Generic Environmental 

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 56

Regarding Fermi 2 

Nuclear Power Plant

Final Report

Chapters 1 to 8

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 56

Volume 1

Generic Environmental

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 56 

Regarding Fermi 

Nuclear Power Plant

Final Report

 

Chapters 1 to 8

Manuscript Completed: August 2016

Date Published: September 2016

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 56

Volume 1

iii

COVER SHEET

Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor 

Regulation. There are no cooperating agencies involved in the preparation of this document.

Title: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, 

Supplement 56, Regarding Fermi 2 Nuclear Power Plant (NUREG–1437). Fermi 2 is located in 

Frenchtown Township, Michigan.

For additional information or copies of this document contact:

Division of License Renewal

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Mail Stop O-11F1

11555 Rockville Pike

Rockville, Maryland 20852

Phone: 1-800-368-5642, extension 8517

Fax: 301-415-2002

Email: elaine.keegan@nrc.gov

ABSTRACT

This supplemental environmental impact statement (SEIS) has been prepared in response to an 

application submitted by DTE Electric Company (DTE), to renew the operating license for the 

Fermi 2 Nuclear Power Plant for an additional 20 years.

This SEIS includes analyses that evaluate the environmental impacts of the proposed action 

and the alternatives to the proposed action. Alternatives considered include: (1) natural gas 

combined-cycle (NGCC), (2) coal-integrated gasification combined-cycle (IGCC), (3) new 

nuclear power generation, (4) a combination of NGCC, wind, and solar generation, and (5) the 

no-action alternative (i.e., no renewal of the license).

The U.S. Nuclear Regulatory Commission (NRC) staff’s recommendation is that the adverse 

environmental impacts of license renewal for Fermi 2 are not so great that preserving the option 

of license renewal for energy-planning decisionmakers would be unreasonable. The NRC staff 

based its recommendation on the following factors:

• the analysis and findings in NUREG–1437, Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Volumes 1 and 2;

• the Environmental Report submitted by DTE;

• consultation with Federal, state, tribal, and local government agencies;

• the NRC staff’s independent environmental review; and

• consideration of public comments received during the scoping process and received 

on the draft SEIS (DSEIS).

v

TABLE OF CONTENTS

ABSTRACT.............................................................................................................................. iii

TABLE OF CONTENTS ............................................................................................................ v

FIGURES................................................................................................................................. xv

TABLES ................................................................................................................................ xvii

EXECUTIVE SUMMARY ........................................................................................................ xxi

ABBREVIATIONS AND ACRONYMS ..................................................................................xxvii

1.0 INTRODUCTION......................................................................................................... 1-1

1.1 Proposed Federal Action.................................................................................. 1-1

1.2 Purpose and Need for Proposed Federal Action .............................................. 1-1

1.3 Major Environmental Review Milestones.......................................................... 1-1

1.4 Generic Environmental Impact Statement........................................................ 1-3

1.5 Supplemental Environmental Impact Statement............................................... 1-5

1.6 Decisions To Be Supported by the SEIS.......................................................... 1-6

1.7 Cooperating Agencies...................................................................................... 1-6

1.8 Consultations ................................................................................................... 1-6

1.9 Correspondence .............................................................................................. 1-7

1.10 Status of Compliance....................................................................................... 1-7

1.11 Related State and Federal Activities ................................................................ 1-7

1.12 References ...................................................................................................... 1-8

2.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION......................................... 2-1

2.1 Proposed Action .............................................................................................. 2-1

2.1.1 Plant Operations during the License Renewal Term.......................... 2-1

2.1.2 Refurbishment and Other Activities Associated with License 

Renewal ............................................................................................ 2-2

2.1.3 Termination of Nuclear Power Plant Operations and 

Decommissioning after the License Renewal Term ........................... 2-2

2.2 Alternatives...................................................................................................... 2-3

2.2.1 No-Action Alternative......................................................................... 2-3

2.2.2 Replacement Power Alternatives....................................................... 2-3

2.2.2.1 NGCC Alternative............................................................. 2-8

2.2.2.2 IGCC Alternative .............................................................. 2-8

2.2.2.3 New Nuclear Power Alternative...................................... 2-10

2.2.2.4 Combination Alternative (NGCC, Wind, and Solar) ........ 2-11

2.3 Alternatives Considered but Dismissed.......................................................... 2-14

2.3.1 Energy Conservation and Energy Efficiency.................................... 2-14

2.3.2 Solar................................................................................................ 2-15

2.3.3 Wind................................................................................................ 2-15
Table of Contents

vi

2.3.3.1 Offshore Wind ................................................................ 2-16

2.3.3.2 Wind Power with Storage ............................................... 2-16

2.3.3.3 Conclusion ..................................................................... 2-16

2.3.4 Biomass .......................................................................................... 2-17

2.3.5 Hydroelectric ................................................................................... 2-17

2.3.6 Wave and Ocean Energy................................................................. 2-18

2.3.7 Fuel Cells ........................................................................................ 2-18

2.3.8 Delayed Retirement......................................................................... 2-19

2.3.9 Geothermal...................................................................................... 2-19

2.3.10 Municipal Solid Waste ..................................................................... 2-19

2.3.11 Petroleum-Fired Power.................................................................... 2-20

2.3.12 Supercritical Pulverized Coal........................................................... 2-20

2.3.13 Purchased Power ............................................................................ 2-21

2.4 Comparison of Alternatives ............................................................................ 2-21

2.5 References .................................................................................................... 2-24

3.0 AFFECTED ENVIRONMENT ...................................................................................... 3-1

3.1 Description of Nuclear Power Plant Facility and Operation .............................. 3-1

3.1.1 External Appearance and Setting ...................................................... 3-1

3.1.2 Nuclear Reactor Systems .................................................................. 3-5

3.1.3 Cooling and Auxiliary Water Systems................................................ 3-5

3.1.3.1 General Service Water and Intake System....................... 3-6

3.1.3.2 Circulating Water System and Blowdown Discharge ........ 3-9

3.1.3.3 Residual Heat Removal Complex................................... 3-10

3.1.3.4 Potable Water System.................................................... 3-10

3.1.3.5 Fire Protection Water System......................................... 3-10

3.1.4 Radioactive Waste Management Systems ...................................... 3-11

3.1.4.1 Radioactive Liquid Waste Management ......................... 3-11

3.1.4.2 Radioactive Gaseous Waste Management..................... 3-14

3.1.4.3 Radioactive Solid Waste Management........................... 3-15

3.1.4.4 Radioactive Waste Storage............................................ 3-16

3.1.4.5 Radiological Environmental Monitoring Program............ 3-17

3.1.5 Nonradioactive Waste Management Systems ................................. 3-18

3.1.6 Utility and Transportation Infrastructure........................................... 3-19

3.1.6.1 Electricity........................................................................ 3-19

3.1.6.2 Fuel................................................................................ 3-19

3.1.6.3 Water ............................................................................. 3-20

3.1.6.4 Transportation Systems ................................................. 3-20

3.1.6.5 Power Transmission Systems ........................................ 3-20

3.1.7 Nuclear Power Plant Operations and Maintenance.......................... 3-23

3.2 Land Use and Visual Resources.................................................................... 3-23

3.2.1 Land Use......................................................................................... 3-23
Table of Contents

vii

3.2.1.1 Onsite Land Use ............................................................ 3-23

3.2.1.2 Offsite Land Use ............................................................ 3-28

3.2.1.3 Land Use Planning......................................................... 3-31

3.2.2 Visual Resources............................................................................. 3-31

3.3 Meteorology, Air Quality, and Noise............................................................... 3-32

3.3.1 Meteorology and Climatology .......................................................... 3-32

3.3.2 Air Quality........................................................................................ 3-33

3.3.3 Noise............................................................................................... 3-35

3.4 Geologic Environment.................................................................................... 3-37

3.4.1 Physiography and Geology.............................................................. 3-37

3.4.2 Soils ................................................................................................ 3-40

3.4.3 Seismic Setting................................................................................ 3-40

3.5 Water Resources ........................................................................................... 3-40

3.5.1 Surface Water Resources................................................................ 3-40

3.5.1.1 Surface Water Hydrology ............................................... 3-40

3.5.1.2 Surface Water Use......................................................... 3-44

3.5.1.3 Surface Water Quality and Effluents............................... 3-45

3.5.2 Groundwater Resources.................................................................. 3-49

3.5.2.1 Site Description and Hydrogeology ................................ 3-49

3.5.2.2 Groundwater Use........................................................... 3-52

3.5.2.3 Groundwater Quality ...................................................... 3-54

3.6 Terrestrial Resources..................................................................................... 3-55

3.6.1 Fermi 2 Ecoregion ........................................................................... 3-55

3.6.2 Fermi Site Surveys, Studies, and Reports ....................................... 3-55

3.6.3 Fermi Site........................................................................................ 3-57

3.6.3.1 Vegetation...................................................................... 3-58

3.6.3.2 Animals .......................................................................... 3-61

3.6.4 Fermi 2 Wildlife Management Plan .................................................. 3-65

3.6.5 Important Species and Habitats....................................................... 3-65

3.6.5.1 Important Species .......................................................... 3-65

3.6.5.2 Important Habitats.......................................................... 3-68

3.6.6 Bird Collisions and Strikes ............................................................... 3-72

3.7 Aquatic Resources......................................................................................... 3-74

3.7.1 Aquatic Resources—Site and Vicinity.............................................. 3-75

3.7.1.1 Circulating Water Reservoir (Cooling Water Pond 

and Circulation Pond)..................................................... 3-75

3.7.1.2 Overflow and Discharge Canals ..................................... 3-75

3.7.1.3 Drainage Ditches............................................................ 3-76

3.7.1.4 Quarry Lakes ................................................................. 3-76

3.7.1.5 Wetland Ponds and Marshes Managed as Part of 

the DRIWR..................................................................... 3-76
Table of Contents

viii

3.7.1.6 Swan Creek ................................................................... 3-76

3.7.1.7 Stony Creek ................................................................... 3-77

3.7.1.8 Lake Erie........................................................................ 3-78

3.7.2 Aquatic Habitats—Transmission Lines ............................................ 3-88

3.7.3 Important Aquatic Species and Habitats—Site and Vicinity ............. 3-88

3.7.3.1 Commercially Important Species.................................... 3-89

3.7.3.2 Recreationally Important Species................................. 3-100

3.7.3.3 State-Listed Aquatic Species........................................ 3-103

3.7.3.4 Non-Native Nuisance Species...................................... 3-112

3.7.4 Aquatic Species and Habitats in the Transmission Line Corridor... 3-116

3.7.5 Aquatic Monitoring......................................................................... 3-116

3.8 Special Status Species and Habitats............................................................ 3-116

3.8.1 Species and Habitats Protected under the Endangered Species 

Act................................................................................................. 3-116

3.8.1.1 Action Area .................................................................. 3-116

3.8.1.2 Species and Habitats under the FWS’s Jurisdiction ..... 3-117

3.8.1.3 Species and Habitats under the NMFS’s Jurisdiction ... 3-126

3.8.2 Species and Habitats Protected under the Magnuson–Stevens 

Act................................................................................................. 3-126

3.9 Historic and Cultural Resources................................................................... 3-126

3.9.1 Cultural Background...................................................................... 3-127

3.9.2 Historic and Cultural Resources .................................................... 3-129

3.10 Socioeconomics........................................................................................... 3-131

3.10.1 Power Plant Employment and Expenditures.................................. 3-131

3.10.2 Regional Economic Characteristics ............................................... 3-132

3.10.2.1 Employment and Income.............................................. 3-132

3.10.2.2 Unemployment............................................................. 3-134

3.10.3 Demographic Characteristics......................................................... 3-134

3.10.3.1 Transient Population .................................................... 3-137

3.10.3.2 Migrant Farm Workers.................................................. 3-138

3.10.4 Housing and Community Services................................................. 3-139

3.10.4.1 Housing........................................................................ 3-139

3.10.4.2 Education..................................................................... 3-140

3.10.4.3 Public Water Supply..................................................... 3-140

3.10.5 Tax Revenues ............................................................................... 3-142

3.10.6 Local Transportation...................................................................... 3-145

3.11 Human Health.............................................................................................. 3-146

3.11.1 Radiological Exposure and Risk .................................................... 3-146

3.11.2 Chemical Hazards ......................................................................... 3-147

3.11.3 Microbiological Hazards................................................................. 3-148

3.11.3.1 Background Information on Microorganisms of 

Concern ....................................................................... 3-148
Table of Contents

ix

3.11.3.2 Studies of Microorganisms in Cooling Towers.............. 3-149

3.11.3.3 Microbiological Hazards to Plant Workers .................... 3-149

3.11.3.4 Microbiological Hazards to the Public........................... 3-149

3.11.4 Electromagnetic Fields .................................................................. 3-149

3.11.5 Other Hazards ............................................................................... 3-151

3.12 Environmental Justice.................................................................................. 3-151

3.12.1 Minority Population........................................................................ 3-152

3.12.2 Low-Income Population ................................................................. 3-155

3.13 Waste Management and Pollution Prevention.............................................. 3-157

3.13.1 Radioactive Waste......................................................................... 3-157

3.13.2 Nonradioactive Waste ................................................................... 3-157

3.14 References .................................................................................................. 3-157

4.0 ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS....................... 4-1

4.1 Introduction...................................................................................................... 4-1

4.2 Land Use and Visual Resources...................................................................... 4-1

4.2.1 Proposed Action ................................................................................ 4-1

4.2.2 No-Action Alternative......................................................................... 4-2

4.2.2.1 Land Use.......................................................................... 4-2

4.2.2.2 Visual Resources ............................................................. 4-2

4.2.3 Natural Gas Combined-Cycle Alternative .......................................... 4-3

4.2.3.1 Land Use.......................................................................... 4-3

4.2.3.2 Visual Resources ............................................................. 4-3

4.2.4 Integrated Gasification Combined-Cycle Alternative.......................... 4-3

4.2.4.1 Land Use.......................................................................... 4-3

4.2.4.2 Visual Resources ............................................................. 4-4

4.2.5 New Nuclear Alternative .................................................................... 4-4

4.2.5.1 Land Use.......................................................................... 4-4

4.2.5.2 Visual Resources ............................................................. 4-5

4.2.6 Combination Alternative (NGCC, Wind, and Solar)............................ 4-5

4.2.6.1 Land Use.......................................................................... 4-5

4.2.6.2 Visual Resources ............................................................. 4-5

4.3 Air Quality and Noise ....................................................................................... 4-6

4.3.1 Proposed Action ................................................................................ 4-6

4.3.1.1 Air Quality ........................................................................ 4-6

4.3.1.2 Noise................................................................................ 4-6

4.3.2 No-Action Alternative......................................................................... 4-7

4.3.2.1 Air Quality ........................................................................ 4-7

4.3.2.2 Noise................................................................................ 4-7

4.3.3 NGCC Alternative.............................................................................. 4-7

4.3.3.1 Air Quality ........................................................................ 4-7

4.3.3.2 Noise.............................................................................. 4-10
Table of Contents

x

4.3.4 IGCC Alternative ............................................................................. 4-11

4.3.4.1 Air Quality ...................................................................... 4-11

4.3.4.2 Noise.............................................................................. 4-13

4.3.5 New Nuclear Alternative .................................................................. 4-14

4.3.5.1 Air Quality ...................................................................... 4-14

4.3.5.2 Noise.............................................................................. 4-16

4.3.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-17

4.3.6.1 Air Quality ...................................................................... 4-17

4.3.6.2 Noise.............................................................................. 4-19

4.4 Geologic Environment.................................................................................... 4-21

4.4.1 Proposed Action .............................................................................. 4-21

4.4.2 No-Action Alternative....................................................................... 4-21

4.4.3 NGCC Alternative............................................................................ 4-21

4.4.4 IGCC Alternative ............................................................................. 4-22

4.4.5 New Nuclear Alternative .................................................................. 4-22

4.4.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-22

4.5 Water Resources ........................................................................................... 4-22

4.5.1 Proposed Action .............................................................................. 4-22

4.5.1.1 Surface Water Resources .............................................. 4-22

4.5.1.2 Groundwater Resources ................................................ 4-23

4.5.2 No-Action Alternative....................................................................... 4-24

4.5.2.1 Surface Water Resources .............................................. 4-24

4.5.2.2 Groundwater Resources ................................................ 4-24

4.5.3 NGCC Alternative............................................................................ 4-24

4.5.3.1 Surface Water Resources .............................................. 4-24

4.5.3.2 Groundwater Resources ................................................ 4-26

4.5.4 IGCC Alternative ............................................................................. 4-26

4.5.4.1 Surface Water Resources .............................................. 4-26

4.5.4.2 Groundwater Resources ................................................ 4-27

4.5.5 New Nuclear Alternative .................................................................. 4-27

4.5.5.1 Surface Water Resources .............................................. 4-27

4.5.5.2 Groundwater Resources ................................................ 4-28

4.5.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-29

4.5.6.1 Surface Water Resources .............................................. 4-29

4.5.6.2 Groundwater Resources ................................................ 4-30

4.6 Terrestrial Resources..................................................................................... 4-30

4.6.1 Proposed Action .............................................................................. 4-30

4.6.1.1 Generic Terrestrial Resource Issues .............................. 4-30

4.6.1.2 Effects on Terrestrial Resources (Noncooling 

System Impacts) ............................................................ 4-31

4.6.2 No-Action Alternative....................................................................... 4-32
Table of Contents

xi

4.6.3 NGCC Alternative............................................................................ 4-33

4.6.4 IGCC Alternative ............................................................................. 4-34

4.6.5 New Nuclear Alternative .................................................................. 4-34

4.6.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-35

4.7 Aquatic Resources......................................................................................... 4-36

4.7.1 Proposed Action .............................................................................. 4-36

4.7.1.1 Generic GEIS Issues...................................................... 4-36

4.7.2 No-Action Alternative....................................................................... 4-37

4.7.3 NGCC Alternative............................................................................ 4-37

4.7.4 IGCC Alternative ............................................................................. 4-38

4.7.5 New Nuclear Alternative .................................................................. 4-38

4.7.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-39

4.8 Special Status Species and Habitats.............................................................. 4-39

4.8.1 Proposed Action .............................................................................. 4-39

4.8.1.1 Species and Habitats Protected under the 

Endangered Species Act of 1973 ................................... 4-40

4.8.1.2 Species and Habitats Protected under the 

Magnuson–Stevens Act of 2006..................................... 4-49

4.8.2 No-Action Alternative....................................................................... 4-49

4.8.3 NGCC Alternative............................................................................ 4-50

4.8.4 IGCC Alternative ............................................................................. 4-50

4.8.5 New Nuclear Alternative .................................................................. 4-51

4.8.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-51

4.9 Historic and Cultural Resources..................................................................... 4-52

4.9.1 Proposed Action .............................................................................. 4-52

4.9.2 No-Action Alternative....................................................................... 4-54

4.9.3 NGCC Alternative............................................................................ 4-54

4.9.4 IGCC Alternative ............................................................................. 4-55

4.9.5 New Nuclear Alternative .................................................................. 4-55

4.9.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-56

4.10 Socioeconomics............................................................................................. 4-57

4.10.1 Proposed Action .............................................................................. 4-57

4.10.2 No-Action Alternative....................................................................... 4-58

4.10.2.1 Socioeconomics............................................................. 4-58

4.10.2.2 Transportation................................................................ 4-58

4.10.3 NGCC Alternative............................................................................ 4-58

4.10.3.1 Socioeconomics............................................................. 4-58

4.10.3.2 Transportation................................................................ 4-59

4.10.4 IGCC Alternative ............................................................................. 4-60

4.10.4.1 Socioeconomics............................................................. 4-60

4.10.4.2 Transportation................................................................ 4-60
Table of Contents

xii

4.10.5 New Nuclear Alternative .................................................................. 4-61

4.10.5.1 Socioeconomics............................................................. 4-61

4.10.5.2 Transportation................................................................ 4-62

4.10.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-62

4.10.6.1 Socioeconomics............................................................. 4-62

4.10.6.2 Transportation................................................................ 4-63

4.11 Human Health................................................................................................ 4-63

4.11.1 Proposed Action .............................................................................. 4-63

4.11.1.1 Normal Operating Conditions ......................................... 4-64

4.11.1.2 Environmental Impacts of Postulated Accidents............. 4-65

4.11.2 No-Action Alternative....................................................................... 4-75

4.11.3 NGCC Alternative............................................................................ 4-75

4.11.4 IGCC Alternative ............................................................................. 4-75

4.11.5 New Nuclear Alternative .................................................................. 4-76

4.11.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-76

4.12 Environmental Justice.................................................................................... 4-77

4.12.1 Proposed Action .............................................................................. 4-77

4.12.2 No-Action Alternative....................................................................... 4-79

4.12.3 NGCC Alternative............................................................................ 4-80

4.12.4 IGCC Alternative ............................................................................. 4-80

4.12.5 New Nuclear Alternative .................................................................. 4-81

4.12.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-82

4.13 Waste Management and Pollution Prevention................................................ 4-82

4.13.1 Proposed Action .............................................................................. 4-83

4.13.2 No-Action Alternative....................................................................... 4-83

4.13.3 NGCC Alternative............................................................................ 4-84

4.13.4 IGCC Alternative ............................................................................. 4-84

4.13.5 New Nuclear Alternative .................................................................. 4-84

4.13.6 Combination Alternative (NGCC, Wind, and Solar).......................... 4-85

4.14 Evaluation of New and Potentially Significant Information.............................. 4-85

4.15 Impacts Common to All Alternatives............................................................... 4-89

4.15.1 Fuel Cycle ....................................................................................... 4-90

4.15.1.1 Uranium Fuel Cycle........................................................ 4-90

4.15.1.2 Replacement Power Plant Fuel Cycles .......................... 4-91

4.15.2 Terminating Power Plant Operations and Decommissioning ........... 4-92

4.15.2.1 Existing Nuclear Power Plant ......................................... 4-92

4.15.2.2 Replacement Power Plants ............................................ 4-92

4.15.3 Greenhouse Gas Emissions and Climate Change........................... 4-93

4.15.3.1 Greenhouse Gas Emissions from the Proposed 

Project and Alternatives ................................................. 4-93

4.15.3.2 Climate Change Impacts to Resource Areas.................. 4-96
Table of Contents

xiii

4.16 Cumulative Impacts of the Proposed Action................................................. 4-103

4.16.1 Air Quality and Noise..................................................................... 4-104

4.16.1.1 Air Quality .................................................................... 4-104

4.16.1.2 Noise............................................................................ 4-105

4.16.2 Geology and Soils ......................................................................... 4-106

4.16.3 Water Resources........................................................................... 4-106

4.16.3.1 Surface Water Resources ............................................ 4-106

4.16.3.2 Groundwater Resources .............................................. 4-113

4.16.4 Terrestrial Resources .................................................................... 4-115

4.16.4.1 Conclusion ................................................................... 4-118

4.16.5 Aquatic Resources ........................................................................ 4-118

4.16.6 Historic and Cultural Resources .................................................... 4-124

4.16.7 Socioeconomics ............................................................................ 4-125

4.16.7.1 Conclusion ................................................................... 4-126

4.16.8 Human Health ............................................................................... 4-126

4.16.9 Environmental Justice ................................................................... 4-127

4.16.9.1 Conclusion ................................................................... 4-128

4.16.10 Waste Management and Pollution Prevention ............................... 4-128

4.16.11 Global Climate Change ................................................................. 4-129

4.16.12 Summary of Cumulative Impacts................................................... 4-131

4.17 Resource Commitments Associated with the Proposed Action .................... 4-133

4.17.1 Unavoidable Adverse Environmental Impacts................................ 4-133

4.17.2 Relationship between Short-Term Use of the Environment and 

Long-Term Productivity ................................................................. 4-133

4.17.3 Irreversible and Irretrievable Commitment of Resources ............... 4-134

4.18 References .................................................................................................. 4-134

5.0 CONCLUSION ............................................................................................................ 5-1

5.1 Environmental Impacts of License Renewal..................................................... 5-1

5.2 Comparison of Alternatives .............................................................................. 5-1

5.3 Recommendations........................................................................................... 5-1

6.0 LIST OF PREPARERS ............................................................................................... 6-1

7.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES 

OF THIS SEIS ARE SENT .......................................................................................... 7-1

8.0 INDEX ......................................................................................................................... 8-1

APPENDIX A COMMENTS RECEIVED ON THE FERMI 2 ENVIRONMENTAL 

REVIEW........................................................................................................A-1

APPENDIX B APPLICABLE LAWS, REGULATIONS, AND OTHER 

REQUIREMENTS.........................................................................................B-1

APPENDIX C CONSULTATION CORRESPONDENCE .....................................................C-1
Table of Contents

xiv

APPENDIX D CHRONOLOGY OF ENVIRONMENTAL REVIEW 

CORRESPONDENCE ..................................................................................D-1

APPENDIX E ACTIONS AND PROJECTS CONSIDERED IN CUMULATIVE 

ANALYSIS....................................................................................................E-1

APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION 

OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR FERMI 

UNIT 2 NUCLEAR STATION, IN SUPPORT OF LICENSE RENEWAL 

APPLICATION REVIEW...............................................................................F-1
xv

FIGURES

Figure 1–1. Environmental Review Process........................................................................ 1-2

Figure 1–2. Environmental Issues Evaluated for License Renewal ..................................... 1-5

Figure 3–1. Fermi 2 50-mi (80-km) Radius Map.................................................................. 3-2

Figure 3–2. Fermi 2 6-mi (10-km) Radius Map.................................................................... 3-3

Figure 3–3. Fermi 2 Site Boundary ..................................................................................... 3-4

Figure 3–4. Closed-Cycle Cooling System with Natural Draft Cooling Tower...................... 3-6

Figure 3–5. Fermi 2 Cooling Water Supply Facilities and Major Surface Water 

Features .......................................................................................................... 3-8

Figure 3–6. Fermi 2 In-Scope Transmission Lines............................................................ 3-22

Figure 3–7. Fermi Site Land Uses .................................................................................... 3-25

Figure 3–8. Detroit River International Wildlife Refuge, Lagoona Beach Unit 

Boundaries on the Fermi Site......................................................................... 3-27

Figure 3–9. Land Use and Land Cover within a 6-mi (10-km) Radius of the Fermi 

Site ................................................................................................................ 3-30

Figure 3–10. Topographic Map and Site Boundary............................................................. 3-38

Figure 3–11. Fermi Site Geologic Column .......................................................................... 3-39

Figure 3–12. Surface Water Features at the Fermi Site and Vicinity ................................... 3-42

Figure 3–13. Bed Rock Water Levels and Lateral Groundwater Flow Directions ................ 3-51

Figure 3–14. Wells within 2 mi (3 km) of Fermi ................................................................... 3-53

Figure 3–15. Delineated Wetlands on the Fermi Site.......................................................... 3-71

Figure 3–16. Estimated Abundance of Walleye Aged 2 and Older in Lake Erie, 

1980–2010 (Lake Erie Walleye Task Group 2010)......................................... 3-96

Figure 3–17. Estimated Abundance of Yellow Perch Aged 2 and Older in the Western 

Basin of Lake Erie, 1975–2010 (Lake Erie Yellow Perch Task Group 

2010) ............................................................................................................. 3-99

Figure 3–18. 2010 U.S. Census Minority Block Groups within a 50-mi (80-km) Radius 

of Fermi 2 .................................................................................................... 3-154

Figure 3–19. U.S. Census Low-Income Block Groups within a 50-mi (80-km) Radius 

of Fermi 2 .................................................................................................... 3-156

xvii

TABLES

Table ES–1. Summary of NRC Conclusions Relating to Site-Specific Impacts of 

License Renewal............................................................................................. xxiii

Summary of Replacement Power Alternatives and Key Characteristics 

Considered In Depth........................................................................................ 2-6

Summary of Environmental Impacts of the Proposed Action and 

Alternatives.................................................................................................... 2-22

Fermi 2 Nonnuclear Fuel Storage Units ......................................................... 3-19

Fermi Site Land Uses by Area ....................................................................... 3-23

Monroe County Land Use, 2008 .................................................................... 3-29

Monroe County Land Cover, 2010 ................................................................. 3-29

Air Emission Estimates for Permitted Combustion Sources at Fermi 2........... 3-35

Common Noise Sources and Noise Levels .................................................... 3-36

Annual Surface Water Withdrawals and Return Discharges to Lake Erie, 

Fermi 2 .......................................................................................................... 3-44

NPDES-Permitted Outfalls, Fermi 2 ............................................................... 3-47

Vegetative Cover Types and Dominant Species on the Fermi Site by 

Area............................................................................................................... 3-58

Mammals Observed on the Fermi Site, 2008–2009 ....................................... 3-63

Reptiles and Amphibians Observed on the Fermi Site, 2008–2009................ 3-64

Rare Species with Known Occurrences within 1.5 mi (2.4 km) of the 

Fermi Site ...................................................................................................... 3-65

Delineated Wetlands on the Fermi Site by Area............................................. 3-70

Bird Strike Occurrences, 2005–2014.............................................................. 3-73

Bird Strike Monitoring Data, 2008–2009......................................................... 3-73

Percent Abundance of Fish Species Collected in Lake Erie near the 

Fermi Site during 2008 and 2009................................................................... 3-83

Estimated Numbers of Fish Eggs and Larvae Entrained by the Fermi 2 

Cooling Water Intake from July 2008–July 2009 ............................................ 3-85

Estimated Numbers of Fish Impinged by the Fermi 2 Cooling Water 

Intake from August 2008–July 2009............................................................... 3-87

Important Aquatic Species That Have Been Observed in the Vicinity of 

the Fermi Site ................................................................................................ 3-88

Commercial Fishery Statistics for Michigan from Lake Erie during 2010 ........ 3-90

Commercial Fishery Statistics for Ohio from Lake Erie during 2010............... 3-91

Exclusively State-Listed Aquatic Species That Have Been Observed in 

Monroe County and Their Potential To Occur on the Fermi Site .................. 3-103

Federally Listed Species in Monroe County, Michigan ................................. 3-117

Cultural Resources Located within the Fermi Site........................................ 3-130

Fermi 2 Employees Residence by County/Province..................................... 3-132

Employment by Industry in the Fermi 2 ROI (2013 Estimates) ..................... 3-133

Major Employers in Monroe County in 2013................................................. 3-133
Tables

xviii

Estimated Income Information for the Fermi 2 ROI (2013 Estimates)........... 3-134

Population and Percent Growth in Fermi 2 ROI Counties, 1970–2010, 

2013 (Estimated), and Projected for 2020–2060 .......................................... 3-135

Demographic Profile of the Population in the Fermi 2 ROI in 2010............... 3-135

Demographic Profile of the Population in the Fermi 2 ROI in 2013............... 3-136

2013 Estimated Seasonal Housing in Counties Located within 50 mi 

(80 km) of Fermi 2........................................................................................ 3-137

Migrant Farm Workers and Temporary Farm Labor in Counties Located 

within 50 mi (80 km) of Fermi 2 (2012)......................................................... 3-138

Housing in the Fermi 2 ROI (2013 estimate) ................................................ 3-139

Local Public Water Supply Systems............................................................. 3-140

Fermi 2 Property Tax Distribution 2009–2013 (in Dollars)............................ 3-142

Property Taxes Paid for Fermi 2 by Millage Type, 2013 Tax Year................ 3-142

2013 Frenchtown Charter Township Millage Totals by District ..................... 3-144

2013 Fermi 2 Property Tax Distribution in Millage........................................ 3-144

2013 Fermi 2 Property Tax Distribution as a Percentage of Total 

Property Taxes Collected by Frenchtown Township..................................... 3-145

Major Commuting Routes in the Vicinity of Fermi 2: 2013 Average 

Annual Daily Traffic Count ........................................................................... 3-146

Land Use and Visual Resource Issues............................................................. 4-2

Air Quality and Noise ....................................................................................... 4-6

Geology and Soils Issues............................................................................... 4-21

Surface Water Resources Issues................................................................... 4-22

Groundwater Issues....................................................................................... 4-23

Terrestrial Resource Issues ........................................................................... 4-30

Aquatic Resource Issues ............................................................................... 4-36

Special Status Species and Habitat Issues .................................................... 4-40

Effect Determinations for Federally Listed Species ........................................ 4-41

Historic and Cultural Resources..................................................................... 4-52

Socioeconomic NEPA Issues......................................................................... 4-57

Human Health Issues..................................................................................... 4-63

Issues Related to Postulated Accidents ......................................................... 4-65

Potentially Cost-Beneficial SAMAs for Fermi Unit 2 ....................................... 4-71

Estimated Cost Ranges of SAMA Implementation Costs at Fermi Unit 2 ....... 4-73

Environmental Justice NEPA Issue................................................................ 4-77

Waste Management Issues............................................................................ 4-83

Issues Related to the Uranium Fuel Cycle ..................................................... 4-90

Issues Related to Decommissioning .............................................................. 4-92

Estimated GHG Emissions from Operations at Fermi 2.................................. 4-94

Direct GHG Emissions from Operation of the Proposed Action and 

Alternatives.................................................................................................... 4-96
Tables

xix

Cumulative Surface Water Withdrawals from the Michigan Portion of the 

Lake Erie Watershed by Water Use Sector (2013)....................................... 4-108

Comparison of GHG Emission Inventories................................................... 4-130

Summary of Cumulative Impacts on Resource Areas .................................. 4-131

List of Preparers .............................................................................................. 6-1

List of Agencies, Organizations, and Persons to Whom Copies of This 

SEIS Are Sent.................................................................................................. 7-1

Table A–1. Individuals Providing Comments during the Scoping Comment Period ............A-2

Table A–2. Issue Categories..............................................................................................A-5

Table A–3. Commenters on the Draft Supplemental Environmental Impact

Statement ....................................................................................................A-312

Table A–4. Issue Categories..........................................................................................A-315

Table B–1. Federal and State Requirements .....................................................................B-2

Table B–2. Licenses and Permits.......................................................................................B-6

Table C–1. ESA Section 7 Consultation Correspondence..................................................C-3

Table C–2. NHPA Correspondence....................................................................................C-4

Table D–1. Environmental Review Correspondence ..........................................................D-1

Table E–1. Actions and Projects Considered in Cumulative Analysis.................................E-1

Table F–1. Fermi 2 CDF for Internal Events.......................................................................F-2

Table F–2. Base Case Mean Population Dose Risk and Offsite Economic Cost Risk 

for Internal Events............................................................................................F-4

Table F–3. Summary of Major PRA Models and Corresponding CDF and LERF 

Results.............................................................................................................F-5

Table F–4. Fermi 2 Important Contributors to Fire CDF ................................................... F-11

Table F–5. SAMA Cost/Benefit Screening Analysis for Fermi 2 Station ........................... F-30

Table F–6. Adjusted Cost/Benefit Analysis for SAMAs Impacted by Accident 

Class IIA Consequence Revisions ................................................................. F-54

xxi

EXECUTIVE SUMMARY

BACKGROUND

By letter dated April 24, 2014, DTE Electric Company (DTE) submitted an application to the 

U.S. Nuclear Regulatory Commission (NRC) to issue a renewed operating license for Fermi 2

Nuclear Power Plant (Fermi 2) for an additional 20-year period.

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 51.20(b)(2), the renewal of a 

power reactor operating license requires preparation of an environmental impact statement 

(EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that, in connection 

with the renewal of an operating license, the NRC shall prepare an EIS, which is a supplement 

to the Commission’s NUREG-1437, Generic Environmental Impact Statement (GEIS) for 

License Renewal of Nuclear Plants.

Upon acceptance of DTE’s application, the NRC staff began the environmental review process 

described in 10 CFR Part 51 by publishing a Notice of Intent to prepare a supplemental 

environmental impact statement (SEIS) and to conduct scoping. In preparation of this SEIS for 

Fermi 2, the NRC staff performed the following:

• conducted public scoping meetings on July 24, 2014, in Monroe, Michigan;

• conducted a site audit at Fermi 2 from September 8, 2014, to September 11, 2014;

• reviewed DTE’s Environmental Report (ER) and compared it to the GEIS; 

• consulted with Federal, state, tribal, and local agencies;

• conducted a review of the issues following the guidance set forth in

Standard Review Plans for Environmental Reviews for Nuclear Power Plants: 

Environmental Standard Review Plan for Operating License Renewal (NUREG-1555

Supplement 1, Revision 1, Final Report);

• considered public comments received during the scoping process;

• issued the draft SEIS (DSEIS) for comment;

• conducted a public meeting to receive comments on the DSEIS on 

December 2, 2015; and

• considered the public comments received during the DSEIS comment period.

PROPOSED ACTION

DTE initiated the proposed Federal action (i.e., issuance of a renewed power reactor operating 

license) by submitting an application for license renewal of Fermi 2 for which the existing license 

(NPF-43) expires on March 20, 2025. The NRC’s Federal action is to decide whether to renew 

the license for an additional 20 years. The regulation at 10 CFR 2.109 states that, if a licensee 

of a nuclear power plant files an application to renew an operating license at least 5 years 

before the expiration date of that license, the existing license will not be deemed to have expired 

until the safety and environmental reviews are completed and until the NRC has made a final 

decision on whether to deny the application or to issue a renewed license for the additional 

20 years.
Executive Summary

xxii

PURPOSE AND NEED FOR ACTION

The purpose and need for the proposed action (issuance of renewed license) is to provide an 

option that allows for baseload power generation capability beyond the term of the current 

nuclear power plant operating license to meet future system generating needs. Such needs 

may be determined by other energy-planning decisionmakers, such as states, operators, and, 

where authorized, Federal agencies (other than the NRC). This definition of purpose and need 

reflects the NRC’s recognition that, unless there are findings in the safety review required by the 

Atomic Energy Act of 1954, as amended, or findings in the National Environmental Policy Act of 

1969, as amended, environmental analysis that would lead the NRC to reject a license renewal 

application, the NRC does not have a role in the energy-planning decisions as to whether a 

particular nuclear power plant should continue to operate.

ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL

The SEIS evaluates the potential environmental impacts of the proposed action. The 

environmental impacts from the proposed action are designated as SMALL, MODERATE, or 

LARGE. As established in the GEIS, Category 1 issues are those that meet all of the following 

criteria:

The environmental impacts associated with the issue 

are determined to apply either to all plants or, for 

some issues, to plants having a specific type of 

cooling system or other specified plant or site 

characteristics.

A single significance level (i.e., SMALL, MODERATE, 

or LARGE) has been assigned to the impacts except 

for collective offsite radiological impacts from the fuel 

cycle and from high-level waste and spent fuel

disposal.

Mitigation of adverse impacts associated with the 

issue is considered in the analysis, and it has been 

determined that additional plant-specific mitigation

measures are likely not to be sufficiently beneficial to warrant implementation.

For Category 1 issues, no additional site-specific analysis is required in this SEIS unless new 

and significant information is identified. Chapter 4 of this SEIS presents the process for 

identifying new and significant information. Site-specific issues (Category 2) are those that do 

not meet one or more of the criteria for Category 1 issues; therefore, an additional site-specific 

review for these nongeneric issues is required, and the results are documented in the SEIS. 

Neither DTE nor the NRC identified information that is both new and significant related to 

Category 1 issues that would call into question the conclusions in the GEIS. This conclusion is 

supported by the NRC staff’s review of the applicant’s ER and other documentation relevant to 

the applicant’s activities, the public scoping process and substantive comments raised, and the 

findings from the environmental site audit conducted by the NRC staff. Therefore, the NRC staff

relied upon the conclusions of the GEIS for all Category 1 issues applicable to Fermi 2.

Table ES-1 summarizes the Category 2 issues relevant to Fermi 2 and the NRC staff’s findings 

related to those issues. If the NRC staff determined that there were no Category 2 issues 

applicable for a particular resource area, the findings of the GEIS, as documented in 

Appendix B to Subpart A of 10 CFR Part 51, are incorporated for that resource area.

SMALL: Environmental effects are not 

detectable or are so minor that they will 

neither destabilize nor noticeably alter 

any important attribute of the resource.

MODERATE: Environmental effects are 

sufficient to alter noticeably, but not to 

destabilize, important attributes of the 

resource.

LARGE: Environmental effects are 

clearly noticeable and are sufficient to 

destabilize important attributes of the 

resource.
Executive Summary

xxiii

Table ES–1. Summary of NRC Conclusions Relating to Site-Specific Impacts of

License Renewal

Resource Area Relevant Category 2 Issues Impacts

Groundwater Resources Radionuclides released to groundwater SMALL

Terrestrial Resources Effects on terrestrial resources (noncooling 

system impacts)

SMALL

Special Status Species and 

Habitats

Threatened, endangered, and species and 

essential fish habitat

No effect(a)

Historic and Cultural

Resources

Historic and cultural resources No adverse effect(b)

Human Health Electric shock hazards SMALL

Environmental Justice Minority and low-income populations See note below(c)

Cumulative Impacts Air Quality and Noise

Geology and Soils

Water Resources

Terrestrial Ecology

Aquatic Resources

Historic and Cultural Resources

Socioeconomic

Human Health

Environmental Justice

Waste Management

Global Climate Change

SMALL

SMALL

SMALL to MODERATE

MODERATE to LARGE

LARGE

SMALL

SMALL to LARGE

SMALL

See note below(c)

SMALL

MODERATE

(a) For Federally protected species, the NRC reports the effects from continued operation of Fermi 2 during the 

license renewal period in terms of its Endangered Species Act of 1973, as amended, findings of “no effect,” “may 

effect, but not likely to adversely effect,” or “may affect, and is likely to adversely affect.”

(b) The National Historic Preservation Act of 1966, as amended, requires Federal agencies to consider the effects of 

their undertakings on historic properties.

(c) There would be no disproportionately high and adverse impacts to minority and low-income populations and 

subsistence consumption from continued operation of Fermi 2 during the license renewal period and from 

cumulative impacts.

SEVERE ACCIDENT MITIGATION ALTERNATIVES

Since severe accident mitigation alternatives (SAMAs) have not been previously considered in 

an environmental impact statement or environmental assessment for Fermi 2, 

10 CFR 51.53(c)(3)(ii)(L) requires DTE to submit, with the ER, a consideration of alternatives to 

mitigate severe accidents. SAMAs are potential ways to reduce the risk or potential impacts of 

uncommon, but potentially severe accidents. SAMAs may include changes to plant 

components, systems, procedures, and training.

The NRC staff reviewed DTE’s ER evaluation of potential SAMAs and determined whether the 

identified potentially cost-beneficial SAMAs are subject to aging management. Because the 

potential cost-beneficial SAMAs are associated with procedure changes, new hardware to 

improve a manual action, and a new structure between switchgear rooms, the NRC staff 
Executive Summary

xxiv

determined that these SAMAs do not relate to managing the effects of aging during the period of 

extended operation. Therefore, the potentially cost-beneficial SAMAs identified need not be 

implemented as part of the license renewal, pursuant to 10 CFR Part 54.

ALTERNATIVES

The NRC staff considered the environmental impacts associated with alternatives to license 

renewal. These alternatives include other methods of power generation, as well as not 

renewing the Fermi 2 operating license (the no-action alternative). The NRC staff considered 

the following feasible and commercially viable replacement power alternatives:

• natural gas combined-cycle (NGCC);

• coal-integrated gasification combined-cycle (IGCC);

• new nuclear power; and

• a combination of NGCC, wind, and solar power.

The NRC staff initially considered a number of additional alternatives for analysis as alternatives 

to the license renewal of Fermi 2. The NRC staff later dismissed these alternatives because of

technical, resource availability, or commercial limitations that currently exist and that the NRC 

staff believes are likely to continue to exist when the current Fermi 2 license expires. The 

no-action alternative and the effects it would have were also considered by the NRC staff.

Where possible, the NRC staff evaluated potential environmental impacts for these alternatives

located at both the Fermi 2 site and some other unspecified alternate location. The NRC staff 

considered the following alternatives, but dismissed them:

• energy conservation and energy efficiency,

• solar power,

• wind power,

• biomass power,

• hydroelectric power,

• wave and ocean energy,

• fuel cells,

• delayed retirement,

• geothermal power,

• municipal solid waste,

• petroleum-fired power,

• supercritical pulverized coal, and

• purchased power.

The NRC staff evaluated each alternative using the same resource areas that were used in 

evaluating impacts from license renewal.
Executive Summary

xxv

RECOMMENDATION

The NRC staff’s recommendation is that the adverse environmental impacts of license renewal 

for Fermi 2 are not so great that preserving the option of license renewal for energy-planning 

decisionmakers would be unreasonable. The NRC staff based its recommendation on the 

following:

• the analyses and findings in the GEIS;

• the ER submitted by DTE;

• the NRC staff’s consultation with Federal, state, tribal, and local agencies;

• the NRC staff’s independent environmental review; 

• the NRC staff’s consideration of public comments received during the scoping

process, and

• the NRC staff’s consideration of public comments received during the DSEIS 

comment period.

xxvii

ABBREVIATIONS AND ACRONYMS

ac acre(s)

AC alternating current

ACHP Advisory Council on Historic Preservation

ADAMS Agencywide Documents Access and Management System

AEA Atomic Energy Act of 1954 (as amended)

ALARA as low as is reasonably achievable

ANS American Nuclear Society

APE averted public exposure

APE area of potential effect

AQCR Air Quality Control Region

ASLB Atomic Safety and Licensing Board (NRC)

ASME American Society of Mechanical Engineers

ATWS anticipated transient(s) without scram

AWEA American Wind Energy Association

BGEPA Bald and Golden Eagle Protection Act of 1940, as amended

Black and Veatch Black & Veatch Corporation

BLM Bureau of Land Management

BLS Bureau of Labor Statistics

BOEM Bureau of Ocean Energy Management

BWR boiling water reactor

°C degrees Celsius

CAA Clean Air Act

CAES compressed air energy storage

CCS carbon capture and storage

CDC Centers for Disease Control and Prevention

CDF core damage frequency

CEQ Council on Environmental Quality

CET containment event tree

CFR Code of Federal Regulations

cfs cubic foot (feet) per second

cm centimeter

CNWR Center for Nuclear Waste Regulatory Analysis

CO carbon monoxide
Abbreviations and Acronyms

xxviii

CO2 carbon dioxide

CO2/MWh carbon dioxide per megawatt hour

COL combined license

Compact 2008 Great Lakes–St. Lawrence River Basin Water Resources 

Compact

CSAPR Cross-State Air Pollution Rule

CWA Clean Water Act

CWR circulating water reservoir

CWS circulating water system

CZMA Coast Zone Management Act of 1972

dB decibels

dBA decibel(s) on the A-weighted scale

DBA design-basis accident

DECo Detroit Edison Company

DBH diameter at breast height

DOE U.S. Department of Energy

DRIWR Detroit River International Wildlife Refuge

DSIRE Database of State Incentives for Renewables and Efficiency

DSM demand-side management

DTE DTE Electric Company

Ducks Unlimited Ducks Unlimited, Inc.

DWCA Detroit Wayne County Airport

ECCS emergency core cooling system

EDG emergency diesel generator

EFH essential fish habitat

EIA Energy Information Administration

EIS environmental impact statement

EMF electromagnetic field

EO Executive Order

EPA U.S. Environmental Protection Agency

EPRI Electric Power Research Institute

EPT Ephemeroptera-Plecoptera-Trichoptera index

EPZ emergency planning zone

ER Environmental Report

ERC Energy Recovery Council
Abbreviations and Acronyms

xxix

ESA Endangered Species Act of 1973, as amended

ESBWR economic simplified boiling water reactor

°F degrees Fahrenheit

FDC floor drain collector

FDCT floor drain collector tank

FEIS final environmental impact statement

Fermi 2 Fermi, Unit 2

Fermi 3 Fermi, Unit 3

FES-C final environmental statement–construction

FES-O final environmental statement–operation

FIVE fire-induced vulnerability evaluation

FLIGHT Facility Level Information on Green House Gases Tool

FR Federal Register

FRN Federal Register Notice

ft foot (feet)

ft3 cubic foot (feet)

FWS U.S. Fish and Wildlife Service

g Ceq/kWh gram(s) of carbon equivalent per kilowatt-hour

gal gallon(s)

GEIS generic environmental impact statement

GI generic issue

GL generic letter

GLC Great Lakes Commission

gpm gallon(s) per minute

GSW general service water

ha hectare(s)

HCLPF high confidence in low probability of failure

HFO high winds, floods, and other

HRA human reliability analysis

HRSG heat recovery steam generator

IEA International Energy Agency

IEEE Institute of Electrical and Electronics Engineers

IGCC integrated gasification combined-cycle

in. inch(es)

ISFSI independent spent fuel storage installation
Abbreviations and Acronyms

xxx

IPE individual plant examination

IPEEE individual plant examination(s) of external events

ISLOCA interfacing-systems loss-of-coolant accident

kg kilogram(s)

km kilometer(s)

km2 square kilometer(s)

kph kilometer(s) per hour

kV kilovolt(s)

kW kilowatt(s)

kWh/m2

/d kilowatt hours per square meter per day

L liter(s)

LaMP (Lake Erie) Lakewide Management Plan Work Group

LDN day-night sound intensity level

LEQ equivalent sound intensity level

Ln statistical sound level

lb pound(s)

LERF large early release frequency

LLMW low-level mixed waste

LOCA loss-of-coolant accident

LOOP loss(es) of offsite power

Lpd liter(s) per day

L/min liter(s) per minute

LRA license renewal application

m/s meter(s) per second

m3 cubic meter(s)

m3

/d cubic meter(s) per day

m3

/s cubic meter(s) per second

m3

/y cubic meters per year

MAAP Modular Accident Analysis Program

MAC Michigan Administrative Code

MACCS2 MELCOR Accident Consequence Code System 2

MCPDC Monroe County Planning Department and Commission

MACR maximum averted cost risk

MATS Mercury and Air Toxics Standards

MCL Michigan Compiled Laws
Abbreviations and Acronyms

xxxi

MCR main control room

MDEQ Michigan Department of Environmental Quality

MDCH Michigan Department of Community Health

MDHS Michigan Department of Human Services

MDNR Michigan Department of Natural Resources

mgd million gallons per day

mgy million gallons per year

mGy milligray

mi mile(s)

mi2 square mile(s)

MIOSHA Michigan Occupational Safety and Health Administration

MISO Midcontinent Independent System Operator

mm millimeter

MNFI Michigan Natural Features Inventory

MOA Memorandum of Agreement

mph mile(s) per hour

mrad millirad

mrem millirem

MSA Magnuson–Stevens Fishery Conservation and Management Act, 

as amended through 2006

MSL mean sea level

MSUE Michigan State University Extension

mSv millisievert

MUR measurement uncertainty recapture

MW megawatt(s)

MWe megawatt(s) electric

MWh megawatt hour(s)

MWt megawatt(s) thermal

NAAQS National Ambient Air Quality Standards

NASS National Agricultural Statistics Service (U.S. Department of 

Agriculture)

NAVD88 North American Vertical Datum of 1988

NCDC National Climatic Data Center

NCES National Center for Education Statistics

NEI Nuclear Energy Institute
Abbreviations and Acronyms

xxxii

NEPA National Environmental Policy Act of 1969, as amended

NESC National Electrical Safety Code

NETL National Energy Technology Laboratory

NGCC natural gas combined-cycle

NHPA National Historic Preservation Act of 1966, as amended

NIEHS National Institute of Environmental Health Sciences

NMFS National Marine Fisheries Service (National Oceanic and 

Atmospheric Administration)

NO2 nitrogen dioxide

NOx nitrogen oxide(s)

NOAA National Oceanic and Atmospheric Administration

NPDES National Pollutant Discharge Elimination System

NPS National Park Service

NRC U.S. Nuclear Regulatory Commission

NRCS Natural Resources Conservation Service

NREL National Renewable Energy Laboratory

NREPA Michigan’s Natural Resources and Environmental Protection Act 

451 of 1994, as amended

NRR Nuclear Reactor Regulation, Office of (NRC)

NSR New Source Review

O3 ozone

ODCM Offsite Dose Calculation Manual

ODNR Ohio Department of Natural Resources

OECR offsite economic cost risk

ORNL Oak Ridge National Laboratory

OSHA Occupational Safety and Health Administration

OSSF onsite storage facility

OW open water

pCi/L picocurie(s) per liter

Pb lead

PDR population dose risk

PDS plant damage state

PEIS programmatic environmental impact statement

PEM palustrine emergent marsh

PFO palustrine forested
Abbreviations and Acronyms

xxxiii

PHAC Public Health Agency of Canada

P-IBI Planktonic Index of Biotic Integrity

PM particulate matter

PRA probabilistic risk assessment

PRE principal residence exemption

PSDAR post-shutdown decommissioning activities report

PSS palustrine scrub-shrub

PTS post-treatment system

PV photovoltaic

radwaste radioactive waste

RAI request(s) for additional information

RCRA Resource Conservation and Recovery Act of 1976, as amended

rem roentgen equivalent(s) man

REMP Radiological Environmental Monitoring Program

RESA (Wayne) Regional Educational Service Agency

RHR residual heat removal

ROI region(s) of influence

ROW right-of-way(s)

RPHP Radiation and Public Health Project

RPS reactor protection system

RPV reactor pressure vessel

RRW risk reduction worth

SAMA severe accident mitigation alternative

SAR Safety Analysis Report

SBO station blackout

SCPC supercritical pulverized coal

SCR selective catalytic reduction

SEIS supplemental environmental impact statement

SEMCOG Southeast Michigan Council of Government

SER safety evaluation report

SESC Soil Erosion and Sediment Control (Michigan)

SHPO State Historic Preservation Office

SMA seismic margin assessment

SO2 sulfur dioxide

SOx sulfur oxide(s)
Abbreviations and Acronyms

xxxiv

SSC structure(s), system(s), and component(s)

SSEL Safe Shutdown Equipment List

Sv sievert(s)

syngas synthesis gas

TAC technical assignment control

TEEIC Tribal Energy and Environmental Information Clearinghouse

U.S. United States

USACE U.S. Army Corps of Engineers

U.S.C. United States Code

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

UFSAR updated final safety analysis report

USGCRP U.S. Global Change Research Program

USGS U.S. Geological Survey

μm micrometer

WAPA Western Area Power Administration

WCS waste collector subsystem

WHC Wildlife Habitat Council

WM wooded marsh
1-1

1.0 INTRODUCTION

The U.S. Nuclear Regulatory Commission’s (NRC’s) environmental protection regulations in 

Title 10 of the Code of Federal Regulations (10 CFR) Part 51 implement the National 

Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq., herein referred to as 

NEPA). The regulations at 10 CFR Part 51 require the preparation of an environmental impact 

statement for issuance or renewal of a nuclear power plant operating license.

The Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.), specifies that licenses 

for commercial power reactors can be granted for up to 40 years. The NRC’s regulations in 

10 CFR 54.31 allow for an option to renew a license for up to an additional 20 years. The initial 

40-year licensing period was based on economic and antitrust considerations rather than on 

technical limitations of the nuclear facility.

The decision to seek a license renewal rests entirely with nuclear power facility owners and, 

typically, is based on the facility’s economic viability and the investment necessary to continue 

to meet NRC safety and environmental requirements. The NRC makes the decision to grant or 

deny license renewal based on whether the applicant has demonstrated that the environmental 

and safety requirements in the agency’s regulations can be met during the period of extended 

operation.

1.1 Proposed Federal Action

DTE Electric Company (DTE) initiated the proposed Federal action by submitting an application 

for license renewal of Fermi 2 Nuclear Power Plant (Fermi 2), for which the existing license

(NPF-43) expires on March 20, 2025. The NRC’s Federal action is to decide whether to renew 

the license for an additional 20 years.

1.2 Purpose and Need for Proposed Federal Action

The purpose and need for the proposed action (issuance of a renewed license) is to provide an 

option that allows for baseload power generation capability beyond the term of a current nuclear 

power plant operating license to meet future system generating needs, as such needs may be 

determined by other energy-planning decisionmakers. This definition of purpose and need 

reflects the NRC’s recognition that, unless there are findings in the safety review required by the 

Atomic Energy Act or findings in the NEPA environmental analysis that would lead the NRC to 

reject a license renewal application (LRA), the NRC does not have a role in the energy-planning 

decisions of state regulators and utility officials as to whether a particular nuclear power plant 

should continue to operate.

1.3 Major Environmental Review Milestones

DTE submitted an Environmental Report (ER) (DTE 2014b) as part of its LRA (DTE 2014a) in

April 2014. After reviewing the LRA and ER for sufficiency, the NRC staff published a 

Federal Register (FR) Notice of Acceptability and Opportunity for Hearing (79 FR 34787) on 

June 18, 2014. Then, on June 30, 2014, the NRC published another notice in the Federal 

Register (79 FR 36837) on the intent to conduct scoping, thereby beginning the 60-day scoping 

period.

Two public scoping meetings were held on July 24, 2014, in Monroe, Michigan (NRC 2014a). A 

report entitled, “Environmental Impact Statement, Scoping Process, Summary Report,” presents 
Introduction

1-2

the comments received during the scoping process (NRC 2015). The scoping process 

summary report presents NRC responses to comments that the NRC staff considered to be 

outside the scope of the environmental license renewal review. Appendix A of this 

supplemental environmental impact statement (SEIS) presents the public comments considered 

to be within the scope of the environmental license renewal review and the NRC responses to 

those comments.

To independently verify information provided in the ER, the NRC staff conducted a site audit at 

Fermi 2 in September 2014. During the site audit, the NRC staff met with plant personnel, 

reviewed specific documentation, toured the facility, and met with interested local agencies. A 

summary of that site audit and a list of the attendees are contained in “Summary of Site Audit in 

Support to the Environmental Review of the License Renewal Application for Fermi 2 (TAC 

No. MF4064)” that was sent to DTE by letter dated October 15, 2014 (NRC 2014b).

Upon completion of the scoping period and site audit, the NRC staff compiled its findings in the

draft SEIS (DSEIS). This document was made available for public comment for 45 days. 

During that time, the NRC staff hosted a public meeting and collected public comments. Based 

on the information gathered, the NRC staff amended the DSEIS findings, as necessary, and 

then published the final SEIS. Figure 1–1 shows the major milestones of the NRC’s LRA

environmental review.

Figure 1–1. Environmental Review Process

The NRC has established a license renewal process that can be completed in a reasonable 

period of time with clear requirements to ensure safe plant operation for up to an additional 

20 years of plant life. The NRC staff conducts the safety review simultaneously with the 

environmental review. The NRC staff documents the findings of the safety review in a safety 

evaluation report. The findings in the SEIS and the safety evaluation report are both factors in 

the NRC’s decision to either grant or deny the issuance of a renewed license.
Introduction

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1.4 Generic Environmental Impact Statement

The NRC staff performed a generic assessment of the environmental impacts associated with 

license renewal to improve the efficiency of its license renewal review. NUREG–1437, Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996, 

1999, 2013), documented the results of the NRC staff’s systematic approach to evaluate the 

environmental consequences of renewing the licenses of individual nuclear power plants and 

operating them for an additional 20 years. The NRC staff analyzed in detail and resolved those 

environmental issues that could be resolved generically in the GEIS. The GEIS originally was 

issued in 1996, Addendum 1 to the GEIS was issued in 1999, and Revision 1 to the GEIS was 

issued in 2013. Unless otherwise noted, all references to the GEIS include the GEIS, 

Addendum 1, and Revision 1.

The GEIS establishes separate environmental impact issues for the NRC staff to independently 

verify. Of these issues, the NRC staff determined that some issues are generic to all plants 

(Category 1). Other issues do not lend themselves to generic consideration (Category 2 or 

uncategorized). The NRC staff evaluated these issues on a site-specific basis in the SEIS. 

Appendix B to Subpart A of 10 CFR Part 51 provides a summary of the NRC staff findings in the 

GEIS.

For each potential environmental issue in the GEIS the NRC staff:

• describes the activity that affects the environment,

• identifies the population or resource that is affected,

• assesses the nature and magnitude of the impact on the affected population 

or resource,

• characterizes the significance of the effect for both beneficial and adverse 

effects,

• determines whether the results of the analysis apply to all plants, and

• considers whether additional mitigation measures would be warranted for 

impacts that would have the same significance level for all plants.

The NRC’s standard of significance for impacts was established using the Council on 

Environmental Quality terminology for “significant.” The NRC established three levels of 

significance for potential impacts—SMALL, MODERATE, and LARGE, as defined below.

SMALL: Environmental effects are not 

detectable or are so minor that they will neither 

destabilize nor noticeably alter any important 

attribute of the resource.

MODERATE: Environmental effects are 

sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource.

LARGE: Environmental effects are clearly 

noticeable and are sufficient to destabilize 

important attributes of the resource.

The GEIS includes a determination of whether the analysis of the environmental issue could be 

applied to all plants and whether additional mitigation measures would be warranted. Issues 

Significance indicates the importance of 

likely environmental impacts and is 

determined by considering two variables: 

context and intensity.

Context is the geographic, biophysical, and 

social context in which the effects will occur.

Intensity refers to the severity of the impact 

in whatever context it occurs.
Introduction

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are assigned a Category 1 or Category 2 designation. As established in the GEIS, Category 1 

issues are those that meet the following criteria:

• The environmental impacts associated with the issue have been determined 

to apply either to all plants or, for some issues, to plants that have a specific 

type of cooling system or other specified plant or site characteristics.

• A single significance level (i.e., SMALL, MODERATE, or LARGE) has been 

assigned to the impacts (except for collective offsite radiological impacts from 

the fuel cycle and from high-level waste and spent fuel disposal).

• Mitigation of adverse impacts associated with the issue has been considered 

in the analysis, and it has been determined that additional plant-specific 

mitigation measures are likely not to be sufficiently beneficial to warrant 

implementation.

For generic issues (Category 1), no additional site-specific analysis is required in the SEIS 

unless new and significant information is identified. The process for identifying new and 

significant information for site-specific analysis is presented in Chapter 4. Site-specific issues 

(Category 2) are those that do not meet one or more of the criteria of Category 1 issues; 

therefore, additional site-specific review for these issues is required. A site-specific analysis is 

required for 17 of the 78 issues evaluated in the GEIS. Figure 1–2 illustrates this process. The 

results of that site-specific review are documented in the SEIS.
Introduction

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Figure 1–2. Environmental Issues Evaluated for License Renewal

In the GEIS, the NRC evaluated 78 issues. 

A site-specific analysis is required for 17 of those 78 issues.

1.5 Supplemental Environmental Impact Statement

The SEIS presents an analysis that considers the environmental effects of the continued 

operation of Fermi 2, alternatives to license renewal, and mitigation measures for minimizing 

adverse environmental impacts. Chapter 4 contains analysis and comparison of the potential 

environmental impacts from alternatives. Chapter 5 presents the NRC’s recommendation on 

whether the environmental impacts of license renewal are so great that preserving the option of 

license renewal would be unreasonable. The final recommendation was made after 

consideration of comments received on the DSEIS during the public comment period.

In the preparation of the SEIS for Fermi 2, the NRC staff carried out the following activities:

• reviewed the information provided in DTE’s ER;

• consulted with Federal agencies, state and local agencies, and tribal nations; 
Introduction

1-6

• conducted an independent review of the issues during site audit; and

• considered the public comments received for the environmental review 

(during the scoping process and for the DSEIS).

New information can be identified from many 

sources, including the applicant, the NRC, other 

agencies, or public comments. If a new issue is 

revealed, it is first analyzed to determine whether 

it is within the scope of the license renewal 

environmental evaluation. If the new issue is not 

addressed in the GEIS, the NRC staff would determine the significance of the issue and 

document the analysis in the SEIS.

1.6 Decisions To Be Supported by the SEIS

The decision to be supported by the SEIS is whether to renew the operating license for Fermi 2

for an additional 20 years. The regulation at 10 CFR 51.103(a)(5) specifies the NRC’s decision 

standard as follows:

In making a final decision on a license renewal action pursuant to Part 54 of this 

chapter, the Commission shall determine whether or not the adverse 

environmental impacts of license renewal are so great that preserving the option 

of license renewal for energy planning decisionmakers would be unreasonable.

There are many factors that the NRC takes into consideration when deciding whether to renew 

the operating license of a nuclear power plant. The analyses of environmental impacts 

evaluated in the GEIS will provide the NRC’s decisionmaker (in this case, the Commission) with 

important environmental information for use in the overall decisionmaking process. There are 

also decisions outside the regulatory scope of license renewal that cannot be made on the basis 

of the GEIS analysis. These decisions include the following issues: (1) changes to plant 

cooling systems, (2) disposition of spent nuclear fuel, (3) emergency preparedness, 

(4) safeguards and security, (5) need for power, and (6) seismicity and flooding (NRC 2013).

1.7 Cooperating Agencies

During the scoping process, no Federal, state, or local agencies were identified as cooperating 

agencies in the preparation of this SEIS.

1.8 Consultations

The Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.); the 

Magnuson–Stevens Fishery Conservation and Management Act of 1996, as amended

(16 U.S.C. 1801 et seq.); and the National Historic Preservation Act of 1966, as amended 

(54 U.S.C. 300101 et seq.), require Federal agencies to consult with applicable state and 

Federal agencies and groups before taking action that may affect endangered species, 

fisheries, or historic and archaeological resources, respectively. The NRC consulted with the 

following agencies and groups; Appendix D discusses the consultation documents:

• U.S. Fish and Wildlife Service,

• Michigan Historical Center,

• Advisory Council on Historic Preservation,

New and significant information. To merit 

additional review, information must be both 

“new” and “significant,” and it must bear on 

the proposed action or its impacts. 
Introduction

1-7

• Keweenaw Bay Indian Community,

• Bay Mills Indian Community,

• Grand Traverse Band of Ottawa and Chippewa Indians,

• Lac Vieux Desert Band of Lake Superior Chippewa Indians,

• Little Traverse Bay Bands of Odawa Indians,

• Pokagon Band of Potawatomi Indians,

• Sault Ste. Marie Tribe of Chippewa Indians of Michigan,

• Hannahville Indian Community,

• Nottawaseppi Huron Band of the Potawatomi,

• Saginaw Chippewa Indian Tribe of Michigan,

• Match-e-be-nash-she-wish Band of Pottawatomi Indians of Michigan,

• Little River Band of Ottawa Indians,

• Forest County Potawatomi,

• Shawnee Tribe,

• Delaware Nation,

• Wyandotte Nation, and

• Ottawa Tribe of Oklahoma.

1.9 Correspondence

During the course of the environmental review, the NRC staff contacted Federal, State, regional, 

local, and tribal agencies listed in Section 1.8. Appendices C and D contain a chronological list 

of all documents sent and received during the environmental review. Appendix C lists the 

correspondence associated with the Endangered Species Act, the Magnuson–Stevens Fishery 

Conservation and Management Act, and the National Historic Preservation Act. Appendix D

lists all other correspondence.

1.10 Status of Compliance

DTE is responsible for complying with all NRC regulations and other applicable Federal, State, 

and local requirements. Appendix F of the GEIS describes some of the major applicable 

Federal statutes. Numerous permits and licenses are issued by Federal, State, and local 

authorities for activities at Fermi 2. Appendix B contains further information about DTE’s status 

of compliance.

1.11 Related State and Federal Activities

The NRC reviewed the possibility that activities of other Federal agencies might affect the 

renewal of the operating license for Fermi 2. There are no Federal projects that would make it 

necessary for another Federal agency to become a cooperating agency in the preparation of 

this SEIS.
Introduction

1-8

There are no known American Indian lands within 50 miles (mi) (80 kilometers (km)) of Fermi 2 

(DTE 2014b). There are 11 Federal- and 110 State-managed lands within 50 mi (80 km) of 

Fermi 2, which includes 5 Federal- and 60 State-managed lands located in Ohio. In addition, 

there is the Federal and State jointly managed Newport NIKE Missile Battery D-57/58 site 

located in Carleton, Michigan, and the Federal and local jointly managed Fallen Timbers 

Battlefield National Historical Site located in Ohio, both located within 50 mi (80 km) of Fermi 2. 

Parcels of the Federally managed Detroit River International Wildlife Refuge are located on the 

Fermi site (DTE 2014b). Besides Federal- and State-managed lands, 10 Canadian provincial 

lands are located within 50 mi (80 km) of Fermi 2, including a portion of the Walpole Island First 

Nation Reserve (DTE 2014b).

The Walpole Island First Nation, an Indian Tribe from Ontario, Canada, sent a letter to the NRC 

stating that they would like an opportunity to thoroughly review the Fermi 2 license renewal 

process to ensure that their rights to fish and harvest resources in western Lake Erie and other 

nearby areas are not adversely impacted. Accordingly, the NRC invited the tribe to provide 

input on the Fermi 2 license renewal environmental review process (NRC 2014c).

The NRC is required under Section 102(2)(C) of NEPA to consult with and obtain comments 

from any Federal agency that has jurisdiction by law or special expertise with respect to any 

environmental impact involved in the subject matter of the environmental impact statement. For 

example, during the course of preparing the SEIS, the NRC consulted with the U.S. Fish and 

Wildlife Service. Appendix C provides a complete list of consultation correspondence.

1.12 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

renewal of operating licenses for nuclear power plants.”

79 FR 34787. U.S. Nuclear Regulatory Commission. “DTE Electric Company; Fermi 2; License 

renewal application; Opportunity to request a hearing and to petition for leave to intervene.”

Federal Register 79(117):34787–34790. June 18, 2014.

79 FR 36837. U.S. Nuclear Regulatory Commission. “DTE Electric Company; Fermi 2; Intent 

to prepare an environmental impact statement and conduct the scoping process.” Federal 

Register 79(125):36837–36839. June 30, 2014.

Atomic Energy Act of 1954, as amended. 42 U.S.C. § 2011 et seq.

[DTE] DTE Electric Company. 2014a. Fermi 2 License Renewal Application. Newport, MI: 

DTE Electric Company. April 2014. ADAMS No. ML14121A532.

[DTE] DTE Electric Company. 2014b. Applicant’s Environmental Report—Operating License 

Renewal Stage, Fermi 2. Newport, MI: DTE Electric Company. April 2014. ADAMS 

Nos. ML14121A538, ML14121A539, and ML14121A540.

Endangered Species Act of 1973, as amended. 16 U.S.C. § 1531 et seq.

Magnuson–Stevens Fishery Conservation and Management Act, as amended. 

16 U.S.C. § 1801 et seq.

National Environmental Policy Act of 1969, as amended. 42 U.S.C. § 4321 et seq.

National Historic Preservation Act of 1966, as amended. 54 U.S.C. § 300101 et seq.
Introduction

1-9

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Final Report. Washington, DC: U.S. Nuclear 

Regulatory Commission. NUREG–1437, Volumes 1 and 2. May 31, 1996. ADAMS 

Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3—Transportation, Table 9.1, 

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, in Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 

U.S. Nuclear Regulatory Commission. NUREG–1437, Volume 1, Addendum 1. August 1999. 

ADAMS No. ML040690720.

[NRC] U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Revision 1. Washington, DC: U.S. Nuclear Regulatory 

Commission. NUREG–1437, Volumes 1, 2, and 3. June 19, 2013. 1,535 p. ADAMS 

No. ML13107A023.

[NRC] U.S. Nuclear Regulatory Commission. 2014a. Public Meeting To Discuss the License 

Renewal Process and Environmental Scoping Process for Fermi, Unit 2. Washington, DC: 

U.S. Nuclear Regulatory Commission. September 18, 2014. ADAMS No. ML14233A450.

[NRC] U.S. Nuclear Regulatory Commission. 2014b. Letter from L. Perkins, Project Manager, 

to V. Kaminskas, DTE Electric Company. Subject: Summary of the site audit related to the

review of the license renewal application for Fermi 2 (TAC No. MF4064). October 15, 2014. 

ADAMS No. ML14274A304.

[NRC] U.S. Nuclear Regulatory Commission. 2014c. Letter from W. Dean, Director, Office of 

Nuclear Reactor Regulation, to D. Miskokomon, Chief, Walpole Island First Nation. Subject: 

Fermi Unit 2 Nuclear Reactor License NPF-43 Extension Application.” October 31, 2014. 

ADAMS Nos. ML14295A239, ML14279A561, ML15303A464, and ML15303A479.

[NRC] U.S. Nuclear Regulatory Commission. 2015. Environmental Impact Statement Scoping 

Summary Report, Fermi 2, Frenchtown Township, MI. Rockville, MD: U.S. Nuclear Regulatory 

Commission. October 2015. ADAMS No. ML15252A015.

2-1

2.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION 

Although the U.S. Nuclear Regulatory Commission’s (NRC’s) decisionmaking authority in 

license renewal is limited to deciding whether to renew a nuclear power plant’s operating 

license, the agency’s implementation of the National Environmental Policy Act of 1969, as 

amended (NEPA) (42 U.S.C. 4321 et seq.), requires consideration of the environmental impacts 

of potential alternatives to renewing a plant’s operating license. Although the ultimate decision 

on which alternative (or the proposed action) to carry out falls to operator, state, or other 

non-NRC Federal officials, comparing the impacts of renewing the operating license to the 

environmental impacts of alternatives allows the NRC to determine whether the environmental 

impacts of license renewal are so great that preserving the option of license renewal for 

energy-planning decisionmakers would be unreasonable (Title 10 of the Code of Federal 

Regulations (10 CFR) 51.95(c)(4)). 

Energy-planning decisionmakers and owners of the nuclear power plant ultimately decide 

whether the plant will continue to operate, and economic and environmental considerations play 

important roles in this decision. In general, the NRC’s responsibility is to ensure the safe 

operation of nuclear power facilities and not to formulate energy policy or encourage or 

discourage the development of alternative power generation. The NRC does not engage in 

energy-planning decisions, and it makes no judgment as to which energy alternatives evaluated 

would be the most likely alternative in any given case.

The remainder of this chapter provides (1) a description of the proposed action, (2) a description 

of alternatives to the proposed action (including the no-action alternative), and (3) alternatives to

the Fermi, Unit 2 (Fermi 2), license renewal that the NRC staff considered and eliminated from 

detailed study. Chapter 4 of this plant-specific supplemental environmental impact statement 

(SEIS) compares the impacts of renewing the operating license of Fermi 2 and continued plant 

operations to the environmental impacts of the alternatives.

2.1 Proposed Action

As stated in Section 1.1 of this document, the NRC’s proposed Federal action is the decision 

whether to renew the Fermi 2 operating license for an additional 20 years. For the NRC to 

determine the impacts from continued operation of Fermi 2, an understanding of that operation 

is needed. A description of normal power plant operations during the license renewal term is 

provided in Section 2.1.1. Fermi 2 is a single-unit, nuclear-powered steam-electric generating 

facility that began commercial operation in July 1985. The nuclear reactor is a General Electric

boiling water reactor (BWR) that produces 1,170 megawatts electric (MWe) (DTE 2014b). 

2.1.1 Plant Operations during the License Renewal Term

Most plant operation activities during license renewal would be the same as, or similar to, those 

occurring during the current license term. Section 2.1.1 of NUREG–1437, Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), Volume 1, 

Revision 1 (NRC 2013a), describes the general types of activities that are carried out during the 

operation of a nuclear power plant, such as Fermi 2. These general types of activities are:

• reactor operation;

• waste management;

• security;
Alternatives Including the Proposed Action

2-2

• office and clerical work;

• surveillance, monitoring, and maintenance; and

• refueling and other outages.

As stated in DTE Electric Company’s (DTE’s) Environmental Report (ER), Fermi 2 will continue 

to operate during the license renewal term in the same manner as it would during the current 

license term except for, as appropriate, additional aging management programs to address 

structure and component aging in accordance with 10 CFR Part 54. 

2.1.2 Refurbishment and Other Activities Associated with License Renewal

Refurbishment activities include replacement and repair of major structures, systems, and 

components (SSCs). The major refurbishment class of activities characterized in the GEIS is 

intended to encompass actions that typically take place only once in the life of a nuclear plant, if 

at all (NRC 2013a). Examples of these activities include, but are not limited to, replacement of 

BWR recirculation piping and pressurized water reactor steam generators. These actions may 

have an impact on the environment beyond those that occur during normal operations and may 

require evaluation, depending on the type of action and the plant-specific design. 

In preparation for its license renewal application, DTE performed an evaluation of these SSCs,

in accordance with 10 CFR 54.21, to identify the need to undertake any major refurbishment 

activities that would be necessary to support the continued operation of Fermi 2 during the 

proposed 20-year period of extended operation (DTE 2014b).

As a result of its evaluation of SSCs, DTE did not identify the need to undertake any major 

refurbishment or replacement activities associated with license renewal to support the continued 

operation of Fermi 2 beyond the end of the existing operating license (DTE 2014b). Therefore, 

refurbishment activities are not discussed under the proposed action in Chapter 4.

2.1.3 Termination of Nuclear Power Plant Operations and Decommissioning after the 

License Renewal Term

The impacts of decommissioning are described in NUREG–0586, Generic Environmental 

Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Volumes 1 and 2, 

Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The majority of the 

activities associated with plant operations would cease with reactor shutdown. Some activities 

(e.g., security and oversight of spent nuclear fuel) would remain unchanged, whereas others 

(e.g., waste management; office and clerical work; laboratory analysis; and surveillance, 

monitoring, and maintenance) would continue at reduced or altered levels. Systems dedicated 

to reactor operations would cease operations; however, impacts from the physical presence of 

these systems may continue if they are not removed after reactor shutdown. Impacts 

associated with dedicated systems that remain in place would be unchanged.

Decommissioning will occur whether Fermi 2 is shut down at the end of its current operating 

license or at the end of the period of extended operation. There are no site-specific issues 

related to decommissioning. The GEIS concludes that license renewal would have a negligible 

(SMALL) effect on the impacts of terminating operations and decommissioning on all resources

(NRC 2013a).
Alternatives Including the Proposed Action

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2.2 Alternatives

As stated at the beginning of this chapter, the NRC is obligated to consider reasonable 

alternatives to the proposed action of renewing the license for a nuclear reactor. The update to 

the GEIS (NRC 2013a) incorporates the latest information on replacement power alternatives; 

however, rapidly evolving technologies are likely to outpace the information presented in the 

GEIS. As such, a site-specific analysis of alternatives must be performed for each SEIS, taking 

into account changes in technology and science since the preparation of the GEIS.

Section 2.2.1 below describes the no-action alternative in which the NRC takes no action and 

does not issue a renewed license for Fermi 2. Sections 2.2.2.1–2.2.2.4 describe the 

characteristics of replacement power alternatives for Fermi 2.

2.2.1 No-Action Alternative

At some point, operating nuclear power plants will terminate operations and undergo 

decommissioning. The no-action alternative represents a decision by the NRC not to renew the 

operating license of a nuclear power plant beyond the current operating license term. Under the 

no-action alternative, the NRC does not renew the operating license, and Fermi 2 shuts down at 

or before the end of the current license in 2025. After shutdown, plant operators will initiate 

decommissioning in accordance with 10 CFR 50.82.

This SEIS will only address those impacts that arise directly from plant shutdown. Several other 

documents, including NUREG-0586, Supplement 1 (NRC 2002); Chapter 4 of the license 

renewal GEIS (NRC 2013a); and Chapter 4 of this SEIS, address the environmental impacts 

from decommissioning and related activities. These analyses either directly address or bound 

the environmental impacts of decommissioning whenever DTE ceases to operate Fermi 2.

Even with a renewed operating license, Fermi 2 will eventually shut down, and the 

environmental impacts addressed later in Chapter 4 of this SEIS will occur at that time. As with 

decommissioning impacts, shutdown impacts are expected to be similar whether they occur at 

the end of the current license or at the end of a renewed license. 

Termination of operations at Fermi 2 would result in the total cessation of electrical power 

production. Unlike the alternatives described below in Section 2.2.2, the no-action alternative 

does not expressly meet the purpose and need of the proposed action, as described in 

Section 1.2, because it does not provide a means of delivering baseload power to meet future 

electric system needs. Assuming that a need currently exists for the power generated by 

Fermi 2, the no-action alternative would likely create a need for a replacement power

alternative. The following section describes the full range of replacement power alternatives 

(including fossil fuel, new nuclear, and renewable energy sources), and Chapter 4 assesses 

their potential impacts. Although the NRC’s authority only extends to deciding whether to renew 

the Fermi 2 operating license, the replacement power alternatives described in the following 

sections represent possible options for energy-planning decisionmakers if the NRC decides not 

to renew the Fermi 2 operating license.

2.2.2 Replacement Power Alternatives

In evaluating alternatives to license renewal, the NRC considered energy technologies or 

options currently in commercial operation and technologies not currently in commercial 

operation but that are likely to be commercially available by the time the current Fermi 2

operating license expires. The current operating license for Fermi 2 expires on March 20, 2025. 
Alternatives Including the Proposed Action

2-4

The NRC eliminated from detailed study alternatives that cannot be constructed, permitted, and 

connected to the grid by the time the Fermi 2 license expires.

The agency also eliminated from detailed study alternatives that cannot provide the equivalent 

of Fermi 2’s current generating capacity and, in some cases, those alternatives whose costs or 

benefits do not justify inclusion in the range of reasonable alternatives. This chapter provides a 

brief discussion of each alternative eliminated from detailed study and provides a basis for its 

removal at the end of this section. In addition to the no-action alternative, the NRC staff 

considered 17 alternatives to the proposed action (see text box below) and then narrowed these 

to the four alternatives considered in Sections 2.2.2.1–2.2.2.4. The NRC staff evaluated the 

environmental impacts of these four alternatives (and the no-action alternative) and provides an 

in-depth discussion of them in Chapter 4 of this SEIS. 

The GEIS presents an overview of some energy 

technologies, but it does not reach any conclusions 

about which alternatives are most appropriate. 

Because many energy technologies are continually 

evolving in capability and cost and because 

regulatory structures have changed to either promote 

or impede development of particular alternatives, the 

analyses in this chapter may include updated 

information from the following sources:

• Energy Information Administration (EIA),

• other offices within the U.S. Department 

of Energy (DOE),

• U.S. Environmental Protection Agency 

(EPA),

• industry sources and publications, and

• information submitted by DTE in its ER.

The evaluation of each alternative in Chapter 4 of this 

SEIS considers the environmental impacts across 

several impact categories, including land use and 

visual resources, air quality and noise, geologic environment, water resources, ecological 

resources, historic and cultural resources, socioeconomics, human health, environmental 

justice, and waste management. Most site-specific issues (Category 2) have been assigned a 

significance level of SMALL, MODERATE, or LARGE. For ecological and historic and cultural 

resources, the impact significance determination language is specific to the authorizing 

legislation (e.g., the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.), 

and the National Historic Preservation Act of 1966, as amended (16 U.S.C. 470 et seq.)). The 

order of presentation of the alternatives is not meant to imply increasing or decreasing level of 

impact, nor does it imply that an energy-planning decisionmaker would be more likely to select 

any given alternative.

To ensure that the alternatives analysis is consistent with state or regional energy policies, the 

NRC reviewed energy-related statutes, regulations, and policies within the Fermi 2 region. As a 

result, the NRC staff considers alternatives that include wind power or solar photovoltaic (PV) 

power and a combination of both technologies.

Alternatives Evaluated In Depth:

• new nuclear

• coal-integrated gasification 

combined cycle (IGCC)

• natural gas combined-cycle (NGCC)

• combination alternative (wind 

power, NGCC, and solar power)

Other Alternatives Considered:

• energy conservation and efficiency

• solar power

• wind power

• biomass

• hydroelectric power

• wave and ocean energy

• fuel cells

• delayed retirement

• geothermal power

• municipal solid waste

• petroleum–fired power

• supercritical pulverized coal (SCPC)

• purchased power
Alternatives Including the Proposed Action

2-5

Region of Influence

If the NRC does not issue a renewed license, replacement power for Fermi 2 would be required. 

Fermi 2 is owned and operated by DTE and provides electricity through the Midcontinent 

Independent System Operator (MISO) to an 11-county service area in southeastern Michigan 

(DTE 2014b). This service area constitutes the region of influence (ROI) for the NRC’s analysis 

of replacement power alternatives.

In 2010, electric generators in Michigan had a net summer generating capacity of approximately 

30,000 megawatts (MW). This capacity included units fueled by coal (39 percent), natural gas 

(37 percent), and nuclear power (13 percent), with lesser amounts fueled by hydroelectric and 

pumped storage (7 percent), petroleum (2 percent), and other renewable energy sources 

including wood, biomass, solar, and wind (2 percent) (EIA 2012). 

In 2011, the electric industry in Michigan provided approximately 109 million megawatt hours

(MWh) of electricity. This electrical production was dominated by coal (54 percent), nuclear 

(30 percent), and natural gas (12 percent). Hydroelectric and other renewable energy sources 

produced approximately 4 percent of the electricity in the State (EIA 2014a).

The production of renewable energy is mandated in Michigan. In 2008, Michigan enacted a 

Renewable Energy Standard that requires utilities to generate 10 percent of their retail electricity 

sales from renewable energy resources by 2015. The standard also allows energy efficiency 

and advanced cleaner energy systems to meet part of the requirement. Renewable energy 

credits can be purchased from in- or out-of-State facilities as long as the facilities are located 

within the retail electric service territory of a utility that is recognized by the Michigan Public 

Service Commission (DSIRE 2014). As of November 2015, net electricity generation in 

Michigan from renewable energy sources (other than hydroelectric) comprised approximately 

8 percent of the State total (EIA 2016). 

Given known technology and technological and demographic trends, the EIA predicts that 

35 percent of electricity in the United States will be generated by coal in 2040 (EIA 2013a). In 

all the Midwest case projections, coal accounts for 42 percent in 2040 (EIA 2013a). Nationwide, 

natural gas generation rose from 16 percent in 2000 to 24 percent in 2011 and is projected to 

increase to 30 percent in 2040 (EIA 2013a). Electricity generation from renewable energy is 

expected to grow nationwide, from 13 percent of total generation in 2011 to 16 percent in 2040. 

However, there are uncertainties that could affect this forecast, particularly the implementation 

of policies aimed at reducing greenhouse gas emissions, which would have a direct effect on 

fossil fuel-based generation technologies (EIA 2013a).

