ML19289E215
| ML19289E215 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1979 |
| From: | Goldberg J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Armstong W MCCUTCHEN, DOYLE, BROWN & EMERSEN |
| References | |
| PROJECT-564M NUDOCS 7904050006 | |
| Download: ML19289E215 (1) | |
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umTED STATES tJUCLEAR REGULATORY COMMISSION f jg$iM' f
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March 12,1979
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William 11. Armstrong, Esq.
McCutchen, Doyle, Brown & Enersen Three Embarcadero Center, 28th Floor San Francisco, California 94111 Re:
Pacific Gas and Electric Company, Stanislaus fluclear Project, Unit flo 1, f1RC Docket flo. P-564A
Dear Mr. Armstrong:
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In the footnote on the first page of PG&E's March 2nd Answer opposing the intervenors' motions for a protective order, you stated that Staff agreed to answer the interrogatories voluntarily "unless they ' raised specific objections after a reasonable opportunity to examine the interrogatories."
I believe that statement misstates the nature of the stipulation we have.
Specifically, the stipulation does not require the Staff to raise specific objections after a reasonable time.
The stipulation, as approved by the Board, is simply that of the Staff's " willingness to read over these interrogatories and on a voluntary basis provide whatever information I can... at whatever point it becomes available to the staff."
Tr. at 2219.
In your own words, "I had understood [Mr. Goldberg] to say that the Staff after reviewing them would consider voluntarily responding at some point, whether it is voluntary or otherwise." Tr. at 2219-20 These state-ments correctly reflect the stipulation approved by the Board.
See Tr.
at 2220.
Let me assure you that the Staff will voluntarily respond to the interrogatories at the appropriate time as indicated at the prehearing con ference.
Very truly you c,,
U(
/
Jack R. Goldberg
, Counsel for f1RC Staff cc i. All parties on Service List
/90405DDDh
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