ML20052D094

Motion for Protective Order Re Section V,Discovery Requests 8(b) & (C).Requests Seek Info on Programmatic or Policy Issues Outside Scope of Proceeding

ML20052D094
Person / Time
Site:	Clinch River
Issue date:	05/04/1982
From:	Edgar G, Silverstrom L ENERGY, DEPT. OF, PROJECT MANAGEMENT CORP.
To:	NRC COMMISSION (OCM)
References
NUDOCS 8205060271
Download: ML20052D094 (2)

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T May 4, 1982 UNITED STATES OF AMERICA g _4 g, 3 3 NUCLEAR REGULATORY COMMISSION g pq S h,

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UNITED STATES DEPARTMENT OF ENERGY ) A

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PROJECT MANAGEMENT CORPORATION ) Dockdt.No. 50-537 TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant )

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MOTION FOR A PROTECTIVE ORDER Pursuant to the Board's Prehearing Conference Order and the procedural rules set forth in Texas Utilities Generating Company (Comanche Peak Steam Electric Station, Units 1 and 2), LBP-81-22, 14 NRC 150 (1981), the Department of Energy and Project Management Corporation, acting for themselves and on behalf of the Tennessee Valley Authority (the Applicants), hereby submit their Motion for a Protec-1 tive Order.- /

1. On April 22, 1982, this Board issued a Protec-tive Order as to all the latest discovery requests submitted by the parties. In issuing its order, the Board also 9 503 e

--1/ Applicants have, this date, filed their answers to I b Intervenors 18th Set of Interrogatories amounting to approximately 375 questions with the exception of Section V, Interrogatory 8 which is addressed in this Motion.

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required that the parties meet and attempt to resolve volun-tarily all discovery disputes.

2. In accordance with the Board's Order, on April 23, 1982, the Applicants and Intervenors met and substantially resolved all their major disputes.--2/ The parties were, however, unable to resolve their disagreements as to Section V, Requests 8(b) and (c).

3. As discussed in detail in the accompanying Memorandum of Points and Authorities, the discovery requests listed above seek information which is related to program-matic or policy issues outside the purview of this '

proceeding.

Accordingly, for the reasons stated above as well as those contained in Applicants' Memorandum of Points and Authorities, Applicants respectfully request that their '

Motion be granted.

Respectfully submitted, I

eorge . Edgar Attorney for Project Management Corporation s

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Leon

, 4W ilverstrom Attorney for the Department of Energy

--/ A more detailed description of the resolution of the various disputes is included in the accompanying Memorandum of Points and Authorities.

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