ML19274E636
| ML19274E636 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1979 |
| From: | Goldberg J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Armstrong W MCCUTCHEN, DOYLE, BROWN & EMERSEN |
| References | |
| PROJECT-564M NUDOCS 7904090382 | |
| Download: ML19274E636 (1) | |
Text
,"
b' h~\\
/g >P at c,,,9,,
%?
_r.
.g e
,p!
);j e '.,.
NUCLEAfl ilEGULATOHY COMMISSION
'T i-T,l k 'lh lf, $
W ASHirJG T OfJ, D. C. 20555
'h, e
Q(. g~l j
\\
m/
W) i
\\,,, f a Nlte p %
.s u.
s March 12,1979
/
Duo.
-f
- u,_g,7 Nf,p William H. Armstrong, Esq.
McCutchen, Doyle, Brown & Enersen Three Embarcadero Center, 28th Floor San Francisco, California 94111 Re:
Pacific Gas and Electric Company, Stanislaus f;uclear Project, Unit f!o 1, flRC Docket flo. P-504A
Dear Mr. Armstrong:
in the footnote on the first page of PG&E's March 2nd Answer oppos i n'] the intervenors' motions for a protective order, you stated that Sta ff agreed to answer the interrogatories voluntarily "unless they raised specific objections a f ter a reasonable opportunity to examine the interroga tories. "
I believe that statement misstates the na ture of the stipula tion we have.
Specifically, the stipulation does not require the Staff to raise specific objections a f ter a reasonable time.
The stipulation, as approved by the Board, is simply that of the Sta ff's " willingness to read over these interrogatories and on a volunta ry basis provide whatever in forma tion I cari... a t whatever point it becomes available to the staff."
1r. a t 2219.
In your own words, "I had understood [f tr. Goldberg] to say that the Staff af ter reviewing them would consider voluntarily responding a t some point, whether it is voluntary or otherwise."
Tr. at 2219-20.
These state-rrents correctly reflect the stipulation approved by the Board.
See Tr.
at 2220.
Let me assure you that the Staff will voluntarily respond to the intes rogatories at the appropriate time as indicated at t he prehearing con ference.
Very truly you s, f
s
${
- b /
H k R. Goldberg Counsel for f!RC Sta ff cc: All parties on Service List 204.09Ch
.