ML20052H868

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Motion for Leave to File Aj Schwartz Testimony on Oneill Contention II-D.Good Cause for Late Filing Exists.Related Correspondence
ML20052H868
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/18/1982
From: Oneill J, Semmel H
ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL, O'NEILL, J.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20052H869 List:
References
ISSUANCES-OLA, NUDOCS 8205240097
Download: ML20052H868 (2)


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ShLATED COHHESPONDENGt

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UNITED STATES OF AMERICA 05h'V NUCLEAR REGULATORY COMMISSION BEFORETHEATOMICSAFETYANDLICENSINGBbR In the Matter of

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Docket No. 50-155-OLA

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CONSUMERS POWER COMPANY

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(Spent Fuel Pool Modification)

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(Big Rock Point Nuclear Power Plant)

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MOTION FOR LEAVE TO FILE TESTIMONY OF DR. ARTHUR J. SCHWARTZ ON O'NEILL CONTENTION II-D and TESTIMONY OF DR. SCHWARTZ Intervenors request permission to file the testOmony of Dr. Arthur Schwartz, Associate Professor of Mathematics at the University of Michigan.

Dr. Schwartz's curriculum vitae is attached to his testimony.

He has taught in the mathematics department at the University of Michigan since 1965, including courses in Numerical Analysis and in Probability Theory and Stocahstic Processes.

He is also acting coordinator of the-Energy Studies Program at the University _

of Michigan.

The attached af fidavit of Herbert Semmel demonstrates why good cause is shown for filing at this time.

.Intervenors did not learn about Dr. Schwartz until May 8, the day after testimony was scheduled-to be filed.

Intervenors had been previously unable to find an expert DSOY S

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8205240097 820518 PDR ADOCK 05000155 G

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J willing to prepare testimony on Contention II-D without fee and.

Intervenors lacked the means to pay experts.

Respectfully subn

tted,

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'gr-l h Serbert Semmel /

Attorney for Indervenors Christa-Maria, Mills and Bier 4

Antioch School of Law 2633 Sixteenth Street, N.W.

Washingtcn, D.C.

20009 4

(202) 265-9500, ext. 240

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