ML19325E011
| ML19325E011 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/20/1989 |
| From: | Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J. |
| To: | |
| Shared Package | |
| ML19325E010 | List: |
| References | |
| OLA-4, NUDOCS 8910310190 | |
| Download: ML19325E011 (3) | |
Text
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.y UNITED STATES OF AMERICA
'89 COT 24 - P 3 :28 NUCLEAR REGULATORY COMMISSION l I' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.*Ce E
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y a "In the Matter of
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Dockets Nos. 50-250 OLA-4 1
FLORIDA POWER & LIGHT COMPANY
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50-251 OLA-4
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(Turkey Point Plant,
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(Pressure / Temperature Limits)
. Units 3 and 4)
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AFFIDAVIT OF JOETTE LORION ON CONTENTION NO. 2 I, Joette Lorion bedng duly sworn, state as follows:
'1.-
I am the Director of the Center for Nuclear Responsibility
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Inc,
a non-profit organization that researches nuclear issues. I h&Ve been researching and litigating nuclear safety 1ssues since 1978.
Through the years I have acquired a broad knowledge of safety o
isGues surrounding the Turkey Point nuclear power plant, including the oroblem of pressure vessel embrittlement.
2.
I am a
professional research consultant. As a research-consultsnt and analyst I provide research data to writers, lawyers, and other professionals on a variety of topics.
I am skilled at
/
reading voluminous documents and evaluating and analy:1ng the information contained therein.
3.
I feel that my Droad knowledge of pressure vessel
./
embrittlement issues and safety problems at Turkey Point coupled
'q-with' my research skills enable me to offer information that relates to 1mportant e'lements of this proceeding.
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As:D1 rector of the Center, I have prepared responses to the r
h Licensee's motion for summary disposition in Inis proceeding.
I incorporate these' responses, by reference, with my affidavit and offer them in support of Intervenors' contention no. 2 in this r
. proceed 1ng.
F 5.
I have also-prepared the exhibits attached to Intervenors' 3
response to Licnesee's. motion for summary disposition and testify that each extract of a document, to the best of my knowledge, was taken'from the document that is listed as the exhibit.
6.
I: offer'these responses and these exhibits to the Board for whatever infronmation they may glesm from them.
I have personal knowledge of the matters =tated here, and believe them to be true and correct.
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Joette Lorion i
Sworn before me this 20th day of October 1989.
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COM14ISSION
,89 PM 24 P 3 28 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.n, In the Matter of
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'l,66
,c, FLORIDA' POWER & LIGHT CO.
Docket !;os. 50-250 OLA
)
50-251 OLA uk Un s
and 4 (Prossure/ Temperature Amendments)
CERTIFICATE GF SERVICE u
1 hereby certify that. copies of " Affidavit of Joette Lorion on Contention 2" have been served on the Board by fax transmission and on the other parties by deposit'in the United States mail, first class, postage prepaid to be incorporated with Intervenors' Response to Licensee's Motion for Summary Disposition of Intervenors' Contentions on the date shown below Dr.-Paul. Cotter John T. Butler Atomic Safety & Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 SE Financial Center Washington, D.C.
20$55 Miami, Florida 33131 Glenn O. Bright Steven P. Frantz Atomic fafety & Licensing Board Newman & Holtzinger P.C.
U.S.
Nuclear Regulatory Commission 1615 L.
Street NW Washington, D.C.
20555 Suite 1000 Washington, DC 20036 Jerry Harbour Atomic Safety & Licensing Board U.S.
Nuclear Regulatory Commf.ssion Washington, D.C.
20555 office of Secretary U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Janice Moore
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Office of General Counsel Joettc Lorion U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Director, Ccnter for Nuclear Responsibility October 20, 1989 7210 Red Road #217 Miami, Florida 33143 (305) 661-2165
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