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Relicensing

The U.S. nuclear reactor fleet is aging but owners are applying to the Nuclear Regulatory Commission for license extensions to operate reactors an additional 20 years beyond their licensed lifetimes. Beyond Nuclear is challenging and opposing relicensing efforts.

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Monday
Oct272014

Beyond Nuclear to challenge Davis-Besse containment cracking at NRC HQ on Nov. 12th

Severe sub-surface laminar cracks in the Shield Building concrete adjacent to rebar (left) grow a half-inch every time it freezes at Davis-Besse. Core bore monitoring tests (right) are too few and far between, and too infrequent.

Please listen-in by phone, to show your support, as Beyond Nuclear and environmental allies challenge the problem-plagued Davis-Besse atomic reactor's proposed 20-year license extension. The focus of the Wednesday, November 12th hearing, beginning at 9 AM Eastern sharp, will be worsening cracking of the concrete containment. Your presence on the phone line will let the U.S. Nuclear Regulatory Commission (NRC), its Atomic Safety and Licensing Board Panel (ASLBP), and FirstEnergy Nuclear Operating Company know they are being watched. It will also let Beyond Nuclear and its allies know they have your support.

According to the NRC ASLB point of contact, law clerk Sachin Desa:

"...The dial-in number for calling in to the Davis-Besse November 12th Oral Argument (listen-only) is 888-790-4078.  When prompted, please enter the passcode 2475418.  

If others are interested in listening in on the call, please have them reach out to me so we can keep an accurate count.

The argument will start at 9:00 AM Eastern Time.  Please try to be on the line at least five minutes early so as to allow time to work through any technical issues that may arise.  Let me know if there are any further questions.

Sachin Desai, Law Clerk

Atomic Safety and Licensing Board Panel
U.S. Nuclear Regulatory Commission

Sachin.Desai@nrc.gov | 301-415-6523"

Background:

The U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board Panel (ASLBP) overseeing FirstEnergy Nuclear Operating Company's (FENOC) application proceeding for a 20-year license extension at its problem-plagued Davis-Besse atomic reactor in Oak Harbor, OH on the Lake Erie shore has announced oral argument pre-hearings will be held at NRC HQ in Rockville, Maryland on Wed., Nov. 12th, beginning at 9am Eastern sharp. The hearing will focus on the environmental coalition's latest concrete containment cracking contention, motivated by recent revelations of "ice-wedging crack propagation," despite earlier assurances by FENOC -- backed by NRC staff -- that the already severe cracking could not possibly get worse.

As ordered by the ASLBP, "a listen-only line will be available for members of the public that wish to listen to the proceedings by telephone. Interested members of the public should contact Sachin Desai [at 301-415-6532 or Sachin.Desai@nrc.gov] no later than Monday, November 10, 2014 to receive the listen-only telephone conference number and passcode...Those participating by telephone should be on the line at least five minutes early so as to allow time to work through any technical issues that may arise."

Please see Sachin Desai's detailed call-in instructions, posted above in bold.

Supporters of this environmental intervention are encouraged to phone and listen-in, to show NRC, the ASLBP, and FENOC that people care, and to show support for the intervening groups and their representatives.

If you happen to be in Washington, D.C. at the time (such as for Michael Mariotte of NIRS's Lifetime Achievement Award event on Nov. 10th, and/or the Sierra Club Nuclear-Free Campaign gathering beginning on Nov. 14th), you can also attend this ASLBP proceeding in person:

"The oral argument will be held at the NRC [Headquarters] on November 12, 2014, in the Advisory Committee on Reactor Safeguards Meeting Room 2 (Room #2B1), which is on the second floor of Two White Flint North, 11545 Rockville Pike, Rockville, Maryland 20852...All persons participating in person should arrive at the NRC at least fifteen minutes early so as to allow sufficient time to pass through security screening."

NRC HQ is located immediately across the street from the White Flint Metro Station on the Red Line.

30-minutes ahead of time would be safer, actually, given NRC's strict security and escorting protocols. Be sure to bring a valid photo ID.

