ML19325E011: Difference between revisions
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AFFIDAVIT OF JOETTE LORION ON CONTENTION NO. 2 I, Joette Lorion bedng duly sworn, state as follows: | |||
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 [ | '1.- I am the Director of the Center for Nuclear Responsibility [ | ||
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 , | 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. ! | isGues surrounding the Turkey Point nuclear power plant, including the oroblem of pressure vessel embrittlement. ! | ||
I | I | ||
: 2. am a professional research consultant. As a research-consultsnt and analyst I provide research data to writers, lawyers, | : 2. 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 | , and other professionals on a variety of topics. I am skilled at | ||
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reading voluminous documents and evaluating and analy:1ng the | reading voluminous documents and evaluating and analy:1ng the | ||
, information contained therein. | , information contained therein. | ||
< 3. I feel that my Droad knowledge of pressure vessel | < 3. I feel that my Droad knowledge of pressure vessel | ||
./ | ./ | ||
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}'' PDR | }'' PDR | ||
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: 4. As:D1 rector of the Center, I have prepared responses to the r | : 4. 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 ! | 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. ! | . proceed 1ng. ! | ||
F 5. I have also-prepared the exhibits attached to Intervenors' 3 | 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. | 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 | : 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. | knowledge of the matters =tated here, and believe them to be true and correct. | ||
T ~ | T ~ | ||
- . . _. d . b _C. M _' b _''.'_ " | - . . _. d . b _C. M _' b _''.'_ " | ||
Joette Lorion i | Joette Lorion i | ||
Sworn before me this 20th day of October 1989. | Sworn before me this 20th day of October 1989. | ||
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COM14ISSION | UNITED STATES OF AMERICA NUCLEAR REGULATORY COM14ISSION | ||
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) 50-251 OLA uk Un s and 4 (Prossure/ Temperature Amendments) u CERTIFICATE GF SERVICE 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, , | ) 50-251 OLA uk Un s and 4 (Prossure/ Temperature Amendments) u CERTIFICATE GF SERVICE 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' , | 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 , | 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 , | 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. | Glenn O. Bright Steven P. Frantz Atomic fafety & Licensing Board Newman & Holtzinger P.C. |
Revision as of 01:36, 1 February 2020
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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UNITED STATES OF AMERICA '89 COT 24 - P 3 :28 NUCLEAR REGULATORY COMMISSION l EI' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.*Ce vu -
o y
a "In the Matter of ) ,
) Dockets Nos. 50-250 OLA-4 1 FLORIDA POWER & LIGHT COMPANY ) 50-251 OLA-4
- )
(Turkey Point Plant, ) (Pressure / Temperature Limits)
. Units 3 and 4) ) I
< )
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 [
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. !
I
- 2. 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.
4
/
y q' .- , PY.10310190 891020
,. ('Dit ADOCK 05000250
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- 4. 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.
T ~
- . . _. d . b _C. M _' b _.'_ "
Joette Lorion i
Sworn before me this 20th day of October 1989.
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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 ) 'l,66 -
, ,c, FLORIDA' POWER & LIGHT CO. Docket !;os. 50-250 OLA
) 50-251 OLA uk Un s and 4 (Prossure/ Temperature Amendments) u CERTIFICATE GF SERVICE 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 [ Ot( / i Uv--
Office of General Counsel U.S. Nuclear Regulatory Commission Joettc Lorion 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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