ML20140D778

Affidavit of J Lorion Re Contentions 3,4,5,6,7,8 & 10

ML20140D778
Person / Time
Site:	Turkey Point
Issue date:	03/19/1986
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:
References
CON-#186-533 OLA-2, NUDOCS 8603260482
Download: ML20140D778 (2)

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9 UNITED STATES OF AMERICA x'f Y$kf eb NUCLEAR REGULATORY COMMISSION J w hl ..?'l~~

, D BEFORE THE ATOMIC SAFETY AND LICENSING BOARD c-

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Docket nos. 50-250-OLA-2l2/

-FLORIDA POWER AND LIGHT COMPANY ) \p0-251-OLA3/

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(SP ent Fuel Pool' Expansion)

Turkey Point Nuclear )

Units 3 and 4 )

AFFIDAVIT OF'JOETTE LORION ON CONTENTIONS 3,4,5,6,7,8',10-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 here, and believe them to be true and correct.

k N Joette Lorion Sworn before me this /'Y day of March, 1986.

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