The environmental coalition intervening against Davis-Besse's 2017-2037 license extension includes Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and the Green Party of Ohio. The coalition is represented by Terry Lodge, an attorney based in Toledo. The coalition launched its intervention nearly four years ago, on December 27, 2010. The coalition has raised numerous concrete containment cracking contentions since the severe -- and now admittedly worsening -- problem was first revealed in late 2011.

Thursday
Oct162014

Environmental coalition filings on Davis-Besse Shield Building cracking issue

The environmental coalition challenging FirstEnergy Nuclear Operating Company's (FENOC) proposed 20-year license extension at the problem-plagued Davis-Besse atomic reactor, near Toledo on the Lake Erie shore, has been challenging Shield Building cracking since January 10, 2012. Below are the coalition's filings thus far, in chronological order, as well as associated coalition press release, FirstEnergy Nuclear Operating Company (FENOC) filings, U.S. Nuclear Regulatory Commission (NRC) staff filings, NRC Atomic Safety and Licensing Board Panel's (ASLBP) orders, etc.:

2011

June 15, 2011: ASLBP's Initial Scheduling Order (“ISO”).

October 10, 2011: "Laminar crack discovered in the shield building access opening during 17M (documented under CR 2011-03346)" (as put by Performance Improvement International in its 9/11/13 Full Apparent Cause Evaluation on ice-wedging crack propagation, not released by FENOC until ten months later, on 7/8/14. See PII FACE, p.26 of 98 on PDF counter. 17M refers to the 17th mid-cycle outage.)

October 31, 2011: Letter from R. Seeholzer, FirstEnergy, to the Investment Community (provided as Attachment 1 to FENOC’s Original Contention 5 Answer).

December 2, 2011: NRC Confirmatory Action Letter (CAL), permitting FENOC to rush the restart of the Davis-Besse reactor, despite the recently discovered cracking of unknown origin, extent, and safety significance (NRC ADAMS ML# ML11336A355).

2012

January 5, 2012: FENOC Presentation Slides, NRC Public Meeting (provided as Attachment 2 to FENOC’s Original Contention 5 Answer).

January 10, 2012Environmental Intervenors' original cracking contention. (Motion for Admission of Contention No. 5 on Shield Building Cracking, 61 pages.)

January 31, 2012: NRC Integrated Inspection Report. 93 pages.

February 6, 2012: FENOC's Answer Opposing Intervenors' Motion for Admission of Contention No. 5 on Shield Building Cracking. 137 pages.

February 13, 2012: Intervenors' Combined Reply in Support of Motion for Admission of Contention No. 5. 110 pages. (Associated February 14, 2012 coalition press release)

February 27, 2012: Filing (Intervenors' first Motion to Amend 'Motion for Admission of Contention No. 5') based on U.S. Rep. Kucinich's (D-OH) revelation that the shield building's outer rebar layer was no longer structurally functional, due to the cracking. First contention supplement/amendment. (Associated coalition media release.)

February 27, 2012: Letter from B. Allen, Vice President-Nuclear, FENOC, to C. Pederson, Acting Administrator, NRC, Submittal of Shield Building Root Cause Evaluation (submitted as an enclosure to Letter from T. Matthews, FENOC Counsel, to Board, Notification of Filing Related to Proposed Shield Building Cracking
Contention (Feb. 29, 2012).

April 5, 2012: Letter from D. Imlay, FENOC, to NRC, Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 25, Attachment L-12-028 (provided as an enclosure to the Board Notification for April 2012 RAI Response); Letter from T. Matthews, FENOC Counsel, to the Board, Notification of Filing Related to Proposed Shield Building Cracking Contention

May 7, 2012: Davis-Besse Nuclear Power Station Reactor Vessel Head Replacement and Shield Building Cracking Inspection Report 05000346/2012007 (DRS) (provided as an enclosure to Letter from B. Harris, Staff Counsel, to Board (May 10, 2012)).