This section describes replacement power alternatives to license renewal. These alternatives

include an NGCC alternative in Section 2.2.2.1; a coal-IGCC alternative in Section 2.2.2.2; a 

new nuclear power alternative in Section 2.2.2.3; and a combination natural gas, wind, and solar 

power alternative in Section 2.2.2.4. Table 2–1 summarizes key design characteristics of the 

alternative technologies evaluated in depth. The environmental impacts of these alternatives 

are evaluated in Chapter 4.
Alternatives Including the Proposed Action

2-6

Summary of Replacement Power Alternatives 

and Key Characteristics Considered In Depth

NGCC Alternative IGCC Alternative

New Nuclear 

Alternative

Combination 

Alternative

Summary of 

Alternative

Three 400-MWe units 

for a total of 

1,200 MWe

Two 618-MWe units 

for a total of 

1,236 MWe

One 1,170 MWe 

single-unit nuclear 

plant

One 400-MWe 

NGCC unit, a 

600-MWe wind 

farm, and a 

200-MWe solar PV 

facility for a total of 

1,200 MWe

Location On the Fermi site, 

outside the footprint 

of the existing Fermi 2 

and proposed Fermi 3 

plants: Some 

infrastructure 

upgrades may be 

required and would 

require construction

of a new or upgraded 

gas pipeline. Some 

facilities (e.g., support 

buildings, potable 

water supply, and 

sanitary discharge 

structures) could be 

shared with the 

existing plant.

On or adjacent to the 

Fermi site, outside 

the footprint of the 

existing Fermi 2 and 

proposed Fermi 3 

plants: Some 

transmission line 

infrastructure 

currently supporting 

Fermi 2 would be 

used (DTE 2014b). 

Some facilities 

(e.g., support 

buildings, potable 

water supply, and 

sanitary discharge 

structures) could be 

shared with the 

existing plant.

On or adjacent to 

the Fermi site, 

outside the footprint 

of the existing 

Fermi 2 and 

proposed Fermi 3 

plants. Some 

transmission line 

infrastructure 

currently supporting 

Fermi 2 would be 

used. Some 

facilities 

(e.g., support 

buildings, potable 

water supply, and 

sanitary discharge 

structures) could be 

shared with the 

existing plant.

Spread across 

multiple sites 

throughout the ROI

Cooling 

System

Closed-cycle with 

mechanical draft 

cooling towers; 

cooling water 

withdrawal—7.5 mgd; 

consumptive water 

use—5.7 mgd 

(NETL 2010, 2013a)

Closed-cycle with 

mechanical draft 

cooling towers; 

cooling water 

withdrawal—

16.5 mgd; 

consumptive water 

use—13 mgd 

(NETL 2013a)

Closed-cycle with 

natural draft cooling 

tower; cooling water 

withdrawal—

32 mgd; 

consumptive water 

use—16 mgd 

(NRC 2013c)

For NGCC portion, 

closed-cycle with 

mechanical draft 

cooling towers; 

cooling water—33% 

of that required for 

the NGCC 

alternative; minimal 

water use for wind 

and solar
Alternatives Including the Proposed Action

2-7

NGCC Alternative IGCC Alternative

New Nuclear 

Alternative

Combination 

Alternative

Land 

Requirements

24 ac (10 ha) for the 

plant (NETL 2010); 

4,320 ac (1,748 ha) 

for gas extraction and 

collection (NRC 1996)

1,000 ac (400 ha) for 

the major permanent 

facilities (adjacent 

land parcels would be 

acquired to provide 

the full complement 

of total land needed);

550 ac (225 ha) per 

year for mining 

(DOE 2010a)

301 ac (122 ha) 

(adjacent land 

parcels would be 

acquired to provide 

the full complement 

of total land 

needed); no 

expected net 

change in impacts 

associated with 

uranium mining and 

processing as these 

would just be 

redirected from 

Fermi 2 

(DTE 2014b)

Wind farms would 

require 1,117 ac 

(452 ha) to 

3,351 ac (1,356 ha) 

(WAPA and 

FWS 2013); solar 

PV facilities would 

require 3,577 ac 

(1,448 ha) 

(Ong et al. 2013). 

For the NGCC 

portion, land use 

would remain the 

same as the NGCC 

alternative, 24 ac 

(10 ha).

Work Force 1,440 workers during 

peak construction; 

75 workers during 

operations 

(NRC 1996)

2,300 workers during 

peak construction; 

210 workers during 

operations 

(DOE 2010a)

2,900 workers 

during peak 

construction; 

900 workers during 

operations 

(NRC 2013a)

Solar PV system—

528 workers during 

peak construction 

and 53 workers 

during operations 

(DOE 2010b); for 

wind farm—

307 workers during 

peak construction 

and 187 workers 

during operations. 

The number of 

NGCC construction 

and operations 

workers would be 

less than that 

needed for the 

standalone NGCC 

alternative, but it 

would not be a 

linear reduction 

because of the 

minimum number of 

workers needed 

regardless of the 

size of the NGCC 

plant. 

Key: ac = acres; ha = hectares; IGCC = coal-integrated gasification combined cycle; mgd = million gallons per day; 

MWe = megawatts electric; NGCC = natural gas combined-cycle; and ROI = region of influence.

Sources: DOE 2010a, 2010b; DTE 2014b; NETL 2010, 2013a; NRC 1996, 2013b; Ong et al. 2013; and WAPA and 

FWS 2013.
Alternatives Including the Proposed Action

2-8

2.2.2.1 NGCC Alternative

In this section, the NRC staff describes the NGCC alternative. The NRC staff evaluates the 

environmental impacts from this alternative in Chapter 4. 

Natural gas represents 37 percent of the installed generation capacity in Michigan, but provides 

only 12 percent of all electrical power generated in the State (EIA 2012, 2014a). Nationwide, 

the percentage of power generated by natural gas is expected to rise by 2040, although the 

actual rise in natural gas generation will depend on future natural gas prices (EIA 2013a). The 

NRC staff considers the construction of an NGCC power plant to be a reasonable alternative to 

license renewal because it is a feasible, commercially available option for providing baseload 

electrical generating capacity beyond the expiration of Fermi 2’s current license. 

Baseload NGCC power plants have proven their reliability and can have capacity factors as high 

as 85 percent. In an NGCC system, electricity is generated using a gas turbine that burns 

natural gas. A steam turbine uses the heat from gas turbine exhaust through a heat recovery 

steam generator to produce additional electricity. This two-cycle process has a high rate of 

efficiency because the NGCC system captures the exhaust heat that would otherwise be lost 

and reuses it. Like other fossil fuel sources, NGCC power plants are a source of greenhouse 

gases, including carbon dioxide. However, an NGCC power plant produces significantly fewer 

greenhouse gases per unit of electrical output than conventional coal-powered plants

(NRC 2013a). 

To replace the electricity that Fermi 2 generates, the NRC staff considered three NGCC units, 

each with a net capacity of 400 MWe. The NRC staff assumes that each plant configuration 

consists of two combustion turbine generators, two heat recovery steam generators, and one 

steam turbine generator with mechanical draft cooling towers for heat rejection. The power 

plant is assumed to incorporate a selective catalytic reduction system to minimize the plant’s 

nitrogen oxide emissions (NETL 2007). Natural gas would be extracted from the ground 

through wells and then treated to remove impurities and blended to meet pipeline gas standards 

before being piped through the State’s pipeline system to the plant site. This NGCC alternative 

would produce relatively little waste, primarily in the form of spent catalysts used for control of 

nitrogen oxide emissions.

The NRC assumes that the NGCC alternative is located within the existing Fermi site to 

maximize availability of infrastructure and to reduce other environmental impacts. Depending 

on its specific configuration within the site, construction of new intake and discharge facilities 

and a new cooling system may be necessary. Because NGCC power plants generate much of 

their power from a gas-turbine combined-cycle plant, and because the overall thermal efficiency 

of this type of plant is high, an NGCC alternative would require less cooling water than Fermi 2

would. This system would withdraw 7.5 mgd (28 million liters per day (Lpd)) of water and 

consume 5.7 mgd (22 million Lpd). The NRC staff assumes the cooling system would use a 

closed-cycle system with mechanical draft cooling towers. Onsite visible structures could 

include the cooling towers, exhaust stacks, intake and discharge structures, transmission lines, 

natural gas pipelines, and an electrical switchyard. Construction materials could be delivered by 

a combination of rail spur, truck, and barge, depending on the location of the plant within the 

Fermi site. Modifications may be required to deliver such materials, including upgrades to 

existing rail lines or access roads.

2.2.2.2 IGCC Alternative

In this section, the NRC staff describes the IGCC alternative. The NRC staff evaluates the 

environmental impacts from this alternative in Chapter 4. 
Alternatives Including the Proposed Action

2-9

Coal provides the greatest share of electrical power in Michigan. In 2010, coal represented

39 percent of installed generation capacity and accounted for 59 percent of all electricity 

generated in the State (EIA 2012). IGCC is a technology that generates electricity from coal 

and combines modern coal gasification technology with both gas- and steam-turbine power 

generation. The technology generates fewer pollutants than conventional pulverized coal plants 

do because major pollutants are removed from the gas stream before combustion. An IGCC 

power plant consists of coal gasification and combined-cycle power generation. Coal gasifiers 

convert coal into a gas (synthesis gas, also referred to as syngas) that fuels the combined-cycle 

power generating units. The combined-cycle system for a 618-MWe IGCC power plant includes 

two combustion turbines, two heat recovery steam generators, and a steam turbine. The 

combined-cycle units combust gas in one or more combustion turbines, and the resulting hot 

exhaust gas is then used to heat water into steam to drive a steam turbine. The steam turbine 

then uses the heat from the gas turbine’s exhaust through a heat recovery steam generator to 

produce additional electricity (DOE 2010a). This two-cycle process has a high rate of efficiency

because the IGCC system captures the exhaust heat that would otherwise be lost and reuses it. 

In addition, the power plant would reduce sulfur dioxide, nitrogen oxides, mercury, and 

particulate emissions by removing constituents from the syngas before combustion. Nearly 

100 percent of the nitrogen from the syngas would be removed before combustion in the gas 

turbines and would result in lower nitrogen oxide emissions compared to emissions from 

conventional coal-fired power plants (DOE 2010a). 

IGCC power plants have been in operation since the mid-1990s. The Wabash Rice IGCC 

repowering project in Indiana and the Polk Power Station in Florida are two examples of 

operating IGCC plants. Recently, interest in new IGCC projects has increased, and multiple 

new projects have been proposed or recently have begun operations in the United States. The 

Duke Energy Edwardsport Generation Station in neighboring Indiana is a 618-MWe IGCC 

power plant that began commercial operation in June 2013. Duke Energy estimates that the 

IGCC plant will produce 10 times as much power as the retired coal plant it replaced with 

70 percent fewer emissions of sulfur dioxide, nitrogen oxides, and particulates. The IGCC plant 

will reduce carbon emissions per megawatt hours by nearly half (Duke Energy 2013). In 

addition, the Edwardsport Generation Station has the potential for carbon capture and geologic 

sequestration. Space has been reserved at the site for carbon dioxide capture equipment 

(NETL 2013b). 

Many IGCC power plants have been designed with carbon capture and storage (CCS) to further 

reduce carbon dioxide emissions. The Kemper County IGCC project in east-central Mississippi 

proposes to use CCS to reduce carbon dioxide emissions by almost 70 percent by removing 

carbon from the syngas postgasification (DOE 2010a). According to a 2013 National Energy 

Technology Laboratory (NETL) report, nine IGCC projects totaling over 4,000 MW are currently 

active; these projects are in the planning stages, or they have begun construction. 

Thirteen projects have been proposed and subsequently cancelled for a variety of reasons, 

including air quality issues, State laws and regulations, redirected focus on gas-fired generation 

and renewables, and unanticipated rising costs (NETL 2013c). IGCC technology and proposed 

projects have experienced a number of setbacks and opposition that have hindered the full 

integration of the technology into the energy market. The high capital cost of the IGCC 

technology is the most significant roadblock compared to the cost of conventional coal-fired 

power plants. Cost overruns have been experienced at both the Edwardsport IGCC project and 

the Kemper County IGCC project. FutureGen, an IGCC plant featuring CCS, lost DOE financial 

support because of escalating cost estimates (Reuters 2012). Other issues include construction 

timeline overruns, a limited track record for reliable performance, and opposition from an 

environmental perspective.
Alternatives Including the Proposed Action

2-10

Despite some of the current setbacks and concerns associated with IGCC projects, the NRC 

staff considers IGCC technology to be a reasonable source of baseload power to replace 

Fermi 2 by the time its license expires in 2025 because of the current regulatory framework and 

the number of IGCC plants that have, or are expected to become, operational. For example, on

August 3, 2015, EPA signed a final rule for carbon pollution that would apply to new fossil

fuel-fired power plants (EPA 2015). The action establishes performance standards for utility 

boilers and IGCC units based on partial implementation of a CCS system as a method of 

emission reduction. The emission limit for these sources is 1,305 pounds (lb) of carbon dioxide 

per megawatt hour (CO2/MWh), and any new coal-fired power plants could require CCS to 

achieve this emission limit. Therefore, the NRC staff considers IGCC power plants as an 

alternative to Fermi 2 in this section because the Edwardsport IGCC project in Indiana is 

currently in operation and because the Kemper IGCC project in Mississippi is under 

construction. The technology parameters for these plants are considered the current state of 

technology and are used here to describe a hypothetical IGCC power plant located on, or 

adjacent to, the current Fermi property. 

To replace the electricity that Fermi 2 generates, the NRC staff considered two IGCC units, 

each with a net capacity of 618 MWe. Various coal sources are available to coal-fired power 

plants in the ROI. For the purpose of this evaluation, the NRC staff assumes that the IGCC 

alternative would burn a sub-bituminous Powder River Basin coal, consistent with the type of 

coal used in other DTE electric plants. In addition, the units would be designed with the 

potential to add CCS later. In a CCS, carbon dioxide emissions would be compressed and 

piped off site where the compressed emissions could be sold for beneficial use or geologic 

storage. Additional discussion of air quality impacts associated with the IGCC alternative is 

discussed in Section 4.3.

The IGCC alternative would be located on, or adjacent to, the existing Fermi property to 

maximize availability of infrastructure and to reduce other environmental impacts. Depending 

on its specific configuration within the site, there might be a need to construct new intake and 

discharge facilities and a new cooling system. The IGCC alternative would use a similar 

amount of water as that of the Edwardsport IGCC plant. The NRC staff assumes the cooling 

system would use a closed-cycle system with mechanical draft cooling towers. This system 

would withdraw 16.5 mgd (62 million Lpd) of water and consume 13 mgd (49 million Lpd). 

Onsite visible structures could include the boilers, exhaust stacks, intake and discharge 

structures, mechanical draft cooling towers, transmission lines, and an electrical switchyard. 

Construction materials could be delivered by a combination of rail spur, truck, and barge, 

depending on the specific site location. Modifications may be required to deliver such materials

and could include new rail lines or access roads.

2.2.2.3 New Nuclear Power Alternative

In this section, the NRC staff describes the new nuclear power alternative. The NRC staff 

evaluates the environmental impacts from this alternative in Chapter 4. 

The NRC staff considered the construction of a new nuclear power plant to be a reasonable 

alternative to license renewal. For example, nuclear power generation currently provides 

approximately 24 percent of electricity generation in Michigan (EIA 2016). In addition to 

Fermi 2, two other nuclear power plants operate in Michigan and have received renewed 

licenses (NRC 2013b). In September 2008, DTE filed an application for a combined license 

(COL) to build and operate a new reactor unit (Fermi 3) on the existing Fermi site. The NRC 

staff published the final environmental impact statement (FEIS) for Fermi 3 in January 2013 

(NRC 2013c). On May 1, 2015, the NRC issued the license authorizing DTE to build and 

operate an economic simplified boiling water reactor at the Fermi site (80 FR 26302).
Alternatives Including the Proposed Action

2-11

In evaluating the new nuclear power alternative, the NRC staff assumed that one new nuclear 

reactor, in addition to the proposed Fermi 3, would be built on the existing Fermi site to allow for 

the maximum use of existing ancillary facilities, such as support buildings and transmission 

infrastructure. The location of this new reactor would be outside the footprints of the existing 

Fermi 2 and proposed Fermi 3 units and may require DTE to acquire additional land parcels 

adjacent to the current Fermi property to accommodate the buildout of this new plant. For the 

purposes of this analysis, the NRC relied on the Fermi 3 COL FEIS to scale technological 

parameters for the new nuclear power alternative because the NRC staff considers the 

proposed Fermi 3 plant to be a new nuclear reactor representative of the reactor type that could 

be constructed before Fermi 2’s license expires. Consistent with DTE’s ER, the NRC staff 

assumed that one economic simplified boiling water reactor with a net electrical output of 

approximately 1,170 MWe would replace Fermi 2’s current reactor for this alternative 

(DTE 2014b). 

In the Fermi 3 COL FEIS, the NRC estimated 301 ac (121 ha) would be required for 

construction of a new unit (NRC 2013a). In its ER, DTE further indicated that it did not expect 

any net change in impacts associated with uranium mining and processing because these 

impacts would just replace those previously attributed to Fermi 2 (DTE 2014b). The NRC staff 

considers these assessments to be valid for determining impacts associated with a new nuclear 

power alternative at Fermi.

The heat rejection demands of a new nuclear power alternative would be similar to those of 

Fermi 2. The new reactor may require a new cooling system (including natural draft cooling 

towers and intake and discharge structures). The NRC staff assumes that water requirements 

for the new nuclear alternative would be similar to current water use at Fermi 2. Existing 

transmission lines and water supply lines would be used. A new onsite transmission line may 

be required if insufficient transmission occurs on site. Construction materials could be delivered 

by a combination of rail spur, truck, and barge, depending on the specific site location of the 

plant within the Fermi site. Modifications may be required to deliver such materials and could 

include upgrades to new existing rail lines or access roads. The NRC staff also considered the 

installation of multiple small modular reactors as an alternative to renewing the Fermi 2 license. 

The NRC established the Advanced Reactor Program in the Office of New Reactors because of 

considerable interest in small modular reactors along with anticipated license applications by 

vendors. Small modular reactors are approximately 300 MW or less, would have lower initial 

capacity than large-scale units, and would have siting flexibility for locations that are not large 

enough to accommodate traditional nuclear reactors (DOE undated b). As of January 2015, no 

applications for small modular reactors have been submitted to the NRC. The DOE has 

estimated that the technology may achieve commercial operation by 2021 to 2025 

(DOE undated b). Because small modular reactors may not be operational on a commercial 

scale until near the expiration of Fermi 2’s license, the construction of four new small modular 

reactors (i.e., the number of units required to replace Fermi 2’s current output) in the ROI is 

unlikely; therefore, this analysis focuses on nuclear power generation by larger nuclear units.

2.2.2.4 Combination Alternative (NGCC, Wind, and Solar)

In this section, the NRC staff describes a combination alternative to the continued operation of 

Fermi 2 that would consist of an NGCC facility constructed on the Fermi 2 plant site operating in 

conjunction with land-based wind farms and solar energy facilities—all of which would be 

located within the ROI. The NRC staff evaluates the environmental impacts from this alternative 

in Chapter 4. 

To serve as an effective baseload power alternative to the Fermi 2 reactor, this combination 

alternative must be capable of providing an equivalent amount of baseload power. For the 
Alternatives Including the Proposed Action

2-12

purpose of this evaluation, the NRC staff presumes that the combination alternative would 

comprise NGCC, wind farms, and solar PV facilities. 

NGCC Portion of the Combination Alternative

To produce its required share of power, the NGCC portion, operating at an expected capacity 

factor of 85 percent (NETL 2007), would need a nameplate rating of approximately 470 MWe. 

In 2013, EIA reported that natural gas-fired power plants are generally used for shorter periods 

to meet peak demand on an infrequent basis. Capacity factors for natural gas plants averaged 

less than 5 percent during off-peak demand hours for most regions of the country. Natural gas 

is used for these “peaker plants” because natural gas combustion turbines can respond quickly 

to meet short-term increases in electricity demand (EIA 2013d). A report prepared by CITI 

Research stated that gas-fired power plants can help overcome the intermittent nature of 

renewable energy (Channell et al. 2012). 

The NRC staff assumed that one new NGCC unit of the type described in Section 2.2.2.1 would 

be constructed and installed at the Fermi site with a total net capacity of 400 MWe. The 

configuration of the NGCC unit would be similar to that of the full NGCC alternative considered 

in Section 2.2.2.1, although only one unit would be constructed. The NRC staff assumes that 

the NGCC portion of this alternative would use existing electrical switchyards, substations, and 

transmission lines. Depending on the existing site conditions, it is possible that intake and 

discharge structures of the existing cooling system could continue in service, but would be 

connected to a new closed-cycle cooling system. For the purposes of this analysis, the NRC 

staff assumes that the NGCC portion of the combination would use mechanical draft cooling 

towers.

Wind Portion of the Combination Alternative

The NRC staff assumes that the wind-generated power from this combination alternative would 

come from land-based wind farms that would be located within the ROI. The wind portion, 

assuming a capacity factor of 30 percent, would require a nameplate capacity of 2,000 MWe 

(WAPA and FWS 2013).

The American Wind Energy Association (AWEA) reports a total of approximately 62,000 MW of 

installed wind energy capacity nationwide as of July 2014 (AWEA 2014). As of December 2014, 

Texas is the leader with 14,098 MW of installed land-based wind energy capacity. Michigan has 

the 14th largest installed wind energy capacity in the Nation at 1,525 MW (DOE 2015). DTE 

currently has nine wind energy facilities that generate approximately 800 MW (DTE 2015a). 

Therefore, NRC staff considers 2,000 MW of wind energy to be a reasonable amount by the 

time the Fermi 2 license expires in 2025.

As is the case with other renewable energy sources, the feasibility of wind resources serving as 

alternative baseload power is dependent on the location (relative to expected load centers), 

value, accessibility, and constancy of the resource. Wind power installations, which may consist 

of several hundred turbines, produce variable amounts of electricity. However, Fermi 2 

produces electricity almost constantly. Because there are limited energy storage opportunities 

available to overcome the intermittency and variability of wind resources, wind power cannot 

substitute for existing baseload generation on a one-to-one basis.

The energy potential in wind is expressed by wind power classes, which range from 1 (least 

energetic) to 7 (most energetic). At the current stage of wind energy technology development, 

wind resources in Wind Power Class 3 and higher areas are suitable for most utility scale 

applications (NREL 2014). Wind power Class 3 is defined as having a wind speed of 15.7 miles 

per hour (7.0 meters per second) and a wind density of 500 watts per square meter at 164 feet 
Alternatives Including the Proposed Action

2-13

(50 meters) (NREL 2014). The ROI contains the highest concentration of wind resources in 

Michigan that meet this power class (NREL 2004). Individual wind turbine capacity increased 

from 0.71 MW in 1999 to 1.79 MW in 2010. The size of turbine most frequently installed in the 

United States in recent years is the 1.5-MW turbine (WAPA and FWS 2013). For the purposes 

of this analysis, the NRC staff assumes wind turbines with a capacity of 1.79 MW. For the wind 

portion of the combination alternative, the NRC staff assumed a capacity factor of 30 percent, 

resulting in an estimated total net capacity of 600 MWe. Wind farms require substantial 

amounts of land because wind turbines must be well separated from each other to avoid 

interferences to wind flowing through the wind farm. Wind turbines may require as much as 1 to 

3 ac (0.4 to 1.2 ha) of land for each turbine (WAPA and FWS 2013). Based on the size of the 

turbines and amount of land required between each turbine, the wind portion of the combination 

alternative would require approximately 1,117 turbines and 1,117 to 3,351 ac (452 to 1,356 ha).

Wind energy’s intermittency affects its viability as a baseload power source. However, the 

variability of wind-generated electricity can be lessened if the proposed wind farms were located 

at a large distance from one another, allowed to operate as interconnected wind farms, and

controlled in aggregate from a central point. Distance separation ensures that the two wind 

farms will not simultaneously experience the same climate, and power will likely be produced at 

some of the wind farms at any given time (Archer and Jacobson 2007). 

Solar Photovoltaic Portion of the Combination Alternative

The solar PV portion of the combination alternative would be generated through one or more 

solar PV energy facilities located in the ROI. Assuming a capacity factor of 19 percent, the solar 

energy facilities would need a collective nameplate capacity of 1,052 MWe. Solar PV

technologies could be installed on building roofs at existing residential, commercial, or industrial 

sites or at larger standalone solar facilities.

Solar PV uses solar panels to convert solar radiation into usable electricity. Solar 

manufacturers form solar cells into solar panels that can then be linked into PV arrays to 

generate electricity. The electricity generated can be stored, used directly, fed into a large 

electricity grid, or combined with other electricity generators as a hybrid plant. Solar PV

systems can generate electricity whenever there is sunlight, regardless of whether the sun is 

directly shining on solar panels. Therefore, solar PV technologies do not need to directly face 

and track the sun, which has allowed solar PV systems to have broader geographical use than 

concentrated solar power (Ardani and Margolis 2011). 

Nationwide, growth in large solar PV facilities (greater than 5 MW) has resulted in an increase 

from 70 MW in 2009 to over 700 MW installed capacity in 2011. As of January 2012, it is 

estimated that more than 11,000 MW of large solar PV projects have signed power purchase 

agreements (Mendelsohn et al. 2012). Over 9,000 MW of those solar projects are 50 MW or 

greater, and most are located in the southwestern United States (Mendelsohn et al. 2012). 

Under a program begun in 2009, DTE obtains easement rights to locate large (100-kilowatts 

(kW) to 500-kW) solar arrays on suitable property in southeastern Michigan, and it has allocated 

15 MW for this program (DTE 2015b). As of 2014, 20 projects totaling approximately 8.2 MW of 

solar PV capacity had been installed in the ROI, and 3 other projects representing 5.2 MW were 

in the construction, design, or feasibility stages (MPSC 2015).

Solar PV resources in the ROI and across Michigan range from 4.0 to 4.5 kilowatt hours per 

square meter per day (kWh/m2

/d) (NREL 2013c). Economically viable solar resources are 

considered to be 6.75 kWh/m2

/d and greater (BLM and DOE 2010). As is the case with wind 

energy sources, the feasibility of solar energy resources serving as alternative baseload power 

depends on the location, value, accessibility, and constancy of the resource.
Alternatives Including the Proposed Action

2-14

For the purposes of this analysis, the NRC staff assumes solar PV facilities with a capacity 

factor of 19 percent (Ardani and Margolis 2011). Solar PV facilities may require 6.2 ac (2.5 ha)

per megawatt of land. Although not all this land would be cleared of vegetation and 

permanently affected, it represents the land enclosed in the total site boundary of the solar 

facility (Ong et al. 2013). For the solar portion of this combination alternative, approximately

3,577 ac (1,448 ha) would be required to support an installed net capacity of 200 MWe. In this 

analysis, the NRC staff does not speculate on the number and size of individual solar facilities, 

nor their locations within the ROI. However, as stated above, some of the output could be 

realized by solar PV installations on building roofs at existing residential, commercial, or 

industrial sites or at larger standalone solar facilities. To the extent that rooftop or 

building-integrated solar PV installations remain popular, land impacts would be relatively minor. 

Solar PV systems do not require water for cooling purposes, but a small amount of water is 

needed to clean the panels and for potable water for the workforce. The U.S. Department of the 

Interior Bureau of Land Management (BLM) and DOE’s Solar Energy Programmatic 

Environmental Impact Statement (PEIS) (BLM and DOE 2010, 2012), among other technical 

reports, provides information on impacts used in the analyses presented in the impact sections 

in Chapter 4.

Although solar PV resources in Michigan are modest in comparison to solar resources available 

elsewhere in the Nation, solar PV systems remain a commercially available option for providing 

electrical generating capacity. Therefore, the NRC staff considers the construction of solar PV

facilities to be a reasonable alternative to license renewal when combined with wind and NGCC.

2.3 Alternatives Considered but Dismissed

This section presents alternatives to Fermi 2 license renewal that the NRC considered and 

eliminated from detailed study. These alternatives were eliminated because of technical 

resource availability or current commercial limitations. Many of these limitations would continue 

to exist when the current Fermi 2 license expires.

2.3.1 Energy Conservation and Energy Efficiency 

Energy conservation can include reducing energy demand through behavioral changes or 

through altering the shape of the electricity load and usually does not require the addition of new 

generating capacity. Conservation and energy efficiency programs are more broadly referred to 

as demand-side management (DSM). 

Conservation and energy efficiency programs can be initiated by a utility, transmission 

operators, the State, or other load-serving entities. DTE currently offers its customers several 

conservation and DSM programs to reduce peak electricity demands and daily power 

consumption (DTE 2014b). A recent Michigan Public Service Commission study estimated that 

energy efficiency programs potentially could reduce demand in the DTE service area by 

approximately 800 MW by 2023 (MPSC 2013, DTE 2014b). 

In general, residential electricity consumers have been responsible for the majority of peak load 

reductions, and participation in most programs is voluntary. Therefore, the existence of a 

program does not guarantee that reductions in electricity demand would occur. The GEIS

concludes that while the energy conservation or energy efficiency potential in the United States 

is substantial, cases in which an energy efficiency or conservation program has been 

implemented expressly to replace or offset a large baseload generation station (NRC 2013a)

are unlikely. Although significant energy savings are possible in the ROI through DSM and 

energy efficiency programs, conservation and energy efficiency programs are not likely to 
Alternatives Including the Proposed Action

2-15

replace Fermi 2 as a standalone alternative; therefore, the NRC staff does not consider 

conservation and energy efficiency to be a reasonable alternative to license renewal.

2.3.2 Solar

Solar power, including solar PV systems and concentrated solar power technologies, produce 

power generated from sunlight. PV systems convert sunlight directly into electricity using solar 

cells made from silicon or cadmium telluride. Concentrating solar power uses heat from the sun 

to boil water and produce steam to drive a turbine connected to a generator to produce 

electricity (NREL 2013d). To be considered a viable alternative, a solar alternative must replace 

the amount of electricity that Fermi 2 provides. Assuming a capacity factor of 19 percent 

(Ardani and Margolis 2011), solar energy facilities in the ROI would need to generate 

approximately 6,160 MWe of electricity.

In 2015, approximately 5.2 MW of electricity was generated from solar energy in the ROI 

(DTE 2015b). DOE’s National Renewable Energy Laboratory (NREL) reports that Michigan 

receives solar insolation of 4.0 to 4.5 kWh/m2

/d, which is considered low to average 

(NREL 2013c). For utility-scale development, insolation levels below 6.5 kWh/m2

/d are not 

considered economically viable given current technologies (BLM and DOE 2010). More 

potential for solar development exists using local PV applications, such as rooftop solar panels, 

than through utility-scale solar facilities. In addition, a solar facility can only generate electricity 

when the sun is shining. Energy storage can be used to overcome intermittency for 

concentrating solar power facilities; however, current and foreseeable storage technologies that 

have been paired with solar power facilities have a much smaller capacity than that necessary 

to replace Fermi 2’s baseload generation. Given all the factors above, using solar PV systems 

or concentrated solar power technologies as baseload power in the ROI to replace Fermi 2’s 

current electricity output is unlikely. Given the modest levels of solar energy available 

throughout the ROI, the lack of substantial installed solar capacity in the ROI, and the 

weather-dependent intermittency of solar power, the NRC staff concludes that a solar power 

energy facility in the ROI would not be a reasonable standalone alternative to license renewal. 

However, the NRC staff describes an alternative using solar power in combination with wind and 

an NGCC plant in Section 2.2.2.4.

2.3.3 Wind

The installed wind capacity in Michigan is among the largest and fastest growing in the Nation

(DOE 2015, EIA 2015). All of the wind energy facilities and the electricity generation from wind 

currently being produced in Michigan are land-based. A wind alternative must replace the 

amount of electricity Fermi 2 provides in order to be considered a viable alternative. Assuming 

a capacity factor of 30 percent for land-based wind and 40 percent for offshore wind, some 

combination of land-based and offshore wind energy facilities in the ROI would need to 

generate a range of 2,925 to 3,900 MWe of electricity.

As is the case with other renewable energy sources, the feasibility of using wind resources for 

alternative baseload power depends on the location (relative to expected load centers), value, 

accessibility, and constancy of the resource. Wind energy must be converted to electricity at or 

near the point at which it is extracted, and there are limited energy storage opportunities 

available to overcome the intermittency and variability of wind resource availability. Although 

wind power is intermittent and individual facilities are unable to provide baseload power, multiple 

interconnected wind installations separated by long distances could theoretically function as a 

virtual power plant and could provide baseload power because individual facilities would be 
Alternatives Including the Proposed Action

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exposed to different weather and wind conditions. However, no states or utilities to date 

operate arrays of wind installations as virtual power plants.

Given the amount of wind capacity necessary to replace Fermi 2 and the intermittency of wind 

power, the NRC staff finds a completely wind-based alternative to be unreasonable. However, 

the NRC staff also concludes that wind energy can provide a viable alternative when it is used in 

combination with other technologies with inherently higher capacity factors. The NRC staff 

describes such a possible combination in Section 2.2.2.4.

2.3.3.1 Offshore Wind

The United States does not have any offshore wind farms in operation; however, approximately 

20 projects representing more than 2,000 MW of capacity are in the planning and permitting 

process as of 2010 (Musial and Ram 2010). Offshore wind projects have been developed in 

Europe; most of them are located close to shore and in shallow water less than 98.4 feet 

(30 meters) in depth. Total worldwide installed capacity has been estimated at 2,377 MW 

(Musial and Ram 2010). 

Although wind data suggest that the potential exists for offshore wind farms in the Great Lakes, 

project costs likely will limit the future potential of large-scale projects (Tidball et al. 2010). 

NREL estimated that offshore project costs would run approximately 200 to 300 percent higher 

than land-based systems (Tidball et al. 2010). In addition, based on current prices for wind 

turbines, the 20-year levelized cost of electricity produced from an offshore wind farm would be 

above the current production costs from existing power generation facilities. In addition to cost, 

other barriers include the immature status of the technology, limited resource area, and high 

risks and uncertainty (Tidball et al. 2010). Because no offshore wind capacity yet exists either 

in the Great Lakes or on the Atlantic Coast and because none appears likely to exist on a large 

commercial scale in the Great Lakes by 2025 (given the current state of development), the NRC 

staff finds that offshore wind will not be a reasonable alternative to Fermi 2.

2.3.3.2 Wind Power with Storage

Energy storage is one possible way to overcome intermittency. Besides pumped hydroelectric 

facilities, compressed air energy storage (CAES) is the technology most suited for storage of 

large amounts of energy. In CAES systems, electricity generated during low-demand periods 

can be stored by using a compressor to pressurize and store air, and during high-demand

periods, the compressed air can be used to drive a turbine to generate electricity. A 2011 DOE

report analyzed various power generation sources, including wind, coupled with CAES systems 

(Ilic et al. 2011). The report considered siting criteria, using (1) proximity to natural gas lines, 

high-voltage transmission, and a market for wholesale electric power and (2) availability of 

geology and wind resources. Without detailed wind-speed data, specific site information, and 

detailed information on the energy-storage capacity of potential CAES sites, estimating how 

much wind capacity would be necessary and determining whether it could provide for an 

all-wind alternative are difficult. Furthermore, the NRC staff is not aware of a CAES project 

coupled with wind generation that is providing baseload power. Therefore, the NRC staff 

concludes that the use of CAES in combination with wind turbines to replace the Fermi 2 power 

plant is unlikely.

2.3.3.3 Conclusion

Despite the relatively high reliability demonstrated by modern turbines, the recent technological 

advancements in turbine design and wind farm operation, and wind energy’s dramatic market 

penetrations of recent years, empirical data on wind farm capacity factors and wind energy’s 

limited ability to store power for delayed production of electricity cause the NRC staff to 

conclude that wind energy—on shore, off shore, or a combination thereof—could not serve as a 
Alternatives Including the Proposed Action

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discrete alternative to the baseload power supplied by Fermi 2. However, the NRC staff also 

concludes that, when used in combination with other technologies with inherently higher 

capacity factors, wind energy can provide a viable alternative. The NRC staff describes such a 

possible combination in Section 2.2.2.4.

2.3.4 Biomass

Resources used for biomass-fired generation include agricultural residues, animal manure, 

wood wastes from forestry and industry, residues from food and paper industries, municipal 

green wastes, dedicated energy crop, and methane from landfills (IEA 2007). Using 

biomass-fired generation for baseload power depends on the geographic distribution, available 

quantities, constancy of supply, and energy content of biomass resources. For this analysis, the 

NRC staff assumed that biomass would be combusted for power generation in the electricity 

sector. Biomass is also used for space heating in residential and commercial buildings and can 

be converted to a liquid form for use in transportation fuels (Haq undated). In the GEIS, the 

NRC staff indicated that a wood waste facility could provide baseload power and could operate 

with capacity factors between 70 and 80 percent (NRC 2013a). With over one-half of the State 

forested, Michigan has abundant woody biomass (EIA 2015). However, most biomass 

resources are concentrated in northern Michigan and are far-removed from the DTE service 

area (NRC 2013c). DTE operates three biomass fuel facilities, the largest of which has a 

capacity of 17 MWe (DTE 2014b). Based on the relatively low-electricity generation currently 

produced at biomass plants, it is unlikely that these plants, or the construction of several new 

biomass plants, could increase capacity by adding 1,170 MWe of electricity from biomass-fired 

generation by the expiration of Fermi 2’s license in 2025. 

For utility-scale biomass electricity generation, the NRC staff assumes that the technologies 

used for biomass conversion would be similar to fossil fuel plants, including the direct 

combustion of biomass in a boiler to produce steam (NRC 2013a). Biomass generation is 

generally more cost effective when it is co-fired with coal plants (IEA 2007). Biomass-fired 

generation plants generally are small and can reach capacities of 50 MWe, which means that 

more than 20 new facilities would be required before the Fermi 2 license expires. After 

reevaluating current technologies, the NRC staff finds that biomass-fired alternatives are still 

unable to reliably replace the Fermi 2 capacity. For this reason, the NRC staff does not 

consider biomass to be a reasonable alternative to Fermi 2 license renewal.

2.3.5 Hydroelectric

Hydroelectric power uses the force of water to turn turbines that spin a generator to produce 

electricity. There are two types of hydroelectric power systems: (1) run-of-the-river systems 

and (2) storage systems. In a run-of-the-river system, the force of a river current provides the 

force to create the needed pressure for the turbine. In a storage system, water is accumulated 

in reservoirs created by dams and is released as needed to generate electricity. 

DOE’s Idaho National Environmental Engineering Laboratory (now Idaho National Laboratory) 

completed a comprehensive survey of hydropower resources in 1997. Michigan has a

hydroelectric generating potential of 389 MW, adjusting for environmental, legal, and 

institutional constraints (Conner et al. 1998). These constraints could include (1) scenic, 

cultural, historical, and geological values, (2) Federal and State land use, and (3) legal 

protection issues, such as wild and scenic legislation and threatened or endangered fish and 

wildlife legislative protection. A separate assessment by DOE of nonpowered dams (dams that 

do not produce electricity) concludes that there is potential for only 48 MW of electricity in the 
Alternatives Including the Proposed Action

2-18

State (ORNL 2012). These nonpowered dams serve various purposes, such as providing water 

supply to inland navigation. 

Generating capacity of hydroelectric power is projected to continue decreasing through 2040 

(EIA 2013b). In 2015, hydroelectric power represented approximately 1 percent of Michigan’s 

total electricity (EIA 2016). Given the decrease in projected power generation from 

hydroelectric facilities and the low potential for developing additional capacity within Michigan, 

the NRC staff does not consider hydroelectric power to be a reasonable alternative to Fermi 2 

license renewal.

2.3.6 Wave and Ocean Energy

Waves, currents, and tides are often predictable and reliable, making them attractive candidates 

for potential renewable energy generation. Four major technologies may be suitable to harness 

wave energy: (1) terminator devices that range from 500 kW to 2 MW, (2) attenuators, (3) point 

absorbers, and (4) overtopping devices (BOEM undated). Point absorbers and attenuators use 

floating buoys to convert wave motion into mechanical energy, driving a generator to produce 

electricity. Overtopping devices trap a portion of a wave at a higher elevation than the sea 

surface; waves then enter a tube and compress air that is used to drive a generator that 

produces electricity (NRC 2013a). Some designs are undergoing demonstration testing at 

commercial scales, but none are currently used to provide baseload power (BOEM undated). 

The Great Lakes do not experience large tides, and energy output for wave technologies in the

region is limited. The Electric Power Research Institute (EPRI) published a document that 

assessed ocean wave energy resources in the United States (EPRI 2011). The analysis did not 

include the Great Lakes, and there are no major studies that address the use of wave energy in 

the Great Lakes on a commercial scale. Consequently, the infancy of the technologies and the 

lack of associated studies addressing the resource potential of the Great Lakes support the 

NRC staff’s conclusion that wave and ocean energy technologies are not feasible substitutes for 

Fermi 2.

2.3.7 Fuel Cells

Fuel cells oxidize fuels without combustion and its environmental side effects. Fuel cells use a 

fuel (e.g., hydrogen) and oxygen to create electricity through an electrochemical process. The 

only byproducts (depending on fuel characteristics) are heat, water, and carbon dioxide

(depending on hydrogen fuel type) (DOE undated a). Hydrogen fuel can come from a variety of 

hydrocarbon resources, including natural gas.

Fuel cells are not economically or technologically competitive with other alternatives for 

electricity generation. EIA projects that fuel cells may cost $6,835 per installed kilowatt (total 

overnight capital costs, 2010 dollars), which is greater than other alternative replacement power

technologies analyzed in this section (EIA 2010). More importantly, fuel cell units are likely to 

be small in size (approximately 10 MWe). Replacing the power that Fermi 2 provides would be 

cost prohibitive because it would require approximately 117 units and modifications to the 

existing transmission system. Given the immature status of fuel cell technology and its high 

cost, the NRC staff does not consider fuel cells to be a reasonable alternative to Fermi 2 license 

renewal.
Alternatives Including the Proposed Action

2-19

2.3.8 Delayed Retirement

The retirement of a power plant ends its ability to supply electricity. Delaying the retirement of a 

power plant enables it to continue supplying electricity. A delayed retirement alternative would 

consider deferring the retirement of generating facilities within or near the DTE service area. 

There are no nuclear plants in DTE’s service area or elsewhere in Michigan for which delayed 

retirement could replace the baseload generating capacity of Fermi 2 by 2025 (DTE 2014b). As 

described in Appendix E of this report, the J.R. Whiting Power Plant and two units of the 

Trenton Channel Power Plant are scheduled for retirement by 2016. Delayed retirement of 

these coal plants could retain approximately 550 MW of capacity. However, the Annual Energy 

Outlook 2014 (EIA 2013b) predicts that there will be more coal plant retirements before 2016 

than previously predicted. These accelerated retirements are driven by low natural gas prices, 

slow growth in electricity demand, and the requirements of the Mercury and Air Toxics 

Standards that will impose significant reductions in plant emissions (EIA 2014b). 

Most retired units generate more pollutants and are less efficient than new units. Often, units 

are retired because operation is no longer economical. In some cases, the cost of 

environmental compliance or necessary repairs and upgrades are too great to justify continued 

operation. For these reasons, the NRC staff does not consider delayed retirement to be a 

reasonable alternative to Fermi 2 license renewal.

2.3.9 Geothermal

Geothermal technologies extract the heat contained in geologic formations to produce steam to 

drive a conventional steam turbine generator. Facilities producing electricity from geothermal 

energy have demonstrated capacity factors of 95 percent or greater, making geothermal energy 

a potential source of baseload electric power. However, the feasibility of geothermal power 

generation to provide baseload power depends on the regional quality and accessibility of 

geothermal resources. Utility-scale geothermal energy generation requires geothermal 

reservoirs with a temperature above 200 °F (93 °C). Utility-scale power plants range from small 

300 kilowatts electric to 50 MWe and greater (TEEIC undated). Geothermal resources are 

concentrated in the western United States. Specifically, these resources are found in Alaska, 

Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, 

Washington, and Wyoming (USGS 2008). In general, most assessments of geothermal 

resources have been concentrated on these western states. The DOE also has quantified 

geothermal resources in Minnesota and Vermont but not in Michigan (DOE 2013c). Geothermal 

resources are used in the ROI for heating and cooling purposes, but no electricity is currently 

being produced in the ROI from these resources (DTE 2015c, EIA 2014a). Given the low 

resource potential in the ROI, the NRC staff does not consider geothermal energy to be a 

reasonable alternative to Fermi 2 license renewal.

2.3.10 Municipal Solid Waste

Energy recovery from municipal solid waste converts nonrecyclable waste materials into usable 

heat, electricity, or fuel through combustion (EPA 2013b). The three types of combustion 

technologies are mass burning, modular systems, and refuse-derived fuel systems 

(EPA 2013a). Mass burning is the method used most frequently in the United States. The heat 

released from combustion is used to convert water to steam, which is used to drive a turbine 

generator to produce electricity. Ash is collected and taken to a landfill, and particulates are 

captured through a filtering system (EPA 2013a). As of 2010, approximately 

86 waste-to-energy plants are in operation in 25 States, processing more than 28 million tons of 
Alternatives Including the Proposed Action

2-20

waste per year (EPA 2013b). These waste-to-energy plants have an aggregate capacity of 

2,720 MWe, and although some plants have expanded to handle additional waste and to 

produce more energy, no new plants have been built in the United States since 1995 

(EPA 2013b). The average waste-to-energy plant produces about 50 MWe of electricity, with 

some producing up to 77 MWe of electricity, and can operate at capacity factors greater than 

90 percent (Michaels 2010). Michigan has three waste-to-energy facilities that produce 

approximately 89 MW of electricity (Michaels 2014). One of these three facilities is located in 

the ROI. On average, nearly 40 such plants would be necessary to provide the same level of 

output as Fermi 2.

The decision to burn municipal waste to generate energy is usually driven by the need for an 

alternative to landfills rather than energy considerations. Given the improbability that additional 

stable supplies of municipal solid waste would be available to support approximately 40 new 

facilities, and that so few existing plants operate in the ROI, the NRC staff does not consider 

municipal solid waste combustion to be a reasonable alternative to Fermi 2 license renewal.

2.3.11 Petroleum-Fired Power

EIA projects that petroleum-fired plants will account for very little of the new generation capacity 

constructed in the United States during the 2008 to 2030 time period (EIA 2013a). In 2015, 

Michigan generated 0.1 percent of its total electricity from petroleum (EIA 2016).

The variable costs of petroleum-fired generation tend to be greater than those of nuclear or 

coal-fired operations, and petroleum-fired generation tends to have greater environmental 

impacts than natural gas-fired generation. The high cost of petroleum has resulted in a steady 

decline in its use for electricity generation (EIA 2013a). Given the cost of petroleum and the 

small generating capacity from petroleum-fired power plants in the State, the NRC staff does not 

consider petroleum-fired generation a reasonable alternative to Fermi 2 license renewal.

2.3.12 Supercritical Pulverized Coal

In general, SCPC power plants are feasible, commercially available options for providing 

electrical generating capacity. Baseload coal units have proven their reliability and can sustain 

capacity factors as high as 79 percent. Pulverized coal power generation uses crushed coal 

that is fed into a boiler where it is burned to create heat. The heat produces steam that is used 

to turn one or more turbines to generate electricity. Among the technologies available, 

pulverized coal boilers that produce supercritical steam (SCPC boilers) are increasingly 

common for new coal-fired plants because of their high operating temperatures and pressures,

which increase thermal efficiencies and overall reliability. SCPC facilities consume less fuel per 

unit output, thus reducing environmental impacts (NETL undated). 

As described in Section 2.2.2.2, EPA has signed a final rule for carbon pollution that would 

apply to new fossil fuel-fired power plants, including SCPC facilities (EPA 2015). The action 

establishes performance standards and has identified a CCS system as a method of emission 

reduction. The emission limit for these sources is 1,305-lb CO2/MWh, and any new coal-fired 

power plants could require CCS to achieve this emission limit.

In addition, given known technology and technological and demographic trends, EIA predicts 

that by 2040 natural gas will surpass coal as the largest share of U.S. electric power generation 

(EIA 2013a). This does not consider the EPA rule described above but indicates a general 

trend away from coal-fired facilities in favor of natural gas-fired power plants resulting from

falling natural gas prices. MISO projected that the EPA regulations could lead to increased coal 
Alternatives Including the Proposed Action

2-21

plant retirements and estimated retirements from 3,000 to 12,600 MW, which could have a large 

impact on MISO’s reserve margin in the future (MISO 2011).

Given the potential for stringent air quality regulations and trends toward natural gas-fired power 

plants, the NRC staff does not consider SCPC to be a reasonable alternative to Fermi 2 license 

renewal. Instead, the NRC staff describes an IGCC plant as an alternative in Section 2.2.2.2.

2.3.13 Purchased Power

Power to replace the capacity of Fermi 2 could be purchased from sources within the 

United States or from sources within Canada, or both. The power purchased likely would be 

generated from coal, natural gas, nuclear, renewables, or some combination similar to the 

alternatives considered in this chapter. Unlike those alternatives considered in this chapter, 

facilities to supply purchased power would not likely be constructed solely to replace Fermi 2, 

although they may require construction of new transmission lines, on slightly older and less 

efficient technologies, and may operate at higher capacities.

One of the objectives that the State of Michigan is proposing is to “avoid undue reliance on 

energy produced by other states.” Thus, reliance on electrical power produced outside the 

State of Michigan is contrary to the objectives of Michigan’s 21st Century Electric Energy Plan 

(MPSC 2007). In addition, purchased power is generally economically adverse because the 

cost of generated power historically has been less than the cost of the same power provided by 

a third party (NRC 2013c). Power purchase agreements also have an inherent risk that the 

power contracted for will not be delivered. 

For these reasons, the NRC staff does not consider purchasing power from other utilities or 

power generators to be a reasonable alternative for replacement of Fermi 2’s baseload 

generation.

2.4 Comparison of Alternatives

In this chapter, the NRC staff considered the following alternatives to Fermi 2 license renewal: 

(1) NGCC generation, (2) IGCC generation, (3) new nuclear power generation, and (4) a 

combination alternative of natural gas, wind, and solar. The NRC staff also considered the

no-action alternative and its impacts. The impacts for all alternatives to Fermi 2 license renewal 

are discussed in Chapter 4 and summarized in Table 2–2 below.

The environmental impacts of the proposed action (issuing a renewed Fermi 2 operating 

license) would be SMALL for all impact categories. The environmental impacts from all other 

alternatives would be larger than the proposed license renewal, as indicated in Table 2–2.

In conclusion, the environmentally preferred alternative is the granting of a renewed license for 

Fermi 2. All other alternatives capable of meeting the needs currently served by Fermi 2 entail 

potentially greater impacts than the proposed action of renewing the license for Fermi 2. To

make up the lost generation of electricity if a renewed license is not issued (the no-action 

alternative), one alternative or a combination of alternatives would be implemented—all of which 

have greater impacts than the proposed action. Hence, the NRC staff concludes that the 

no-action alternative will have environmental impacts greater than or equal to the proposed 

license renewal action.
2-22

Summary of Environmental Impacts of the Proposed Action and Alternativ

Impact Area (Resource)

Fermi 2

License 

Renewal 

(Proposed 

Action) No-Action

NGCC 

Alternative

IGCC 

Alternative

New Nucle

Power 

Alternative

Land Use SMALL SMALL TO 

MODERATE

SMALL TO 

MODERATE

SMALL TO 

LARGE

SMALL TO 

LARGE

Visual Resources SMALL SMALL SMALL SMALL SMALL 

Air Quality SMALL SMALL SMALL TO 

MODERATE

SMALL TO 

MODERATE

SMALL 

Noise SMALL SMALL SMALL SMALL TO 

MODERATE

SMALL 

Geologic Environment SMALL SMALL SMALL SMALL SMALL 

Surface Water Resources SMALL SMALL SMALL SMALL TO 

MODERATE

SMALL 

Groundwater Resources SMALL SMALL SMALL SMALL SMALL 

Terrestrial Resources SMALL SMALL SMALL TO 

MODERATE

MODERATE 

TO LARGE

SMALL TO 

LARGE

Aquatic Resources SMALL SMALL SMALL SMALL TO 

MODERATE

SMALL 

Special Status Species and Habitats NO 

EFFECT

SEE NOTE10F SEE NOTE1 SEE NOTE1 SEE NOTE

Historic and Cultural Resources SEE 

NOTE21F

NO EFFECT SMALL SMALL TO 

MODERATE

SMALL TO 

MODERAT

 1 The magnitude of impact could vary widely based on site selection and the presence or absence of special status species and habita

implemented; therefore, the NRC staff cannot forecast a level of impact for this alternative.

2 Based on (1) fulfillment of the MOA stipulations regarding the NRHP-eligible Fermi 1, (2) there currently being no other known NRHP

on the Fermi site, (3) DTE’s site procedures and work instructions for protecting cultural resources, (4) the assurance that no license 

changes or ground-disturbing activities would occur outside developed areas, (5) Michigan SHPO input, and (6) this cultural resource 

properties would be adversely affected by the license renewal decision (36 CFR Section 800.4(d)(1)).
2-23

Impact Area (Resource)

Fermi 2

License 

Renewal 

(Proposed 

Action) No-Action

NGCC 

Alternative

IGCC 

Alternative

New Nucle

Power 

Alternative

Socioeconomics SMALL SMALL TO 

LARGE

SMALL TO 

LARGE

SMALL TO 

LARGE

SMALL TO 

LARGE

Transportation SMALL SMALL SMALL TO 

LARGE

SMALL TO 

LARGE

SMALL TO 

LARGE

Human Health SMALL32 F SMALL3 SMALL3 SMALL3 SMALL3 

Environmental Justice SEE 

NOTE43F

SEE NOTE54F SEE NOTE65F SEE NOTE66F SEE NOTE

Waste Management SMALL SMALL SMALL MODERATE SMALL 

 3 The impacts on human health from chronic effects of electromagnetic fields are categorized as UNCERTAIN.

4 Continued operation of Fermi 2 would not have disproportionately high and adverse human health and environmental effects on mino

populations.

5 The No-Action alternative could disproportionately affect minority and low-income populations that may have relied on the public serv

County.

6 Based on available information, it is not likely that the NGCC, IGCC, new nuclear, and combination alternatives would have dispropo

human health and environmental effects on U.S. minority and low-income populations. However, this determination would depend on 

design, and operational characteristics of new power generating facilities. Therefore, the NRC cannot determine whether these alter

disproportionately high and adverse human health and environmental effects on minority and low-income populations.
Alternatives Including the Proposed Action

2-24

2.5 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

renewal of operating licenses for nuclear power plants.”

79 FR 1430. U.S. Environmental Protection Agency. “Standards of performance for 

greenhouse gas emissions from new stationary sources: Electric utility generating units.”

Federal Register 79(5):1430–1519. January 8, 2014.

80 FR 26302. U.S. Nuclear Regulatory Commission. “DTE Electric Company: Fermi 3. 

Combined License and Record of Decision: Issuance.” Federal Register 80: 26302-26303. 

May 7, 2015.

Archer CL, Jacobson MZ. 2007. Supplying baseload power and reducing transmission 

requirements by interconnecting wind farms. Journal of Applied Meteorology and 

Climatology 46(11):1701–1717. Available at 

<http://www.stanford.edu/group/efmh/winds/aj07_jamc.pdf> (accessed 26 February 2015). 

Ardani K, Margolis R. 2011. 2010 Solar Technologies Market Report. Golden, CO: National 

Renewable Energy Laboratory. November 2011. 136 p. Available at 

<http://www.nrel.gov/docs/fy12osti/51847.pdf> (accessed 26 February 2015).

[AWEA] American Wind Energy Association. 2014. AWEA U.S. Wind Industry Second Quarter 

2014 Market Report Executive Summary. July 31, 2014. 12 p. Available at 

<http://awea.files.cms-plus.com/FileDownloads/pdfs/2Q2014%20AWEA%20Market%20Report

%20Public%20Version%20.pdf> (accessed 10 October 2014).

[BLM and DOE] U.S. Department of the Interior Bureau of Land Management and 

U.S. Department of Energy. 2010. Draft Programmatic Environmental Impact Statement for 

Solar Energy Development in Six Southwestern States. DES 10-59; DOE/EIS-0403, Volumes 1 

to 8. December 2010. 11,145 p. Available at 

<http://www.solareis.anl.gov/documents/dpeis/index.cfm#vol1> (accessed 18 September 2014).

[BLM and DOE] U.S. Department of the Interior Bureau of Land Management and 

U.S. Department of Energy. 2012. Final Programmatic Environmental Impact Statement 

(PEIS) for Solar Energy Development in Six Southwestern States. FES 12-24; DOE/EIS-0403, 

Volumes 1 to 7. July 2012. 3,596 p. Available at 

<http://www.solareis.anl.gov/documents/fpeis/index.cfm> (accessed 18 September 2014).

[BOEM] Bureau of Ocean Energy Management. Undated. Ocean Wave Energy. Available at 

<http://www.boem.gov/Renewable-Energy-Program/Renewable-Energy-Guide/

Ocean-Wave-Energy.aspx> (accessed 25 February 2015).

Channell J, Lam T, Pourreza S. 2012. Shale and renewables: A symbiotic relationship. CITI 

Research. September 12, 2012. 88 p. Available at <http://www.ourenergypolicy.org/

wp-content/uploads/2013/04/citigroup-renewables-and-natgas-report.pdf> (accessed 

26 November 2013).
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Conner AM, Francfort JE, Rinehart BN. 1998. U.S. Hydropower Resource Assessment, Final 

Report. Idaho Falls, ID: Idaho National Engineering and Environmental Laboratory. 

DOE/ID-10430.2. December 1998. 49 p. Available at 

<http://hydropower.inl.gov/resourceassessment/pdfs/doeid-10430.pdf> (accessed 

26 February 2015).

[DOE] U.S. Department of Energy. 2010a. Kemper County Integrated Gasification 

Combined-Cycle (IGCC) Project, Final Environmental Impact Statement (EIS). Washington, 

DC: U.S. Department of Energy. DOE/EIS-0409, Volume 1. May 2010. 671 p. Available at 

<http://energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/

EIS-0409-FEIS-01-2010.pdf> (accessed 17 September 2014).

[DOE] U.S. Department of Energy. 2010b. Final Environmental Assessment for Department of 

Energy Loan Guarantee for the Agua Caliente Solar Project in Yuma County, Arizona. 

DOE/EA-1797. November 2010. Available at 

<http://energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/EA-1797-FEA-2010.pdf> 

(accessed 18 September 2014).

[DOE] U.S. Department of Energy. 2013c. State Geothermal Resource Assessment and Data 

Collection Efforts. February 22, 2013. Available at 

<http://www1.eere.energy.gov/geothermal/resource_assessments.html> (accessed 

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3-1

3.0 AFFECTED ENVIRONMENT

In this supplemental environmental impact statement (SEIS), the “affected environment” is the 

environment that currently exists at and around Fermi 2. Because existing conditions are at 

least partially the result of past construction and operation at the plant, the impacts of these past 

and ongoing actions and how they have shaped the environment are presented here. The 

facility and its operation are presented in Section 3.1. Sections 3.2 to 3.13 present the affected 

environment.

3.1 Description of Nuclear Power Plant Facility and Operation

Fermi 2 is a single-unit nuclear power plant located in Frenchtown Township, Michigan. 

Fermi 2’s operating license was issued in July 1985 and Fermi 2 began commercial operation 

on February 15, 1988. Generally, the U.S. Nuclear Regulatory Commission (NRC) staff drew 

information about Fermi 2’s facilities and operation from the DTE Electric Company’s (DTE’s)

Environmental Report (ER) (DTE 2014d). 

3.1.1 External Appearance and Setting 

The Fermi site is located on the western shore of Lake Erie in Frenchtown Township, Monroe 

County, Michigan, approximately 8 miles (mi) (13 kilometers (km)) east-northeast of Monroe, 

28 mi (45 km) south-southwest of Detroit, and 26 mi (42 km) northeast of Toledo, Ohio 

(Figure 3–1) (DTE 2014d).

Fermi 2 is located on approximately 1,260 acres (ac) (510 hectares (ha)) of land owned by DTE 

(Figure 3–2 and Figure 3–3). The principal structures at Fermi 2 consist of the reactor building, 

turbine building, auxiliary building, radioactive waste building, 120-kilovolt (kV) and 345-kV 

switchyards, residual heat removal (RHR) complex, two natural draft hyperbolic cooling towers, 

general service water (GSW) pump house, circulating water pump house, circulating water 

reservoir (CWR), meteorological tower, auxiliary boiler house, training center, and independent 

spent fuel storage installation (ISFSI) pad (DTE 2014d).
Affected Environment

3-2

Figure 3–1. Fermi 2 50-mi (80-km) Radius Map

Source: DTE 2014d
Affected Environment

3-3

Figure 3–2. Fermi 2 6-mi (10-km) Radius Map

Source: DTE 2014d
Affected Environment

3-4

Figure 3–3. Fermi 2 Site Boundary

Source: NRC 2013a, Figure 2–1
Affected Environment

3-5

3.1.2 Nuclear Reactor Systems

Fermi 2 uses a General Electric Company single-cycle, forced-circulation boiling water reactor 

(BWR) of the BWR 4 Class, with a pressure-suppression Mark I containment. The reactor

pressure vessel contains the core and supporting structures; steam separators and dryers; jet 

pumps; control rod guide tubes; distribution lines for the feedwater; core sprays; and standby 

liquid control, in-core instrumentation, and other components. The main connections to the 

reactor pressure vessel include the steam lines, the coolant recirculation lines, feedwater lines, 

control rod drive housings, and emergency core cooling system lines (DTE 2014d).

The reactor recirculation system consists of two recirculation pump loops that are external to the 

reactor vessel but are inside the primary containment. These loops provide the piping path for 

the driving flow of water to the reactor vessel jet pumps that provide continuous internal 

circulation of the core coolant flow (DTE 2014d).

On February 10, 2014, the NRC approved Fermi 2’s measurement uncertainty recapture

(thermal power optimization) request to increase the thermal power limit from 3,430 megawatts

thermal (MWt) to 3,486 MWt (NRC 2014a). This measurement uncertainty recapture increases 

the net electrical capacity from 1,150 megawatts-electric (MWe) to approximately 1,170 MWe. 

Fuel for the reactor core consists of enriched uranium dioxide pellets sealed in Zircaloy-2 tubes. 

Fuel enrichment and average peak rod burnup conditions are no more than 5 percent

uranium-235 and 60,000 megawatt-days per metric ton of uranium, respectively (DTE 2014d).

3.1.3 Cooling and Auxiliary Water Systems

Fermi 2 uses a closed-cycle (cooling-tower-based) heat dissipation system that during normal 

plant operating conditions withdraws makeup water from, and discharges cooling water back to, 

Lake Erie. Two concrete natural draft cooling towers are used for heat dissipation. 

Fermi 2’s GSW system supplies water to the plant heat exchangers for use in waste heat 

removal and other nonsafety-related plant systems. Water is withdrawn from Lake Erie for 

GSW makeup through a shoreline pump house and intake canal located southeast of the main 

plant complex. In turn, discharge from the GSW system provides a source of makeup water for 

the circulating water system (CWS) and the CWR, which supplies the main condenser

(DTE 2014d). 

A BWR, like the one used at Fermi 2, generates steam directly in the reactor vessel. The steam 

passes through moisture separators and steam dryers and then flows to the turbine. Such 

systems contain only two heat transfer (exchange) loops (DTE 2014d; NRC 2013b). The 

primary loop transports the steam from the reactor vessel directly to the turbine, which 

generates electricity. The secondary cooling water loop removes excess heat from the primary 

loop in the main condenser. From the condenser, the primary condensate is returned as 

feedwater to the reactor; the secondary cooling water loop removes the excess heat and then 

routes it to the cooling towers. The cooling towers dissipate the excess heat to the atmosphere. 

Water that is not lost to evaporation is either recirculated through the system or discharged as 

blowdown (i.e., water that is periodically rinsed from the cooling system to remove impurities 

and sediment that may degrade plant performance) to a receiving water body. Water that is lost 

to evaporation or that is discharged as blowdown must be replaced with fresh water; this water 

is referred to as makeup water (NRC 2013b). Figure 3–4 provides a basic schematic diagram 

of a once-through cooling system with a natural draft cooling tower.
Affected Environment

3-6

Figure 3–4. Closed-Cycle Cooling System with Natural Draft Cooling Tower

Source: Modified from NRC 2013b

No onsite groundwater is used at the site. Water for potable and other related uses is supplied 

by the Frenchtown municipal system, which also withdraws water from Lake Erie.

Unless otherwise cited for clarity, the NRC drew information about Fermi’s cooling and auxiliary 

water systems from the DTE’s ER (DTE 2014d) and from the updated final safety analysis

report (UFSAR) (DECo 2012e, 2012f). The NRC staff visited the facilities cited herein during 

the September 2014 environmental site audit (NRC 2014c). Individual plant systems that 

interact with the environment are discussed further below.

3.1.3.1 General Service Water and Intake System

The GSW system consists of two trash racks, two traveling screens, sluice gates, five GSW 

pumps located in the GSW pump house and two CWR makeup pumps to provide additional 

makeup water to the CWR, five strainers on the discharge of the GSW pumps, and the 

necessary piping and other equipment and controls to operate the system components. As 

discussed later, the GSW pump house also contains two 100-percent-capacity CWR makeup 

pumps and two 100-percent-capacity fire water pumps.

The GSW system provides water to support both continuous and intermittent demands at 

Fermi 2. It provides a continuous flow to the biocide injection system and plant heat exchanger 

equipment, the reactor building and turbine building closed cooling water heat exchangers, the 

main generator hydrogen coolers, and the main turbine lube oil coolers. The return flow from 

these sources is discharged into the CWR for circulating water makeup usage. Intermittent flow 

is provided to the auxiliary boiler house, the traveling screen backwashing system, the fire 

protection system, the lawn sprinkling system, and the RHR complex.

Makeup water for the GSW system is withdrawn through a lakeshore intake structure at the 

head of a concrete intake canal (Figure 3–5) that originally served Fermi 1. The head of the 

canal is 33 feet (ft) (10 meters (m)) wide with an average water depth of 12.5 ft (3.8 m) that 

increases down the canal toward the pump house. The canal runs approximately 61 ft (19 m)

from its entrance to the submerged opening into the GSW pump house, with the last 25 ft 

(7.6 m) of the canal separated into two channels by a concrete pier. Water enters through the 

pump house’s two submerged intake openings and passes through two stationary steel-bar 
Affected Environment

3-7

trash racks (with a 3-inch (in.) (7.6-centimeter (cm)) spacing) that are equipped with a sliding 

steel rake system to remove floating debris. Trash and other debris collected by the rake 

system are discharged to a collection cart before disposal.

After the trash racks, intake water then flows through two screen bays, each 11.75 ft (3.6 m) in 

width. Each bay has a vertical traveling screen designed to prevent small debris that is not 

intercepted by the trash racks and fish from entering the pump pits. Each screen has 3/8-in. 

(0.95-cm) woven wire openings that are mounted on two strands of endless roller chains. 

Based on intake velocity studies performed between 1991 through September 1992, no average 

velocity at the intake forebay or traveling screens exceeded 0.5 feet per second (0.15 meter per 

second). The traveling screens can operate in automatic or manual modes, and a line from the 

GSW discharge header provides high-pressure water to backwash each screen. The screens 

are also equipped with a separate line that supplies warm water for deicing. Backwashing is 

automatically initiated when differential pressure readings across the screens rise above a 

predetermined value (DECo 2012f). The backwash system sprays water out through the 

screens to remove debris while the screens are rotating, and a smaller traveling screen filters 

the debris. Backwash can be directed to the GSW backwash system or the Fermi 1 overflow 

canal (North Canal) through a permitted outfall, and an auger system collects and conveys the 

debris and any fish removed from the screens to a collection container for proper disposal. The 

intake has neither a low-pressure wash to remove impinged fish from the screens nor a 

separate fish return system. The configuration of the backwash system allows for the addition 

of biocides to the entire GSW to prevent fouling of piping from zebra mussel 

(Dreissena polymorpha) infestation.
Affected Environment

3-8

Figure 3–5. Fermi 2 Cooling Water Supply Facilities and Major Surface Water Features

Source: Modified from DTE 2014d
Affected Environment

3-9

Water passing through the traveling screens enters the GSW pump pits, which are equipped 

with sluice gates that allow the pits to be closed off to Lake Erie. The GSW pump house houses 

five GSW pumps that take suction from the pits. Each pump has a capacity of 7,700 gallons per 

minute (gpm) (17 cubic feet per second (cfs) or 0.48 cubic meter per second (m3

/s)), and each 

has its own basket strainer to remove any remaining debris with automatic backwashing. As 

demand varies, the pumps are operated as necessary from the Fermi 2 main control room 

(DECo 2012f). During the winter months, two pumps are normally in service, and four are in 

service during the summer. Consequently, with four GSW pumps operating, Fermi 2 withdraws 

approximately 30,800 gpm (68.6 cfs; 1.94 m3

/s) or about 44.4 million gallons per day (mgd) 

(168,000 cubic meters per day (m3

/d)) of water from Lake Erie.

3.1.3.2 Circulating Water System and Blowdown Discharge

The CWS provides water to the main condenser to condense the steam discharged from the 

Fermi 2 turbine. Cooling occurs as heat is rejected from the circulating water to the atmosphere 

through the plant’s natural draft cooling towers. The system normally supplies water to the main 

condenser at temperatures ranging from 55 °F to 94 °F (13 to 34 °C). However, when lake 

intake temperatures fall to 35 °F (1.7 °C), the cooling towers are bypassed within the circulating 

water flow.

The CWS encompasses the main condenser, two cooling towers, the CWR, and associated 

circulating water pumps and piping. The CWR is a 5.5-ac (2.2-ha) impoundment located 

immediately east of, and adjacent to, Fermi’s two natural-draft cooling towers (Figure 3–5). 

From the CWR, water is pumped through the CWS piping from the circulating water pump 

house located at the southern end of the CWR. This structure contains five circulating water 

pumps. Each pump has a rated capacity of 180,000 gpm (400 cfs; 11.3 m3

/s). Based on plant 

heat load demand and weather, one to five circulating pumps may be operated to meet 

circulating water needs. The pumps take suction from the CWR, and the water is passed 

through a stationary screen for debris removal. Sodium hypochlorite is added as a biocide to 

the circulating water to limit biofouling of condenser tube surfaces. The circulating water is then 

discharged through two pipelines to the plant’s main condenser. Heated water returns through 

two interconnected 12-ft- (3.7-m)-diameter pipes and conveyed to Fermi 2’s natural draft cooling 

towers, with cooled water exiting the base of the towers and flowing back to the CWR.

The CWS also includes a blowdown (decanting) system to keep dissolved solid concentrations 

in the circulating water at acceptable levels. Blowdown is discharged continuously to Lake Erie 

at a rate ranging from approximately 10,000 to 30,000 gpm (22.3 to 66.8 cfs (0.63 to 1.9 m3

/s), 

or 14.4 to 43.2 mgd)). Decanting pumps discharge blowdown through a 3-ft- (1-m)-diameter 

discharge line that runs east from the circulating water pump house to a shoreline discharge 

structure, which is Fermi 2’s primary National Pollutant Discharge Elimination System (NPDES)

permitted outfall (Outfall 001) (Figure 3–5 and 3–12). As further described in Section 3.5.1.3 of 

this SEIS, the Fermi 2 NPDES permit (No. MI0037028) (MDNR 2012) imposes limits on the 

blowdown discharge and specifies monitoring of residual chlorine and other listed biocides 

(used for zebra mussel control) from Outfall 001. Sodium bisulfite is added to dechlorinate the 

blowdown stream in accordance with NPDES permit provisions. The plant’s NPDES permit 

does not impose any thermal effluent limits, such as either a maximum temperature or a change 

in receiving water temperature per unit of time. The nominal (design) temperature rise in the 

circulating water passing through the main condenser results in a discharge temperature to the 

lake that is typically no higher than approximately 18 °F (10 °C) above that of the intake water. 

Fermi 2’s NPDES permit does include a cold shock prevention requirement (applicable 

November through March) for the gradual reduction of discharges to allow aquatic life to 

acclimate to reduced temperatures near Outfall 001.
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Makeup water is needed to replace evaporative (cooling tower evaporation and drift and 

evaporation from the CWR) and blowdown losses from normal operation of the CWS, as 

described above. Normally, when losses exceed the normal makeup rate from the GSW, two 

circulating water makeup pumps located in the GSW pump house provide additional makeup 

water to the CWR through a 54-in. (138-cm) pipeline that connects the GSW pump house and 

the CWR. Each 100-percent capacity pump is rated at 15,000 gpm (33.4 cfs; 0.94 m3

/s) 

(DECo 2012f). Alternatively, the pipeline can also be used to supply heat loads normally 

serviced by the GSW by opening the normally closed valve in the connecting pipeline between 

the CWR and the GSW pump intake pit while closing the sluice gates to the intake canal. In this 

manner, the GSW and CWSs can operate sufficiently long enough to support plant load 

reduction and shutdown. This dual capability guards against low lake levels or otherwise from 

the loss of the intake structure.

3.1.3.3 Residual Heat Removal Complex

Although Fermi 2’s natural-draft cooling towers provide the normal heat sink for the plant’s main 

condenser and auxiliary cooling systems, the RHR complex serves as the ultimate heat sink for 

plant shutdown and recovery from the loss of normal cooling during emergency conditions. The 

RHR complex comprises seismic Category I (safety-related) structures, including a highly

reliable water supply reservoir; mechanically induced draft cooling towers for heat rejection; four 

emergency diesel generators for emergency power; a makeup water supply and blowdown 

system; and associated pumps, piping, and controls. The ultimate heat sink system is sized to 

provide sufficient cooling for 7 days following a reactor shutdown without makeup water addition 

to the RHR reservoir (DECo 2012f).

The RHR complex reservoir consists of two one-half-capacity reinforced-concrete structures, 

each storing 3.41 million gal (12,900 m3

) of water. Each reservoir structure is equipped with a 

two-cell induced draft cooling tower located on top of it that is designed to cool one division of 

the plant load and provide complete redundancy. Blowdown from the induced-draft cooling 

towers is discharged to the CWR. The GSW system provides makeup water to the RHR 

complex to replace evaporation and blowdown losses during normal shutdown cooling.

3.1.3.4 Potable Water System

Potable water is supplied to the Fermi site through a distribution pipeline from the Frenchtown 

Township Water Department. Delivered water is stored in a 100,000-gal (380-m3

) elevated 

storage tank from where potable water is distributed to restrooms, drinking fountains, kitchen 

facilities, and safety showers throughout the Fermi site and to the turbine building heating, 

ventilation, and air conditioning evaporative coolers. Potable water is also supplied to the 

demineralized water makeup system, which provides demineralized water to Fermi 2’s reactor

core. Fermi site’s potable water demand is approximately 20,000 gallons per day (76 m3

/d), or 

about 14 gpm) (DTE 2014d).

The source of Frenchtown Township’s water supply is Lake Erie, and it shares a raw water 

intake with the City of Monroe at Pointe Aux Peaux located south of the Fermi site. In 2006, the 

township upgraded its water treatment plant’s capacity to 8 mgd (30,300 m3

/d, or about 

5,560 gpm). The township’s current excess supply capacity is approximately 4 mgd 

(15,140 m3

/d, or about 2,780 gpm) (MCPDC 2010; NRC 2013a).

3.1.3.5 Fire Protection Water System

Fire protection water mains encircling the Fermi site are normally supplied with makeup water 

from the GSW system. However, firewater can also be supplied directly through two 

interconnected fire-water pumps housed in the GSW pump house. One pump is electric-driven,

and the other is a diesel-driven pump. Both pumps have a capacity of 2,500 gpm (5.6 cfs;
Affected Environment

3-11

0.16 m3

/s), and each can supply the required fire protection water demands. The pumps are 

normally in standby mode as the fire mains are supplied with makeup water and pressurization 

from the fire protection jockey pump, which takes suction from the GSW pump header. 

Changes in pressure between the fire protection and GSW supply headers will automatically 

trigger the pumps in sequence as demands dictate (DECo 2012f; DTE 2014d).

3.1.4 Radioactive Waste Management Systems

As part of normal operations and as a result of equipment repairs and replacements due to 

normal maintenance activities, nuclear power plants routinely generate both radioactive and 

nonradioactive wastes. Nonradioactive wastes include hazardous and nonhazardous wastes. 

There is also a class of waste, called mixed waste, that is both radioactive and hazardous. The 

systems used to manage (i.e., treat, store, and dispose of) these wastes are described in this 

section. Waste minimization and pollution prevention measures commonly employed at nuclear 

power plants are also discussed in this section.

All nuclear plants were licensed with the expectation that they would release radioactive 

material to both the air and water during normal operation. However, the NRC’s regulations 

require that gaseous and liquid radioactive releases from nuclear power plants must meet 

radiation dose-based limits specified in Title 10 of the Code of Federal Regulations (10 CFR) 

Part 20, and the as low as is reasonably achievable (ALARA) criteria in Appendix I to 10 CFR 

Part 50. Regulatory standards in 10 CFR 20.1301 limit the radiation dose that members of the 

public can receive from radioactive effluents released by a nuclear power plant. All nuclear 

power plants use radioactive waste management systems to control and monitor radioactive 

wastes.

Fermi 2 uses liquid, gaseous, and solid waste processing systems to collect and process, as 

needed, radioactive materials produced as a by-product of plant operations. The liquid and 

gaseous radioactive effluents are processed to reduce the levels of radioactive material before 

such materials are discharged to the environment to ensure that the dose to members of the 

public from radioactive effluents is reduced to levels that are ALARA in accordance with the 

NRC’s regulations. The radioactive material removed from the effluents is either released into 

the environment or converted into a solid form for disposal at a licensed radioactive disposal 

facility. Fermi 2 has an Offsite Dose Calculation Manual (ODCM) that contains the methods and 

parameters used to calculate offsite doses resulting from liquid and gaseous radioactive 

effluents (DTE 2014d).

Fermi 2 assesses the impact to the environment from its radioactive effluents through the use of 

a radiological environmental monitoring program (REMP). The REMP measures the aquatic, 

terrestrial, and atmospheric environment for radioactivity, as well as the ambient radiation. The 

REMP monitors and/or obtains samples from indicator stations close to the plant to determine 

direct impacts from Fermi 2 operations and has control stations located farther away from the 

plant to measure background radiation (i.e., cosmic sources; global fallout; and naturally 

occurring radioactive material, including radon). The Fermi 2 REMP was established in 1978 

before the nuclear operations to obtain data on background radiation and radioactivity levels in 

the local environment (DTE 2014d).

3.1.4.1 Radioactive Liquid Waste Management

The liquid radioactive waste system at Fermi 2 collects, monitors, processes, stores, and 

returns radioactive liquid wastes to the plant for reuse or to the CWR blowdown line for 

controlled discharge. The collection and processing are done in a controlled, preplanned 

manner in compliance with established regulatory requirements. Any leakage or spillage due to 

equipment failure or malfunction is contained and recollected in the system. The system is 
Affected Environment

3-12

capable of handling anticipated quantities of liquid radioactive waste without affecting the 

normal operation or availability of the plant.

At times, the liquid radioactive waste system may produce water that may not be required for 

reuse; in this case, the liquid effluent could be discharged in a controlled manner to the CWR 

blowdown line. Processed liquid not meeting the criteria for either discharge or reuse is 

normally returned to the system for reprocessing.

Fermi 2 operates three radioactive liquid waste subsystems: (1) the floor drain collector (FDC) 

subsystem, (2) the waste collector subsystem (WCS), and (3) the side stream liquid radioactive 

waste processing subsystem (DTE 2014d).

Floor Drain Collector Subsystem

The FDC subsystem receives inputs from various floor drains in the plant. The inputs to this 

subsystem have been segregated from the WCS because the generally poor quality water from 

the FDC inputs has high conductivity and higher concentrations of suspended and dissolved 

solids. However, the radioactivity levels are generally lower than that of the WCS. Periodic and 

variable quantities of oil and grease are also handled by this subsystem and, when necessary, 

are removed by filters and an oil coalescer, which combines the oil into a mass that can be 

readily removed from the waste stream. Evaporators can also be used to separate the FDC 

subsystem low-purity liquid by evaporation and condensation into a concentrated liquid that is 

sent to the radioactive solid waste system and a high-purity distillate that is sent to the FDC and 

waste collector demineralizers. The FDC and waste collector streams are normally passed 

through demineralizers. If needed, additional filters can be used to provide additional cleanup of 

the waste stream. The estimated design-basis daily volume inputs for the FDC subsystem is 

15,219 gal (57,608 liters (L)), and the maximum daily volume input is calculated to be 

42,284 gal (160,058 L) (DTE 2014d). 

Waste Collector Subsystem

The WCS receives inputs from a variety of plant equipment drain sources. The equipment drain 

sources have been segregated from the FDC subsystem (and other sources) because the WCS 

inputs are generally of a higher purity, having lower conductivity and suspended solids, than that 

of the FDC inputs. The radioactive material concentrations handled by the WCS are generally 

higher than they are in the FDC subsystem. Oil and grease may be present in the WCS but 

less frequently than they are in the FDC subsystem. Oil coalescers are available for oil 

removal, as needed. The WCS also handles liquid waste generated by the radioactive solid 

waste system that dewaters solid waste for disposal. 

The estimated design-basis daily volume inputs for the WCS total 28,805 gal (109,035 L). The 

maximum daily equipment drain volume input to this subsystem is calculated to be 48,846 gal

(184,897 L). A waste surge tank, which has a working volume of about 65,700 gal (248,694 L)

serves as the backup collection point for any excess volume input to the WCS (DTE 2014d).

Side Stream Liquid Radioactive Waste Processing Subsystem

The side-stream liquid radioactive waste processing subsystem processes chemical waste tank

contents before forwarding it to the floor drain collector tank (FDCT). In addition, it processes

liquids, such as sludge from various building sumps, water collected in drums from the standby 

liquid control system rinses during refueling outages, and water from mopping the building 

floors.

The side-stream liquid radioactive waste processing subsystem includes two evaporators and 

two components that makeup the post-treatment system (PTS). The PTS consists of a 
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3-13

granulated active charcoal filter; an ultraviolet total organic carbon reducing system; a mixed 

bed filter; and associated tanks, pumps, and other system components.

Each evaporator can process liquids in 55-gal (208-L) batches at a nominal rate of 0.2 gpm 

(0.8 liters per minute (L/min)). The vapor from the evaporator is condensed and collected in the 

post-treatment batch tank. The evaporator residue is processed and shipped as radioactive 

solid waste. Liquids from the post-treatment batch tank are processed by the PTS. The PTS 

can process FDCT liquids at a nominal 40 gpm (151 L/min) rate. The processed liquid is 

collected in the sample batch tank and returned to the FDCT through the radioactive waste 

building basement floor drain system (DTE 2014d).

The use of these radioactive waste systems and the procedural requirements in the Fermi 2 

ODCM ensure that the dose to members of the public from radioactive liquid effluents complies 

with NRC and U.S. Environmental Protection Agency (EPA) regulatory dose standards.

Dose estimates for members of the public are calculated based on radioactive liquid effluent 

release data and aquatic transport models. DTE’s annual radiological effluent release report 

contains a detailed presentation of any radioactive liquid effluents released from Fermi 2 and 

the resultant calculated doses. The NRC staff reviewed 5 years of radioactive liquid effluent 

release data: 2010 through 2014 (DECo 2011d, 2012c, 2013b; DTE 2014e, 2015b). A 5-year 

period provides a data set that covers a broad range of activities that occur at a nuclear power 

plant, such as refueling outages, routine operation, and maintenance activities, that can affect 

the generation of radioactive effluents. As noted by DTE in its ER, Fermi 2’s last planned 

radioactive liquid effluent release was in 1994. Since that time, Fermi 2 has operated as a 

zero-discharge radioactive liquid effluent release facility with a goal to continue operating in the 

manner in the future. The NRC staff’s review of the radioactive liquid effluent release data 

shows that Fermi 2 had not had any planned radioactive liquid effluent releases in Lake Erie for 

the years 2010 through 2014. However, DTE reported in its “2010 Annual Radiological 

Environmental Operating Report and Radiological Effluent Release Report for Fermi 2” that on 

December 1, 2010, there was an inadvertent (abnormal) release of radioactive water from a spill 

inside its radiological restricted area into its sanitary sewer system. As a result, some of this 

water entered the sewer line leading to the Monroe wastewater treatment plant and was 

discharged into Lake Erie. The potential dose to a member of the public from this abnormal 

release was calculated by Fermi 2 personnel to be 1.3x10−6 millirem (mrem) (1.3x10−8 

millisievert (mSv)) to the total body and 4.5x10−6 mrem (4.5x10−8 mSv) to the gastrointestinal 

tract (DECo 2011d). 

The NRC staff compared these calculated doses against the NRC’s ALARA dose criteria in 

Appendix I to 10 CFR Part 50. The 1.3x10−6 mrem (1.3x10−8 mSv) total body dose is well below 

the 3 mrem (0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50. The 4.5x10−6 mrem 

(4.5x10−8 mSv) dose to the gastrointestinal tract is well below the 10 mrem (0.1 mSv) dose 

criterion in Appendix I to 10 CFR Part 50. 

As previously discussed, there were no planned radioactive liquid effluent releases from Fermi 2 

during the 5-year period from 2010 through 2014. Therefore, there was no dose to members of 

the public from radioactive liquid effluents other than the dose from the abnormal release 

in 2010.

Routine plant refueling and maintenance activities currently performed will continue during the 

license renewal term. Based on the past performance of the radioactive waste system to 

maintain doses from radioactive liquid effluents within NRC and EPA radiation protection 

standards and on the DTE’s goal to maintain Fermi 2 as a zero-discharge radioactive liquid 

effluent release facility in the future, similar performance is expected during the license renewal 

term.
Affected Environment

3-14

3.1.4.2 Radioactive Gaseous Waste Management

The radioactive gaseous waste system at Fermi 2 reduces radioactive materials in gaseous 

effluents before being released into the environment.

