ML20065J094

Motion to Dismiss License Application for Failure to Comply W/Discovery.Intervenors Unable to Prepare Adequately for Defense of Interests Against Impact of Facility on Lives & Livelihoods

ML20065J094
Person / Time
Site:	Waterford
Issue date:	09/29/1982
From:	Groesch G JOINT INTERVENORS - WATERFORD
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20065J098	List: ML20065J094 ML20065J117 ML20065J134
References
NUDOCS 8210050366
Download: ML20065J094 (2)

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DOCKETED

. USNRC  ;

UNITED STATES

• NUCLEAR REGULATORY COMMISSION g gq g

-IN the Matter of ) , l LOUISIANA POWER 5. LIGHT CO. ) Docket 50-382 OckErfachs$k'

1. 8 i (Waterford Steam Electric Station, )

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-Unit 3) .,

r BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

. s MOTION TO DISMISS FOR FAILURE TO MAKE DISCOVERY Now into court through the undersigned come Joint Intervenors and upon suggesting to the court as follows:

! (1) Joint Intervenors have participated in 3 years of this licensing process including exhaustive hearings and have produced expert [

testimony and affidavits on both the Synergism and Evacuation f i portions of this license and, j (2) Materials presently being furnished by the Applicant to the l Staff and /or FEMA or materials being prepared by the Staff and/or (

FEMA for this licensing directly affects and is related to the  !

evacuation contentions of the Joint Intervenors and, I (3) these materials have not been provided to the Joint Intervenors and t (4) this has resulted in grievous harm to the rights of the Joint f Intervenors.

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These materials include inter alias (a) all documents eva.uating evacuation procedures or establishing i schedules for such evaluation j (b) all documents evaluating the siren warning system or establishing 'f schedules for such evaluation.

.(c) all documents pertaining to any and all teaching methods or l sessions concerning evacuation procedures including names and f

curriculum vitae of those individuals doing the instruction. j (c) all standard operating procedures for the removal of individuals a

during a nuclear accident ' including but not limited to the special  ;

categories of individuals named in Joint Intervenor's contentions. I i

(d) all. documents relating to any agreements reached by Applicant  ;

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

(e) all documents relating to the installation or testing of communi-cation equipment in the Waterford facility which would interface with any and all state or local agencies.

The grievous harm done to the Joint Intervenors include inte_r alias .

(i) removal of the right of due process under the 5th Amendment of the Constitution.

(ii) the inability of Joint Intervenors to prepare adequately for the defense of their. interests against the tremendous impact of this facility on their lives and livelihoods.

Therefore, because of the grievous harm done to Joint Intervenors because of this failure, Joint Intervenors move that the license application of Applicant be denied.

In the alternative, with a surfeit of caution, Joint Intervenors are including a request for the production and copying of documents.

Joint Intervenors believe a prompt and complete response on behalf of Applicant y 6 Staff and y FEMA will mitigate the harm.

_ .. . w. 3 d'ar L.C/roescI J int Intervenors e

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