May 17, 2012: Revised Root Cause Evaluation (dated May 8, but not submitted till May 17, as an enclosure to Letter from T. Matthews, FENOC Counsel, to Board, Notification of Filing Related to Proposed Shield Building Cracking Contention), 131 pages. (In its September 11, 2013 Full Apparent Cause Evaluation (see below) -- not released by FENOC until July 8, 2014 -- PII refers to this document as RCA-1, Performance Improvement International Laminar Cracking Root Cause (Davis-Besse Condition Report 2011-03346)).

May 24, 2012: FENOC Davis-Besse nuclear power station, Unit 1, Submittal of Contractor Root Cause Assessment Report, Revised Root Cause Assessment Report, or RRCAR, from B.S. Allen, FirstEnergy Nuclear Operating Company, to Cynthia D. Pedersen, NRC, NRC/RGN-III/ORA, L-12-196, NRC ADAMS Accession No. ML12138A037, 257 pages. (Per immediately above, in its September 11, 2013 Full Apparent Cause Evaluation (see below) -- not released by FENOC until July 8, 2014 -- PII refers to this document as RCA-1, Performance Improvement International Laminar Cracking Root Cause (Davis-Besse Condition Report 2011-03346)).

June 4, 2012: Filing, (Intervenors' second Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking)) in response to FENOC's woefully inadequate Aging Management Plan (AMP) for the shield building's cracks. Second contention supplement/amendment.

June 21, 2012: NRC Inspection to Evaluate the Root Cause Evaluation and Corrective Actions for Cracking in the Reinforced Concrete Shield Building of the Containment System 05000346/2012009(DRS). See page 3 of Attachment 2 (Page 35 of 46 on PDF counter) for a photo showing how severe the subsurface laminar cracking discovered on Oct. 10, 2011 actually was.

June 29, 2012: FENOC’s Answer Opposing Intervenors’ Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking).

July 16, 2012: Filing (Intervenors' Third Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), in response to FENOC's revised root cause analysis report, which revealed that shield building cracking was first observed not in October 2011, but rather August 1976. Third contention supplement/amendment.

July 23, 2012: Filing (Intervenors' Fourth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), based on revelations in FENOC contractor Performance Improvement International's revised root cause assessment report, which revealed 27 areas of skeptical NRC questioning about FENOC's "Blizzard of 1978" theory of shield building cracking (the environmental Intervenors also posted documents supportive of this fourth contention supplement/amendment). NRC ADAMS Accession No. ML12205A507, 56 pages.

August 16, 2012: Contention supplement (Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), on the severe shield building cracking, which cites U.S. Nuclear Regulatory Commission (NRC) documents revealed through a Freedom of Information Act (FOIA) request submitted by Beyond Nuclear. The coalition issued a media release about this contention supplementation.

August 2012: Beyond Nuclear prepared a report, entitled "What Humpty Dumpty Doesn't Want You to Know: Davis-Besse's Cracked Containment Snow Job," which summarized the coalition's work in 2012 on Davis-Besse's dangerously degraded condition, focused on the Shield Building cracking.
August 22, 2012: Licensing Board Notice (Advising Parties of Amendments to 10 C.F.R. Part 2; unpublished).
2012: ASLBP Order to hold oral argument pre-hearings in Toledo on Monday, November 5 and Tuesday, November 6 [Election Day].
November 5 and 6 [Election Day], 2012: Oral argument pre-hearings in Toledo before ASLBP (transcripts).
November 20, 2012: Letter from T. Matthews, FENOC Counsel, to the Board, Notification of Filing Related to Shield Building Laminar Cracking: Letter from D. Imlay, FENOC, to NRC, Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 36, Attachment L-12-418 (provided as an enclosure to the Board Notification for November 2012 RAI Response).