Gaseous radioactive wastes are released into the atmosphere in a controlled and monitored 

manner. The radioactive gaseous waste sampling and analysis program specifications provided 

in the Fermi 2 ODCM address the gaseous release type, sampling frequency, minimum analysis 

frequency, type of activity analysis, and lower limit of detection (i.e., sensitivity) for the radiation 

monitors.

Gaseous wastes are generated from the main condenser, the turbine gland seal condenser, and 

various plant ventilation systems that collect gases from the main steam line and primary 

coolant system.

The noncondensible gases (offgas) removed from the main condenser is the largest single 

source of radioactive gaseous waste from the plant. Other sources of radioactive gaseous 

waste include releases from the turbine gland seal steam condenser and releases from various 

plant ventilation systems from potential leakage of the main steam line and primary reactor

coolant system.

Fermi 2 uses an offgas system to reduce the amount of radioactive material released into the 

environment. Above low power operation, the offgas system processes the condenser offgas 

by delaying the gases in six charcoal beds so that significant radioactive decay of the 

radionuclides occurs before their release from the plant. 

During plant operation, offgas released from the steam-jet air ejectors is diluted with steam to 

control hydrogen concentrations. The gas is heated and enters a component that uses a 

catalytic process to combine the hydrogen and oxygen into water. The gases are routed to a 

long pipe that takes them approximately 2.2 minutes to transit. This time delay allows the short 

half-life radionuclides to decay away. The gases are then passed through a sand filter followed 

by charcoal adsorbers. A system vacuum pump maintains a slightly negative pressure 

throughout the offgas system to minimize system leakage. The condenser offgas system 

removes most of the radioactivity from the waste gases and removes essentially all of the 

hydrogen. The effluent from the offgas system is discharged from the plant after dilution in the 

reactor building ventilation system exhaust (DTE 2014d).

The use of these radioactive waste systems and the procedural requirements in the Fermi 2 

ODCM ensure that the dose to members of the public from radioactive gaseous effluents 

complies with NRC and EPA regulatory dose standards.

Dose estimates for members of the public are calculated based on radioactive gaseous effluent 

release data and atmospheric transport models. DTE’s annual radioactive material release 

report contains a detailed presentation of the radioactive gaseous effluents released from 

Fermi 2 and the resultant calculated doses. The NRC staff reviewed 5 years of radioactive 

effluent release data: 2010 through 2014 (DECo 2011d, 2012c, 2013b; DTE 2014e, 2015b). 

A 5-year period provides a data set that covers a broad range of activities that occur at a 

nuclear power plant, such as refueling outages, routine operation, and maintenance activities,

that can affect the generation of radioactive effluents. The NRC staff compared the data against 

NRC dose limits and looked for indication of adverse trends (i.e., increasing dose levels) over 

the period of 2010 through 2014. The following information summarizes the calculated doses 

from radioactive gaseous effluents released from Fermi 2 during 2014:
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3-15

• The air dose at the site boundary from gamma radiation in gaseous effluents from 

Fermi 2 was 2.24x10−3 millirad (mrad) (2.24x10−5 milligray (mGy)), which is well 

below the 10 mrad (0.1 mGy) dose criterion in Appendix I to 10 CFR Part 50.

• The air dose at the site boundary from beta radiation in gaseous effluents from 

Fermi 2 was 1.53x10−3 mrad (1.53x10−5 mGy), which is well below the 20 mrad 

(0.2 mGy) dose criterion in Appendix I to 10 CFR Part 50.

• The dose to an organ (bone) from radioactive iodine, radioactive particulates, and 

carbon-14 from Fermi 2 was 2.32x10−1 mrem (2.32x10−3 mSv), which is well below 

the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50.

The NRC staff’s review of Fermi 2’s radioactive gaseous effluent control program showed that 

radiation doses to members of the public were controlled within NRC and EPA radiation 

protection standards in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 40 CFR Part 190. 

No adverse trends were observed in the dose levels.

Routine plant refueling and maintenance activities currently performed will continue during the 

license renewal term. Based on the past performance of the radioactive waste system to 

maintain doses from radioactive gaseous effluents within NRC and EPA radiation protection 

standards, similar performance is expected during the license renewal term.

3.1.4.3 Radioactive Solid Waste Management

Low-level radioactive waste (LLW) is generated by the removal of radioactive material from 

liquid waste streams, filtration of gaseous effluents, and removal of contaminated material from 

various reactor areas. 

The radioactive solid waste system at Fermi 2 collects, processes, and packages LLW for 

disposal at a licensed LLW disposal facility. Radioactive liquid and wet solid wastes and slurries 

are processed to remove the water from the waste and are stored temporarily until they are 

transported to a licensed LLW disposal facility. A subsystem packages, stores, and prepares 

dry wastes generated during plant operations for disposal. The dry waste includes paper, rags, 

and other disposables that are usually compacted to reduce their volume. The equipment used 

to process the solid waste is designed to minimize the release of radioactive material and 

radiation exposure to plant personnel. Radioactive solid waste processing is performed in the 

onsite storage facility (OSSF) using a vendor-supplied system.

The Fermi 2 solid radioactive waste system has a portable solidification and dewatering system 

supplied and operated by a vendor. The types and quantities of waste to be processed are the 

same as those for the Fermi radioactive liquid radioactive waste system discussed above. The 

OSSF was specifically designed and constructed to contain and handle the waste processing 

systems. The basic design of the processing areas and the methods of system operation 

incorporate features to minimize radioactive exposure to plant personnel. Concrete floors and 

walls use a protective coating, and drains are routed back to the liquid radioactive waste 

system. The waste is transported in a shielded tunnel directly to the vendor’s processing 

equipment. A remote-operated overhead crane is available to move equipment onto or from 

trucks located in the facility’s truck bay. 

Radioactive liquid waste is either solidified or dewatered and placed into either a steel liner or a 

high-integrity container for transport to a licensed low-level radioactive disposal facility. 

Depending on the radiation levels, the steel liner or high-integrity container may be put into a 

shielded shipping cask to reduce the external radiation levels to minimize radiation exposure to 

workers and members of the public during transport.
Affected Environment

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Transportation of radioactive solid waste for further processing or disposal is performed in 

accordance with the NRC’s regulations at 10 CFR Part 71 and with the U.S. Department of 

Transportation’s regulations at 49 CFR 171–178. In 2014, 47 shipments were made from 

Fermi 2 to treatment facilities for processing and disposal. The radioactive waste was sent to 

two locations in 2014: (1) the EnergySolutions facility in Clive, Utah, and (2) the 

EnergySolutions processing facility in Oak Ridge, Tennessee, where the waste is further 

processed before disposal. The total volume and radioactivity of LLW shipped offsite in 2014

was 1.51x103 m3 (5.33x104 cubic feet (ft3

) and 8.98x102 curies (3.32x107 megabecquerels), 

respectively (DTE 2015b). Radioactive waste can also be shipped to the Waste Control 

Specialist facility in Andrews, Texas, as needed; however, no shipments were made to the 

Waste Control Specialist facility in 2014. Routine plant operation, refueling outages, and 

maintenance activities that generate radioactive solid waste will continue during the license 

renewal term. Radioactive solid waste is expected to be generated and shipped off site for 

disposal during the license renewal term.

3.1.4.4 Radioactive Waste Storage

LLW is stored temporarily on site in restricted areas until it can be shipped off site for disposal at 

a licensed LLW disposal facility.

LLW is classified as Class A, Class B, Class C, or greater than Class C. Class A includes both 

dry active waste and processed waste (e.g., dewatered resins). Classes B and C normally 

include processed waste and irradiated hardware. The majority of LLW generated at Fermi 2 is 

Class A waste. It can be shipped to licensed processors for volume reduction and repackaging, 

or it can be shipped from Fermi 2 directly to a licensed LLW disposal facility. Classes B and C 

wastes constitute a low percentage by volume of the total LLW generated and are stored at 

Fermi 2. The Waste Control Specialist facility in Andrews, Texas, is licensed by the State of 

Texas for disposal of Classes A, B, and C wastes; therefore, this facility could be used for 

disposal of Fermi 2 Class B and Class C wastes as needed. Disposal of greater than Class C 

waste is the responsibility of the Federal Government (DTE 2014d).

Fermi 2 uses the OSSF for holding LLW. It provides interim storage capacity for the amount of 

waste estimated to be generated during a 5-year period of plant operation. The storage 

capacity allows Fermi 2 to continue operating in the event that LLW disposal facilities may be 

temporarily unavailable. Under normal conditions, a portion of the storage facility is used as a 

staging area to load the LLW onto transport vehicles.

Fermi 2 has developed long-term plans to ensure that LLW generated during the license 

renewal term would be sent directly for disposal, stored on site in existing structures, or shipped 

to an offsite licensed facility for processing and disposal. Fermi 2 expects that there will be 

adequate LLW processing and storage capacity so that construction of additional LLW storage 

facilities will not be needed (DTE 2014d).

Fermi 2 stores its spent nuclear fuel in a spent fuel pool and on an ISFSI storage pad. An ISFSI 

is used to safely store spent fuel in licensed and approved dry cask storage containers on site. 

The installation and monitoring of an ISFSI is governed by NRC requirements in

10 CFR Part 72, “Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, 

High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste.” 

The Fermi 2 ISFSI storage pad is a 141-ft- x 141-ft- (43-m- x 43-m)-square reinforced concrete 

structure that is 2 ft (0.6 m) thick. The pad is designed to accommodate 64 dry storage casks. 

Additionally, the area to the north of the pad has been prepared for possible future expansion of 

the pad to allow up to an additional 32 dry storage casks (DTE 2014d).
Affected Environment

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3.1.4.5 Radiological Environmental Monitoring Program

DTE conducts an REMP to assess the radiological impact, if any, to the public and the 

environment from the operations at the Fermi site.

The REMP measures the aquatic, terrestrial, and atmospheric environment for radioactivity, as 

well as the ambient radiation, by sampling air, water, milk, leafy vegetables, fish, and sediment. 

In addition, the REMP measures background radiation (i.e., cosmic sources; global fallout; and 

naturally occurring radioactive material, including radon). The radiation detection devices and 

analysis methods used to determine the radioactivity in environmental samples are very 

sensitive to small amounts of radioactivity (DTE 2015b).

The Fermi 2 REMP is designed to perform the following:

• Analyze atmospheric and liquid pathways for anticipated types and quantities of 

radioactive effluents released from Fermi 2.

• Assess the potential buildup of long-lived radionuclides in the environment and 

identify physical and biological accumulations that may contribute to human 

exposures.

• Consider the potential radiation exposure to plant and animal life in the environment 

surrounding Fermi 2.

• Correlate levels of radiation and radioactivity in the environment with radioactive 

effluent releases from Fermi 2.

The Fermi 2 REMP was established in 1978 before the station became operational to provide

data on background radiation and radioactivity normally present in the airborne, direct radiation,

waterborne, and ingestion pathways. 

The REMP includes sampling indicator and control locations. The REMP uses indicator 

locations near the site to show any increases or buildup of radioactivity that might occur due to 

station operation and control locations farther away from the site to indicate the presence of

naturally occurring radioactivity. Fermi 2 personnel compare indicator results with control and

preoperational results to assess any impact that Fermi 2 operations may have had on the

surrounding environment (DTE 2014d).

In addition to the REMP, Fermi 2 has an onsite groundwater protection program designed to 

monitor the onsite plant environment to improve the management and response to instances in 

which the inadvertent release of radioactive material may result in detectable levels of 

plant-related radioactive material in subsurface soils and water (DTE 2014d). Section 3.5.2 of 

this SEIS contains information on the groundwater protection program.

The NRC staff reviewed 5 years of annual radiological environmental monitoring data: 2010 

through 2014 (DECo 2011d, 2012c, 2013b; DTE 2014e, 2015b). A 5-year period provides a 

data set that covers a broad range of activities that occur at a nuclear power plant, such as 

refueling outages, routine operation, and maintenance activities, that can affect the generation 

and release of radioactive effluents into the environment. The NRC staff looked for indication of 

adverse trends (i.e., buildup of radioactivity levels) over the period of 2010 through 2014.

The NRC staff’s review of the DTE’s data showed no indication of an adverse trend in 

radioactivity levels in the environment. The data showed that there was no measurable impact 

to the environment from operations at Fermi 2.
Affected Environment

3-18

3.1.5 Nonradioactive Waste Management Systems

Like any other industrial facility, nuclear power plants generate wastes that are not 

contaminated with either radionuclides or hazardous chemicals. These wastes include trash, 

paper, wood, and sewage (NRC 2013b). 

Fermi 2 has a nonradioactive waste management program to handle its nonradioactive 

hazardous and nonhazardous wastes. The waste is collected in central collection areas within 

the Fermi site and managed in accordance with DTE’s procedures. The materials are received 

in various forms and packaged to meet regulatory requirements before their final disposition at 

an offsite facility licensed to receive and manage the waste. The following list summarizes the 

types of waste materials generated and managed at Fermi 2:

• Fermi 2 is classified as a small quantity hazardous waste generator. The amounts of 

hazardous wastes generated are only a small percentage of the total wastes 

generated. These wastes consist of paints and paint-related materials; spent, 

off-specification, and shelf-life expired chemicals; laboratory chemical wastes; and 

occasional project-specific wastes. Fermi 2 has processes in place to transfer 

hazardous waste to licensed offsite treatment and disposal facilities (DTE 2014d).

• Fermi 2’s nonhazardous wastes include used oil and ethylene glycol. Universal 

wastes, such as batteries, mercury-containing lamps, and other potential wastes, 

such as oils, scrap metal, aluminum cans, plastic bottles, cardboard, and paper, are 

recycled when possible in accordance with DTE’s procedures (DTE 2014d). General 

plant trash is collected in dumpsters and transported to a State-licensed regional 

landfill permitted to accept solid wastes.

• Low-level mixed waste (LLMW) is waste that contains a low-level radioactive 

component regulated under the Atomic Energy Act of 1954, as amended (AEA) 

(42 U.S.C. 2011 et seq.), and a hazardous component regulated under the Resource 

Conservation and Recovery Act of 1976, as amended (RCRA) 

(42 U.S.C. 6901 et seq.). The State of Michigan regulates the hazardous component 

of the mixed waste through RCRA, and the NRC regulates the radioactive 

component through the AEA. Mixed wastes generated at Fermi 2 may consist of 

paint debris, oil laboratory waste, halogenated oil, grease, solvents, parts cleaner 

filters, and aerosol cans. These wastes are managed in accordance with Fermi 2’s 

waste management program to ensure compliance with applicable regulatory 

requirements and good practices. Once the wastes are moved to the OSSF, they 

are managed in accordance with Fermi 2’s LLMW management procedure, which 

prescribes the storage and disposal requirements. Fermi 2 operates under the 

conditional exemption for LLMW storage and disposal per Michigan Administrative 

Code (MAC) R299.9822 (MI 2014). Liquid LLMW is transported to Diversified 

Scientific Services, Inc., in Kingston, Tennessee, which is licensed to accept and 

manage the wastes. Solid and semi-solid LLMW is stored at the OSSF and has not 

been shipped offsite for disposal.

• DTE transfers domestic sewage to the City of Monroe wastewater collection system 

for treatment. Effluent discharge is regulated under the pretreatment effluent 

limitations and other conditions specified in the Fermi 2 discharge permit 

(DTE 2014d).
Affected Environment

3-19

3.1.6 Utility and Transportation Infrastructure

The utility and transportation infrastructure at nuclear power plants typically interfaces with 

public infrastructure systems available in the region. Such infrastructure includes utilities, such 

as suppliers of electricity, fuel, and water, and roads and railroads that provide access to the 

site. The following sections briefly describe the existing utility and transportation infrastructure 

at Fermi 2.

3.1.6.1 Electricity

Fermi 2 uses electricity supplied by other independent power plants to operate. Six 

transmission lines provide offsite power to Fermi 2 from the grid, as needed. DTE owns three of 

these lines, which extend approximately 640 ft (200 m) from the 345-kV switchyard to Fermi 2 

Division II systems. The International Transmission Company (ITC Transmission) owns the 

remaining three lines, which extend approximately 1,550 ft (474 m) from the 345-kV switchyard 

to the Fermi 2 circulating water pump house. Additionally, three underground 13.2-kV medium 

voltage cables provide offsite power to Fermi 2 Division I systems, the GSW pump house, and 

the cooling tower circulating water pumps. DTE also maintains four emergency diesel 

generators as a standby power source (DTE 2014d).

3.1.6.2 Fuel

Two underground fiberglass storage tanks—one 8,000-gal (30,000-L) gasoline tank and one 

6,000-gal (23,000-L) diesel fuel tank—provide fuel for onsite vehicles (DTE 2014d). DTE also 

maintains a number of nonnuclear fuels on site to operate emergency generators, auxiliary 

boilers for heating the plant, and peaker units (DTE 2014g). Table 3–1 lists and describes these 

fuel storage units. Additionally, some building heat is generated from propane (DTE 2014g). 

Section 3.1.4 discusses nuclear fuel and radioactive waste systems.

Fermi 2 Nonnuclear Fuel Storage Units

Storage Unit

Fuel 

Type Location

Capacity

(in gal)(a)

Combustion Turbine Generator 

Diesel Storage Tank

Diesel Southwest of Fermi 1 site adjacent 

to South Lagoon

845,970

Temporary Diesel Generator Diesel 

Storage Tank

Diesel North side of peaker yard, east of 

enclosure

1,000

Emergency Diesel Generator (EDG) 

Fuel Oil Tank

Diesel In RHR complex 168,00 total

(4 tanks)

EDG Diesel Storage Tanks Diesel In RHR complex 2,200 total

(4 tanks)

Auxiliary Boiler Fuel Oil Tank Diesel North of auxiliary boiler house 159,000

Fermi 2 Diesel Fire Pump Oil Tank Diesel North exterior side of the GSW 

pump house

275

Nuclear Operations Center 

Emergency Diesel Storage Tank

Diesel South side of Nuclear Operations 

Center building (west of back 

entrance)

500

Security EDG Diesel Storage Tanks Diesel North and south side of reactor

building

1,000 total 

(2 tanks)

Liquid Propane Gas Propane Various locations outside the 

protected area

Currently 13,000 

(15 tanks)

(a) To convert U.S. gallons to liters, divide gallons by 0.26417.

Source: DTE 2014g
Affected Environment

3-20

3.1.6.3 Water

The Frenchtown Township water system supplies the Fermi site with potable water for the 

demineralized water makeup system; sanitary plumbing; drinking fountains; washrooms; kitchen 

facilities; safety showers; and heating, ventilation, and air conditioning evaporative coolers in the 

turbine building. Potable water coming into the site flows into a 100,000-gal (380,000-L) 

elevated storage tank, and underground piping distributes water from the tank to the various 

onsite facilities (DTE 2014d). Section 3.1.3 describes the Fermi 2 cooling and auxiliary water 

systems.

3.1.6.4 Transportation Systems

Enrico Fermi Drive serves as the main entrance to the Fermi site. Enrico Fermi Drive connects 

to North Dixie Highway, which links the site to local communities north and south and to many 

other key local and regional highways. Interstate 75 (I-75) lies 2 mi (1.2 km) west of the Fermi 

site and is the closest interstate access point to the site (DTE 2014d). Section 3.10.6 describes 

local transportation systems, including roadway access, in more detail.

Three major railway systems provide service near the Fermi site: (1) Canadian National 

Railway, (2) CSX Transportation, Inc., and (3) Norfolk Southern Corporation (DTE 2014d). The 

Canadian National Railway maintains one active railroad spur off of its main line that traverses 

the Fermi site in a west-east direction parallel to Enrico Fermi Drive (DECo 2011b). 

DTE (2014d) transports large and heavy equipment to and from the site via this rail spur.

The Great Lakes St. Lawrence Seaway System is a deep draft waterway that extends 2,340 mi 

(3,700 km) from the Atlantic Ocean to the head of the Great Lakes and into mid-Lake Erie 

(SLSMC 2014). Most barge traffic in the vicinity of the Fermi site travels to and from the Ports 

of Toledo, Detroit, and Monroe. A former barge slip, which was used to offload equipment 

during Fermi 2 construction, lies in the northeast corner of the site near the cooling towers 

(DECo 2011b). The barge slip is no longer operational, but Fermi 3, if constructed by the 

applicant, would include the construction of a new barge slip east of the 120-kV switchyard 

(DECo 2011b). The Fermi 3 barge slip would remain on the site during the proposed Fermi 2

license renewal term.

The Wayne County Airport Authority operates the Detroit Metropolitan Wayne County Airport 

and the Willow Run Airport, which are located 19 mi (31 km) north and 7 mi (11 km) west of the 

Fermi site, respectively. Detroit Metropolitan Wayne County Airport is the largest commercial 

airport in the region, and Willow Run Airport is the largest cargo airport in the region. Several 

other smaller cargo, passenger, and private airports lie in the vicinity of the Fermi site 

(NRC 2013a).

3.1.6.5 Power Transmission Systems

ITC Transmission owns and operates the transmission system in Southeastern Michigan, 

including a 120-kV switchyard and a 345-kV switchyard on the Fermi site and the lines 

extending from these switchyards that connect to the regional electric grid. The 120-kV 

switchyard was originally built to service the decommissioned Fermi 1; it now services four 

diesel fuel-fired turbine generators and provides power to the Fermi 2 Division I systems. The 

345-kV switchyard transfers electricity generated by Fermi 2 into a regional grid and transfers 

offsite power onto the site for station use (DECo 2011b; DTE 2014d).

For license renewal, the NRC (2013b) evaluates those transmission lines that connect the 

nuclear power plant to the substation where electricity is fed into the regional power distribution 

system and transmission lines that supply power to the nuclear plant from the grid. 
Affected Environment

3-21

DTE (2014d) has determined that the following transmission lines are in-scope for the license 

renewal environmental review:

• Six transmission lines that transmit electricity from Fermi 2 to the electrical grid. 

These lines extend from the Fermi 2 turbine building, combine into three lines 

through a common bus, and terminate at the 345-kV switchyard. The total length of 

the lines is 640 ft (195 m).

• Six transmission lines that provide offsite power to Fermi 2. Three lines extend 

approximately 640 ft (195 m) from the 345-kV switchyard to the plant and provide 

offsite power to the Fermi 2 Division II systems. The remaining three lines extend 

approximately 1,550 ft (472 m) from the 345-kV switchyard to the Fermi 2 circulating 

water pump house.

All of the in-scope transmission lines lie within the owner-controlled and industrial use area of 

the site. Figure 3–6 depicts the in-scope transmission lines.

The out-of-scope portions of the transmission lines (those that would stay in service regardless 

of Fermi 2 license renewal) extend from the 345-kV switchyard west to the Fermi site perimeter 

fences. An associated transmission line corridor traverses the site, and DTE and the U.S. Fish 

and Wildlife Service (FWS) have collaboratively restored a small area near the west property 

boundary to native prairie (discussed in Section 3.6). The lines continue from the site boundary 

about 5 mi (8 km) to a point west of I-75 where the lines turn north and run adjacent to I-75 for 

about 12 mi (19 km) before terminating at the Brownstown Substation in Woodhaven, Michigan

(DECo 2011b).
3-22

Figure 3–6. Fermi 2 In-Scope Transmission Lines

Source: DTE 2014d, Figure 2.2–7
Affected Environment

3-23

3.1.7 Nuclear Power Plant Operations and Maintenance

Maintenance activities conducted at Fermi 2 include inspection, testing, and surveillance to 

maintain the current licensing basis of the facility and to ensure compliance with environmental 

and safety requirements. Various programs and activities are currently in place at Fermi 2 to 

maintain, inspect, and monitor the performance of facility structures, components, and systems. 

These activities include in-service inspections of safety-related structures, systems, and 

components, quality assurance and fire protection programs, and radioactive and 

nonradioactive water chemistry monitoring. 

Additional programs include those implemented to meet technical specification surveillance 

requirements and those implemented in response to NRC generic communications and include 

various periodic maintenance, testing, and inspection procedures necessary to manage the 

effects of aging on structures and components. Certain program activities are performed during 

the operation of the units, whereas others are performed during scheduled refueling outages 

(DTE 2014d). Reactor refueling occurs on an 18-month cycle (DTE 2014d).

3.2 Land Use and Visual Resources

3.2.1 Land Use

3.2.1.1 Onsite Land Use

The Fermi site encompasses approximately 1,260 ac (510 ha) in Frenchtown Township, Monroe 

County, Michigan. The site lies on the west bank of Lake Erie approximately 30 mi (48 km) 

southwest of Detroit, Michigan; about 24 mi (39 km) northeast of Toledo, Ohio; and 7 mi (11 km) 

east of the United States-Canada border, which runs through Lake Erie (NRC 2013a).

The site is bounded on the north by Swan Creek, on the east by Lake Erie, on the south by 

Pointe Aux Peaux Road, and on the west by a private road owned by DTE. Large lagoons 

dominate the northern and southern areas of the site, whereas the western side of the site 

includes several wood lots and a series of small quarry lakes. Site elevation ranges from lake 

level on the eastern edge of the site to approximately 25 ft (7.6 m) above lake level on the 

western edge of the site (DTE 2014f).

Land on the Fermi site is designated as “industrial” by Monroe County and is zoned as “public 

service” by Frenchtown Township. Future land use maps produced by both planning agencies 

indicate that these uses will continue on the Fermi 2 property (Anulewicz and McKenna 2003; 

MCPDC 2010). Table 3–2 lists, and Figure 3–7 depicts, site land uses.

Fermi Site Land Uses by Area

Land Use

Area

(in acres) Percent

Developed Areas 212 16.8

 Decommissioned Fermi 1 6.7 0.5

 Fermi 2 plus associated support 

facilities

205.3 16.3

 Fermi 3 0(a) 0.0

Coastal Emergent Wetland 273 21.7

Forest 256 20.3

 Coastal shoreline 47 3.7
Affected Environment

3-24

Land Use

Area

(in acres) Percent

 Lowland hardwood 92 7.3

 Woodlot 117 9.3

Water 215 17.1

 Lakes, ponds, rivers 44 3.5

 Lake Erie 171 13.6

Grassland 168 13.3

 Row crops 64 5.1

 Idle/old field/planted 75 5.9

 Right-of-way 29 2.3

Shrubland 113 9.0

Thicket 23 1.8

Total 1,260 100.0

(a) At this time, no land has been committed to the proposed Fermi 3. However, 

if Fermi 3 is built, 301 ac (122 ha) would be required, and 112 ac (45 ha) of 

the 301 ac (122 ha) would have been land that was previously disturbed 

during Fermi 1 or 2 construction (DTE 2014g).

Sources: NRC 2013a; DECo 2011b; DTE 2014d, 2014g
Affected Environment

3-25

Figure 3–7. Fermi Site Land Uses

Source: DECo 2011b, Figure 2–10
Affected Environment

3-26

Developed Areas

Approximately 212 ac (86 ha) of the site are developed and in industrial use. In addition to the 

Fermi 2 facilities described in Section 3.1.1, Fermi 1, an experimental sodium-cooled breeder 

reactor that operated from 1963 through 1972, also lies on the site. Fermi 1 is permanently shut 

down and in safe storage status with a possession-only license that expires in 2025 

(DTE 2014b). At a future date, decommissioning activities will continue to remove the 

remaining radioactive material associated with Fermi 1 and to terminate the Fermi 1 license 

(DTE 2014b).

Fermi 3, a proposed economic simplified boiling water reactor, for which the NRC approved a 

combined license (COL) application on May 1, 2015 (NRC 2015), would also be contained 

within the footprint of the existing site if constructed by the applicant. Fermi 3 would share some 

facilities with Fermi 2, including office buildings, potable water supply, and sanitary discharge 

structures. Fermi 3 would require the construction of a new reactor building, an additional 

cooling water intake, a new natural draft cooling tower, an underwater discharge pipe, a 

switchyard, transmission lines, and other buildings and facilities that would directly support 

power generation (NRC 2013a). Construction would disturb an estimated 301 ac (122 ha); 

154 ac (62 ha) of those acres would be permanently occupied (NRC 2013a). Approximately 

189 ac (77 ha) of the land that would be disturbed is currently undeveloped. The NRC (2013a) 

considered the environmental impact of construction and operation of Fermi 3 in NUREG–2105, 

“Environmental Impact Statement for the Combined License (COL) for Enrico Fermi Unit 3,” and 

Section 4.16 of this SEIS considers contributions from the cumulative impacts of Fermi 3 during 

the proposed license renewal period.

The site also includes transmission lines, a railroad spur that connects to the Canadian National 

main line, and a former barge slip—all of which are discussed in Section 3.1.6. Figure 3–3

depicts the site layout.

Natural Areas

The majority of the site (1,048 ac (424 ha) or 83.1 percent) consists of natural areas, including 

coastal emergent wetlands, forests, grasslands, shrublands, thickets, Lake Erie, and other 

various waterbodies (Table 3–2). The northern and southern portions of the site feature large 

lagoons, whereas the western portion includes coastal emergent wetlands and a series of 

quarry lakes (DTE 2014d; NRC 2013a). The quarry lakes formed when water filled abandoned 

rock quarries that were created to provide crushed limestone to raise the site elevation and 

prevent flooding during Fermi 2 construction (DECo 2011b). Small parcels of forested land 

occur in the northwestern and southwestern portions of the site and along the Lake Erie 

shoreline. Site elevation ranges from the Lake Erie water level to approximately 25 ft (7.6 m) 

above lake level (DECo 2011b). Sections 3.6 and 3.7 describe the terrestrial and aquatic 

resources, respectively, and provide more information on the site’s natural areas.

Detroit River International Wildlife Refuge

Since September 2003, DTE has maintained a cooperative agreement with the FWS to allow 

the FWS to manage 62.6 percent (656 ac (265 ha)) of the site’s natural areas as part of the 

Detroit River International Wildlife Refuge (DRIWR) (DECo 2011b; DECo and FWS 2003). 

Congress established the DRIWR in 2001, and it is the only international wildlife refuge in North 

America. The refuge includes islands, coastal wetlands, marshes, shoals, and waterfront lands 

along 48 mi (77 km) of the western Lake Erie shoreline and Detroit River (EPA 2009b). The 

DRIWR lands on the Fermi site constitute the refuge’s Lagoona Beach Unit (DTE 2014d) 

(Figure 3–8). The general public does not have access to the Lagoona Beach Unit 

(DECo 2011b). Section 3.6 discusses the DRIWR in more detail.
Affected Environment

3-27

Figure 3–8. Detroit River International Wildlife Refuge, 

Lagoona Beach Unit Boundaries on the Fermi Site

Source: DTE 2014d, Figure 3.6–1

Leased Cropland

DTE leases approximately 64 ac (26 ha) in the western-most portion of the site to private 

individuals for agricultural use (DECo 2011b). This land is typically planted with one crop—

either corn or soybeans—and harvested annually (DECo 2011b). Figure 3–7 depicts the area 

leased for cropland.

According to the Natural Resources Conservation Service’s (NRCS’s) maps (NRCS 1997), a 

portion of the leased cropland contains prime farmland. The U.S. Department of Agriculture 

(USDA) defines “prime farmland” as land that has the best combination of physical and 
Affected Environment

3-28

chemical characteristics for producing food, feed, forage, fiber, and oilseed crops and that is 

also available for these uses (USDA 1993). Although much of the Fermi site likely once 

qualified as prime farmland, DTE (2014d) indicates that construction- and operation-related 

disturbances would no longer qualify most areas on the site as potential prime farmland.

Mineral and Surface Rights

In Michigan, minerals can be owned by the surface property owner or by a different party. DTE 

owns and controls 99.93 percent of mineral rights within the Fermi site (DECo 2011b). In the far 

southeastern portion of the site, the Michigan Department of Natural Resources (MDNR) owns 

0.88 ac (0.36 ha) of mineral rights (DECo 2011b). DTE (2014d) indicates that presently there is 

no exploration or commercial mineral production on the Fermi site or on properties adjoining the 

site and that no such projects are anticipated to occur in the foreseeable future.

DTE (2014d) has acquired surface ownership of all land on the Fermi site and would maintain 

ownership during the proposed license renewal term.

Coastal Zone

The Fermi site lies within Michigan’s coastal zone (i.e., the coastal waters and the adjacent 

shore lands strongly influenced by one another, which may include islands, transitional and 

intertidal areas, salt marshes, wetlands, beaches, and Great Lakes waters). In 1972, Congress 

promulgated the Coastal Zone Management Act of 1972 (CZMA) (16 U.S.C. 1451 et seq.) to 

encourage and assist states and territories in developing management programs that preserve;

protect; develop; and, where possible, restore or enhance, the resources of the coastal zone. 

Individual states are responsible for developing a Federally approved Coastal Management 

Plan and implementing a coastal management program in accordance with such a plan. In 

Michigan, the Michigan Department of Environmental Quality (MDEQ) administers the coastal 

management program.

Section 307(c)(3)(A) of the CZMA requires that applicants for Federal permits whose proposed 

activities could reasonably affect coastal zones certify to the licensing agency (here, the NRC) 

that the proposed activity would be consistent with the state’s coastal management program. 

The regulations that implement the CZMA indicate that this requirement is applicable to renewal 

of Federal licenses for actions not previously reviewed by the state (15 CFR 930.51(b)(1)).

In a September 3, 2013, telephone conversation between the MDEQ and DTE, the MDEQ 

indicated that once DTE submits the license renewal application to the NRC, it should request a 

consistency determination review by formal letter. On October 29, 2013, DTE (2013a) sent the 

MDEQ a letter summarizing the September 3, 2013, telephone conversation. Subsequently, in 

a May 16, 2014, letter, DTE (2014g) submitted its request and a copy of the Fermi 2 license 

renewal application to the MDEQ. The MDEQ (2014b) responded in a letter dated 

July 28, 2014. In that letter, the MDEQ indicated that no adverse impacts to coastal resources 

are anticipated from the license renewal as long as all required permits are issued and that DTE 

complies with those permits. DTE (2014g) has indicated that all required permits for Fermi 2

have been issued and that DTE is in compliance with those permits. Accordingly, the proposed 

Fermi 2 license renewal is consistent with Michigan’s Coastal Management Program.

3.2.1.2 Offsite Land Use

Within a 6-mi (10-km) radius of the Fermi site, most lands are contained within Monroe County; 

however, the radius also includes a small area of land in Wayne County and a portion of 

Lake Erie within the State of Ohio. Lake Erie comprises the majority of the area within this 

radius (about 52.2 percent). Agriculture, which accounts for about 20.5 percent, is the largest 

land use. Developed land, including open space and low-intensity, medium-intensity, and 
Affected Environment

3-29

high-intensity developed categories, comprises 11.3 percent. Figure 3–9 illustrates land uses 

and land cover within 6 mi (10 km) of the Fermi site (DTE 2014d).

Monroe County is a predominantly agricultural County with two major residential areas (the City 

of Monroe and Bedford Township), other scattered small towns, forested areas, and wetlands 

(MCPDC 2010). The County encompasses 549.4 square miles (mi2

) (1,423 square 

kilometers (km2

)) (351,600 ac or 142,400 ha) (USCB 2014f), and according to the 2012 Census 

of Agriculture (USDA 2014b), 49.3 percent of land within Monroe County is farmland devoted to 

either crop or livestock production. This value is down from the Southeast Michigan Council of 

Government’s (SEMCOG’s) estimate of 54.2 percent in 2008 (SEMCOG 2014a). Monroe 

County’s major agricultural crops include corn, soybeans, wheat, vegetables, and forage, and 

major livestock commodities include laying hens, cattle, calves, horses, ponies, sheep, and 

lambs (USDA 2014b). The County’s land cover is predominantly characterized as open space 

(72 percent), which includes agricultural fields, grasslands, and turf grass (SEMCOG 2014a). 

The Monroe County Comprehensive Plan (MCPDC 2010) indicates that a substantial portion of 

the County is prime farmland. Table 3–3 and Table 3–4 summarize Monroe County’s land uses 

in 2008 and land cover in 2010, respectively.

Monroe County Land Use, 2008

Land Use

Area

(in acres) Percent

Agricultural 193,439 54.2

Residential 111,596 31.3

Commercial 8,398 2.4

Industrial 8,134 2.3

Governmental/Institutional 5,780 1.6

Park, recreation, and open space 10,066 2.8

Airport 316 0.1

Transportation, communication, and utility 14,036 3.9

Water 4,981 1.4

Total 356,746 100.0

Source: SEMCOG 2014a

Monroe County Land Cover, 2010

Type Description

Area

(in acres) Percent

Open Space agricultural fields, grasslands, turf grass 257,905 72.3

Trees woody vegetation, trees 66,784 18.7

Impervious buildings, roads, driveways, parking lots 21,486 6.0

Water rivers, lakes, drains, ponds 7,114 2.0

Bare soil, aggregate piles, unplanted fields 3,507 1.0

Total 356,797 100.0

Source: SEMCOG 2014a
Affected Environment

3-30

Figure 3–9. Land Use and Land Cover within a 6-mi (10-km) 

Radius of the Fermi Site

Source: DTE 2014d, Figure 3.1–2
Affected Environment

3-31

The Monroe County Comprehensive Plan (MCPDC 2010) anticipates that the County will 

experience a slight (8-percent) increase in population over the next 20 years. The County plans 

to manage its land resources in a manner that will discourage sprawl and encourage future 

development to occur in and around existing developed areas so that farmland, open spaces, 

and natural and cultural resources are preserved.

Several Federal lands, State wildlife areas, and parks occur in the vicinity of the Fermi site. In 

addition to the onsite DRIWR Lagoona Beach Unit, nine other DRIWR units lie to the north and 

south. The River Raisin National Battlefield Park lies 7 mi (11 km) southwest of the site. State 

lands within 10 mi (16 km) include Pointe Aux Peaux State Wildlife Area, Pointe Mouillee State 

Game Area, Pointe Mouillee Natural Area, Sterling State Park, Point Mouillee State Game Area 

Celeron Island Unit, and Bolles Harbor. Monroe County has five County parks, including Heck 

Park and Nike Park, which are located about 6 mi (10 km) from the Fermi site (DTE 2014d).

3.2.1.3 Land Use Planning

Three agencies are responsible for land use planning in the vicinity of the Fermi site. At the 

regional level, the SEMCOG is a regional planning partnership that assists County and local 

governments with regional transportation planning, housing and land use planning, economic 

development, and water and air quality matters (SEMCOG 2014b). At the County level, the 

Monroe County Planning Department and Commission (MCPDC) prepares and updates the 

Monroe County Comprehensive Plan; develops and maintains a central bank of planning 

information; reviews zoning amendments in unincorporated portions of the County; and 

coordinates with Federal and State agencies and other Counties on economic, social, and 

physical development matters (MCPDC 2009). Locally, Frenchtown Township maintains the 

township’s Master Plan and has zoning authority over the township’s land, including the Fermi 

site (Anulewicz and McKenna 2003).

3.2.2 Visual Resources

As described in the previous section, the Fermi site is located on the western shore of Lake Erie 

in a predominantly agricultural region. The site’s grade elevation is approximately 581.8 ft 

(177.3 m) (referenced to the North American Vertical Datum of 1988 (NAVD88)). The site 

includes Fermi 2 and the decommissioned Fermi 1. During the proposed license renewal term, 

the site could potentially contain an additional reactor (Fermi 3) within the footprint of the 

existing site if Fermi 3 is constructed by the applicant.

Fermi 2’s buildings have a natural concrete exterior and neutral gray color, which tends to 

minimize visual impact. Two 450-ft (140-m) diameter concrete natural draft cooling towers rise 

approximately 400 ft (120 m) above grade elevation. The cooling towers are the tallest, most 

predominant features of the site and are visible from outside the property boundary. The 

transmission lines associated with Fermi 2 and that are considered within the scope of the 

license renewal review lie within the developed area of the site (DTE 2014d).

Because the land surrounding Fermi 2 is primarily agricultural, the areas most likely to 

experience visual impacts would be adjacent residents and traffic associated with the Dixie 

Highway and smaller arterial roads. Depending on air and weather conditions, the cooling 

towers may also be seen from I-75 and I-275 and in Sterling State Park and the Pointe Mouillee

State Game Area (DTE 2014d).
Affected Environment

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3.3 Meteorology, Air Quality, and Noise

3.3.1 Meteorology and Climatology

Fermi 2 is located within the Lower Michigan Peninsula, with Lake Michigan to the west and 

Lake Huron, St. Clair, and Erie to the east. The regional climate is characterized as a 

quasi-marine type (NCDC undated). Latitude, the Great Lakes, and elevation play a major role 

in controlling Michigan’s climate. The Lower Peninsula topography varies from level terrain in 

the southeast to gently rolling hills with elevations of 800 to 1,000 ft (240 to 305 m) in the 

southwest. Because of Michigan’s mid-latitude location, prevailing winds are from a westerly 

direction. During the summer months, prevailing winds are influenced by the position of the 

semi-permanent high-pressure system, known as the Bermuda high, located in the 

southeastern region of the United States resulting in winds predominantly from the southwest. 

Michigan is influenced by the temperature moderating effects of the Great Lakes, which results 

in late arrivals of summer and winter, cooler spring temperatures, and warmer fall temperatures. 

Proximity to the Great Lakes also results in localized wind patterns in the summer; during the 

day, the warmer air over the land rises and cooler air over the lakes moves inland, and at night 

this pattern is reversed. Annual precipitation in Michigan is approximately 31 in. (79 cm) with 

summer precipitation in the form of showers and thunderstorms and winter precipitation, 

including a combination of snow, rain, freezing rain, and sleet. 

The NRC staff obtained climatological information with 30-year averages from the Detroit 

Wayne County Airport (DWCA) weather station; this station is approximately 18 mi (28.9 km) 

north-northwest of the Fermi site and is used to characterize the region’s climate because of its 

nearby location and long period of record. Additionally, DTE maintains a meteorological tower 

that consists of 10- and 60-m sensors that measure wind speed and direction, dew point, 

temperature, and precipitation. Recent meteorological observations from the Fermi site were 

made available to the NRC staff; these data were evaluated in context of the longer 

climatological record from the DWCA’s weather station.

The prevailing wind direction at the DWCA’s weather station is from the southwest during most 

of the year, except during the spring months (March, April, and May) when it is from the 

northwest (NCDC 2013). Mean annual wind speed is 9.6 miles per hour (mph) (15 kilometers 

per hour (kph), and mean monthly wind speed ranges from 7.5 mph (12 kph) in August to 

11.2 mph (18 kph) in January. Annual wind rose data from the meteorological tower at Fermi 2 

displays a prevailing wind direction from the southwest and a mean annual wind speed of 

6.92 knots (8 mph (13 kph)) during the 2008–2012 period (DTE 2014d).

The mean annual temperature for the period of record (1984–2013) at the DWCA’s station is 

50.3 °F (10.1 °C) with a mean monthly temperature ranging from a low of 25.9 °F (-3.4°C) in 

January to a high of 73.9 °F (23.3 °C) in July (NCDC 2013). The hottest year over the period of 

record was in 2012, and the coolest was in 1989. Recent (2009–2013) temperature 

observations at Fermi 2 are consistent with these values; mean annual temperature taken at 

Fermi 2’s meteorological tower for the identified timeframe is 48.6 °F (9.2 °C), with a mean 

monthly temperature ranging from a low of 23.1 °F (-4.9 °C) in January to a high of 72.8 °F 

(22.7 °C) in July (DTE 2014g). 

Mean annual liquid precipitation measured at the DWCA’s weather station is 33.73 in. 

(85.7 cm). The wettest year for the period of record is 47.70 in. (121 cm) in 2012 (NCDC 2013); 

the driest year from the same period is 26.27 in. (66.7 cm) in 1984 (NCDC 2013). Monthly 

precipitation amounts tend to be evenly distributed throughout the year and range from an 

average of 2.01 in. (5.1 cm) in January to 3.43 in. (8.7 cm) in July (NCDC 2013). Mean total 

annual precipitation measurements taken at Fermi 2’s meteorological tower for the 2009–2013 
Affected Environment

3-33

period is 51.68 in. (131 cm) (DTE 2014g). Snowfalls are common in the region; average annual 

snowfall at the DWCA’s weather station is 44.7 in. (113.5 cm) (NCDC 2013), with a maximum 

monthly snowfall of 31.7 in. (80.5 cm) recorded in February 2010.

Monroe County, where Fermi 2 is located, experiences severe weather events, such as hail, 

tornadoes, floods, and heavy snow. In the past 64 years (1950–2014), the following number of 

days with severe events has been reported in Monroe County (NCDC 2014): 

• Hail—56 days,

• Tornadoes—24 days,

• Blizzard—1 day, and

• Floods—12 days.

The tornadoes identified above varied in intensity between F0–F4 and EF0–EF2 on the Fujita 

scale.9F

7 On June 6, 2010, an EF2 tornado with maximum sustained winds of 130 to 135 mph

(209 to 217 kph) moved through Monroe County (NCDC 2014). As a result of the tornado, a 

partial loss of offsite power at Fermi 2 occurred, and the licensee declared an Unusual Event, 

the lowest of the NRC’s four emergency level classifications. The reactor was shut down and 

put into a stable condition (NRC 2010). There were no radiological releases from this event and 

power was restored to the site (NRC 2010).

3.3.2 Air Quality

Under the Clean Air Act of 1970, as amended (CAA) (42 U.S.C. 7410), EPA has set primary 

and secondary National Ambient Air Quality Standards (NAAQS) (40 CFR Part 50) for six 

common criteria pollutants to protect sensitive populations and the environment. The NAAQS 

criteria pollutants include carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO2), ozone (O3), 

sulfur dioxide (SO2), and particulate matter (PM). Particulate matter is further categorized by 

size—PM10 (diameter between 2.5 and 10 micrometers (μm) and PM2.5 (diameter of 2.5 μm or 

less).

The EPA designates areas of “attainment” and “nonattainment” with respect to the NAAQS. 

Areas that have insufficient data to determine designation status are denoted as 

“unclassifiable.” Areas that were once in “nonattainment,” but are now in “attainment,” are 

called “maintenance” areas; these areas are under a 10-year monitoring plan to maintain the 

attainment designation status. States have primary responsibility for ensuring attainment and 

maintenance of the NAAQS. Under Section 110 of the CAA and related provisions, states are 

to submit, for EPA approval, State Implementation Plans that provide for the timely attainment 

and maintenance of the NAAQS. 

Air quality designations generally are made at the county level. For the purpose of planning and 

maintaining ambient air quality with respect to the NAAQS, EPA has developed Air Quality 

Control Regions (AQCRs). The AQCRs are intrastate or interstate areas that share a common 

airshed (40 CFR Part 81). Monroe County, Michigan, where Fermi 2 is located, along with two 

Counties (Lucas and Wood County) in the State of Ohio are part of the Metropolitan Toledo 

Interstate AQCR (40 CFR 81.43). With regard to the NAAQS criteria pollutants, Monroe County 

is designated a maintenance area for the 8-hour ozone 1997 standard and for the PM2.5 1997 

 7 The original Fujita six-point scale (F0 to F5) was used to rate the intensity of a tornado based on the damage it 

inflicts to structures and vegetation from the lowest intensity, F0, to the highest, F5. In February 2007, the 

enhanced Fujita scale replaced the original Fujita scale. The enhanced Fujita scale still uses six categories of 

tornado intensity (EF0 to EF5), but the new scale more accurately matches wind speeds to the severity of damage 

caused by the tornado.
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and 2006 standard (EPA 2014a). The currently designated nonattainment or maintenance 

Counties adjacent to the Fermi site (within a 50-mi (80-km) radius of the Fermi site) are as 

follows: 

• Wayne County, Michigan: nonattainment for sulfur dioxide (2010 standard), 

maintenance area for 8-hr ozone (1997), particulate matter less than 2.5 μm in 

diameter (1997 and 2006 standard), and carbon monoxide;

• Washtenaw County, Michigan: maintenance area for 8-hr ozone (1997 standard) 

and particulate matter less than 2.5 μm in diameter (1997 and 2006 standard);

• Oakland County, Michigan: maintenance area for particulate matter less than 

2.5 μm in diameter (1997 and 2006 standard), carbon monoxide, and 8-hr ozone 

(1997 standard);

• Macomb County, Michigan: maintenance area for particulate matter less than 

2.5 μm in diameter (1997 and 2006 standard), carbon monoxide, and 8-hr ozone 

(1997 standard);

• Livingston County, Michigan: maintenance area for particulate matter less than 

2.5 μm in diameter (1997 and 2006 standard) and 8-hr ozone (1997 standard);

• Lenawee County, Michigan: maintenance area for 8-hr ozone (1997 standard);

• Lucas County, Ohio: maintenance area for 8-hr ozone (1997 standard) and sulfur 

dioxide (1971 standard); and

• Wood County, Ohio: maintenance area for 8-hr ozone.

Michigan air pollution control rules are issued under Act 451, Natural Resources and 

Environmental Protection Act (NREPA), Part 55, “Air Pollution Control” 

(451 MCL 324.5501-5542). DTE maintains a Renewable Operating Permit (Permit 

No. MI-ROP-B4321-2013) issued by the MDEQ for sources of air emissions at Fermi 2. 

Michigan’s Renewable Operating Permit (ROP) program consolidates all Federal and State 

requirements intended to protect air quality into a single permit/document. The ROP folds in 

Fermi 2’s permit to install, which includes legally enforceable limits designed specifically to limit 

air emissions from the permitted sources identified in the permit, commonly known as a 

synthetic minor air permit.10F

8 Fermi 2’s ROP became effective on November 1, 2013, and must 

be renewed every 5 years. Fermi 2’s ROP identifies monitoring, reporting, and emission limit 

requirements (DTE 2014g). For instance, DTE is required to submit annual reports to the 

MDEQ that include an emissions inventory, known as the Michigan Air Emissions Reporting 

System.

Permitted sources at Fermi 2 include combustion turbines (peakers), auxiliary boilers, diesel 

driven fire pump, diesel generators, and cold (degreaser) cleaner units. Emissions provided in 

Table 3–5 are associated with infrequent use of permitted sources during testing or outages. 

Combustion turbines (peakers) are intermittently used to provide additional electricity to the 

power grid when needed during peak demand periods (MDEQ 2013b). R 336.1280 (Rule 280) 

of the MAC rules for air pollution control exempts water cooling towers from the MDEQ’s air 

permitting requirements. However, annual particulate matter emissions of less than 10 μm 

associated with each tower is estimated to be 0.10 tons per year (DTE 2014d, 2014g). The 

NRC staff reviewed the five most recent Michigan Air Emissions Reporting System reports 

submitted to the MDEQ by DTE (DTE 2014g). Fermi 2 has been in compliance with the 

 8 A synthetic minor source has the potential to emit air pollutants in quantities at or above the major source 

threshold levels but has accepted enforceable limitations to keep the emissions below such levels. 
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requirements set forth in the air permit, and there are no reported violations in the last 5 years 

(EPA 2014a; DTE 2014g). Section 4.15.3 discusses greenhouse gas emissions resulting from 

operation of Fermi 2.

Air Emission Estimates for Permitted Combustion Sources at Fermi 2

Year CO (T) NOx (T) PM10 (T) SOx (T) VOCs (T) HAPs (T)

2008 3.27 21.62 0.82 1.34 0.24 .0056

2009 2.43 34.37 0.92 1.84 0.16 .0112

2010 4.25 46.39 1.47 1.27 0.26 .0144

2011 2.70 44.85 1.01 0.47 0.20 .0113

2012 2.83 21.40 0.65 0.07 0.24 .0017

Key: CO = carbon monoxide; MT = metric ton; NOx = nitrogen oxides; PM10 = particulate matter less than 10 μm; 

SOx = sulfur oxides; T = ton; VOCs = volatile organic compounds; and HAPs = hazardous air pollutants.

To convert T to MT, multiply by 0.9072.

Source: DTE 2014d

EPA issued the Regional Haze Rule to improve and protect visibility in national parks and 

wilderness areas from haze, which is caused by numerous, diverse sources located across a 

broad region (40 CFR 51.308–309). Specifically, 40 CFR 81 Subpart D lists mandatory Class I 

Federal Areas where visibility is an important value. The Regional Haze Rule requires states to 

develop State Implementation Plans to reduce visibility impairment at Class I Federal areas. 

The nearest Class I Federal area for visibility protection is the Otter Creek Wilderness, which is 

about 269 mi (432.9 km) from the Fermi site. The EPA recommends that emission sources 

located within 62 mi (100 km) of a Class I area be modeled to consider adverse impacts 

(EPA 1992). Considering the distance to the nearest Class I area and the minor nature of air 

emissions from the site, there is little likelihood that ongoing activities at the Fermi site adversely 

affect air quality and air quality-related values (e.g., visibility or acid deposition) in any of the 

Class I areas.

3.3.3 Noise

Noise is unwanted sound and can be generated by many sources. Sound intensity is measured 

in logarithmic units called decibels (dB). A dB is the ratio of the measured sound pressure level 

to a reference level equal to a normal person’s threshold of hearing. Most people barely notice 

a difference of 3 dB or less. Another characteristic of sound is frequency or pitch. Noise may 

be composed of many frequencies, but the human ear does not hear very low or very high 

frequencies. To represent noise as closely as possible to the noise levels people experience, 

sounds are measured using a frequency-weighting scheme known as the A-scale. Sound levels 

measured on this A-scale are given in units of A-weighted decibels (dBA). Table 3–6 presents 

common noise sources and their respective noise levels. Noise levels can become annoying at 

80 dBA and very annoying at 90 dBA. To the human ear, each increase of 10 dBA sounds

twice as loud (EPA 1981).
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Common Noise Sources and Noise Levels

Noise Source Noise Level (dBA)

Human hearing threshold 0

Soft whisper 30

Quiet residential area 40

Dishwasher 55–70

Lawn mower 65–95

Blender 80–90

Ambulance siren, jet plane 120

Source: CHC undated

Several different terms are commonly used to describe sounds that vary in intensity over time.

The equivalent sound intensity level (Leq) represents the average sound intensity level over a 

specified interval, often 1 hour. The day-night sound intensity level (LDN) is a single value 

calculated from hourly Leq over a 24-hr period, with the addition of 10 dBA to sound levels from 

10 p.m. to 7 a.m. This addition accounts for the greater sensitivity of most people to nighttime 

noise. Statistical sound level (Ln) is the sound level that is exceeded “n” percent of the time 

during a given period. For example, L90 is the sound level exceeded 90 percent of the time and 

is considered the background level.

Nuclear power generation is an industrial process that can generate noise. Common noise 

sources from nuclear power plant operations include cooling towers, transformers, and worker 

vehicles. Major noise sources at Fermi 2 that are audible beyond the site-boundary include the 

cooling towers, firing range, and transmission lines (DECo 2011b). Offsite noise sources in the 

vicinity of the Fermi site include road traffic; animals (birds, dogs, and coyotes); and trains 

(DECo 2011b). The nearest noise sensitive receptor to Fermi 2 is a residence approximately 

0.72 mi (1.2 km) from the reactor and cooling towers, 0.1 mi (0.16 km) from the site boundary, 

and 0.4 mi (0.6 km) from the shooting range (DTE 2014g).

DTE conducted an ambient sound level survey around the Fermi site. Continuous and/or 

short-term measurements were taken at seven noise sensitive receptors (including the nearest 

residence identified above) located within 5 mi (8 km) of the Fermi site (DECo 2011b). Noise 

sources documented during the survey included road traffic, trains, Fermi 2 firing range, 

transmission lines, and Fermi 2 cooling towers. Continuous measurements taken at three noise 

sensitive receptors resulted in day-night LDN between 54 and 63 dBA. L90 sound levels at the 

seven receptors measured between 32 and 42 dBA. Hourly Leq sound levels at the receptors 

were the greatest between 10 a.m. and 2 p.m. and ranged between 52 dBA and 70 dBA and 

were the lowest between 11 p.m. and 3 a.m. and ranged between 36 and 48 dBA 

(DECo 2011b).

There are no Federal regulations1F

9 for public exposures to noise. The EPA recommends daynight average sounds levels (LDN) of 55 dBA as guidelines or goals for outdoors in residential 

areas (EPA 1974). However, these are not standards. The Federal Housing Administration has 

 9 In 1972, Congress passed the Noise Control Act of 1972 (42 U.S.C. 4901 et seq.) establishing a national policy to 

promote an environment free of noise that impacts the health and welfare of the public. However, in 1982 there 

was a shift in the Federal noise control policy to transfer the responsibility of regulating noise to state and local 

governments. The Noise Control Act of 1972 was never rescinded by Congress but remains unfunded 

(EPA 2014b).
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established noise assessment guidelines for housing projects and finds that day-night average 

sound levels (LDN) of 65 dBA or less are acceptable (HUD 2014). Day-night sound levels 

measured at the sensitive noise receptors near Fermi 2 are above EPA-recommended sound 

levels but below the Federal Housing Administration guideline. The Frenchtown Charter 

Township Noise Ordinance (Ordinance No. 184) prohibits excessive or loud noise and 

disturbance as specified in the ordinance (FTC 2015). However, acceptable noise levels or 

limits are not specified in the noise ordinance. Beyond the Frenchtown Township ordinances, 

there are no State or County ordinances for public exposures to noise applicable to Fermi 2.

DTE has received noise complaints regarding activities associated with the firing range. 

Specifically, the noise complaints have been limited to nighttime fire training at the range.

Nighttime shooting training takes place between the hours of 4:30 p.m. and 10 p.m. and occurs 

12 to 15 times a year (DTE 2014g). In response to these complaints, DTE notifies the nearby 

municipalities of upcoming scheduled training at the range and provides information about 

upcoming activities (DTE 2014g).

3.4 Geologic Environment

This section describes the geologic environment of the Fermi site and vicinity, including 

landforms, geology, soils, and seismic conditions.

3.4.1 Physiography and Geology

The Fermi site is located in the Eastern Lake Section of the Central Lowland physiographic 

province on the western shore of Lake Erie. The area has little topographic relief and is drained 

by streams and rivers that flow eastward into Lake Erie (Figure 3–10). Because the Fermi site 

lies on significant volumes of imported fill material that was put in place and then graded, it has 

very little relief (DECo 2011b). Surface elevations within the site boundary range from

approximately 575 to 595 ft (175 to 181 m) above mean sea level (MSL). The average water 

elevation for Lake Erie is estimated to be 571.6 ft (174 m) above MSL. A rock barrier is located 

along the shoreline to protect the site against high water levels in Lake Erie. The crest of the 

rock barrier is 581.8 ft (177 m) above MSL (DTE 2014d; NRC 2013a).

The site is in an area of unconsolidated glacial and lake formed sediments (interbedded silt, 

clays, and sands) that are underlain by bedrock consisting of a large thick sequence of 

sedimentary rocks. The bedrock is made up of more than 2,500 ft (762 m) of limestone, 

dolomite, sandstone, and shale beds that lie on top of metamorphic and igneous crystalline 

basement rocks (DTE 2014d). Figure 3–11 identifies the major geologic units that make up this 

large sedimentary sequence of rocks. Regionally, the bedrock layers dip toward the northwest.

The major buildings are built into the bedrock and on fill that consists of gravel and cobble 

aggregate (NRC 2013a). The fill was excavated from the now water-filled quarries located in 

the southwest corner of the site property (Figure 3–10). The fill was also used to provide a

structural base for several power plant auxiliary buildings and extends across most of the area 

containing plant structures (DTE 2014d). Other than fill, the unconsolidated material that 

overlies the bedrock is made up of glacial and lake sedimentary layers. Bedrock is encountered 

at about 30 ft (9.1 m) below the land surface. The Bass Islands Group forms the top of the 

bedrock. It consists of dolomite rock and is underlain by the Salina Group, which is made up of 

interbedded layers of dolomite, limestone, shale, claystone, sandstone, and anhydrite rock 

(DTE 2014d).

Mineral resources in Monroe County include active and inactive rock quarries, sand and gravel 

pits, and clay pits. The nearest pit to the Fermi property is a clay pit 6 mi (9.7 km) to the north
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(NRC 2013a). The nearest quarry is about 2.5 mi (4 km) north-northeast of the Fermi site

(DTE 2014d). Other than the gravel and cobble aggregate deposits used to construct Fermi 2,

significant economic mineral deposits have not been found at the site.

Figure 3–10. Topographic Map and Site Boundary

Source: Modified from DTE 2014d
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Figure 3–11. Fermi Site Geologic Column

Source: Modified from DTE 2014d
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3.4.2 Soils

The soils around the site are very poorly drained to somewhat poorly drained. Within the site 

boundary, the soils are poorly drained loam to silty clay loams, with some beach sands located 

along the lake shore and stream channels. The soils around most of the plant structures were 

replaced with fill material when Fermi 2 was constructed.

The plant buildings and physical structures are located on land that is committed to industrial 

development and that has been previously disturbed by site activities. The rest of the land 

within the site boundary is poorly drained. Most undisturbed areas are either covered with water 

or subject to frequent flooding. These areas are classified as poorly drained and not prime 

farmland or prime farmland “if drained.” A small parcel of land in the southwestern area of the 

site is designated as prime farmland and is currently used as such. Another smaller portion of 

land within the site boundary is also designated as prime farmland but is not farmed 

(DTE 2014d; NRC 2013a; USDA 2014a).

3.4.3 Seismic Setting

The Fermi site is located in one of the most seismically stable regions in the United States. 

Since the beginning of the 19th century, no recorded earthquake epicenter has been located 

closer than about 25 mi (40 km), and only seven earthquakes have been reported within 50 mi 

(80 km) of the site. Few reported earthquakes were of a high enough intensity to cause 

structural damage to reasonably well-built structures in the area (DTE 2014d). The NRC 

requires every nuclear plant to be designed for site-specific ground motions that are appropriate 

for its location.

3.5 Water Resources

3.5.1 Surface Water Resources

This section describes surface water resources within and near the Fermi 2 site.

3.5.1.1 Surface Water Hydrology

Fermi 2 is located on the western edge of Lake Erie. The site drains to Lake Erie to the east

and to one of its tributaries to the north (Swan Creek) through the North Lagoon (see Figure 3–5

and Figure 3–12). The North Lagoon and South Lagoon are connected to Lake Erie through 

direct contiguous waterways. There are two manmade canals on the western side of the Fermi 

site. The North Canal (also known as the overflow canal) flows to the North Lagoon. It 

previously served as the cooling water discharge channel for Fermi 1 and now receives 

stormwater and other effluents from the Fermi site, as further discussed in Section 3.5.1.3 

(DTE 2014d; NRC 2013a).

The South Canal (also known as the discharge canal) flows to the South Lagoon. A small pond 

is located between the North and South Canals. Nearby wetlands are hydraulically connected 

to the canals through culverts, but the small pond is not directly connected to any other surface 

water features. The wetlands, North and South canals, and lagoons are all hydraulically 

connected to the western basin of Lake Erie and subject to lake level changes and weather 

conditions (NRC 2013a).

Other streams near the Fermi site (not shown in Figure 3–12) include Stony Creek, located 

approximately 3 mi (4.8 km) southwest of the site; the River Raisin, located about 6 mi (9.7 km) 

southwest of the site; the Huron River, located 6 mi (9.7 km) to the north of the site; and the 
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mouth of the Detroit River, located approximately 6.5 mi (10 km) northeast of the site 

(DTE 2014d; NRC 2013a).

Lake Erie has an open water surface area of 9,910 mi2 (25,700 km2

), which makes it the 

12th largest freshwater lake on Earth. Lake Erie is the warmest of the Great Lakes, which also 

contributes to its high productivity and ecological sensitivity. The average depth of the entire 

lake is 62 ft (19 m), with a maximum depth of 210 ft (64 m). In all, Lake Erie holds an estimated 

116 mi3 (483 km3

) of water, or about 128 trillion gal (0.48 trillion m3) (GLC 2014a). The lake 

retention (residence) time for water entering the lake is approximately 2.6 years. Although there 

is great uncertainty in calculating the lake’s water balance and hydrologic flux over time, it is 

estimated that the Detroit River, which connects Lake Huron and Lake Erie, contributes about 

80 percent of Lake Erie’s total inflow. The other major inputs to Lake Erie are from precipitation 

(11 percent) and tributaries (9 percent) flowing through watersheds in Michigan, Ohio, 

Pennsylvania, New York, and Ontario (NRC 2013a). Specifically, based on estimated monthly 

contributions, inflow from the Detroit River system is estimated at 188,333 cfs (5,320 m3

/s). 

Annual average rainfall over Lake Erie is about 35 in. (89 cm) per year and contributes about 

25,497 cfs (720 m3

/s) of water to the lake’s water balance. Runoff from tributaries contributes 

another 21,189 cfs (599 m3

/s) of water. Groundwater contributions to the lake have not been 

quantified but have been assumed to be a relatively small component to the overall water 

balance. Losses from the lake due to evaporation are estimated to be 36 in. (91 cm) per year, 

equating to 26,027 cfs (735 m3

/s). Outflow from Lake Erie to Lake Ontario is estimated to be 

206,202 cfs (5,825 m3

/s) (Neff and Nicholas 2005; NRC 2013a). This is equivalent to about 

133,292 mgd (504.5 million m3

/d). For 2013, reported water withdrawals from the Lake Erie 

Basin totaled 51,623 mgd (195.4 million m3

/d), or about 79,861 cfs (2,256 m3/s); less than about 

4 percent of this water withdrawal was diverted out of the Lake Erie Basin or consumptively 

used (GLC 2014b).

The Fermi site is situated on the western drainage basin of Lake Erie, which is characterized as 

very shallow with an average water depth of 24 ft (7.3 m). This part of the lake basin is partially 

restricted from the rest of the lake by chains of barrier beaches and islands. Current patterns in 

the western basin are typically west to east. The current flow velocity averages 0.4 feet per 

second (0.12 meter per second), but it can vary due to winds and on a seasonal basis 

(DTE 2014d; NRC 2013a).
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Figure 3–12. Surface Water Features at the Fermi Site and Vicinity

Source: Modified from DTE 2014d
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Erosion and sediment transport in the western basin of Lake Erie near the Fermi site are

dictated primarily by two major streams: (1) the Detroit River to the north and (2) the River 

Raisin to the south. However, the Maumee River farther south is the major sediment source to 

Lake Erie and contributes the highest amount of suspended solids per year of any other 

tributary to the Great Lakes (DTE 2014d; NRC 2013a).

The Lake Erie shoreline at the Fermi site has generally been stable since plant construction 

more than 30 years ago. A rock barrier exists along the shoreline that serves to stabilize the 

site and to protect against the high water levels of Lake Erie (DTE 2014d; NRC 2013a). The 

rock barrier and associated backfill across the Fermi site are comprised of bedrock excavated 

during plant construction to raise the entire plant grade approximately 10 ft (3 m) above the 

surrounding land area and lake surface (DECo 2012e). Thus, the top of the rock barrier and 

most existing Fermi 2 facilities are located at an elevation of 581.8 ft (177.3 m) above MSL 

(referenced to NAVD88). The average water elevation of Lake Erie at Fermi 2 is 571.6 ft 

(174.2 m) above MSL (DTE 2014d; NRC 2013a).

The National Oceanic and Atmospheric Administration (NOAA) operates a water level gauging 

station at the Fermi site (station number 9063090), located adjacent to the Fermi 2 GSW pump 

house and near the head of the intake channel (Figure 3–5). The gauge was established in 

1963. For the 51-year period of record, the highest recorded lake level was 576.2 ft (175.6 m) 

on April 9, 1998, and the lowest was 563.65 ft (171.8 m) above MSL on February 16, 1967 

(DTE 2014d; NOAA 2014). The highest water levels are generally in the spring and summer,

with the lowest in the fall and winter (DTE 2014d).

In general, the potential for flooding at Fermi 2 exists from storms and winds on the lake that 

can cause a surge in lake levels and subsequent “seiches” (i.e., oscillations of the water surface 

due to atmospheric changes in pressure and winds). The U.S. Army Corps of Engineers

(USACE) estimates that the maximum 100-year storm-induced surge on Lake Erie is 3.9 ft 

(1.2 m) at the Fermi site (NRC 2013a). Nevertheless, all seismic Category I (safety-related) 

structures at Fermi 2 are designed for the probable maximum meteorological event water level 

of 586.9 ft (178.9 m) plus the runup from small waves. The openings in the structures are 

watertight and designed for the high water levels. Otherwise, the Fermi site is not susceptible to 

flooding caused by surface runoff because of the shoreline location, the engineered grade and 

associated backfill across the site, and the distance to major streams (DECo 2012e).

Other surface water features on the Fermi site include two quarry lakes and several manmade 

impoundments (Figure 3–12). The NRC staff visited all of these features during the 

September 2014 environmental site audit. The two lakes are former rock quarries used during 

Fermi 2 construction and are located near the Fermi administrative and training buildings. Since 

the termination of quarrying in 1972, groundwater and runoff have filled the excavations 

(DECo 2012e).

The most notable impoundment is the 5.5-ac (2.2-ha) CWR, which is central to Fermi 2’s CWS

(Section 3.1.3). The clay-lined CWR receives cooling tower blowdown and other plant effluents 

before they are discharged through Fermi 2’s primary permitted outfall (Outfall 001) in 

accordance with the plant’s Michigan-issued NPDES permit. Section 3.5.1.3 further discusses 

the site’s NPDES permit in detail.

Two other impoundments are the Chem Basin and Chem Waste Pond. The Chem Basin is a 

small, elevated clay-lined impoundment that temporarily stores wastewater from the plant’s 

auxiliary boiler blowdown sump, diesel fuel storage tank berm, and diesel fuel offloading station 

before it is discharged to the plant’s sanitary sewer system. The Chem Waste Pond is a 

chambered, clay-lined structure that receives plant low-volume wastes, metal cleaning wastes, 
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and stormwater. It is also an active NPDES-permitted discharge point to the North Canal 

through Outfall 009 (DTE 2014d).

Finally, the dredge basin is an excavated basin with supporting embankments that is used for 

the discharge of dredge spoils associated with intake structure maintenance dredging. 

Dewatering flows from the dredged materials are discharged through NPDES Outfall 013 to the 

South Lagoon (DTE 2014d; NRC 2013a).

3.5.1.2 Surface Water Use

As previously detailed in Section 3.1.3, Fermi 2 withdraws surface water from Lake Erie for plant 

cooling and other uses through a dedicated intake structure. Cooling tower blowdown and other 

permitted effluent streams are discharged back to either Swan Creek or directly to Lake Erie 

through an on-shore discharge structure located just east of the CWR and designated as 

NPDES Outfall 001 (Figure 3–12). 

The maximum (hypothetical) surface water withdrawal rate for Fermi 2 is 53,500 gpm (119 cfs; 

3.36 m3

/s), which is equivalent to 77 mgd (291,500 m3/d). This surface water withdrawal rate is 

based on all five GSW pumps in continuous operation plus one CWR makeup pump

(Section 3.1.3). However, DTE reports that, based on four GSW pumps operating, Fermi 2’s 

average daily (nominal) withdrawal rate is 31,000 gpm (69 cfs; 1.95 m3

/s) or about 44.6 mgd 

(169,000 m3

/d). On average, approximately 40 percent of the water withdrawn is consumptively 

used (DTE 2014d).

Table 3–7 summarizes Fermi 2’s surface water withdrawals for the period 2009 to 2013. Based 

on the NRC staff’s review of DTE’s surface water withdrawal and use reports to the State of 

Michigan, Fermi 2’s surface water withdrawals have averaged 19,086 million gallons per year

(mgy) (72.2 million cubic meters per year (m3

/yr)), which is equivalent to an average withdrawal 

rate of approximately 36,300 gpm (80.8 cfs; 2.28 m3

/s) or 52.3 mgd (198,000 m3/d). Return 

discharges to Lake Erie have averaged 12,011 mgy (45.5 million m3

/y). This is equivalent to an 

average discharge rate of 22,850 gpm (50.9 cfs; 1.44 m3

/s), or 32.9 mgd (125,000 m3/d). The 

values reflect a consumptive use rate averaging 37 percent or about 19 mgd (72,000 m3

/d). 

Annual Surface Water Withdrawals and Return Discharges to Lake Erie, 

Fermi 2

Year Withdrawals (mgy) mgd Discharges (mgy)(a) mgd

2009 18,192.6 49.8 11,003(b) 30.1

2010 19,244.7 52.7 12,165(b) 33.3

2011 21,111.3 57.8 14,006.2 38.4

2012 19,309.0 52.9 12,267.9 33.6

2013 17,575.1 48.1 10,613.7 29.1

Average 19,086.5 52.3 12,011.2 32.9

Note: Reported values are rounded. To convert million gallons per year (mgy) to million cubic meters (m3), divide 

by 264.2. 

(a) Reflects withdrawn water returned to Lake Erie and connecting waters as referenced in Michigan Water Use 

Reports.

(b) Value was calculated from information in the referenced report. All other values are as listed in the reports cited. 

Sources: DECo 2010a, 2011c, 2012b, 2013a; DTE 2014a
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Fermi 2’s surface water withdrawals and consumptive water use are not currently subject to any 

water allocation or related permitting requirements. However, the State of Michigan is a party to 

the 2008 Great Lakes–St. Lawrence River Basin Water Resources Compact (the Compact) 

(451 MCL 324.34201), which also includes the States of Illinois, Indiana, Minnesota, New York, 

Ohio, Pennsylvania, and Wisconsin. The Compact is a legally binding interstate agreement that 

details how its member States will manage the use of the water supply of the Great Lakes 

Basin. The Compact explicitly provides a framework for each State to enact programs and laws 

protecting the Basin, and it is the formal mechanism for implementing the previous good-faith 

commitments made between the governors of the U.S. member States and the premiers of 

Ontario and Quebec under the 2005 Great Lakes–St. Lawrence River Basin Sustainable Water 

Resources Agreement (Council of Great Lakes Governors 2015).

Following ratification of the Compact by all eight member States and the U.S. Congress, the 

Great Lakes–St. Lawrence River Basin Water Resources Council (Compact Council) was 

established on December 8, 2008, in accordance with Section 2.2 of the Compact. The 

Compact Council acts as the governing body under the Compact and comprises the governors 

and representatives from the eight member States. The Compact Council is responsible for 

conducting research, collecting data, and overseeing disputes related to the water management 

of the basin (Compact Council 2015). The Compact Council works in partnership with the Great 

Lakes Commission, which is an interstate compact agency originally established in 1955 that 

promotes the orderly, integrated, and comprehensive development, use, and conservation of 

the water and related natural resources of the Great Lakes Basin and St. Lawrence River. Its 

members likewise include the eight Great Lakes States with associate member status for the 

Canadian provinces of Ontario and Québec (GLC 2015).

Under the terms of the Compact, any water withdrawals within the Great Lakes Basin that would 

result in a new or increased consumptive use of 5 mgd (18,925 m3

/d) are subject to review by all 

States within the region. Central to the water use management provisions of the Compact is 

that withdrawals and consumptive uses will be managed to ensure that there will be no 

significant individual or cumulative adverse impacts to the quantity or quality of the waters of the 

Great Lakes. The consumptive use and water diversion requirements of the Compact are met 

by the State of Michigan under the MDEQ’s water withdrawal permitting program 

(451 MCL 324.32723). DTE is subject to these requirements because its water withdrawals 

result in consumptive use greater than 5 mgd (18,925 m3

/d). DTE reports its surface water

withdrawals and pays a water usage fee to the MDEQ in accordance with 451 MCL 324.32705.

3.5.1.3 Surface Water Quality and Effluents

The MDEQ is responsible for assessing the support of beneficial uses of surface water bodies in

Michigan and it promulgates water quality standards applicable to the Great Lakes, connecting 

waters, and all other surface waters in Michigan in accordance with MAC Rule (R) 323.1041–

1117. At a minimum, all surface waters of the State are designated and protected for all of the 

following uses: (1) agriculture, (2) navigation, (3) industrial water supply, (4) warm water 

fishery, (5) other indigenous aquatic life and wildlife, (6) partial body contact recreation, and 

(7) fish consumption under these standards. In addition, all Great Lakes and most connecting 

waters are designated and protected for cold water fisheries with specific numeric criteria for

chemical parameters and temperature.

Lake Erie is extensively used for water supply (e.g., industrial and drinking water), recreation, 

navigation, and commercial fishing. Frenchtown Township withdraws water from Lake Erie 

through an intake, located south of the Fermi site at Pointe Aux Peaux, that it shares with the 

City of Monroe. However, Fermi 2’s restricted area prohibits recreational activity and navigation 

near the site (NRC 2013a).
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Section 303(d) of the Federal Clean Water Act of 1977, as amended (CWA) 

(33 U.S.C. 1251 et seq.), requires states to identify all “impaired” waters for which effluent 

limitations and pollution control activities are not sufficient to attain water quality standards in 

such waters. The Section 303(d) list includes those water quality limited stream segments that 

require the development of total maximum daily loads to ensure future compliance with water 

quality standards. Michigan prepares and submits its lists and associated report every 2 years.

As reaffirmed in Michigan’s current Section 303(d) report, the Michigan waters of the Great 

Lakes and their connecting channels continue to be listed as not supporting the fish 

consumption designated use because of elevated concentrations of polychlorinated biphenyls, 

dichlorodiphenyltrichloroethane, mercury, chlordane, and/or dioxin in the water. Atmospheric 

deposition is the major source of these persistent compounds (MDEQ 2014a).

Current water quality concerns with regard to Lake Erie include (1) increased phosphorus 

loading from regional agricultural activities, which is a factor that contributes to toxic algal 

blooms, and (2) elevated concentrations of three bioaccumulative contaminants (mostly from 

historical industrial activities), such as dioxin, polychlorinated biphenyls, and mercury, as 

indicated above (NRC 2013a). In 2005, the Detroit River–Western Lake Erie Basin Indicator 

Project was initiated. This joint U.S.-Canadian effort was led by the FWS and EPA along with 

their Canadian counterparts and other Governmental and non-Governmental partners. 

A primary objective of the study was to assess basin ecosystem status, quality, and trends and 

the factors that affect them (EPA 2009a). While the report identified a number of areas of 

substantial improvement in overall environmental quality, including water quality, the following 

challenges for the Detroit River–Western Lake Erie Basin were noted: (1) population growth 

and accompanied land use changes, (2) nonpoint source pollution, (3) toxic substances 

contamination, (4) habitat loss and degradation, (5) exotic species, and (6) greenhouse gases

and global warming (Hartig et al. 2007; NRC 2013a).

To operate a nuclear power plant, NRC licensees must comply with the CWA, including 

associated requirements imposed by EPA or the state, as part of the NPDES permitting system 

under Section 402 of the CWA, as well as state water quality certification requirements under 

Section 401 of the CWA. The EPA or the state, not the NRC, sets the limits for effluents and 

operational parameters in plant-specific NPDES permits. Nuclear power plants cannot operate 

without a valid NPDES permit and a current Section 401 Water Quality Certification. In 

Michigan, EPA delegated its responsibility for administration of the NPDES program to the State 

in 1973. The NPDES permits are issued by the MDEQ on a 5-year cycle.

Under this approach, all of the permits in each individual watershed expire in the same year and 

are reviewed for reissuance, as applicable. This approach allows the MDEQ to consider 

cumulative impacts of all dischargers on water quality in the watershed. Discharges to lakes, 

streams, and wetlands must not cause a violation of Michigan water quality standards. As part 

of the permit issuance process, limits are developed for pollutants to avoid a violation of water 

quality standards and ensure compliance with the treatment technology regulations of the CWA 

(MDEQ 2014a). The State of Michigan’s regulations for administering its NPDES permit 

program are contained in MAC R 323.2101–2197.

Fermi 2 is currently operating under NPDES Permit No. MI0037028, issued on June 3, 2010 

(MDNR 2012). It was last modified on April 23, 2012. The permit expired on October 1, 2014. 

However, DTE submitted a permit renewal application to the MDEQ on March 31, 2014, which 

the MDEQ subsequently accepted as administratively complete (DTE 2014c, 2014g). As a 

result, DTE’s NPDES permit for Fermi 2 operations remains in effect (i.e., administratively 

continued) because DTE submitted an application for renewal at least 180 days before the 

expiration of the current permit in accordance with MAC R 323.2151.
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The permit specifies the discharge standards and monitoring requirements for effluent 

(wastewater) chemical and thermal quality and for stormwater discharges through the primary, 

internal, and secondary outfalls to Lake Erie and connected waters, as summarized in

Table 3–8.

NPDES-Permitted Outfalls, Fermi 2

Outfall

Max. Permitted 

Flow Rate (mgd) Description

001

(001A)(a)

45.1 Cooling tower blowdown, processed

Radioactive liquid (radwaste) wastewater, RHR system service water 

and metal cleaning wastes(b) through Outfall 001 to Lake Erie

001B(a) 1.44 RHR system service water (cooling water blowdown) 

001D(a) 0.216 Processed radwaste wastewater(c)

001E(a) 0.5 Treated chemical and nonchemical metal cleaning wastes from the 

condenser water box 

009 (009A)(a) 0.72 Chem Waste Pond discharge, low volume wastes, chemical 

metal-cleaning wastes,

(b) and nonchemical metal-cleaning wastes and 

stormwater runoff to Swan Creek through the overflow canal

011

(011A)(a)

0.216 Treated oily wastewater and an unspecified amount of General 

Service Water screen and pump strainer backwash to Swan Creek 

through the overflow canal 

011C(a) 0.216 Oily waste equalization basin, stormwater from oil-fired peaker units 

and associated fuel oil tank containment dike(d)

013 (013A) Intermittent up to 

450 mgy

Dredge basin, dredging dewatering water to Lake Erie

Note: To convert million gallons per day (mgd) or million gallons per year (mgy) to million cubic meters (m3), divide 

by 264.2.

(a) This is an NPDES permit internal monitoring point(s) located upstream of the numbered point source outfall(s). 

(b) Chemical metal cleaning wastes were originally permitted as a potential waste stream to support Fermi 2

construction. However, other than nonchemical metal-cleaning wastes comprising water used for the periodic 

washdown of the main unit transformers and discharged through Outfall 009, Fermi 2 does not anticipate 

discharging any chemical metal-cleaning wastes through Outfalls 001 and 009 in the future (DTE 2014d).

(c) Although permitted, Fermi 2 has not had a planned liquid effluent radioactive waste discharge since 1994 and 

plans to voluntarily continue to operate as a zero-discharge liquid radioactive waste release facility (DTE 2014d). 

DTE’s NPDES permit renewal application to the MDEQ identifies its processed radioactive waste effluent stream 

to Outfall 001 as “inactive” (DTE 2014c). 

(d) This basin takes stormwater inputs from the site's peaker power generating units and associated fuel oil tank 

containment dike. Although permitted, oily wastewater is no longer discharged through Outfall 011. Waste 

stream is now discharged to the sanitary sewer system (DTE 2014d). DTE’s NPDES permit renewal application 

to the MDEQ identifies Outfall 011C as “inactive” (DTE 2014c).

Sources: DTE 2014d; MDNR 2012

For Fermi 2’s primary outfall (Outfall 001), the NPDES permit requires DTE to monitor and 

report flow rate, pH, temperature of intake water and discharge, total residual chlorine, and the 

concentration of a cooling water biocide when used for zebra mussel control. For the other 

outfalls, other monitored parameters include total suspended solids, oil and grease, and various 

metals. Monitoring results are reported in monthly discharge monitoring reports submitted to 

the State.
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Fermi 2’s NPDES permit also governs stormwater discharges associated with industrial activity 

through six stormwater-only outfalls (i.e., Outfalls 002, 004, 005, 007, 012, and 014)

(Figure 3–12). As specified in Part I, Section A.13 of Fermi 2’s NPDES permit, DTE is required 

to develop, maintain, and implement a Storm Water Pollution Prevention Plan so that 

stormwater discharges do not violate State water quality standards (DTE 2013b). Based on the 

NRC staff’s review, the plan identifies potential sources of pollution that could affect stormwater, 

groundwater, and/or offsite surface water quality, as well as the practices, controls, and 

inspections used to prevent or reduce pollutants in stormwater discharges.

The NRC staff’s review of Discharge Monitoring Reports from 2009 through 2013 found no 

substantial or recurrent exceedances of NPDES permit requirements or unusual conditions of 

operations, with reported discharges in compliance with specified effluent limitations. 

Additionally, DTE reported that it has not received any Notices of Violation, nonconformance 

notifications, or related infractions associated with the site’s NPDES permit within the past 

5 years. However, DTE has identified a number of self-reported permit exceedances, permit 

noncompliances, and reportable releases (reported to responsible regulatory agencies) that 

have occurred over the last 5 years (DTE 2014g). Based on the NRC staff’s review of the 

available information, all these self-reported events had little or no effect on offsite water quality.

Sanitary effluent from Fermi 2 is not discharged to surface water through a plant outfall but 

instead is discharged to a publicly owned treatment works (Monroe Metropolitan Wastewater 

Facility). This effluent stream includes domestic sewage, effluent from several oil-water 

separators, and effluent from the Chem Basin. These flows are first collected in an 

aboveground concrete-lined holding tank (i.e., the sewage forwarding station) where the 

streams are combined and forwarded to the offsite treatment facility. The effluent is subject to 

discharge (pretreatment) limits and monitoring requirements specified under 

Industrial/Non-Domestic User Discharge Permit No. 1020 issued to DTE by the City of Monroe 

(City of Monroe 2012).

Section 401 of the CWA requires an applicant for a Federal license to conduct activities that 

may cause a discharge of regulated pollutants into navigable waters to provide the licensing 

agency with water quality certification from the State. This certification implies that discharges

from the project or facility to be licensed will comply with CWA requirements and will not cause 

or contribute to a violation of state water quality standards. If the applicant has not received 

Section 401 certification, the NRC cannot issue a license unless that state has waived the 

requirement. The NRC recognizes that some NPDES-delegated states explicitly integrate their 

Section 401 certification process with NPDES permit issuance. Fermi 2’s NPDES permit does 

not explicitly convey water quality certification under CWA Section 401. Nevertheless, the 

MDNR previously issued a Section 401 Water Quality Certification for Fermi 2 on 

September 27, 1977. In it, the State noted that issuance of an NPDES permit, also by the State 

of Michigan, would ensure that applicable water quality provisions under the Federal Water 

Pollution Control Act of 1972, as amended (33 U.S.C. 1251 et seq.) (i.e., referred to as the 

CWA), would be met in satisfaction of Section 401 requirements (DTE 2014d). 

