereof, applications by the System for any other type of authorization, permit or license pursuant to 42 U.S.C. Sections 2232 or 2235.

8409040228 840720 PDR FOIA PDR COHEN 84-603 M

MEREDITH & COHEN, P. C.

J.M.

Felton, Director J uly 20, 198 4 j

Page Two 1

(6)

Communications between you or your personnel on the one hand and the System or those speaking on its behalf, (including but not limited to, attor-neys, engineering, contracting and consulting firms), concerning adequacy and safety of design, engineering and/or construction of the System's Project Numbers 1, 2, 3, 4 and/or 5.

(7)

Communications between you or your personnel on the one hand and the System or those speaking on its behalf, (including but not limited to, attor-neys, engineering, contracting and consulting firms), concerning changes in Nuclear Regulatory

  • Commission rules, regulations or requirements.

(8)

All documents relied on or considered or filed of record in connection with any decision of the Nuclear Regulatory Commission, its Boards, Panels or other divisions of any type, (including but not limited to the Atomic Safety and Licensing Board and the Atomic Safety and Licensing Appeal Board),

relating to the System's Project Numbers 1, 2, 3, 4 and/or 5.

(9)

Transcripts of any hearings held pursuant to 42 U.S.C. Section 2239 in connection with the Sys-tem's Project Numbers 1, 2, 3, 4 and/or 5.

(10)

The ability of the System to finance its Project Numbers 1, 2, 3, 4 and/or 5.

(11)

The ability, willingness and/or authority of the Participants to have entered into and/or comply with the terms of the Participants Agreement pro-viding security for the System's Project Numbers 4 and 5 Bonds.

(12)

The need for the System's Project Numbers 4 and 5,

including consideration of,any alternatives to their construction.

Pursuant to 5 U.S.C.

Section 552(a)(6)(A), we hereby request that the NRC respond in writing to this request within ten (10) days after its receipt.

We further request that, if you deny any portion of this request, you provide a detailed

+

. MEREDITH O COHEN, P. C.

J.M.

Felton, Director July 20,1984 Page Three statement of the reasons for such denial and a description of all documents or portions of documents withheld.

The undersigned and other plaintiffs' counsel will be available to inspect and copy these documents promptly upon their production and will pay any reasonable costs associated therewith.

Your attention to this request would be greatly appreciated.

Sincerely, MEREDITH & COHEN, P.C.

)

VLA_L_

h By:' Bruce K. Cohen BKC/ jr cc:

Paul M. Bernstein, Esquire Melvyn I. Weiss, Esquire James R.

Irwin, Esquire Michael Mines, Esquire DaviG Berger, Esquire Mark C.

Rutzick, Esquire All Defendants' Lead and Liaison Counsel

.