ML20140D549

Affidavit of J Lorion Supporting Intervenor Contention 3 Concerning Util Motions for Summary Disposition.Certificate of Svc Encl

ML20140D549
Person / Time
Site:	Turkey Point
Issue date:	03/19/1986
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:
References
CON-#186-534 OLA-3, NUDOCS 8603260308
Download: ML20140D549 (3)

Text

4 I-UNITED STATES OF AMERICA

]h NUCLEAR REGULATORY COMMISSIOSOCKETED USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 16 MAR 24 R2:29 In the Matter of )

} Docke{rNos.: 50-250-OLA-3 FLORIDA POWER AND LIGilT COMPANY ) 00Cbtf o 50-251-OLA-3 o n - x.

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Turkey Point Nuclear ) (Uranium Enrichment)

Units 3 and 4 )

AFFIDAVIT.OF JOETTE LORION ON CONTENTION 3 I, Joette Lorion being duly sworn, state as follows:

1. I am the Director of the Center for Nuclear Responsibility Inc., a non-profit organization that researches nuclear issues.

I have been researching, writing on, and involved in litigation on nuclear power safety issues since 1978. Although I.am not a nuclear scientist, I have acquired a broad knowledge of safety issues surrounding the Turkey Point nuclear power plant.

2. I am a professional researcher and provide research to writers, lawyers, and other professionals on a. variety of topics.

I am skilled in reading large amounts'of information and picking out interesting or problem areas.

3. I feel that my broad knowledge of safety problems at Turkey Point and my skill at research.has allowed me to offer information that relates to important elements of this proceeding.

4. As Director of the Center, I have prepared responses to the FPL motions for summary disposition in this proceeding.

I incorporate these responses, by reference, with my affidavit and offer them in support of Intervenors' contentions in this proceeding.

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5. I offer these responses to the Board for whatever information they may offer. I have personal knowledge.'of the matters stated hers_, and believe.them~to be true and. correct.

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Joette Lorion sworn before me this [ -

day of March, 1986.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00 p BEFORE THE ATOMIC SAFETY AND LICENSING BOAhD In the' Matter of ) Docket oh hd-;PQ:3%A-3

) 50-251-OLA-3 FLORIDA POWER & LIGHT COMPANY ) 0,Frit .

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Turkey Point Plants, Units 3 and'4 )

CERTIFICATE OF SERVICE ~

I hereby certify that copies of "Intervenors' Response to Licensee's Motion for Summary Disposition of Intervenors' Contention 3", and "Intervenors' Statement of Material Facts As To Which There is a Genuine Issue To Be Heard With Respect to Intervenors' Contention 3", and " Affidavit Of Joette Lorion", have been served on the following parties by deposit in the United States Mail, first class, postage prepaid, on the date shown below:

Dr. Robert M. Lazo, Chairman Norman A. Coll, Esquire Atomic Safety and Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 SE Financial Center Washington, D.C. 20555 Miami, F1. 33131-2398 Dr. Emmeth A. Luebke Michael A. Bauser, Esquire Atomic Safety and Licensing Board Newman and Holtzinger, PC U.S. Nuclear Regulatory Commission 1615 L. Street NW Washington, D.C. 20555 Washington, D.C. 20036 Dr. Richard F. Cole Atomic Safety and Licensing Board ik 'N U.S. Nuclear' Regulatory Commission Joette Lorion, Director Washington, D.C. 20555 Center for Nuclear Responsibility Mitzi A. Young, Esquire 7210 Red Rd. #208 Office of Executive Legal Director Miami, Fl. 33143 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dated: March 19,'1986 I

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