In response to the NRC staff’s request for additional information for documentation of the status 

of Fermi 2’s Section 401 Water Quality Certification, DTE cited a meeting between DTE and 

staff of the MDEQ’s Water Bureau, which was held on January 31, 2013. At the meeting, the 

MDEQ informed DTE that Section 401 Water Quality Certification is implicitly granted by the 

State with Fermi 2’s NPDES permit (DTE 2014g).

The surface water intake from Lake Erie for Fermi 2 is located between the two rock groins that 

extend into Lake Erie to minimize shoaling and to protect the Fermi 2 water intake (Figures 3–5

and 3–12). DTE periodically performs maintenance dredging in the area between the two 
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groins constituting the intake channel. The current dredge cycle is 4 years (NRC 2013a). This 

maintenance dredging is conducted under permits issued by the USACE in accordance with 

Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403 et seq.) and Section 404 of the 

CWA and by the MDEQ under Act 451, NREPA, Part 325, “Great Lakes Submerged Lands” 

(451 MCL 324.32501–32515a). 

Specifically, Fermi 2 possesses Department of the Army Permit No. 88-001-040-8

(USACE 2004) and MDEQ Permit No. 11-58-0055-P (MDEQ 2012) that authorize the hydraulic 

dredging of up to 25,000 cubic yards (19,100 m3

) of material from the main intake channel and 

disposal of the dredge spoils in the dredge basin (Figure 3–12). In addition, dredging of up to 

500 cubic yards (380 m3

) from the GSW intake canal adjacent to the intake channel

(Figure 3–5) is separately permitted under U.S. Army letter of authorization 

LRE-1988-10408-L13 (USACE 2013) and MDEQ Permit No. 13-58-0013-P (MDEQ 2013a). 

These authorizations were sought by DTE and issued by the USACE and the MDEQ after DTE 

performed dredging of the intake canal, a location not explicitly authorized under U.S. Army 

Permit No. 88-001-040-8 and MDEQ Permit No. 11-58-0055-P. Initially, DTE applied for 

after-the-fact permits as directed by the MDEQ to address the noncompliance. The MDEQ then 

issued an after-the-fact permit for the completed activity, and the USACE issued an 

after-the-fact Section 404 Nationwide Permit 3 (DTE 2014d).

Dredge spoils from the intake canal and channel are piped to the dredge basin to dewater. As 

previously noted, and indicated in Table 3–8, the dredge basin has an NPDES-permitted outfall

for the discharge of dewater effluent. Dredge spoils are removed approximately every 10 years. 

The materials are sampled to ensure that the quality is acceptable to meet MDNR requirements 

for land application before they are placed on the Fermi site and are seeded to prevent erosion 

(DTE 2014d).

The dredge basin was visited by NRC personnel during the September 2014 environmental site 

audit, during which time DTE contractor personnel were performing grading and maintenance of 

the basin.

3.5.2 Groundwater Resources

This section describes the current groundwater resources within and near the Fermi site.

3.5.2.1 Site Description and Hydrogeology

Because of the low lying topography and the numerous water bodies around the site 

(Figure 3–10), the water table can often be found near the land surface. The depth to the water 

table within the site boundary generally ranges from the land surface to greater than 6.6 ft (2 m). 

Recharge to the water table is from local precipitation or, depending on the location, from 

occasional flooding or high lake levels. Around plant buildings, the depth to the water table is 

around 9 ft (2.7 m). Here the water table is in the construction fill and unconsolidated sediments 

(interbedded silt, clays, and sands). The unconsolidated material on top of the bedrock near the 

major buildings also contains vertical clay dikes that were installed during construction activities 

to limit the volume of groundwater flowing into building excavations. These dikes were left in 

place after construction activities stopped; they continue today to limit the lateral flow of water 

within the diked areas. Recharge to the water table in the plant area is primarily from 

precipitation, with some lateral infiltration from Lake Erie during high levels in Lake Erie 

(DTE 2014d; NRC 2013a; USDA 2014a).

Groundwater flow in the unconsolidated sediments is laterally to or away from surface water

bodies and vertically downward into the underlying bedrock (DTE 2014d; NRC 2013a). Beneath 

the Fermi site, the Bass Islands Group forms the underlying bedrock. It is made up of 
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approximately 50 to 100 ft (15.2 to 30.5 m) of dolomite rock. Groundwater flow is primarily 

through joints in the rock. Historically, the average lateral direction of groundwater flow in this 

group (and immediately underlying groups) was eastward toward the lake (DTE 2014d; 

NRC 2013a). However, the lateral direction of groundwater flow in the bedrock beneath the site 

is presently away from the lake toward quarry operations that are removing groundwater as part 

of their operations. These quarry operations are located to the north and southwest of the site 

(Figure 3–13) (DTE 2014d; NRC 2013a). At the site, recharge to the Bass Islands Group is 

from the overlying unconsolidated sediments or from the lake because the bedrock subcrops 

beneath Lake Erie and the water levels in this group are presently less than Lake Erie water 

levels (DECo 2011b).

The vertical flow of groundwater within the Bass Island Group is downward into the underlying 

Salina Group. The Salina Group is primarily composed of dolomite, shale, breccia, and 

limestone. As with the Bass Island Group, groundwater flow is mostly transmitted through joints 

in the rock. The thickness of the Salina Group is over 100 ft (30.5 m). Locally, it is recharged 

by the Bass Islands Group aquifer and Lake Erie. Regionally both the Bass Island and the 

Salina Groups are recharged by areas west of both the site and the two quarry operations 

(DTE 2014d). Both the Bass Island and Salina Groups are considered to be aquifers 

(Section 3.5.2.2).
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Figure 3–13. Bed Rock Water Levels and Lateral Groundwater Flow Directions

Source: Modified from NRC 2013a
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3.5.2.2 Groundwater Use

Groundwater use in the vicinity of the Fermi site is primarily limited to individual residences. 

Locally, the lake and glacially deposited material that lies on top of the bedrock is not 

considered to be an aquifer as they contain considerable amounts of clay and silt and do not 

readily transmit water (DECo 2011b). The Bass Islands and the Salina Groups are part of the 

regional bedrock aquifer that exists throughout Monroe County. In Monroe County, water from 

this aquifer is used by individual residences and quarries, with quarries being the largest 

consumer of groundwater (DECo 2011b) (Figure 3–14).

Groundwater is not used at the Fermi site and is not planned for use in the future. The primary 

cooling-water source for Fermi 2 is Lake Erie. Potable water used for drinking water and 

sanitary purposes comes from the Frenchtown Township Water Plant, which obtains its water 

from Lake Erie (DTE 2014d; NRC 2013a).

Although Fermi 2 does not consume groundwater for potable uses, the high groundwater table 

around plant buildings has caused some intermittent leakage of groundwater into the turbine 

building basement. The maximum quantity of groundwater that has been collected in a 24-hr 

period from this flow into the basement is 220 gal (833 L) (DTE 2014d).

In addition, water is pumped from site cable vaults to keep the cables dry. Some of the vaults 

are manually pumped periodically and some are pumped automatically. Typically, this water is 

from a mixture of groundwater inflow and stormwater runoff. Once the water is pumped from

the vaults, it is discharged through stormwater outfalls to water bodies that are in 

communication with Lake Erie (DTE 2014d).
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Figure 3–14. Wells within 2 mi (3 km) of Fermi

Source: Modified from DTE 2014d
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3.5.2.3 Groundwater Quality

In the local area, naturally occurring concentrations in the groundwater of arsenic and some 

nonhazardous water quality constituents may exceed drinking water standards, but overall the 

groundwater quality in the bedrock aquifers is generally adequate for public consumption 

(DECo 2011b; DTE 2014d; NRC 2013a).

In wells within a 5-mi (8-km) radius of the Fermi site, elevated concentrations of arsenic above 

EPA’s maximum contaminant level (0.010 mg/L) for drinking water were found in groundwater

samples. Fermi site activities did not cause the arsenic concentrations in these wells 

(NRC 2013a). In the local area and in other areas of Michigan, natural earth materials, such as 

bedrock, sand, and gravel, may contain arsenic-bearing minerals. The arsenic in these 

naturally occurring materials may enter the groundwater as a dissolved constituent, which in 

turn would increase the concentration of arsenic in wells that withdraw this groundwater 

(MDEQ 2013c).

A few nonradiological spills of chemicals into the water table of the Fermi site have occurred. 

DTE reported all spills to the MDEQ and has remediated them (NRC 2013a; DTE 2014g). Spill 

incidences are as follows:

• In 1987, a leak of sodium hydroxide to groundwater was identified, and the pH of the

groundwater in the area of the spill was measured to be 12.8. DTE excavated the

soil in the area of the spill and pumped groundwater from the excavated area until 

the groundwater pH was reduced to 9.5.

• A diesel tank leak at the Fermi site was discovered on October 18, 2001. The 

investigation for this leak was closed on December 19, 2001.

• In 2002, 20 gal (76 L) of 15-percent sodium hypochlorite solution was accidentally 

spilled on soil. The contaminated soil was subsequently excavated and neutralized.

• Remedial action was taken to clean up a diesel spill to groundwater that was 

identified in 2002. Free phase diesel fuel was found in a dewatering sump within the 

Fermi 2 RHR complex in June 2002. A leak in the emergency fuel drain pipe was 

thought to be the source, and the leak was repaired. The diesel fuel contamination 

in the groundwater was monitored and remediated.

• Approximately 3,000 gal (11,365 L) of auxiliary boiler blowdown water was released 

to both the ground and to Outfall 002A on November 3, 2010. The release was 

determined to be the result of a leaking underground pipe that was subsequently 

repaired. No cleanup was required.

• Ten gallons (37 L) of raw sewage was discharged to the ground from a sanitary 

sewer line break on November 23, 2010. The line was immediately repaired.

• Thee gallons (11.4 L) of nonradioactive oily water from an oil/water separator tank 

spilled onto the ground surface on November 1, 2012. The contaminated soil and 

rock were removed.

Occasionally, low-level concentrations of tritium (hydrogen with an atomic weight of 3) have 

been detected above the laboratory lower limit of detection (500 picocuries per liter (pCi/L)) in a 

few onsite wells that monitor groundwater quality in the unconsolidated material. At the end 

of 2014, tritium was detected above the detection limit in six wells. These wells are located near 

the lake and the Fermi 2 air emissions stack. They are completed in unconsolidated material 

that contains fill. Tritium concentrations in these wells averaged 802 pCi/L. The maximum 

value recorded was 1,750 pCi/L (DTE 2015b). Tritium detected in these wells is believed to 
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have originated from permitted (allowable) air releases of water vapor that contained tritium. 

The water vapor in the air condensed into liquid water and fell to the ground where it seeped 

into the ground and infiltrated down to the water table. Increasing trends in tritium concentration 

in the groundwater have not been observed, and all detected concentrations of tritium are well 

below EPA’s drinking water standard of 20,000 pCi/L (NRC 2013a; DTE 2014e, DTE 2015b). 

Tritium has not been detected above the detection limit in wells that monitor the Bass Island 

Group. No other radionuclides have been detected in groundwater samples above their 

baseline values (DECo 2011b, DTE 2015b).

3.6 Terrestrial Resources

3.6.1 Fermi 2 Ecoregion

Fermi 2 lies in the Southern Lower Peninsula within the Maumee Lake Plain Level IV Ecoregion. 

The Southern Lower Peninsula encompasses 24,248 mi2 (62,802 km2

) and is characterized by 

rolling moraines and flat lake prairies. The region is underlain by Paleozoic bedrock and was 

completely glaciated during the Late Wisconsinan Glacial period; typically 100 to 400 ft (30 to 

120 m) of loamy glacial drift covers the bedrock (MDNR 2006a). This ecoregion experiences 

the warmest climate and longest growing season in the State. Historically, open fire-dependent 

oak savannas and prairies, oak-hickory forests, prairie fens, lakeplain prairies, southern wet 

meadows, southern swamps, and floodplain forests covered much of the region. The MDNR 

(2006a) reports that this region was the only region in Michigan to support large areas of 

tallgrass prairie. Today, agriculture and urban development constitute the major land uses. 

Remaining floodplain forests provide important habitat for migrating and breeding songbirds and 

other wildlife, especially as the region has become increasingly fragmented. Most of the oak 

savannahs have been eliminated or converted to closed-canopy forest due to fire suppression, 

and almost all of the original tallgrass and wet prairies have been converted to farmland. The 

MDNR (2006a) considers the remaining marshes and wetlands along Great Lakes shorelines to 

be critical for maintaining migratory waterfowl, shore birds, and the Great Lakes fisheries. Rare 

plant communities found within this region include coastal plain marshes, which occur in sandy 

depressions in outwash plains and glacial lake beds; inland salt marshes, which are limited to a 

handful of locations along the Maple River; and prairie fens, which are concentrated in the 

interlobate region (MDNR 2006a).

The MDNR maintains Michigan’s Wildlife Action Plan (MDNR 2006a), which addresses native 

habitat and species decline and contains a Statewide conservation plan. In the plan, the MDNR 

identifies and prioritizes conservation actions, research and survey needs, and long-term 

monitoring initiatives. Within the Southern Lower Peninsula, the MDNR’s (2006a) priority 

conservation actions include invasive species monitoring, prevention, and control programs; 

management of natural disturbance regimes, such as prescribed fires; and working with 

municipalities to develop planning and zoning ordinances that promote the conservation of 

native grasslands, shrublands, and forests. The MDNR (2006b) has also identified species of 

greatest conservation need within the area, the list of which includes 92 birds, 91 insects, 

15 reptiles, 12 mammals, 11 amphibians, and 9 snails.

3.6.2 Fermi Site Surveys, Studies, and Reports

A number of vegetation and wildlife surveys have been conducted on the Fermi site beginning 

with preconstruction surveys in the early 1970s. This section summarizes these surveys in 

chronological order.
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Final Environmental Statement for Construction (1972)

In July 1972, the U.S. Atomic Energy Commission (AEC), the predecessor agency to the NRC, 

issued a final environmental statement that evaluated the construction of Fermi 2 (FES-C) 

(AEC 1972). Although no specific studies were conducted to support the preparation of the 

FES-C, the report summarizes the terrestrial habitats and wildlife on the site.

Preconstruction Surveys (1973–1974)

From January 1973 through January 1974, NUS Corporation (1974) performed baseline 

preconstruction surveys of the Fermi site. The surveys included qualitative and quantitative 

surveys of woody vegetation, herbaceous plants, and wetland plants; bird censuses; mammal 

field studies and population estimates; and qualitative reptile and amphibian surveys. The final 

report also contains extensive tables of species present at the Fermi site.

Final Environmental Statement for Operation (1981)

In August 1981, the NRC issued a final environmental statement that evaluated the operation of 

Fermi 2 (FES-O) (NRC 1981). The report includes updates to the information provided on 

terrestrial habitats and wildlife in the FES-C.

Wildlife Habitat Council Vegetation and Wildlife Surveys (2000)

In July 2000, Wildlife Habitat Council (WHC) biologists performed a general habitat survey that 

identified wildlife and plant species common to the site and surrounding vicinity (DTE 2014d). 

The Fermi 2 Wildlife Management Plan (DECo 2000) documents the survey results.

Fermi 3 Reconnaissance Surveys (2006–2008)

Between November 2006 and May 2008, Black & Veatch Corporation (Black & Veatch) 

conducted reconnaissance surveys of the Fermi site to assess existing ecological conditions in 

support of Detroit Edison Company’s (DECo) preparation of the Fermi 3 COL application. The 

surveys included both vegetation sampling and wildlife surveys. DECo’s ER for the Fermi 3 

COL application (DECo 2011b) documents the results of the surveys.

Ducks Unlimited Wetland Investigation Report (2008)

In 2008, DTE contracted with Ducks Unlimited, Inc. (Ducks Unlimited) to perform wetland 

delineation on 1,106 undeveloped acres (448 ha) on the Fermi site. Ducks Unlimited reviewed 

existing topographic and National Wetlands Inventory maps, soil surveys, and other existing 

information; conducted onsite investigations of soil, hydrology, flora, and fauna in May and 

June 2008; and delineated all wetlands on the site using USACE delineation guidance. A

July 2008 Wetland Investigation Report (Ducks Unlimited 2008) delineates the results. In 2011, 

Ducks Unlimited updated the report to incorporate minor changes to the delineation provided by 

the MDEQ and the USACE (Ducks Unlimited 2011).

Fermi 3 Terrestrial Vegetation and Wildlife Surveys (2008–2009)

From July 2008 through June 2009, Black & Veatch conducted more detailed surveys of 

vegetation and wildlife on the Fermi site than that of the previous reconnaissance surveys.

Black & Veatch gathered quantitative data on the abundance, density, and cover of plant 

species on the site using line transects and plot sampling methods during 3-day periods in 

July 2008, October 2008, May 2009, and June 2009. Transects were positioned in areas that 

Fermi 3 construction was expected to affect and that generally represented the plant 

communities present, including emergent wetland, restored prairie, Lake Erie shoreline, and 

wooded lots. Black & Veatch issued a final report in November 2009 (Black & Veatch 2009c).
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The wildlife surveys were conducted to systematically confirm data obtained from earlier 

surveys and to further characterize the terrestrial wildlife species that inhabit the site. General 

visual encounter surveys were conducted during 4-day periods in July 2008, October 2008, 

January 2009, and April 2009. Black & Veatch also conducted focused surveys for Federally 

and State-listed birds, mammals, reptiles, and amphibians. Black & Veatch issued a final report 

in November 2009 (Black & Veatch 2009d).

Transmission Line Corridor Prairie Planting Survey (2005 and 2007)

In July 2005 and September 2007, representatives from the Michigan State University 

Extension surveyed a 29-ac (12-ha) area of restored prairie within an onsite transmission line 

corridor (MNFI 2007h). Section 3.6.5.2 describes the survey results.

Threatened and Endangered Species Assessment (2013)

In July and August 2013, Cardno JFNew representatives conducted surveys for Federally and 

State-listed threatened and endangered species on the Fermi site (Kogge and Heslinga 2013). 

Frog and toad surveys were also conducted at several locations throughout the site. 

Section 3.6.3.2 discusses the State-listed species observed during this assessment in detail. 

No Federally listed species were observed during the assessment.

2014 Special Status Species Survey (2014)

In response to proposed rules to Federally list two species—the red knot (Calidris canutus rufa) 

and northern long-eared bat (Myotis septentrionalis)—DTE contracted with Cardno JFNew to 

perform a supplemental threatened and endangered species assessment in 2014 

(Kogge 2014). Field surveys for the two species were conducted in September 2014. Although 

neither species was observed during the surveys, Cardno JFNew concludes, in the final report,

that potential roosting and foraging habitat for the northern long-eared bat and potential 

migratory stopover or resting habitat for the red knot occurs on the site. Section 3.8 discusses 

this study in detail.

Annual Christmas Bird Count (1990–Present)

DTE has hosted an annual Christmas bird count on the Fermi site with the National Audubon 

Society since 1990. The Fermi site counts are reported with the Rockwood, Michigan 

(Christmas Bird Count Code MIRO), counts on the National Audubon Society’s Christmas Bird 

Count web site.

Fermi 2 Wildlife Habitat Team Monitoring (Ongoing)

The Fermi 2 Wildlife Habitat Team conducts periodic wildlife surveys of the site four to five times 

per year to monitor changes in wildlife communities and to document any new species found on 

the site. The surveys are random and include the South Lagoon, dredge basin, quarry lakes, 

and several areas of wooded wetlands (DTE 2014g).

3.6.3 Fermi Site

The Fermi site encompasses 1,260 ac (510 ha) in Frenchtown Township, Monroe County, 

Michigan. Approximately 212 ac (86 ha) of the site are developed and in industrial use. DTE 

leases approximately 64 ac (26 ha) in the western-most portion of the site to private individuals 

for agricultural use. The remainder of the site consists of natural areas, including coastal 

emergent wetlands, forests, grasslands, shrublands, thickets, Lake Erie, and other various 

waterbodies. The FWS manages approximately 656 ac (265 ha) of the site’s natural areas as 

part of the DRIWR under a cooperative agreement with DTE that was first established in 2003 

(DECo and FWS 2003). DTE manages the remaining natural areas on the site in accordance 
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with its WHC-certified Wildlife Management Plan (DECo 2000). The DRIWR cooperative 

agreement and Wildlife Management Plan are discussed in more detail in Sections 3.6.5.2 

and 3.6.4, respectively.

Much of the site was disturbed before or during Fermi 2 construction through clearing or 

covering with fill materials, and some of the forested tracts along the southern edge of the site 

were also logged (DTE 2014d).

3.6.3.1 Vegetation

As described in Section 3.6.2, Black & Veatch conducted initial vegetation surveys of the Fermi 

site from November 2006 through May 2008 (DECo 2011b) and more detailed surveys from 

July 2008 through June 2009 (Black & Veatch 2009c). These surveys and the NRC’s final 

environmental impact statement (FEIS) for the Fermi 3 COL (NRC 2013a), inform the 

description of the vegetative communities on the Fermi site. Table 3–9 lists the vegetative 

cover types, dominant species, and acreage for each of the nine terrestrial habitat types on the 

site.

Vegetative Cover Types and Dominant Species on the Fermi Site by Area

Cover Type (Habitat)(a) Dominant Species

Area

(in acres) Percent(b)

Coastal Emergent Wetland 273 32.8

Coastal Emergent Wetland common reed (Phragmites australis), cattail 

species (Typha spp.), American lotus 

(Nelumbo lutea)

273 32.8

Forest 256 30.6

Coastal Shoreline cottonwood (Populus deltoides), peachleaf 

willow (Salix amygdaloides)

47 5.6

Lowland Hardwood cottonwood, peach-leafed willow, oak species 

(Quercus spp.), basswood (Tilia americana), 

hickory species (Carya spp.)

92 11.0

Woodlot cottonwood, box elder (Acer negundo), green 

ash (Fraxinus pennsylvanica)

117 14.0

Grassland 168 20.2

Right-of-way big bluestem (Andropogon gerardii), 

Indiangrass (Sorghastrum nutans)

29 3.5

Idle, Old Field, or Planted smooth brome (Bromus inermis), Canada 

goldenrod (Solidago canadensis)

75 9.0

Row Crop corn (Zea mays), soybeans (Glycine max) 64 7.7

Shrubland 113 13.6

Shrubland dogwood species (Cornus spp.), common 

buckthorn (Rhamnus cathartica), multiflora 

rose (Rosa multiflora), blackberry species 

(Rubus spp.)

113 13.6

Thicket 23 2.8

Thicket hawthorn species (Crataegus spp.), box elder, 

dogwoods

23 2.8

Total 833
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(a) Vegetative cover types are based on the MDNR’s (2006a) Wildlife Action Plan.

(b) Percentages represent the percent of the undeveloped portion of the site (excluding water) that the cover type 

represents.

Source: DECo 2011b; NRC 2013a

Coastal Emergent Wetland

Coastal emergent wetland is the most prevalent terrestrial habitat on the Fermi site and 

accounts for approximately 32.8 percent of the site’s undeveloped terrestrial land cover.

The largest area of coastal wetland on the site includes the North and South Lagoons and an 

unnamed drainage corridor that flows from the west. The hydrology of the coastal emergent 

wetlands is controlled almost entirely by variations in Lake Erie and Swan Creek surface water

elevations (DECo 2011a). During the 2006 through 2008 study, Black & Veatch estimated that 

only about 238 ac (96 ha) of coastal emergent wetland is vegetated and that the remaining area 

that is so designated (approximately 35 ac (14 ha)) is actually open water (DECo 2011b). 

However, the extent of emergent vegetation appears to fluctuate annually depending on Lake 

Erie water levels with more open water in high-water years and less open water in low-water 

years. For example, water conditions were relatively high in 1981 and relatively low in 2005. 

Aerial photographs from 2005 show a marked increase in emergent vegetation in the lagoons 

(NRC 2013a).

Presently, site lagoons are dominated by dense and extensive stands of common reed 

(Phragmites australis) and cattail (Typha spp.). Purple loosestrife (Lythrum salicaria), an 

invasive non-native herbaceous wetland species, is present throughout most of the coastal 

emergent wetlands on the Fermi site. The west-side drainage corridor has virtually no open 

water because of the dense growth of common reed, cattails, and purple loosestrife. These 

dense stands of non-natives likely provide low-quality habitat for wildlife, especially waterfowl. 

However, some species of songbirds, including the red-winged blackbird (Agelaius phoeniceus), 

use the cattails and reeds for nesting. Moderately shallow areas of the South and North 

Lagoons and the South Canal contain stands of American lotus (Nelumbo lutea), which is a 

State-threatened species. Section 3.6.5.1 discusses the American lotus in detail. Most of the 

South Lagoon is shallow and contains fill deposits. Wading birds, such as egrets and other 

herons, use these shallow water areas for foraging.

Forest

Forest accounts for 30.6 percent of the undeveloped portion of the Fermi site and is the second 

most prevalent terrestrial habitat type. Three types of forested habitat occur on the site: 

(1) coastal shoreline, (2) lowland hardwood, and (3) woodlot.

Coastal Shoreline. Forested coastal shoreline consists of a narrow, interrupted band along 

Lake Erie. This cover type accounts for about 47 ac (19 ha) or 5.6 percent of undeveloped land 

cover. The area is dominated by large eastern cottonwoods (Populus deltoides), some of which 

are 2 ft (0.3 m) or more in diameter at breast height (DBH), and peachleaf willow (Salix

amygdaloides). Box elder (Acer negundo) is also scattered in the area. Green ash (Fraxinus 

pennsylvanica) was formerly common in the area before the emerald ash borer (Agrilus 

planipennis), an invasive beetle, killed virtually all ash trees on the site. Shrub growth varies 

from dense to sparse depending on lake exposure and the extent of high-water ponding. 

Ground cover is sparse in heavily shaded areas, whereas the edges of the coastal shoreline 

habitat include dense stands of reed canarygrass (Phalaris arundinacea). Several forbs, 

including stinging nettle (Urtica dioica), are present as many forbs can grow in sandy soils and 
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are capable of withstanding fluctuations in moisture availability. Several unexpected native and 

introduced species also occur in this habitat that have likely dispersed through water from other 

areas of Lake Erie. Examples of such species include jimson-weed (Datura strumonium) and 

clammy-weed (Polanisia dodecandra) (NRC 2013a).

Lowland Hardwood. Lowland hardwoods represent the most mature vegetation on the Fermi 

site. This cover type accounts for about 92 ac (37 ha) or 11.0 percent of undeveloped land 

cover and occurs immediately northeast of the quarry lakes and within the south-central portion 

of the site along the west side of the South Lagoon. Eastern cottonwood and peachleaf willow 

are present, but oaks (Quercus spp.), American basswood (Tilia americana), and hickories 

(Carya spp.) are more dominant. Overall, this habitat is drier and more stable than the coastal 

shoreline habitat, and the topsoil is organic or composed of clay rather than sand. The largest 

trees occur in the area northeast of the quarry lakes where many specimens range from 18 to 

26 in. (0.46 to 0.66 m) DBH. In the south-central area, some trees reach this size, but most are 

less than 14 in. (0.36 m) DBH. Scattered stumps indicate that larger trees in this area were 

likely logged before the construction of Fermi 2. Shrubs are widely scattered in the understory. 

Ground cover is generally sparse but consists of a variety of woodland species, such as 

woodland bluegrass (Poa sylvestris), scattered sedges (Carex spp.), Enchanter’s nightshade 

(Circaea lutetiana), false spikenard (Smilacina racemosa), and Virginia stickseed (Hackelia

virginiana). Poison ivy (Toxicodendron radicans) and wild grapes (Vitis spp.) are also common

(NRC 2013a).

Woodlot. Woodlots occur in the east-central and northwestern portions of the Fermi site and 

account for about 117 ac (47 ha) or 14.0 percent of the undeveloped land cover. These areas 

primarily lie above fill material from the construction of Fermi 1 and 2 or on land otherwise 

heavily disturbed by construction activities. Until the early 2000s, the tree canopy was well 

developed and composed mostly of eastern cottonwood, box elder (Acer negundo), and green 

ash. Since that time, the canopy has become more open because of the loss of almost all the 

site’s green ash trees to the invasive emerald ash borer. As a result, the majority of the 

understory is composed of tree saplings of various species. Introduced tree species, such as 

the tree of heaven (Ailanthus altissimus), are also present. Poison ivy, wild grape, and trumpet 

creeper (Campsis radicans) vines form localized thickets, and the non-native invasive shrub 

species European privet (Ligustrum vulgare) and common buckthorn (Rhamnus cathcartica) are 

relatively common. Ground cover is generally sparse and composed mostly of aggressive 

native plant species and non-native invasive plant species. Some of the more common 

herbaceous species include burdock (Arctium minus) and heal-all (Prunella vulgaris), both of 

which are native, and the highly invasive garlic mustard (Alliaria petiolata) (NRC 2013a).

Grassland

Grassland accounts for 20.2 percent of the undeveloped portion of the Fermi site. Three types 

of grasslands occur on the site: right-of-way grasslands; idle, old field, or planted grasslands; 

and agricultural fields used for growing row crops.

Right-of-way. Right-of-way grasslands encompass 29 ac (12 ha) or 3.5 percent of the site’s 

undeveloped land cover. Right-of-way grasslands may be associated with roadways, rail lines, 

transmission lines, pipelines, and other linear features. On the Fermi site, the onsite 

transmission line corridor accounts for the majority of this land cover type. DTE, in coordination 

with the NRCS, Ducks Unlimited, ITC Transmission, and the FWS, began restoring the corridor 

habitat to native prairie beginning in 2005. Section 3.6.5.2 discusses this effort in more detail in 

the subsection entitled, “Restored Prairie Habitat.”

Idle, Old Field, or Planted. Idle, old field, or planted land comprises 75 ac (30 ha) or 

9.0 percent of the site’s undeveloped land cover and consists of land that had once been 
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cleared for agriculture or other purposes and that has now been taken over in part by 

opportunistic plants. In some cases, these areas were initially planted with a cover grass, such 

as perennial brome (Bromus spp.) or fescues (Fescue spp.). Smooth brome grass (Bromus 

ramosus ssp. ramosus) often dominates these areas, but other opportunistic (weedy and 

invasive) native and introduced species, such as Canada thistle (Cirsium arvense), Canada 

goldenrod (Solidago canadensis), and flattop-fragrant goldenrod (Euthamia graminifolia), are 

also common. Native shrubs, such as blackberry (Rubus spp.), and non-native invasive shrubs, 

such as multiflora rose (Rosa multiflora), are also present but are not dominant (NRC 2013a).

Row Crop. Row crops represent agricultural fields that are planted with a single species, such 

as corn (Zea mays) or soybeans (Glycine max), and that are harvested annually (NRC 2013a). 

Approximately 64 ac (26 ha) or 7.7 percent of the undeveloped land consists of this cover type 

(NRC 2013a). DTE leases this land to private individuals (DECo 2011b). According to 

NRCS (1997) maps, a portion of the leased cropland contains prime farmland.

Shrubland

Shrublands include upland areas with relatively dry soils that are dominated by deciduous 

shrubs. Approximately 113 ac (45.7 ha) or 13.6 percent of the site’s undeveloped land cover is 

shrubland. Most of the site’s shrubland lies in areas that were filled or otherwise extensively 

disturbed by development of Fermi 1 and 2 with the possible exception of some shrubland in the 

extreme southeastern corner of the site. Dogwoods (Cornus spp.), common buckthorn, 

multiflora rose, and blackberries are among the dominant species. Tree saplings, such as 

honey locust (Gleditsia triacanthos), eastern cottonwood, and green ash, are common, and 

grasses and forbs generally form substantial ground cover. Many introduced or opportunistic 

species, including smooth brome grass, prickly lettuce (Lactuca serriola), Canada goldenrod, 

and Missouri ironweed (Vernonia missurica), are likely the result of past habitat disturbances

(NRC 2013a).

Thicket

The 23 ac (9.3 ha) of thicket on the Fermi site are generally located in transitional areas 

between wetlands and uplands. This cover type occurs at lower elevations than the shrubland 

cover type does; however, like shrubland, it is in a successional stage that is likely to transition 

to forest conditions over time. The site’s thickets are densely covered with saplings of eastern 

cottonwood, peachleaf willow, and green ash, as well as small trees, such as hawthorns 

(Crataegus spp.) and box elder. Common shrubs include European privet and dogwoods. 

Poison ivy is abundant, and ground cover is sparse except in a few open areas (NRC 2013a).

3.6.3.2 Animals

As described in Section 3.6.2, Black & Veatch conducted initial wildlife surveys of the Fermi site

from November 2006 through May 2008 (DECo 2011b) and more detailed surveys from 

July 2008 through April 2009 (Black & Veatch 2009d). Black & Veatch (2009b) also conducted 

focused surveys for Federally and State-listed birds, mammals, reptiles, and amphibians. 

Cardno JFNew conducted surveys for Federally and State-listed threatened and endangered 

species on the Fermi site (Kogge and Heslinga 2013) in July and August 2013 and performed a 

supplemental assessment (Kogge 2014) in September 2014 in response to proposed rules to 

Federally list the red knot and northern long-eared bat. These surveys and the NRC’s FEIS for 

the Fermi 3 COL (NRC 2013a) inform the description of the animals present on the Fermi site.
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Birds

Birds in the Fermi 2 region include year-round residents, seasonal residents, and transients 

(birds stopping briefly during migration). Lake Erie, on which Fermi 2 lies, is within the Atlantic 

flyway, one of several major migratory flyways in North America.

In preconstruction surveys, NUS Corporation (1974) identified about 150 bird species that were 

known to occur or were likely to occur on or near the Fermi site. In its July 2008 through June 

2009 wildlife survey, Black & Veatch (2009b) identified a total of 118 bird species on the Fermi 

site across four survey sessions (74 species in July, 57 in October, 29 in January, and 79 in 

April). The five most abundant species across all survey sessions were ring-billed gull (Larus

delawarensis), European starling (Sturnus vulgaris), mallard (Anas platyrhynchos), red-winged 

blackbird, and double-crested cormorant (Phalacrocorax auritus), which together accounted for 

60 percent of the total number of birds observed (Black & Veatch 2009b). These species were 

especially common in small flocks or large assemblages during migratory periods (October and 

April survey sessions) (Black & Veatch 2009b).

Black and Veatch (2009b) observed some habitat segregation among species. Generally, gulls, 

ducks, cormorants, and geese dominated the Lake Erie shoreline. Warblers, flycatchers, and 

other songbirds were most commonly observed or heard calling in wooded areas. Interior forest 

species, such as ovenbird (Seiurus aurocapilla) and veery (Catharus fuscescens), were absent, 

which Black & Veatch (2009b) attributed to past site disturbance and unsatisfactory forest size, 

structure, and maturity. Species that depend on large grassland tracts, such as Henslow’s 

sparrow (Ammodramus henslowii) were also absent, whereas species tolerant of edge habitats, 

such as American robin (Turdus migratorius), blue jay (Cyanocitta cristata), Northern cardinal 

(Cardinalis cardinalis), European starling, American goldfinch (Spinus tristis), and several 

sparrow species, were found within the site’s grassland and prairies. Red-tailed hawks (Buteo

jamaicensis) were found to use transmission line towers as hunting perches in the right-of-way 

grasslands, and bald eagles (Haliaeetus leucocephalus) were observed along the Lake Erie 

waterfront. Black & Veatch (2009b) observed evidence of both red-tailed hawks and bald 

eagles nesting on the site. Other raptors, including the broad-winged hawk (Buteo platypterus), 

northern harrier (Circus cyaneus), osprey (Pandion haliaetus), and peregrine falcon (Falco

peregrinus), were seen hunting or flying overhead, but no signs of nesting were observed. 

Herons, egrets, and other wading birds were usually present along the Lake Erie shoreline near 

the dredge disposal pond or within marshes throughout the site when water levels were low 

enough to create mud flats in these areas.

Mammals

The Fermi site is surrounded by high chain-linked fences, which likely inhibit larger mammals 

from entering the site (DTE 2014d). However, individuals can gain access to the site through 

the Lake Erie waterfront, North Lagoon area, and through entrance roadways.

During its 2008 through 2009 survey, Black & Veatch (2009b) recorded observations of 

mammals and any signs (scat, tracks, rubs, or discarded hair) that could be attributed to a 

particular species. The survey identifies 16 mammals that occur on the site (Table 3–10), many 

of which are small rodents. The most commonly observed mammal was the white-tailed deer 

(Odocoileus virginianus). Coyote (Canis latrans), eastern cottontail (Sylvilagus floridanus), 

eastern fox squirrel (Sciurus niger), groundhog (Marmota monax), muskrat (Ondatra zibethica), 

and raccoon (Procyon lotor) were also common. The least encountered species were nocturnal 

species, such as the striped skunk (Mephitis mephitis) and Virginia opossum (Didelphis

virginianus); shrews; and other small rodents.
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Black & Veatch (2009b) found most mammals to be relatively nonselective in their habitat 

preferences (i.e., occurring in both remote locations and locations near human activity). Distinct 

white-tailed deer trails were generally present in wooded areas, thickets, and other areas of 

dense vegetative cover. Eastern fox squirrels were only observed in distant wooded areas of 

the site.

Mammals Observed on the Fermi Site, 2008–2009

Common Name Species Name Abundance(a)

coyote Canis latrans Common

deer mouse Peromyscus maniculatus Infrequent

domestic cat Felis catus Obscure

eastern cottontail Sylvilagus floridanus Common

eastern fox squirrel Sciurus niger Common

eastern gray squirrel Sciurus carolinensis Obscure

groundhog Marmota monax Common

meadow vole Microtus pennsylvanicus Obscure

muskrat Ondatra zibethica Common

northern short-tailed shrew Blarina brevicauda Obscure

raccoon Procyon lotor Common

red fox Vulpes vulpes Obscure

striped skunk Mephitis mephitis Infrequent

Virginia opossum Didelphis virginianus Obscure

white-footed mouse Peromyscus leucopus Obscure

white-tailed deer Odocoileus virginianus Common

(a) Black & Veatch (2009b) defined abundance classes for mammals as follows:

• Common = appears in three or more (out of four total) survey sessions.

• Occasional = appears in two survey sessions or in one session with more than 

10 individuals.

• Infrequent = appears in only two survey sessions.

• Obscure = observed in only one survey session with less than 10 individuals.

Source: Black & Veatch 2009b

Reptiles and Amphibians

The lagoons, other wetlands areas, and adjacent habitats on the Fermi site provide substantial 

areas of potential habitat for amphibians and reptiles. However, direct and indirect observations

have been infrequent both in recent and past studies (NRC 2013a).

During the 2008 through 2009 wildlife survey, Black & Veatch (2009b) observed four reptile 

species and six amphibians (Table 3–11). All of the observed amphibians were frogs and were 

observed in or near wetlands. Black & Veatch (2009b) conducted call surveys to identify these 

species. Wetlands near roads were selected for listening based on the audible presence of 

singing or calling frogs or toads, and listening was conducted for at least 5 minutes at 13 locations 

representing approximately 40 percent of the wetlands on the Fermi site. During the April survey 
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session, the western chorus frog (Pseudacris triseriata triseriata) and American toad (Bufo 

americanus) were heard. In July 2008, the American toad, bullfrog (Rana catesbeiana), and 

green frog (Rana clamitans melanota) were heard. Additional incidental observances included 

one road-killed and one live pickerel frog (Rana palustris) in October 2008 and a northern leopard 

frog (Rana pipiens) during the May 2009 vegetation sampling.

Reptiles were most closely associated with vegetation bordering wetlands and other wet areas. 

The midland painted turtle (Chrysemys picta marginata) was the most commonly observed 

reptile and was present in three out of the four survey sessions. Black & Veatch (2009b) notes 

that both reptiles and amphibians are likely underrepresented in the survey because occurrence 

and abundance was determined based on encounter rates during the survey.

Black & Veatch (2009b) did not observe any salamanders, although the study notes that the site 

potentially provides habitat for seven species, including the blue-spotted salamander 

(Ambystoma laterale), eastern newt (Notophthalmus viridescens), eastern tiger salamander 

(Ambystoma tigrinum tigrinum), and spotted salamander (Ambystoma maculatum). The 

wooded portion of the site includes scattered pools that appear suitable for use by salamanders, 

but most of the pools do not have substantial invertebrate populations other than mosquitoes 

and may not represent usable salamander forage or breeding habitat (Black & Veatch 2009b).

Reptiles and Amphibians Observed on the Fermi Site, 2008–2009

Common Name Species Name Abundance(a)

Reptiles

Blanding’s turtle Emydoidea blandingii Obscure

eastern fox snake(b) Pantherophis gloydi n/a(c)

eastern garter snake Thamnophis sirtalis sirtalis Occasional

midland painted turtle Chrysemys picta marginata Common

queen snake Regina septemvittata Obscure

Amphibians

American toad Bufo americanus Infrequent

bull frog Rana catesbeiana Obscure

green frog Rana clamitans Obscure

northern leopard frog Rana pipiens Obscure

pickerel frog Rana palustris Obscure

western chorus frog Pseudacris triseriata triseriata Obscure

(a) Black & Veatch (2009b) defined abundance classes for mammals as follows:

• Common = appears in three or more (out of four total) survey sessions.

• Occasional = appears in two survey sessions or in one session with more than 10 individuals.

• Infrequent = appears in only two survey sessions.

• Obscure = observed in only one survey session with less than 10 individuals.

(b) Black & Veatch (2009b) did not observe this species during its survey but noted that it had been 

observed in wetlands west of Doxy Road by Ducks Unlimited field staff while conducting a wetland 

delineation of the Fermi site in May and June 2008.

(c) Black & Veatch (2009b) did not assign an abundance designation to this species because it was not 

observed during the survey.

Source: Black & Veatch 2009b
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3.6.4 Fermi 2 Wildlife Management Plan

The Fermi 2 Wildlife Management Plan (DECo 2000) outlines the goals and projects of DTE’s 

Wildlife at Work program. Some of the plan’s goals include conducting regular site inventories 

of native plant and animal species, providing nesting structures for select native birds on the 

site, enhancing wildflower habitat on the site, and monitoring and removing problematic invasive 

species. DTE first received WHC certification for its plan in 2000 (DTE 2014g), and it most 

recently received recertification in October 2014 (WHC 2014). WHC certification lasts for 2-year 

periods. DTE intends to seek WHC recertification and to continue to implement wildlife 

protection programs during the proposed license renewal term (DTE 2014g).

3.6.5 Important Species and Habitats

3.6.5.1 Important Species

Michigan’s Natural Resources and Environmental Protection Act 451 of 1994, as amended 

(NREPA), Part 365, “Endangered Species Protection,” contains provisions for the protection of 

species deemed to be endangered or threatened at the State level. The NREPA designates the 

MDNR as the agency responsible for determining which species should be listed as 

State-endangered or State-threatened and for managing protection and recovery programs. 

The act also prohibits the take of State-listed species unless a person or party first receives an 

Endangered Species Permit from the MDNR Wildlife Division.

Within Monroe County, the Michigan Natural Features Inventory (MNFI) natural heritage 

database indicates that 87 State-listed terrestrial species (49 flowering plants, 13 insects, 

11 birds, 8 snails, 4 reptiles, and 2 amphibians) occur in Monroe County (MSUE 2014). In 

September 2013, the Michigan State University Extension (MSUE), on behalf of the MDNR, 

provided DTE with records from the MNFI’s natural heritage database on known occurrences 

and localities of rare species and unique natural features near the Fermi site. Of the 

87 State-listed terrestrial species in Monroe County, MSUE (2013) identified 7 species with 

known occurrences within 1.5 mi (2.4 km) of the Fermi site. Table 3–12 lists these species, and 

each species is discussed in detail in this section.

Rare Species with Known Occurrences within 

1.5 mi (2.4 km) of the Fermi Site

Species Common Name Status(a)

Recorded Occurrence

on Fermi site? (Y/N)

Birds

Haliaeetus leucocephalus bald eagle SSC Y

Sterna hirundo common tern ST Y

Tyto alba barn owl SE N

Flowering Plants

Nelumbo lutea American lotus ST Y

Sagittaria montevidensis giant arrowhead ST N

Strophostyles helvula trailing wild bean SSC N

Reptiles

Pantherophis gloydi eastern fox snake ST Y

(a) SE = State-endangered; ST = State-threatened; and SSC = State species of concern.

Sources: MSUE 2013, 2014
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Bald Eagle

The bald eagle is a large, blackish-brown eagle with a white head and tail and heavy yellow bill. 

The species typically inhabits lakes, rivers, marshes, and seacoasts and nests in tall trees or on 

top of buildings or cliffs. The bald eagle regularly occurs on and in the vicinity of the Fermi site, 

and DTE has observed nests on site property in recent years. In late 2007, DTE (2014d) 

personnel observed three bald eagle nests in large trees along the shoreline of Lake Erie. Only 

two nests remained following a series of winter storms in 2007 through 2008; by spring 2008, 

eagles continued to occupy only one of the two nests (DTE 2014d). In late May 2012, 

DTE (2014d) personnel observed a new nest with chicks near the site’s firing range, and an 

additional active nest was identified near the dredge basin along the Lake Erie shoreline in early 

spring 2013. As of August 2014, DTE (2014g) personnel had identified an additional nest near 

the firing range. In addition to the nests, Black & Veatch (2009b) observed individuals during all 

of its 2008 through 2009 survey sessions. Black & Veatch (2009b) observed three fledglings in 

October 2008, several fledglings and subadults in January 2009, and one subadult in 

April 2009. Black & Veatch (2009b) noted that the successful fledging of eaglets indicates that 

bald eagles do not appear to be affected by ongoing site activity. Kogge and Heslinga (2013) 

observed several bald eagles in flight in July and August 2013.

In addition to being a Michigan species of special concern, bald eagles are protected under the 

Bald and Golden Eagle Protection Act of 1940, as amended (BGEPA) (16 U.S.C. 668 et seq.). 

This Federal act prohibits anyone from taking or disturbing bald eagles or golden eagles (Aquila 

chrysaetos), including their nests or eggs, without an FWS-issued permit. The BGEPA defines 

the term “take” to mean to “pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, 

destroy, molest, or disturb” (50 CFR 22.3). “Disturb” means to take action that causes, or is 

likely to cause, (1) injury to an eagle, (2) decreases its productivity by substantially interfering 

with normal breeding, feeding, or sheltering behavior, or (3) nest abandonment (50 CFR 22.3). 

DTE maintains site procedures that ensure that personnel consider any potential environmental 

impacts before performing work on site (Section 4.6.1.2). Such impacts include those that may 

require a bald eagle take permit. Although DTE has initiated communications with the FWS 

pursuant to the BGEPA on several occasions, no site activities have required DTE to obtain a 

bald eagle take permit to date (DTE 2012, 2014g; FWS 2012).

Common Tern

The common tern (Sterna hirundo) is a medium-sized tern that is grayish-white in color with a 

black cap and wingtips. Common terns typically inhabit sand and gravel beaches and nest in 

shallow scrapes of bare sand between mid-May and early July (MNFI 2014d). Individuals often 

nest on islands to avoid human disturbance and terrestrial predators (MNFI 2014d). The 

MSUE (2013) reports that common terns have been observed nesting near the Fermi site. The 

MNFI (2014d) and the Audubon Society’s Michigan Bird Records Committee (Audubon 2013) 

has not documented the species in Monroe County since the mid-1980s. However, Black &

Veatch observed the species on the Fermi site during the November 2006 through 2008 

reconnaissance surveys documented in the Fermi 3 COL application ER (DECo 2011b). Black 

& Veatch (2009b) also observed two individuals during the 2008 through 2009 survey. 

However, given the large resident population of gulls that inhabit the Fermi 2 intake area, Black 

& Veatch (2009b) concluded that common terns were unlikely to use the available coastal 

habitat on site for nesting. Kogge and Heslinga (2013) considered the species to have a 

“moderate or high potential to occur within the assessment area” based on previous site studies 

but did not observe the common tern during its 2013 threatened and endangered species 

assessment and did not find the site to contain optimal habitat for the species.
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Barn Owl

The barn owl (Tyto alba) is a crow-sized owl with a buff to brown back and white face and 

underside. Its heart-shaped face distinguishes it from other owls. The species uses a wide 

variety of open habitats, including wet prairie, coastal plain marshes, emergent marshes, and 

oak barrens, but it is less common where intensive agriculture dominates the landscape 

(MNFI 2014f). The MSUE (2013) reports that barn owls have been known to nest along 

Post Road to the north of the Fermi site. Barn owls nest in hollow trees, buildings, or nest 

boxes between early April and late July (MNFI 2014f). According to MNFI (2014f) and the 

Audubon Society’s Michigan Bird Records Committee (Audubon 2013), the species has not 

been documented in Monroe County since the early 1980s. Additionally, none of the Fermi site 

surveys or reports (AEC 1972; Black & Veatch 2009b; Kogge and Heslinga 2013; NRC 1981; 

NUS 1974) have documented this species. Specifically, in the 2008-2009 Black & Veatch 

study, particular emphasis was placed on surveying suitable habitat for barn owls. The survey 

identified no suitable nesting or roosting habitat due to the absence of large mature trees (Black 

& Veatch 2009b). Black & Veatch (2009b) also conducted night call surveys that included barn 

owl calls. However, none of the survey sessions resulted in a response by a barn owl.

American Lotus

The American lotus is a marsh-dwelling perennial emergent plant that grows from thick tubers 

and flowers in mid-summer (DTE 2014d). It is often associated with water-plaintain 

(Alisma spp.), sedges (Carex spp.), spike-rush (Eleocharis palustris), cattail, water-milfoil 

(Myriophyllum spp.), pondweed (Potamogeton nodosus), and other emergent marsh plants 

(MNFI 2014a). The species occurs in aquatic beds throughout the Fermi 2 property and is 

particularly abundant in the site’s north and south lagoons (DTE 2014d). Kogge and 

Heslinga (2013) estimate that the total area of American lotus on the site is approximately 65 ac 

(26 ha), which represents a regionally significant population. In most areas where it occurs on 

site, American lotus is the dominant species and forms a significant aquatic/deepwater wetland 

community together with other submergent and aquatic plant species (Kogge and 

Heslinga 2013).

Giant Arrowhead

The giant arrowhead (Sagittaria montevidensis) is an emergent wetland plant with broad 

arrow-shaped leaves, white flowers, and sepals closely cupped around the flower and fruit 

(MNFI 2014c). It grows on wet to shallowly inundated mud flats, lagoons, and estuaries that are 

exposed to fluctuating water levels (MSUE 2013). Southeastern Michigan represents the 

species’ northern distribution limit (Black & Veatch 2009a). Although MSUE (2013) indicates 

that the species has been known to occur on the Fermi site, the available site surveys and 

reports (Black & Veatch 2009a; DeCo 2000; Kogge and Heslinga 2013; NRC 1981; NUS 1974) 

did not identify this species on the site. The FES-C (AEC 1972) indicates that arrowhead 

occurs within site marshes, but the AEC only provides the genus (Sagittaria); therefore, it is 

unclear whether the report is referring to the presence of the State-threatened giant arrowhead 

or another unprotected arrowhead species. The MNFI (2014c) reports this species as occurring 

in Monroe County as recently as 2001.

Trailing Wild Bean

The trailing wild bean (Strophostyles helvula) is a twining to trailing annual vine that inhabits 

open, moist, sandy soil on disturbed roadsides, ditch banks, beaches, and dunes in or near 

emergent marsh or mesic sand prairie habitats. It produces pinkish, pea-like flowers and 

greenish pods that coil after seed dispersal. As a special concern species, the trailing wild bean 

is not legally protected under Michigan’s endangered species legislation, but the MDNR 
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considers the remaining population to be small enough that continued decline could necessitate 

its reclassification as a State-threatened or -endangered species (MSUE 2013). The 

MNFI (2014e) indicates that the species was last observed in Monroe County in 1985. None of 

the available site surveys or reports (AEC 1972; Black & Veatch 2009a; DeCo 2000; Kogge and 

Heslinga 2013; NRC 1981; NUS 1974) have recorded this species as occurring on the site.

Eastern Fox Snake

The eastern fox snake (Pantherophis gloydi) is a large snake with dark brown to black blotches 

down the middle of the back and smaller, alternating blotches along the sides of its yellowish 

body. The species inhabits emergent wetlands along Great Lakes shorelines, as well as drier 

habitats, including vegetated dunes, beaches, old fields, and open woodlands (MNFI 2014b). 

Individuals may also use disturbed areas, such as pastures, woodlots, vacant urban lots, rock 

riprap, ditches, dikes, and residential properties (Black & Veatch 2009b). Eastern fox snakes 

inhabit marsh and wetland on the Fermi site. The species was first observed within site 

wetlands west of Doxy Road in May and June 2008 during the Ducks Unlimited wetland 

delineation effort (Black & Veatch 2009b). The species was not observed during the 2008

through 2009 Black & Veatch (2009b) wildlife surveys but was again observed on a sand/gravel 

beach on the northern edge of the site during the Kogge and Heslinga 2013 survey.

As part of the preparation for construction and operation of the proposed Fermi 3, DTE 

developed a Habitat and Species Conservation Plan for the eastern fox snake (DECo 2012a). 

The plan includes measures to minimize or mitigate impacts to the eastern fox snake. Such 

measures include educating employees through use of a fox snake manual, adding the eastern 

fox snake to pre-job brief checklists to reinforce the issue before work begins each day, having 

a biologist capture and release snakes observed in developed areas before the commencement 

of work in those areas, and reporting of eastern fox snake sightings on the site.

For Fermi 2, DTE uses some similar measures to minimize impacts to the eastern fox snake. 

For instance, in accordance with Site Procedure MCE06, “Non-Radiological Environmental 

Protection,” DTE personnel must include a Protected Species Protection Plan in the work 

package for any activities planned in undeveloped areas of the site unless the environmental 

engineer’s work package review determines that such a plan is not needed (DTE 2014g). The 

pre-job brief for such work would include an explanation of the plan and the responsibilities of 

workers to prevent harm to protected species. If a protected species were to be harmed during 

the work, DTE personnel would prepare a Corrective Action Resolution Document (CARD), 

which would require followup action (DTE 2014g). For instance, in 2013, two eastern fox 

snakes were killed on site roadways; in response to these events, the site Wildlife Habitat 

Committee placed eastern fox snake signs on site roads to increase awareness following these 

events, and DTE implemented an awareness campaign through the site’s daily update meetings 

(DTE 2014g). Because DTE maintains these administrative controls and because DTE does 

not anticipate any impact to habitat occupied by the snake as a result of continued operation of 

Fermi 2 during the proposed license renewal term, DTE has not implemented a specific 

mitigation plan for eastern fox snakes, and it has not found reason to seek a take permit from 

the MDNR (DTE 2014g).

3.6.5.2 Important Habitats

Detroit River International Wildlife Refuge

The DRIWR consists of nearly 6,000 ac (2,400 ha) of coastal wetlands, marshes, shoals, 

waterfront lands, and islands along 48 mi (77 km) of shoreline on the lower Detroit River and 

western shore of Lake Erie (FWS 2014f). Congress established the DRIWR in 2001, and it is 

the only International Wildlife Refuge in North America. The refuge contains bottomland 
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hardwoods, glacial lakeplain prairie, coastal plain pond communities, and a variety of wetland 

types (FWS 2005). The refuge’s coastal marshes are used by as many as 17 species of 

raptors, including eagles, hawks, owls, and falcons, as feeding and resting habitat, and by as 

many as 48 species of nonraptors, including waterfowl, loons, herons, egrets, terns, and 

neotropical migrant songbirds that migrate through the Detroit River area each year 

(FWS 2005). The FWS (2005) maintains a Comprehensive Management Plan for the refuge 

that includes plans for restoration of the Lake Erie shoreline, control of exotic species, and 

development of private land partnerships to enable restoration of wetlands, grasslands, stream 

channels, and riparian corridors used by Federal trust resources (migratory birds, Federally 

listed species, and interjurisdictional fish).

Since September 2003, DTE has maintained a cooperative agreement with the FWS to allow 

the FWS to manage 62.6 percent (656 ac (265 ha)) of the site’s natural areas as part of the 

DRIWR (DECo 2011b; DECo and FWS 2003). The DRIWR lands on the Fermi site constitute 

the DRIWR Lagoona Beach Unit, and the general public does not have access to this unit 

(DTE 2014d; DECo 2011b). The Lagoona Beach Unit consists of the following four sections 

(Figure 3–8):

(1) DRIWR-1 lies in the northern portion of the Fermi site and consists of coastal 

wetlands and palustrine systems, including freshwater emergent wetlands and 

semi-permanently flooded lake areas (DTE 2014d).

(2) DRIWR-2 lies south of DRIWR-1 in the northwestern portion of the site. It includes 

coastal wetlands, upland forests, wet meadows, and coastal prairies, as well as 

palustrine scrub-shrub systems. This unit is seasonally inundated (DTE 2014d).

(3) DRIWR-3 lies in the southwest portion of the site and includes upland forests and 

palustrine forests with broad-leaved deciduous vegetation. It is seasonally inundated 

or partially drained throughout the year (DTE 2014d).

(4) DRIWR-4 lies in the south-southeast portion of the site and includes coastal 

wetlands and upland forest composed on palustrine forested and seasonally 

inundated areas (DTE 2014d).

DTE intends to maintain the cooperative agreement with the FWS for management of the 

DRIWR Lagoona Beach Unit throughout the proposed license renewal term. However, if 

Fermi 3 is built, small modifications to the refuge acres would be required for temporary 

construction buildings and laydown, and some small permanent impacts would occur due to a 

new site access road and meteorological tower (DTE 2014g). Section 4.16.4 discusses these 

cumulative impacts in more detail.

Delineated Wetlands

The National Wetlands Inventory indicates that 31 types of wetlands totaling approximately 

1,508 ac (610 ha) lie within a 6-mi (10-km) radius of the Fermi site (DTE 2014d). Within 

Michigan, the MDEQ administers Section 404 of the Federal Water Pollution Control Act 

of 1972, as amended (referred to as the CWA). The MDEQ issues Section 404 permits, which 

are required for actions that result in the discharge of dredge or fill material into wetlands that 

are considered waters of the United States. Within Michigan, some wetlands in coastal areas, 

including those on the Fermi site, are further protected under Act 451, NREPA, Part 323, 

“Shorelands Protection and Management.”

As previously described, Ducks Unlimited performed wetland delineation on 1,106 undeveloped 

acres (448 ha) on the Fermi site in 2008 and updated its Wetland Investigation Report in 2011 

to incorporate minor changes to the delineations provided by the MDEQ and the USACE. 
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During its wetland assessment, Ducks Unlimited (2011) identified 37 wetlands comprising 

52.8 percent (553.35 ac (223.74 ha)) of the undeveloped land on the Fermi site. The majority of 

the site’s wetlands are palustrine emergent marsh and palustrine forested. With the exception 

of a few wetlands isolated by roads or berms, most of the wetlands are hydrologically connected 

and are therefore part of one wetland system (DTE 2014d). Ducks Unlimited (2011) found the 

principal functions of the Fermi 2 wetland system to be (1) flood flow alteration, (2) sediment or 

toxicant retention, (3) nutrient removal, and (4) fish and wildlife habitat. Table 3–13 lists the 

total area of delineated wetlands on the site by wetland type. Figure 3–15 depicts the location 

of each of the 37 delineated wetlands on the Fermi site.

Delineated Wetlands on the Fermi Site by Area

Area

Wetland Type Acres Hectares

Palustrine Emergent Marsh (PEM) 318.03 128.70

Palustrine Forested (PFO) 166.73 67.47

Palustrine Scrub-Shrub (PSS) 16.15 6.54

PEM/Wooded Marsh (WM) 6.47 2.62

Open Water (OW) 45.04 18.03

PFO/PSS/PEM 0.93 0.38

Total 553.35 223.74

Source: Ducks Unlimited 2011

The site’s palustrine emergent marshes (PEM) are characterized by reed canarygrass, common 

reed, sedges, narrow-leaf cattail (Typha angustifolia), water lily (Nymphaea spp.), and coontail 

(Ceratophyllum demersum). These areas range from inundated wet meadows to deep water 

marsh systems, and herbaceous or small woody vegetation covers more than 50 percent of the 

ground surfaces (Ducks Unlimited 2011).

The palustrine forested (PFO) wetlands contain hydric soils with pockets of standing water. 

Dominant species include silver maple (Acer saccharinum), shellbark hickory (Carya laciniosa), 

swamp white oak (Quercus bicolor), American elm (Ulmus americana), and eastern cottonwood, 

and the shrub layer is dominated by American elm saplings, silky dogwood (Comus amomum), 

and green ash saplings. Herbaceous vegetation is sparse and includes black raspberry 

(Rubus spp.), mayapple (Podophyllum peltatum), reed canarygrass, poison ivy, and Virginia 

creeper (Parthenocissus quinquefolia) (Ducks Unlimited 2011).

Palustrine scrub-shrub (PSS) wetlands are characterized by herbaceous or woody vegetation 

constituting less than 50 percent of ground cover. On the Fermi site, these wetlands largely 

consist of early successional woody communities dominated by silky dogwood, green ash, and 

hawthorn (Ducks Unlimited 2011).

Open water areas are characterized by inundation to a depth of greater than 4 ft (1.2 m) with no 

emergent vegetation present (Ducks Unlimited 2011).
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Figure 3–15. Delineated Wetlands on the Fermi Site

Source: NRC 2013a, Figure 2-11

Restored Prairie Habitat

DTE has undertaken two prairie restoration projects on the Fermi site. DTE planted the first 

prairie in 2003 in coordination with the NRCS, Ducks Unlimited, ITC Transmission, and the FWS
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with the assistance of a grant under the North American Wetlands Conservation Act of 1989 

(16 U.S.C. 4401–4412) (DTE 2014d; NRC 2013a). The prairie occupies about 29 ac (12 ha) 

within the existing onsite transmission line corridor (NRC 2013a). The prairie is dominated by 

big bluestem (Andropogon gerardii) and Indiangrass (Sorghastrum nutans). Broomsedge 

(Andropogon virginicus), a less desirable native grass, is also relatively common in dense 

localized patches. Undesirable plants include purple loosestrife, common reed, and teasel 

(Dipsacus sylvestris) (NRC 2013a).

DTE, in conjunction with the FWS, restored a second area of tall-grass prairie of about 5 ac 

(2 ha) in the southeastern corner of the Fermi site. The prairie was planted in 2010 with a 

purchased tall grass seed mix. A July 2011 survey (DTE 2011) of the area revealed 38 native 

species within the prairie. Winged lythrum (Lythrum alatum), white blue-eyed grass 

(Sisyrinchium albidum), Indiangrass, dense blazing star (Liatris spicata), Canada wildrye 

(Elymus canadensis), and swamp milkweed (Asclepias incarnata) are among the dominant 

species (DTE 2011).

3.6.6 Bird Collisions and Strikes

Erickson et al. (2001) estimates that millions of birds are killed each year in the United States 

when they collide with manmade objects, including cooling towers, radio and television towers, 

buildings, vehicles, wind generation facilities, transmission lines, and numerous other objects. 

Bird mortality resulting from collisions with manmade structures is of concern if the stability of 

the local or migratory population of any bird species is threatened or if the reduction in numbers 

within any bird population significantly impairs its function within the ecosystem. Bird collision 

monitoring has been conducted at several nuclear power plants. Section 4.6.1.1 of

NUREG–1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants

(GEIS) (NRC 2013b), summarizes the results of these monitoring efforts. In the GEIS, the NRC 

(2013b) found that nuclear power plant operation does not represent a significant threat to 

overall bird populations and that there are no known instances in which bird collisions with plant 

structures or transmission lines have resulted in noticeable effects on local bird populations.

The FES-O for Fermi 2 (NRC 1981) notes that in September 1973, 50 dead birds of unspecified 

species were observed near the Fermi 2 cooling towers. In the FES-O, the NRC (1981) stated

that only a few dead birds were observed near the cooling tower following this event and until 

the issuance of the FES-O.

As part of the license renewal application review, DTE (2014g) provided data on the last 

10 years of bird strike occurrences (2005 through 2014), which is summarized in Table 3–14. 

Of particular note is DTE’s observation of 45 dead birds in a one-week period in October 2007

near the Fermi 2 south cooling tower. DTE (2014g) reports that the species is unknown, but 

that individuals may have been American goldfinches. Following this occurrence, DTE 

undertook a two-year surveillance effort during migration periods to determine the number and 

species of birds that were colliding with the cooling tower and other plant structures. During the 

surveillance period, the most bird mortalities identified in any given week was four individuals, 

and no Federally or State-listed bird species were identified. Following this effort, DTE 

developed Nuclear Licensing Work Instruction 11801, “Unusual or Important Environmental 

Events Reporting Guidelines,” that details reporting thresholds for “excessive bird impacts” and 

other unusual or important environmental events reportable to the NRC under Section 4.1 of 

Appendix B to the Fermi 2 operating license (DTE 2014g; NRC 1985). Table 3–14 lists the bird 

strike occurrences in the last 10 years (2005 through 2014), and Table 3–15 lists the results of 

the bird strike surveillance data from 2008 and 2009.
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Since DTE’s completion of its 2-year surveillance effort, DTE personnel have reported only two 

bird strikes, one of which was a bald eagle in October 2011. The bald eagle is a Michigan 

species of special concern and Federally protected under the BGEPA. Following this event, it 

was determined, after contacting the FWS, that no further followup action was necessary 

(DTE 2014g).

DTE’s bird strike records do not indicate that any Federally or State-listed species have collided 

with plant structures or transmission lines.

Bird Strike Occurrences, 2005–2014

Date Species and Number Description

May 31, 2005 unknown species 

(1 individual)

Mortality was due to collision with condenser fan. The

individual likely entered through an opening in fan 

louvered cover.

October 2007 unknown (possibly 

American goldfinch) (45)

The birds were found near Fermi 2 south cooling tower 

over a 1-week period.

May 5, 2009 unknown species (1) Mortality was due to a bird striking a ceiling fan inside 

of warehouse.

October 21, 2011 bald eagle (1) A dead eagle was found near the 120-kV switchyard. 

DTE communications with the FWS determined that 

further followup action was unnecessary.

August 28, 2012 goose (1) A dead goose was found with a singed wing beneath 

transmission line.

Source: DTE 2014g

Bird Strike Monitoring Data, 2008–2009

Date Species and Number Description

2008

March 27 European starling (4) The birds were found on the south cooling tower in an 

advanced state of decay.

April 18 house sparrow (Passer

domesticus) (1)

grackle (family Icterid) (2)

The birds were found on ground around the

meteorological tower.

April 29 yellow-rumped warbler 

(Setophaga coronata) (1)

The bird was found between cooling towers.

May 6 American goldfinch (1)

American robin (1)

The goldfinch was found on the deck of the south 

cooling tower. The robin was found in a parking lot.

May 7 Baltimore oriole (Icterus 

galbula) (1)

yellow-rumped warbler (1)

The birds were found on the ground around the 

meteorological tower.

May 22 ovenbird (1)

yellow-rumped warbler (1)

chestnut-sided warbler

(Setophaga pensylvanica)

(1)

The birds were found on the south cooling tower deck

or on the ground by the south tower.
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Date Species and Number Description

May 28 American redstart 

(Setophaga ruticilla) (1)

eastern wood pewee 

(Contopus virens) (1)

magnolia warbler 

(Setophaga magnolia) (1)

unspecified warbler (1)

The American redstart and eastern wood pewee were 

found on the south cooling tower deck. The magnolia 

warbler was found on the ground near the 

meteorological tower. The unspecified warbler was 

found partially eaten on the ground near the south

cooling tower deck.

2009

April 3 golden crowned kinglet 

(Regulus satrapa) (1)

The bird was found on the southeast side of the south 

cooling tower.

September 3 pigeon (1)

golden crowned kinglet (1)

The pigeon was found on the north cooling tower. 

The kinglet was found on the south cooling tower.

September 18 Philadelphia vireo (Vireo 

philadelphicus) (2)

One bird was found on the south cooling tower, and 

the other was found on the north cooling tower.

September 25 golden crowned kinglet (3)

unspecified warbler 

(possibly cerulean) (1)

The kinglets were found on the south cooling tower. 

The warbler was found on the north cooling tower.

October 2 unspecified birds (possibly 

kinglets) (4)

The birds were found on the south cooling tower.

Source: DTE 2014g

3.7 Aquatic Resources

This section describes the aquatic environment and aquatic biota in the vicinity of the Fermi site 

and other areas that could be affected by operation or maintenance of Fermi 2. This description 

of the aquatic environment is largely taken from the NRC’s Environmental Impact Statement for 

the COL application for the proposed Enrico Fermi Unit 3 (NRC 2013a) and has been updated 

as appropriate.

The Fermi site is located on 1,260 ac (510 ha) of developed and undeveloped land on the 

shoreline of the western basin of Lake Erie between Swan Creek and Stony Creek (Figure 3–3). 

Approximately 656 ac (265 ha) of this land (called the Lagoona Beach Unit) is managed as part 

of the DRIWR. As in many areas bordering the Great Lakes, coastal freshwater marshes are 

common in the vicinity of the Fermi site. These freshwater marshes play a pivotal role in the 

aquatic ecosystem of the Great Lakes, including storing and cycling nutrients and organic 

material from the land into the aquatic food web (Bouchard 2007). Most of the fish species in 

the Great Lakes depend on freshwater marshes during at least some portion of their life cycles 

(Wei et al. 2004). Freshwater marshes associated with the Great Lakes typically contain 

aspects of both riverine and lacustrine (standing water) habitats, are usually found in the vicinity 

of river mouths, and are influenced by both the level of the adjacent lake and riverine inflows. 

The Fermi site is located near the mouth of Swan Creek, which borders the site to the north, 

and it is surrounded by coastal freshwater marsh habitat. The largest water body near the site 

is Lake Erie, which borders the site to the east. Lake Erie provides cooling water and the Fermi 

site’s cooling water discharges back to Lake Erie (Section 3.1.3).
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3.7.1 Aquatic Resources—Site and Vicinity

The aquatic resources on the Fermi site and vicinity occur in a variety of natural and constructed 

freshwater habitats (Figure 3–12). The discussion of aquatic resources present within the 

potentially affected area is divided among the prominent surface water features associated with 

the site, including the following:

• circulating water reservoir,

• overflow and discharge canals,

• drainage ditches,

• quarry lakes,

• wetland ponds and marshes managed as part of the DRIWR,

• Swan Creek,

• Stony Creek, and

• Lake Erie.

3.7.1.1 Circulating Water Reservoir (Cooling Water Pond and Circulation Pond)

The CWR, a component of the heat dissipation system associated with the operation of Fermi 2, 

provides the cooling water for the CWS. The CWR is located east of the Fermi 2 cooling towers 

in the northern portion of the developed part of the Fermi site (Figure 3–12). This manmade 

reservoir encompasses an area of approximately 5 ac (2 ha), is approximately 20 ft (1.5 m) 

deep, and is clay-lined. Although the CWR is periodically treated with chemicals to inhibit 

excessive growth of vegetation and the production of aquatic organisms, some benthic 

organisms and aquatic vegetation do occur in the reservoir. Overall, the habitat provided by the 

CWR is not suitable for supporting significant populations of aquatic species.

3.7.1.2 Overflow and Discharge Canals

One clay-lined canal, approximately 5 to 10 ft (1.5 to 3 m) deep and 70 ft (21 m) wide, originates 

in the central portion of the Fermi site (along the western edge of the developed portion of the 

site) and extends northward where it connects with Swan Creek after passing through a marshy 

area known as the North Lagoon. This constructed canal is referred to as the overflow canal or 

the North Canal (Figure 3–12). This channel was historically used as a cooling water discharge 

and overflow canal for operation of Fermi 1 but ceased being used when Fermi 1 was shut 

down. The overflow canal is hydraulically connected to the wetlands to the west and provides 

the hydraulic connection between Lake Erie and the wetland area. Currently, the Fermi site 

uses the overflow canal as a permitted wastewater discharge (Outfalls 002, 003, 009, and 014)

(Figure 3–12). Section 3.1.3 further discusses the outfall and discharge points of the Fermi site. 

Thirty fish species were captured in the overflow canal during surveys conducted in 2008; the 

most abundant species were bluegill (Lepomis macrochirus), pumpkinseed (L. gibbosus), 

emerald shiner (Notropis atherinoides), and gizzard shad (Dorosoma cepedianum) 

(AECOM 2009).

A second manmade canal, referred to as the discharge canal or the South Canal, originates in 

the central portion of the Fermi site and extends southward where it flows into the South Lagoon

(Figure 3–12). This canal is approximately 5 to 10 ft (1.5 to 3 m) deep and 70 ft (21 m) wide 

and serves as the hydraulic connection between Lake Erie and the wetland areas located west 

of the developed portion of the Fermi site. Twenty-eight fish species were collected in the 

discharge canal during surveys conducted in 2008; the most abundant species were goldfish 
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(Carrasius auratus), common carp (Cyprinus carpio), bluegill, pumpkinseed, and golden shiner 

(Notemigonus crysoleucas) (AECOM 2009).

A third small water body is located between the overflow and discharge canals. This manmade 

feature, referred to as the small pond, is stagnant and has no connections to the overflow canal 

or the discharge canal (Figure 3–12). Thirteen fish species were collected in the Central Canal 

during surveys conducted in 2008; the most abundant species were bluegill, gizzard shad, 

largemouth bass (Micropterus salmoides), white crappie (Pomoxis annularis), green sunfish 

(L. cyanellus), and bluntnose minnow (Pimephales notatus) (AECOM 2009).

3.7.1.3 Drainage Ditches

Several ditches located throughout the Fermi site drain surface water runoff to Swan Creek and 

the nearby wetlands. The drainage ditches are regularly maintained and equipped with 

concrete culverts to divert runoff from the surface roads. The drainage ditches are periodically 

dry, and the habitat provided by the ditches is not suitable for supporting significant populations 

of aquatic species.

3.7.1.4 Quarry Lakes

The North and South Quarry Lakes are located in the southwestern portion of the Fermi site. 

The two lakes are approximately 50 ft (15 m) deep and, in total, cover an area of approximately 

100 ac (40 ha). The quarry lakes were created when water filled abandoned rock quarries that 

were used for site development and for construction of Fermi 2 (DECo 1977).

The quarry lakes support a limited variety of aquatic species common to Lake Erie coastal 

marsh habitats. Nine fish species were collected in the quarry lakes during surveys conducted 

in 2008; the most abundant species were bluegill, gizzard shad, green sunfish, goldfish, and 

common carp (AECOM 2009).

3.7.1.5 Wetland Ponds and Marshes Managed as Part of the DRIWR

The acreage managed as part of the DRIWR surrounds the developed portion of the Fermi site 

on the northern, western, and southern borders. This area encompasses approximately 656 ac 

(265 ha) that includes coastal wetlands and palustrine wetlands, such as freshwater emergent 

wetlands and small lakes that are semipermanently or seasonally inundated. These types of 

coastal wetlands are essential to many aquatic species because of the spawning, nursery, and 

feeding grounds they provide (Kelleys Island Birds and Natural History 2006). 

A fisheries survey of coastal marshes managed as part of the DRIWR was conducted in 

September 2005 as a joint venture by the MDNR and the FWS to document fish communities 

associated with the Michigan waters of Lake Erie and to inventory the fishery resources of the 

refuge. This survey used electrofishing and seining to sample four marsh complexes within the 

refuge, one of which was the Swan Creek Estuary located near the northern extent of the Fermi 

site. A total of 38 species of fish from 13 families were collected at this sampling site. Species 

most common in the catch included gizzard shad, bluntnose minnow, mimic shiner 

(Notropis volucellus), bluegill, pumpkinseed, goldfish, and largemouth bass. Thirty-three fish 

species were collected during fishery surveys conducted near the mouth of Swan Creek 

in 2008. The most abundant species in those collections were gizzard shad, emerald shiner, 

bluegill, brook silverside (Labidesthes sicculus), pumpkinseed, and golden shiner (AECOM 

2009).

3.7.1.6 Swan Creek

Swan Creek is located on the northern boundary of the Fermi site. It originates approximately 

12 mi (19 km) to the northwest of the Fermi site as small streams and then flows south and east 
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where it enters Lake Erie. Land use adjacent to the Swan Creek drainage includes small 

residential communities and agricultural development.

Swan Creek forms a freshwater estuary where it flows into Lake Erie. The aquatic habitat in this 

area is shallow, with large stands of submerged aquatic vegetation. Many areas along the 

shoreline support water lilies, cattails, common reed, and other emergent vegetation (Francis 

and Boase 2007; AECOM 2009). The benthic habitat associated with this area of Swan Creek 

consists of sandy sediment interspersed with small pockets of gravel and flat stone 

(AECOM 2009).

Benthic macroinvertebrates were collected during eight sampling events from July 2008 through 

June 2009 near the location where water from the North Lagoon area enters Swan Creek 

(AECOM 2009). These collections were dominated by aquatic worms (Haplotaxida, 

31 percent); small crustaceans (Amphipoda, 23 percent); and midge larvae (Diptera,

19 percent), among others (AECOM 2009).

A fisheries survey of the Swan Creek estuary was conducted in September 2005 by the MDNR 

and the FWS using electrofishing and seining to sample nine sites along Swan Creek ranging 

from approximately 0.5 to 2.5 mi (0.8 to 4 km) from the Fermi site (Francis and Boase 2007). A 

total of 38 species from 13 families were collected at these sampling sites. Frequently 

encountered species included gizzard shad, bluntnose minnow, emerald shiner, mimic shiner, 

bluegill, pumpkinseed, goldfish, and largemouth bass (Francis and Boase 2007).

Fish were also collected from Swan Creek monthly from July 2008 to June 2009 (excluding 

winter months) near the location where water from the North Lagoon area enters Swan Creek 

(AECOM 2009). Overall, the fish species encountered during these surveys were similar to 

those observed in the survey by Francis and Boase (2007) described above. A total of 

1,790 fish (33 species) were represented in the samples; dominant species included gizzard 

shad, emerald shiner, bluegill, brook silverside, and pumpkinseed (AECOM 2009).

Swan Creek is popular with recreational anglers, and several species common to Michigan are

frequent catches in Swan Creek, including smallmouth bass (Micropterus dolomieu), largemouth 

bass, and bluegill.

3.7.1.7 Stony Creek

Stony Creek is located generally to the west of the Fermi site in Washtenaw and Monroe 

Counties, Michigan, and drains directly into the western basin of Lake Erie at a location 

approximately 3 mi (5 km) southwest of the Fermi site boundary. Stony Creek is about 35 mi 

(56 km) long. Land cover within the watershed includes forested areas, agricultural lands, and 

residential developments (Gustavson and Ohren 2005).

Some biological data were collected from Stony Creek and its tributaries. The Stony Creek 

Watershed Project performed studies focusing on water quality, nutrients, and indicator species, 

although the majority of the data from these studies were not collected near the Fermi site. 

A macroinvertebrate survey was conducted in 2004 at several sampling sites along Stony Creek 

to assess water quality. The nearest sampling site was located approximately 2.5 mi (4 km) 

south-southwest of the Fermi site. Data on various hydrological parameters were collected in 

addition to the macroinvertebrate samples. Results from the survey indicated an increase in the 

number of insect families with respect to previous studies of Stony Creek. There was also an 

abundance and diversity of mayflies (Ephemeroptera); stoneflies (Plecoptera); and caddisflies 

(Trichoptera), which are three orders of insects that are considered sensitive to poor water 

quality. Together, the abundance of taxa in these three orders are used to calculate the 

Ephemeroptera-Plecoptera-Trichoptera (EPT) index, which is a measure of water quality, with a 

higher number of taxa from each of these orders generally indicating better water quality. The 
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downstream sites (located nearest to the Fermi site) had a higher EPT index than did the 

upstream survey sites (Gustavson and Ohren 2005).

Fish surveys conducted in portions of Stony Creek located in Monroe County during 1997 

indicated that the fish community in Stony Creek was dominated by taxa that are tolerant of 

degraded water quality conditions, although the fish community was rated as acceptable 

(MDEQ 1998). Dominant species found to be present included green sunfish, rock bass, 

(Ambloplites rupestris), common carp, and blackside darter (Percina maculata) (MDEQ 1998).

3.7.1.8 Lake Erie

The Fermi site is situated along the shoreline of Lake Erie. Lake Erie provides the source of 

cooling water and receives cooling water discharge from Fermi 2. Consequently, aquatic 

habitats and organisms in Lake Erie in the vicinity of the Fermi site have the potential to be

affected by operation of Fermi 2. This section describes the ecological setting and recent 

ecological history of Lake Erie, with a focus on the vicinity of the Fermi site.

Lake Erie is one of the five lakes included in the Great Lakes system and is the smallest of the 

group in volume (116 mi3

) (484 km3). Measuring 241 mi (388 km) across and 57 mi (92 km) 

from north to south, Lake Erie has a surface area of nearly 10,000 mi2 (2,600 km2

) with 871 mi 

(1,400 km) of shoreline. The average depth of Lake Erie is approximately 62 ft (19 m) and is 

210 ft (64 m) deep at its maximum depth (EPA 2008).

Lake Erie is divided into three basins on the basis of the bathymetry of the lake: (1) eastern 

basin, (2) central basin, and (3) western basin. Because the Fermi site is located on the 

shoreline of the western basin, this portion of Lake Erie is of the greatest concern with regard to 

operation of Fermi 2. The western basin receives 95 percent of the water that drains into 

Lake Erie, including several major river drainages (e.g., Maumee River, River Raisin, Huron 

River, and Detroit River), as well as numerous smaller streams that discharge directly into the 

western basin. Depth generally increases from west to east in Lake Erie. The western basin is 

the shallowest basin in the lake, averaging approximately 24 ft (7.3 m) in depth (LaMP Work 

Group 2008). Although thermal stratification is a frequent and persistent condition during 

summer months for the central basin, stratification events are relatively rare and brief in the 

western basin (LaMP Work Group 2008; Bolsenga and Herdendorf 1993). As a consequence, 

the western basin is less likely to experience severe or prolonged episodes of oxygen depletion 

in deeper waters, which can result in large mortality events for aquatic species that are 

physiologically restricted to cooler water conditions.

The drainage basin of Lake Erie includes portions of Indiana, Michigan, Ohio, Pennsylvania, 

New York, and Ontario, and it is the most densely populated of the five Great Lakes basins 

(LaMP Work Group 2008). The fertile soils associated with the Lake Erie watershed support

intense agricultural production throughout the entire drainage basin. Greater urbanization, 

industrialization, agricultural development, and the smaller volume of water make the Lake Erie 

ecosystem more susceptible to external stressors than the ecosystems of the other Great 

Lakes. This became apparent by the 1960s when decades of nutrient enrichment 

(eutrophication) and chemical contamination resulted in severe degradation of the Lake Erie 

ecosystem. By the 1980s, positive recovery of Lake Erie’s water quality was observed as a 

result of the implementation of remediation plans through the NPDES program that helped meet 

targets for nutrient levels (especially phosphorus) established under the Great Lakes Water 

Quality Agreement (LaMP Work Group 2008). In addition to pollution abatement programs, 

colonization of Lake Erie by invasive zebra mussels (Dreissena polymorpha) and quagga 

mussels (D. rostriformi) during this same period helped return the lake to more mesotrophic 

(i.e., less nutrient-rich) conditions.
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There are indications, however, that total phosphorus concentrations in Lake Erie waters have 

again started to increase over the past decade; this trend has been hypothesized to be related 

to changes in lakewide nutrient dynamics and more frequent storm events (LaMP Work 

Group 2008). Coincident with (and perhaps attributable to) these increasing dissolved 

phosphorus loads, blooms of some undesirable algal taxa (e.g., Cladophora spp. and 

Microcystis spp.) have increased. In recent years, Lyngbya wollei, an invasive filamentous 

cyanobacterial (also called blue-green algae) species, has become a nuisance in some areas of 

the western basin, such as Maumee Bay (approximately 18 mi (29 km) south-southeast of the 

Fermi site), that continue to experience higher levels of nutrient enrichment through riverine 

inputs (LaMP Work Group 2008).

The following sections summarize information for major ecological groups of aquatic organisms,

including plankton, benthic invertebrates, and fish, that are present in the waters of Lake Erie.

Plankton

Plankton are very small aquatic organisms that drift in the water column and are unable to move 

or are too small or too weak to swim against water currents. Some plankton serve as the base 

of the aquatic food chain in Lake Erie, providing food for larger aquatic organisms. The plants

of the plankton community are called phytoplankton, and the animals are called zooplankton. 

Most phytoplankton serve as food for benthos and zooplankton, which is directly eaten by many 

species of fish (at least during early fish life stages) and other zooplankton. Zooplankton 

includes animals that spend their entire lives in the plankton community (holoplankton) and the 

larval forms of many species of invertebrates and fish that are planktonic during early life 

stages. Fish eggs, larvae, and juveniles (called ichthyoplankton) are also part of the overall 

zooplankton community.

Phytoplankton studies conducted in the 1980s and 1990s in nearshore waters of the western 

basin of Lake Erie demonstrated that phytoplankton biomass fluctuates seasonally, with the 

highest overall phytoplankton densities occurring in the spring. Phytoplankton density also 

varies spatially throughout the western basin, with increased phytoplankton abundance along 

the entire southern shore and decreased abundance offshore and throughout deeper waters. 

The types of phytoplankton typically documented in greatest abundance during those earlier 

studies were diatoms (Bacillariophyceae) and green algae (Chlorophyceae). Millie et al. (2009)

found that the phytoplankton community in the western basin during the late summer from 2003

to 2005 was dominated by various species of green algae, diatoms, and cyanobacteria 

(blue-green algae).

Periodically, there can be a rapid increase in the population of particular species of planktonic 

algae that results in unusually high densities. Such events are referred to as algal blooms. 

Sometimes algal blooms can discolor water or produce other undesirable conditions. 

