Expert witness report examining the licensing basis for First Energy's proposed Replacement Once Through Steam Generator modification to its Davis-Besse nuclear reactor. Fairewinds concludes that First Energy is attempting to avoid the more rigorous, full license amendment process, as Edison did at San Onofre with disastrous results. A formal license amendment with public participation must be required fro Davis-Besse. Clients: Beyond Nuclear (Takoma Park, MD), Citizens Environment Alliance SW Ontario Canada, Don't Waste Michigan (MI), and Sierra Club Ohio Chapter (OH).
Fairewinds Davis-Besse Petition to Intervene, May 20, 2013, Arnie Gundersen