2013

The environmental coalition (Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and Sierra Club Ohio Chapter) intervention against Davis-Besse's steam generator replacement project included concerns about damage to the Shield Building. Arnie Gundersen, Chief Engineer of Fairewinds Associates, Inc., served as the coalition's expert witness. (Multiple filings) 

See also:

September 3, 2013: NRC Safety Evaluation Report [SER] Related to the License Renewal of Davis-Besse Nuclear Power Station, available at ADAMS Accession No. ML13248A267. 895 pages. See particularly Section 3.0.3.3.9. NRC states in its April 15, 2014 RAI (see below): "Following review of the Shield Building Monitoring Program, responses to several rounds of follow-up Requests for Additional Information (RAIs), and an updated Shield Building Monitoring Program, the NRC staff found the Updated Shield Building Monitoring Program to be acceptable, as documented in Section 3.0.3.3.9. [of this SER]."

September 11, 2013: RCA-2, Performance Improvement International Laminar Crack Propagation Root Cause (Davis-Besse Condition Report 2013-14097). See Enclosure 2, beginning at page 17 of 98, of FENOC's July 8, 2014 (see below) letter to the ASLBP. Note that FENOC withheld this PII report for 10 months, despite its significance.

September 20, 2013: Preliminary Notification -- [NRC] Region III, Preliminary Notification of Event or Unusual Occurrence, PNO-III-13-007, Davis-Besse Shield Building Laminar Cracks, NRC ADAMS ML# ML13263A410, 2 pages.

November 1, 2013: Davis-Besse Nuclear Power Station NRC Integrated Inspection Report 05000346/20130004, available at ADAMS Accession No. ML13308A283. (Excerpts from the November 2013 NRC Inspection Report were provided as Attachment 2 to FENOC’s Answer to Contention 6.)

2014 
April 22, 2014 (Earth Day, 3 years to the day before Davis-Besse's original 40-year license expires): The coalition issued a press release.

ASLB filing:

MOTION FOR ADMISSION OF CONTENTION NO. 6 ON SHIELD BUILDING CONCRETE VOID, CRACKING AND BROKEN REBAR PROBLEMS

Exhibits: #1, NRC Preliminary Notice of Event or Occurrence (Feb. 19, 2014); #2, Toledo Blade article, “Davis-Besse Had Air Gap in Shield Building,” (Feb. 15, 2014); #3, Declaration of Victoria Clemons (April 14, 2014); #4, Minutes of Internal Meeting of Davis-Besse Oversight Panel (Oct. 18, 2001); #5, Minutes of Internal Meeting of Davis-Besse Oversight Panel (Oct. 29, 2002); #6, NRC Preliminary Notice of Event or Occurrence (Sept. 20, 2013); #7, NRC Request for Additional Information (April 15, 2014); #8, Expert Witness Report of Arnold Gundersen, 50-246-LA (2013).

DEIS comments:

1. Amory Lovins' "Nuclear power’s competitive landscape and climate opportunity cost," March 28, 2014 (TMI+35), Dartmouth College, NH

Amory Lovins on uncompetitiveness of old atomic reactors. At page 5 Lovin’s writes: "Reactors are promoted as costly to build but cheap to run. Yet as Daniel Allegretti ably described, many existing, long-paid-for U.S. reactors are now starting to be shut down because just their operating cost can no longer compete with wholesale power prices, typically depressed by gas-fired plants or windpower."

2. PJM Interconnect: 30% grid integration of renewables not a problem.

In fact, it was well known to PJM (Pennsylvania/Jersey/Maryland) Interconnect, covering 13 states and this nation's largest single electric grid, as published in this 2010 2010 ISO/RTO Metrics Report, posted at the website of the U.S. Federal Energy Regulatory Commission, that wind power and solar PV are available in abundance and that there is no disruption or destabilizing of "baseload grid" associated with their integration. Replacement power was available in 2010, and is available now, and certainly in 2017.

On Dec. 27, 2010, the environmental coalition -- with University of Toledo professor emeritus Al Compaan as its expert witness -- contended that wind and solar PV, combined with compressed air energy storage, could easily replace Davis-Besse's 908 megawatts of electricity during the 2017-2037 period. In 2011, the ASLB agreed to hear the contention. But on March 27, 2012, the five-member NRC Commission, responding to an appeal by FENOC, unanimously overruled the ASLB, rejecting the renewables-as-alternative-to-license-extension hearing. Interveners reassert their contention and call for the NRC Commissioners' order to be reversed, because they are simply wrong. The coalition reserves the right to appeal the rejection of its renewables contention to federal court, once the ASLB proceeding has concluded.

3. Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, also submitted five comments to NRC: #1, Jan. 10, 2012 SB cracking contention's relevance to DEIS; #2, four 2012 cracking contention supplements' (Feb. 27; June 4; July 16; July 23) relevance to DEIS; #3, fifth cracking contention supplement's (Aug. 16, 2012) relevance to DEIS; #4, Dec., 2010 backgrounder, "Davis-Besse Atomic Reactor: 20 MORE Years of Radioactive Russian Roulette on the Great Lakes Shore?!"; #5, Aug. 2012 SB summary report, "What Humpty Dumpty Doesn't Want You to Know: Davis-Besse's Cracked Concrete Containment Snow Job". 

4. Joe DeMare's comments. Joe is a local resident near Davis-Besse. He is also an official intervener, as part of the environmental coalition, against the license extension. Joe is affiliated with the Ohio Green Party.

May 16, 2014: FENOC’s Answer Opposing Intervenors’ Motion for Admission of Contention No. 6.

May 16, 2014: NRC Staff’s Answer to Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems.

May 23, 2014: Intervenors’ Reply in Support of Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems.

July 3, 2014: FENOC filing "L-14-224," including: cover letter; Attachment L-14-224, "Reply to Requests for Additional Information for the Review of [LRA] Section B.2.42"; and Enclosure, Amendment No. 51 to the D-B LRA. NRC ADAMS ML# ML14184B184, 14 pages.

July 8, 2014: FENOC filing, "Notification of Documents Related to Davis-Besse Shield Building," including: Enclosure 1 (identical to July 3, 2014 post immediately above); and Enclosure 2, "Full Apparent Cause Evaluation, Shield Building Laminar Crack Propagation." NRC ADAMS Accession No. ML14189A452, 98 pages.

July 25, 2014: ASLB Memorandum and Order (Denying Intervenors' Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems). 19 pages.

September 29, 2014: Letter from E. Sayoc, NRC, to R. Lieb, FENOC, Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station License Renewal Application (TAC No. ME4640), available at ADAMS Accession No. ML14258A285 (requesting supplemental information regarding 2013 Shield Building operating experience).
NRC's posted schedule for Davis-Besse's License Renewal Application (LRA) proceeding shows that there are few hurdles left before NRC rubberstamps the 20-year extension. Davis-Besse's current, initial 40-year operating license expires on April 22 (Earth Day), 2017. The environmental Intervenors' filed a request for hearings and petitioned to intervene against the license extension by NRC's original deadline of December 27, 2010.
October 27, 2014: ASLBP NOTICE AND ORDER (Scheduling Oral Argument) [for November 12, 2014, as well as specifying subject areas of enquiry parties should be ready to discuss]
Saturday
Oct112014

Coalition presses case against containment cracking at Davis-Besse

An NRC inspector investigates cracking revealed in Davis-Besse's Shield Building wall shortly after it was discovered on 10/10/11.An environmental coalition, challenging the proposed 20-year license extension at FirstEnergy Nuclear Operating Company's (FENOC) Davis-Besse atomic reactor in Oak Harbor, OH on the Lake Erie shore, has filed a defense of its September 3rd and September 8th, 2014 contentions regarding worsening containment cracking.

This comes in response to October 3rd motions, by both FENOC and the U.S. Nuclear Regulatory Commission (NRC) staff, calling for the NRC's Atomic Safety and Licensing Board (ASLB) panel overseeing the nearly four-year-old License Renewal Application (LRA) proceeding, to dismiss the contentions.

The coalition consists of Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and the Green Party of Ohio. It is represented by Toledo-based attorney, Terry Lodge.

The coalition's filing on October 10th marks the third anniversary, to the day, of when severe cracking was first discovered and publicly announced at Davis-Besse, on Oct. 10, 2011 (see photo, above). The environmental coalition filed its first cracking contention in the proceeding a few months later, and has filed many more -- throughout 2012, and on Earth Day this year. However, all have been dismissed by the ASLB, despite many of the coalition's assertions later being acknowledged as correct by FENOC.