Decomposition of dead cells from algal blooms (regardless of the species involved) can 

sometimes lower the concentration of dissolved oxygen in the water, causing hypoxic 

(low oxygen) or anoxic (no oxygen) conditions that can result in fish kills. Of particular concern 

in Lake Erie is a phytoplanktonic genus of blue-green alga (Microcystis spp.) that can produce a 

substance (microcystin) that is toxic to fish and other organisms when concentrations are high 

enough (EPA 2009c). Under certain conditions (such as high nutrient concentrations, increased 

light levels, and calm weather (usually in the summer)), Microcystis spp. can form dense 

aggregations of cells that form a thick layer (mat) on the surface of the water. At higher 

concentrations, Microcystis spp. blooms can resemble bright green paint. Mycrocystis spp. 

blooms can affect water quality, as well as the health of human and natural resources. The 

NOAA (2012) has been conducting research in Lake Erie to develop methods to identify the 

presence of cyanobacterial (blue-green algae) blooms from satellite imagery and to determine 
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the factors controlling production of toxins associated with Microcystis spp. blooms. Results of 

this research indicate that cyanobacterial blooms tend to occur primarily in the southwestern 

portion of the western basin, especially in the vicinity of Maumee Bay, during summer months 

(NOAA 2012).

Dominant zooplankton taxa in Lake Erie include various species of crustaceans, such as 

copepods (e.g., Cyclops spp. and Diaptomus spp.); cladocerans (e.g., Daphnia spp., 

Bosmina spp., and Leptodora spp.); rotifers (e.g., Keratella spp. and Asplanchna spp.); and 

other taxonomic groups. The early life stages of some fish species can be part of the 

zooplankton. Zooplankton populations are typically lowest during winter months and most 

abundant during summer months. Two species of zooplankton, the spiny water flea 

(Bythotrephes spp.) and the fishhook water flea (Cercopagis pengoi), are invasive species 

throughout Lake Erie (Bolsenga and Herdendorf 1993).

Because plankton responds quickly to changes in nutrient inputs, phytoplankton and 

zooplankton are important indicators of nutrient pollution. One measure that has been 

developed to assess the biological health and diversity of offshore waters of Lake Erie is the 

Planktonic Index of Biotic Integrity (P-IBI) (Kane et al. 2009). This indicator, which is based on 

the abundance and number of different species groups of phytoplankton and zooplankton 

present in water samples, is used to evaluate the productivity level of the lake. Plankton 

productivity in formerly oligotrophic lakes is related to the anthropogenic introduction of 

phosphorus into lake waters from point sources (e.g., permitted discharge sites) or nonpoint 

sources (e.g., surface water runoff). Low productivity (oligotrophic condition) is associated with 

low phosphorus enrichment, moderate productivity (mesotrophic condition) is associated with 

moderate phosphorus levels, and high productivity (eutrophic condition) is associated with high 

phosphorus levels. Application of the P-IBI to the waters of the western basin of Lake Erie 

suggests that the overall condition of the western basin was mesotrophic during 1995 and 

became more eutrophic during the period from 2000 to 2003 (EPA 2009d).

Benthic Invertebrates

Benthic species inhabit the bottom of aquatic environments and serve as valuable indicators of 

the surrounding ecosystem. Benthic species include epifauna, which live on substrate surfaces, 

and infauna, which burrow into bottom sediments. Benthic communities consist of many 

different types of organisms and many different species. Examples of benthic invertebrates 

present in Lake Erie include mollusks (i.e., snails, mussels, and clams); larvae of various insects 

(such as midges, mosquitoes, mayflies, and stoneflies); and worms. The distribution and 

density of benthic organisms can be quite variable and are especially affected by the type of 

substrate (e.g., mud, sand, gravel, or cobble) and the water conditions present at a particular 

location. As are plankton, benthic organisms are important members of the aquatic food web,

and the presence, absence, and abundance of some species or species groups can serve as 

indicators of local water conditions.

As part of the COL process for the proposed Fermi 3 unit, benthic invertebrates were sampled 

by DTE from two locations in Lake Erie just offshore from the Fermi site during 2008 and 2009 

(AECOM 2009) to determine those species that could be present in areas potentially affected by 

building and operating Fermi 3. One site (Lake Erie intake), located in water approximately 3 to 

5 ft (1 to 1.5 m) deep near the existing cooling water intake for Fermi 2 and the proposed intake 

location for Fermi 3, had a substrate that consisted of mud and sand. The benthic organisms 

collected at this site consisted primarily of various species of amphipods (62 percent of the 

organisms collected); dipterans (fly and midge larvae, 18 percent); and tubificid worms 

(10 percent) (AECOM 2009). The second site, located in water approximately 1 to 4 ft (0.3 to 

1.2 m) deep at the southern end of the Fermi site near the South Lagoon, had a rocky substrate. 
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Dominant taxa collected from this site included various species of ephemeropterans (mayflies,

19 percent); amphipods (18 percent); dipterans (14 percent); tubificid worms (13 percent);

mollusks (13 percent); and water mites (11 percent) (AECOM 2009).

The four families of bivalve mollusks that live in the streams and lakes of Michigan are 

freshwater unionid mussels (Unionidae), fingernail and pea clams (Sphaeriidae), Asian clams 

(Corbiculidae), and zebra and quagga mussels (Dreissenidae). Unionid mussels and sphaeriid 

clams are native to North America, whereas Asian clams and zebra and quagga mussels are 

not native to this continent. The Asian clam (Corbicula fluminea) was introduced to North 

America in 1938 as a food species and has since spread throughout the United States. The 

Asian clam is present in Lake Erie. Pea clams and fingernail clams are fairly widespread and 

common in Michigan. Unionid mussels are of particular interest because of their unique life 

history, importance to aquatic ecosystems, and use as indicators of change in water and habitat 

quality. They have also undergone significant declines in range and abundance over the past 

century. 

Unionid mussels require a fish host to complete their life cycle, whereas other bivalve families 

produce free-swimming larvae that develop into the adult form without a host. Eggs of unionid 

mussels are fertilized and develop into larvae within the gills of the female mussel. These 

larvae, called glochidia, are released into the water and must attach to the gills or fins of a 

suitable fish or amphibian host to survive and transform into the adult form. Glochidia are very 

small (approximately 0.1 mm (0.004 in.) in length) and do not significantly harm their hosts. 

Some unionids are known to have only one or two suitable host species, whereas others are 

generalists and use several fish species as hosts. Without the presence of healthy fish host 

populations, unionid mussels are unable to reproduce.

Although they were once widely distributed and common in the western basin of Lake Erie, 

declines in the abundance of unionid mussels have been documented since 1961 (Schloesser 

and Nalepa 1994). Although earlier declines were largely attributable to declines in water 

quality, the introduction and subsequent proliferation of zebra and quagga mussels in the 

late 1980s is believed to have been a primary factor in the large declines in (i.e., near extirpation 

of) unionid mussel populations in a large portion of western Lake Erie between 1989 and 1991 

(Schloesser and Nalepa 1994).

Lake Erie was one of the first North American water bodies to be colonized by zebra mussels 

and quagga mussels in the late 1980s. Believed to have been introduced in ballast water of 

ocean-going vessels entering the Great Lakes, these non-native, invasive mussels have caused 

extensive economic and environmental impacts on Lake Erie and on many other freshwater 

systems in the United States. Many power plants, including Fermi 2 (Section 3.1.3), have 

implemented control programs specifically to address these species, which can accumulate on 

intake and discharge structures, potentially affecting the efficiency of cooling water operations. 

Populations of native mussel species have also been affected by the introduction and 

proliferation of zebra and quagga mussels (USGS 2008; Schloesser and Nalepa 1994). 

Fish

Human activities have resulted in considerable changes in the nature of the Lake Erie fish 

community during the past century. These changes have resulted from many causes, including 

overfishing, introduction and expansion of invasive exotic species, nutrient enrichment (and 

reversal of nutrient enrichment), deterioration of tributaries and other habitat features, and 

introduction of contaminants (Regier and Hartman 1973).

Van Meter and Troutman (1970) listed 138 species of fish documented to occur in Lake Erie or

its tributaries. Since then, additional non-native fish species have been introduced into 
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Lake Erie, including ghost shiner (Notropis buchanani) and round goby (Neogobius 

melanostomus). Prior to 1900, lake trout (Salvelinus namaycush) was the dominant predator in 

the eastern basin of Lake Erie, with walleye (Sander vitreus) and burbot (Lota lota) as 

subdominants. Before 1950, the dominant predatory fish species in the western and central 

basins included walleye and blue pike (S. vitreus glaucus). The forage fish community in the 

western and central basins was dominated by emerald shiner, spottail shiner (Notropis 

hudsonius), and gizzard shad. In the eastern basin, the prey fish community was dominated by 

cisco (formerly called lake herring, Coregonus artedi). Changes in the structure of the fish 

community began to occur in the early 1900s, and the fish community structure was very 

different by 1960 (Tyson et al. 2009). These changes were primarily attributed to invasions of 

fish, such as sea lamprey (Petromyzon marinus), alewife (Alosa pseudoharengus), and rainbow 

smelt (Osmerus mordax); over-exploitation of important species, including the extinction of the 

blue pike; and declines in water quality and habitat degradation in nearshore areas and 

tributaries (Tyson et al. 2009). By the 1980s, Lake Erie’s water quality started to improve as a 

result of reductions in nutrient inputs caused by remediation programs and as a result of the

colonization of Lake Erie by invasive zebra mussels and quagga mussels. These changes in 

the nutrient status of the lake in conjunction with additional invasions by non-native species,

such as the round goby, have resulted in further changes in the structure of the fish community.

The western basin contains important fish spawning and nursery areas and is also important to 

commercial and recreational fisheries. Although movements of fish among basins make it 

difficult to explicitly define a fish community by basin, examples of dominant fish species in the 

western basin include yellow perch (Perca flavescens), walleye, smallmouth bass, channel 

catfish (Ictalurus punctatus), alewife, gizzard shad, carp, freshwater drum (Aplodinotus 

grunniens), and emerald shiner.

The U.S. Geological Survey (USGS) has conducted assessments of fish populations throughout 

the western basin of Lake Erie for a number of years to estimate density and biomass of key 

forage and predator species in Michigan and Ontario waters. These data are maintained in an

interagency database that is used to assess seasonal and spatial distributions of fish and year 

class strength of key forage and predator species. Based on sampling conducted in the 

western basin during 2011 (Kocovsky et al. 2012), populations of several ecologically and 

economically important native fish species remained low in abundance or appeared to be 

declining in numbers compared to previous years. There was an indication of recent increases 

in the abundance of walleye and freshwater drum, but both of these species, as well as yellow 

perch, remained at depressed levels of abundance. Alewife, an introduced species that is an 

important prey species in Lake Erie, has drastically declined in abundance and was not 

captured during surveys for four consecutive years (Kocovsky et al. 2012). Most of the 

15 species examined had poor or moderate year classes in 2011; only gizzard shad, freshwater 

drum, and rainbow smelt had catch levels above the 8-year mean. Yearling and older silver 

chub (Machrybopsis storeriana) increased in abundance compared to 2010 and remains much 

more abundant than in the 1990s (Kocovsky et al. 2012).

As part of the COL application process, fish were collected monthly from July 2008 to 

June 2009 (excluding winter months) at two sampling locations in Lake Erie just offshore from 

the Fermi site (AECOM 2009) to determine those species that could be present in areas 

potentially affected by building and operating Fermi 3. The intake location was near the existing 

cooling water bay for Fermi 2 and the proposed intake location for Fermi 3, whereas the other 

sampling location was along the Lake Erie shoreline near the South Lagoon. The two locations 

differed in the types of aquatic habitat that were present and had comparatively different species 

richness and abundance. The intake location was located along a sand and gravel beach in the 

open waters of Lake Erie and had little or no structure that would provide cover or spawning 
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features. The South Lagoon location was near sand and gravel shoreline areas and vegetated 

shoreline areas that could provide cover and spawning areas for some fish species. In addition, 

the South Lagoon location was near the mouth of the drainage area for the South Lagoon,

which has extensive aquatic vegetation; fish within that drainage can move freely from the 

lagoon out into the main body of the lake.

Overall, 5,765 individual fish, composed of 40 species, were collected from the two Lake Erie 

sampling locations (Table 3–16). The most abundant species encountered in those collections 

were gizzard shad, goldfish, white perch (Morone americana), emerald shiner, spottail shiner,

and bigmouth buffalo (Ictiobus cyprinellus) (AECOM 2009).

Percent Abundance of Fish Species Collected in Lake Erie 

near the Fermi Site during 2008 and 2009(a)

Common Name Scientific Name

Intake

Location

South

Lagoon Overall

alewife Alosa pseudoharengus 0.1 0.0 <0.1

banded killifish Fundulus diaphanus 0.5 0.5 0.4

bigmouth buffalo Ictiobus cyprinellus 2.7 4.8 4.1

black bullhead Ameiurus melas 0.0 2.9 1.9

bluegill Lepomis macrochirus 0.6 0.9 0.8

bluntnose minnow Pimephales notatus 0.3 5.5 3.8

bowfin Amia calva 0.0 0.1 0.1

brook silverside Labidesthes sicculus 0.0 2.6 1.7

brown bullhead Ameiurus nebulosus 0.0 0.3 <0.1

channel catfish Ictalurus punctatus 0.4 0.3 0.1

common carp Cyprinus carpio 0.5 5.6 3.8

common shiner Luxilus cornutus 0.0 0.3 <0.1

emerald shiner Notropis atherinoides 6.8 13.6 11.3

freshwater drum Aplodinotus grunniens 0.0 0.1 0.1

gizzard shad Dorosoma cepedianum 44.9 15.8 25.4

golden redhorse Moxostoma erythrurum 0.0 0.1 0.1

golden shiner Notemigonus crysoleucas 0.0 2.2 1.4

goldfish Carassius auratus 4.0 28.0 19.7

green sunfish Lepomis cyanellus 0.0 0.2 0.2

largemouth bass Micropterus salmoides 0.1 2.5 1.7

longnose gar Lepisosteus osseus 0.2 0.0 0.1

logperch Percina caprodes 0.0 0.5 <0.1

longear sunfish Lepomis megalotis 0.0 0.2 <0.1

northern pike Esox lucius 0.0 0.3 0.2

pumpkinseed Lepomis gibbosus 0.0 3.2 2.1
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Common Name Scientific Name

Intake

Location

South

Lagoon Overall

quillback Carpiodes cyprinus 0.1 0.7 0.5

rock bass Ambloplites rupestris 0.3 0.4 0.3

round goby Neogobius melanostomus 0.0 0.6 0.4

sand shiner Notropis stramineus 0.3 0.2 0.2

smallmouth bass Micropterus dolomieu 0.0 0.3 <0.1

spotfin shiner Cyprinella spiloptera 0.8 1.9 1.5

spottail shiner Notropis hudsonius 5.8 3.2 4.1

spotted gar Lepisosteus oculatus 0.0 0.3 <0.1

spotted sucker Minytrema melanops 0.0 0.3 <0.1

tadpole madtom Noturus gyrinus 0.0 0.5 <0.1

western mosquitofish Gambusia affinis 0.0 0.3 <0.1

white perch Morone americana 33.5 1.9 12.4

white sucker Catostomus commersonii 0.3 0.2 0.2

yellow bullhead Ameiurus natalis 0.0 0.3 0.0

yellow perch Perca flavescens 0.0 1.8 1.2

(a) Percent of the individuals collected at site location.

Source: AECOM 2009

Entrainment and impingement studies provide additional data on fish from the waters of 

Lake Erie near the Fermi site.

The rates at which fish eggs and fish larvae were entrained by the existing cooling water intake 

of Fermi 2 were measured from July 2008 through July 2009, excluding the months of 

December through February when ice cover was present and spawning by fish would most 

likely be at minimum levels (AECOM 2009). Entrainment rates (fish eggs plus larvae per unit 

volume of water) ranged from 4.82 /m3 (0.14 /ft3

) in July 2009 to 0.00 /m3 (0.00/ft3) in 

November 2008 and March 2009. The average annual entrainment rate for all species collected 

from July 2008 through July 2009 was 0.98/m3 (0.028/ft3

). Of the 12 fish species identified in 

entrainment samples, the species with the highest annual entrainment rates included gizzard 

shad, emerald shiner, bluntnose minnow, and yellow perch (AECOM 2009). Table 3–17

presents the overall estimates of the total numbers of fish eggs and larvae entrained during the 

study period. These estimates were calculated by multiplying monthly entrainment estimates by 

the volume of water drawn into the cooling system during each period.
3-85

Estimated Numbers of Fish Eggs and Larvae Entrained by the 

Fermi 2 Cooling Water Intake from July 2008–July 2009(a)

Common Name

2008 2009 

Jul Aug Sep Oct Nov Mar Apr May Jun 

gizzard shad 62,048 1,452,781 1,191,501 2

emerald shiner 1,054,814 1,897,015 109,500 2,994,507 911,148 

bluntnose minnow 72,962 15,643 4,892,017 560,707 

yellow perch 140,786 4,121,154 560,707 

unidentified spp. 4,298,465 

freshwater drum 

round goby 62,048 510,735 141,109 770,863 210,265 

bigmouth buffalo 1,274,889 420,530 

channel catfish 434,335 

largemouth bass 62,571 88,946 

sunfish sp. 148,243 

white perch 124,096 

unknown 

centrarchidae 

70,088 

brook silverside 59,297 

Total 1,737,341 2,480,712 141,109 4,298,465 0 0 328,500 15,802,697 3,924,946 3

(a) Estimates are based on measured entrainment rates and actual operational flow volume reported by DECo from July 2008 through Ju

(b) The annual estimate does not include data from December through February. The numbers of eggs and larvae are expected to be lo

because it is outside the normal spawning period for most Lake Erie fish species.

Source: AECOM 2009
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In general, fish species entrained during the 2008 to 2009 study (AECOM 2009) were similar to 

those captured during a previous entrainment study (Lawler, Matusky, and Skelly 

Engineers 1993) conducted at the Fermi site from October 1991 to September 1992. The most 

abundant larval fish taxa entrained during the earlier study included Cyprinids (22.9 percent), 

Morone spp. (20.0 percent), gizzard shad (19.5 percent), Clupeids (8.8 percent), and white 

perch (6.2 percent); the taxa for which fish eggs were most abundant in entrainment samples 

included Cyprinidae (42.1 percent of eggs) and Percidae (22.4 percent of eggs).

Impingement data collected from 1991 to 1992 from the Fermi 2 intake indicated that the 

dominant species impinged was the gizzard shad, which accounted for 71.5 percent of the 

estimated total number of individual fish impinged during the study period. White perch was the 

second most abundant species impinged (6.8 percent of the estimated total). Third, fourth, and 

fifth species ranked by the estimated number of individuals affected were the rock bass, 

freshwater drum, and emerald shiner, respectively. Table 3–18 presents the estimated 

numbers of fish impinged (by species) in 2008 through 2009 from Fermi 2. During that period, 

gizzard shad accounted for approximately 39 percent, emerald shiner accounted for 

approximately 29 percent, and white perch accounted for approximately 10 percent of the total 

estimated numbers of fish impinged at the plant (AECOM 2009). Overall, an estimated 

3,102 individual fish were impinged by the Fermi 2 cooling water intake during the 2008 through 

2009 sampling period (Table 3–18). Most of the fish species identified in impingement samples 

are considered forage species for other fish. On the basis of an analysis conducted by the Lake 

Erie Forage Task Group (2010), the long-term average density of forage fish in size classes 

capable of being captured in nets and trawls is approximately 1,384,680 fish per square mile in 

the western basin. Assuming an estimate of approximately 1,200 mi2 (3,100 km2

) for the 

western basin as a whole, the long-term average number of forage fish within the basin is 

estimated to be approximately 1.7 billion.
3-87

Estimated Numbers of Fish Impinged by the Fermi 2

Cooling Water Intake from August 2008–July 2009(a)

Common Name

2008 2009 

Aug Sep Oct Nov Dec Jan Feb Mar Apr(b) May Jun Jul

gizzard shad 62 150 930 62 

emerald shiner 31 30 31 62 93 84 558 

white perch 62 30 31 30 31 28 93 

bluegill 31 31 28 124 

round goby 31 30 31 31 

smallmouth bass 31 31 

spottail shiner 31 31 

banded killifish 31 

brook silverside 31 

largemouth bass 31 

bluntnose minnow 30 

channel catfish 30 

freshwater drum 30 

green sunfish 30 

rock bass 30 

Total 186 210 186 180 1054 217 140 806 62 30 31 

(a) Estimates are based on measured impingement rates and actual operational flow volume reported by DECo from August 2008 throug

(b) Annual estimates do not include data from April 2009 because heavy debris prevented sample collection.

Source: AECOM 2009
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3.7.2 Aquatic Habitats—Transmission Lines

The in-scope transmission lines that connect Fermi 2 to the transmission grid for purposes of 

power transmission are located within the property boundary, are aboveground, and are limited 

to the developed portion of the site. The in-scope transmission lines do not pass over aquatic 

habitat.

3.7.3 Important Aquatic Species and Habitats—Site and Vicinity

Important aquatic species include commercially or recreationally important fishery species,

species considered to have vital roles in ecosystem dynamics, and Federally and State-listed 

species. Although tabulated here for completeness, Federally protected species are discussed 

in Section 3.8. On the basis of these criteria, 37 species that inhabit the freshwater habitats 

near the Fermi site were identified as important species (Table 3–19).

Brief summaries of distribution and life history information for important species are also 

provided; these summaries were developed from information provided by NatureServe (2009) 

unless otherwise indicated. Where applicable, information about impingement and entrainment

during Fermi 2 operations is presented for each species based on recently collected 

impingement and entrainment data for the Fermi site (AECOM 2009).

Important Aquatic Species That Have 

Been Observed in the Vicinity of the Fermi Site(a)

Common Name Scientific Name Category(b,c)

Mollusks

elktoe Alasmidonta marginata ESA-NL, MI-SC

northern riffleshell Epioblasma torulosa rangiana ESA-E, MI-E

purple lilliput Toxolasma lividus ESA-NL, MI-E

purple wartyback Cyclonaias tuberculata ESA-NL, MI-T

rayed bean Villosa fabalis ESA-E, MI-E

round hickorynut Obovaria subrotunda ESA-NL, MI-E

round pigtoe Pleurobema sintoxia ESA-NL, MI-SC

salamander mussel Simpsonaias ambigua ESA-NL, MI-E

slippershell Alasmidonta viridis ESA-NL, MI-T

snuffbox mussel Epioblasma triquetra ESA-E, MI-E

wavyrayed lampmussel Lampsilis fasciola ESA-NL, MI-T

white catspaw Epioblasma obliquata perobliqua ESA-E, MI (presumed extirpated in 

Michigan)

Fish

bigmouth buffalo Ictiobus cyprinellus Commercial fishery

brindled madtom Noturus miurus ESA-NL, MI-SC

channel catfish Ictalurus punctatus Commercial fishery, recreational 

fishery

channel darter Percina copelandi ESA-NL, MI-E

common carp Cyprinus carpio Commercial fishery

creek chubsucker Erimyzon claviformis ESA-NL, MI-E
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Common Name Scientific Name Category(b,c)

eastern sand darter Ammocrypta pellucida ESA-NL, MI-T

freshwater drum Aplodinotus grunniens Commercial fishery

gizzard shad Dorosoma cepedianum Commercial fishery 

goldfish Carassius auratus Commercial fishery

lake whitefish Coregonus clupeaformis Commercial fishery

largemouth bass Micropterus salmoides Recreational fishery

orangethroat darter Etheostoma spectabile ESA-NL, MI-SC

pugnose minnow Opsopoedus emiliae ESA-NL, MI-E

quillback Carpiodes cyprinus Commercial fishery

river darter Percina shumardi ESA-NL, MI-E

sauger Sander canadensis ESA-NL, MI-T

silver chub Macrhybopsis storeriana ESA-NL, MI-SC

silver shiner Notropis photogenis ESA-NL, MI-E

smallmouth bass Micropterus dolomieu Recreational fishery

southern redbelly dace Phoxinus erythrogaster ESA-NL, MI-E

walleye Sander vitreus Commercial fishery, recreational 

fishery

white bass Morone chrysops Commercial fishery, recreational 

fishery

white perch Morone Americana Commercial fishery

yellow perch Perca flavescens Commercial fishery, recreational 

fishery

(a) These are commercial and recreationally important species and Federally and State-listed species that could 

occur in the waters of the western basin of Lake Erie near the Fermi site and freshwater habitats of Monroe 

County, Michigan.

(b) ESA-E = Federally listed under ESA as endangered, ESA-NL = not listed under ESA, MI-E = listed by the State 

as endangered, MI-SC = listed by the State as a species of concern, and MI-T = listed by the State as 

threatened.

(c) Section 3.8 discusses Federally listed species, but they are included in this table for completeness.

3.7.3.1 Commercially Important Species

Although other waters in the vicinity of the Fermi site do not support commercial fisheries, Lake 

Erie supports one of the largest freshwater commercial fisheries in the world, with the majority of 

commercial fishing occurring along the Canadian border. Commercial landings in Lake Erie are 

dominated by yellow perch, walleye, rainbow smelt (Osmerus mordax), and white bass (Morone 

chrysops). In the western basin of Lake Erie, management of commercial fisheries falls under 

the jurisdiction of the MDNR; the Ohio Department of Natural Resources (ODNR); or the Ontario 

Ministry of Natural Resources, depending upon where the fishing occurs. The Great Lakes 

Fisheries Commission coordinates fisheries research and facilitates cooperative fishery 

management among the state, provincial, tribal, and Federal agencies that manage fishery 

resources within the Great Lakes and has established a Lake Erie Committee that considers 

issues pertinent to Lake Erie waters.
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Michigan’s commercial landings from Lake Erie for 2010 (the year for which the most recent 

report is available) was 752,956 lb (341,535 (kilograms (kg)) (Table 3–20) (NMFS 2014). 

Twelve fish species are included in the landings for an estimated value of $288,563. Three 

species comprised over half (57 percent) of the landings: carp, freshwater drum, and quillback.

Commercial Fishery Statistics for Michigan from Lake Erie during 2010

Species

Landings 

(lb)(a)

Percent of

Total 

Landings

Reported

Market

Value ($)

Percent of 

Total 

Value

carp 191,321 25.4 47,844 16.6

freshwater drum 130,533 17.3 27,411 9.5

quillback 107,037 14.2 24,619 8.5

goldfish 77,550 10.3 62,819 21.8

bigmouth buffalo 68,511 9.1 32,888 11.4

channel catfish 64,913 8.6 30,519 10.6

brown bullhead 47,612 6.3 20,948 7.3

white bass 37,021 4.9 27,398 9.5

white perch 19,524 2.6 11,522 4.0

suckers 7,919 1.1 1,346 0.5

lake whitefish 963 0.1 1,232 0.4

gar 52 0.0 17 0.0

Total 752,956 100 288,563 100

(a) To convert pounds to kilograms, 1 lb = 0.45 kg.

Source: NMFS 2014

Ohio’s commercial landings from Lake Erie for 2010 (the year for which the most recent report is 

available) were 4,133,417 lb (1,874,886 kg) (Table 3–21) (NMFS 2014). Thirteen fish species 

are included in the landings, for an estimated value of $4,115,982. The three species that 

comprised over half (56 percent) of the landings were yellow perch, white perch, and freshwater 

drum. Although yellow perch has historically been a significant component of the commercial 

fishery in the Ohio waters of the western basin, this area was closed to commercial yellow perch 

harvest in 2008 and 2009.
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Commercial Fishery Statistics for Ohio from Lake Erie during 2010

Species

Landings 

(lb)(a)

Percent of

Total 

Landings

Reported

Market Value

($)

Percent of 

Total 

Value

yellow perch 1,284,404 31.1 3,006,787 73.1

white perch 551,042 13.3 232,480 5.6

freshwater drum 491,999 11.9 85,002 2.1

channel catfish 452,637 11.0 154,887 3.8

white bass 357,083 8.6 285,156 6.9

bigmouth buffalo 343,962 8.3 138,818 3.4

carp 255,991 6.2 51,192 1.2

quillback 183,093 4.4 33,305 0.8

lake whitefish 83,303 2.0 83,303 2.0

goldfish 59,681 1.4 35,817 0.9

brown bullhead 33,401 0.8 6,676 0.2

suckers 22,076 0.5 2,411 0.1

gizzard shad 14,745 0.4 148 0.0

Total 4,133,417 100 4,115,982 100

(a) To convert pounds to kilograms, 1 lb = 0.45 kg.

Source: NMFS 2014

Additional information about the distribution and life history for selected commercially important 

species that could be present in Lake Erie in the vicinity of the Fermi site is presented below.

Bigmouth Buffalo (Ictiobus cyprinellus)

The bigmouth buffalo is fairly common throughout North America from the Mississippi River 

Basin stretching from Louisiana to Ohio to southern Michigan, Wisconsin, Minnesota, North 

Dakota, Montana, the lower Great Lakes Basin, the Hudson Bay Basin (Nelson River drainage) 

and Saskatchewan. This species makes up a portion of the commercial fishery in the western 

basin of Lake Erie.

The preferred habitat for bigmouth buffalo consists of the main channels, pools, and backwaters 

of small to large sluggish rivers, oxbows, bayous, reservoirs, and lakes. The bigmouth buffalo is 

tolerant of low oxygen levels and high temperatures. These fish prefer to spawn after spring 

floods, doing so in flooded marshes and river bottoms or in tributary streams. Both juvenile and 

adult members of this species rely mainly on planktonic and bottom-dwelling invertebrates as

food sources.

AECOM (2009) estimates that approximately 1.7 million bigmouth buffalo eggs and larvae were 

entrained at the Fermi site during 2008, primarily during the months of May and June

(Table 3–17). No bigmouth buffalo juveniles or adults were observed during impingement

studies conducted at the Fermi site during 2008 and 2009 (AECOM 2009). 

Channel Catfish (Ictalurus punctatus)

Channel catfish occur mostly in the central drainages of North America from southern Canada 

to northern Mexico. This species has been widely distributed throughout the United States and
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other countries. Channel catfish prefer clean, well-oxygenated water of rivers and streams but 

also inhabit ponds and lakes. They occur in locations ranging from clear, rapid-flowing waters 

over firm bottoms to turbid, slow-moving water over mud substrates.

Channel catfish have been known to migrate hundreds of miles throughout their lifetime. They 

generally spawn between April and July, and females lay up to 20,000 eggs in nests dug in 

sandy substrates. Males then guard and fan water across the nest during the 3- to 8-day 

incubation period. Larval development lasts about 2 weeks, and schools of larvae may persist 

for weeks after leaving the nest. Sexual maturity is reached anywhere from 2 to 8 years, and 

adults may reach over 130 cm (51 in.) and live up to 16 years.

Juvenile channel catfish eat mainly small invertebrates and insects and prey increasingly on 

crayfish and fish as they grow. Adults eat mainly fish but will also feed on insects, small 

mammals, and vegetation.

The potentially large size and food quality of channel catfish make it a highly sought after sport 

fish, and this species also has a significant commercial value in Lake St. Clair and Lake Erie. It 

was estimated (Table 3–17 and Table 3–18) that approximately 435,000 channel catfish eggs 

and larvae were entrained and 30 individual fish were impinged by the Fermi 2 cooling water 

intake during studies conducted in 2008 and 2009.

Common Carp (Cyprinus carpio)

The common carp is native to temperate Eurasia where it has been domesticated and bred for 

human food for several centuries. Common carp were first introduced into the United States 

around 1872, and the species was subsequently stocked throughout the United States. Carp 

are now found in every state except Hawaii and Alaska, in five Canadian provinces, and on 

every continent except Antarctica.

This species is typically found in rivers, lakes, ponds, reservoirs, swamps, or low-salinity 

estuaries, usually in shallow water with abundant vegetation and little or no current. The 

species is tolerant of a wide range of oxygen, salinity, turbidity, and bottom conditions. 

Common carp usually spawn in shallows and flooded areas, although deeper water may also be 

used. Eggs are dispersed and stick to submerged objects. Fry remain attached to the 

vegetation for about 2 days before dropping to the bottom and inhabit shallow, warm, and 

slow-moving water during their first summer.

Common carp are omnivorous, and adults eat primarily invertebrates, detritus, fish eggs, and 

plant material. Fry feed on zooplankton but will also eat phytoplankton if zooplankton densities 

are low.

Common carp make up a relatively large portion of the commercial fishery within the western 

basin of Lake Erie, as described above. No common carp were identified in impingement or 

entrainment samples collected at the Fermi site during 2008 and 2009 (AECOM 2009).

Freshwater Drum (Aplodinotus grunniens)

The freshwater drum occurs throughout North and Central America. The species ranges from 

the St. Lawrence, Great Lakes, Hudson Bay, and Mississippi River Basins to Gulf Coast 

drainages, south through eastern Mexico, and down to Guatemala.

Freshwater drum occur in a variety of habitats but are usually found in large, silty lakes and 

large rivers. They generally occur over mud bottoms in open water. Freshwater drum spawn 

from spring to late summer as water temperatures reach 51 to 72 °F (10.5 to 22 °C). They 

broadcast eggs in shallow water, which float on the surface and hatch in about 1 day. Males 

generally reach sexual maturity in 2 to 4 years, whereas females take 4 to 6 years. Maximum 

life expectancy for this species is 10 years. Juvenile drum feed primarily on small crustaceans 
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3-93

and insect larvae. Adults are mostly benthic foragers, and prey items include insect larvae;

crustaceans; fish; and mollusks, such as clams and snails.

Freshwater drum are harvested commercially in Lake Erie, although there is not a significant 

recreational fishery for this species. It was estimated that approximately 2.3 million freshwater 

drum eggs and larvae were entrained by the Fermi 2 cooling water intake during a study 

conducted in 2008 and 2009; entrainment was observed only in July 2009 

(AECOM 2009)(Table 3–17). Approximately 30 individual freshwater drum were impinged 

during studies conducted at the Fermi 2 cooling water intake in 2008 and 2009 (AECOM 2009) 

(Table 3–18).

Gizzard Shad (Dorosoma cepedianum)

The gizzard shad is distributed widely in the continental United States from Utah and Arizona 

eastward to the Atlantic seaboard. This species occurs throughout the Great Lakes region 

within both the United States and Canada and is common within the western basin of Lake Erie.

As an adult, the gizzard shad can reach 9 to 14 in. (23 to 35 cm) in length and can weigh up to 

2 lb (0.9 kg). This fish can thrive in a wide variety of habitats, including large rivers, reservoirs, 

lakes, swamps, bays, sloughs, and similar quiet open waters. Young and juveniles live in 

relatively clear and shallow waters, whereas adult gizzard shad tend to stay in deeper waters or 

near the bottom. Although gizzard shad are capable of withstanding temperatures from 

approximately 43 to 91 °F (6 to 33 °C), they are very sensitive to cold water temperatures, and 

large numbers are often found dead in the spring when the ice melts off of reservoirs and lakes.

Female gizzard shad can produce as many as 500,000 eggs, which are spawned by scattering 

them over sandy or rocky substrates. The eggs adhere to objects on the bottom until hatching 

2 to 4 days later. Sexual maturity is generally reached in 2 to 3 years. A few individuals will 

survive beyond 3 years of age, with their maximum lifespan approximately 4 to 6 years. 

Because of the large numbers of eggs produced, gizzard shad populations are often capable of 

rebounding quickly following overwinter die-offs.

Juvenile gizzard shad are planktivores, feeding on both zooplankton and phytoplankton. Adults 

are primarily bottom filter-feeding detritivores, mostly eating plants and animals that live 

attached to hard substrates, such as sand and rocks.

Gizzard shad often travel in large schools, and young gizzard shad are ecologically significant 

because they serve as prey for many species of commercially and recreationally important fish. 

Because of their rapid growth rates, many individuals are too large to be eaten by most other 

fish by the end of their first year of life. Recreational anglers commonly use gizzard shad as a 

bait fish, and the species makes up a substantial portion of the commercial harvest in the 

Michigan waters of Lake Erie.

Gizzard shad was the most commonly entrained species during studies conducted at the 

Fermi 2 cooling water intake in 2008 and 2009, and it is estimated that approximately 

30.2 million gizzard shad eggs and larvae were entrained during the 1-year study period 

(AECOM 2009) (Table 3–17). In addition, gizzard shad was the most commonly impinged 

species during studies conducted at the Fermi 2 cooling water intake in 2008 and 2009, with 

approximately 1,200 individuals impinged during the year (AECOM 2009) (Table 3–18).

Goldfish (Carassius auratus)

Goldfish are native to Eurasia and have been introduced throughout the United States and in 

parts of southern Canada. They were first introduced in the Great Lakes around 1885 and have 

since become well established in the region. They are abundant in the shallow bays and 

marshes of western Lake Erie and can also be found in slow-moving tributaries.
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Goldfish can grow to be 12 in. (30 cm) or larger, although most individuals are considerably 

smaller. Goldfish spawn during the spring and summer in shallow water, and the eggs adhere 

to vegetation and substrates. A single female can produce several lots of eggs within a season. 

Hatching occurs in 2 to 14 days, depending on water temperature.

Goldfish feed on a variety of small aquatic invertebrates and vegetation. Because of their 

abundance within shallow habitats, including marsh habitats, of the western basin and because 

of their relatively small size, goldfish are a potentially important prey species for fish-eating fish 

and birds. Goldfish also have some commercial importance within the western basin, making

up approximately 10 percent of the commercial harvest in Michigan waters of the basin. 

Although goldfish were relatively abundant in collections made during fish surveys on and near 

the Fermi site, no goldfish were identified in impingement or entrainment samples during 2008 

and 2009 (AECOM 2009).

Lake Whitefish (Coregonus clupeaformis)

Lake whitefish occur throughout most of Canada and Alaska, in south to northern New England, 

in the Great Lakes region, and in central Minnesota. Lake Erie is considered to be at the 

southern extent of the range for this species. Lake whitefish have also been introduced as 

forage and food fish in other areas, including the States of Montana, Idaho, and Washington.

The lake whitefish is a cool-water species that has a narrow temperature tolerance and requires 

cold, well-oxygenated bottom waters throughout the summer to survive. Optimum temperature 

for the lake whitefish ranges from 50 to 57 °F (10 to 14 °C) for adults and 60 to 67 °F (15.5 to 

19 °F) for juveniles. This species usually spawns during late fall or early winter over rocky or 

sandy substrates in water less than 25 ft (7.5 m) deep. Eggs hatch in the early spring, and 

sexual maturity is generally reached in 5 to 7 years. Young lake whitefish subsist primarily on 

zooplankton, whereas adults usually eat bottom-dwelling invertebrates and small fish.

Lake whitefish are an indicator of ecosystem health and an important component of the Great 

Lakes food web. During the late 19th and early 20th centuries, large numbers of lake whitefish 

entered the Detroit River each year to spawn (EPA 2009e). Reports indicate that the lower 

Detroit River was a prolific spawning area before the construction of the Livingstone Shipping 

Channel. The timing of this construction coincides with the degradation of whitefish populations 

in the river and western Lake Erie (EPA 2009e). Recently, populations of lake whitefish were 

once again discovered in the Detroit River, but further studies are necessary to ascertain their 

presence in other tributaries of western Lake Erie (EPA 2009e).

Lake whitefish historically made up a large proportion of the commercial fishery in the western 

basin of Lake Erie. In the late 1800s and early 1900s, more than 500,000 lb (225,000 kg) of 

lake whitefish were commercially harvested each year, but catches declined drastically after that 

period. There have been improvements in the fishery more recently, and the commercial lake 

whitefish landings in all of Lake Erie exceeded 1 million lb (450,000 kg) in 2000 (EPA 2009e). 

In the western basin, the commercial harvest of lake whitefish was only 8,800 lb (4,000 kg) in 

Michigan waters during 2007, and it was more than 287,000 lb (130,000 kg) in Ohio waters 

during 2009. Lake whitefish were not observed in collections made during fish surveys on and 

near the Fermi site, and no lake whitefish were identified in impingement or entrainment

samples during 2008 and 2009 (AECOM 2009).

Quillback (Carpiodes cyprinus) 

The quillback has a wide distribution in North America, with inhabited areas encompassing an 

area with a northward boundary from the Alberta to Quebec Provinces in Canada, southward to 

the Gulf Slope, and eastward to the Atlantic slope drainages. The species is relatively common 

in the Great Lakes, including Lake Erie.
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These fish are suited to a variety of aquatic habitat conditions, including pools, backwaters, and 

main channels and clear to turbid waters of creeks, rivers, and lakes. Spawning usually occurs 

in April through May over sand and mud bottoms in quiet waters of streams, overflow areas in 

bends of rivers, or the bays of lakes. Quillbacks sometimes migrate up small streams and 

creeks during the spring and summer to find suitable spawning habitat. Both adults and 

juveniles are omnivorous, feeding on organic matter in bottom sediments, insect larvae, and 

plant material.

The quillback is a small component of the commercial fisheries in the Michigan and Ohio waters 

of the western basin (Table 3–20 and Table 3–21). In Ohio, commercial harvest of quillback 

averaged more than 200,000 lb (90,000 kg) per year from 2000 through 2009 (ODNR 2010). 

Although small numbers of quillback were collected during fish surveys on and near the Fermi

site, no quillback were present in impingement or entrainment samples during 2008 and 2009 

(AECOM 2009).

Walleye (Sander vitreus) 

The walleye is the largest member of the perch family and can be found in all of the Great Lakes 

where it is a native species. Walleye have been introduced and are stocked widely in the 

United States; the distribution for the species now extends across most of the continental 

United States and Canada.

The walleye can be found in a variety of large bodies of freshwater, including lakes, pools, 

backwaters, rivers, and flooded marshes. It prefers deep waters and avoids bright light. This 

species spawns in late spring or early summer in turbulent rocky areas in rivers, coarse gravel 

shoals in lakes, or flooded marshes. Eggs hatch in approximately 26 days. Adults may migrate 

up to 100 mi (160 km) between spawning habitat and nonspawning habitat. Sexual maturity is 

reached in 2 to 4 years for males and in 3 to 8 years for females. Young walleye up to 6 weeks 

of age primarily eat zooplankton and small fishes, whereas adults feed upon fishes and larger 

invertebrates. Adults typically range in length from 13 to 25 in. (33 to 64 cm) and weigh 1 to 5 lb 

(0.5 to 2.3 kg).

The walleye is considered an extremely important commercial and recreational fishery resource 

in Lake Erie. Although the commercial fisheries for walleye in the Michigan and Ohio waters of 

Lake Erie have been closed for many years, commercial fishing for walleye in the western basin 

waters of Ontario has continued, and the annual harvest since 1976 has averaged 

approximately 1.5 million fish per year (the range is approximately 113,000 to approximately 

2.8 million fish) (Lake Erie Walleye Task Group 2010). The western basin also supports a 

popular recreation fishery, with average harvests of approximately 1.6 million; 293,000; and 

39,000 fish in the western basin waters of Ohio, Michigan, and Ontario, respectively, since 1975 

(Lake Erie Walleye Task Group 2010).

Because of the importance of walleye to the commercial and recreational fisheries in Lake Erie, 

the status of walleye populations in the lake are closely monitored by various agencies. The 

Lake Erie Committee of the Great Lakes Fishery Commission has formed the Walleye Task 

Group to bring together information from various agencies so that the population status of 

walleye in Lake Erie can be monitored each year. This task group maintains and updates 

centralized datasets, improves population models so that scientifically defensible abundance 

estimates and forecasts can be produced, makes recommendations regarding allowable harvest 

levels, and helps identify studies that need to be conducted to address data gaps (Lake Erie 

Walleye Task Group 2010). Modeled abundance estimates of walleye in Lake Erie for the 

period from 1980 to 2010 indicate that the overall numbers of walleye aged 2 and older have 

varied considerably, ranging from a low of approximately 15 million individuals in 2004 to a high 
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of approximately 74 million individuals in 1988 (Figure 3–16). Estimated abundance for 2010 

was approximately 30 million fish (Lake Erie Walleye Task Group 2010).

Figure 3–16. Estimated Abundance of Walleye Aged 2 and Older in Lake Erie, 

1980–2010 (Lake Erie Walleye Task Group 2010)

Source: NRC 2013a, Figure 2-13

No walleye were observed in collections made during fish surveys in aquatic habitats on and 

near the Fermi site, and no walleye were present in impingement or entrainment samples 

collected at the Fermi 2 cooling water intake during 2008 and 2009 (AECOM 2009).

White Bass (Morone chrysops) 

The white bass is distributed across the United States and eastern Canada. It is a relatively 

common species in the Great Lakes, including Lake Erie. White bass typically inhabit open 

waters of large lakes and reservoirs and pools of slow-moving rivers. Often traveling in schools, 

white bass tend to occur in offshore waters during the day and in inshore waters at night.

Tributary streams appear to be the preferred spawning habitat, but white bass may also spawn 

along lake shores with high wave action. Spawning occurs during the spring, usually over rock 

or gravel substrate in water up to 10 ft (3 m) deep. After hatching, the young fish generally 

remain in shallow water for a period of time before migrating to deeper areas. White bass 

become sexually mature at 1 to 3 years of age and usually do not live past 4 years of age. As 

adults, they can reach up to 16 in. (40 cm) in length and can weigh up to 4 lb (1.8 kg). White 

bass are carnivores that eat zooplankton, insect larvae, and other fish.
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White bass can be a notable component of the commercial fisheries in the Michigan and Ohio 

waters of the western basin. By weight, white bass accounted for approximately 7 percent of 

the fish commercially harvested from Michigan waters of Lake Erie in 2007 and for 25 percent of 

the fish commercially harvested from Ohio waters of the western basin in 2009.

White bass are also an important recreational fishing species in each of these States. In 

general, it is reported that very few angler boat trips specifically target white bass, and the 

majority of white bass are harvested as incidental catch from anglers targeting other species 

(ODNR 2010). However, when adult fish are moving into major tributaries to spawn during the 

spring, the aggregations of fish can attract many anglers, especially in major spawning 

tributaries, such as the Maumee River (Bolsenga and Herdendorf 1993). The recreational 

noncharter boat harvest of white bass from Michigan waters in the western basin during 2007 

was estimated to be 7,911 individual fish (Thomas and Haas 2008). From 2000 to 2009, the 

recreational white bass harvest in the Ohio waters of the western basin averaged over 

72,000 individual fish per year, with a peak of 121,000 fish caught in 2009 (ODNR 2010).

Although small numbers of white bass were collected on and near the Fermi site, no white bass 

were present in impingement or entrainment samples during 2008 and 2009 (AECOM 2009).

White Perch (Morone americana)

White perch are native to the east coast of the United States and Canada but can be found in 

the Great Lakes area where they are considered an introduced species. This species was first 

observed in Lake Erie in 1954 and has been abundant in the lake since the 1980s (Bolsenga 

and Herdendorf 1993). On the Atlantic coast, they are typically found in brackish waters, but 

they have adapted to inland freshwater lakes and tributaries. 

White perch spawn in the spring by releasing their eggs in the shallow waters of tributaries. The 

eggs sink and stick to the bottom until hatching approximately 4 days later. After hatching, the 

young feed initially on small planktonic organisms; as they grow larger, their diet changes to 

include aquatic insects, invertebrates, other fish, and the eggs of other fish species. 

White perch make up a component of the commercial fish harvest in the western basin of 

Lake Erie. In 2007, approximately 36,000 lb (16,000 kg) (3.4 percent of the commercial 

harvest) of white perch were reported in Michigan waters of the western basin. In Ohio waters 

of the western basin, white perch was the second most dominant species in the commercial 

catch during 2009, with more than 535,000 lb (243,000 kg) (23.4 percent of the commercial 

catch by weight) reported. Although white perch is generally regarded as an undesirable sport

fish in the Great Lakes, it is considered an excellent sport fish in the eastern United States.

White perch was one of the dominant fish species collected during fish surveys on and near the 

Fermi site during 2008 and 2009. Overall, white perch accounted for more than 12 percent of 

the individual fish collected during the surveys and more than 33 percent of the individuals 

collected in areas near the existing Fermi 2 cooling water intake location (Table 3–16). It is 

estimated that more than 124,000 white perch eggs and larvae were entrained during studies 

conducted at the Fermi 2 cooling water intake in 2008 and 2009 (AECOM 2009) (Table 3–17). 

In addition, white perch was the third most commonly impinged species during studies 

conducted at the Fermi 2 cooling water intake in 2008 and 2009, with approximately 

305 individuals being impinged during the year (AECOM 2009) (Table 3–18).

Yellow Perch (Perca flavescens)

The yellow perch is native to the Great Lakes region but can be found in almost all 50 states 

and most of Canada. This species is one of the most common fish in Michigan waters; is
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commonly found in Lake Erie; and is assumed to occur throughout the Detroit River, 

Swan Creek, Stony Creek, and other surface water habitats on the Fermi site.

Yellow perch usually travel in schools and are generally associated with the clear, shallower 

waters of lakes or weedy backwaters of creeks and rivers. Yellow perch usually grow to be 6 to 

10 in. (15 to 25 cm) long and weigh between 6 and 16 ounces (0.17 to 0.45 kg). Yellow perch 

spawn in the spring in shallower waters over submerged beds of aquatic vegetation or over 

sand, gravel, or rubble. The eggs, which are laid in gelatinous strands that can be several feet 

long, usually hatch in 10 to 20 days. Sexual maturity is reached in 2 to 3 years for males and in 

3 to 4 years for females; the maximum lifespan is about 10 years. Larval and young yellow 

perch feed primarily on zooplankton, whereas adults feed on larger invertebrates and small fish. 

Yellow perch is one of the most popular and economically valuable sport and commercial fish in 

Lake Erie and is considered an indicator of the ecological condition of Lake Erie (EPA 2009f). 

Because of the importance of yellow perch in Lake Erie, various agencies closely monitor the 

status of yellow perch populations in the lake. The Lake Erie Committee of the Great Lakes 

Fishery Commission has formed the Yellow Perch Task Group to bring together information 

from various agencies so that the population status of yellow perch in Lake Erie can be 

monitored each year. This task group maintains and updates centralized datasets of 

information needed to evaluate population status and to support population and harvest 

modeling efforts and makes recommendations regarding sustainable harvest levels (Lake Erie 

Yellow Perch Task Group 2010).

After peaking in the late 1800s, commercial catches of yellow perch in the Detroit River and the 

western basin of Lake Erie decreased substantially through the 1960s. These decreases are 

attributed primarily to a combination of high levels of fishing pressure and deteriorating water 

quality. Improvement in yellow perch population levels occurred during the 1970s as fishing 

pressure declined and as water quality improved as a result of lakewide pollution control 

programs that were implemented (EPA 2009f). The numbers of yellow perch in Lake Erie 

dropped again to very low levels during the early 1990s, possibly because of the combined 

effects of a lakewide invasion of zebra and quagga mussels, fishing pressure, and unsuitable 

weather conditions (EPA 2009f). Yellow perch populations increased again beginning in the 

latter portion of the 1990s; although they are not at the levels observed during the 1970s 

and 1980s, they have remained relatively stable since that time (Figure 3–17) (EPA 2009f; Lake 

Erie Yellow Perch Task Group 2010). In addition to potentially being affected by water quality, 

fishing pressure, and invasive species, yellow perch are one of the principal prey items for 

walleye. As a consequence, as walleye populations increase, there is often a corresponding 

decrease in yellow perch populations (EPA 2009f).
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Figure 3–17. Estimated Abundance of Yellow Perch Aged 2 and Older in the Western 

Basin of Lake Erie, 1975–2010 (Lake Erie Yellow Perch Task Group 2010)

Source: NRC 2013a, Figure 2-14

Although yellow perch historically made up a large portion of commercial fishery in the western 

basin of Lake Erie, the commercial perch fishery in Michigan waters has been closed 

since 1970, and the commercial perch fishery in the western basin waters of Ohio has been 

closed since 2008. From 1999 to 2008, the annual commercial harvest of yellow perch in Ohio 

waters of the western basin ranged from approximately 179,000 to 357,000 lb (81,000 to 

162,000 kg) (with a mean of approximately 255,000 lb (116,000 kg)). Commercial fishing for 

yellow perch also occurs in the western basin waters of Ontario, Canada, with a mean landing 

of approximately 1.1 million lb (500,000 kg) from 1999 to 2009 (Lake Erie Yellow Perch Task 

Group 2010).

Yellow perch is present in at least low numbers in most of the surface water habitats on the 

Fermi site based on fish surveys conducted in 2008 and 2009 (AECOM 2009). Yellow perch 

was among the most common species observed during entrainment studies conducted at the 

Fermi 2 cooling water intake in 2008 and 2009, and it is estimated that more than 4.8 million 

yellow perch eggs and larvae were entrained during the year-long study (AECOM 2009) (Table 

3–17). No yellow perch adults or juveniles were observed during impingement studies 

conducted at the Fermi 2 cooling water intake during the same period (AECOM 2009)

(Table 3–18).
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3.7.3.2 Recreationally Important Species

Lake Erie is the warmest and most biologically productive of the Great Lakes, producing more 

fish each year than any of the other Great Lakes (Bolsenga and Herdendorf 1993). Walleye 

and yellow perch are the most popular recreational species in the western basin of Lake Erie. 

The total noncharter sport harvest from the Michigan waters of Lake Erie for 2009, based on 

creel surveys, was estimated at 460,425 fish (Thomas and Haas 2010). Walleye and yellow 

perch together accounted for 93 percent of the reported recreational fishing harvest. Walleye 

harvest rates had declined since the previous estimate obtained in 2007, while yellow perch 

harvest rates were at the highest levels observed since 1998. It is estimated that noncharter 

boat anglers harvested 85,348 walleye and 344,811 yellow perch during 2009, whereas charter

boat anglers harvested 10,258 walleye and 9,989 yellow perch (Thomas and Haas 2010). 

Reported recreational harvests of other species from the Michigan waters of Lake Erie were 

considerably lower than those of walleye and yellow perch; they included white perch, channel 

catfish, freshwater drum, largemouth bass, smallmouth bass, and rainbow trout (Thomas and 

Haas 2010).

In 2009, sport anglers made more than 300,000 trips to fish in the Ohio waters of the western 

basin of Lake Erie, and the private sport boat fishing effort within the Ohio waters of the basin 

totaled more than 1.6 million hours (ODNR 2010). Charter boat fishing effort within the Ohio

waters of the western basin in 2009 totaled approximately 158,000 hours (ODNR 2010). 

Estimates of angler hours indicate that most of the private boat angling effort was directed 

toward walleye (56 percent of angler hours) and yellow perch (35 percent). Smallmouth bass 

(4 percent), white bass (2 percent), and largemouth bass (2 percent) were less commonly 

targeted by private boat anglers (ODNR 2010). Charter boat anglers mainly targeted walleye 

(95 percent of angler hours), followed by yellow perch (4 percent) and smallmouth bass (less 

than 1 percent). The total (combined private and charter boat) recreational harvest of fish from 

the Ohio waters of the western basin in 2009 was estimated at approximately 2.6 million fish 

and was made up primarily of walleye (21 percent of harvest), yellow perch (72 percent of 

harvest), and white bass (5 percent of harvest). Smallmouth bass, white perch, freshwater 

drum, channel catfish, and other species accounted for less than 2 percent of the recreational 

harvest within the Ohio waters of the western basin of Lake Erie (ODNR 2010). On the basis of 

fish surveys conducted in 2008 and 2009, each of these recreationally important species, with 

the exception of walleye, is present in Lake Erie adjacent to the Fermi site and/or in onsite 

surface water habitats (AECOM 2009).

Sport fish landings are managed by using State-implemented fishing regulations, such as 

harvest quota systems and requirements that fish must be within certain length limits to be 

harvested. Typical goals of such regulations are to maintain the numbers of catchable-sized

and reproductive-sized individuals at desired levels and to maintain sustainable population 

levels. For example, walleye fisheries throughout Lake Erie were affected by reduced 

spawning, which resulted in a lower adult abundance during the 1990s. Harvest quotas and 

other fishing regulations for walleye became more restrictive because of this reduced adult 

population, and the result was a rebound in the adult walleye population. Subsequently, less 

restrictive fishing regulations for the walleye have been implemented in more recent years. The 

States of Michigan and Ohio have implemented other species-specific fishing regulations.

Recreational angling also occurs in other waters within the vicinity of the Fermi site, such as 

ponds and tributary drainages of Lake Erie. Swan Creek supports a recreational fishery for 

common game fish, including largemouth bass and bluegill. Portions of the creek located near 

recreational areas, such as public parks, receive the largest share of fishing pressure. There 
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are no significant recreational fisheries within the boundaries of Stony Creek, the area managed

as part of the DRIWR, or other water bodies located at the Fermi site.

Because many of the recreationally important aquatic species that occur in the vicinity of the 

Fermi site are also commercially important, the distribution and life history information for those 

species was summarized above. The distribution and life history information for other 

recreationally important species that may occur in the vicinity of the site is summarized below. 

Bluegill (Lepomis macrochirus)

The bluegill is popular with many recreational anglers and is important ecologically because it 

can affect the composition of aquatic communities by controlling zooplankton populations and 

by serving as an important prey item for many larger fish, including largemouth bass and 

northern pike.

The bluegill is native to the Great Lakes and Mississippi River Basins from Quebec and New 

York to Minnesota and south to the Gulf of Mexico. It is also native to the Atlantic and Gulf 

Slope drainages from the Cape Fear River, which flows through North Carolina, to the Rio 

Grande River, which flows through Texas, New Mexico, and northern Mexico (Page and 

Burr 1991). It has been introduced throughout North America and is now found in many other 

parts of the world. This sunfish species most commonly inhabits shallow lakes, ponds, 

reservoirs, sloughs, and slow-flowing streams. It is often associated with rooted aquatic 

vegetation and silt, sand, or gravel substrates. 

Bluegills lay eggs in a nest excavated in shallow water by the male on bottoms of gravel, sand, 

or mud that contain pieces of debris. Adult bluegills can reach sizes of between 10 and 16 in. 

(25 and 40 cm) and may live longer than 10 years. Young bluegill feed primarily on planktonic 

crustaceans, insect larvae, and worms. Adults eat mainly aquatic insects, small crayfish, and 

small fishes; in some bodies of water, adults may primarily consume zooplankton. 

The bluegill is very common in the immediate vicinity of the Fermi site, according to recent fish

surveys. Francis and Boase (2007) found that bluegills made up approximately 9 percent of the 

individual fish collected during surveys in Swan Creek. Bluegills were also found in most 

aquatic habitats associated with the Fermi site during surveys conducted in the 2008–2009

period; overall, they accounted for 13 percent of the individual fish collected (AECOM 2009). 

Impingement rates measured at the cooling water intake indicate that an estimated 214 bluegills 

were impinged at the Fermi 2 cooling water intake from August 2008 through July 2009 (Table 

3–18) (AECOM 2009), accounting for approximately 7 percent of the fishes impinged by Fermi 2

during the sampling period. No bluegill eggs or larvae were specifically identified in entrainment

samples collected at the Fermi 2 cooling water intake from August 2008 through July 2009 

(AECOM 2009). However, it was estimated that approximately 70,000 eggs or larval stages of 

fish in the same fish family (Centrarchidae) would be entrained annually on the basis of the 

presence of eggs and larvae not identifiable to the species level (AECOM 2009). Some portion 

or all of these unidentified eggs and larvae could have been those of bluegill.

Largemouth Bass (Micropterus salmoides)

The largemouth bass is native to the Great Lakes, Hudson Bay (Red River), and Mississippi 

River Basins from southern Quebec to Minnesota and south to Texas, throughout the Gulf 

Coast and southern Florida, and in Atlantic coast drainages from North Carolina to Florida. 

Because of its popularity as a sport fish, this species has been introduced throughout the 

United States, southern Canada, and much of the world. Largemouth bass occur in a variety of 

habitats, including clear and turbid waters of lakes, ponds, reservoirs, and swamps and pools or 

in backwater areas of creeks and rivers. They are often found in areas containing aquatic 

vegetation.
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Largemouth bass spawn primarily in the spring and summer in water temperatures of 60 °F 

(15.5 °C) or higher. Males excavate nests in shallow water. After a female deposits eggs in the 

nest, the male guards the eggs, which hatch within a few days. Largemouth bass reach sexual 

maturity in 2 to 5 years and can attain sizes as large as 38 in. (96 cm), although approximately 

28 in. (70 cm) is a typical size for older adult fish. This species feeds mainly upon zooplankton 

as fry. As the juvenile grows, it begins to prey on larger organisms, including insect larvae, 

crustaceans, and small fish. Adults prey mainly on fish but are also known to eat other 

organisms, including crayfish and frogs. 

The largemouth bass is a popular sport fish in the Great Lakes region, including Lake Erie 

and its tributaries. This species is present, at least in low numbers, in most of the surface 

water habitats on the Fermi site, according to fish surveys conducted in 2008 and 2009 

(AECOM 2009). Largemouth bass was among the species observed during entrainment

studies conducted at the Fermi 2 cooling water intake in 2008 and 2009, and it is estimated that 

approximately 152,000 largemouth bass eggs and larvae were entrained during the year-long 

study (AECOM 2009) (Table 3–17). On the basis of species-specific impingement rates 

measured at the Fermi 2 cooling water intake, it is estimated that a total of 31 largemouth bass 

individuals were impinged at the Fermi 2 cooling water intake during the period from 

August 2008 through July 2009 (AECOM 2009) (Table 3–18).

Smallmouth Bass (Micropterus dolomieu)

The smallmouth bass is native to the St. Lawrence–Great Lakes, Hudson Bay (Red River), and 

Mississippi River Basins from southern Quebec to North Dakota and south to northern Alabama 

and eastern Oklahoma. It has been widely introduced throughout the United States, southern 

Canada, and other countries. Smallmouth bass prefer large, clear lakes (especially in the 

northern part of the range) and clear, intermediate-sized streams that contain large pools and

abundant cover (e.g., rocks, shelves, and logs), and they prefer cool summer temperatures. 

Adults typically seek the shelter of pools or deep water during the day.

Spawning habitat includes shallow water in lakes or quiet areas of streams, often fairly close to 

shore. In lakes, spawning adults sometimes move a short distance up a stream to spawn. 

Spawning generally occurs in late spring or early summer. Females deposit eggs in nests that 

are constructed by the males; nests usually occur near cover on gravel or sand bottoms. Eggs 

typically hatch in 2 to 10 days, and males guard eggs and hatchlings for a period of 4 weeks or 

longer. Individuals usually attain sexual maturity at 2 to 6 years of age, depending on local 

conditions. Young smallmouth bass eat primarily small crustaceans and aquatic insects 

(e.g., midge larvae and pupae) until the fish are about 2 in. (5 cm) in length, after which they

primarily eat fish. Crayfish, amphibians, and larger insects often become the dominant or 

seasonal foods of local smallmouth bass populations.

In addition to being a species that has recreational importance, smallmouth bass have

ecological importance as being one of the top-level predators in aquatic habitats in the 

Great Lakes region. Smallmouth bass make up a small component of the aquatic community in 

the immediate vicinity of the Fermi site, according to recent fish surveys. Francis and 

Boase (2007) captured low numbers of smallmouth bass in collections from Swan Creek. 

Smallmouth bass were not found in most aquatic habitats on the Fermi site during surveys 

conducted in the 2008–2009 period (AECOM 2009), perhaps because many of these habitats 

have conditions (e.g., warm summer water temperatures and high turbidity) that are not optimal 

for smallmouth bass. Based on impingement rates measured at the cooling water intake, it is 

estimated that 62 smallmouth bass were impinged at the Fermi 2 cooling water intake from 

August 2008 through July 2009 (AECOM 2009) (Table 3–18), accounting for approximately 

2 percent of the fishes impinged by Fermi 2. No smallmouth eggs or larvae were identified in 
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entrainment samples collected at the Fermi 2 cooling water intake from August 2008 through 

July 2009 (AECOM 2009). However, it was estimated that approximately 70,000 eggs or larval 

stages of fish in the same fish family (Centrarchidae) would be entrained annually based on the 

presence of eggs and larvae not identifiable to the species level (AECOM 2009). Some portion 

or all of these unidentified eggs and larvae could have been those of smallmouth bass.

3.7.3.3 State-Listed Aquatic Species

This section presents information about Michigan State-listed aquatic species near the Fermi 

site. Section 3.8 discusses aquatic species that are either Federally or both Federally and 

Michigan State listed. Table 3–22 indicates State-listed aquatic species that may occur on or 

near the Fermi site or in Monroe County.

Exclusively State-Listed Aquatic Species(a) That Have Been Observed in 

Monroe County(b) and Their Potential To Occur on the Fermi Site

Common Name Scientific Name

State

Status(c)

Fermi

Site(d)

Mollusks

hickorynut Obovaria olivaria E U

purple lilliput Toxolasma lividus E U

purple wartyback Cyclonaias tuberculata T U

round hickorynut Obovaria subrotunda E U

salamander mussel Simpsonaias ambigua E P

slippershell Alasmidonta viridis T U

wavyrayed lampmussel Lampsilis fasciola T U

Fish

channel darter Percina copelandi E U

creek chubsucker Erimyzon claviformis E U

eastern sand darter Ammocrypta pellucida T U

pugnose minnow Opsopoedus emiliae E P

river darter Percina shumardi E U

sauger Sander canadensis T P

silver shiner Notropis photogenis E U

southern redbelly dace Phoxinus erythrogaster E U

(a) This list contains those species that are listed for protection only by the State of Michigan. Section 3.8 

discusses species that are both State and Federally listed.

(b) County-level occurrence based on information provided by MNFI (MNFI 2014g).

(c) State species information provided by MNFI (MNFI 2014g) is as follows: E = endangered and

T = threatened.

(d) P = possible occurrence on Fermi site due to presence of potentially suitable habitat and nearby 

populations, but it has not been reported on or adjacent to the Fermi site. U = unlikely to occur due to 

absence of nearby populations and/or lack of suitable habitat on or adjacent to the Fermi site. Species for 

which there was no record of occurrence reported by MNFI (MNFI 2014g) for Monroe County were 

considered unlikely to occur on the Fermi site.
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Excluding Federally listed species, the State of Michigan has listed 15 aquatic species as 

endangered (10 species) or threatened (5 species) in Monroe County (Table 3–22) 

(MNFI 2014g). Of these, 8 species are fish and 7 species are mollusks (all freshwater 

mussels). Additional information about the distribution, life history, population status, and 

potential for occurrence of exclusively State-listed threatened and endangered aquatic species 

that could be present in the vicinity of the Fermi site is provided below. MNFI (2014g) presents 

additional information about distribution, life history, and ecology of species of special concern 

to the State of Michigan.

Hickorynut (Obovaria olivaria)

The hickorynut is a freshwater unionid mussel that is listed as endangered by the State of 

Michigan (MNFI 2014g). The historic range for the hickorynut includes eastern North America 

from western Pennsylvania and New York to Missouri, Iowa, and Kansas, and from Michigan 

and the St. Lawrence drainage southward to Alabama and Arkansas (Badra 2004a). In 

Michigan, the historic range for this species included the Kalamazoo, Grand, Menominee, 

Saginaw, and Detroit Rivers, as well as Lake Erie and Lake St. Clair (Badra 2004a). Habitat for 

the hickorynut consists of sand or mixed sand and gravel substrates in large rivers and lakes 

(Badra 2004a).

Section 3.7.1 describes the general life history of unionid mussels. Gravid individuals of the 

hickorynut retain larvae internally over the winter and release glochidia in the spring 

(Badra 2004a). The shovelnose sturgeon (Scaphirhynchus platorynchus) and freshwater drum 

have been shown to be suitable hosts, and it possibly uses additional species as hosts in 

natural environments (Badra 2004a). Like all freshwater mussels, the hickorynut is a filter 

feeder.

Principal threats to the hickorynut include siltation and runoff from human activities, damming 

and dredging of rivers, and the spread of introduced invasive species. Zebra mussels pose a 

threat for freshwater mussels because they compete for food and benthic habitat and because 

they attach to the shells of native mussels, making it difficult for the mussels to move and feed 

properly. The hickorynut has not been reported from Monroe County (MNFI 2014g). Although 

streams with conditions suitable for the hickorynut are not present on the Fermi site, some 

nearshore areas in Lake Erie in the vicinity of the site could potentially provide suitable 

substrate.

Purple Lilliput (Toxolasma lividus)

The purple lilliput is a freshwater unionid mussel listed as endangered by the State of Michigan 

(MNFI 2014g). The historic range for the purple lilliput extends from Michigan south to Alabama 

and from Missouri and Arkansas eastward to Virginia (Carman 2002a). In Michigan, the purple 

lilliput is generally restricted to the southeastern portion of the State, and spent shells have been 

found from sites in the River Raisin in Monroe Country (Carman 2002a). The purple lilliput 

occurs in small- to medium-sized streams and occasionally in large rivers and lakes; the 

preferred substrate for this species is well-packed sand or gravel and a water depth of less than 

1 m (3 ft) (MNFI 2014g).

Section 3.7.1 describes the general life history of unionid mussels. Gravid purple lilliputs have 

been known to retain the larvae internally for about a year, although populations in Michigan 

reportedly produce multiple broods in a single year (Carman 2002a). Fish hosts for the purple 

lilliput include green sunfish and longear sunfish (Lepomis megalotis) (Carman 2002a); both 

species have been observed in aquatic habitats associated with the Fermi site (AECOM 2009). 

Like all freshwater mussels, the purple lilliput is a filter feeder.
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Principal threats to survival of the species are similar to those described previously for the 

hickorynut. The purple lilliput was last reported from Monroe County in 1977 (MNFI 2014g). 

Streams with conditions suitable for the purple lilliput are not present on the Fermi site. The

portions of Lake Erie adjacent to the Fermi site do not offer suitable habitat for this species.

Purple Wartyback (Cyclonaias tuberculata)

The purple wartyback is a freshwater unionid mussel listed as threatened by the State of 

Michigan (MNFI 2014g). The historic range for the purple wartyback includes eastern 

North America from Ontario, Canada, south to Alabama, west to Oklahoma, and east to 

Pennsylvania (Badra 2004b). It is present in the Mississippi River, Ohio River, Lake Michigan, 

Lake St. Clair, and Lake Erie drainages (Badra 2004b). The purple wartyback is found in 

medium to large rivers with gravel or mixed sand and gravel substrates in areas with relatively 

fast current (Badra 2004b).

Section 3.7.1 describes the general life history of unionid mussels. Gravid individuals of the 

purple wartyback release glochidia during the same summer that they are fertilized 

(Badra 2004b). The yellow bullhead and channel catfish have been shown to be suitable hosts 

for the purple wartyback, and it possibly uses additional species as hosts in natural 

environments (Badra 2004b). Like all freshwater mussels, the purple wartyback is a filter 

feeder.

Principal threats to survival of the species are similar to those described previously for the 

hickorynut. The purple wartyback was last reported from Monroe County in 2000 (MNFI 2014g). 

Streams with conditions suitable for the purple wartyback are not present on the Fermi site, and 

Lake Erie adjacent to the Fermi site does not offer suitable habitat for this species.

Round Hickorynut (Obovaria subrotunda)

The round hickorynut is a freshwater unionid mussel listed as endangered by the State of 

Michigan (MNFI 2014g). The historic range for the round hickorynut includes much of eastern 

North America from Ontario and New York southward to Arkansas, Mississippi, Alabama, and 

Georgia. It has historically been present in the Ohio, Tennessee, Cumberland, and Mississippi 

River systems, as well as the St. Lawrence and Lake Erie/Lake St. Clair drainages 

(Carman 2001f). In Michigan, the round hickorynut occurs in the Lake St. Clair and Lake Erie 

drainages, and it has historically been observed in Sanilac, St. Clair, Macomb, Wayne, Monroe, 

and Lenawee Counties (Carman 2001f). The round hickorynut is found in sand and gravel 

substrates of moderately flowing medium to large rivers and along the shores of Lake Erie and 

Lake St. Clair near river mouths (Carman 2001f).

Section 3.7.1 describes the general life history of unionid mussels. Gravid individuals of the 

round hickorynut retain fertilized larvae over the winter and release glochidia during the early 

summer (Carman 2001f). The host fish species for the round hickorynut is unknown 

(Carman 2001f). Like all freshwater mussels, the round hickorynut is a filter feeder.

Principal threats to survival of the species are similar to those described previously for the 

hickorynut. The round hickorynut was last reported from Monroe County in 1977 (MNFI 2014g). 

Streams with conditions suitable for the round hickorynut are not present on the Fermi site, 

although areas in Lake Erie near the mouths of Swan Creek or Stony Creek could contain 

suitable substrates.

Salamander Mussel (Simpsonaias ambigua)

The salamander mussel is a freshwater unionid mussel listed as endangered by the State of 

Michigan (MNFI 2014g). The historic range for the salamander mussel includes North America 

from Ontario southward to Tennessee, where it is found in the Great Lakes Basin in the Lake 
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St. Clair, Lake Huron, and Lake Erie drainages. The salamander mussel is also found in the 

Ohio River, Cumberland River, and upper Mississippi River drainages (Carman 2002b). The 

salamander mussel is found in medium to large rivers and in lakes. It is usually found in silt or 

sand substrates under flat stones (MNFI 2014g).

Section 3.7.1 describes the general life history of unionid mussels. The biology of the 

salamander mussel is poorly understood. Gravid females release glochidia in the spring or 

summer (Carman 2002b). The host for the salamander mussel is the mudpuppy (Necturus 

maculosus) (Carman 2002b), a large (8- to 15-in.-long) salamander species that inhabits many 

water bodies in Michigan. Like all freshwater mussels, the salamander mussel is a filter feeder.

Principal threats to survival of the salamander mussel are similar to those described previously 

for the hickorynut. The salamander mussel was last reported from Monroe County in 1977

(MNFI 2014g). Streams with conditions suitable for the salamander mussel are not present on 

the Fermi site. However, areas in Lake Erie near the site could contain suitable substrates and

the mudpuppy host. Although the exact locations of the salamander mussel’s occurrence are 

unknown, its nearest reported occurrence is from Macon Creek, a medium-sized tributary of 

Lake Erie, and La Plaisance Bay, which is located 6 to 9 mi (10 to 15 km) southwest of the 

Fermi site (Carman 2002b).

Slippershell (Alasmidonta viridis)

The slippershell is a freshwater unionid mussel listed as threatened by the State of Michigan 

(MNFI 2014g). The historic range for this species extends from southern Ontario south to 

Alabama and from South Dakota and Kansas east to New York, Virginia, and North Carolina 

(Carman 2002c). It is found in the Lake Michigan, Lake Huron, Lake St. Clair, and Lake Erie 

drainages of the Great Lakes Basin and is also present in the Mississippi River system from the 

Ohio River drainage to the Tennessee River drainage (Carman 2002c). In Michigan, this 

species has been observed in a number of counties, including Monroe and Washtenaw 

Counties. The slippershell typically occurs in creeks and headwaters of rivers in sand or gravel 

substrates, although it can also be present in larger rivers and lakes and has occasionally been 

found in mud substrates (MNFI 2014g).

Section 3.7.1 describes the general life history of unionid mussels. The biology of the 

slippershell is poorly understood. The slippershell retains larvae internally for about a year. 

Fish species that are hosts for the slippershell include the johnny darter (Etheostoma nigrum) 

and mottled sculpin (Carman 2002c). Like all freshwater mussels, the slippershell is a filter 

feeder.

Principal threats to survival of the slippershell are similar to those described previously for the 

hickorynut (Carman 2002c). The slippershell was last reported from Monroe County in 2000 

(MNFI 2014g). Streams with conditions suitable for the slippershell are not present on the 

Fermi site, and Lake Erie adjacent to the Fermi site does not offer suitable habitat for this 

species

Wavyrayed Lampmussel (Lampsilis fasciola) 

The wavyrayed lampmussel is a freshwater unionid mussel listed as threatened by the State of 

Michigan (MNFI 2014g). The historic range for this species extended from Ontario to Alabama 

and Illinois to New York, and it is now discontinuously distributed in the Great Lakes tributaries 

of Lake Michigan, Lake Erie, Lake Huron, and Lake St. Clair, and in the Ohio, Mississippi, and 

Tennessee River drainages (Stagliano 2001c). Historically, the wavyrayed lampmussel was 

found throughout the streams and rivers of southeastern Michigan, but the current distribution is 

more limited (Stagliano 2001c). It is currently known to occur in the Clinton River drainage in 

Macomb and Oakland Counties; the St. Joseph River in Hillsdale County; the Belle River in 
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St. Clair County; the Huron River drainage in Washtenaw County; and the River Raisin drainage 

in Jackson, Lenawee, and Washtenaw Counties. It has also been reported in the past from the 

River Raisin in Monroe County, although the status of populations in that area is not known. 

The wavyrayed lampmussel occurs in small to medium-sized shallow streams, in and near 

riffles, with good current; it rarely occurs in medium or larger rivers (Stagliano 2001c). The 

preferred substrate is sand and gravel (Stagliano 2001c).

Section 3.7.1 describes the general life history of unionid mussels. The wavyrayed lampmussel 

breeding season extends from August of one year through July of the following year 

(Stagliano 2001c). Following fertilization, gravid females retain larvae over the winter and 

release glochidia during spring and summer (Stagliano 2001c). The smallmouth bass is the 

only known fish host (Stagliano 2001c). After dropping off the fish host, this species reportedly 

does not move more than approximately 300 yards (300 m) throughout its life (Stagliano 2001c). 

The life span of the wavyrayed lampmussel is unknown (Stagliano 2001c). Like all freshwater 

mussels, the wavyrayed lampmussel is a filter feeder.

Principal threats to survival of this species are similar to those described previously for the 

hickorynut. The wavyrayed lampmussel was last reported from Monroe County in 2000 

(MNFI 2014g). Streams with conditions suitable for the wavyrayed lampmussel are not present 

on the Fermi site, and Lake Erie adjacent to the Fermi site does not offer suitable habitat for this 

species.

Channel Darter (Percina copelandi)

The channel darter is a small fish listed as endangered by the State of Michigan (MNFI 2014g). 

Its distribution extends from the upper St. Lawrence drainages through the Great Lakes Basin 

and into the Ohio River Basin. The darter is found primarily in the Ohio River Basin, but isolated 

populations occur southward to Louisiana (Carman and Goforth 2000c). In Michigan, the 

darter’s range historically included nearshore areas of Lake Erie and Lake Huron, including 

some tributaries (Carman and Goforth 2000c). Since 1994, it has been recorded only in the 

Au Sable, Pine, and St. Clair Rivers in Michigan (Carman and Goforth 2000c). The channel 

darter’s habitat includes rivers and large creeks with moderate current over sand and gravel 

substrate. It has also been recorded in wave-swept areas of Lake Huron and Lake Erie that 

have coarse-sand, fine-gravel beach and sandbar substrates (Carman and Goforth 2000c). The 

darter is usually found in deeper water but will move into shallow water (less than 3 ft) (less than 

1 m) at night (Carman and Goforth 2000c).

The channel darter spawns in July in Michigan and requires flowing water conditions for 

successful spawning (Carman and Goforth 2000c). Spawning males maintain a territory with a 

radius of approximately 1.6 ft (0.5 m) around a large rock as a spawning female partially buries 

herself in gravel downstream of the rock and deposits her eggs (Carman and Goforth 2000c). 

Adults grow to be approximately 2 in. (5 cm) long. Channel darters are benthic feeders whose 

diet consists of small invertebrates, including mayfly and midge larvae, small crustaceans, 

algae, and organic debris (Carman and Goforth 2000c). 

In Michigan, the range of the channel darter was severely reduced during the past century. 

Before 1957, this species was reported from 11 counties along Lake Huron, Lake St. Clair, the 

St. Clair River, and Lake Erie (Carman and Goforth 2000c). Declines in abundance and 

distribution have been attributed primarily to loss of suitable habitat (Carman and 

Goforth 2000c). The channel darter was last observed in Monroe County in 1941

(MNFI 2014g). No suitable stream habitat for the channel darter is present on the Fermi site, 

although the potential exists for this species to inhabit wave-swept shorelines in Lake Erie, such 

as that located along the eastern edge of the Fermi site. However, no channel darter individuals

were collected during recent surveys of aquatic habitats on the Fermi site (AECOM 2009), and 
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none were reported in past biological surveys of Stony Creek (MDEQ 1996, 1998) or the Swan 

Creek estuary (Francis and Boase 2007) near the Fermi site. No channel darter eggs or larvae 

were observed during entrainment and impingement studies conducted at the Fermi 2 intake 

in 2008 and 2009 (AECOM 2009).

Creek Chubsucker (Erimyzon oblongus claviformis)

The creek chubsucker is listed as endangered by the State of Michigan and has been reported 

from Monroe County (MNFI 2014g). This fish occurs throughout most of the eastern 

United States but is becoming increasingly rare at the edges of its historic distribution. The 

northern extent of the range for the creek chubsucker terminates in Michigan where it has been 

found in the Kalamazoo River, St. Joseph River, and River Raisin and their tributaries. For the 

last two decades, it has been reported only in the Kalamazoo River, located west of Monroe 

County. The creek chubsucker inhabits headwaters and clear creeks with moderate currents 

over sand-gravel substrate. In Michigan, the creek chubsucker has been reported primarily 

from streams that are 3 to 5 ft (1 to 1.5 m) deep with moderately swift currents and muddy 

bottoms (Carman 2001b).

The creek chubsucker migrates upstream to spawn in early spring. Eggs are usually scattered 

over substrates, although males have been observed building nests. Adults may produce up to 

9,000 eggs per year. Juveniles of this species often form schools in vegetated headwater areas 

with less current but migrate to deeper downstream areas as they become adults. Life 

expectancy of the creek chubsucker is approximately 5 years. The diet of the creek chubsucker 

is mostly small benthic invertebrates (Carman 2001b).

The preferred habitat type for this species (clear creeks with sandy substrates and moderate 

current) does not occur on the Fermi site. No creek chubsuckers were collected during recent 

surveys on the Fermi site (AECOM 2009), and none were reported in past biological surveys of 

Stony Creek (MDEQ 1996, 1998) or the Swan Creek estuary (Francis and Boase 2007) in the 

vicinity of the Fermi site.

Eastern Sand Darter (Ammocrypta pellucida)

The eastern sand darter is listed as threatened by the State of Michigan (MNFI 2014g). This 

fish occurs in the St. Lawrence River drainage and the Lake Champlain drainage in Vermont 

and occurs south to West Virginia and Kentucky and west through Ontario and Michigan

(Derosier 2004a). Within Michigan, this darter was found historically in the Huron, Detroit, 

St. Joseph, River Raisin, and Rouge Rivers and in Lake St. Clair. However, in the past 

2 decades, it has been recorded in the Lake St. Clair and Huron River drainages 

(Derosier 2004a). The preferred habitats of the eastern sand darter are streams and rivers with 

sandy substrates and lakes with sandy shoals. They frequently occur in slow-moving streams 

with deposits of fine sand, often just downstream of a bend (Derosier 2004a). 

The spawning period for the eastern sand darter occurs from April through June. Eggs are 

buried singly in sandy sediments. These darters reach sexual maturity at age one and have a 

life expectancy of 2 to 3 years. The eastern sand darter feeds mostly on chironomid larvae but 

will also prey upon aquatic worms and small crustaceans (Derosier 2004a).

Declines in Michigan populations of eastern sand darters have been attributed to siltation, 

modification of riparian areas, channel and flow alterations, and nutrient enrichment 

(Derosier 2004a). In the vicinity of the Fermi site, the eastern sand darter was last observed in 

Monroe County in 1929 (MNFI 2014g). Although suitable habitat for this species could be 

present in Stony Creek, no eastern sand darters were collected during recent surveys of aquatic 

habitats on the Fermi site (AECOM 2009), and none were reported in past biological surveys of 

Stony Creek (MDEQ 1996, 1998) or the Swan Creek estuary (Francis and Boase 2007) near 
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the Fermi site. No eastern sand darter eggs or larvae were collected during entrainment or 

impingement studies in 2008 and 2009 (AECOM 2009).

Pugnose Minnow (Opsopoeodus emiliae)

The pugnose minnow is listed as endangered by the State of Michigan (MNFI 2014g). This fish 

species has been documented from the southern Great Lakes Basin through the Mississippi 

River valley to the Gulf of Mexico (Carman 2001c). Although common in the southeastern 

portion of its range, it is becoming rare at the northern edge of its range (Carman 2001c). 

Historically, the pugnose minnow occurred in Michigan tributaries and nearshore areas of 

Lake Erie and Lake St. Clair, located approximately 15 mi (24 km) northeast of the Fermi site, 

although there is no recent record of occurrence (Carman 2001c). The pugnose minnow 

inhabits slow, clear waters of rivers and shallow regions of lakes and is found in greatest 

abundance in weedy areas over sand or organic substrate (Carman 2001c). Historically, it 

occurred in turbid areas of the Huron River that lacked aquatic vegetation, although it is 

believed that such conditions are not preferred (Carman 2001c).

The life history of the pugnose minnow is not well documented. Spawning occurs in June 

and July (MNFI 2014g). After hatching, it reaches its adult length of 2 in. (5 cm) within 2 years 

(Carman 2001c). The pugnose minnow feeds on small crustaceans, dipteran larvae, and other 

aquatic invertebrates, as well as algae and plants (Carman 2001c).

In Michigan, the pugnose minnow has been observed in Monroe County within the past 

15 years (MNFI 2014g). Declines in Michigan populations have been attributed primarily to 

increased siltation and loss of weedy aquatic habitats (Carman 2001c). Although there is a 

potential for suitable habitat for the pugnose minnow to be present in the vicinity of the Fermi 

site, no individuals were collected during recent surveys on the Fermi site (AECOM 2009), and 

none were reported in past biological surveys of Stony Creek (MDEQ 1996, 1998) or the Swan 

Creek estuary (Francis and Boase 2007) near the Fermi site. No pugnose minnow eggs or 

larvae were collected during entrainment or impingement studies in 2008 and 2009 

(AECOM 2009).

Pugnose Shiner (Notropis anogenus)

The pugnose shiner is listed as endangered by the State of Michigan (MNFI 2014g). The 

distribution of this fish species historically ranged from the Lake Ontario drainage of eastern 

Ontario and western New York to southeastern North Dakota and central Illinois 

(Derosier 2004b). The species is rare and declining in much of its former range 

(Derosier 2004b). Within Michigan, the pugnose shiner was historically found within at least 

18 watersheds (MNFI 2014g). The pugnose shiner usually inhabits clear vegetated lakes and 

vegetated pools and runs of low-gradient streams and rivers and appears to be extremely 

intolerant of increased levels of turbidity (MNFI 2014g). The species feeds on filamentous 

green algae, plant material, and small crustaceans (Derosier 2004b). There is little other 

information available about the life history of this species.

