ML19261C111

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Objection to Intervenor Carolina Environ Study Groups Discovery Requests & Motion for Protective Order.Urges Denial of 781218 Request Items 44A,45A,46A & 64A as Irrelevant to Contentions
ML19261C111
Person / Time
Site: 07002623
Issue date: 02/09/1979
From: Porter W
DUKE POWER CO.
To:
References
NUDOCS 7903140651
Download: ML19261C111 (2)


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NUCLEAR REGULATORY COSDtISSION

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Docket No. 70-2623 Station Spent Fuel Transportation and Storage at McGuire Nuclear

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OBJECTION AND MOTION FOR PROTECTIVE ORDER Pursuant to Rule 2.740(c), Applicant moves the Board to issue a protective Order, and shows as good cause the follows:

1.

Intervenor, CESG has forwarded numerous discovery requests to the Applicant, Duke Power Company.

Intervenor CESG's first set of Interrogt?ories were filed on September 11, 1978; CESG's Request for Admissic is from Duke Power Company were submitted on September 29, 1978; two Requests to Produce were filed on November 16, 1978; and further discovery requests were submitted on November 20, 1978, December 18, 1978, and February 3, 1979.

In each instance, Applicant has replied with detailed and time-consuming responses, or is in the process of responding to said request.

2.

However, in one of the most recent discovery requests dated December 18, 1978, Applicant did not respond to items 44A, 45A, 46A, and 64A, because such requests were not even generally relevant to the contentions are beyond the scope of the proceeding and are not likely to lead.to admissible evidence.

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hBEREFORE, Applicant moves for a Protective Order that the discovery sought by the Intervenor CESG be denied. I!

Dated February 9, 1979.

Respectfully submitt

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William L. Porth / ~

Counsel for Applidant 1/

This motion is filed to protect Applicant's interests in view of 10 CFR 2.740(f).