Davis-Besse's original 40-year license will expire on Earth Day (April 22nd), 2017. FENOC is seeking a 20-year extension, till 2037. NRC has rubber-stamped 73 such extensions since the year 2000.

Monday
Sep292014

Chris Williams to speak against Davis-Besse & Fermi

Chris Williams speaking at Nuclear-Free, Carbon-Free Contingent of the People's Climate March in New York City on Sept. 21stChris Williams (photo, left), the chairman of the board of directors of Nuclear Information and Resource Service (NIRS), and a lead organizer with Vermont Citizen Action Network (VCAN) and Vermont Yankee Decommissioning Alliance (VYDA), will speak out against the Davis-Besse, Ohio and Fermi, Michigan nuclear power plants during a Great Lakes tour in mid-October.

Chris will speak in Port Clinton, Ohio on Monday, October 13th (7 to 8:30pm at Ida Rupp Public Library, 310 Madison Street; see flier here), and in Bowling Green, Ohio on Tuesday, October 14th (7:30 to 8:30pm at BGSU Business Administration Building, Room 103; see flier here). Please see the linked fliers, print them up, post them, hand them out, and otherwise spread the word!

Chris will also speak in downtown Monroe, Michigan on Thursday, October 16th (Hospitality at 4pm; Teach In at 6pm; Slide Show at 7pm; at Loranger Square Pavilion, E. 1st St. & Washington St., 48161; see flier here).

During a quarter-century of service at Citizens Action Coalition of Indiana, including 18 years as executive director, Chris helped lead the effort that successfully blocked the proposed new nuclear power plant at Bailly in the Gary, IN/Indiana Dunes area on the Lake Michigan shore, as well as the proposed new nuclear plant at Marble Hill, on the banks of the Ohio River in Madison, IN. To this day, there are no atomic reactors located within the Hoosier State.

And since "retiring" to Vermont over a decade ago, Chris has helped achieve the tremendous grassroots victory of forcing Entergy Nuclear to permanently shut its Vermont Yankee reactor by the end of this year.

Chris's Lake Erie shoreline speaking tour is sponsored by Beyond Nuclear, Don't Waste Michigan, the Green Party of Ohio, and the Toledo Safe Energy Coalition, united in coalition to block old reactor license extensions at Fermi 2, MI and Davis-Besse, OH, and the proposed new reactor at Fermi 3, MI. The Fermi and Davis-Besse nuclear power plants are visible with the naked eye, one from the other, 30 miles apart as the crow flies, across Lake Erie.

Monday
Sep292014

17 groups urge NRC to halt licensing, relicensing of 23 reactors due to failure to address 2012 court ruling

Diane CurranAs reported by a coalition press release, 17 groups engaged in interventions against 23 old and new reactors have filed new contentions with U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) panels.

The contentions cite NRC's own lack of safety assurances regarding ultimate disposal of irradiated nuclear fuel, a recent reversal of NRC's previous so-called "Nuclear Waste Confidence." In addition to the contentions seeking to block new reactor licenses and old reactor license extensions, the coalition has requested stays on all proceedings until the matter is resolved.

Diane Curran (photo, above) of Harmon, Curran, Spielberg + Eisenberg, LLP in Washington, D.C., is a lead attorney representing the environmental coalition. Mindy Goldstein of Turner Environmental Law Clinic at Emory University in Atlanta also serves as a lead attorney on behalf of the coalition.

Dr. Mark Cooper of Vermont Law School, and Dr. Arjun Makhijani of Institute for Energy and Environmental Research, have each filed expert testimony on behalf of the coalition.

Beyond Nuclear's role in this coalition effort includes its intervention against old reactor license extensions at Davis-Besse, Ohio and Fermi 2, Michigan, as well as its intervention against the proposed new reactor at Fermi 3, Michigan. Toledo-based attorney Terry Lodge serves as legal counsel for the environmental coalitions intervening in these particular ASLB proceedings.