Although not reported from Monroe County, where Fermi 2 is located, pugnose shiner has been 

reported from the three adjacent counties—Wayne, Washtenaw, and Lenawee Counties—and 

therefore is addressed here. The pugnose shiner was last reported from Washtenaw County 

in 1938 and from Wayne County in 1894; it has not been reported from Monroe County 

(MNFI 2014g). No individuals were collected during recent surveys on the Fermi site 

(AECOM 2009), and none were reported in past biological surveys of Stony Creek 

(MDEQ 1996, 1998) or the Swan Creek estuary (Francis and Boase 2007) near the Fermi site. 

No pugnose shiner eggs or larvae were collected during entrainment or impingement studies 
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in 2008 and 2009 (AECOM 2009). Suitable habitat for this species does not occur on the Fermi 

site.

River Darter (Percina shumardi)

The river darter is listed as endangered by the State of Michigan (MNFI 2014g). The distribution 

of this fish species ranges from southern Canada to the Gulf of Mexico, including the Great 

Lakes Basin (Carman 2001d). The river darter is found in rivers and large streams with deep, 

fast-flowing riffles and cobble and boulder substrates. This species has also been observed at 

depths below 15 ft (5 m) in nearshore areas of the Great Lakes and is tolerant of elevated levels 

of turbidity (Carman 2001d).

The river darter is believed to move upstream to spawn. Spawning occurs in late winter to early 

spring in southern areas from April through May in the Midwest and as late as June or July in 

Canada. The female river darter buries eggs in loose gravel or sand substrates during 

spawning, and neither males nor females provide parental care to the young. River darters 

grow to be about 3 in. (7.5 cm) long, mostly within the first year of development, and sexual 

maturity is usually reached after 1 year. As juveniles, river darters primarily feed on small 

zooplankton; adults prey upon midge and caddisfly larvae, as well as some snail species 

(Carman 2001d).

Even though the river darter is relatively tolerant of elevated turbidity and other water quality 

changes, the species generally requires deep and swiftly flowing waters as habitat. Such 

habitats are becoming more limited as a result of flood control efforts and riverine 

impoundments. The river darter was last observed in Monroe County in 1941 (MNFI 2014g).

No suitable stream habitat for the river darter is present on the Fermi site. No river darters were 

collected during recent surveys on the Fermi site (AECOM 2009), and none were reported in

past biological surveys of Stony Creek (MDEQ 1996, 1998) or the Swan Creek estuary (Francis 

and Boase 2007) near the Fermi site. No river darter eggs or larvae were collected during 

entrainment and impingement studies in 2008 and 2009 (AECOM 2009).

Sauger (Sander canadensis)

The sauger is listed as threatened by the State of Michigan (MNFI 2014g). The native range for 

this fish species includes the St. Lawrence, Great Lakes, Hudson Bay, and Mississippi River 

Basins and the Tennessee River in Alabama and Louisiana; the sauger has also been 

introduced into the Atlantic, Gulf, and southern Mississippi River drainages (Derosier 2004c). 

This species was historically abundant in Lake Erie. 

The sauger, which is closely related to the walleye, prefers turbid areas of lakes, reservoirs, and 

large rivers (MNFI 2014g). This species spawns over shallow areas with gravel and rubble 

substrates in May or June when temperatures range from 4 to 6 °C (39 to 43 °F) 

(Derosier 2004c). The sauger broadcasts demersal, adhesive eggs over shoals during the 

night. After hatching, young sauger spend up to 9 days on the bottom, absorbing yolk from their 

egg sacs. Males reach sexual maturity within 3 years, while females take 4 to 6 years to mature 

(Derosier 2004c). The life expectancy for the sauger is up to 13 years (Derosier 2004c), and it 

can attain lengths up to approximately 18 in. (45 cm) (NatureServe 2009). Saugers have a 

specialized structure in their eyes that makes them very sensitive to light, and they prefer to 

feed at night in clearer waters or during the day in turbid areas (Derosier 2004c). Juvenile 

sauger prey on zooplankton and aquatic insect larvae, whereas adults feed on fish and larger 

invertebrates, including gizzard shad, emerald shiner, crappie, bass, freshwater drum, leeches, 

crayfish, and insects (Derosier 2004c).

The sauger was last reported from Monroe County in 1996 (MNFI 2014g). Although there is no 

riverine habitat suitable for sauger on or adjacent to the Fermi site, suitable habitat could be 
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present in Lake Erie near the Fermi site. However, no sauger individuals were collected during 

recent surveys on the Fermi site (AECOM 2009), and none were reported in past biological 

surveys of Stony Creek (MDEQ 1996, 1998) or the Swan Creek estuary (Francis and 

Boase 2007) near the Fermi site. No sauger eggs or larvae were collected during entrainment

and impingement studies in 2008 and 2009 (AECOM 2009).

Silver Shiner (Notropis photogenis)

The silver shiner is listed as endangered by the State of Michigan (MNFI 2014g). The 

distribution for this fish species ranges from the Great Lakes and their tributaries through the 

Ohio River Basin and Tennessee drainage to northern Alabama and Georgia. This shiner is 

fairly common within most of the Ohio River Basin but occurs more rarely in tributaries of the 

Great Lakes. Within Michigan, it is locally abundant in the St. Joseph River (Hillsdale County) 

and in the River Raisin (Washtenaw County). Historically, the silver shiner was also found in 

the River Raisin in Monroe County (Carman 2001e).

Preferred habitat for the silver shiner is medium to large streams with moderate to high 

gradients. This species is usually found in deeper water, such as pools or eddies directly below 

riffles. The species has been documented to prefer a variety of substrates, including gravel and 

boulder; pebble and cobble; and sand, mud, and clay and is believed to avoid areas with dense 

vegetation and substantial siltation. In Michigan, the shiner has been found to inhabit areas of 

strong current with wooded banks (Carman 2001e). 

Reproduction of the silver shiners is not well documented, but it is believed to spawn in June. 

Juvenile silver shiners exhibit rapid growth, reaching sexual maturity at age 2 and maximum 

size by age 3. Although the silver shiner primarily feeds at the surface, it will take mid-water 

prey as well. The majority of the silver shiner’s prey are aquatic stages of insects, especially 

flies (Carman 2001e).

The silver shiner is relatively rare in Michigan, but populations appear to be stable 

(Carman 2001e). The species is fairly tolerant of human impact and poor water quality 

(Carman 2001e). The silver shiner prefers stream habitats with moderate to high gradient; this 

type of habitat is not present on the Fermi site. No silver shiners were collected during recent 

surveys on the Fermi site (AECOM 2009), and none were reported in past biological surveys of 

Stony Creek (MDEQ 1996, 1998) or the Swan Creek estuary (Francis and Boase 2007) in the 

vicinity of the Fermi site. No silver shiner eggs or larvae were observed during entrainment or 

impingement studies in 2008 and 2009 (AECOM 2009). Suitable habitat for this species does 

not occur on the Fermi site.

Southern Redbelly Dace (Phoxinus erythrogaster) 

The southern redbelly dace is listed as endangered by the State of Michigan (MNFI 2014g). 

The distribution for this fish species ranges from the Lake Erie and Lake Michigan drainages 

through the Mississippi River Basin south to Alabama, Arkansas, and Oklahoma. The northern 

limit of this species’ range is in southeastern Michigan in the Huron River and River Raisin 

drainages that feed Lake Erie (Stagliano 2001b). The southern redbelly dace generally occurs 

in the clear and cool permanent headwaters of river systems, especially small, 

moderate-gradient, spring-fed, and wooded streams that contain pools and are shaded 

(Stagliano 2001b). Preferred substrates include mud bottoms of pools and clean gravel of riffles 

(Stagliano 2001b).

In the northern portion of its range, the southern redbelly dace usually spawns in May and June. 

Spawning fish migrate from pools to riffles where they use nests built by other fish in the same 

family (Cyprinidae). Females generally release 700 to 1,000 eggs during each spawning event. 

Southern redbelly dace reach sexual maturity within 1 year and a length of less than 2 in. 
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(5 cm). This species is generally herbivorous, feeding on filamentous algae, diatoms, and 

drifting or benthic detritus. Larger fish reportedly feed on chironomid and mayfly larvae and

other small invertebrates (Stagliano 2001b).

Near the Fermi site, the southern redbelly dace was last reported from Monroe County in 1930

and from Washtenaw County in 1973; there are no reports of this species from Wayne County 

(MNFI 2014g). Although there is a potential for suitable habitat to be present in some of the 

small streams adjacent to the Fermi site, the areas of Lake Erie near the Fermi site are not 

suitable habitat for this species. No southern redbelly dace were collected during recent 

surveys on the Fermi site (AECOM 2009), and none were reported in past biological surveys of 

Stony Creek (MDEQ 1996, 1998) or the Swan Creek estuary (Francis and Boase 2007) near 

the Fermi site. No southern redbelly dace eggs or larvae were collected during entrainment and 

impingement studies in 2008 and 2009 (AECOM 2009).

3.7.3.4 Non-Native Nuisance Species

Aquatic non-native nuisance species have the ability to cause large-scale ecological and 

economic problems when they have been introduced into an ecosystem that does not have the 

natural controls to keep them in check, such as pathogens, predators, and parasites. When 

new species are introduced into an area, the lack of natural controls may cause the populations 

to grow at or near maximum exponential rates. If a nuisance species becomes established, it 

may disrupt the balance of the existing ecosystem. As a nuisance species proliferates, it may 

prey upon, out-compete, or cause disease in the existing inhabitants. Some aquatic non-native 

nuisance species known to occur on or near the Fermi site are discussed below.

Asian Clam (Corbicula fluminea)

The Asian clam was imported in the northwestern United States in 1938 as a food source and 

subsequently released to the environment. The species has since become widely distributed 

throughout the United States (Foster et al. 2011). Native to Asia and Africa, the first report of 

this species from Lake Erie was in 1981, and it has now become established in the Great Lakes. 

Cold water temperatures limit the potential for survival and reproduction of this species in the 

Great Lakes Region where it is often found in areas influenced by the heated water discharged 

from power plants (French and Schloesser 1991). Asian clams can attach to intake pipes and 

other manmade structures, causing problems related to the operation and maintenance of 

power plants and industrial water systems. The cost of removing them from intake systems is 

estimated at about a billion dollars each year (Foster et al. 2011). Asian clams compete with 

other species, especially native freshwater mussels, by occupying benthic habitat and filtering 

phytoplankton and suspended matter from the water column. This species is also eaten by 

some aquatic species, such as some fish and crayfish (Foster et al. 2011).

Fishhook Water Flea (Cercopagis pengoi)

The fishhook water flea is an invasive planktonic crustacean that is native to the Caspian Basin 

in southwest Asia. It is believed to have been introduced to the Great Lakes from the ballast 

water of a transoceanic ship in the late 1990s. It is now considered established in Lake Ontario 

and has substantial populations in all of the Great Lakes except Lake Superior and Lake Huron. 

The fishhook water flea consumes zooplankton and competes with other planktivores for food. 

Similar to the spiny water flea (described below), this species has a long spine that makes it 

less palatable to planktivorous fish, and it has a high reproductive rate. As a consequence, it is 

feared that the establishment of this species could result in substantial changes to plankton 

communities and could affect survival of planktivorous fish in affected lakes. The current 

distribution of this species in the vicinity of the Fermi site is unknown, although it was found in 

Lake Erie in 2002 (Benson et al. 2010a).
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Lyngbya (Lyngbya wollei)

Lyngbya is an invasive filamentous cyanobacterial (blue-green algal) species that has become 

established in some areas of the western basin of Lake Erie. Lyngbya, which is common in 

some areas of the southeastern United States, was first observed in Maumee Bay

(approximately 18 mi (30 km) south-southwest of the Fermi site) in 2006. This species has 

been observed to form dense benthic and floating mats that can interfere with boating and other 

lake activities and may negatively affect other aquatic organisms. In addition, when the algal 

mats wash ashore, they can blanket extensive shoreline areas and become a nuisance as they 

decompose. 

Bridgeman and Penamon (2010) conducted surveys of the western basin in 2008 and found 

that lyngbya was most prevalent along shorelines in the vicinity of Maumee Bay, becoming less 

prevalent with increasing distance from Maumee Bay. In addition, the biomass of benthic mats 

of lyngbya was found to be greatest in Maumee Bay and Bolles Harbor at water depths of 

5 to 11 ft (1.5 to 3.3 m) on substrates that contained mixtures of sand and fragmented shells 

from dreissenid mussels (i.e., zebra and quagga mussels). The closest record of occurrence of 

lyngbya is in the vicinity of Sterling State Park, approximately 5 mi (8 km) south-southwest of 

the Fermi site (Bridgeman and Penamon 2010). Bridgeman and Penamon (2010) found no 

lyngbya in samples collected at Stony Point (approximately 2 mi (3 km) southwest of the Fermi 

site) in 2008, and lyngbya has not been documented at the Fermi site. Overall, it appears that 

the potential for excessive growth of lyngbya is related to the amount of light penetration into the 

water column (a function of water turbidity), water depth, nutrient availability, and type of 

substrate that is present (Bridgeman and Penamon 2010; LaMP Work Group 2008). Bridgeman 

and Penamon (2010) found that lyngbya in the vicinity of Maumee Bay usually occurred at 

depths between 6.6 and 9.2 ft (2 to 3 m). Nutrient concentrations of nitrate, orthophosphate, 

and total phosphorus reported from Maumee Bay (Moorhead et al. 2008) were higher than 

those reported by DTE in Lake Erie near the Fermi site (AECOM 2009).

A report prepared by DECo (2012d) documented visual inspections for algae recorded in ship 

and dive logs during surveys conducted as part of the Fermi 2 Radiological Environmental 

Monitoring Program. DECo (2012d) also performed microscopic analyses of algal samples 

collected near the Fermi 2 discharge and the proposed location for the Fermi 3 discharge in 

2011. Information from the logs indicated that no mats or stands of algae were observed in the 

vicinity of the Fermi site. The microscopic analyses confirmed that Lyngbya wollei was not 

present in samples from the Fermi site.

Quagga Mussel (Dreissena rostriformis bugensis)

The quagga mussel is a nuisance species believed to have been introduced to the United 

States through the ballast water discharge of transatlantic shipping vessels. Native to Ukraine, 

this species was first discovered in the Great Lakes region in 1989 and has now become well 

established in Lake Erie. It has been reported in Lake Erie near the mouths of Swan and Stony 

Creeks (near the Fermi site), and it is most likely present in parts of the Detroit River as well. 

Very similar to the zebra mussel (described below), the quagga mussel attaches to a wide 

variety of living and nonliving things, including intake pipes and structures, causing problems 

related to the operation and maintenance of these structures. By filtering phytoplankton and 

suspended matter from the water column, the quagga mussel consumes a large portion of the 

zooplankton food source, thus affecting the entire food chain. By clarifying the water, the 

species augments the natural success of aquatic vegetation and, in turn, alters the entire lake 

ecosystem (Benson et al. 2010b).
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Round Goby (Neogobius melanostomus)

The round goby is an invasive species abundant throughout the Great Lakes region, with origins 

in the Black and Caspian Seas. It is commonly believed that the round goby was introduced to 

the Great Lakes through ballast water. First encountered in the vicinity of the St. Clair River in 

1990, the round goby has now spread to all of the Great Lakes. The largest populations are 

believed to be in Lake Erie and Lake Ontario. This small fish feeds primarily on bivalves 

(including zebra mussels), amphipods, small fish, and fish eggs. Thermal tolerance for this

species ranges from 39 to 68 °F (4 to 20 °C). Known to compete with other fish for food and to 

consume eggs and juvenile fish, the round goby is seen as a detriment to the Lake Erie 

ecosystem (Fuller et al. 2010a).

The round goby is present in habitats near the Fermi site and is likely present in Swan Creek 

and Stony Creek. During aquatic surveys conducted at the Fermi site in 2008 and 2009, a total 

of 22 round gobys were collected along the Lake Erie shoreline near the South Lagoon 

(AECOM 2009). Round gobys were also observed in samples collected during impingement

and entrainment studies during 2008 and 2009; it was estimated that 123 individuals would be 

impinged and that more than 1.7 million eggs and larvae would be entrained annually during 

normal operations of the water intake (AECOM 2009).

Sea Lamprey (Petromyzon marinus)

The sea lamprey is a primitive jawless fish originating in the Atlantic Ocean. The sea lamprey is 

an invasive species and is larger and far more predacious than the lamprey species that are 

native to Lake Erie. During the adult stage, sea lampreys parasitize other fish by attaching to 

them with their suckerlike mouth and penetrate the body wall with sharp teeth in order to feed 

on body fluids; this often results in the death of the host fish (Great Lakes Fishery 

Commission 2000). A single sea lamprey can kill as much as 40 lb (18 kg) of fish in its lifetime, 

and it is estimated that only one in seven fish survive an attack by a sea lamprey (Great Lakes 

Fishery Commission 2000). They have a strong advantage over the many species of fish native 

to Lake Erie because they have no natural predators in the lake. The sea lamprey has no 

economic value, and during its peak abundance, it is estimated that 85 percent of lake trout 

encountered that have not been killed by the lamprey will have scarring from their attacks 

(Great Lakes Fishery Commission 2000). Sea lampreys were first observed in Lake Erie 

in 1921 (Great Lakes Fishery Commission 2000). This species typically moves into tributaries 

to spawn, and many tributaries of Lake Erie are treated with chemicals, called lampricides, that 

kill the larval stages of sea lampreys to prevent further expansion of the species. Although 

Lake Erie and Swan Creek are the only waterways in the vicinity of the Fermi site where sea 

lampreys have been found, Stony Creek and the Detroit River could have individuals present 

during spawning runs.

Spiny Water Flea (Bythotrephes longimanus)

The spiny water flea is an invasive planktonic crustacean (cladoceran) that is native to Europe 

and northern Asia and is believed to have arrived in the Great Lakes region through ballast 

water in the mid-1980s. Because of a preference for cooler waters, the spiny water flea is more 

abundant in the central basin of Lake Erie than it is in the western basin; however, it can be 

found throughout the lake (Berg 1992). There are populations found in inland lakes of the 

Great Lakes region, and it is presumed that the spiny water flea could also occur in tributaries of 

Lake Erie, such as Swan Creek, Stony Creek, and the Detroit River, as well.

This is a large plankton species, about 0.5 in. (1.25 cm) long, that has a very high reproductive 

rate. The spiny water flea consumes small zooplankton, such as small cladocerans, copepods, 

and rotifers, and the introduction of this species could result in changes to the zooplankton 
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community structure in affected lakes. The spiny water flea also competes with juvenile fish 

since they share many similar food sources, such as zooplankton, fish larvae, and eggs. This 

species is not an attractive prey to the native inhabitants of Lake Erie because of the sharp 

spines located on its tail; therefore, there are few deterrents to the success of its rapidly growing 

population (Liebig and Benson 2010).

Tubenose Goby (Proterorhinus semilunaris)

The tubenose goby is a small fish that was introduced into the St. Clair River, in Michigan

in 1990 and probably originated in ballast water discharged from a foreign tanker that took on 

water somewhere in the Black Sea (Jude et al. 1992). This species is believed to be 

established but rare in the St. Clair River and in Lake St. Clair in Michigan (Fuller et al. 2012). 

Since its establishment, the distribution of the species has expanded, and it now also occurs in 

the Detroit River and the western basin of Lake Erie (Kocovsky et al. 2011). This species was 

also found to be present in Swan Creek in 2001 within approximately 2.5 mi (4 km) of Lake Erie 

and the Fermi site (Fuller et al. 2012).

In the western basin of Lake Erie, maximum densities of tubenose gobies occurred in sheltered 

areas with abundant growth of aquatic vegetation, which also is the preferred habitat for the 

native northern Black Sea populations (Kocovsky et al. 2011). Tubenose gobies were generally 

absent from sampled areas of the western basin that were dominated by cobble along 

windswept shores or that lacked vegetation (Kocovsky et al. 2011). The diet of tubenose gobies 

in the western basin consisted almost exclusively of invertebrates, especially midge larvae and 

amphipods, suggesting that it may compete for food with other bottom-dwelling fish, such as 

darters (Etheostoma spp. and Percina sp.), madtoms (Noturus spp.), and sculpins (Cottus spp.), 

and could displace some of these native species (Kocovsky et al. 2011).

Zebra Mussel (Dreissena polymorpha)

The zebra mussel is considered a nuisance species throughout the entire Great Lakes region 

and is known to inhabit the western basin of Lake Erie near the Fermi site. Zebra mussels have 

been reported in Swan Creek, Stony Creek, and the Detroit River. Originally found primarily in 

Russia, it is believed that this species was transported to the Great Lakes region in the ballast 

water of a transatlantic freighter in 1988. Since that time, it has spread to more than 100 lakes 

and several major river systems, including the Mississippi River (USGS 2008).

Zebra mussels are very successful invaders because they live and feed in many different 

aquatic habitats, breed prolifically, and have both a planktonic larval stage and an attached 

adult stage. Adult zebra mussels attach to a wide variety of living and nonliving things from 

boats, docks, piers, and water intake pipes to plants and even slow-moving animals. They can 

also attach to each other, creating dense blankets of mussels up to 1 ft (1/3 m) thick. In 1989, 

the City of Monroe lost its water supply for 3 days when large amounts of zebra mussels 

clogged the city’s water intake pipeline. The FWS estimates the economic impact of zebra 

mussels to be in the billions of dollars (over the next 10 years) in the Great Lakes region alone 

(USGS 2008). 

In addition to the economic damage caused by this species, the invasion of the Great Lakes and 

other areas by this species has had important ecological effects. As identified in previous 

sections, zebra mussels have contributed to the decline of native freshwater mussels by 

competing for food and space and by preventing burrowing and other activities when they attach 

to the shells of freshwater mussels. In addition, the collective water-filtering ability of quagga 

and zebra mussels is believed to have had lakewide effects on nutrient levels; the abundance 

and composition of phytoplankton and zooplankton communities; and water clarity, thus 

resulting in large-scale ecological changes (USGS 2008).
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3.7.4 Aquatic Species and Habitats in the Transmission Line Corridor

Aquatic habitats within or adjacent to the in-scope transmission line corridor include only small 

streams and drainage ditches. The in-scope transmission line corridor does not cross any 

lakes, ponds, or reservoirs. 

3.7.5 Aquatic Monitoring

No formal monitoring of the aquatic environment on the Fermi site has been conducted or is 

planned. The current NPDES permit for the Fermi site does not require monitoring of aquatic 

ecological resources, and the operating license for Fermi 2 does not require monitoring of 

aquatic resources, including specific aquatic ecological monitoring of the algal community, 

benthic invertebrates, or fish.

3.8 Special Status Species and Habitats

This section addresses species and habitats that are Federally protected under the Endangered 

Species Act of 1973 (ESA) (16 U.S.C. 1531 et seq.) and the Magnuson–Stevens Fishery 

Conservation and Management Act of 2006, as amended (MSA) (16 U.S.C. 1801–1884). The 

ESA and the MSA placed requirements on Federal agencies, such as the NRC. The terrestrial 

and aquatic resource sections (Sections 3.6 and 3.7, respectively) discuss other species and 

habitats protected by other Federal acts and the State of Michigan that do not place

requirements on the NRC.

3.8.1 Species and Habitats Protected under the Endangered Species Act

The FWS and the National Marine Fisheries Service (NMFS) jointly administer the ESA. The 

FWS manages the protection of, and recovery effort for, listed terrestrial and freshwater 

species, and the NMFS manages the protection of, and recovery effort for, listed marine and 

anadromous species. This section describes the action area and considers those species that 

could occur in the action area under both the FWS’s and the NMFS’s jurisdictions.

3.8.1.1 Action Area

The implementing regulations for Section 7(a)(2) of the ESA define “action area” as all areas 

affected directly or indirectly by the Federal action and not merely the immediate area involved 

in the action (50 CFR 402.02). The action area effectively bounds the analysis of 

ESA-protected species and habitats because only species that occur within the action area may 

be affected by the Federal action.

For the purposes of the ESA analysis in this SEIS, the NRC staff considers the action area to be 

the Fermi site (described in Sections 3.1 and 3.6) and the portion of Lake Erie that would be 

affected by water withdrawal and discharge effluent (described in Section 3.7). The NRC staff 

expects all direct and indirect effects of the proposed action to be contained within these areas.

The NRC staff recognizes that, although the action area is stationary, Federally listed species 

can move in and out of the action area. For instance, a migratory fish species could occur in the 

action area periodically and then travel to freshwater streams to spawn. Similarly, a flowering 

plant known to occur near, but outside of, the action area could appear within the action area 

over time if its seeds are carried into the action area by wind, water, or animals. Thus, in its 

analysis, the NRC staff considers not only those species known to occur directly within the 

action area but also those species that may passively or actively move into the action area. The 
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NRC staff then considers whether the life history of each species makes the species likely to 

move into the action area where it could be affected by the proposed Fermi 2 license renewal.

Within the action area, Federally listed terrestrial species could experience impacts, such as 

habitat disturbance associated with ground-disturbing activities; cooling tower drift; collisions 

with cooling towers and in-scope transmission lines; exposure to radionuclides; and other direct 

and indirect impacts associated with station, cooling system, and in-scope transmission line 

operation and maintenance (NRC 2013b). The proposed action has the potential to affect 

Federally listed aquatic species in several ways: impingement or entrainment of individuals into 

the cooling system; alteration of the lake environment through water level reductions; changes 

in dissolved oxygen, gas supersaturation, eutrophication, and thermal discharges from cooling 

system operation; habitat loss or alteration from dredging; and exposure to radionuclides 

(NRC 2013b).

3.8.1.2 Species and Habitats under the FWS’s Jurisdiction

Table 3-23 identifies the species under the FWS’s jurisdiction that occur within Monroe County, 

Michigan. Monroe County includes approximately 680 mi2 (1,761 km2) of varying land uses and 

habitat types. Thus, a Federally listed species that occurs within Monroe County does not 

necessarily occur within the action area. The NRC staff uses this geographical range as a 

starting point for its analysis because Federally listed species distribution and critical habitat

information is readily available at the County level. Additionally, the action area is a small area 

of land wholly contained within the geographical boundaries of the County. Following the table, 

descriptions of each species include a determination of whether each species occurs in the 

action area based on the species’ habitat requirements, life history, and available occurrence 

information.

The NRC compiled the list of species in Table 3–23 from the FWS’s Endangered Species 

Program online databases (FWS 2014a, 2014b); correspondence between the NRC and the 

FWS (FWS 2014c; NRC 2014b); information from DTE’s ER (DTE 2014d); and available 

scientific studies, surveys, and literature. The NRC staff did not identify any candidate species

or designated critical habitats within the action area.

Federally Listed Species in Monroe County, Michigan

Species Common Name

Federal 

Status Habitat

Birds

Calidris canutus red knot T The Lake Erie shoreline is part of the red 

knot’s migratory route and potential 

resting grounds when it migrates to and 

from the Canadian Artic and Argentina.

Charadrius melodus piping plover E When the piping plover inhabits the 

Great Lakes during spring and summer, 

its nest sites include open, sparsely 

vegetated, sandy areas along the Great 

Lakes.

Reptiles

Sistrurus catenatus eastern 

massasauga

PT During summer through fall, generally 

occupies higher, drier habitats, open 

canopy wetlands, and adjacent upland 

area. Hibernates during winter.
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Species Common Name

Federal 

Status Habitat

Mammals

Myotis septentrionalis northern 

long-eared bat

T During late spring and summer, the 

northern long-eared bat roosts and 

forages in upland forests. It uses caves 

and mines as hibernacula in winter.

Myotis sodalis Indiana bat E The Indiana bat inhabits hardwood 

forests; hardwood pine forests; and 

old-growth forests, especially near 

stream and river corridors; agricultural 

lands; and old fields. It uses caves and 

mines as hibernacula during winter.

Insects

Lycaeides melissa samuelis Karner blue 

butterfly

E The Karner blue butterfly inhabits pine 

barrens and oak savannas that contain 

wild lupines (Lupinus perennis), the only 

known food plant of larvae.

Plants

Platanthera leucophaea Eastern prairie 

fringed orchid

T The eastern prairie fringed orchid

inhabits mesic to wet prairies and 

meadows.

Mussels

Epioblasma torulosa rangiana northern riffleshell E The northern riffleshell inhabits Lake 

Erie, large streams, and small rivers in 

areas of firm sand and where riffles 

occur.

Epioblasma triquetra snuffbox mussel E The snuffbox mussel inhabits Lake Erie, 

small- to medium-sized creeks, and 

some larger rivers in areas with a swift 

current.

Villosa fabalis rayed bean E The rayed beam inhabits Lake Erie and 

smaller headwater creeks or sometimes 

in large rivers.

Key: E = endangered; T = threatened, P = proposed

Sources: 80 FR 17973, 80 FR 58688; DTE 2014d, 2014g; FWS 2014a, 2014b, 2014c, 2016

Red Knot (Calidris canutus rufa)

The FWS published a final rule to list the red knot as threatened throughout its range on 

December 11, 2014 (Volume 79 of the Federal Register (FR), page 73706). The FWS (2014d) 

expects to issue a proposal to designate critical habitat for the red knot in 2015. Loss of 

breeding and nonbreeding habitat, reduced prey availability, and increasing frequency and 

severity of asynchronies in the timing of the birds’ annual migratory cycle relative to favorable 

food and weather conditions are factors that have contributed to the decline of this species. 

Unless otherwise cited, the information in this section is derived from the FWS’s listing 

document (79 FR 73706).
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The red knot is a medium-sized (9 to 11 in. (23 to 28 cm) in length) shorebird. It migrates 

annually between its breeding grounds in the Canadian Arctic and several wintering regions, 

including the Southeastern United States, Northeast Gulf of Mexico, northern Brazil, and Tierra 

del Fuego off the coast of the southern tip of South America. Between both its spring and fall 

migrations, the red knot uses key staging and stopover areas to rest and feed.

Red knots live up to 7 years (Niles et al. 2008) and likely begin breeding at 2 years 

(Harrington 2001). The species breeds in June in inland areas near arctic coasts and nests in 

dry, slightly elevated tundra areas. Breeding success can vary dramatically from year to year 

based on weather, food availability (insects and other terrestrial invertebrates), and abundance 

of predators (the arctic lemmings Dicrostonyx torquatus and Lemmus sibericus). Little 

information is available on mating fidelity, but the species is known to return to the same 

breeding grounds each year, and pairs seem to form monogamous bonds throughout the 

breeding season (Niles et al. 2008). Females lay one clutch of three to four eggs per season. 

Males and females participate in egg incubation, which lasts for approximately 22 days 

(Niles et al. 2008). Chicks are born in early July, and the fledgling period lasts 18 days 

(Niles et al. 2008). 

Red knots migrate up to 19,000 mi (30,000 km)—one of the longest migrations known in the 

animal kingdom—each year, and individuals can undertake flights of several thousand miles 

without stopping. Stopover habitat most often includes muddy or sandy coastal areas near 

mouths of bays and estuaries (Niles et al. 2008). In the spring, stopover areas include the 

Atlantic coast of Argentina, eastern and northern Brazil, the Virginia barrier islands, and the 

Delaware Bay. Important fall stopover sites include southwest Hudson Bay, James Bay, the 

St. Lawrence River, the Mingan Archipelago in Canada, the Bay of Fundy, the coasts of 

Massachusetts and New Jersey, the mouth of the Altamaha River in Georgia, the Caribbean, 

and the northern coast of South America from Brazil to Guyana. During both migrations, red 

knots may stopover along the coast of the Great Lakes. During migration, red knots eat 

bivalves, gastropods, amphipods, and occasionally polychaetes (Niles et al. 2008).

Occasional observations of red knots have been recorded within the 6-mi (10-km) vicinity 

surrounding the Fermi site, including at Estral Beach, Sterling State Park, and Pointe Mouillee 

State Game Area (eBird 2014). DTE’s contractor, Kogge, conducted a field survey for the red 

knot on September 3, 2014, and September 4, 2014, which consisted of visual searches for the 

presence of this species and its preferred or suitable habitat. The focus of the visual surveys 

occurred on the coastal shoreline and wetland areas adjacent to the existing Fermi 2 facilities 

and undeveloped shoreline areas along the Lake Erie coastline of the Fermi site. Kogge (2014) 

did not observe this species or optimal feeding or overwintering habitats, such as areas with 

horseshoe crabs or other preferred foods. However, Kogge (2014) concluded that the coastal 

areas on the Fermi site could provide suitable resting or foraging habitat for the red knot. The 

last time that DTE recorded an observation of this species on the Fermi site was in 1973 

(NUS 1974, DTE 2015a). Thus, shoreline within the Fermi site may provide suitable habitat for 

migrating red knots that stop to rest or feed, but the occurrence of this species within the action 

area would be occasional or rare.

Piping Plover (Charadrius melodus) – Great Lakes Watershed Population

The FWS listed the Great Lakes watershed population of piping plover as endangered in 1985 

(50 FR 50726). The species occurs through much of the Northern Great Plains, Great Lakes 

region, Atlantic coast, and Gulf Coast region. Miller et al. (2009) conducted a recent study of 

the taxonomy of the species and confirmed the genetic uniqueness of only two subspecies—

Atlantic (C.m. melodus) and Interior (C.m. circumcinctus), although the FWS (2009a) recognizes 

three distinct population segments in its ESA rulemakings—the Atlantic Coast, the Great Lakes, 
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and the Northern Great Plains populations. The Atlantic Coast population is C.m. melodus, 

while the Great Lakes and Northern Great Plains populations are C.m. circumcinctus.

Piping plovers inhabit open, sandy, sparsely vegetated beaches and barrier islands along the 

Great Lakes’ shorelines. They avoid high bluffs or areas where the beach has been severely 

eroded. Historically, the Great Lakes watershed population bred throughout the Great Lakes’ 

shorelines within eight states, including Michigan, and Ontario. Currently, breeding is restricted 

to several beaches along Lake Superior and Lake Michigan in northern Michigan. The 

population winters along the Gulf coasts of Texas, Louisiana, Alabama, and Florida (Haig 1992).

Piping plovers have not nested on Lake Erie since 1942 (ODNR 2014). Suitable breeding 

habitat for plovers occurs along Lake Erie in Ohio and Ontario (FWS 2003). The MNFI did not 

contain any records of piping plovers within Monroe County (MNFI 2007a). Occasional 

observations of piping plovers have been recorded within the vicinity surrounding the Fermi site, 

including in Sterling State Park and Pointe Mouillee State Game Area (eBird 2014). At the 

Fermi site, Black & Veatch, DTE’s contractor, observed several transient piping plovers on the 

sandy beach south of the Fermi 2 intake in July 2008 (Black & Veatch 2009a). DTE (2014d) 

reported that no piping plovers have been observed on site since 2008. Most recently, Kogge 

and Heslinga (2013), another DTE contractor, conducted surveys in 2013 and did not observe 

piping plovers nor did they find suitable nesting habitat onsite. Thus, DTE (2014d) finds that the

shoreline within the Fermi site may provide marginal habitat for migrating piping plovers that 

stop to rest or feed, but the occurrence of this species within the action area would be rare.

The FWS designated critical habitat for the Great Lakes breeding population in May 2001 

(66 FR 22938). However, designated critical habitat does not occur within the action area.

Eastern massasauga (Sistrurus catenatus)

In September 2015, FWS (80 FR 58688) proposed to list the eastern massasauga rattlesnake 

as a threatened species. In the proposed rule, FWS determined that it was not prudent to 

designate critical habitat. 

The eastern massasauga is a small, thick-bodied rattlesnake that occupies shallow wetlands 

and adjacent upland habitat in portions of Illinois, Indiana, Iowa, Michigan, Minnesota,

New York, Ohio, Pennsylvania, Wisconsin, and Ontario. Eastern massasauga rattlesnakes 

hibernate in the winter and are active in spring, summer, and fall. During the active period, this 

species generally occupies higher, drier habitats, open canopy wetlands, and adjacent upland 

area. The FWS lists the main threats to this species as habitat loss and fragmentation. Habitat 

loss includes the loss of natural areas, such as grassland, swamp, fen, bog, wet prairie, sedge 

meadow, marshland, peatland, floodplain forest, or coniferous forests, due to conversion to 

agricultural land, development, and infrastructure associated with development. (80 FR 58688). 

MNFI (2015) has no records of this species occurring in Monroe County. This species has not 

been observed on or near the Fermi site since wildlife studies began in 1973 (NUS 1974; Black 

& Veatch 2009a; DECo 2011b; NRC 2013a; Kogge and Heslinga 2013; DTE 2014d). Given 

that the MNFI has no records of this species in Monroe County and that the species has never 

been observed on or near the Fermi site, the NRC staff concludes that the eastern massasauga

is unlikely to occur within the action area.

Northern Long-Eared Bat (Myotis septentrionalis)

The FWS published a final rule to list the northern long-eared bat as threatened throughout its 

range on April 2, 2015 (80 FR 17973). The FWS did not propose to designate critical habitat for 

the species because it found that such habitat is “not determinable at this time” (80 FR 17973). 

White-nose syndrome, wind energy development, and loss of habitat specifically linked to 
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surface coal mining in prime summer habitat are factors that have contributed to the decline of 

this species. White-nose syndrome was first confirmed in Michigan in the winter of 2014 

through 2015 (80 FR 17973). 

The northern long-eared bat is a medium-sized bat that is distinguished from other Myotis

species by its long ears, which average 0.7 in. (17 mm) in length. This bat inhabits 39 states in 

the eastern and north central United States and all Canadian provinces west to the southern 

Yukon Territory and eastern British Columbia. Populations are typically composed of small 

numbers and tend to be patchily distributed across the species’ range. More than 780 winter 

hibernacula have been recorded in the United States (94 in Michigan), most of which contain 

only a few (one to three) individuals. The FWS recognizes four U.S. populations. Northern 

long-eared bats inhabiting Michigan are considered part of the Midwest population

(78 FR 61046; 80 FR 17973).

In the Midwest, the northern long-eared bat is fairly common during summer mist-net surveys 

and is found infrequently in winter hibernacula surveys (80 FR 17973). In summer, bats roost 

alone or in small colonies under the bark of live or dead trees; in caves or mines; or in 

manmade structures, such as barns, sheds, and other buildings. The species opportunistically 

roosts in a variety of trees, including several species of oak, maple, beech, and pine 

(80 FR 17973). In southern Michigan, northern long-eared bats use cavities within roost trees, 

living trees, and roosts with greater canopy cover more often than does the Indiana bat, which 

occurs in the same area (Foster and Kurta 1999). Northern long-eared bats forage both in flight 

and on the ground and eat a variety of moths, flies, leafhoppers, caddisflies, and beetles. The 

species breeds from late July to early October, after which time it will migrate to winter 

hibernacula. Northern long-eared bats are short-distance migrators and will travel 35 to 55 mi 

(56 to 89 km) from summer roosts to winter hibernacula (80 FR 17973). Hibernating females 

store sperm until spring and give birth to one pup approximately 60 days after fertilization 

(80 FR 17973). Females raise young in maternity colonies of up to 30 individuals 

(80 FR 17973).

In Michigan, the northern long-eared bat is known to occur within 36 counties, including Monroe 

County. The northern long-eared bat is most common in the northern Lower Peninsula and 

portions of the Upper Peninsula. Similarly, the majority of hibernacula in Michigan are in the far 

northern and western Upper Peninsula. Therefore, few bats occur in the southern half of the 

Lower Peninsula during the summer because of the long distance to hibernacula in the northern 

portion of the State. The few bats that spend summer in the southern half of the Lower 

Peninsula may hibernate during the winter in caves or mines in neighboring States

(80 FR 17973).

DTE’s contractor, Kogge (2014), conducted a field survey for the northern long-eared bat on 

September 3, 2014, and September 4, 2014, which consisted of visual searches for the 

presence of this species and its preferred or suitable habitat. Kogge (2014) analyzed the 

suitability of individual trees and woodland areas by following the protocols set forth by the FWS

guidelines for northern long-eared bat (FWS 2014e) and previous bat surveys on the Fermi site 

(Black & Veatch 2009a). These protocols included methods for measuring the tree’s DBH and 

assessing overhead canopy cover, understory density, and proximity to flowing or standing 

water. Kogge (2014) did not observe this species during the surveys, but the NRC staff notes 

that the surveys occurred at a time when northern long-eared bats are migrating north to winter 

hibernacula (FWS 2014e). Kogge (2014) determined that the site provides potential roosting 

and foraging habitat for the northern long-eared bat. For example, woodlots and several 

individual trees could provide suitable roosting habitat due to the presence of trees with a DBH

of greater than 3 in. (8 cm) and with exfoliating, peeling, or scaling bark. This species has not 

been observed on or near the Fermi site since wildlife studies began in 1973 (NUS 1974; Black 
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& Veatch 2009a; DECo 2011b; NRC 2013a; Kogge and Heslinga 2013; Kogge 2014; 

DTE 2014d, 2014g). However, DTE has not conducted onsite mist-net surveys for northern 

long-eared bats that follow protocols recommended by the FWS.

Indiana Bat (Myotis sodalis)

The FWS listed the Indiana bat as endangered in 1967 (32 FR 4001). The FWS designated 

critical habitat for the Indiana bat in 1976 (41 FR 41914) to include 11 caves and 2 mines in 

6 states, none of which are located in Michigan.

The Indiana bat is an insectivorous, migratory bat that inhabits the central portion of the Eastern 

United States and hibernates colonially in caves and mines. The decline of Indiana bats is 

attributed to urban expansion, habitat loss and degradation, human-caused disturbance of 

caves or mines, insecticide poisoning, and white-nose syndrome (FWS 2011; Pruitt and 

TeWinkel 2007).

During summer months, reproductive female bats tend to roost in colonies under slabs of 

peeling tree bark or cracks within trees in forest fragments, often near agricultural areas (Pruitt 

and TeWinkel 2007). Colonies may also inhabit closed-canopy, bottomland deciduous forest; 

riparian habitats; wooded wetlands and floodplains; and upland communities (Pruitt and 

TeWinkel 2007). Maternity colonies typically consist of 60 to 80 adult females (Whitaker and 

Brack 2002). Colonies occupy multiple trees for roosting and rearing young 

(Watrous et al. 2006), and once these colonies are established, the Indiana bats usually return 

to the same areas each year (Pruitt and TeWinkel 2007). Nonreproductive females and males 

do not roost in colonies during the summer; they may remain near the hibernacula or migrate to 

summer habitat (Pruitt and TeWinkel 2007). High-quality summer habitat includes mature forest 

stands containing open subcanopies, multiple moderate- to high-quality snags, and trees with 

exfoliating bark (Farmer et al. 2002). In summer, bats forage for insects along forest edges, 

riparian areas, and in semi-open forested habitats. In the winter, Indiana bats rely on caves for 

hibernation. The species prefers hibernacula in areas with karst (limestone, dolomite, and 

gypsum), although it may also use other cave-like locations, such as mines.

The FWS’s Indiana bat recovery plan (Pruitt and TeWinkel 2007) indicates that one winter 

hibernaculum occurs within Michigan, approximately 200 mi (322 km) from the Fermi site. 

Additionally, 11 extant maternity colonies occur in Michigan. None of these records identify 

Monroe County as containing hibernacula or maternity colonies. For 2007, the FWS (2009b) 

estimated that Michigan’s total population of Indiana bats was 20 individuals. According to more 

recent estimates based on FWS winter surveys conducted in January and February 2013, the 

Michigan population of Indiana bats remained the same with 20 individuals (King 2013).

The Fermi site could provide habitat for the Indiana bat. Although portions of the Fermi site are 

forested, large live trees with loose bark that would provide roosting habitat for the Indiana bat 

are not common there. The death of many green ash (Fraxinus pennsylvanica) trees in the 

action area caused by the emerald ash borer (Agrilus planipennis) has made some dead tree 

suitable for summer roosting habitat. 

On August 2, 2011, DTE’s contractor, Black & Veatch (2011) conducted a field visit to the Fermi 

site to look for potential roost trees for Indiana bats within areas that would be affected by 

building the proposed Fermi 3 facilities. Black & Veatch evaluated potential roost trees as low, 

moderate, or high potential based on criteria drawn from the FWS’s Indiana bat recovery plan 

(Pruitt and TeWinkel 2007). Black & Veatch (2011) determined that six trees were potentially 

suitable for summer roosts by the Indiana bat, including one tree that was considered high 

potential for roosting. The study indicated that most trees in the area were either too small or 

otherwise unsuitable for Indiana bat summer roosts (Black & Veatch 2011). In addition, other 
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habitat features usually preferred by Indiana bat were generally lacking at the Fermi site (Black 

& Veatch 2011).

The MNFI (2007b) does not include any reported occurrences of the Indiana bat in Monroe 

County, although this species has been observed in counties north and west of the Fermi site. 

This species has not been observed on or near the Fermi site since wildlife studies began in 

1973 (NUS 1974; Black & Veatch 2009a; Black & Veatch 2011; DECo 2011b; NRC 2013a; 

Kogge and Heslinga 2013; DTE 2014d). However, the NRC staff notes that DTE has not 

conducted onsite mist-net surveys for Indiana bats that follow FWS protocols.

Karner blue butterfly (Lycaeides melissa samuelis)

The FWS listed the Karner blue butterfly as endangered in 1992 (57 FR 59236). No critical 

habitat has been designated for this species. 

The Karner blue butterfly is a small silvery butterfly with a 0.9- to 1.3-in. (2.2- to 2.3-cm) 

wingspan. These butterflies typically occur with landscapes composed of sandy soils, which 

supported oak or oak-pine savanna or barrens before European settlement. Given that its 

historical habitat suffers from fire suppression efforts, the butterfly often occurs in openings, old 

fields, and utility right of ways (ROWs) surrounded by close-canopied oak forest. Karner blue 

larvae feed exclusively on wild lupine (Lupinus perennis), but adults visit a wide variety of 

flowering plants for nectar (MNFI 2007c).

MNFI surveys (MDNR 2015) have not recorded the occurrence of any Karner blue butterflies in 

Monroe County within the past 5 years. The most recent observations of a Karner blue butterfly 

in Monroe County occurred in 2008 and 1986 (MNFI 2007c; NRC 2013a). This species has not 

been observed on site since wildlife studies began in 1973 (Black & Veatch 2009a; DECo 

2011b; DTE 2014d; Kogge and Heslinga 2013; NRC 2013a; NUS 1974).

During interactions with the FWS and the MDNR for the proposed construction and operation of 

Fermi, Unit 3, the MDNR and the FWS concluded that Karner blue butterflies are not likely to 

occur on the Fermi site (NRC 2013a). As described above, DTE and its contractors have 

conducted several terrestrial ecology surveys on site. Based on these surveys (DECo 2009, 

2011b), the NRC staff concludes that suitable habitat for this species, which consists of dry 

forest openings with wild lupine, does not exist on the Fermi site or in the immediate vicinity. 

Given that this species has not been observed on site and that no suitable habitat occurs within 

the action area, the NRC staff concludes that the Karner blue butterfly is unlikely to occur within 

the action area.

Eastern Prairie Fringed Orchid (Platanthera leucophaea)

The FWS listed the eastern prairie fringed orchid as threatened in 1989 (54 FR 39857). No 

critical habitat has been designated for this species.

The eastern prairie fringed orchid is a perennial herb that grows 8 to 40 in. (20 to 102 cm) tall 

and produces long clusters of up to 40 white flowers in early July (NatureServe 2014). It 

inhabits mesic prairie, wetlands, sedge meadows, marsh edges, and bogs with full sun and little 

to no woody encroachments (FWS 2013). These orchids require hawkmoths (family 

Sphingidae) for successful pollination, and seedling establishment requires a mycorrhizal 

relationship with soil fungus (Bowles 1999). Eastern prairie fringed orchids occur in the Eastern 

United States and Great Lakes States and in Nova Scotia and Ontario, Canada. 

The eastern prairie fringed orchid historically occurred within 21 counties in Michigan 

(Case 1987). Today, about 12 populations are thought to exist within nine counties mostly in 

southeastern lower Michigan. A cluster of these flowers occurs on degraded prairie and 

wetland habitat bordering western Lake Erie. The total number of flowering plants contained in 
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this cluster has fluctuated from an estimated 900 plants in 1984 (Chapman and Crispin 1985) to 

an estimated 314 plants in 1990 (Case and Case 1990).

The most recent observations of eastern prairie fringed orchid in Monroe County occurred 

in 2006 (MNFI 2007d). This species has not been observed on or near the Fermi site in any 

onsite vegetation study since 1973 (NUS 1974; Black & Veatch 2009b; DECo 2011b; 

NRC 2013a; Kogge and Heslinga 2013; DTE 2014d). In the NRC staff’s review of the proposed 

construction and operation of Fermi 3, the NRC staff concluded that this species could occur on 

the site because the plant is known to occur in lakeplain prairies around western Lake Erie 

(NRC 2013a). The NRC (2013a) noted that, although emergent wetlands exist on the Fermi 

site, large portions of these emergent wetlands have been severely degraded by the common 

reed, an invasive plant.

Northern Riffleshell (Epioblasma torulosa rangiana)

The FWS listed the northern riffleshell as endangered in 1993 (58 FR 5638). No critical habitat

has been designated for this species.

The northern riffleshell is a freshwater unionid mussel. The habitat for the northern riffleshell is 

fine to coarse gravel in riffles and runs of streams with swift currents (MNFI 2007e). The 

northern riffleshell holds larvae over the winter and releases glochidia in the spring (Carman and 

Goforth 2000a). In the laboratory, glochidia developed with brown trout (Salmo trutta), 

bluebreast darter (Etheostoma camurum), banded darter (Etheostoma zonale), and banded 

sculpin (Cottus carolinae) as hosts; however, these fish species do not occur in the areas of 

Michigan that could harbor northern riffleshell populations, suggesting that there are also other 

hosts (Carman and Goforth 2000a). The age at maturity for northern riffleshell is not known, but 

this species may reach 15 years of age (Carman and Goforth 2000a). Like all freshwater 

mussels, the northern riffleshell is a filter feeder.

The historic range for the northern riffleshell includes Illinois, Indiana, Kentucky, Michigan, Ohio, 

Pennsylvania, West Virginia, and western Ontario (Carman and Goforth 2000a). It was once 

widespread in the Ohio and Maumee River Basins and in tributaries of western Lake Erie 

(Carman and Goforth 2000a). In Michigan, the northern riffleshell is known to currently occur 

only in the Black River in Sanilac County and the Detroit River in Wayne County (Carman and 

Goforth 2000a). More than 100 individuals from the Detroit River population were relocated to 

the St. Clair River in 1992 as part of an effort to establish a new population, but the success of 

that effort is not known (Carman and Goforth 2000a).

The survival of this species depends on the protection and preservation of suitable habitat and 

host fish species. The MNFI includes two recorded observations of this species in Monroe 

County, the most recent of which was in 1977 (MNFI 2007e). This species has not been 

observed on or near the Fermi site in any aquatic study conducted on the site (AECOM 2009; 

DECo 2011b; NRC 2013a; DTE 2014d). Streams with conditions suitable for the northern 

riffleshell are not present on the Fermi site (NRC 2013a). Therefore, no suitable habitat occurs 

within the Fermi site or adjacent waters on Lake Erie. Given that the MNFI most recently 

observed this species in Monroe County in 1977, that the species has never been observed on 

or near the Fermi site, and that no suitable habitat occurs within the action area, the NRC staff 

concludes that the northern riffleshell is unlikely to occur within the action area.

Snuffbox (Epioblasma triquetra)

Snuffbox is a freshwater mussel belonging to the family Unionidae that the FWS designated as 

endangered through its range in 2012 (77 FR 8632). No critical habitat has been designated for 

this species. Unless otherwise cited, information for the present summary is from the FWS’s 

listing document (77 FR 8632).
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Adults are small- to medium-sized mussels; males attain lengths up to 7.0 cm (2.8 in.), and 

females attain lengths up to 4.5 cm (1.8 in.). The shells are somewhat triangular in females and 

oblong or ovate in males, with the anterior of the shell being rounded and the posterior 

truncated. The shells are solid and thick and typically smooth and yellowish or yellowish-green 

in young individuals and become darker with age. Snuffbox reproductive and maximum ages 

are unknown, but unionids are generally long-lived, and maximum ages can exceed that of 

humans. The adults are suspension feeders that consume algae, bacteria, microscopic 

animals, and detritus. They may also deposit-feed on particles in the sediment.

Snuffbox has separate male and female individuals. Like other unionids, snuffbox has an 

unusual life cycle, although all the details are not known for snuffbox. After fertilization, the 

eggs live in special gill chambers of the females and develop into microscopic larvae called 

glochidia. Females may brood the glochidia from September to May. When the glochidia are 

ready, female snuffbox move to the surface and may attract host fish, whereupon the female 

expels the glochidia, which then must attach to the host fish’s gills or fins to complete 

development by enclosing themselves in a cyst (encysting). They drop off the host fish as 

newly transformed juveniles.

Different unionid species require different host fish. In the laboratory, juvenile snuffbox have 

successfully transformed on logperch (Percina caprodes), blackside darter (P. maculata), 

rainbow darter (Etheostoma caeruleum), Iowa darter (E. exile), blackspotted topminnow

(Fundulus olivaceous), mottled sculpin (Cottus bairdii), banded sculpin, Ozark sculpin 

(C. hypselurus), largemouth bass (Micropterus salmoides), and brook stickleback 

(Culaea inconstans). 

The snuffbox was once widespread and occurred in 210 lakes and streams in 18 states and 

one Canadian province. The historic range of the snuffbox mussel extended from Ontario 

southward to Mississippi and Alabama and eastward to New York and Virginia; extant 

populations are still present in Wisconsin, Illinois, Indiana, Kentucky, Michigan, Ohio, 

Pennsylvania, Tennessee, and West Virginia (NatureServe 2009). In Michigan, this species is 

found primarily in eastern and southeastern rivers, including Otter Creek in Monroe County and 

the Detroit River in Wayne County (Carman and Goforth 2000b). The snuffbox mussel primarily 

inhabits small- and medium-sized rivers, although specimens have also been collected from 

Lake Erie and large rivers, such as the St. Clair River. Preferred habitat usually has clear water 

and a sand, gravel, or cobble substrate with a swift current; individuals are often buried deep in 

the sediment (Carman and Goforth 2000b).

The MNFI includes three recorded observations of this species in Monroe County, the most 

recent of which was in 1933 (MNFI 2007f). This species has not been observed on or near the 

Fermi site in any aquatic study conducted on the site (AECOM 2009; DECo 2011b; NRC 2013a;

DTE 2014d). Streams with conditions suitable for the snuffbox mussel are not present on the 

Fermi site, although shoreline areas of Lake Erie near the site possibly could contain suitable 

substrates (NRC 2013a). Given that the MNFI most recently observed this species in Monroe 

County in 1933 and that the species has never been observed on or near the Fermi site, the

NRC staff concludes that the snuffbox is unlikely to occur within the action area.

Rayed Bean (Villosa fabalis)

The rayed bean is a freshwater unionid mussel that was Federally listed as endangered in 2012 

(77 FR 8632). No critical habitat has been designated for this species.

The rayed bean reportedly holds glochidia internally over the winter for release in the spring; 

female rayed beans bearing eggs have been found in May (Carman 2001a). Fish hosts for the 

glochidia could include the Tippecanoe darter (Etheostoma tippecanoe), greenside darter 
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(Etheostoma blennioides), rainbow darter, mottled sculpin, and largemouth bass (FWS 2002). 

The limited data available suggest that the lifespan for the rayed bean is less than 20 years 

(FWS 2002). Like all freshwater mussels, the rayed bean is a filter feeder.

The rayed bean is patchily distributed in the St. Lawrence, Ohio, and Tennessee River 

drainages (Carman 2001a). Although it was historically widespread from Ontario to Alabama 

and from Illinois to New York, only a few populations are currently known to exist, and it is 

assumed to be extirpated throughout much of its former range (Carman 2001a). As of 

November 2010, extant populations were known from 28 streams in Indiana, Michigan, New 

York, Ohio, Pennsylvania, West Virginia, and the province of Ontario in Canada. In Michigan, 

existing rayed bean populations occur in the Black, Pine, Belle, and Clinton River systems.

The rayed bean is generally found in smaller headwater creeks, although it has also been found 

in larger rivers (FWS 2002). Individuals are usually found in or near shoal or riffle areas; rayed 

bean specimens were also recorded to occur in shallow, wave-washed areas of Lake Erie, 

generally associated with islands in the western portion of the lake (FWS 2002). Preferred 

substrates are gravel and sand, and it is oftentimes found among the roots of vegetation 

growing in riffles and shoals (FWS 2002).

The MNFI includes six recorded observations of this species in Monroe County, the most recent 

of which is in 1984 (MNFI 2007g; NRC 2013a). However, these observations were based on 

the presence of shells rather than live specimens (Carman 2001a). Although there are records 

of rayed bean shells from shallow, wave-washed areas of western Lake Erie, it is unlikely that 

the species occurs in the vicinity of the Fermi site for a number of reasons: (1) this species has 

not been observed on or near the Fermi site in any aquatic study conducted on or adjacent to 

the site (AECOM 2009; DTE 2010; DECo 2011b; NRC 2013a; DTE 2014d), (2) DTE reviewed 

approximately 30 years of mussel surveys in the western basin of Lake Erie (including in the 

vicinity of the Fermi site), none of which identified rayed bean specimens (Napela et al. 1991;

Shackelford et al. 2009; DTE 2009, 2010), (3) the USACE conducted mussel surveys in 

Lake Erie approximately 2 mi (3.2 km) south of the Fermi site and found no live specimens or 

shells of the rayed bean (Clarke 1980, 1981), (4) observations made by DTE divers during 

sediment sampling for Fermi 2’s REMP program and buoy maintenance indicated that the 

sediment and other habitat characteristics are not suitable for the rayed bean (DTE 2009, 2010), 

and (5) no streams occur on the Fermi site with conditions suitable for the rayed bean 

(NRC 2013a). Given that the MNFI most recently observed this species in Monroe County 

in 1984, that it has never been observed on or near the Fermi site, and that no suitable habitat 

occurs within the action area, the NRC staff concludes that the rayed bean is unlikely to occur 

within the action area.

3.8.1.3 Species and Habitats under the NMFS’s Jurisdiction

As discussed in Section 3.7, Lake Erie does not contain marine or anadromous fish species. 

Therefore, no Federally listed species or habitats under the NMFS’s jurisdiction occur within the 

action area.

3.8.2 Species and Habitats Protected under the Magnuson–Stevens Act

The NMFS has not designated essential fish habitat in Lake Erie. Therefore, this section does 

not contain a discussion of any species or habitats protected under the MSA.

3.9 Historic and Cultural Resources

This section discusses the cultural background and the known historic and cultural resources

found on and in the vicinity of Fermi 2. The discussion is based on a review of historic and 
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cultural resource surveys and other background information on the region surrounding Fermi 2. 

In addition, a records search was performed through the Michigan State Historic Preservation 

Office (SHPO) to obtain the most up-to-date information about historic and cultural resources in 

the region.

The area of potential effect is the area at the Fermi site, the transmission lines up to the first 

substation, and the immediate environs that may be affected by the license renewal decision 

and land-disturbing activities associated with continued reactor operations. For this analysis, 

the first substation (the 345-kV Fermi switchyard) is located on the Fermi site (DTE 2014d). The 

area of potential effect may extend beyond the immediate environs in instances where 

land-disturbing maintenance and operations activities during the license renewal term or 

refurbishment activities could potentially have an effect (Figure 3–3).

3.9.1 Cultural Background

Human occupation in the vicinity of the Fermi site is generally characterized according to the 

following chronological sequence (MI SHPO undated):

• Paleo-Indian Period (12,000–10,000 years before present (BP)),

• Archaic Period (10,000–2,500 BP),

• Woodland Period (2,500–400 BP (ca. A.D. 1600)), and

• Historical Period (400 BP–Present (ca. A.D. 1600 to present)).

Fermi 2 and the surrounding region show evidence of both prehistoric and historic occupation

and/or settlement by Native Americans and Euroamericans that has continued through to the

present. Archaeological records suggest that the area has had the potential for occupation from

the Paleo-Indian Period, the Archaic Period, and the Woodland Period (NRC 2013a).

Paleo-Indian Period (12,000–10,000 BP)

The earliest evidence of people living in Michigan dates to the Paleo-Indian Period. 

Paleo-Indian sites are generally found upland or on river terraces and are characterized by 

specific types of projectile points (i.e., fluted Clovis and Folsom points) and stone tools, such as 

gravers, scrapers, or large blades. These artifacts often occur in association with mastodon 

remains, suggesting a reliance on megafauna (e.g., mammoth, ground sloth, and saber-toothed

tiger) for subsistence, along with plants, small game, birds, and amphibians. Social 

organization consisted of small, highly nomadic bands of hunter-gatherers, leaving Paleo-Indian 

sites with little detailed archaeological information (Neusius and Gross 2007). Evidence of 

Paleo-Indian sites is sparse in southeast Michigan and in the immediate vicinity of the Fermi site 

(DTE 2014d).

Archaic Period (10,000–2,500 BP)

The Archaic Period was a time of major climatic shifts as colder environments transitioned to 

warmer environments similar to modern conditions. In response to this shift, new technologies 

and subsistence strategies were developed during this time. The Archaic Period is often divided 

into early, middle, and late subperiods. The Early Archaic Period is characterized by a shift 

from nomadic to sedentary settlement patterns, with central base camps located on river 

terraces and smaller hunting camps located in upland areas. This subperiod also shows an 

increased reliance on wild plant foods, small game, and aquatic resources. The Middle Archaic 

Period is characterized by an increased number of settlement sites on high stream terraces, 

which may reflect population increases. Although subsistence and settlement patterns 

remained fairly similar to the Early Archaic Period, artifact assemblages suggest increased 
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exploitation of aquatic resources and new artifacts, such as pecked and ground stone tools 

used for intensive processing of nuts, banner stones that signaled the innovation of a new 

projectile technology called the atlatl or spear-thrower, and grooved axes. The Late Archaic 

Period is characterized by an increase in the number and size of settlement sites, which 

indicates an increase in population and a more sedentary lifestyle. New features of Late 

Archaic artifact assemblages, such as crude ceramic vessels, represent a shift toward 

increased reliance on horticulture as a subsistence strategy, although hunting and gathering 

would have continued (Fagan 2005; Neusius and Gross 2007).

Woodland Period (2,500–400 BP)

The Woodland Period is also often divided into early, middle, and late periods. However, the 

distinction between the early and middle period is not fixed. The Woodland Period is marked by 

an increase in more permanent settlements; changes in burial practices; increased cultivation of 

plants, such as sunflowers and cucurbits (e.g., squashes, gourds, and melons); and a rise in the 

manufacture and use of pottery (Fagan 2005). During the Middle Woodland Period, the large 

and complex Hopewell Culture emerged in the northeastern and midwestern United States. 

This culture is characterized by settlement in villages, increased reliance on intensive 

horticulture, burial mounds, and long-distance trade networks. These long-distance networks 

allowed the trade of exotic materials from far outside their immediate locations, such as marine 

shells from the Gulf Coast, obsidian from the Rocky Mountains, copper from Lake Superior, and 

mica from the Appalachian Mountains. The burial mounds of this period often included central 

features, lined with logs, and filled with grave goods (Neusius and Gross 2007). The Middle

Woodland period in Michigan is characterized as exhibiting a definite Hopewell cultural influence 

in terms of its ceramic styles and elaborate burial procedures (DTE 2014d). The Late Woodland 

Period is characterized by an increase in settlement sites, which suggests a rise in population 

and/or a change in settlement patterns from large, centralized village sites to smaller, dispersed 

habitation sites. Late Woodland Period artifact assemblages are characterized by an increase 

in thin-walled plain ceramic types and stemmed and side-notched projectile points. The sudden 

appearance of very small, thin triangular projectile points between 1,300 and 1,400 BP indicates 

the invention of bow and arrow technology and suggests a corresponding change in hunting 

techniques (Fagan 2005).

Historical Period (A.D. 1600–Present)

The end of the Woodland Period is characterized by severe social, political, and demographic 

changes that resulted from indirect and direct contact with Europeans. In particular, it is 

believed that the introduction of European infectious diseases, such as smallpox, yellow fever, 

typhoid, and influenza, severely decimated Native American populations, which had no 

immunity to these diseases. The spread of these diseases, which were fatal to large numbers 

of Native Americans, resulted in the widespread abandonment of villages and a concurrent 

collapse of Native American socioeconomic networks (Fagan 2005). Native American groups

that lived in the region of the Fermi site at the time of contact with early European explorers and

settlers were identified from historic written accounts, which indicated that these contact-period

Native American groups were associated with the Erie, an Iroquoian group, and with the

Wendat/Huron, Ottawa, Miami, and allied Fox and Mascouten, which are all Algonquian groups

(NRC 2013a).

According to the Michigan Department of Human Services (MDHS) and the U.S. Bureau of

Indian Affairs, there are currently 12 Federally recognized tribes in the State of Michigan, all 

primarily associated with the Chippewa, Ottawa, and Potawatomi. None of these 12 Federally 

recognized tribes are currently located within the Fermi 2 region or its surrounding region in 

southeastern Michigan (MDHS 2015, undated). However, the closest of these 12 Federally 
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recognized tribes are three groups of Potawatomi Indians in southwestern Michigan and one 

group of Chippewa Indians in central Michigan: the Nottawaseppi Huron Band of Potawatomi 

Indians in Calhoun County, the Pokagon Band of Potawatomi Indians in Cass County, the Gun 

Lake Potawatomi Tribe (also known as the Match-e-be-nash-she-wish Band of Pottawatomi 

Indians of Michigan) in Allegan County, and the Saginaw Chippewa Indian Tribe on the Isabella 

Indian Reservation in Isabella County (NRC 2013a).

The National Park Service’s (NPS) Native American Consultation Database, developed as part 

of NPS’s national program for compliance with the Native American Graves Protection and 

Repatriation Act of 1990 (25 U.S.C. 3001 et seq.), identified three Federally recognized Indian 

tribes with judicially established land claims within Monroe County, Michigan. One is the 

Hannahville Indian Community in Menominee County (northern Michigan). The other two are 

outside the State of Michigan: the Forest County Potawatomi Community in Forest County, 

Wisconsin (northeastern Wisconsin), and the Ottawa Tribe of Oklahoma in Ottawa County, 

Oklahoma (northeastern Oklahoma). Because judicially established land claims are based on 

proven ancestral or historic ties to lands, these three Federally recognized Indian tribes may 

also have been prehistorically or historically associated with the Fermi 2 property or its 

surrounding region (NRC 2013a).

The regional historic cultural background begins with European exploration and settlement by 

the French in the 17th century, followed by British control of the area in the mid- to 

late-18th century. After the War of 1812, the region came under American control and was 

reorganized into counties, including the establishment of Monroe County and the Village of 

Monroe in 1817. With the opening of a Federal Land Office in the area in 1824, increasing 

settlement occurred in the region through the remainder of the 19th century. However, because 

the Fermi site was historically a wetland environment, little settlement occurred in the area in the 

19th century, although the shoreline areas were used for commercial fishing purposes and 

upland areas were used for vineyards and silica sand mining. The local commercial fishing

industry was replaced in the early 20th century by the development of summer cottage 

communities and resorts northeast and southwest of the Fermi site along the Lake Erie 

shoreline. In the mid-20th century, these seasonal communities subsequently transitioned into 

year-round communities that are still occupied today (NRC 2013a).

3.9.2 Historic and Cultural Resources

Historic and cultural resources include prehistoric era and historic era archaeological sites;

historic districts; buildings; and any site, structure, or object that may be considered eligible for 

listing on the National Register of Historic Places (NRHP). Historic and cultural resources also 

include traditional cultural properties that are important to a living community of people for 

maintaining their culture. “Historic property” is the legal term for a historic and/or cultural 

resource that is eligible for listing on the NRHP.

A review of databases maintained by the NPS indicates that there are 12 historic properties 

listed on the NRHP within Monroe County and that none of these historic properties are located 

at the Fermi site (NPS 2015a, 2015b). These historic properties consist of historic buildings, 

structures, and districts dating from the mid-18th through mid-20th centuries. Located 

approximately 7 mi (11 km) southwest of Fermi is the River Raisin Battlefield Site, a component 

of the River Raisin National Battlefield Park, which commemorates two key battles fought during 

the War of 1812 (NPS 2015d; DTE 2014d). There are no National Historic Landmarks located 

within Monroe County (NPS 2015c).

The NRHP-eligible Enrico Fermi Atomic Power Plant Unit 1 (Fermi 1) is located adjacent to 

Fermi 2 (DTE 2014d, 2014g). Fermi 1 was the Nation’s first commercial sized 
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liquid-metal-cooled fast breeder reactor and, for a time, was the world’s largest reactor of this 

type. Construction of Fermi 1 began in 1956, and initial criticality was achieved in 1963. 

Fermi 1 operated until 1972, and it was permanently shut down in 1975 (Kuranda et al. 2009). 

In 2012, NRC entered into a Memorandum of Agreement with the Michigan SHPO regarding 

mitigation measures to take into account with regard to the proposed demolition of Fermi 1 

(NRC 2012; DTE 2014g). The Joseph Fix Farmstead, located approximately 0.5 mi (0.8 km) 

northwest of the Fermi property boundary, is the nearest offsite NRHP-eligible property. A 2012 

windshield survey identified this site to be the only offsite historic property to have the Fermi 2 

cooling towers within its viewshed (DTE 2014d).

As described in DTE’s ER (DTE 2014d), several cultural resource investigations have been 

conducted at the Fermi site and nearby areas. Much of the land involving Fermi 2 was 

previously disturbed by the construction of Fermi 1. No surveys were conducted at the Fermi 

site before the construction of Fermi 1. Subsequent cultural resource investigations for Fermi 2 

noted that there were no known historical or archeological resources on the Fermi site. A more 

comprehensive series of cultural resource surveys (including literature reviews, pedestrian 

surveys, and shovel tests) were conducted from 2007 to 2010 in support of the Fermi 3 COL 

application. These surveys focused on historic sites within a 10-mi (16-km) radius of Fermi and 

on archeological sites located within a 1.5-mi (2.4-km) radius (NRC 2013a). In 2012, additional 

file searches and archeological field surveys were conducted on the Fermi site in association 

with the Fermi 2 license renewal effort (DTE 2014d, 2014g).

Based on these surveys, a total of 17 historic and archaeological sites have been identified at 

the Fermi site. Table 3–24 lists these sites. One of these, Fermi 1, is a NRHP-eligible site. The 

other archaeological sites have either been determined by the Michigan SHPO as ineligible or 

have been recommended not eligible for listing on the NRHP. The location of Site 20MR207 is 

based entirely on literature sources that have never been verified in the field. The reported site 

area was revisited during 2012 field investigations and was found to be visibly eroded, and no 

evidence of the site was found. Therefore, the site (at its reported location) is recommended not 

eligible for listing on the NRHP (DTE 2014d; OSA 2014). A search of the Michigan 

Archaeological Site Files conducted in 2014 by the Michigan SHPO updated the status of these 

17 cultural resources.

Cultural Resources Located within the Fermi Site

Site On Fermi Site Description NRHP Status

Enrico Fermi Atomic 

Power Plant (Fermi 1)

Yes Decommissioned Nuclear Power 

Plant

Eligible

20MR207 Yes Prehistoric/historic literature reference Recommended not 

eligible

20MR702 Yes Prehistoric/lithic scatter on beach; 

presumed destroyed

Not eligible

20MR818 Yes Prehistoric/isolated flake; early 20th 

century/artifact scatter

Not eligible

20MR819 Yes Prehistoric/isolated flake Not eligible

20MR820 Yes Prehistoric/isolated flake Not eligible

20MR821 Yes Prehistoric/isolated flake Not eligible

20MR822 Yes Prehistoric/isolated flake Not eligible
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Site On Fermi Site Description NRHP Status

20MR823 Yes 20th century/building foundation,

concrete pad, box cistern, and artifact 

scatter

Not eligible

20MR825 Yes 20th century/artifact scatter and 

wooden markers (crosses and 

possible pet burials)

Not eligible

20MR828 Yes Late 19th century–early 20th 

century/structural remains (former 

foundation)

Not eligible

20MR829 Yes 20th century/structural remains 

(former foundation), artifact scatter

Not eligible

20MR830 Yes 20th century/structural remains 

(former foundation), cisterns, and 

artifact scatter

Not eligible

20MR831 Yes 20th century/structural remains 

(poured concrete pads) and artifact 

scatter

Not eligible

20MR832 Yes 20th century/structural remains 

(former foundation) and artifact scatter

Not eligible

20MR833 Yes 20th century/structural remains 

(former foundation) and cistern

Not eligible

20MR834 Yes 20th century/structural remains 

(former foundation and poured 

concrete pad) and well pipe

Not eligible

Sources: DTE 2014d, 2014g; NRC 2013a; OSA 2014

3.10 Socioeconomics

This section describes current socioeconomic factors that have the potential to be directly or 

indirectly affected by changes in operations at Fermi 2. Fermi 2 and the communities that 

support it can be described as a dynamic socioeconomic system. The communities supply the 

people, goods, and services required to operate the nuclear power plant. Power plant 

operations, in turn, supply wages and benefits for people and dollar expenditures for goods and 

services. The measure of a community’s ability to support Fermi 2 operations depends on its 

ability to respond to changing environmental, social, economic, and demographic conditions.

3.10.1 Power Plant Employment and Expenditures

The socioeconomic region of influence (ROI) is defined by the areas where Fermi 2 employees 

and their families reside; spend their income; and use their benefits, thus affecting the economic 

conditions of the region. DTE employs approximately 890 full-time workers (DTE 2014d). 

Approximately 78 percent of Fermi 2 employees reside in southern Michigan in Monroe and 

Wayne Counties. Most of the remaining 22 percent of the workforce are spread among 18 other 

counties in Michigan and Ohio, 3 counties in other states, and one Canadian province, with 

numbers ranging from 1 to 74 employees per County (DTE 2014d). Given the residential 

locations of Fermi 2 employees, the most significant effects of plant operations are likely to 
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occur in Monroe and Wayne Counties. Table 3–25 summarizes the Fermi 2 workforce 

geographic distribution. Therefore, the focus of the socioeconomic impact analysis in this SEIS 

is on the impacts of continued Fermi 2 operations on these two Counties, also termed the ROI.

Fermi 2 Employees Residence by County/Province

County/Province

Number of 

Employees

Percentage 

of Total

Michigan

Lenawee 17 2

Monroe 526 59

Oakland 30 3

Washtenaw 25 3

Wayne 167 19

Ohio

Lucas 74 8

Wood 15 2

Other counties/province 35 4

Total 889 100

Source: DTE 2014d

DTE purchases goods and services to facilitate Fermi 2 operations. Although specialized 

equipment and services are procured from a wider region, some proportion of the goods and 

services used in plant operations are acquired from within the ROI. These transactions fuel a 

portion of the local economy, creating jobs and generating purchases by suppliers.

Refueling outages occur on an 18-month cycle and historically have lasted approximately 

42 days on average. During refueling outages, site employment typically increases by an 

additional 1,400 to 1,500 temporary workers (DTE 2014d). Outage workers are drawn from all 

regions of the country and Canada; however, the majority would be expected to come from 

Michigan, Ohio, and other Midwestern states.

3.10.2 Regional Economic Characteristics

This section presents information on employment and income in the Fermi 2 socioeconomic 

ROI. Monroe County is predominantly rural with agricultural and forested land comprising the 

majority of the land use in the County. Conversely, Wayne County is predominantly urban with 

developed land comprising about 80 percent of total land area in the County (USDA 2014c).

3.10.2.1 Employment and Income

From 2010 to 2013, the labor force in the Fermi 2 ROI decreased approximately 2.4 percent to 

just over 889,000. However, the number of employed persons increased by the same 

percentage, about 2.4 percent, to approximately 798,000. Consequently, the number of 

unemployed people in the ROI decreased by nearly 31 percent, by approximately 

41,000 persons to over 91,000, or about 10.3 percent of the current workforce, down from 

14.6 percent in 2010 (BLS 2014).
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According to the U.S. Census Bureau’s (USCB’s) 2013 American Community Survey estimates, 

the educational, health, and social services industry represented the largest employment sector 

in the socioeconomic ROI (23.5 percent) followed by manufacturing (17 percent) and 

professional, scientific, management, administrative, and waste management services

(10.9 percent). A list of employment by industry in each County of the ROI is provided in

Table 3–26.

Employment by Industry in the Fermi 2 ROI (2013 Estimates)

Industry Monroe Wayne Total Percent

Total employed civilian workers 65,527 696,644 762,171 –

Agriculture, forestry, fishing, hunting, and mining 747 2,348 3,095 0.4

Construction 3,257 26,981 30,238 4.0

Manufacturing 14,981 115,587 130,568 17.1

Wholesale Trade 1,260 16,082 17,342 2.3

Retail Trade 6,682 73,640 80,322 10.5

Transportation, warehousing, and utilities 3,844 43,478 47,322 6.2

Information 957 13,897 14,854 1.9

Finance, insurance, real estate, rental, and leasing 2,295 39,082 41,377 5.4

Professional, scientific, management, administrative, and 

waste management services

4,394 78,914 83,308 10.9

Educational, health, and social services 16,066 163,197 179,263 23.5

Arts, entertainment, recreation, accommodation, and food 

services

6,529 64,443 70,972 9.3

Other services (except public administration) 2,725 34,323 37,048 4.9

Public administration 1,790 24,672 26,462 3.5

Source: USCB 2014a

Major employers in Monroe County, the County in which Fermi 2 is located, are listed in

Table 3–27. Mercy Memorial Hospital is shown as the largest employer in the County.

Major Employers in Monroe County in 2013

Employer Number of Employees

Mercy Memorial Hospital 1,738

DECo 1,251

Johnson Controls (Plastech) 815

Dundee Engine Plant 519

Monroe Public Schools 549

Gerdau Specialty Steel 510

La-Z-Boy, Inc. 491

Meijer, Inc. 475
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Employer Number of Employees

Tenneco, Inc. 456

Monroe Bank and Trust 450

Source: MCFD 2014

Table 3–28 presents the estimated income information for the Fermi 2 ROI. According to the 

USCB’s 2013 American Community Survey estimates, 12.3 percent of families and 17 percent 

of individuals in Michigan were living below the Federal poverty threshold, and the median 

household income for Michigan was $48,273 (USCB 2014a). In the socioeconomic ROI, people 

living in Monroe County had median household and per capita incomes above the State 

average. The median household income average in Monroe County was $53,561 with 

10.4 percent of families and 12.9 percent of individuals living below the poverty level. 

Conversely, Wayne County had a lower median household income average ($40,487) and a 

higher percentage of families (19.6 percent) and individuals (24.9 percent) living below the 

official poverty level (USCB 2014a).

Estimated Income Information for the Fermi 2 ROI (2013 Estimates)

Monroe Wayne Michigan

Median household income (dollars)(a) 53,561 40,487 48,273

Per capita income (dollars)(a) 26,825 22,538 25,918

Individuals living below the poverty level (percent) 12.9 24.9 17.0

Families living below the poverty level (percent) 10.4 19.6 12.3

(a) In 2012 inflation adjusted dollars.

Source: USCB 2014a

3.10.2.2 Unemployment

According to the USCB’s 2013 American Community Survey estimates, the unemployment 

rates in Monroe County and in the State of Michigan as a whole were both 9.8 percent. 

Comparatively, the Wayne County unemployment rate during this same time period was 

14.8 percent (USCB 2014a).

3.10.3 Demographic Characteristics

According to the 2010 Census, an estimated 434,209 people lived within 20 mi (32 km) of 

Fermi 2, which equates to a population density of 346 persons per square mile (DTE 2014d). 

This translates to a Category 4 “least sparse” population density using the GEIS measure of 

sparseness (greater than or equal to 120 persons per square mile within 20 mi (32 km)). An 

estimated 5,176,563 people live within 50 mi (80 km) of Fermi 2 with a population density of 

659 persons per square mile (DTE 2014d). This translates to a Category 4 density, using the 

GEIS measure of proximity (greater than or equal to 190 persons per square mile within 50 mi 

(80 km)). Therefore, Fermi 2 is located in a high population area based on the GEIS 

sparseness and proximity matrix.
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Table 3–29 shows population projections and percent growth from 1970 to 2060 in the 

two-County Fermi 2 ROI. The population in Monroe County has increased while the population 

in Wayne County has decreased over the previous two decades (2000 and 2010). Based on 

forecasts, the population is expected to continue these trends at a moderate to low rate. 

Population projections for years 2020 and 2040 shown in the table were developed by the 

SEMCOG.

Population and Percent Growth in Fermi 2 ROI Counties, 

1970–2010, 2013 (Estimated), and Projected for 2020–2060

Year

Monroe County Wayne County

Population

Percent 

Change Population

Percent 

Change

1970 118,479 – 2,666,751 –

1980 134,659 13.7 2,337,891 -12.3

1990 133,600 -0.8 2,111,687 -9.7

2000 145,945 9.2 2,061,162 -2.4

2010 152,021 4.2 1,820,584 -11.7

2013 150,376 -1.1 1,775,273 -2.5

2020 156,592 3.0 1,700,779 -6.6

2030 160,841 2.7 1,664,635 -2.1

2040 164,720 2.4 1,656,931 -0.5

2050 168,846 2.5 1,630,267 -1.6

2060 172,910 2.4 1,608,343 -1.3

Source: Decennial population data for 1970–2010 and estimated for 2013 (USCB 2014b); 

projections for 2020–2040 by the SEMCOG (SEMCOG 2012); and 2050-2060 calculated.

Table 3–30 presents the 2010 Census demographic profile of the two-County ROI population. 

According to the 2010 Census, minorities (race and ethnicity combined) comprised 47.1 percent

of the total two-County population. The largest minority populations in the ROI were Black or 

African American (37.3 percent) and Hispanic or Latino (5.1 percent).

Demographic Profile of the Population in the Fermi 2 ROI in 2010

Monroe Wayne ROI

Total Population 152,021 1,820,584 1,972,605

Race (percent of total population, Not-Hispanic or Latino)

White 92.5 49.6 52.9

Black or African American 2.1 40.3 37.3

American Indian and Alaska Native 0.3 0.3 0.3

Asian 0.6 2.5 2.4

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0

Some other race 0.1 0.1 0.1
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Monroe Wayne ROI

Two or more races 1.5 2.0 2.0

Ethnicity

Hispanic or Latino 4,667 95,260 99,927

Percent of total population 3.1 5.2 5.1

Minority population (including Hispanic or Latino ethnicity)

Total minority population 11,412 918,404 929,816

Percent minority 7.5 50.4 47.1

Source: USCB 2014b

The USCB’s 2013 American Community Survey 1-Year Estimates (USCB 2014c) shows that, 

since 2010, minority populations in the ROI have decreased by approximately 28,600 persons 

and now comprise 46.8 percent of the ROI population (Table 3–31). The largest decline 

occurred in the Black or African American population (nearly 38,000 persons since 2010, a 

decrease of 5.2 percent). This corresponds with the overall decline in regional population 

(nearly 47,000 persons since 2010, a decrease of 2.4 percent). However, some of this 

decrease was partially offset by an increase in the Asian population (over 6,700 persons), an 

increase of over 14.5 percent from 2010. The next largest increase in minority population was 

Hispanic or Latino, an increase of approximately 3,600 persons or 3.6 percent from 2010 

(USCB 2014g).

Demographic Profile of the Population in the Fermi 2 ROI in 2013

Monroe Wayne ROI

Total Population 150,376 1,775,273 1,925,649

Race (percent of total population, Not-Hispanic or Latino)

White 91.9 49.9 53.2

Black or African American 2.3 39.1 36.2

American Indian and Alaska Native 0.5 0.3 0.3

Asian 0.6 2.9 2.8

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0

Some other race 0.1 0.2 0.2

Two or more races 1.3 2.0 2.0

Ethnicity

Hispanic or Latino 4,981 98,590 103,571

Percent of total population 3.3 5.6 5.4

Minority population (including Hispanic or Latino ethnicity)

Total minority population 12,112 889,109 901,221

Percent minority 8.1 50.1 46.8

Source: USCB 2014c
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3.10.3.1 Transient Population

Within 50 mi (80 km) of Fermi 2, colleges and recreational opportunities attract daily and 

seasonal visitors who create a demand for temporary housing and services. In 2013, 

approximately 211,000 students attended colleges and universities within 50 mi (80 km) of 

Fermi 2 (NCES 2014a).

Based on the USCB’s 2011–2013 American Community Survey 3-Year Estimates 

(USCB 2014d), approximately 34,300 seasonal housing units are located within 50 mi (80 km) 

of Fermi 2. Of those, 4,409 were located in the Fermi 2 ROI. Table 3–32 presents information 

about seasonal housing for the counties located all or partly within 50 mi (80 km) of Fermi 2.

2013 Estimated Seasonal Housing in 

Counties Located within 50 mi (80 km) of Fermi 2

County(a) Total Housing Units

Vacant Housing Units for 

Seasonal, Recreational, 

or Occasional Use Percent

Michigan

Jackson 69,042 1,464 2.1

Lenawee 43,317 2,643 6.1

Livingston 73,190 2,167 3.0

Macomb 358,565 1,720 0.5

Monroe 63,077 233 0.4

Oakland 529,279 5,052 1.0

St. Clair 71,764 2,445 3.4

Washtenaw 148,202 1,345 0.9

Wayne 818,113 4,176 0.5

County Subtotal 2,174,549 21,245 1.0

Ohio

Erie 37,669 2,746 7.3

Fulton 17,352 45 0.3

Henry 11,905 20 0.2

Lucas 201,884 920 0.5

Ottawa 27,877 8,679 31.1

Sandusky 26,256 443 1.7

Seneca 23,942 97 0.4

Wood 53,472 99 0.2

County Subtotal 400,357 13,049 3.3

Total 2,574,906 34,294 1.3

(a) Counties within 50 mi (80 km) of Fermi 2 with at least one block group located within the 50-mi (80-km) radius.

