Intervenors' Rebuttal Statement of Position on Contention 15

On behalf of Beyond Nuclear and other intervenors, Arnie Gundersen provides expert testimony that the Quality Assurance activities of Detroit Edison Co. do not satisfy the requirement of the Atomic Energy Act and its regulations. The evidence is “sufficient to raise legitimate doubt as to whether the plant can be operated safely,” and so the Licensing Board should deny a combined license for Fermi 3.

For the United States Nuclear Regulatory Commission, before the Atomic Safety and Licensing Board in the matter of the Detroit Edison Company, Fermi Nuclear Power Plant Unit 3