Note: ROI Counties are in bold italics.

Source: USCB 2014d
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3.10.3.2 Migrant Farm Workers

Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

crops. These workers may or may not have a permanent residence. Some migrant workers 

follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 

Others may be permanent residents living near Fermi 2 and travel from farm to farm harvesting 

crops.

Migrant workers may be members of minority or low-income populations. Because they travel 

and can spend a significant amount of time in an area without being actual residents, migrant 

workers may be unavailable for counting by census takers. If uncounted, these minority and 

low-income workers would be “underrepresented” in the decennial Census population counts.

In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 

they hired migrant workers—defined as farm workers whose employment required travel—to do 

work that prevented the migrant workers from returning to their permanent place of residence 

the same day. The Census is conducted every 5 years and results in a comprehensive 

compilation of agricultural production data for every county in the Nation.

Information about migrant and temporary labor (working less than 150 days) was collected in 

the 2012 Census of Agriculture. Table 3–33 supplies information about migrant and temporary 

farm labor within 50 mi (80 km) of Fermi 2. According to the 2012 Census, approximately 

11,000 farm workers were hired to work for less than 150 days and were employed on 

2,623 farms within 50 mi (80 km) of Fermi 2. The County with the highest number of temporary 

farm workers (984) on 281 farms was Lenawee County, Michigan (NASS 2014).

Migrant Farm Workers and Temporary Farm 

Labor in Counties Located within 50 mi (80 km) of Fermi 2 (2012)

County(a)

Number of 

Farms with 

Hired Farm 

Labor(b)

Number of Farms 

Hiring Workers for 

Less than 

150 Days (b)

Number of Farm 

Workers Working for 

Less than 

150 Days(b)

Number of Farms 

Reporting Migrant 

Farm Labor(b)

Michigan

Jackson 260 209 546 4

Lenawee 376 281 984 8

Livingston 164 131 508 3

Macomb 165 130 934 19

Monroe 246 188 934 16

Oakland 210 152 555 7

St. Clair 254 190 522 4

Washtenaw 310 242 937 7

Wayne 87 66 577 1

County Subtotal 2,072 1,589 6,497 69

Ohio

Erie 102 65 445 8

Fulton 229 199 637 3

Henry 156 128 480 5

Lucas 113 94 454 6
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County(a)

Number of 

Farms with 

Hired Farm 

Labor(b)

Number of Farms 

Hiring Workers for 

Less than 

150 Days (b)

Number of Farm 

Workers Working for 

Less than 

150 Days(b)

Number of Farms 

Reporting Migrant 

Farm Labor(b)

Ottawa 102 74 811 9

Sandusky 165 133 655 13

Seneca 225 166 495 4

Wood 240 175 512 6

County Subtotal 1,332 1,034 4,489 54

Total 3,404 2,623 10,986 123

(a) Counties within 50 mil (80 km)of Fermi 2 with at least one block group located within the 50-mi (80-km) radius.

(b) Table 7: Hired Farm Labor—Workers and Payroll: 2012.

Note: ROI Counties are in bold italics.

Source: 2012 Census of Agriculture—County Data (NASS 2014)

A total of 123 farms in the 50-mi (80-km) radius of the Fermi 2 reported hiring migrant workers in 

the 2012 Census. Macomb County, Michigan, reported the most farms with migrant farm labor 

(19 farms) (NASS 2014).

3.10.4 Housing and Community Services

This section presents information on housing and local public services, including education and 

water supply.

3.10.4.1 Housing

Table 3–34 lists the total number of occupied and vacant housing units, vacancy rates, and 

median value in the ROI. Based on the USCB’s 2013 American Community Survey Estimates 

(USCB 2014e), there were nearly 880,000 housing units in the ROI, nearly 723,000 of which 

were occupied. The median values of owner-occupied housing units in the ROI range from 

$78,100 in Wayne County to $132,100 in Monroe County. The vacancy rate also varied 

considerably between the two Counties, from 7.5 percent in Monroe County to 18.6 percent in 

Wayne County (USCB 2014e).

Housing in the Fermi 2 ROI (2013 estimate)

Monroe Wayne ROI

Total housing units 63,191 816,539 879,730

Occupied housing units 58,479 664,415 722,894

Total vacant housing units 4,712 152,124 156,836

Percent total vacant 7.5 18.6 17.8

Owner occupied units 46,015 416,280 462,295

Median value (dollars) 132,100 78,100 83,475

Owner vacancy rate (percent) 2.8 2.7 2.7

Renter occupied units 12,464 248,135 260,599
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Monroe Wayne ROI

Median rent (dollars/month) 754 783 782

Rental vacancy rate (percent) 12.6 8.0 8.2

Source: USCB 2014e

3.10.4.2 Education

Wayne County has 33 public school districts with approximately 600 public schools and 

290,000 students (RESA 2014). In Monroe County, the County in which Fermi 2 is located, 

there are 13 public school districts with 55 public schools and over 25,700 students 

(NCES 2014b).

3.10.4.3 Public Water Supply

The City of Monroe pumps and treats water from Lake Erie and operates a joint intake and

pumping facility with Frenchtown Charter Township. The city’s water treatment and distribution

system serves the City of Monroe and portions of the surrounding townships, including Monroe

Charter, Raisinville, Exeter, Ida, and London. In addition, the City of Monroe supplies water in

bulk to the village of Dundee and the City of Petersburg, serving an estimated population of

53,000 residents. The City of Monroe treatment plant has a treatment capacity of approximately 

18 mgd. Frenchtown Charter Township shares the water intake with the City of Monroe and 

operates a water treatment plant that services approximately 20,000 residents and other 

nonresidential customers within the township.

Northern portions of Monroe County, including Ash Township, Berlin Township, and the villages

of Carleton, Estral Beach, and South Rockwood receive water supplies directly through the 

Detroit Water and Sewage District, which maintains three intake facilities that draw water from 

Lake Huron and the Detroit River and five water treatment plants.

Wastewater treatment services are provided by a number of townships and municipalities in

Monroe County that service residential, commercial, and industrial customers in the City of

Monroe; in Frenchtown Charter, Monroe Charter, Raisinville, Bedford, Berlin, Ida, York, LaSalle

and Ash townships; in the Cities of Milan, Petersburg, and Luna Pier; and in the villages of

Dundee, Carleton, and Maybee. Other residents within the County are served by private onsite

wastewater disposal systems. The Monroe Metropolitan Water Pollution Control System serves 

approximately 52,000 residents within the City of Monroe, large portions of Monroe Charter and 

Frenchtown Charter townships, and a small portion of Raisinville Township.

Table 3–35 lists the largest public water suppliers in Monroe and Wayne Counties and provides 

water source and population served for those suppliers. The discussion of public water supply 

systems is limited to major municipal water systems. All major public water suppliers in Monroe 

and Wayne Counties obtain their supplies from surface water. Currently, there is excess 

capacity in every major public water system in the two Counties. Fermi 2 gets potable water 

from Frenchtown Charter Township.

Local Public Water Supply Systems

Public Water System Source

Population 

Served(a)

Monroe County

Ash Township Surface water purchased 5,304

Berlin Township Surface water purchased 9,700
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Public Water System Source

Population 

Served(a)

Dundee Surface water purchased 3,975

Frenchtown Township Surface water 16,481

Monroe Surface water 48,726

Monroe South County Surface water purchased 33,816

Wayne County

Allen Park Surface water purchased 28,210

Brownstown Township Surface water purchased 30,627

Canton Township Surface water purchased 90,173

Dearborn Surface water purchased 98,153

Dearborn Heights Surface water purchased 57,774

City of Detroit Surface water 713,777

Garden City Surface water purchased 27,692

Grosse Ile Township Surface water purchased 10,371

Grosse Pointe Farms Surface water 9,479

Grosse Pointe Park Surface water purchased 11,555

Grosse Pointe Woods Surface water purchased 16,135

Hamtramck Surface water purchased 22,423

Harper Woods Surface water purchased 14,236

Highland Park Surface water 11,776

Huron Township Surface water purchased 15,879

Inkster Surface water purchased 25,369

Lincoln Park Surface water purchased 38,144

Livonia Surface water purchased 96,942

Melvindale Surface water purchased 10,715

Northville Township Surface water purchased 26,655

Plymouth Surface water purchased 9,132

Plymouth Township Surface water purchased 27,524

Redford Township Surface water purchased 48,362

Riverview Surface water purchased 12,486

Romulus Surface water purchased 23,989

Southgate Surface water purchased 30,047

Sumpter Township Surface water purchased 9,549

Taylor Surface water purchased 63,131

Trenton Surface water purchased 18,853

Van Buren Township Surface water purchased 27,359

Wayne Surface water purchased 17,593

Westland Surface water purchased 84,094

Woodhaven Surface water purchased 12,875

Wyandotte Surface water 25,883
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Public Water System Source

Population 

Served(a)

(a) Safe Drinking Water Search for the State of Michigan (EPA 2014c).

Source: EPA 2014c

3.10.5 Tax Revenues

Fermi 2 property taxes are paid to Frenchtown Township, Monroe County, Michigan.

Table 3–36 lists the property taxes paid for Fermi 2 for the years of 2009 through 2013. As

shown in the table, total property tax payment amounts for the reported years fluctuated from 

year to year because, in part, of an order issued by the Michigan State Tax Commission in 

December 2008 that changed the classification of nuclear fuel from real property to industrial 

personal property. This classification change meant that nuclear fuel was no longer subject to

the school millage rate (i.e., 24 mills), which resulted in a refund for the 2008 tax year. This 

refund was provided to DTE in the form of three equal installments from 2009 to 2011. 

Additionally, the value of nuclear fuel decreases each year, and because there were no 

additions in nuclear fuel in 2009, the taxes for that year decreased from the previous year. 

However, the tax payments in 2010 increased due to a refueling that increased the value 

subject to the new Michigan State Tax Commission order (DTE 2014d).

Fermi 2 Property Tax Distribution 2009–2013 (in Dollars)

Year Plant Property Tax(a) Nuclear Fuel Property Taxes(b) Total Property Taxes

2009 18,205,402 182,717 18,388,119

2010 18,717,489 1,595,989 20,313,478

2011 18,402,570 1,386,006 19,788,576

2012 19,508,133 1,024,198 20,532,331

2013 19,047,062 597,092 19,644,154

(a) Plant property tax for 2013 includes a refund of $155,604 received for a land parcel reclassification.

(b) $801,192 settlement refund (2013 refund of $665,532 included above; 2014 refund of $67,830; and 2015 refund 

of $67,830 from Frenchtown Township).

Source: DTE 2014g

Fermi 2 property tax payments for 2013 were distributed in accordance with the Frenchtown 

Charter Township millage spread (tax rates per $1,000 of taxable value) detailed in Table 3–37. 

Monroe and Airport schools do not receive revenue directly from property taxes paid for 

Fermi 2.

Property Taxes Paid for Fermi 2 by Millage Type, 2013 Tax Year

Millage Type

Millage Amount Paid 

Rate Dollars (dollars)

State Education 6 2,312,816

County Operating 4.7952 2,162,592
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Millage Type

Millage Amount Paid 

Rate Dollars (dollars)

County Winter 0.802 361,695

Senior Citizens 0.5 225,496

Veterans 0.002 902

Fairview 0.2 90,198

Tourism 0.1 45,099

Monroe School District 4.7541 2,144,057

Technology Enhancement 0.9866 444,948

Allocated 0.2897 130,652

Voted Operating 3.4778 1,568,457

Monroe Community College 2.1794 982,890

Monroe County Library 1 450,991

Frenchtown Allocations 7.909 3,566,888

Operating 2.7166 1,225,162

Water Bond Debt 1.5 676,487

Fire Department 3 1,352,973

Lake Erie Transportation 0.6924 312,266

Monroe Schools 19 (a)

Voted Operating 18 –

Voted Sinking Fund 1 –

Airport Schools 19.9 (a)

Voted Operating 18 –

Voted Bonded Debt 1.9 –

Jefferson Schools 18.5 7,163,251

Voted Operating 18 6,937,755

Voted Recreation 0.5 225,496

Resort District Authority 2.9274 1,320,110

Total, Including Adjustments 20,465,290

Adjustments (821,136)

Total Frenchtown Township Mills/Tax—47.8428 19,644,154

(a) These school districts do not receive revenue directly from property taxes paid for Fermi 2.

Source: DTE 2014g

Table 3–38 lists 2013 millage totals by district. The Frenchtown Charter Township prepares tax 

bills by July 1 and December 1. The summer tax bill includes State education tax millage and 

Monroe County allocated operating millage. The winter tax bill includes revenues for the 

Monroe County Community College; Monroe County Intermediate Schools; Monroe County 

seniors; Lake Erie Transportation; additional voted school millage; local township operations 

and, when applicable, the Resort Authority. At the end of the winter tax season, the Frenchtown 
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Charter Township reaches a settlement with the Monroe County Treasurer and provides their 

appropriate apportionment (DTE 2014d).

2013 Frenchtown Charter Township Millage Totals by District

District

Winter 

PRE(a)

Winter 

NonPRE(a)Summer 

All

Annual 

PRE(a)

Annual 

Non-PRE (a)

Annual 

Industrial 

Personal (b)

Annual 

Commercial 

Personal(c)

Monroe 

Schools

17.6445 35.6445 10.7952 28.4397 46.4397 22.4397 34.4397

Airport 

Schools

18.5445 36.5445 10.7952 29.3397 47.3397 23.3397 35.3397

Jefferson 

Schools

17.1445 35.1445 10.7952 27.9397 45.9397 21.9397 33.9397

Jefferson 

Schools in 

Resort District 

Authority

20.0719 38.0719 10.7952 30.8671 48.8671 24.8671 36.8671

(a) PRE = principal residence exemption.

(b) Industrial personal exempt from 18 school operating mills and 6 State education mills.

(c) Commercial personal exempt from 12 school operating mills.

Source: DTE 2014g

Fermi 2 is located within the Jefferson Resort School District; in 2013, it paid approximately

48.8671 mills in total property tax payments (Table 3–39). Of that amount, 7.9090 mills

(16 percent of the total) went to Frenchtown Township and 13.5307 mills (28 percent of the 

total) went to Monroe County (Monroe Intermediate School District, Monroe County Library, and 

Monroe County Community College). Approximately 18.5 mills (38 percent of the total) went to 

the school district, approximately 3 mills (6 percent of the total) went to the Resort Authority, and 

6 mills (12 percent of the total) went to the State of Michigan State education tax fund 

(DTE 2014d).

2013 Fermi 2 Property Tax Distribution in Millage

Jurisdiction Total (Mills) Percent of Total

State Education Tax 6.0000 12

Frenchtown Charter Township 7.9090 16

Monroe County 13.5307 28

Jefferson Schools in Resort 

District Authority

18.5000 38

Resort Authority 2.9274 6

Total 48.8671 100

Source: DTE 2014g

Table 3–40 presents Fermi 2 total property tax distribution as a percentage of the total amount 

of property taxes collected by selected jurisdictions in Frenchtown Township for 2013. The 

amount of property tax revenue attributable to Fermi 2 ranges from 34 to 53 percent of the total 

property tax revenues. 
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3-145

2013 Fermi 2 Property Tax Distribution as a Percentage of 

Total Property Taxes Collected by Frenchtown Township

Jurisdiction

Total

Mills(a)

Total Property 

Taxes Collected 

by Frenchtown 

Township(b)

Fermi 2

Property Tax 

Payment

Percent of 

Total Property 

Taxes 

Collected

Mills Included in 

Total

State Education 

Tax

6.0000 6,795,216 2,312,816 34 State Education

Frenchtown 

Township

9.9500 11,264,062 4,886,998 43 Frenchtown 

Allocations and Resort 

District Authority

Monroe County 6.6000 7,471,567 3,958,168 53 County Operating, 

County Winter, 

Monroe Community 

College, and Monroe 

County Library

School Taxes(c) 18.7900 21,281,376 9,307,308 44 Monroe School District 

and Jefferson Schools

(a) Total mills is a weighted average from page 30 of the Michigan Department of Treasury’s “Taxable Valuations, 

Tax Levies, and Tax Rates for the Year 2013 in Michigan Townships.”

(b) Due to different classifications and tax abatements, the amount of property taxes paid may not equal the amount 

owed.

(c) Millage rate attributable to the Monroe School District is included within the Jefferson Schools weighted average 

millage.

Source: DTE 2014g

In addition, DTE makes annual payments to the State of Michigan, Monroe County, and Wayne 

County and to Amherstburg, Canada, in support of the radiological emergency response plan. 

The annual payments are as follows:

• State of Michigan—$877,000

• Monroe County—$97,200

• Wayne County—$67,200

• Amherstburg, Canada—$30,000

3.10.6 Local Transportation

The region surrounding Fermi 2 has a highly developed roadway network. I-75 running north 

and south through Monroe County and Frenchtown Charter Township is located 2 mi (3 km) 

west of Fermi 2. I-75 provides access to the Fermi site from Detroit to the north and Toledo to 

the south. North of the Fermi site, I-275 connects with I-75 connecting the western Detroit 

metropolitan area, Wayne County Airport, western Wayne County, and Oakland County. It also 

connects to I-94 and I-96, which are the primary Michigan east-west interstates.

Enrico Fermi Drive is the primary road entrance and connects the Fermi site to North Dixie 

Highway after crossing Toll Road and Leroux Road. North Dixie Highway runs north and south 

through Monroe County and Frenchtown Charter Township and provides access to regional 

highways. To the north, North Dixie Highway intersects Swan Creek Road, which connects to 
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I-75 approximately 6 mi (9.7 km) to the northwest of Fermi 2. To the south, North Dixie Highway 

provides direct access to I-75 at an interchange located approximately 6.2 mi (10 km) southwest 

of Fermi 2. North Dixie Highway also intersects Nadeau Road south of Fermi 2 with additional 

access to I-75 at an interchange approximately 6 mi (9.7 km) west of Fermi 2.

Table 3–41 lists commuting routes to the Fermi site and average annual daily traffic volume 

values. The average annual daily traffic values represent traffic volumes for a 24-hour period 

factored by both the day of the week and the month of the year.

Major Commuting Routes in the Vicinity of Fermi 2: 

2013 Average Annual Daily Traffic Count

Roadway and Location Average Annual Daily Traffic

I-75, I-275 to Newport/Swan Creek Road 49,700

I-75, North Dixie Highway to Nadeau Road 65,200

North Dixie Highway, I-75 to Nadeau Road 12,700

North Dixie Highway, Stony Creek to Williams 8,310

North Dixie Highway, Enrico Fermi to Post Road 4,140

Nadeau Road 5,300

Enrico Fermi Drive 2,378

Post Road, west of North Dixie Highway 275

Source: MDOT 2014

3.11 Human Health

3.11.1 Radiological Exposure and Risk

The regulations at 10 CFR 20.1101 require Fermi 2 to have a radiation protection program 

designed to protect onsite personnel, including employees, contractor employees, visitors, and 

offsite members of the public from radiation and radioactive material generated at Fermi 2.

The radiation protection program is extensive and includes, but is not limited to, the following:

• organization and administration (i.e., a Radiation Protection Manager who is 

responsible for implementing the program and for ensuring that workers are trained 

and qualified);

• implementing procedures;

• an ALARA program to minimize dose to workers and members of the public;

• a dosimetry program (i.e., measure radiation dose of plant workers);

• Radiological Controls (i.e., protective clothing, shielding, filters, respiratory 

equipment, and individual work permits with specific radiological requirements);

• radiation area entry and exit controls (i.e., locked or barricaded doors, interlocks, 

local and remote alarms, and personnel contamination monitoring stations);

• posting of radiation hazards (i.e., signs and notices alerting plant personnel of 

potential hazards);
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• record keeping and reporting (i.e., documentation of worker dose and radiation 

survey data);

• radiation safety training (i.e., classroom training and use of mockups to simulate 

complex work assignments);

• radioactive effluent monitoring management (i.e., control and monitor radioactive 

liquid and gaseous effluents released into the environment);

• radioactive environmental monitoring (i.e., sampling and analysis of environmental 

media, such as air, water, vegetation, food crops, direct radiation, and milk to 

measure the levels of radioactive material in the environmental that may impact 

human health); and

• radiological waste management (i.e., control, monitor, process, and dispose of 

radioactive solid waste).

In regard to the radiation exposure to Fermi 2 personnel, the NRC staff reviewed the data in 

NUREG–0713, Occupational Radiation Exposure at Commercial Nuclear Power Reactors and 

Other Facilities 2014: Forty-Seventh Annual Report (Volume 36) (NRC 2016x). This report was 

the most recent available at the time of this review; it summarizes the occupational exposure 

data through 2014 that are maintained in the NRC’s Radiation Exposure Information and 

Reporting System database. The regulations at 10 CFR 20.2206 require nuclear power plants 

to report their occupational exposure data to the NRC annually.

NUREG–0713 calculates a 3-year average collective dose per reactor for all nuclear power 

reactors licensed by the NRC. The 3-year average collective dose is one of the metrics that the 

NRC uses in the Reactor Oversight Program to evaluate the applicant’s ALARA program. 

Collective dose is the sum of the individual doses received by workers at a facility licensed to 

use radioactive material over a 1-year time period. There are no NRC or EPA standards for 

collective dose. Based on the data for operating BWRs like those at Fermi 2, the 3-year 

average annual collective dose per reactor was 118.64 person-rem. In comparison, Fermi 2 

had a 3-year average annual collective dose of 123.62 person-rem.

In addition, as reported in NUREG–0713, no worker at Fermi 2 in 2014 received an annual dose

greater than 0.75 rem (0.0075 sievert (Sv)), which is well below the NRC occupational dose limit 

of 5.0 rem (0.05 Sv) in 10 CFR 20.1201.

3.11.2 Chemical Hazards

State and Federal environmental agencies regulate the use, storage, and discharge of 

chemicals, biocides, and sanitary wastes and minor chemical spills. Chemical hazards to plant 

workers resulting from continued operations associated with license renewal are expected to be 

minimized by the licensee implementing good industrial hygiene practices as required by 

permits and Federal and state regulations. Plant discharges of these chemical and sanitary 

wastes are monitored and controlled as part of the plant’s NPDES permit process to minimize 

impacts to the public and the environment. In addition, proposed changes in the use of cooling 

water treatment chemicals would require review by the plant’s NPDES permit-issuing authority 

and possible modification of the existing NPDES permit, including examination of the human

health effects of the change.

DTE controls the use, storage, and discharge of chemicals and sanitary wastes at Fermi 2 in 

accordance with its chemical control procedures and site-specific chemical spill prevention 

plans. As part of the chemical control procedures, DTE minimizes onsite chemical inventory by 

requiring personnel, before they can procure new chemical stocks, to check DTE’s existing 
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stock system to ensure that requested chemicals, or similar chemicals, are not already available 

elsewhere in the facility (DTE 2014g). Chemical wastes are controlled and managed in 

accordance with DTE’s waste management procedure. These plant procedures and plans are 

designed to prevent and minimize the potential for a chemical or hazardous waste release that 

could impact workers, members of the public, and the environment (DTE 2014d).

3.11.3 Microbiological Hazards

Typical microbiological hazards associated with nuclear plant cooling operations and thermal 

discharge include thermophilic microorganisms, such as enteric pathogens (Salmonella spp., 

Shigella spp., and Pseudomonas aeruginosa), thermophilic fungi, bacteria (Legionella spp.), 

and the free-living amoeba (Naegleria fowleri). The presence of these microorganisms could

result in adverse effects to the health of nuclear power plant workers in plants that use cooling 

towers and to the health of the public where thermal effluents discharge into cooling ponds, 

lakes, canals, or rivers. Section 4.14 addresses harmful algal blooms, such as those observed 

in recent years in Lake Erie.

3.11.3.1 Background Information on Microorganisms of Concern

Salmonella typhimurium and S. enteritidis are two species of enteric bacteria that cause 

salmonellosis, a disease more common in summer than winter (CDC 2012). Salmonellosis is 

transmitted through contact with contaminated human or animal feces and may be spread 

through water transmission or contact with food or infected animals (CDC 2014). The bacteria 

grow at temperatures ranging from 77 to 113 °F (25 to 45 °C), have an optimal growth 

temperature around human body temperature (98.6 °F (37 °C)), and can survive extreme 

temperatures as low as 41 °F (5 °C) and as high as 122 °F (50 °C) (Oscar 2009). Research 

studies examining the persistence of Salmonella spp. outside of a host found that the bacteria 

can survive for several months in water and in aquatic sediments (Moore et al. 2003).

Shigellosis infections are caused by the transmission of Shigella spp. from person to person 

through contaminated feces and unhygienic handling of food. Like salmonellosis, infections are 

more common in summer than in winter (CDC 2014). The bacteria grow at temperatures 

between 77 and 99 °F (25 and 37 °C) and can survive temperatures as low as 41 °F (5 °C) 

(PHAC 2011).

Pseudomonas aeruginosa can be found in soil, hospital respirators, water, and sewage and on 

the skin of healthy individuals. It is most commonly linked to infections transmitted in healthcare 

settings. It is a waterborne pathogen, and infections from exposure to P. aeruginosa in water 

can lead to development of mild respiratory illness (CDC 2013c). These bacteria have an 

optimal growth temperature of 98.6 °F (37 °C) and can survive in temperatures as high as 

107.6 °F (42 °C) (Todar 2004).

Legionella spp. infections result in legionellosis (e.g., Legionnaires’ disease), which manifests 

as a dangerous form of pneumonia or an influenza-like illness. Legionellosis occurrences vary 

by season and geographic location; Midwestern states report the highest numbers of cases 

during summer and early fall (CDC 2011). Legionella spp. thrive in aquatic environments as 

intracellular parasites of protozoa and are only infectious in humans through inhalation contact 

from an environmental source (CDC 2013a). Conditions that favor Legionella spp. growth are 

stagnant water between 95 and 115 °F (35 and 46 °C), although the bacteria can grow at 

temperatures as low as 68 °F (20 °C) and as high as 122 °F (50 °C) (OSHA 1999).

The free-living amoeba Naegleria fowleri prefers warm freshwater habitats and is the causative 

agent of human primary amoebic meningoencephalitis. Infections occur when N. fowleri

penetrate the nasal tissue through direct contact with water in warm lakes, rivers, or hot springs 
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and migrate to the brain tissues (CDC 2013b). This free-swimming amoeba species is rarely 

found in water temperatures below 95 °F (35 °C), and infections rarely occur at those 

temperatures (Tyndall et al. 1989).

3.11.3.2 Studies of Microorganisms in Cooling Towers

A 1981 study (Tyndall 1982) found pathogenic Naegleria fowleri in heated cooling water at 2 of 

11 nuclear power plant sites and infectious Legionella spp. at 7 of the 11 sites. The 

concentrations of these organisms at these sites increased less than 10 fold in heated waters 

relative to source water. Tyndall’s (1982) recommendations for disease prevention include the 

use of protective devices for plant personnel in close contact with cooling water sources known 

to contain infectious microorganisms.

In another study, Tyndall (1983) examined the distribution and abundance of Legionella spp. 

and N. fowleri near large industrial cooling towers. Legionella spp. were detected at low 

abundances in air discharged from cooling towers and in some upwind and downwind air 

samples. N. fowleri were detected but were not pathogenic. Tyndall (1983) concludes that 

industrial hygiene measures to limit plant worker exposure during maintenance of cooling water 

systems may be appropriate.

A more recent study (Berk et al. 2006) examined 40 natural aquatic environments and 

40 cooling towers to determine the relative abundance of amoebae that may harbor infectious 

bacteria due to cooling tower operations from industries, hospitals, and public buildings. Those 

authors found that infected amoebae are 16 times more likely to occur in cooling towers than in 

natural environments and that cooling towers may be possible “hot spots” for emerging 

pathogenic bacteria.

3.11.3.3 Microbiological Hazards to Plant Workers

Plant workers are most likely to be exposed to pathogenic microorganisms from power plant 

operations when cleaning or providing other maintenance services that involve the cooling water 

system, including cooling towers and condensers. Diseases (e.g., legionellosis and primary 

amoebic meningoencephalitis) that involve respiratory or nasal infectivity routes are of primary 

concern, and workers should wear appropriate respiratory protection. Workers performing 

underwater activities should wear protective gear to prevent oral or nasal exposure to amoebae 

or other pathogenic bacteria. Plant operators should continue using proven industrial hygiene 

principles to minimize workforce exposures to microbiological organisms that may occur in the 

cooling water system (NRC 2013b).

3.11.3.4 Microbiological Hazards to the Public

Thermal effluents produced during nuclear power plant operations discharge to lakes, ponds, 

canals, or rivers and, therefore, may enhance the growth of naturally occurring thermophilic 

microorganisms. The public may come into contact with these water bodies through swimming 

and boating activities. Although the NPDES permit for Fermi 2 has no discharge temperature 

limits, DTE (2014d) reports that the heated effluent from Fermi 2 discharges into a restricted 

industrial area along the Lake Erie shoreline that is not used for recreation activities, such as 

boating, swimming, diving, and other water sports, which limits exposure to people on the 

shoreline or those engaging in water sports to warm water that might support thermophilic 

microorganisms.

3.11.4 Electromagnetic Fields

Based on the GEIS, the Commission found that electric shock resulting from direct access to 

energized conductors or from induced charges in metallic structures has not been found to be a 
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problem at most operating plants and generally is not expected to be a problem during the 

license renewal term. However, a site-specific review is required to determine the significance 

of the electric shock potential along the portions of the transmission lines that are within the 

scope of this SEIS.

In the GEIS, the NRC found that without a review of the conformance of each nuclear plant 

transmission line with National Electrical Safety Code® (NESC®) criteria, determining the 

significance of the electric shock potential (IEEE 2002) was not possible. Evaluation of 

individual plant transmission lines is necessary because the issue of electric shock safety was 

not addressed in the licensing process for some plants. For other plants, land use in the vicinity 

of transmission lines may have changed, or power distribution companies may have chosen to 

upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an 

assessment of the impact of the proposed action on the potential shock hazard from the 

transmission lines if the transmission lines that were constructed for the specific purpose of 

connecting the plant to the transmission system do not meet the recommendations of the 

NESC® for preventing electric shock from induced currents. The NRC uses the NESC® criteria 

and the applicant’s adherence to those criteria during the current operating license as its 

baseline to assess the potential human health impact of the induced current from an applicant’s 

transmission lines. As discussed in the GEIS, the issue of electric shock is of small significance 

for transmission lines that are operated in adherence with the NESC® criteria. 

As stated by DTE in its ER, the transmission lines that currently connect Fermi 2 to the regional 

electrical distribution grid and that would remain energized only if the plant’s operating license 

were renewed are in-scope for evaluation in this SEIS. These in-scope transmission lines are 

entirely within the Fermi 2 owner-controlled area and span industrial areas within the Fermi site. 

Therefore, the public does not have access to this area and could not come into contact with 

these energized lines. Therefore, there is no potential shock hazard to members of the public

from these transmission lines.

The Michigan Occupational Safety and Health Administration (MIOSHA) safety standards 

govern the nonradiological occupational safety and health of Fermi 2 workers. Operational 

safety requirements associated with MIOSHA are incorporated into Fermi 2’s occupational

health and safety program. Fermi 2 has implemented the following practices to limit the 

potential hazards from acute and induced electric shock to its workers:

• A risk analysis is performed to determine the probability of a shock hazard based on 

the task, tools, accessibility of equipment, proximity to live parts, and energy level. 

• During work on overhead lines, employees standing on the ground cannot come in

contact with a vehicle or mechanical equipment unless the transmission line is

de-energized and properly grounded, the employee is using proper protective 

equipment, and the vehicle or equipment is located so that no energized conductive 

path is within the limited approach distance. 

• Vehicles or mechanical equipment are properly grounded before approaching the 

limited approach distance. 

• Materials to be stored near the 345-kV energized lines must be stored at a distance 

of 19 ft 10 in. (6 m), plus an amount that provides for maximum sag and swing of the 

line (DTE 2014d). 

DTE manages electric shock hazards, including those from induced current shock, in 

compliance with the MIOSHA’s requirements to protect its workers.
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3.11.5 Other Hazards

Two additional human health issues are addressed in this section: (1) physical occupational 

hazards and (2) electric shock hazards.

Nuclear power plants are industrial facilities that have many of the typical occupational hazards 

found at any other electric power generation utility. Workers at or around nuclear power plants 

would be involved in some electrical work, electric power line maintenance, repair work, and 

maintenance activities and exposed to some potentially hazardous physical conditions 

(e.g., falls, excessive heat, cold, noise, electric shock, and pressure).

The Occupational Safety and Health Administration (OSHA) is responsible for developing and 

enforcing workplace safety regulations. OSHA was created by the Occupational Safety and 

Health Act of 1970, as amended (29 U.S.C. 651 et seq.), which was enacted to safeguard the 

health of workers. With specific regard to nuclear power plants, plant conditions that result in an 

occupational risk, but do not affect the safety of licensed radioactive materials, are under the 

statutory authority of OSHA rather than the NRC as set forth in a Memorandum of 

Understanding (53 FR 43950) between the NRC and OSHA. Occupational hazards are 

reduced when workers adhere to safety standards and use appropriate protective equipment; 

however, fatalities and injuries from accidents may still occur.

Fermi 2 maintains an occupational safety program in accordance with MIOSHA’s regulations for 

its workers (DTE 2014d). MIOSHA is an OSHA-approved State plan and, as such, operates a 

job safety and health program that is at least as effective as the Federal OSHA program 

(OSHA 2014).

3.12 Environmental Justice

Under Executive Order (EO) 12898 (59 FR 7629), U.S. Federal agencies are responsible for 

identifying and addressing, as appropriate, disproportionately high and adverse human health 

and environmental impacts on U.S. minority and low-income populations. Independent 

U.S. agencies, such as the NRC, are not bound by the terms of EO 12898 but are, as stated in 

paragraph 6-604 of the EO, “requested to comply with the provisions of [the] order.” In 2004, 

the Commission issued a Policy Statement on the Treatment of Environmental Justice Matters 

in NRC Regulatory and Licensing Actions (69 FR 52040), which states, “The Commission is 

committed to the general goals set forth in EO 12898, and strives to meet those goals as part of 

its NEPA review process.”

The U.S. Council on Environmental Quality (CEQ) provides the following information in a report 

entitled, “Environmental Justice: Guidance Under the National Environmental Policy Act”

(CEQ 1997):

• Disproportionately High and Adverse Human Health Effects. 

Adverse health effects are measured in risks and rates that could result in latent 

cancer fatalities, as well as other fatal or nonfatal adverse impacts on human health. 

Adverse health effects may include bodily impairment, infirmity, illness, or death. 

Disproportionately high and adverse human health effects occur when the risk or rate 

of exposure to an environmental hazard for a minority or low-income population is 

significant (as employed by NEPA) and appreciably exceeds the risk or exposure 
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rate for the general population or for another appropriate comparison group 

(CEQ 1997).

• Disproportionately High and Adverse Environmental Effects. 

A disproportionately high environmental impact that is significant (as employed by 

NEPA) refers to an impact or risk of an impact on the natural or physical environment 

in a low-income or minority community that appreciably exceeds the environmental 

impact on the larger community. Such effects may include ecological, cultural, 

human health, economic, or social impacts. An adverse environmental impact is an 

impact that is determined to be both harmful and significant (as employed by NEPA). 

In assessing cultural and aesthetic environmental impacts, impacts that uniquely 

affect geographically dislocated or dispersed minority or low-income populations or 

American Indian tribes are considered (CEQ 1997).

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on U.S. minority and low-income populations 

that could result from the operation of Fermi 2 during the renewal term. In assessing the 

impacts, the following definitions of minority individuals and populations and low-income 

population were used (CEQ 1997):

Minority Individuals

Individuals living in the U.S. who identify themselves as members of the following population 

groups: Hispanic or Latino; American Indian or Alaska Native; Asian; Black or African 

American; Native Hawaiian or Other Pacific Islander; or two or more races, meaning individuals 

who identified themselves on a Census form as being a member of two or more races 

(e.g., White and Asian).

Minority Populations

Minority populations are identified when (1) the minority population of an affected area exceeds 

50 percent or (2) the minority population percentage of the affected area is meaningfully greater 

than the minority population percentage in the general population or other appropriate unit of

geographic analysis.

Low-Income Population

Low-income populations in an affected area are identified with the annual statistical poverty 

thresholds from the USCB’s Current Population Reports, Series P60, on Income and Poverty.

3.12.1 Minority Population

According to 2010 U.S. Census data, 33 percent of the U.S. population residing within a 50-mi 

(80-km) radius of Fermi 2 identified themselves as minority individuals. The largest minority 

group was Black or African American (22.6 percent), followed by Hispanic or Latino (of any 

race) (4.4 percent) (USCB 2014b).

According to USCB’s 2010 Census data, minority populations in the socioeconomic ROI 

(Monroe and Wayne Counties) comprised 47.1 percent of the total two-County population 

(Table 3–30). Figure 3–18 shows predominantly minority population U.S. Census block groups, 

using 2010 U.S. Census data for race and ethnicity, within a 50-mi (80-km) radius of Fermi 2 

(USCB 2014b).

According to the USCB’s 2013 American Community Survey 1-Year Estimates (USCB 2014c), 

since 2010, minority populations in the socioeconomic ROI decreased by approximately 

28,600 persons and now comprise 46.8 percent of the population (Table 3–31). The largest 
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decline occurred in the Black or African American population (a decrease of 5.2 percent). This 

corresponds with the overall decline in the regional U.S. population. However, some of this 

decrease was partially offset by increases in the Asian and Hispanic or Latino U.S. populations 

(USCB 2014g).

U.S. Census block groups were considered minority population block groups if the percentage 

of the minority population within any block group exceeded 33 percent (the percent of the 

minority population within the 50-mi (80-km) radius of Fermi 2). A minority population exists if 

the percentage of the minority population within the U.S. Census block group is meaningfully 

greater than the minority population percentage in the 50-mi (80-km) radius. 

Approximately 1,700 of the 4,300 U.S. census block groups located within the 50-mi (80-km) 

radius of Fermi 2 have meaningfully greater minority populations (USCB 2014b).

As shown in Figure 3–18, minority population U.S. Census block groups (race and ethnicity) are 

mostly clustered near Detroit, Michigan, and Toledo, Ohio. The nearest minority population 

U.S. Census block group to Fermi 2 is located south of River Raisin in Monroe, Michigan. None 

of the U.S. Census block groups nearest to Fermi 2 have meaningfully greater minority 

populations.
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Figure 3–18. 2010 U.S. Census Minority Block Groups within a 50-mi (80-km) Radius of 

Fermi 2

Source: USCB 2014b
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3.12.2 Low-Income Population

The USCB’s 2013 American Community Survey 5-Year Estimates for 2009 through 2013

identifies 17 percent of U.S. individuals residing within a 50-mi (80-km) radius of Fermi 2 as 

living below the U.S. Federal poverty threshold in 2010 (USCB 2015). The 2010 U.S. Federal 

poverty threshold was $22,113 for a family of four.

According to the USCB’s 2013 American Community Survey 1-Year Estimates (USCB 2014g), 

12.3 percent of families and 17 percent of individuals residing in Michigan were living below the 

U.S. Federal poverty threshold, and the median household income for Michigan was $48,273 

(USCB 2014g). In the socioeconomic ROI, people living in Monroe County had median 

household and per capita incomes above the State average. The median household income 

average in Monroe County was $53,561 with 12.9 percent of individuals and 10.4 percent of 

families living below the poverty level. Wayne County had a lower median household income 

average ($40,487) and a higher percentage of individuals (24.9 percent) and 19.6 percent of 

families living below the poverty level (USCB 2014g).

Figure 3–19 shows the location of predominantly low-income population U.S. Census block 

groups within a 50-mi (80 km) radius of Fermi 2. U.S. Census block groups were considered 

low-income population block groups if the percentage of individuals living below the 

U.S. Federal poverty threshold within any U.S. Census block group exceeded the percent of the 

individuals living below the U.S. Federal poverty threshold within the 50-mi (80-km) radius of 

Fermi 2. Approximately 1,600 of the 4,300 U.S. Census block groups located within the 50-mi 

(80-km) radius of Fermi 2 have meaningfully greater low-income populations.

As shown in Figure 3–19, low-income population U.S. Census block groups are mostly 

clustered near Detroit, Michigan, and Toledo, Ohio. The Fermi 2 site is located in a low-income 

population U.S. Census block group. This U.S. Census block group is considered a low-income 

population block group because the percentage of people living in poverty in the block group 

was higher than the percentage of all U.S. people living in poverty within the 50-mi (80-km) 

radius of Fermi 2.
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Figure 3–19. U.S. Census Low-Income Block Groups within a 50-mi (80-km) Radius of 

Fermi 2

Source: USCB 2015
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3.13 Waste Management and Pollution Prevention

3.13.1 Radioactive Waste

As discussed in Section 3.1.4 of this SEIS, Fermi 2 uses liquid, gaseous, and solid waste

processing systems to collect and treat, as needed, radioactive materials produced as a 

byproduct of plant operations. Radioactive materials in radioactive gaseous effluents are 

reduced before being released into the environment so that the resultant dose to members of 

the public from these effluents is well within NRC and EPA dose standards. As discussed in 

Section 3.1.4 of this SEIS, Fermi 2 has not had any planned radioactive liquid effluent releases 

into Lake Erie since 1994 and plans to continue this practice in the future. Radionuclides that 

can be efficiently removed from the radioactive liquid and gaseous wastes are converted to a 

solid waste form for disposal in a licensed disposal facility.

3.13.2 Nonradioactive Waste

Waste minimization and pollution prevention are important elements of operations at all nuclear 

power plants. The licensees are required to consider pollution prevention measures as dictated 

by the Pollution Prevention Act of 1990 (42 U.S.C. 13101 et seq.) and the RCRA (NRC 2013b).

As described in Section 3.1.5, Fermi 2 has a nonradioactive waste management program to 

handle this nonradioactive waste. In addition to managing its nonradioactive waste, DTE has 

programs in place to minimize the generation of this waste. Fermi 2 implements a waste 

minimization plan to reduce, to the extent feasible, waste generated, treated, accumulated, or 

disposed. In addition to a focus on recycling operations, DTE’s waste minimization plan focuses 

on identifying waste reduction opportunities and on preventing waste before it happens. 

DTE implements best management practices for solid, special, hazardous, mixed waste, and 

chemicals to control and minimize waste generation to the maximum extent practicable 

(DTE 2014d).

Fermi 2 has a stormwater pollution prevention plan that identifies potential sources of pollution 

that may affect the quality of stormwater discharges from each permitted outfall. The 

stormwater pollution prevention plan also describes practices that are used to reduce pollutants 

in stormwater discharges to ensure compliance with the site’s NPDES permit. As part of 

Fermi 2’s chemical control procedure and site-specific spill prevention plans, measures are in 

place to monitor areas within the site that have the potential for spills of regulated substances, 

such as oil (DTE 2014d).

3.14 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

protection against radiation.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

transportation of radioactive material.” 
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10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, 

and reactor-related Greater than Class C waste.”

40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

“National Primary and Secondary Ambient Air Quality Standards.”

40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of the Environment, Part 51, 

“Requirements for Preparation, Adoptions, and Submittal of Implementation Plans.” 

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

“Designation of areas for air quality planning purposes.”

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

“Environmental radiation protection standards for nuclear power operations.”

49 CFR Parts 171–178. Code of Federal Regulations, Title 49, Transportation, Subchapter C, 

“Hazardous Materials Regulation.”

50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, “Eagle 

permits.”

50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

“Interagency cooperation—Endangered Species Act of 1973, as amended.”

32 FR 4001. U.S. Fish and Wildlife Service. “Endangered species.” Federal Register

32(48):4001. March 11, 1967.

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4-1

4.0 ENVIRONMENTAL CONSEQUENCES

AND MITIGATING ACTIONS

4.1 Introduction

In license renewal environmental reviews, the U.S. Nuclear Regulatory Commission (NRC)

considers the environmental consequences of the proposed action (i.e., continued reactor

operations), the no-action alternative (i.e., not renewing the operating license), and the 

environmental consequences of various alternatives for replacing the nuclear power plant’s 

generating capacity. In plant-specific environmental reviews, the NRC compares the 

environmental impacts of license renewal with those of the no-action alternative and 

replacement power alternatives to determine whether the adverse environmental impacts of 

license renewal are not so great that it would be unreasonable to preserve the option of license 

renewal for energy-planning decisionmakers.

In this chapter, the NRC evaluates the environmental consequences of the proposed action 

(i.e., license renewal of Fermi 2), including the (1) impacts associated with continued operations 

similar to those that have occurred during the current license term, (2) impacts of various 

alternatives to the proposed action, (3) impacts from the termination of nuclear power plant 

operations and decommissioning after the license renewal term (with emphasis on the 

incremental effect caused by an additional 20 years of reactor operation), (4) impacts 

associated with the uranium fuel cycle, (5) impacts of postulated accidents (design-basis 

accidents (DBAs) and severe accidents), (6) cumulative impacts of the proposed action, and 

(7) resource commitments associated with the proposed action, including unavoidable adverse 

impacts, the relationship between short-term use and long-term productivity, and irreversible 

and irretrievable commitment of resources. The NRC also considers new and potentially 

significant information on environmental issues related to the impacts of operation during the 

renewal term.

NUREG–1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants

(GEIS) (NRC 1996, 1999, 2013d), identifies 78 issues to be evaluated in the license renewal 

environmental review process. This supplemental environmental impact statement (SEIS)

supplements the information provided in the GEIS. Generic issues (Category 1) rely on the 

analysis presented in the GEIS, unless otherwise noted. Applicable site-specific issues 

(Category 2) have been analyzed for Fermi 2 and assigned a significance level of SMALL, 

MODERATE, or LARGE. Section 1.4 of this SEIS provides an explanation of the criteria for 

Category 1 and Category 2 issues, as well as the definitions of SMALL, MODERATE, and 

LARGE. Resource-specific impact significance level definitions are provided where applicable.

4.2 Land Use and Visual Resources

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on land use and visual resources.

4.2.1 Proposed Action

Section 3.2 of this SEIS describes land use and visual resources in the vicinity of the Fermi site. 

The four generic (Category 1) issues that apply to land use and visual resources during the 

proposed license renewal period appear in Table 4–1. The GEIS (NRC 2013d) discusses these 

issues in Section 4.2.1. The GEIS does not identify any site-specific (Category 2) land use or 

visual resource issues.
Environmental Consequences and Mitigating Actions

4-2

The NRC staff did not identify any new and significant information related to the generic 

(Category 1) land use and visual resource issues during the review of the applicant’s 

Environmental Report (ER) (DTE 2014a), the site audit, or the scoping process. Therefore, the 

NRC expects no impacts associated with these issues beyond those discussed in the GEIS. 

The GEIS concludes that the impact level for each of these issues is SMALL.

Land Use and Visual Resource Issues

Issue GEIS Section Category

Land Use

Onsite land use 4.2.1.1 1

Offsite land use 4.2.1.1 1

Offsite land use in transmission line right-of-ways (ROWs)(a) 4.2.1.1 N/A

Visual Resources

Aesthetic impacts 4.2.1.2 1

(a) This issue applies only to the in-scope portion of electric power transmission lines, which are defined as 

transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional 

power distribution system and transmission lines that supply power to the nuclear plant from the grid. As 

described in Section 3.1.6, all in-scope transmission lines subject to an environmental impact evaluation for 

license renewal are located within the Fermi site property.

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51, NRC 2013d

4.2.2 No-Action Alternative

4.2.2.1 Land Use

If Fermi 2 were to shut down, the impacts to land use would remain similar to those during 

operations until the plant is fully decommissioned. Temporary buildings and staging or laydown 

areas may be required during large component and structure dismantling. Fermi 2 is likely to 

have sufficient space within previously disturbed areas for these needs; therefore, no additional 

land would need to be disturbed that would result in changes to current land uses. In

Volumes 1 and 2 of NUREG–0586, Final Generic Environmental Impact Statement on 

Decommissioning of Nuclear Facilities, Supplement 1: Regarding the Decommissioning of 

Nuclear Power Reactors, the NRC (2002b) concludes generically that land use during 

decommissioning activities would be SMALL. The NRC staff concludes that the no-action 

alternative could, but may not necessarily, noticeably alter land use. Thus, the NRC staff 

concludes that the impacts of the no-action alternative on land use during the proposed license 

renewal term would be SMALL to MODERATE.

4.2.2.2 Visual Resources

If Fermi 2 were to shut down, visual resource impacts would remain similar to those 

experienced during operations until the site is fully decommissioned. The cooling towers, which 

create the largest visual impact, may eventually be dismantled, which would reduce the already 

SMALL impacts to visual resources that would occur during the proposed license renewal term. 

Thus, the NRC staff concludes that the impacts of the no-action alternative on visual resources 

would be SMALL.
Environmental Consequences and Mitigating Actions

4-3

4.2.3 Natural Gas Combined-Cycle Alternative

4.2.3.1 Land Use

The natural gas combined-cycle (NGCC) alternative assumes that a new NGCC facility would 

be built at the Fermi site outside the existing Fermi 2 and proposed Fermi 3 footprints. The 

facility would require an estimated 24 acres (ac) (9.7 hectares (ha)) of land for the plant with the 

possibility of additional land required for gas pipeline ROWs. Additional offsite land would be 

required for gas extraction and collection, although this impact would be partially offset by the 

elimination of land used for uranium mining to supply fuel to Fermi 2.

During construction, the use of the existing site would maximize availability of existing 

infrastructure. However, construction would likely require the conversion of natural areas 

because the new facility would be built outside the existing industrial footprint. This could affect 

656 ac (265 ha) of wetlands managed as part of the Detroit River International Wildlife Refuge 

(DRIWR) under the cooperative agreement with the U.S. Fish and Wildlife Service (FWS). 

Currently, 62.6 percent of the site’s natural areas are part of the DRIWR. The site has 64 ac 

(26 ha) of leased farmland that could be affected. The Natural Resources Conservation Service 

considers a portion of this area to be prime farmland. Other land uses on the site would likely 

be affected as well. Although construction of an NGCC facility would likely alter current land 

uses, it would be unlikely to destabilize important attributes of sensitive lands, such as DRIWR 

wetlands, because of the NGCC facility’s small footprint. Accordingly, the NRC staff concludes 

that construction impacts would be MODERATE. 

Operation of an NGCC facility would likely not incur additional land use changes; therefore, 

operational impacts would be SMALL.

Overall, impacts of the NGCC alternative on land use would be MODERATE during construction 

and would be SMALL during operation.

4.2.3.2 Visual Resources

Because the NGCC facility would be located on an industrial existing site, additional visual 

resource impacts would be minimal. The mechanical draft cooling towers would likely not be 

taller than other buildings on site and would be significantly less visible than Fermi 2’s 

natural-draft cooling towers. Some temporary visual impacts may occur during construction 

from cranes and other construction equipment that may be visible off site. During operation, 

cooling tower plumes could create noticeable visual impacts. However, these impacts would be 

no different than those assessed in Section 4.2.1 for the proposed license renewal, which were 

determined to be SMALL. The NRC staff concludes that the impacts from the construction and 

operation of an NGCC alternative on visual resources would be SMALL.

4.2.4 Integrated Gasification Combined-Cycle Alternative

4.2.4.1 Land Use

Like the NGCC alternative, the integrated gasification combined-cycle (IGCC) alternative 

assumes that a new facility would be built at the Fermi site outside the existing Fermi 2 and 

proposed Fermi 3 footprints. However, an IGCC facility would require significantly more land 

(an estimated 1,000 ac (405 ha)) than that of the NGCC alternative, which would only require 

24 ac (9.7 ha). The larger footprint of the IGCC facility would require DTE Electric Company 

(DTE) to obtain additional parcels of land adjacent to the existing site. Additional offsite land 

would be required for coal mining, although this impact would be partially offset by the 

elimination of land used for uranium mining to supply fuel to Fermi 2.
Environmental Consequences and Mitigating Actions

4-4

During construction, the use of the existing site would maximize availability of existing 

infrastructure. However, construction would likely significantly affect surrounding natural areas 

on the site and within purchased adjacent land parcels because it would require the clearing 

and grading of these areas for industrial use. This alternative would likely intensify the effects to 

the DRIWR lands, prime farmland, wetlands, and other natural areas described for the NGCC 

alternative in Section 4.2.3.1. Construction would likely noticeably alter land uses, and the large 

area of land required for the IGCC facility could destabilize important attributes of sensitive 

lands, such as DRIWR wetlands or other onsite and nearby wetlands. Accordingly, the NRC 

staff concludes that construction impacts would be MODERATE to LARGE.

Operation of an IGCC facility would likely not incur additional land use changes; therefore, 

operational impacts would be SMALL.

Overall, impacts of an IGCC alternative on land use would be MODERATE to LARGE during 

construction and would be SMALL during operation.

4.2.4.2 Visual Resources

Visual resource impacts for an IGCC facility would be similar in type and magnitude to those 

discussed for the NGCC alternative in Section 4.2.3.2 and would include temporary impacts 

during construction from tall pieces of construction equipment and visual impacts during 

operation from cooling tower plumes. The NRC staff concludes that these impacts on visual 

resources would be SMALL during both construction and operation of an IGCC alternative.

4.2.5 New Nuclear Alternative

4.2.5.1 Land Use

Like the NGCC and IGCC alternatives, this alternative assumes that DTE would build a new 

nuclear facility at the Fermi site outside the existing Fermi 2 and proposed Fermi 3 footprints. 

The facility would require an estimated 301 ac (122 ha) of land. Although the land requirement 

for the new nuclear alternative is not as large as that for the IGCC facility, this alternative would 

still require DTE to obtain additional parcels of land adjacent to the existing site. Additional 

offsite land would be required for uranium mining, although this impact would result in no net 

change in land use impacts from those that would be associated with the proposed license 

renewal of Fermi 2.

During construction, the use of the existing site would maximize availability of existing 

infrastructure. However, as with the IGCC alternative, construction of this alternative would 

likely significantly affect surrounding natural areas on the site and within purchased land 

parcels. Although the NRC (2013a) has previously determined that construction of a new 

nuclear plant on the Fermi site (the proposed Fermi 3) would result in SMALL impacts to land 

use, the new nuclear alternative considered here represents an additional disturbance to the 

Fermi site because the footprints of the proposed Fermi 3 and this new nuclear alternative are 

assumed not to overlap. This alternative would likely intensify the effects to the DRIWR lands, 

prime farmland, wetlands, and other natural areas described for the NGCC alternative in 

Section 4.2.3.1. Construction would likely noticeably alter land uses, and the large area of land

required for the new nuclear facility could destabilize important attributes of sensitive lands, 

such as DRIWR wetlands or other onsite and nearby wetlands. Accordingly, the NRC staff 

concludes that construction impacts would be MODERATE to LARGE. 

Operation of a new nuclear facility would incur impacts similar to those assessed for the 

proposed Fermi 2 license renewal, which the NRC concludes, in Section 4.2.1, would be 

SMALL.
Environmental Consequences and Mitigating Actions

4-5

Overall, impacts of a new nuclear alternative on land use would be MODERATE to LARGE 

during construction and would be SMALL during operation.

4.2.5.2 Visual Resources

Visual resource impacts for a new nuclear facility would be similar in type and magnitude to 

those discussed for the proposed Fermi 2 license renewal, which the NRC staff concludes, in 

Section 4.2.1, would be SMALL. Additional temporary visual impacts would occur during 

construction from tall pieces of construction equipment. These impacts would also be SMALL.

4.2.6 Combination Alternative (NGCC, Wind, and Solar)

4.2.6.1 Land Use

The NGCC component of the combination alternative would have the same land requirements 

as discussed for the NGCC alternative in Section 4.2.3.1. Accordingly, the impacts to land use 

would be similar to those concluded for the NGCC alternative and, therefore, would be 

MODERATE during construction and would be SMALL during operation.

The wind component of this alternative would require an estimated 1,117 to 3,351 ac (452 to 

1,356 ha) of land at onshore wind farm sites across the region of influence (ROI). However, the 

majority of this land would only be temporarily disturbed during construction. Permanently 

disturbed land would hold the wind turbines, access roads, and transmission lines. Land used 

for equipment laydown and turbine component assembly and erection could be returned to its 

original state. Given the large footprint of the wind component, land use could be affected, 

although some land uses, such as agriculture, could continue once the wind turbines are 

operational. Land use impacts for the wind component would range from SMALL to 

MODERATE depending on the amount and types of land that would be affected by wind turbine 

construction.

The solar component would require an estimated 3,577 ac (1,448 ha) of land across the ROI. 

The majority of solar installations could be installed on building roofs at existing residential, 

commercial, or industrial sites or at larger standalone solar facilities; therefore, only a little land 

would possibly be required for construction. However, the exact magnitude of impacts on land 

use would depend on the amount of land that must be converted for construction of solar 

installations. Unlike wind power, solar-powered installations often cannot be collocated with 

existing land uses (such as in crop-producing agricultural fields). The impacts of the solar 

component of this alternative on land use would range from SMALL to MODERATE depending 

on the amount and types of land that would be affected by construction of the solar installations.

The NRC staff concludes that the overall impacts of the combination alternative on land use 

would be SMALL to MODERATE. This range is primarily the result of the NGCC construction 

impacts on sensitive natural areas and the variability in land required for the wind and solar 

components.

4.2.6.2 Visual Resources

Visual resource impacts for the NGCC component of this alternative would be similar to those 

described in Section 4.2.3.2 for the NGCC alternative and, therefore, would be SMALL. Visual 

resources would be significantly affected by construction of the wind component. Although 

specific effects would vary based on the topography and remoteness of the wind turbine 

locations, the visual impact of wind energy is often one of the most significant energy-granting 

visual impacts and could range from MODERATE to LARGE. The visual impacts of the solar 

component would also vary based on the topography of the area, but the NRC expects these 

impacts to be minimal because individual solar installations are not tall or expansive, and many 
Environmental Consequences and Mitigating Actions

4-6

of the installations could be constructed on building roofs at existing residential, commercial, or 

industrial sites. Larger standalone solar facilities could have a greater visual impact depending 

on the location, but the impacts of the solar component would likely be SMALL overall. The 

NRC concludes that the impacts of the combination alternative on visual resources would be 

SMALL to LARGE. This range is primarily the result of the potential visual impacts from the 

wind component of the alternative.

4.3 Air Quality and Noise

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on air quality and noise conditions.

4.3.1 Proposed Action

4.3.1.1 Air Quality

Section 3.3 describes the meteorological, air quality, and noise conditions in the vicinity of 

Fermi 2. Two Category 1 air quality issues are applicable to Fermi 2: (1) air quality impacts (all 

plants) and (2) air quality effects of transmission lines (Table 4–2). There are no Category 2 

issues for air quality. The Category 1 issue, air quality effects of transmission lines, considers 

the production of ozone and oxides of nitrogen; the GEIS found that minute and insignificant 

amounts of ozone and nitrogen oxides (NOx) are generated during the transmission of power to 

the nuclear plant from the grid. The Category 1 issue, air quality impacts (all plants), considers 

the air quality impacts from continued operation and refurbishment associated with license 

renewal.

Air Quality and Noise

Issue GEIS Section Category

Air quality impacts (all plants) 4.3.1.1 1

Air quality effects of transmission lines 4.3.1.1 1

Noise impacts 4.3.1.2 1

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

The NRC staff did not identify any new and significant information during the review of DTE’s 

ER (DTE 2014a), the site audit, or the scoping process. As a result, the NRC did not identify 

any information or impacts related to these issues that would change the conclusions presented 

in the GEIS. Therefore, there are no impacts related to these issues beyond those discussed in 

the GEIS. The GEIS concludes that the impact level for each of these issues is SMALL.

4.3.1.2 Noise

One Category 1 noise issue is applicable to Fermi 2: noise impacts (Table 4-2). The 

1996 GEIS (NRC 1996) concluded that noise was not a problem at operating plants and was 

not expected to be a problem at any nuclear plant during the license renewal term. The GEIS 

(NRC 2013d) did not identify new information that would alter this conclusion; therefore, impacts 

are expected to be SMALL. The NRC staff did not identify any new and significant information 

during the review of DTE’s ER (DTE 2014a), the site audit, or the scoping process. As a result, 

the NRC did not identify any information or impacts related to this issue that would change the 

conclusions presented in the GEIS. Therefore, there are no impacts related to this issue 
Environmental Consequences and Mitigating Actions

4-7

beyond those discussed in the GEIS. The GEIS concludes that the impact level for this issue is 

SMALL.

4.3.2 No-Action Alternative

4.3.2.1 Air Quality

When the plant stops operating, there would be a reduction in emissions from activities related 

to plant operation, such as cooling towers, use of stationary combustion sources (e.g., such as 

diesel generators, auxiliary boilers, or combustion turbines), and vehicle traffic (e.g., workers 

and delivery). Activity from these air emission sources would not cease, but emissions would 

be lower. Therefore, if emissions decrease, the impact on air quality from shutdown of the 

Fermi 2 would be SMALL.

4.3.2.2 Noise

As discussed in Section 3.3.3 of this SEIS, the NRC staff found that the noise levels at nearby 

receptors from plant operation were a little higher than the U.S. Environmental Protection

Agency’s (EPA) guideline of 55 decibels on the A-weighted scale (dBA) day-night average 

sound intensity level (LDN) but below the acceptable U.S. Department of Housing and Urban 

Development LDN guideline of 65 dBA. When the plant stops operating, there will be a 

substantial reduction in noise from activities related to plant operation, such as the use of 

cooling towers, switchyard/transformers, stationary combustion sources (e.g., diesel generators, 

and auxiliary boilers), the firing range, and vehicle traffic (e.g., workers and deliveries). In other 

words, noise levels around the Fermi site would approach the background levels that existed 

before Fermi 2 was built. As activity from noise sources is reduced, the impact on ambient 

noise levels is not expected to be greater than that from operation of Fermi 2; therefore, impacts 

would be SMALL.

4.3.3 NGCC Alternative

4.3.3.1 Air Quality

As discussed in Section 2.2.2.1, the NRC staff evaluated an NGCC alternative that consists of 

three 400-megawatt (MW) units for a total of 1,200 MW. The NGCC alternative would be 

located at the Fermi site in Monroe County, Michigan. Some infrastructure upgrades may be 

necessary and would require construction of a new or upgraded pipeline to deliver natural gas. 

Section 3.3 characterizes air quality environment surrounding the Fermi site. Monroe County is 

designated a maintenance area for the 1997 8-hour ozone standard and 1997 and 2006 PM2.5

standard for particulate matter (PM) with a diameter of less than 2.5 micrometers (μm).

Construction

Construction of the NGCC plant would result in short-term impacts on local air quality. 

Construction-related activities, including earthmoving and vehicular traffic, will generate fugitive 

dust that will result in localized suspended particulate matter.12F

10 The operation of internal 

combustion engines in construction vehicles and equipment, delivery vehicles, and vehicles 

used by the commuting construction workforce will release various criteria pollutants, including 

carbon monoxide (CO), nitrogen oxides, sulfur oxides (SOx), PM, volatile organic compounds 

(VOCs), and various greenhouse gases (GHGs). Air emissions would be intermittent and would 

vary based on the level and duration of a specific activity throughout the construction phase. 

Gas-fired power plants are constructed relatively quickly; construction lead times for NGCC 

 10 PM10 refers to particulate matter with a diameter of less than 10 μm. PM2.5 refers to particulate matter with a 

diameter of less than 2.5 μm.
Environmental Consequences and Mitigating Actions

4-8

plants are approximately 2 to 3 years (OECD/NEA 2005; EIA 2011). Various mitigation

techniques could be used to minimize air emissions and to reduce fugitive dust. Because air 

emissions from construction activities would be limited, local, and temporary (short construction 

lead time), the NRC staff concludes that the associated air quality impacts from construction 

would be SMALL.

Operation

Operation of the NGCC plant would result in emissions of criteria pollutants, including carbon 

dioxide (CO2), nitrogen oxides, sulfur oxides, and PM. The sources of air emissions during 

operation include gas turbines through heat recovery steam generator (HRSG) stacks and 

mechanical-draft cooling towers.

Emissions for the NGCC alternative were estimated using emission factors developed by the 

U.S. Department of Energy’s (DOE’s) National Energy Technology Laboratory (NETL) NGCC 

analysis (NETL 2010). Assuming a total gross capacity of 1,200 MW and capacity factor 

of 0.85, the NRC staff estimates the following air emissions for an NGCC alternative plant:

• sulfur oxides—14 tons (13 metric tons (MT)) per year, 

• nitrogen oxides—300 tons (272 MT) per year, 

• carbon monoxide—30 tons (28 MT) per year, 

• PM10—21 tons (20 MT) per year, and 

• carbon dioxide equivalents13F

11 (CO2eq)—3.9 million tons (3.5 million MT) per year. 

Operation of the mechanical-draft cooling tower will also result in additional particulate matter 

emissions above those presented above. Additional emissions will also be associated with 

worker vehicles commuting to and from the plant. 

A new NGCC plant would qualify as a major-emitting industrial facility and would be subject to a 

New Source Review (NSR) under the Clean Air Act of 1970, as amended (CAA) 

(42 U.S.C. 7651 et seq.), to ensure that air emissions are minimized and that the local air quality 

is not substantially degraded (EPA undated(a)). The NGCC plant would need to comply with 

the standards of performance for stationary combustion turbines set forth in Subpart KKKK of 

Title 40 of the Code of Federal Regulations (40 CFR) Part 60. Subpart P of 40 CFR Part 51.307 

contains the visibility protection regulatory requirements, including review of the new sources 

that may affect visibility in any Federal Class I area. As discussed in Section 3.3.2, the nearest 

Class I Federal area for visibility protection is the Otter Creek Wilderness, which is about 

269 miles (mi) (432.9 kilometers (km)) from the Fermi site. The EPA recommends that sources 

located within 62 mi (100 km) of a Class I area be modeled to consider adverse impacts 

(EPA 1992). Considering the distance to the nearest Class I area, operation of the NGCC 

alternative at the Fermi site is not likely to adversely affect air quality and air quality-related 

values (e.g., visibility or acid deposition) at the nearest Class I area.

A new NGCC plant would also have to comply with Title IV of the CAA’s reduction requirements 

for sulfur oxides and nitrogen oxides, which are the main precursors of acid rain and the major 

causes of reduced visibility. Title IV establishes maximum sulfur oxide and nitrogen oxide

 11 CO2eq is a metric used to compare the emissions of GHG based on their global warming potential (GWP), which is 

a measure used to compare how much heat a GHG traps in the atmosphere. GWP is the total energy that a gas 

absorbs over a period of time compared to carbon dioxide. CO2eq is obtained by multiplying the amount of the 

GHG by the associated GWP. For example, the GWP of methane (CH4) is estimated to be 21; therefore, 1 ton

(0.9 MT) of methane emission is equivalent to 21 tons (19 MT) of carbon dioxide emissions.
Environmental Consequences and Mitigating Actions

4-9

emission rates from existing plants and a system of sulfur oxide emission allowances that can 

be used, sold, or saved for future use by new plants.

More recently, EPA has issued additional rules and requirements that apply to certain fossil 

fuel-based power plants, such as NGCC generation. The new plant would be subjected to the 

continuous monitoring requirements of sulfur dioxide and nitrogen oxides as specified in 

40 CFR Part 75. The Cross-State Air Pollution Rule (CSAPR) requires states (including 

Michigan) to significantly improve air quality by reducing power plant emissions that contribute 

to ozone and particulate matter in other states. CSAPR requires states to reduce annual sulfur 

dioxide emissions and nitrogen oxide emissions to attain the 1997 ozone and fine particle and 

2006 fine particle National Ambient Air Quality Standards (NAAQS). A new NGCC plant would 

be subject to these additional rules and regulations.

The NGCC alternative would emit approximately 3.9 million tons (approximately 3.5 million MT) 

of CO2eq per year. The carbon capture and storage (CCS) method would be used to reduce 

carbon dioxide by up to 90 percent; however, it would also decrease the power production 

capacity of an NGCC plant by up to 15 percent (NETL 2013). The plant would be subjected to 

the continuous monitoring requirements for carbon dioxide, as specified in 40 CFR Part 75. In 

May 2010, EPA issued the GHG Tailoring Rule establishing a process to permit GHG emission 

under Prevention of Significant Deterioration (PSD) and Title V Programs (75 FR 31514). On 

July 12, 2012, EPA14F

12 issued the third step of the final rule tailoring the criteria that determine 

which stationary sources and modifications to existing projects become subject to permitting 

requirements for GHG emissions under the PSD and Title V Programs of the CAA (Volume 77 

of the Federal Register, page 41051 (77 FR 41051)). Operating permits issued to major 

sources of GHGs under the PSD or Title V Programs must contain provisions requiring the use 

of best available control technology to limit the emissions of GHGs if those sources would be 

subject to PSD or Title V permitting requirements because of their non-GHG pollutant emission 

potentials and if their estimated GHG emissions are at least 75,000 tons of CO2eq per year. If 

the NGCC alternative meets PSD or Title V permitting requirements for non-GHG pollutant 

emissions and the GHG emission thresholds established in the rule, GHG emissions from this 

alternative would be regulated under the PSD and Title V Programs.

On January 8, 2014, EPA issued a new proposal for GHG emissions from new fossil fuel-fired 

electric utility steam generating units (79 FR 1430). It also proposes standards of performance 

for natural gas-fired stationary combustion turbines based on modern, efficient NGCC 

technology as the best system of emission reduction. In response to the Consolidated 

Appropriations Act of 2008 (Public Law 110-161), EPA issued final mandatory GHG reporting 

regulations for major sources effective in December 2009 (EPA 2012b). For the purposes of 

GHG reporting, major sources are defined as those emitting more than 25,000 MT of CO2eq for

all GHGs per year. An NGCC alternative would be subject to these reporting regulations with or 

without carbon capture.

As noted above, a new NGCC plant would be subject to several EPA regulations designed to 

minimize air quality impacts from operations. Estimated carbon monoxide, sulfur oxides, and 

particulate matter emissions would not exceed the threshold for major sources (100 tons per

year). However, the impacts from nitrogen oxide emissions would be significant and subject to 

 12 On June 23, 2014, the U.S. Supreme Court issued a decision that EPA may not treat GHGs as an air pollutant for 

purposes of determining whether a source is a major source required to obtain a PSD or Title V permit, but could 

continue to require PSD and Title V permits, otherwise required based on emissions of conventional pollutants. 

On July 2014, EPA issued a memorandum in response to the U.S. Supreme Court’s decision and acknowledged 

that, although the decision is pending judicial action, EPA will no longer require PSD or Title V permits for 

GHG-emitting sources that are not sources subject to PSD or Title V permits based on emissions of conventional 

pollutants (e.g., nitrogen oxides and carbon monoxide) (EPA 2014a).
Environmental Consequences and Mitigating Actions

4-10

a Title V permit requirement. Nitrogen oxides are an ozone precursor for which Monroe County 

is currently a designated maintenance area and can contribute to violation of NAAQS. 

Furthermore, GHG emissions would be noticeable and significant; carbon dioxide emissions 

would be much larger than the threshold in EPA’s GHG Tailoring Rule. The NRC staff 

concludes that the overall air quality impacts associated with operation of an NGCC alternative 

would be SMALL to MODERATE.

4.3.3.2 Noise

As discussed in Section 2.3.1, the NRC staff evaluated an NGCC alternative that consists of 

three 400-MW units for a total of 1,200 MW. The NGCC alternative would be located at the 

Fermi site in Monroe County outside the Fermi 2 and proposed Fermi 3 footprints. Section 3.3 

characterizes the noise environment surrounding the Fermi site. Continuous offsite noise 

measurements surrounding the Fermi site resulted in LDN that ranged between 54 and 63 dBA

(DECo 2011). Furthermore, offsite hourly equivalent sound intensity level (Leq) measurements 

were the greatest between 10 a.m. and 2 p.m., ranging between 52 dBA and 70 dBA, and were 

the lowest between 11 p.m. and 3 a.m., ranging between 36 and 48 dBA (DECo 2011).

Construction 

Construction of an NGCC plant is similar to that of other large industrial projects. Several 

factors, including source-receptor configuration, land cover, meteorological conditions 

(e.g., temperature, relative humidity, and vertical profiles of wind and temperature), and 

screening (e.g., topography and natural or manmade barriers) affect noise propagation to 

receptors. Typical construction equipment, such as dump trucks, loaders, bulldozers, graders, 

scrapers, air compressors, generators, and mobile cranes, would be used, and pile-driving and 

blasting activities would take place, during the construction of an NGCC plant. Other noise 

sources include commuter, delivery, and support vehicular traffic traveling within, to, and from 

the facility.

Offsite continuous noise measurements surrounding the Fermi site resulted in LDN between 54 

and 63 dBA. Furthermore, hourly Leq measurements surrounding Fermi were the greatest 

between 10 a.m. and 2 p.m., ranging between 52 dBA and 70 dBA, and were the lowest 

between 11 p.m. and 3 a.m., ranging between 36 and 48 dBA (DECo 2011). Construction 

vehicles and equipment associated with the construction of the NGCC plant would generate 

noise; these impacts would be intermittent and last only through the duration of plant 

construction (2 to 3 years). Noise emissions from common construction equipment would be in 

the 85- to 100-dBA range (Knauer and Pedersen 2011); however, noise levels attenuate rapidly 

with distance. For instance, at a 1,000-foot (ft) (300-meter (m)) distance from construction 

equipment with a sound strength of 85 to 90 dBA, noise levels drop to 59 to 69 dBA. At a 0.5-mi 

(0.8-km) distance from the construction noise source/equipment, noise levels drop to 51 to 

61 dBA (NRC 2002b). Although the layout and the distance from primary construction noise 

sources to the nearby receptors are unknown, the additional noise levels from construction 

related activities are not expected to be noticeable given current noise levels surrounding Fermi. 

Additionally, noise abatement and controls can be incorporated to reduce noise impacts. 

Furthermore, construction activities must be in accordance with the Frenchtown Charter 

Township Noise Ordinance (Ordinance No. 184) (FTC 1988), which prohibits excessive or loud 

noise and disturbance. 

The NRC staff concludes that construction-related noise impacts associated with the NGCC 

alternative would be SMALL.
Environmental Consequences and Mitigating Actions

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Operation

Noise sources from operations of the NGCC alternative would include the cooling tower, 

transformers, turbines, pumps, compressors, exhaust stack, the combustion inlet filter house, 

condenser fans, high-pressure steam piping, and vehicles (Saussus 2012). Pipelines delivering 

natural gas fuel could be audible off site near gas compressor stations. Most noise-producing 

equipment is located inside the power block buildings and no outside fuel-handling activities will 

occur. Minor offsite noise sources could be pipeline compressor stations. The NRC staff does 

not expect noise impacts for the NGCC alternative to be any greater than that analyzed for 

Fermi 2. The NRC staff concludes that operation-related noise impacts from the NGCC 

alternative would be SMALL.

4.3.4 IGCC Alternative

4.3.4.1 Air Quality

As discussed in Section 2.2.2.2, the NRC staff evaluated an IGCC plant alternative that would 

consist of two 618-MW units for a total 1,236 MW. The IGCC alternative would be located at 

the Fermi site in Monroe County. Section 3.3.2 characterizes the air quality environment 

surrounding the Fermi site. Monroe County is designated a maintenance area for the 8-hour

ozone 1997 standard and PM2.5 1997 and 2006 standard.

Construction

Construction of an IGCC plant would be similar to that of other large industrial projects. 

Construction-related activities and associated emissions (i.e., criteria pollutants, VOCs, 

hazardous air pollutants (HAPs), and GHGs) would be similar as those described for the NGCC 

alternative. Air emissions would be intermittent and would vary based on the level and duration 

of a specific activity throughout the construction phase. Construction lead times for IGCC plants 

are estimated to be 3 years (NETL 2007). Impacts would be localized, intermittent, and short

lived, and adherence to well-developed and well-understood construction best management 

practices (BMPs) would mitigate such impacts. The NRC staff concludes that 

construction-related impacts on air quality from an IGCC alternative would be of relatively short 

duration and would be SMALL.

Operation

Operation of the IGCC plant would result in emissions of criteria pollutants, including carbon 

dioxide, nitrogen oxides, sulfur oxides, and PM. The sources of air emissions during operation 

include HRSG stacks, wet gas sulfuric acid system exhaust, acid gas removal process 

startup/shutdown vents, startup stacks, flares, material-handling equipment, and mechanical 

draft cooling towers (DOE 2010). The HRSG stacks would release the most emissions. 

Auxiliary boilers and firewater pumps would also generate emissions on an infrequent basis.

Compared to conventional coal-fired power plants, the proposed IGCC power plant would 

reduce sulfur dioxide, nitrogen oxides, mercury, and particulate matter emissions by removing 

constituents from the synthesis gas (syngas) (i.e., gasifiers convert coal into a gas) (DOE 2010). 

The IGCC alternative would also result in lower nitrogen oxide emissions because nearly 

100 percent of the fuel-bound nitrogen from the syngas would be removed from the syngas 

before combustion in the gas turbine. Sulfur removal technology would remove more than 

99 percent of the sulfur in the syngas. The use of sulfide-activated carbon could remove more 

than 92 percent of mercury from the syngas. More than 99.9 percent of particulate matter

emissions would be removed from the syngas using high-temperature, high-pressure filtration.
Environmental Consequences and Mitigating Actions

4-12

Emissions for an IGCC plant were estimated using emission factors presented in Table 4.3-1 in 

the GEIS (NRC 2013d). Assuming a total gross capacity of 1,236 MW, subbituminous coal, and 

capacity factor of 0.85, the NRC staff estimates the following air emissions for an IGCC 

alternative plant:

• sulfur dioxide—398 tons (360 MT) per year,

• nitrogen oxides—1,456 tons (1,320 MT) per year,

• PM10—232 tons (210 MT) per year,

• carbon monoxide—992 tons (900 MT) per year, and

• carbon dioxide—6.9 million tons (6.2 million MT) per year.

Operation of the mechanical-draft cooling tower will also result in additional particulate matter 

emissions above those presented above. Additional emissions will also be associated with 

worker vehicles commuting to and from the plant. 

Various Federal and state regulations aimed at controlling air pollution would affect an IGCC 

alternative. A new IGCC plant would qualify as a new major source because of its potential to 

emit greater than 100 tons (91 MT) per year of criteria pollutants, and it would be subject to the

NSR Permitting Program requirements under the CAA (EPA undated(a)). An NSR permit or 

construction permit would specify emission limits for each pollutant, along with monitoring and 

reporting requirements, specifications for fuel and control equipment, and monitoring and 

performance testing. The new IGCC plant would be required to secure a Title V operating 

permit from the Michigan Department of Environmental Quality (MDEQ).

An NSR would limit emissions for criteria pollutants and would reflect existing ambient air quality 

at the site location. The IGCC alternative also would need to comply with the standard of 

performance for new stationary sources set forth in Subpart Da, “Standards of Performance for 

Electric Utility Steam Generating Units,” of 40 CFR Part 60. If the IGCC alternative were 

located close to a mandatory Class I area, additional air pollution control requirements would be 

necessary (Subpart P, “Protection of Visibility,” of 40 CFR Part 51) as mandated by the 

Regional Haze Rule. As discussed in Section 3.3.2, the nearest Class I Federal area for 

visibility protection is the Otter Creek Wilderness, about 269 mi (432.9 km) from the Fermi site. 

EPA recommends that sources located within 62 mi (100 km) of a Class I area be modeled to 

consider adverse impacts (EPA 1992). Considering the distance to the nearest Class I area, 

operation of the IGCC at the Fermi site is not likely to adversely affect air quality and air 

quality-related values (e.g., visibility or acid deposition) at the nearest Class 1 area.

The IGCC plant would have to comply with Title IV of the CAA reduction requirements for sulfur 

dioxide and nitrogen oxides, which are the main precursors of acid rain and the major causes of 

reduced visibility. Title IV establishes maximum sulfur dioxide and nitrogen oxide emission 

rates from the existing plants and a system of sulfur dioxide emission allowances that can be 

used, sold, or saved for future use by the new plants. The new plant would be subjected to the 

continuous monitoring requirements of sulfur dioxide and nitrogen oxides as specified in 

40 CFR Part 75. The CSAPR requires states (including Michigan) to significantly improve air 

quality by reducing power plant emissions that contribute to ozone and particulate matter in 

other states. CSAPR requires states to reduce annual sulfur dioxide and nitrogen oxide 

emissions to assist in attaining the 1997 ozone and fine particle and 2006 fine particle NAAQS. 

A new IGCC plant would be subject to these additional rules and regulations.

The IGCC alternative would emit approximately 6.9 million tons (approximately 6.2 million MT) 

per year of carbon dioxide. The CCS could be used as a method to reduce carbon dioxide by 

up to 90 percent; however, it would also decrease the power production capacity of an IGCC 
Environmental Consequences and Mitigating Actions

4-13

plant by up to 17 percent (NETL 2013). The plant would be subjected to the continuous 

monitoring requirements for carbon dioxide, as specified in 40 CFR Part 75. In May 2010, EPA

issued the GHG Tailoring Rule establishing a process to permit GHG emission under PSD and 

Title Programs. On July 12, 2012, EPA issued the third-step of the final rule tailoring the criteria 

that determine which stationary sources and modifications to existing projects become subject 

to permitting requirements for GHG emissions under the PSD and Title V Programs of the CAA

(77 FR 41051). Operating permits issued to major sources of GHG under the PSD or Title V 

Programs must contain provisions requiring the use of best available control technology to limit 

the emissions of GHGs if those sources would be subject to PSD or Title V permitting 

requirements because of their non-GHG pollutant emission potentials and if their estimated 

GHG emissions are at least 75,000 tons per year of CO2eq. If the IGCC alternative meets PSD 

or Title V permitting requirements for non-GHG pollutant emissions and the GHG emission 

thresholds established in the rule, GHG emissions from this alternative would be regulated 

under the PSD and Title V Programs. In response to the Consolidated Appropriations Act 

of 2008, EPA issued final mandatory GHG reporting regulations for major sources effective in 

December 2009 (EPA 2012b). For the purposes of GHG reporting, major sources are defined 

as those emitting more than 25,000 MT per year of CO2eq for all GHGs per year. An IGCC 

alternative would be subject to these reporting regulations with or without carbon capture. On 

January 8, 2014, EPA issued a new proposal for GHG emissions from new fossil fuel-fired 

electric utility steam generating units (79 FR 1430). It also proposes standards of performance 

for IGCC units that burn coal. The performance standards are based on partial implementation 

of the CCS method as the best system of emission reduction. Although the proposed rule has 

not been finalized, the IGCC alternative analysis includes an option for future implementation of 

the CCS method.

An IGCC alternative also would be subject to the Mercury and Air Toxics Standards (MATS) 

final rule, finalized by EPA on December 16, 2011 (77 FR 9304). Standards for emissions of 

heavy metals (mercury, arsenic, chromium, and nickel) and acid gases (hydrochloric acid and 

hydrofluoric acid) are set by MATS. Mercury is the most prominent HAP emitted and is subject 

to regulation by the MATS rule. New IGCC units are required to meet a mercury emission limit 

of 0.003 pound per gigawatt-hour (Subpart UUUUU of 40 CFR Part 63). The NRC staff 

estimates that an IGCC alternative replacing the electrical output of Fermi 2 would generate 

0.01 ton (0.01 MT) of mercury per year.

Estimated criteria pollutants from operation of the IGCC alternative would exceed the threshold 

for major sources (100 tons per year). The impact from criteria pollutant emissions from the 

operation of the IGCC would be significant and would be subject to a Title V permit. Nitrogen 

oxides (precursors of ozone) and particulate matter are of particular concern because Monroe 

County is designated a maintenance area for ozone and PM; therefore, the pollutants can 

contribute to violation of NAAQS. The GHG emissions also would be noticeable and significant.

The GHG emissions would be much larger than the threshold in EPA’s GHG Tailoring Rule, and 

such emissions may be regulated under the PSD and Title V Programs. The NRC staff 

concludes that the air quality impacts associated with the operation of an IGCC alternative 

would be MODERATE.

4.3.4.2 Noise

As discussed in Section 2.2.2.2, the NRC staff evaluated an IGCC plant alternative that would 

consist of two 618-MW units for a total 1,236 MW. The IGCC alternative would be located at 

the Fermi site in Monroe County outside the Fermi 2 and proposed Fermi 3 footprints. 

Section 3.3.3 characterizes the noise environment surrounding the Fermi site. Continuous 

offsite noise measurements surrounding the Fermi site resulted in LDN that ranged between 54 

and 63 dBA (DECo 2011). Furthermore, offsite hourly Leq measurements were the greatest 
Environmental Consequences and Mitigating Actions

4-14

between 10 a.m. and 2 p.m., ranging between 52 dBA and 70 dBA, and were the lowest 

between 11 p.m. and 3 a.m., ranging between 36 and 48 dBA (DECo 2011).

Construction 

Construction of an IGCC plant is similar to that of other large industrial projects, and 

construction-related noise sources would be similar to those for construction of the NGCC 

alternative discussed above. Although the distance from construction-related noise sources to 

the nearby receptors are unknown, the additional noise levels from construction-related 

activities are not expected to be noticeable given current noise levels surrounding Fermi. 

Additionally, noise abatement and controls can be incorporated to reduce noise impacts.

Furthermore, construction activities will need to be done in accordance with the Frenchtown 

Charter Township Noise Ordinance (Ordinance No. 184), which prohibits excessive or loud 

noise and disturbance. The NRC staff concludes that construction-related noise associated with 

the IGCC alternative would be SMALL.

Operation 

Operation of an IGCC plant would introduce mechanical sources of noise that would be audible 

off site. Continuous sources include the mechanical equipment associated with normal plant 

operations and mechanical-draft cooling towers. Intermittent sources include the equipment 

related to coal handling, solid waste disposal, transportation related to coal, and the commuting 

of plant employees. Noise levels from operation of the IGCC plant are expected to be similar to 

the noise levels from operation of Fermi 2. However, noise associated with the rail delivery of 

coal and lime/limestone would extend beyond the plant site boundary and would be most 

significant for residents living in the vicinity of the facility and along the rail route. Noise impacts 

associated with rail delivery are predicted to be in the 80- to 96-dBA range (NRC 2002b).

Transportation-related noise sources have the potential to have offsite noise impact because

noise levels may be noticeable beyond current noise levels surrounding the Fermi site. The 

NRC staff concludes that the potential impacts of noise on residents in the vicinity of the 

alternative IGCC facility and the rail line are considered to range from SMALL to MODERATE, 

depending on the distance from primary noise sources to nearby sensitive receptors.

4.3.5 New Nuclear Alternative

4.3.5.1 Air Quality

This alternative includes the construction and operation of one economic simplified boiling water 

reactor (ESBWR) with an approximate generating capacity of 1,170 megawatt electric (MWe). 

The new nuclear alternative could be located at the Fermi site in Monroe County outside the 

Fermi 2 and proposed Fermi 3 footprints. Using an existing power plant site will maximize the 

use of existing infrastructure. Section 3.3.2 characterizes the air quality environment 

surrounding the Fermi site. Monroe County is designated a maintenance area for the 8-hour

ozone 1997 standard and the PM2.5 1997 and 2006 standard.

Construction

Construction of the new nuclear plant would result in temporary impacts on local air quality. 

During the construction phase, the primary sources of air emissions would consist of engine 

exhaust and fugitive dust emissions. Engine exhaust emissions would be from heavy 

construction equipment and commuter, delivery, and support vehicular traffic traveling within, to, 

and from the facility. Fugitive dust emissions would be from soil disturbances by heavy 

construction equipment (e.g., earthmoving, excavating, and bulldozing), vehicle traffic on 

unpaved surfaces, concrete batch plant operations, and wind erosion to a lesser extent. Air 
Environmental Consequences and Mitigating Actions

4-15

emissions include criteria pollutants (PM, nitrogen oxide, carbon monoxide, and sulfur dioxide), 

VOCs, HAPs, and GHGs. Small quantities of VOCs and HAPs emissions would be released 

from equipment refueling; organic solvents used in cleaning, onsite storage, and use of 

petroleum-based fuels; onsite maintenance of the heavy construction equipment; and certain 

painting and other construction-finishing activities.

Air emissions would be intermittent and would vary based on the level and duration of a specific 

activity throughout the construction phase. Construction lead times for nuclear plants are 

anticipated to be 7 years (NRC 2013f). DTE provided preconstruction and construction air 

emission estimates related to building Fermi 3 to assist the NRC in developing its conformity 

applicability analysis on whether a general conformity determination would be required under

Subpart B, “Determining Conformity of General Federal Actions to State or Federal 

Implementation Plans,” of 40 CFR Part 93, for construction and operation of Fermi 3

(NRC 2013a). The NRC staff expects that construction-related emissions from the new nuclear 

alternative would be bounded by the estimates that DTE provided because they include 

emissions from preconstruction and construction activities of a new nuclear plant. Annual 

emissions would be bounded by the following:

• sulfur dioxide—0.4 tons (0.3 MT) per year, 

• nitrogen oxides—123 tons (112 MT) per year, 

• PM2.5—70 tons (64 MT) per year, 

• carbon dioxide—26,230 tons (23,800 MT) per year, and 

• volatile organic carbons (VOCs)—53 tons (48 MT) per year. 

The emissions presented above account for peak worker vehicle emissions, nonroad 

construction engines, and fugitive dust. Air emissions from construction activities are 

anticipated to be lower than those presented above because the estimates account for

preconstruction activities. Furthermore, State and Federal permits and regulated practices for 

managing air emissions from construction equipment and temporary stationary sources, 

controlling fugitive dust, and developing vehicle inspection and traffic management plans can 

result in even lower emissions than those quantified above. The NRC staff developed an 

applicability analysis and determined that construction of Fermi 3 would not result in any 

exceedance of the emissions budget in the State implementation plan and will not contribute to 

violation of NAAQS (NRC 2013c). Therefore, the overall air quality impacts associated with 

construction of a new nuclear alternative would be SMALL.

Operation

Operation of a new nuclear generating plant would result in air emissions similar in magnitude to 

those of Fermi 2. Nuclear power plants do not burn fossil fuels to generate electricity. Sources 

of air emissions include stationary combustion sources (e.g., diesel generators and auxiliary 

boilers), natural-draft cooling towers, and mobile sources (e.g., worker vehicles, onsite heavy 

equipment and support vehicles, and delivery of materials and disposal of wastes). A new 

nuclear power plant would need to secure a permit from MDEQ for air pollutants emitted from 

stationary combustion sources (e.g., criteria pollutants, VOCs, HAPs, and GHGs) associated 

with its operations.

The NRC staff expects the air emissions for combustion sources from a new nuclear plant to be 

similar to those currently being emitted from Fermi 2, as follows:

• sulfur dioxide—2 tons (1.8 MT) per year, 

• nitrogen oxides—47 tons (42 MT) per year,
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• carbon monoxide—5 tons (4.5 MT) per year,

• PM10—2 tons (1.8 MT) per year, and 

• CO2eq—10,250 tons (9,300 MT) per year. 

In general, most stationary combustion sources at a nuclear power plant would operate only for 

limited periods, often for periodic maintenance testing. Thus, emissions from stationary 

combustion sources are expected to fall far below the threshold for major sources (100 tons 

(91 MT) per year) and the threshold for mandatory GHG reporting (27,558 tons (25,000 MT) per 

year of CO2eq). Additional particulate matter would result from operation of a natural-draft 

cooling tower, and emissions are anticipated to be minimal and similar to Fermi 2 emissions for 

PM10, which is approximately 0.10 tons (0.09 MT) per year (DTE 2014a, 2014c). Additional 

emissions will also be associated with worker vehicles commuting to and from the plant. 

Estimated operational emissions for criteria pollutants would be below the 

100-tons- (91-MT)-per-year threshold for major sources, and GHG emissions will be below 

25,000 MT per year. Therefore, air emissions from operation of a new nuclear alternative are 

not expected to contribute to NAAQS violations. The NRC staff concludes that the impacts of 

operation of a new nuclear alternative on air quality from the emissions of criteria pollutants and 

GHGs would be SMALL.

4.3.5.2 Noise

This alternative includes the construction and operation of one ESBWR with an approximate 

generating capacity of 1,170 MWe. The new nuclear alternative would be located at the Fermi 

site in Monroe County outside the Fermi 2 and proposed Fermi 3 footprints. Section 3.3.3

characterizes the noise environment surrounding the Fermi site. Offsite continuous noise 

measurements surrounding the Fermi site resulted in LDN between 54 and 63 dBA (DECo 2011). 

Furthermore, hourly Leq measurements surrounding Fermi were the greatest between 10 a.m.

and 2 p.m., ranging between 52 dBA and 70 dBA, and were the lowest between 11 p.m. and 

3 a.m., ranging between 36 and 48 dBA (DECo 2011).

Construction

Construction of a new nuclear power plant is similar to that of other large industrial projects and 

involves many noise-generating activities. In general, noise emissions vary with each phase of 

construction, depending on the level of activity, the mix of construction equipment for each 

phase, and site-specific conditions. Several factors, including source-receptor configuration, 

land cover, meteorological conditions (e.g., temperature, relative humidity, and vertical profiles 

of wind and temperature), and screening (e.g., topography, and natural or manmade barriers), 

affect noise propagation to receptors. Typical construction equipment, such as dump trucks, 

loaders, bulldozers, graders, scrapers, air compressors, generators, and mobile cranes, would 

be used, and pile-driving and blasting activities would take place, during the construction of a 

new nuclear power plant. Other noise sources include commuter, delivery, and support 

vehicular traffic traveling within, to, and from the facility.

During the construction phase, a variety of construction equipment would be used for varying 

durations. Noise levels from construction equipment are predicted to be in the 85- to 100-dBA

range (Knauer and Pedersen 2011); however, noise levels attenuate rapidly with distance. For 

instance, at a 1,000-ft (300-m) distance from construction equipment with a sound strength of 

85 to 90 dBA, noise levels drop to 59 to 69 dBA. At a 0.5-mi (0.8-km) distance from the 

construction noise source/equipment, noise levels drop to 51 to 61 dBA (NRC 2002b). The 

maximum hourly Leq resulting from construction equipment of Fermi 3 was estimated to be 

67 dBA at 300 meters (1,000 ft) away from the construction area (DECo 2011; NRC 2013a), 
Environmental Consequences and Mitigating Actions

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which is below current Leq noise levels surrounding Fermi. Although the distance from primary

construction-related noise sources of a new nuclear alternative to the nearby receptors are 

unknown, the additional noise levels from construction-related activities are not expected to be 

noticeable given current noise levels surrounding Fermi. Additionally, noise abatement and 

controls can be incorporated to reduce noise impacts. Furthermore, construction activities must

be in accordance with the Frenchtown Charter Township Noise Ordinance (Ordinance No. 184), 

which prohibits excessive or loud noise and disturbance.

Based on the temporary nature of construction activities, consideration of noise attenuation from 

the construction site to residences, and good noise control practices, the NRC staff concludes 

that the potential noise impacts of construction activities from a new nuclear alternative would 

be SMALL.

Operation

During the operation phase, noise sources from the new nuclear power plant would include the 

cooling tower; transformers; turbines; other auxiliary equipment, such as standby generators or 

auxiliary boilers; and vehicular traffic (e.g., commuting, delivery, and support), similar to the 

Fermi 2 noise sources discussed in Section 3.3.3 of this SEIS. As discussed in Section 3.3.3., 

continuous measurements surrounding the Fermi site resulted in LDN between 54 and 63 dBA. 

Therefore, noise levels from the new nuclear power plant may exceed EPA’s guideline LDN of 

55 dBA, but they may be less than the U.S. Department of Housing and Urban Development’s 

acceptable noise level guideline LDN of 65 dBA. 

Modeled LDN for operation of Fermi 3 ranged between 54 and 63 dBA at three nearby 

noise-sensitive receptors, indicating no increase over existing LDN surrounding Fermi 

(DECo 2011; NRC 2013a). Although the new nuclear plant layout and the distance from 

primary noise sources are unknown, the NRC staff does not expect noise impacts for a new 

nuclear plant to be any greater than those analyzed for the existing Fermi 2. Therefore, the 

noise impacts of a new nuclear plant would be SMALL.

4.3.6 Combination Alternative (NGCC, Wind, and Solar)

4.3.6.1 Air Quality

The combination alternative relies on NGCC-, wind-, and solar-generating capacity. This 

alternative includes the construction and operation of a total installed NGCC capacity of

470 MW, a total wind capacity of 2,000 MW, and a total installed solar photovoltaic (PV) 

capacity of 1,052 MW. The NGCC component would be located at the Fermi site (in Monroe 

County) to maximize use of available infrastructure and to reduce any disruption to the land. 

Monroe County is designated a maintenance area for the 8-hour ozone 1997 standard and 

PM2.5 1997 and 2006 standard. The wind and solar components of the combination alternative 

would be located elsewhere within DTE service area, an 11-county region in southeastern 

Michigan. Because the wind and solar components of the combination alternative would be 

located elsewhere within DTE service area, it is unknown at this time whether the specific site(s) 

would be located within a designated attainment area.

Construction 

Air emissions associated with the construction of the NGCC portion of the combination 

alternative are similar to the NGCC alternative. As discussed in Section 4.3.3, construction 

activities for an NGCC alternative would cause some temporary impacts to air quality from dust 

generation during operation of the earthmoving and material-handling equipment and exhaust 

emissions from worker vehicles and construction equipment. These emissions include criteria 

pollutants, VOCs, GHGs, and small amounts of HAPs. However, these impacts would be 
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localized, intermittent, and short lived, and adherence to well-developed and well-understood 

construction BMPs would mitigate such impacts. The NRC staff concludes that 

construction-related impacts on air quality from an NGCC portion of the combination alternative 

would be of relatively short duration and would be SMALL.

For the wind portion of the combination alternative, only a small percentage of site land (5 to 

10 percent) would be disturbed by construction activities because wind turbines need to be 

separated from one another to maximize energy production and to avoid wake turbulences 

created by upwind turbines. Construction of the wind portion of the combination alternative 

would involve a number of activities, including road and staging/laydown area construction, land 

clearing, topsoil stripping, earthmoving operations, grading, ground excavation, drilling, 

foundation treatment, wind turbine erection, ancillary building/structure construction, and 

electrical and mechanical installation. For most wind energy facilities, the site preparation 

phase would last for only a few months, followed by a year-long construction phase (depending 

on size of the wind energy facility) (Tegen 2006). Air emissions associated with construction 

activities result from fugitive dust from soil disturbances and engine exhaust from heavy 

equipment and vehicular traffic. These emissions include criteria pollutants, VOCs, GHGs, and 

HAPs. Dust suppression methods and other mitigation measures could reduce impacts from 

fugitive dust. The wind portion of the combination alternative would not have a power block 

building requiring intensive construction and excavation activities. Accordingly, the number of 

heavy equipment and workforce, level of activities, and construction duration would be 

substantially lower than that for the other alternatives. Therefore, the NRC staff concludes that 

the overall air quality impacts associated with construction of the wind portion of the 

combination alternative would be SMALL.

Construction of the solar portion of the combination alternative would cause temporary impacts 

to air quality from fugitive dust from soil disturbances and engine exhaust from heavy equipment 

and vehicular traffic. Air emissions associated with construction activities include criteria 

pollutants; VOCs; GHGs; and, to a lesser extent, HAPs. Dust suppression methods and other 

mitigation measures could reduce impacts from fugitive dust. The solar PV portion of the 

combination alternative would also not require a power block building. Accordingly, the number 

of heavy equipment and workforce, level of activities, and construction duration would be 

substantially lower than that for other alternatives. Therefore, the NRC staff concludes that the 

overall air quality impacts associated with construction of the solar PV portion of the 

combination alternative would be SMALL.

Operation

Air emissions associated with the operation of the NGCC portion of the combination alternative 

are similar to those associated with the NGCC alternative in Section 4.3.3, but these emissions 

are reduced proportionally because its electricity output is approximately 33 percent of that of 

the NGCC alternative.

Emissions for a NGCC plant were estimated using emission factors developed by the DOE’s 

NETL life-cycle NGCC analysis (NETL 2010). Assuming a total gross capacity of 400 MW and 

a capacity factor of 0.85, the NRC staff estimates the following air emissions for an NGCC 

alternative plant:

• sulfur dioxide—5.4 tons (5.0 MT) per year,

• nitrogen oxides—118 tons (106 MT) per year,

• PM10—8.5 tons (7.7 MT) per year,
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• carbon monoxide—12 tons (11 MT) per year, and

• CO2eq—1.5 million tons (1.4 million MT) per year.

Annual emissions of nitrogen oxides would exceed the major source threshold and carbon 

dioxide equivalent emissions would exceed the threshold for mandatory GHG reporting 

(25,000 MT (27,558 tons) CO2eq per year). Nitrogen oxides are an ozone precursor for which 

Monroe County is currently a designated maintenance area and can contribute to violation of 

NAAQS. Therefore, overall air quality impacts associated with operation of the NGCC portion of 

the combination alternative would be SMALL to MODERATE.

Emissions from the operation of wind energy facilities would include minor dust and engine 

exhaust emissions from vehicles and heavy equipment associated with site inspections, 

maintenance activities, and wind erosion from cleared land and access roads. There would be 

no direct emissions from operation of the wind portion of this alternative. The NRC staff 

concludes that the overall air quality impacts associated with the operation of the wind portion of 

the combination alternative would be SMALL.

In general, air emissions associated with the operation of solar energy facilities are negligible 

because no fossil fuels are burned to generate electricity. Emissions from solar fields would 

include fugitive dust and engine exhaust emissions from vehicles and heavy equipment 

associated with site inspections, maintenance activities (panel washing or replacement), and 

minor wind erosion from cleared lands and access roads. These emissions should not cause 

exceedances of air quality standards or should not have any impacts on climate change. There 

would be no direct emissions from operation of the solar component of the alternative. The 

NRC staff concludes that the overall air quality impacts associated with the operation of the 

solar PV portion of the combination alternative would be SMALL.

The overall air quality impacts associated with construction and operation of the combination 

alternative would be SMALL to MODERATE.

4.3.6.2 Noise

As discussed in Section 2.2.2.4, the NGCC portion of the combination alternative would be 

located at the Fermi site in Monroe County outside the Fermi 2 and proposed Fermi 3 footprints. 

Section 3.3.3 characterizes the noise environment surrounding the Fermi site. Offsite 

continuous noise measurements surrounding the Fermi site resulted in LDN between 54 and 

63 dBA (DECo 2011). Furthermore, hourly Leq measurements surrounding Fermi were the 

greatest between 10 a.m. and 2 p.m., ranging between 52 dBA and 70 dBA, and were the 

lowest between 11 p.m. and 3 a.m., ranging between 36 and 48 dBA (DECo 2011). The wind 

and solar portion of the combination alternative would be located elsewhere within the DTE 

service area and the noise environment will depend on the specific site location.

Construction 

The construction-related noise sources for the NGCC portion of the combination alternative 

would be similar to those for construction of the NGCC alternative. The construction period for 

the NGCC portion would be shorter, and the level of construction activities would be less 

extensive than the NGCC alternative. Consequently, the NRC staff concludes that 

construction-related noise associated with the NGCC portion of the combination alternative 

would be SMALL.

Construction of the wind portion of the combination alternative would involve a number of 

activities, as described in Section 4.3.6.1 above. Noise levels to nearby receptors will depend 

on the distance from primary noise sources to the nearby receptors. Because the wind portion 

of the combination alternative would have no power block building requiring construction, the 
Environmental Consequences and Mitigating Actions

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number of heavy equipment and workforce, level of activities, and construction duration would 

be substantially lower than that for the other alternatives. Considering these factors, the NRC 

staff concludes that construction-related noise associated with the wind portion of the 

combination alternative would be SMALL.

Construction of the solar PV portion of the combination alternative would involve a number of 

activities. Noise levels to nearby receptors will depend on the distance from primary noise 

construction-related sources to the nearby receptors. The solar PV portion of the combination 

alternative would also not require construction of a power block building. Thus, the intensity and 

duration of construction activities would be substantially lower than they would be for other 

alternatives. Considering these factors, the NRC staff concludes that construction-related noise 

associated with the solar PV portion of combination alternative would be SMALL.

Operation

Operation of the NGCC portion of the combination alternative would be virtually the same as 

operation of the NGCC alternative, as described in Section 4.3.3.2. Noise sources will include 

the power block area, cooling tower, and vehicular traffic. Most noise-producing equipment is 

located inside the power block buildings, and no outside fuel-handling activities would occur. 

Minor offsite noise sources could be pipeline compressor stations. Although the plant layout 

and the distance from primary noise sources to the nearby receptors is unknown, the NRC staff 

does not expect noise impacts for the NGCC portion of the combination alternative to be any 

greater than those analyzed for the existing Fermi 2. Therefore, the NRC staff concludes that 

operation-related noise from the NGCC portion of the combination alternative would be SMALL.

Noise impacts from wind generation operations would include aerodynamic noise from the 

turbine rotors and mechanical noise from the turbine drivetrain components. Noise levels are 

dependent on the wind and atmospheric conditions, which vary with time, and on site-specific 

conditions, including the number and size of wind turbines, their layout and distance to nearby 

sensitive receptors, land cover, and topography. Wind turbine noise levels can reach 105 dBA; 

however, studies show that, at approximately 1,000 ft (300 m) from a wind turbine, noise levels 

can fall to 43 dBA (GE 2010; Hessler 2011). Unless noise from wind turbines is masked by high 

background levels (e.g., near major highways or industrial complexes), it can be noticeable and 

annoying at farther distances. One study indicated that, for the same A-weighted sound level, a 

proportion of the individuals who were surveyed reported being more annoyed by wind turbine 

noise than by other community noise, such as aircraft, road, or railway traffic (Pedersen and 

Persson Waye 2004). Therefore, the NRC staff concludes that operation-related noise from the 

wind portion of the combination alternative would be SMALL to MODERATE, depending on the 

layout and location of the wind facility and its distance to nearby sensitive receptors.

The solar PV portion of the combination alternative would have no power block building and 

cooling towers; therefore, only a minimal number of noise sources with low-level noises would 

be present. Noise sources include small-scale cooling systems to dissipate heat from solar 

module assemblies, solar tracking devices, inverters, transformers, and vehicle traffic for 

maintenance and inspection. Because of minimal noise-generating activities, noise from a solar 

PV facility is expected to be inaudible or barely perceptible at the facility boundaries.

Considering the minimum number of sources with low-noise levels and the relative size of the 

solar PV facility, the NRC staff concludes that operation-related noise from the solar PV portion 

of the combination alternative would be SMALL.

The noise impacts associated with construction and operation of the combination alternative 

would be SMALL to MODERATE.
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4.4 Geologic Environment

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on geologic and soil resources.

4.4.1 Proposed Action

Table 4–3 identifies issues related to geology and soils that are applicable to Fermi 2 during the 

renewal term. Section 3.4 describes the local and regional geologic environment of the Fermi 

site.

Geology and Soils Issues

Issue GEIS Section Category

Geology and Soils 4.4.1 1

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

The NRC staff did not identify any new and significant information associated with the 

Category 1 geology and soils issue identified in Table 4–3 during the review of the applicant’s 

ER, the site audit, the scoping process, or the evaluation of other available information. As a 

result, no information or impacts related to these issues were identified that would change the 

conclusions presented in the GEIS. For these geology and soil issues, the GEIS concludes that 

the impacts are SMALL (NRC 2013d). It is expected that there would be no incremental 

impacts related to these Category 1 issues during the renewal term beyond those discussed in 

the GEIS, and, therefore, the impacts associated with these issues by the proposed action 

would be SMALL.

4.4.2 No-Action Alternative

There would not be any impacts to the geology and soils at the Fermi site with shutdown of the 

facility. With the shutdown of the facility, no additional land would be disturbed. Therefore, 

impacts would be SMALL.

4.4.3 NGCC Alternative

For this alternative, the impacts on geology and soil resources would occur during construction 

and no additional land would be disturbed during operations. During construction, sources of 

aggregate material, such as crushed stone and sand and gravel, would be required to construct 

buildings, foundations, roads, and parking lots. The NRC staff assumes that these resources 

would be obtained from commercial suppliers using local or regional sources. Land clearing 

during construction and the installation of power plant structures and impervious surfaces would 

expose soils to erosion and alter surface drainage. BMPs would be implemented in accordance 

with applicable permitting requirements to reduce soil erosion. These practices would include 

the use of sediment fencing, staked hay bales, check dams, sediment ponds, riprap aprons at 

construction and laydown yard entrances, mulching and geotextile matting of disturbed areas, 

and rapid reseeding of temporarily disturbed areas. Removed soils and any excavated 

materials would be stored on site for redistribution (e.g., for backfill at the end of construction). 

Construction activities would be temporary and localized. Therefore, the impacts of the NGCC 

alternative on geology and soils resources would be SMALL.
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4.4.4 IGCC Alternative

For this alternative, the impacts on geology and soil resources would occur during construction 

and no additional land would be disturbed during operations. Geologic construction material 

would be obtained, and BMPs would be applied as described in Section 4.4.3 for the NGCC 

alternative. Therefore, the impacts of the IGCC alternative on geology and soils resources 

would be SMALL.

4.4.5 New Nuclear Alternative

For this alternative, the impacts on geology and soil resources would occur during construction 

and no additional land would be disturbed during operations. Geologic construction material 

would be obtained, and BMPs would be applied as described in the NGCC alternative in 

Section 4.4.3. Therefore, the impacts of the new nuclear alternative on geology and soils 

resources would be SMALL.

4.4.6 Combination Alternative (NGCC, Wind, and Solar)

For this alternative, the impacts on geology and soil resources would occur during construction,

and no additional land would be disturbed during operations. Geologic construction material 

would be obtained, and BMPs would be applied as described in Section 4.4.3 for the NGCC 

alternative. The solar PV and the wind farm part of this alternative requires a large amount of 

land (up to 6,928 ac (2,804 ha)). However, much of the land would be undisturbed as only a 

small area would be disturbed by road and facility construction. Therefore, the impacts of the 

combination alternative on geology and soils resources would be SMALL.

4.5 Water Resources

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on surface water and groundwater resources.

4.5.1 Proposed Action

4.5.1.1 Surface Water Resources

The Category 1 (generic) surface water use and quality issues applicable to Fermi 2 are 

discussed in the following sections and listed in Table 4–4. There are no plant-specific 

Category 2 surface water use and quality issues applicable to Fermi 2 because Fermi 2 

withdraws water for cooling and other purposes from a lake, not from a river. Surface water 

resources-related aspects and conditions relevant to the Fermi site are described in 

Section 3.5.1.

Surface Water Resources Issues

Issue GEIS Section Category

Surface water use and quality (noncooling system impacts) 4.5.1.1 1

Altered current patterns at intake and discharge structures 4.5.1.1 1

Scouring caused by discharged cooling water 4.5.1.1 1

Discharge of metals in cooling system effluent 4.5.1.1 1

Discharge of biocides, sanitary wastes, and minor chemical spills 4.5.1.1 1
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Issue GEIS Section Category

Effects of dredging on surface water quality 4.5.1.1 1

Temperature effects on sediment transport capacity 4.5.1.1 1

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

Generic Surface Water Resources

The NRC staff did not identify any new and significant information associated with the 

Category 1 surface water issues identified in Table 4-4 during the review of the applicant’s ER 

(DTE 2014a), the applicant’s response to the NRC’s request for additional information

(DTE 2014c), the scoping process, or the evaluation of other available information as 

documented in Section 3.5.1 of this SEIS. As a result, no information or impacts related to 

these issues were identified that would change the conclusions presented in the GEIS

(NRC 2013d). For these issues, the GEIS concludes that the impacts are SMALL. It is 

expected that there would be no incremental impacts related to these Category 1 issues during 

the renewal term beyond those discussed in the GEIS.

4.5.1.2 Groundwater Resources

The groundwater issues applicable to Fermi 2 during the license renewal term are listed in 

Table 4–5. Section 3.5.2 describes groundwater resources at the Fermi site.

Groundwater Issues

Issue GEIS Section Category

Groundwater contamination and use (noncooling system impacts) 4.5.1.2 1

Groundwater use conflicts (plants that withdraw less than 100 gpm) 4.5.1.2 1

Radionuclides released to groundwater 4.5.1.2 2

Key: gpm = gallons per minute.

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

The NRC staff did not identify any new and significant information associated with the 

Category 1 groundwater issues identified in Table 4–5 during the review of the applicant’s ER, 

the site audit, the scoping process, or the evaluation of other available information. As a result, 

no information or impacts related to these issues were identified that would change the 

conclusions presented in the GEIS (NRC 2013d). For these issues, the GEIS concludes that 

the impacts are SMALL. Therefore, it is expected that there would be no incremental impacts 

related to these Category 1 issues during the renewal term beyond those discussed in the 

GEIS.

The Category 2 issue (Table 4–5) related to radionuclides released to groundwater during the 

renewal term is discussed in the following text.

Radionuclides Released to Groundwater

This issue looks at the potential contamination of groundwater from the release of radioactive 

liquids from plant systems into the environment. In evaluating the potential impacts on 

groundwater quality associated with license renewal, the NRC staff uses as its baseline the 

existing groundwater conditions as described in Section 3.5.2.3 of this SEIS. These baseline 
Environmental Consequences and Mitigating Actions

4-24

conditions encompass the existing quality of groundwater that could be potentially affected by 

continued operations (as compared to relevant State or EPA primary drinking water standards),

as well as the current and potential onsite and offsite uses and users of groundwater for drinking 

and other purposes. The baseline also considers other downgradient or in-aquifer uses and 

users of groundwater. As described in Section 3.5.2.3 of this SEIS, no leaks or inadvertent 

releases of radionuclides to groundwater have been detected at the Fermi site. Tritium 

concentrations in groundwater near the plant buildings remain well below the EPA’s standard 

(20,000 picocuries per liter) for public drinking water. 

During the license renewal term, no use of onsite groundwater by Fermi 2 is expected, and DTE 

does not propose to discharge any radioactive effluents to groundwater. Present and future 

Fermi operations are not expected to impact the quality of groundwater in any aquifers that are 

a current or potential future source of water for offsite users. Therefore, the NRC staff 

concludes that the impacts on groundwater use and quality during the Fermi license renewal 

term would be SMALL.

4.5.2 No-Action Alternative

4.5.2.1 Surface Water Resources

Surface water withdrawals and the rate of consumptive water use would greatly decrease and 

eventually cease after Fermi 2 is shut down. Wastewater discharges would be reduced 

considerably. Therefore, shutdown would reduce the overall impacts on surface water use and 

quality. Stormwater would continue to be discharged from the Fermi site throughout plant 

shutdown and decommissioning. Overall, the impact of this alternative on surface water 

resources would remain SMALL.

4.5.2.2 Groundwater Resources

As discussed in Section 3.5.2.2, groundwater is not used (consumed) at the Fermi site. 

Groundwater quality would not be impacted by the cessation of activities. There would be no 

impact on groundwater resources with the cessation of operations. Therefore, the impact of this 

alternative on groundwater resources would be SMALL.

4.5.3 NGCC Alternative

4.5.3.1 Surface Water Resources

Construction activities associated with the NGCC alternative would be similar to those for most 

large industrial facilities. The direct impacts from construction activities associated with the 

NGCC alternative on surface water resources would be less intensive and would be shorter in 

duration than those under either the new nuclear or IGCC alternative. A new NGCC plant on 

the existing Fermi site would occupy a much smaller footprint (i.e., about 24 ac (10 ha)) than 

that of the current Fermi 1 and 2 facilities or new IGCC or nuclear replacement power facilities. 

The new NGGC plant would likely be located on previously disturbed land within the Fermi site. 

Some additional land would also be required for construction of a natural gas supply pipeline 

along a corridor to connect with existing natural gas distribution infrastructure located about 

10 mi (16 km) west of the Fermi site (DTE 2014a). 

Temporary impacts to surface water quality may result from increased sediment loading and 

from any pollutants in stormwater runoff from disturbed areas and excavations, from spills and 

leaks from construction equipment, and from any dredge-and-fill activities. These sources could 

potentially affect surface water quality in near shore lake waters and connecting waterways to 

Lake Erie. Nevertheless, adherence to BMPs, in accordance with a Michigan Soil Erosion and 
Environmental Consequences and Mitigating Actions

4-25

Sediment Control (SESC) permit (Michigan Administrative Code (MAC) Rule

(R) 323.1701–1714) and an MDEQ-issued National Pollutant Discharge Elimination System 

(NPDES) construction stormwater permit, would prevent or minimize any surface water quality 

or groundwater quality impacts during construction. These BMPs would include appropriate 

waste management, water discharge, stormwater pollution prevention, and spill prevention 

practices.

Existing Fermi 2 surface water intake and discharge infrastructure would be used, after 

necessary refurbishment, to the maximum extent possible to reduce construction-related 

impacts on surface water quality. Dredge-and-fill operations necessary to operate and maintain 

surface water intake and discharge structures would be conducted under a permit from the 

U.S. Army Corps of Engineers (USACE) and under MDEQ equivalent permits and would require

the implementation of applicable BMPs to minimize associated impacts. These permit 

requirements would be similar to those under which Fermi 2 currently conducts maintenance 

dredging as described in Section 3.5.1.3 of this SEIS. 

Water would be required for uses, such as potable and sanitary use by the construction 

workforce, and for concrete production, equipment washdown, dust suppression, and soil 

compaction. The NRC staff assumes that the modest volumes of water needed would be taken 

from the Fermi 2 service water system. Alternatively, water could be supplied directly via a 

connection from the municipal water utility (Frenchtown Township) or trucked to the point of use. 

Use of portable sanitary facilities, typically serviced offsite by a commercial contractor, would 

serve to reduce the volume of water needed to meet the sanitary needs of the construction 

workforce. 

Some stream-crossings activities could be necessary, depending on the path of any required 

new gas pipelines and new or upgraded transmission lines to service the NGCC plant. 

However, because of the short-term nature of any required dredging and filling and 

stream-crossing activities, the hydrologic alterations and sedimentation would be localized;

water-quality impacts would be temporary and would cease after construction has been 

completed and after the site has been stabilized. The use of modern pipeline construction 

techniques, such as horizontal directional drilling, would further minimize the potential for water

quality impacts in any affected streams. In addition, as described above, water quality impacts 

would be minimized by the application of BMPs and by compliance with local and State-issued 

permits for soil erosion and sediment control during construction. Any dredge-and-fill operations 

would be conducted under a permit from the USACE and State-equivalent permits requiring the 

implementation of BMPs to minimize impacts.

For onsite facility operations, cooling water demand and consumptive water use for a three-unit 

NGCC plant using closed-cycle cooling with mechanical-draft cooling towers would be 

substantially less than those for current Fermi 2 operations and those for the IGCC and new 

nuclear alternatives. The NGCC plant would require approximately 7.5 million gallons per day 

(mgd) or 5,200 gallons per minute (gpm) (11.6 cubic feet per second (cfs) or 0.33 cubic meters 

per second (m3

/s)) of surface water for cooling water makeup and other processes, with

consumptive use totaling about 5.7 mgd or 3,960 gpm (8.8 cfs or 0.25 m3

/s). Thus, this 

alternative would consume about 70 percent less surface water than that for current Fermi 2

operations, which consumes an average of approximately 19 mgd or 13,190 gpm (29.4 cfs or 

0.83 m3

/s) of lake water.

Surface water withdrawals would be subject to applicable State water withdrawal permitting and 

registration requirements to manage surface water use conflicts. Michigan is a party to the 

2008 Great Lakes–St. Lawrence River Basin Water Resources Compact (the Compact) (Public 

Law 110-342) as discussed in Section 3.5.1.2 of this SEIS. As projected withdrawals under the 
Environmental Consequences and Mitigating Actions

4-26

NGCC alternative would result in consumptive water use greater than 5 mgd (18,925 cubic 

meters per day (m3

/day)), surface water withdrawals would be subject to the MDEQ’s water 

withdrawal permitting program (451 MCL 324.32723).

Cooling water treatment additives would be similar to those used by Fermi 2. Although the 

discharge water quality would be chemically similar except for differences in the total dissolved 

solids concentration, the discharge volume from a new NGCC plant would be a small fraction of 

the volume of cooling tower blowdown and related effluents discharged from Fermi 2. All 

effluent discharges would be subject to an MDEQ-issued NPDES individual permit for the 

discharge of wastewater and industrial stormwater to waters of the United States, in accordance 

with MAC R 323.2101–2197. Sanitary effluent would likely be discharged to Monroe 

Metropolitan Wastewater Facility in compliance with their influent acceptance criteria. To 

prevent and respond to accidental nonnuclear releases to surface water, facility operations 

would be conducted in accordance with a spill prevention, control, and countermeasures plan; 

stormwater pollution prevention plan; or equivalent plans and associated BMPs and procedures. 

Based on this analysis, the NRC staff concludes that the overall impacts on surface water

resources from construction and operations under the NGCC alternative would be SMALL.

4.5.3.2 Groundwater Resources

For the NGCC alternative, the NRC staff assumed that construction water would be obtained 

from surface water or from a local water utility, as further described in Section 4.5.3.1. The 

dewatering of excavations is unlikely to consume enough water to affect groundwater supplies. 

During construction and throughout the life of this alternative, groundwater withdrawals would 

be subject to applicable State water appropriation and registration requirements. The 

application of BMPs in accordance with a State-issued NPDES general permit, including 

appropriate waste management, water discharge, stormwater pollution prevention plan, and spill 

prevention practices, would prevent or minimize groundwater quality impacts during 

construction. For this alternative, after the facility is constructed and operational, groundwater 

would not be consumed or used. During operations, the consumptive use of potable water and 

water for fire protection would be similar to the proposed action. Therefore, the impact of this 

alternative on groundwater resources would be SMALL.

4.5.4 IGCC Alternative

4.5.4.1 Surface Water Resources

Impacts from construction activities associated with the IGCC alternative on surface water

resources would be substantially greater than those under the NGCC alternative 

(Section 4.5.3.1). The potential for greater impacts is primarily attributable to the additional land 

required for construction of the power block buildings for the two IGCC units, excavation and 

construction of other onsite facilities for coal handling and storage, and coal ash and scrubber 

waste management. Otherwise, the same general assumptions for construction and operations 

described in Section 4.5.3.1 for the NGCC alternative also apply to this alternative, except as 

noted.

A new IGCC plant and associated infrastructure at the Fermi site would require about 1,000 ac 

(405 ha), necessitating the acquisition of adjacent land parcels. This would be likely to 

permanently disturb additional mapped wetland areas (NRC 2013a) on and adjoining the site, 

with attendant hydrologic impacts. In addition, temporary impacts to surface water quality may 

result from increased sediment loading and from pollutants in stormwater runoff from disturbed 

areas and from excavation and dredge-and-fill activities. There also would be the potential for 

hydrologic and water-quality impacts to occur from the extension or refurbishment of rail spurs 
Environmental Consequences and Mitigating Actions

4-27

to transport coal and other materials to, and coal ash from, the site. Regardless, as described 

in Section 4.5.3.1 for the NGCC alternative, the application of BMPs and compliance with 

State-issued SESC and NPDES permits for construction would minimize water quality impacts. 

Any dredge-and-fill activities would be conducted under a permit from the USACE and 

State-equivalent permits requiring the implementation of BMPs to minimize impacts.

Siting a new IGCC plant at the Fermi site would have the advantage of using the existing 

cooling water intake, effluent discharge, and rail infrastructure. Dredge-and-fill operations 

necessary to operate and maintain surface water intake and discharge structures would also be 

conducted under a Department of the Army permit from the USACE and MDEQ equivalent 

permits and would require the implementation of applicable BMPs to minimize associated 

impacts.

Operation of an IGCC plant would require less makeup water and would have lower 

consumptive use than that for current Fermi 2 operations. The projected surface water makeup 

requirement for cooling and other processes for an IGCC plant under this alternative is 

16.5 mgd or 11,460 gpm (25.5 cfs or 0.72 m3

/s), with consumptive use of about 13 mgd or 

9,030 gpm (20.1 cfs or 0.57 m3

/s). This alternative would consume about 32 percent less 

surface water than that for current Fermi 2 operations, which consumes an average of 

approximately 19 mgd or 13,190 gpm (29.4 cfs or 0.83 m3

/s) of lake water.

As summarized in Section 4.5.3.1 for the NGCC alternative, surface water withdrawals, effluent 

discharges, and materials handling would be subject to applicable regulatory requirements 

under this alternative. However, management of runoff and leachate from coal and ash storage 

facilities would require additional regulatory oversight and would present an additional risk to 

surface water resources, including Lake Erie.

For this alternative, based on the projected magnitude of ground disturbance and hydrologic 

alteration and the potential water quality impacts from coal and ash handling and management 

along with other operational impacts, the NRC staff concludes that the overall impacts on 

surface water resources would be SMALL to MODERATE.

4.5.4.2 Groundwater Resources

The facts considered, assumptions made, and conclusions reached in determining the impact 

significance level on groundwater resources for this alternative are the same as those for the 

NGCC alternative described in Section 4.5.3.2. Therefore, impacts of the IGCC alternative on 

groundwater resources would be SMALL.

4.5.5 New Nuclear Alternative

4.5.5.1 Surface Water Resources

Impacts from construction activities on surface water resources associated with the new nuclear 

alternative would be appreciable because of the land area required for new nuclear units 

(i.e., 301 ac (122 ha)) using available land on the Fermi site and needed adjacent land parcels. 

Deep excavation work for the nuclear island, extensive site clearing, and a large laydown area 

for facility construction would have the potential for direct and indirect impacts on water 

resources. Otherwise, the same assumptions for construction and operations as described in 

Section 4.5.3.1 for the NGCC alternative also apply to this alternative, except as noted.

Construction activities would alter surface water drainage features within the construction 

footprints, including mapped wetland areas (NRC 2013a) on and adjoining the site. As 

previously described in Section 4.5.3.1 for the NGCC alternative, water quality impacts would be 
Environmental Consequences and Mitigating Actions

4-28

minimized by the application of BMPs and compliance with State-issued SESC and NPDES

permits for construction.

In particular, use of the Fermi site would offer the advantage of use of the existing cooling water 

intake and discharge infrastructure. Some additional construction impacts may result from the 

potential need to refurbish or expand the capacity of the facilities. Nevertheless, dredge-and-fill 

operations necessary to operate and maintain surface water intake and discharge structures 

would also be conducted under a Department of the Army permit from the USACE and MDEQ 

equivalent permits and would require the implementation of applicable BMPs to minimize 

associated impacts.

Water required to support construction activities under this alternative would be greater than 

under either the NGCC or IGCC alternatives due to the larger scale of construction, magnitude 

of excavation work, and longer schedule. Extensive groundwater dewatering of deep 

excavations would be also necessary. The NRC staff assumes that water needed for facility 

construction would be taken from the Fermi 2 service water system. Alternatively, water could 

be supplied directly via a connection from the municipal water utility (Frenchtown Township) or 

trucked to the point of use. Dewatering of excavations would not be expected to affect offsite 

surface water bodies. Groundwater removed from excavations would be managed in 

accordance with MDEQ requirements.

The operation of a new 1,170 MWe ESBWR unit would require an estimated 32 mgd or 

22,200 gpm (49.5 cfs or 1.4 m3

/s) of surface water for cooling makeup and related processes. 

Consumptive water use would be approximately 16 mgd or 11,100 gpm (24.8 cfs or 0.7 m3

/s). 

This alternative would consume about 16 percent less surface water than that for current 

Fermi 2 operations, which consumes an average of approximately 19 mgd or 13,190 gpm

(29.4 cfs or 0.83 m3

/s) of lake water (Section 3.5.1.2 of this SEIS).

The NRC further expects that water treatment additives for new nuclear plant operations and 

effluent discharges would be relatively similar in quality and volume to Fermi 2. All effluent 

discharges would be subject to an MDEQ-issued NPDES individual permit for the discharge of 

wastewater and industrial stormwater to waters of the United States. Sanitary effluent would 

likely be discharged to the Monroe Metropolitan Wastewater Facility in compliance with its

influent acceptance criteria. In accordance with the Great Lakes Compact, surface water

withdrawals and consumptive use would be subject to MDEQ’s water withdrawal permitting 

program (451 MCL 324.32723). To prevent and respond to accidental nonnuclear releases to 

surface water, facility operations would also be conducted in accordance with a spill prevention, 

control, and countermeasures plan; stormwater pollution prevention plan; or equivalent plans 

and associated BMPs and procedures.

For the new nuclear alternative, the NRC staff concludes that overall impacts on surface water

use and quality from construction and operations would be SMALL.

4.5.5.2 Groundwater Resources

The facts considered, assumptions made, and conclusions reached in determining the impact 

significance level on groundwater resources from the new nuclear alternative are the same as 

that for the NGCC alternative described in Section 4.5.3.2. Therefore, impacts of the new 

nuclear alternative on groundwater resources would be SMALL.
Environmental Consequences and Mitigating Actions

4-29

4.5.6 Combination Alternative (NGCC, Wind, and Solar)

4.5.6.1 Surface Water Resources

For the NGCC component of this alternative, the impacts on surface water resources from 

facility construction and operations would be a fraction of those described in Section 4.5.5.1 

because the NGCC plant would be scaled back to a single 400-MW unit. Otherwise, the same 

general assumptions for construction and operations also apply to this alternative. Operational 

cooling water demands would be about 33 percent of those under the NGCC alternative. As a 

result, the NGCC component under this alternative would require approximately 2.5 mgd or 

1,700 gpm (3.9 cfs or 0.11 m3

/s) of surface water for cooling and other processes, with 

consumptive use totaling about 1.8 mgd or 1,250 gpm (2.8 cfs or 0.08 m3

/s). Thus, this 

alternative would consume about 90 percent less surface water than that for current Fermi 2

operations, which consumes an average of approximately 19 mgd or 13,190 gpm (29.4 cfs or

0.83 m3

/s) of lake water.

Direct impacts on surface water resources for the wind and solar portion of this alternative 

during construction are expected to be minimal because the NRC staff assumes that wind 

turbines and utility-scale PV farms would be sited in upland areas to avoid direct impacts on 

surface water features (e.g., lakes, streams, and wetlands) and associated hydrologic alteration. 

Construction of up to 1,117 land-based wind turbines on 1 to 3 ac (0.4 to 1.2 ha) sites each 

would require relatively small amounts of water for dust suppression and soil compaction during 

site clearing and for concrete production. Construction of utility-scale solar PV farms would 

require relatively larger volumes of water per site due to the larger land area required per 

megawatt of replacement power produced. However, for both components under this 

alternative, the NRC staff also assumes water would be procured from offsite sources and 

would be trucked to the point of use (such as from a local water utility) as opposed to the use of 

nearby surface water or onsite groundwater. The likely use of ready-mix concrete would also 

reduce the need for onsite use of nearby water sources for construction.

Installation of land-based wind turbines and utility-scale solar PV farms would also require 

construction of access roads and possibly transmission lines (especially for sites not already 

proximal to transmission line corridors). Access road construction would also require some 

water for dust suppression and roadbed compaction and would have the potential to result in 

soil erosion and stormwater runoff from cleared areas. For construction, water would likely be 

trucked to the point of use from offsite locations along with road construction materials. In all 

cases, it is expected that construction activities would be conducted in accordance with 

State-issued NPDES or equivalent permits for stormwater discharges associated with 

construction activity, which would require the implementation of appropriate BMPs to prevent or 

mitigate water quality impacts. In contrast to land-based wind turbine sites and utility-scale 

solar PV farms, installation of small solar PV units on rooftops and at sites that have already 

been developed would essentially have no impact on surface water resources.

To support the operation of wind turbine and PV installations, there would be no direct use of 

surface water, and no industrial wastewater effluents would be produced. It is expected that 

water would be obtained from groundwater or purchased from a local water utility. Regardless, 

only very small amounts of water would be needed to periodically clean turbine blades and 

motors; water could be trucked to the point of use as part of routine servicing. Water also would 

be required to clean panels at solar PV farms or those situated in rooftop arrays. Adherence to 

appropriate waste management and minimization plans, spill prevention practices, and pollution 

prevention plans during servicing of wind turbine and solar PV installations and operation of 

vehicles connected with site operations would minimize the risks to soils and surface water 

resources from spills of petroleum, oil, and lubricant products and stormwater runoff.
Environmental Consequences and Mitigating Actions

4-30

In consideration of these facts, the NRC staff concludes that the impacts on surface water

resources from construction and operations under the combination alternative would be SMALL.

4.5.6.2 Groundwater Resources

Construction dewatering would be minimal because of the small footprint of foundation 

structures, pad sites, and piling emplacements. Little or no impacts on groundwater use or 

water quality would be expected from routine operations. Consequently, the impacts on 

groundwater use and quality under this alternative would be SMALL.

4.6 Terrestrial Resources

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on terrestrial resources.

4.6.1 Proposed Action

Section 3.6 of this SEIS describes terrestrial resources on and in the vicinity of the Fermi site. 

The generic (Category 1) and site-specific (Category 2) issues that apply to terrestrial resources 

during the proposed license renewal period appear in Table 4–6. The GEIS discusses these 

issues in Section 4.6.1.1 (NRC 2013d).

Terrestrial Resource Issues

Issue GEIS Section Category

Effects on terrestrial resources (noncooling system impacts) 4.6.1.1 2

Exposure of terrestrial organisms to radionuclides 4.6.1.1 1

Cooling system impacts on terrestrial resources (plants with 

once-through cooling systems or cooling ponds)

4.6.1.1 N/A(a)

Cooling tower impacts on vegetation (plants with cooling towers) 4.6.1.1 1

Bird collisions with plant structures and transmission lines(b) 4.6.1.1 1

Water use conflicts with terrestrial resources (plants with cooling ponds 

or cooling towers using makeup water from a river)

4.6.1.1 N/A(c)

Transmission line right-of-way (ROW) management impacts on 

terrestrial resources(b)

4.6.1.1 1

Electromagnetic fields on flora and fauna (plants, agricultural crops, 

honeybees, wildlife, livestock)(b)

4.6.1.1 1

(a) This issue does not apply because the Fermi 2 cooling system is a closed-cycle system and does not include a 

cooling pond.

(b) This issue applies only to the in-scope portion of electric power transmission lines, which are defined as 

transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional 

power distribution system and transmission lines that supply power to the nuclear plant from the grid.

(c) This issue does not apply because Fermi 2 draws water from Lake Erie, not from a river.

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

4.6.1.1 Generic Terrestrial Resource Issues

The NRC staff did not identify any new and significant information related to the generic 

(Category 1) issues listed above during the review of the applicant’s ER (DTE 2014a), the site 
Environmental Consequences and Mitigating Actions

4-31

audit, or the scoping process. Specifically regarding the Category 1 issue, “bird collisions with 

plant structures and transmission lines,” the NRC staff concludes, based on a review of bird 

collision records and bird strike surveillance data for Fermi 2, that DTE’s bird strike information 

does not constitute new and significant information that would change the GEIS’s conclusion of 

SMALL for this issue (Section 4.14).

The NRC expects no impacts associated with the Category 1 terrestrial issues identified above 

in Table 4–6 beyond those discussed in the GEIS. The GEIS concludes that the impact level for 

each of these issues is SMALL.

4.6.1.2 Effects on Terrestrial Resources (Noncooling System Impacts)

In the GEIS (NRC 2013d), the NRC staff determined that “noncooling system effects on

terrestrial resources” is a Category 2 issue (Table 4–6) that requires site-specific evaluation 

during each license renewal review. According to the GEIS, noncooling system impacts can 

include those impacts that result from landscape maintenance activities, stormwater 

management, elevated noise levels, and other ongoing operations and maintenance activities 

that would occur during the renewal period and that could affect terrestrial resources on and 

near a plant site.

Landscape Maintenance Activities 

Section 3.2 indicates that approximately 1,048 ac (424 ha) of the Fermi site (83.1 percent) 

remains as natural areas that are managed by the FWS as part of the DRIWR, leased for 

agricultural use, or are not managed (DTE 2014a). The majority of site landscape maintenance 

is performed within the developed area and not within natural areas on the site (DTE 2014a). 

Typically, only trees and shrubs that pose a safety or security threat would be removed from 

natural areas. Leased agricultural lands would be maintained by the leasee and in accordance 

with the standing lease. DTE (2014c) has no plans to disturb undeveloped areas of the site as 

part of the proposed Fermi 2 license renewal. Several ongoing restoration projects would result 

in positive impacts to terrestrial resources during the license renewal term. These projects are 

discussed in Section 3.6 and include two prairie restoration projects and the continued 

maintenance of the site’s delineated wetlands and the DRIWR Lagoona Beach Unit.

Stormwater Management

Stormwater drainages direct Fermi site runoff to six NPDES-permitted stormwater outfalls. The 

outfalls flow into the quarry lakes (Outfalls 004, 005, and 007), the North Canal (Outfalls 002 

and 014), and the South Lagoon (Outfall 012) (DTE 2014a). Two additional outfalls (003 

and 008) are unused (DTE 2014a). Section A.13 of Part I of the Fermi 2 NPDES permit 

requires DTE (2014a) to maintain and implement a Stormwater Pollution Prevention Plan. This 

plan identifies potential sources of pollution that could affect the quality of stormwater and 

describes practices that DTE uses to reduce such pollutants. Areas with spill potential, such as 

areas around tanks that contain oil, are further monitored under site chemical control 

procedures and spill prevention plans (DTE 2014a). Additionally, any ground disturbances of 

1 ac (0.4 ha) or more or within 500 ft (152 m) of a lake or stream requires DTE (2014a) to obtain 

an SESC permit from the Monroe County drain commissioner. SESC permits specify BMPs to 

reduce erosion caused by stormwater runoff. Collectively, these measures ensure that the 

effects to terrestrial resources from pollutants carried by stormwater would be minimized during 

the proposed license renewal term.

Noise

The GEIS (NRC 2013d) indicates that elevated noise levels could be a noncooling system 

impact to terrestrial resources. However, the GEIS also concludes that generic noise impacts 
Environmental Consequences and Mitigating Actions

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would be small because noise levels would remain well below regulatory guidelines for offsite 

receptors during continued operations and refurbishment associated with license renewal. The 

NRC staff did not identify any information during its review that would indicate that noise 

impacts to terrestrial resources at Fermi 2 would be unique or would require separate analysis.

Other Operations and Maintenance Activities

DTE (2014a) anticipates no refurbishment or other operations or maintenance activities during 

the license renewal term that would disturb terrestrial habitats or that would result in changes to 

existing land uses.

DTE (2014c) would continue to maintain its Wildlife Management Plan and Wildlife Habitat 

Council certification during the proposed license renewal term. DTE (2014c) would also 

continue biannual qualitative prairie vegetation surveys, which would be performed by a botanist 

from the FWS or the Michigan Natural Features Inventory. The Fermi 2 Wildlife Habitat Team 

would also conduct periodic wildlife surveys of site-specific areas several times per year to 

monitor the site’s animal communities and to document the occurrence of any new species.

When new activities that could impact the environment occur at Fermi 2, DTE follows several 

procedures to ensure that it considers potential environmental effects and appropriately 

addresses them. DTE (2014c) maintains an Environmental Monitoring Conduct Manual 

(MCE06), which requires DTE staff to screen proposed activities, such as maintenance 

activities, operational changes, procedure changes, and other facility activities, to determine 

whether the activity warrants further evaluation for environmental impact or risk. If work is to be 

performed in undeveloped areas of the site, a Protected Species Protection Plan must be 

developed (DTE 2014c), and personnel must be briefed on the plan before beginning work. 

Nuclear Licensing Work Instruction 11801, “Unusual or Important Environmental Events 

Reporting Guidance,” provides guidance on reporting unusual or important environmental 

events casually related to plant operation as required by Appendix B to the Fermi 2 operating 

license (DTE 2014c). Additionally, DTE (2014c) corporate personnel continually monitor 

changes to Federal and State requirements and modify applicable company and site-specific 

procedures as necessary.

Conclusion

Based on its independent review, the NRC staff concludes that the landscape maintenance 

activities, stormwater management, elevated noise levels, and other ongoing operations and 

maintenance activities that DTE might undertake during the renewal term would primarily be 

confined to disturbed areas of the Fermi site. These activities would not have noticeable effects 

on terrestrial resources, nor would they destabilize any important attribute of the terrestrial 

resources on or in the vicinity of the Fermi site. Therefore, the NRC staff expects noncooling 

system impacts on terrestrial resources during the license renewal term to be SMALL.

4.6.2 No-Action Alternative

If Fermi 2 were to shut down, the impacts to terrestrial ecology would remain similar to those 

during operations until the plant is fully decommissioned. Temporary buildings and staging or 

laydown areas may be required during large component and structure dismantling. Fermi 2 is 

likely to have sufficient space within previously disturbed areas for these needs; therefore, no 

additional land disturbances would occur on previously undisturbed land. Adjacent lands may 

experience temporary increases in erosional runoff, dust, or noise, but these impacts could be 

minimized with the implementation of standard BMPs (NRC 2002b). In NUREG–0586, the 

NRC (2002b) concludes generically that impacts to terrestrial ecology during decommissioning

activities would be SMALL. In the case of Fermi 2, decommissioning could affect its
Environmental Consequences and Mitigating Actions

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cooperative agreement with the FWS for management of the DRIWR or other sensitive habitats 

on the Fermi site, depending on whether DTE retains or transfers responsibility or ownership of 

the site following decommissioning. However, reclamation of the site following 

decommissioning could create terrestrial habitat in areas currently used as industrial areas. The 

GEIS (NRC 2013d) notes that terrestrial resource impacts could occur in other areas beyond 

the immediate nuclear plant site as a result of the no-action alternative if new power plants are 

needed to replace lost capacity. The NRC staff concludes that the no-action alternative would

unlikely noticeably alter or have more than minor effects on terrestrial resources. Thus, the 

NRC staff concludes that the impacts of the no-action alternative on terrestrial resources during 

the proposed license renewal term would be SMALL.

4.6.3 NGCC Alternative

This alternative assumes that a new NGCC facility would be built at the Fermi site outside the 

existing Fermi 2 and proposed Fermi 3 footprints. The facility would require an estimated 24 ac 

(9.7 ha) of land for the plant with the possibility of additional land requirements for gas pipeline 

ROWs. Additional offsite land would be required for gas extraction and collection, although this 

impact would be partially offset by the elimination of land used for uranium mining to supply fuel 

to Fermi 2.

During construction, the use of the existing site would maximize availability of existing 

infrastructure. However, construction would likely require the conversion of natural areas 

because the new facility would be built outside the existing industrial footprint. This could result 

in noticeable impacts to terrestrial habitats and species, although the level of direct impact 

would vary based on the specific location of new buildings and infrastructure on the site. During 

construction, terrestrial species could experience habitat loss or fragmentation, loss of food 

resources, and altered behavior due to noise and other construction-related disturbances. 

Erosion and sedimentation from clearing, leveling, and excavating land could affect adjacent 

riparian and wetland habitats, if present. Implementation of appropriate BMPs would minimize 

these effects. This alternative could also require construction of new pipelines or upgrades to 

existing lines. Collocating lines within existing corridors would minimize land disturbance. 

Although construction activities could noticeably alter terrestrial resources, primarily through 

habitat loss or fragmentation, construction is unlikely to destabilize any important attributes of 

the terrestrial environment due to the small footprint of the facility. The exact magnitude of 

impacts would vary based on the chosen location of the facility within the Fermi site footprint 

and on the amount and types of undisturbed habitat that would be disturbed for construction of 

the alternative; therefore, impacts of construction could range from SMALL to MODERATE.

The GEIS (NRC 2013d) concludes that impacts to terrestrial resources from operation of fossil 

energy alternatives would essentially be similar to those from continued operations of a nuclear 

facility. Unique impacts would include air emissions of GHGs, such as nitrogen oxides, carbon 

dioxide, and methane, all of which can have far-reaching consequences because they 

contribute to climate change. The effects of climate change on terrestrial resources are 

discussed in Section 4.15.3.2. Although the impacts of operating the NGCC alternative may be 

noticeable, they are unlikely to destabilize any important attribute of the terrestrial environment 

and, therefore, would be SMALL.

The NRC concludes that the impacts of the NGCC alternative on terrestrial resources would be 

SMALL to MODERATE during construction and SMALL during operation.
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4.6.4 IGCC Alternative

Like the NGCC alternative, this alternative assumes that a new facility would be built at the 

Fermi site outside the existing Fermi 2 and proposed Fermi 3 footprints. However, an IGCC 

facility would require significantly more land (an estimated 1,000 ac (405 ha)) than that for the 

NGCC alternative, which would only require 24 ac (9.7 ha). The larger footprint of the IGCC 

facility would require DTE to obtain additional parcels of land adjacent to the existing site. 

Additional offsite land would be required for coal mining, although this impact would be partially 

offset by the elimination of land used for uranium mining to supply fuel to Fermi 2.

During construction, impacts to terrestrial habitats and species are likely to be similar to the 

types of impacts described for the NGCC alternative in Section 4.6.3 but would likely be larger 

in magnitude due to the larger footprint of the IGCC facility. The purchase of additional parcels 

of land could affect sensitive habitats, including wetlands and riparian areas. Accordingly, 

construction would likely noticeably alter terrestrial resources and could destabilize important 

attributes of the terrestrial environment. The exact magnitude of impacts would vary based on 

the chosen location of the facility within the Fermi site footprint, the purchased land parcels, and 

the amount and types of undisturbed habitat that would be disturbed for construction of the 

alternative. Thus, impacts of construction could range from MODERATE to LARGE.

The GEIS (NRC 2013d) concludes that impacts to terrestrial resources from operation of fossil 

energy alternatives would essentially be similar to those from continued operations of a nuclear 

facility. Unique impacts would include periodic maintenance dredging if coal is delivered by 

barge, which could create noise, dust, and sedimentation. Dredging and delivery of coal to the 

site could introduce minerals and trace elements to water resources on which terrestrial biota

rely. Such minerals could also bioaccumulate in nearby riparian or wetland habitats. Air 

emissions during operation would include sulfur oxides and nitrogen oxides, which can combine 

with water vapor and create sulfuric and nitric acids. These acids would then be released back 

into the environment through precipitation, which could affect the acidity levels of water 

resources and could have detrimental effects to plant foliage. Acid precipitation has the 

potential to destabilize the terrestrial environment by creating conditions that are too acidic for 

certain plants or animals. The IGCC facility would also emit various GHGs during operation, 

which is an effect that can have far-reaching consequences because GHGs contribute to 

climate change. The effects of climate change on terrestrial resources are discussed in 

Section 4.15.3.2. The various air emissions during operation of the IGCC facility could create 

noticeable impacts that could destabilize certain attributes of the terrestrial environment;

therefore, the operational impacts would be MODERATE.

The NRC concludes that the impacts of the IGCC alternative on terrestrial resources would be 

MODERATE to LARGE during construction and would be MODERATE during operation.

4.6.5 New Nuclear Alternative

Like the NGCC and IGCC alternatives, this alternative assumes that a new nuclear facility would 

be built at the Fermi site outside the existing Fermi 2 and proposed Fermi 3 footprints. The 

facility would require an estimated 301 ac (122 ha) of land. Although the land requirement for 

this alternative is not as large as that for the IGCC facility, the new nuclear alternative would still 

require DTE to obtain additional parcels of land adjacent to the existing site. Additional offsite 

land would be required for uranium mining, although this impact would result in no net change in 

land use impacts from those that would be associated with the proposed license renewal of 

Fermi 2.
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During construction, impacts to terrestrial habitats and species are likely to be similar to the 

types of impacts described for the NGCC alternative in Section 4.6.3, but these impacts would 

likely be larger in magnitude due to the larger footprint of the new nuclear facility. The purchase 

of additional parcels of land could affect sensitive habitats, including adjacent wetlands and 

riparian areas. Although the NRC (2013a) has previously determined that construction of a new 

nuclear plant on the Fermi site (the proposed Fermi 3) would result in SMALL to MODERATE 

impacts to terrestrial resources (with the potential for MODERATE impacts limited to the eastern 

fox snake) (NRC 2013a), the new nuclear alternative considered here represents an additional 

disturbance to the Fermi site because the footprints of the proposed Fermi 3 and this new 

nuclear alternative are assumed not to overlap. The conversion of sensitive natural areas, such 

as DRIWR wetlands, for industrial use would noticeably affect terrestrial habitats and species

and has the potential to destabilize important attributes of the terrestrial environment. 

Accordingly, the NRC staff concludes that construction impacts would be MODERATE to 

LARGE depending on the specific parcels of land converted to industrial use or disturbed during 

construction.

During operation, impacts would be similar in type and magnitude to those assessed in 

Section 4.6.1 for continued operation of Fermi 2 under the proposed renewal term and, 

therefore, would be SMALL.

The NRC concludes that the impacts of the new nuclear alternative on terrestrial resources 

would be MODERATE to LARGE during construction and would be SMALL during operation.

4.6.6 Combination Alternative (NGCC, Wind, and Solar)

The NGCC component of this alternative would have the same land requirements as discussed 

for the NGCC alternative in Section 4.2.3.1. Accordingly, the impacts to terrestrial resources 

would be similar to those concluded for the NGCC alternative and, therefore, would be SMALL 

to MODERATE during construction and would be SMALL during operation.

The wind component of this alternative would require an estimated 1,117 to 3,351 ac (452 to 

1,356 ha) of land at onshore wind farm sites across the ROI. However, the majority of this land 

would only be temporarily disturbed during construction. Permanently disturbed land would hold 

the wind turbines, access roads, and transmission lines. Land used for equipment laydown and 

turbine component assembly and erection could be returned to its original state. Use of BMPs 

would ensure that disturbed lands were appropriately restored to reduce long-term impacts to 

the terrestrial environment. Operation of wind turbines could uniquely affect terrestrial species 

through mechanical noise, collision with turbines and meteorological towers, and interference 

with migratory behavior. Bat and bird mortality from turbine collisions is an ongoing concern for 

operating wind farms; however, recent developments in turbine design have reduced the 

potential for bird and bat strikes. The NRC staff expects that this component has the potential 

to noticeably alter terrestrial resources, primarily through the loss of habitat and bird and bat 

mortalities associated with wind turbine operation. However, it is unlikely that the wind 

component would destabilize any important attribute of the terrestrial environment; therefore, 

impacts would be MODERATE.

The solar component of this alternative would require an estimated 3,577 ac (1,448 ha) of land 

across the ROI. The majority of solar installations could be installed on building roofs at existing 

residential, commercial, or industrial sites or at larger standalone solar facilities; therefore, it is 

possible that little terrestrial habitat would be disturbed during construction. However, the exact 

magnitude of impacts on terrestrial resources would depend on the amount of terrestrial habitat 

that is lost or fragmented during construction of solar installations. Operation would have no 

measurable effects on the terrestrial environment. Overall impacts from construction and 
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operation of this component of the alternative would range from SMALL to MODERATE 

depending on the locations of solar installations and the amount of terrestrial habitat affected.

Overall, the NRC staff concludes that the impacts of the combination alternative on terrestrial 

resources would be SMALL to MODERATE.

4.7 Aquatic Resources

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on aquatic resources. 

4.7.1 Proposed Action

Section 3.1.3 of this SEIS describes the Fermi 2 cooling and auxiliary water systems, and 

Section 3.7 describes the aquatic resources. The generic (Category 1) and site specific 

(Category 2) issues that apply to aquatic resources at Fermi 2 during the proposed license 

renewal period appear in Table 4–7. The GEIS (NRC 2013d) discusses these issues in 

Section 4.6.1.2.

Aquatic Resource Issues

Issue GEIS Section Category

All plants

Entrainment of phytoplankton and zooplankton 4.6.1.2 1

Infrequently reported thermal impacts 4.6.1.2 1

Effects of cooling water discharge on dissolved oxygen, gas 

supersaturation, and eutrophication

4.6.1.2 1

Effects of nonradiological contaminants on aquatic organisms 4.6.1.2 1

Exposure of aquatic organisms to radionuclides 4.6.1.2 1

Effects of dredging on aquatic organisms 4.6.1.2 1

Effects on aquatic resources (noncooling system impacts) 4.6.1.2 1

Impacts of transmission line ROW management on aquatic resources(a) 4.6.1.2 1

Losses from predation, parasitism, and disease among organisms 

exposed to sublethal stresses

4.6.1.2 1

Plants with cooling towers

Impingement and entrainment of aquatic organisms 4.6.1.2 1

Thermal impacts on aquatic organisms 4.6.1.2 1

(a) This issue applies only to the portion of electric power transmission lines that connect a nuclear power plant to the 

substation where electricity is fed into the regional power distribution system and transmission lines that supply 

power to the nuclear plant from the grid.

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

4.7.1.1 Generic GEIS Issues

The GEIS (NRC 2013d) concludes that the 11 Category 1 issues listed in Table 4–7 would have 

a SMALL impact on aquatic resources during the license renewal term for all plants. For these 
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issues, no additional plant-specific analysis is required unless new and significant information is 

identified.

During its review, the NRC staff considered DTE’s aquatic surveys and studies performed at 

Fermi and in Lake Erie and available scientific literature; attended a site audit; and considered 

Federal and State agency and public comments received during the scoping process. The NRC 

staff identified new information related to harmful algal blooms, which are discussed in the GEIS

under the issue, “Infrequently Reported Thermal Impacts.” The new information related to algal 

blooms is discussed in Section 4.14. Based on its review, the NRC staff concludes that this 

information does not constitute new and significant information that would change the GEIS’s 

conclusion of SMALL for this issue (Section 4.14). For the other generic issues, the NRC staff 

identified no new and significant information; therefore, no site-specific analysis is required for 

these issues, and no impacts would be associated with these issues beyond those discussed in 

the GEIS.

4.7.2 No-Action Alternative

If Fermi 2 were to cease operating, impacts to aquatic ecology would decrease or stop following 

reactor shutdown. Some withdrawal of water from Lake Erie would continue during the 

shutdown period as the fuel is cooled, although the amount of water withdrawn would decrease 

over time. The reduced demand for cooling water would further decrease the effects of 

impingement, entrainment, and thermal effluents that were determined to be SMALL for Fermi 2

during the proposed license renewal term (Section 4.7.1.1).

In NUREG–0586, NRC (2002) concludes generically that impacts to aquatic ecology during 

decommissioning activities would be SMALL for facilities at which the decommissioning 

activities would be limited to existing operational areas. In the case of Fermi 2, the NRC staff 

did not identify any effects that would have more than minor effects on aquatic resources. Thus, 

the NRC staff concludes that the impacts of the no-action alternative on aquatic resources 

during the proposed license renewal term would be classified as SMALL and would be less than 

any current effects.

4.7.3 NGCC Alternative

Construction of an NGCC alternative (three 400-MW units) would occur at the Fermi site outside 

the Fermi 2 and proposed Fermi 3 footprints. The GEIS (NRC 2013d) indicates that the impacts 

of new power plant construction on ecological resources would be qualitatively similar to the 

new nuclear alternative. Thus, those impacts discussed under the new nuclear alternative 

would apply during the construction phase. Construction of new natural gas pipelines, if 

necessary, could impact previously undisturbed habitats. This impact would vary depending on 

the location of the plant and would be more likely to impact terrestrial resources than aquatic 

resources, and the NGCC alternative may occupy (and disturb) less land than the new nuclear 

or IGCC alternatives. Because the NGCC alternative would be built on the existing power plant 

site, new pipelines could be located in existing corridors to reduce impacts. Overall, 

construction impacts would be SMALL.

Operation of the NGCC alternative cooling system would be qualitatively similar to the IGCC 

alternative but would result in smaller impacts because the NGCC alternative would consume 

less cooling water. Air emissions from the NGCC units would include nitrogen oxide, carbon 

dioxide, and particulates that would settle on water bodies or that would be introduced into the 

water from soil erosion. The plant would have closed-cycle cooling with mechanical-draft 

cooling towers; therefore, the effects of entrainment and the thermal effluent would be similar to 

those of Fermi 2. The new plant would probably have a traveling screen with a fish return 
Environmental Consequences and Mitigating Actions

4-38

system on the cooling water intake structure (which Fermi 2 lacks), thus resulting in less 

impingement mortality than that for Fermi 2. Overall operational impacts would be less for the 

NGCC alternative than those for the continued operation of Fermi 2, and the level of impact 

would be SMALL.

The NRC staff concludes that the impacts to aquatic resources from construction of an NGCC 

plant would be SMALL, the impacts of operation would be SMALL, and the fish impingement

mortality would be less than that for Fermi 2 today.

4.7.4 IGCC Alternative

Construction of an IGCC alternative would occur at the Fermi site outside of the Fermi 2 and 

proposed Fermi 3 footprints. The GEIS (NRC 2013d) indicates that the impacts of new power 

plant construction on ecological resources would be qualitatively similar to those of a new 

nuclear alternative. Those impacts discussed under the new nuclear alternative would apply 

during the construction phase. Because the IGCC alternative would require significantly more 

land than that for the new nuclear alternative (1,000 ac (400 ha) versus 301 ac (122 ha)), the 

magnitude of impacts would likely be greater and could create noticeable effects on aquatic 

resources. Thus, construction impacts would be MODERATE.

Operation of the IGCC alternative would require less cooling water than Fermi 2. Accordingly, 

impingement, entrainment, and thermal effects on aquatic resources would likely be smaller 

than those for continued operation of Fermi 2. Chemical discharges from the cooling system 

would be similar to those at Fermi 2. Operation would require coal deliveries, cleaning, and 

storage, which would require periodic dredging (if coal is delivered by barge); create dust, 

sedimentation, and turbidity; and introduce trace elements and minerals into the water. Air 

emissions from the IGCC units would include small amounts of sulfur dioxide, particulates, and 

mercury that would settle on water bodies or be introduced into the water from soil erosion. 

Overall operational impacts would be similar to the continued operation of Fermi 2. The plant 

would have closed-cycle cooling with mechanical-draft cooling towers; therefore, the effects of 

entrainment and the thermal effluent would be similar to those of Fermi 2. The new plant would 

probably have a traveling screen with a fish return system on the cooling water intake structure 

(which Fermi 2 lacks), thus resulting in less impingement mortality than that for Fermi 2. Based 

on the above information, impact levels from operation would likely be SMALL.

The NRC staff concludes that the level of impacts to aquatic resources from construction of an 

IGCC plant would be MODERATE, the impacts of operation would be SMALL, and the fish 

impingement mortality would be less than that for Fermi 2 today.

4.7.5 New Nuclear Alternative

Construction of a new nuclear alternative would occur at the existing Fermi site, although not on 

the footprints of the existing Fermi 2 or proposed Fermi 3 units. Construction activities could 

degrade the water quality of Lake Erie near the site and of nearby streams or ponds through 

erosion and sedimentation, could result in loss of habitat through pond or wetland filling, or 

could result in direct mortality of aquatic organisms from dredging or other in-water work. 

Because of the short-term nature of construction activities, these effects would likely be 

relatively localized and temporary. Constructing a new nuclear plant on the existing site could 

make use of the existing transmission lines, roads, parking areas, and other infrastructure, 

which would limit the amount of habitat disturbance that would be required. Less habitat 

disturbance would create less erosion and sedimentation. The construction of intake and 

discharge structures could result in direct mortality of individuals and in water quality 

degradation. Appropriate permits would ensure that water quality impacts would be addressed 
Environmental Consequences and Mitigating Actions

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through mitigation or BMPs, as stipulated in the permits. The EPA, USACE, or the State of 

Michigan would oversee applicable permitting, including a Section 404 permit under the Clean 

Water Act of 1977, as amended (CWA) (33 U.S.C. 1251 et seq.); Section 401 certification under 

the CWA; and a Section 402(p) NPDES general stormwater permit. The NRC staff (2013a) has 

completed the review of one combined license (COL) application to build and operate a new 

nuclear plant on the Fermi site (Fermi 3) and found that construction would have SMALL 

impacts on aquatic resources. Although the NRC staff assumes a new nuclear alternative 

would not occupy the same footprint as the proposed Fermi 3 unit, it would be on the same 

Fermi site and would use closed-cycle cooling and the same cooling lake and Lake Erie 

discharge structure as the Fermi 2 and proposed Fermi 3 units would so that aquatic impacts 

would be similar to those that the NRC staff expects for the proposed Fermi 3. The NRC finds it 

reasonable to adopt its previous impact conclusions regarding Fermi 3 for the construction 

portion of this alternative.

Operational impacts would include those listed in Table 4–7, and the GEIS (NRC 2013d) 

conclusions of SMALL for Category 1 issues in the table would apply during the operational 

phase of the new nuclear alternative. The NRC staff assumes that the new plant would use 

closed-cycle cooling; therefore, the effects of entrainment and the thermal effluent would be 

similar to those of Fermi 2. The new plant would likely have a traveling screen with a fish return 

system on the cooling water intake structure (which Fermi 2 lacks), thus resulting in less 

impingement mortality than that for Fermi 2. 

The NRC staff concludes that the impacts to aquatic resources from construction and operation 

of a new nuclear alternative would be classified as SMALL and that the fish impingement

mortality would be less than that for Fermi 2 today.

4.7.6 Combination Alternative (NGCC, Wind, and Solar)

The NGCC portion of this alternative could be located at the Fermi site outside the Fermi 2 and 

proposed Fermi 3 footprints. Construction and operation impacts would be qualitatively similar 

to those discussed for the NGCC alternative, but these impacts would be much lower in 

magnitude due to the smaller footprint of the plant, reduced cooling water consumption, and 

lowered air emissions. The wind and solar portions of the alternative, which account for 

75 percent of the alternative’s power generation, would not require cooling or consumptive 

water use during operation and, therefore, may only have a negligible effect on aquatic 

resources. The NRC staff concludes that the impacts on aquatic resources from the 

combination alternative would be SMALL.

4.8 Special Status Species and Habitats

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on special status species and habitats.

4.8.1 Proposed Action

Section 3.8 of this SEIS describes the special status species and habitats that have the 

potential to be affected by the proposed action. The discussion of species and habitats 

protected under the Endangered Species Act of 1973, as amended (ESA)

(16 U.S.C.1531 et seq.), includes a description of the action area as defined by the ESA 

section 7 regulations at 50 CFR 402.02. The action area encompasses all areas that would be 

directly or indirectly affected by the proposed Fermi 2 license renewal.
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Table 4–8 lists the one Category 2 issue related to special status species and habitats identified 

in the GEIS (NRC 2013d). Appendix C.1 contains information on the NRC staff’s ESA section 7 

consultation with the FWS for the proposed action. The NRC did not consult with the National 

Marine Fisheries Service (NMFS) as part of the Fermi 2 license renewal review because (as 

described in Section 3.8) no species or habitats under the NMFS’s jurisdiction occur within the 

action area.

Special Status Species and Habitat Issues

Issue GEIS Section Category

Threatened, endangered, and protected species; critical habitat; and 

essential fish habitat

4.6.1.3 2

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

4.8.1.1 Species and Habitats Protected under the Endangered Species Act of 1973

Species and Habitats under the U.S. Fish and Wildlife Service’s Jurisdiction

Section 3.8 considers whether the 10 Federally listed species identified in Table 4–9 occur in 

the action area based on each species’ habitat requirements, life history, and other available 

information. In that section, the NRC staff concludes that five of these species—eastern 

massasauga (Sistrurus catenatus), Karner blue butterfly (Lycaeides melissa samuelis), northern 

riffleshell (Epioblasma torulosa rangiana), snuffbox mussel (Epioblasma triquetra), and rayed 

bean (Villosa fabalis)—are not likely to occur in the action area. The NRC staff also concludes 

that no candidate species or proposed or designated critical habitat occurs in the action area. 

During consultation with the FWS for the proposed construction and operation of Fermi 3, which 

is a proposed new nuclear unit that would be built on the Fermi site, the FWS (2012) concurred 

with the NRC staff’s determination that the proposed construction and operation would have no 

effect on the Karner blue butterfly, northern riffleshell, snuffbox mussel, and rayed bean. The 

types and intensity of potential effects from the proposed license renewal of Fermi 2 would likely 

be bounded by the potential effects from the proposed construction and operation of Fermi 3 

because the activities associated with Fermi 3 would include construction and operation, 

whereas the activities associated with the proposed license renewal for Fermi 2 would be limited 

to continued operations. Thus, the NRC staff concludes that the proposed license renewal for 

Fermi 2 would have “no effect” on these four Federally listed species, any proposed or 

candidate species, or proposed or designated critical habitats under the FWS’s jurisdiction. In 

comments on the draft SEIS (DSEIS), FWS (2015) stated that it concurred with the NRC’s 

determination that the proposed action would have “no effect” on the Karner blue butterfly, 

northern riffleshell, snuffbox mussel, and rayed bean mussel. FWS (2015) also notes that its 

concurrence on NRCs “no effect” determination is not required. The eastern massasauga was 

proposed for listing just prior to the publication of the DSEIS in September 2015. Since 

publishing the DSEIS, the NRC staff determined that the proposed license renewal for Fermi 2 

would have “no effect” on the eastern massasauga because it is not likely to occur within the 

action area (see Section 3.8). 

In the following sections, the NRC staff analyzes the potential impacts on the other five listed 

species: (1) red knot (Calidris canutus), (2) piping plover (Charadrius melodus), (3) northern 

long-eared bat (Myotis septentrionalis), (4) Indiana bat (Myotis sodalis), and (5) eastern prairie 

fringed orchid (Platanthera leucophaea). The NRC staff determined that the proposed action 

“may affect, but is not likely to adversely affect” these five species. In comments on the DSEIS, 

FWS (2015) concurred with the NRC’s determination that the proposed action “may affect, but is 
Environmental Consequences and Mitigating Actions

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not likely to adversely affect” these five species. See Appendix C for a summary of NRC’s 

section 7 Consultation with FWS for the proposed license renewal. 

Effect Determinations for Federally Listed Species

Species Common Name

Federal 

Status Effect Determination

Birds

Calidris canutus rufa red knot T may affect, but is not likely to 

adversely affect

Charadrius melodus piping plover E may affect, but is not likely to 

adversely affect

Mammals

Myotis septentrionalis northern long-eared bat T may affect, but is not likely to 

adversely affect

Myotis sodalis Indiana bat E may affect, but is not likely to 

adversely affect

Reptile

Sistrurus catenatus eastern massasauga PT no effect

Insects

Lycaeides melissa samuelis Karner blue butterfly E no effect

Plants

Platanthera leucophaea Eastern prairie fringed 

orchid

T may affect, but is not likely to 

adversely affect

Mussels

Epioblasma torulosa rangiana northern riffleshell E no effect

Epioblasma triquetra snuffbox mussel E no effect

Villosa fabalis rayed bean E no effect

Key: E = endangered, P = proposed, and T = threatened.

Sources: 80 FR 17973, 80 FR 58688; FWS 2014a, 2014b, 2014c

Red Knot (Calidris canutus rufa)

• Within the action area, the red knot is most likely to use a shoreline habitat near Lake 

Erie. This habitat may provide suitable or marginal resting or foraging habitat for the 

red knot (Kogge 2014; DTE 2014c). However, shoreline habitat on the Fermi site is 

not likely to provide preferred foraging habitat for the red knot (Kogge 2014). 

One potential impact of the proposed license renewal is the direct mortality of individuals from 

collision with the cooling tower, other plant structures, or in-scope transmission lines. Although 

the NRC (2013d) generically determined this impact to be SMALL for birds at all nuclear plants 

during the license renewal term, this impact could uniquely affect the red knot because of its 

status as Federally threatened.

The NRC staff reviewed the licensee’s bird collision records for the past 10 years (2005 to 2014) 

and bird strike surveillance data from 2008 and 2009. These records are summarized in 
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Section 3.6.6. Aside from two larger bird collision events (50 birds in 1973 and 45 birds in 

October 2007), DTE has relatively few records of bird collisions with plant structures or 

transmission lines. None of DTE’s records include the red knot (DTE 2014c). Additionally, DTE 

has implemented some measures at Fermi 2 that were determined to reduce bird collision 

hazards during consultations between DTE, the FWS, and the Federal Aviation Administration 

for the proposed Fermi 3. These measures include flashing strobe lights on the top of the 

cooling towers (DTE 2014c). DTE (2014c) is also in the process of developing a company-wide 

program to reduce operational risks resulting from avian collisions. The program is based on an 

avian protection plan from the Avian Powerline Interaction Committee and on conversations with 

FWS personnel at the Lansing, Michigan, office (DTE 2014c). The program will address 

changes that are needed to prevent avian fatalities and will require documentation of bird strikes 

to help DTE determine whether reporting to local, State, or Federal agencies is required 

(DTE 2014c). DTE (2014c) expects to begin implementation of the program in early 2015.

Based on the available information on bird mortality, the NRC staff finds that it is possible, 

although unlikely, that red knot individuals could experience injury or mortality resulting from 

collisions with plant structures during the proposed license renewal term. If a red knot were to 

collide with plant structures or transmission lines during the proposed license renewal term, 

such a collision could result in a “take,” as defined by the ESA. The NRC staff believes that the 

likelihood of this happening is extremely unlikely to occur because the red knot is relatively rare

in the action area, the last red knot observed at the Fermi site was in 1973, the red knot is only 

in the action area for a short period of time each year, and the red knot is not likely to inhabit the 

inland developed portions of the site that contain collision hazards (NUS 1974; Niles et al. 2008; 

DTE 2014c, 2015a). However, because this species was recently listed in December 2014 

(79 FR 73705), the ESA has not afforded this species protection for the majority of the operation 

of Fermi 2. Accordingly, until now, the ESA has not necessitated the NRC and DTE consult with 

the FWS in the event that an individual was found injured or dead as a result of collision with 

Fermi 2 plant structures. Although the NRC has no records indicating that such an event 

happened, the NRC staff cannot rely on the absence of records to predict the likelihood of future 

collisions because the ESA has not necessitated action following such an event until recently. 

Thus, the NRC staff assumes that there is a potential for red knots to collide with plant 

structures or transmission lines during the proposed license renewal term, and such collisions 

could result in a take.

In addition to collision hazards, the NRC staff also considered the likelihood of direct mortality, 

loss of habitat or food resources, or behavioral changes resulting from other activities 

associated with continued operations (e.g., regular site maintenance and infrastructure repairs 

during the proposed license renewal term). Applicable infrastructure includes roadways, piping 

installations, onsite transmission lines, fencing, and other security infrastructure.

As discussed in Chapter 2 of this SEIS, DTE presently has no plans to conduct refurbishment or 

replacement actions associated with license renewal to support the continued operation of 

Fermi 2. Furthermore, DTE (2014a, 2014c) anticipates no new construction or other 

ground-disturbing activities, changes in operations, or changes in existing land use conditions in 

natural areas because of license renewal. As a result, the NRC staff does not expect any new 

impacts on red knot habitat as a result of these types of license renewal activities.

Operational and maintenance activities that DTE might undertake during the renewal term, such 

as maintenance and repair of plant infrastructure (e.g., roadways, piping installations, onsite 

transmission lines, fencing, and other security infrastructure), likely would be confined to 

previously disturbed areas of the Fermi site. Noise levels and human activity would remain 

similar to the current operations and would not cause any additional disturbances that would 

cause red knots to avoid or abandon shoreline habitat within the action area. Therefore, the 
Environmental Consequences and Mitigating Actions

4-43

NRC staff determined that maintenance and infrastructure repair activities would result in 

insignificant or discountable effects to the red knot. 

When new activities that could impact the environment occur at Fermi 2, DTE follows several 

procedures to ensure that it considers potential environmental effects and appropriately 

addresses them, as described in Section 4.6.1.2. These procedures detail reporting 

requirements in the event that a Federally listed species is observed on site and requirements to 

update company and site-specific procedures for Federal requirements, such as those for 

Federally listed species (DTE 2014c). 

Given that the red knot has not been observed on site since wildlife studies began in 1973, bird 

collisions with cooling towers or other plant infrastructure would be unlikely and given that any 

impacts from continued operations (including maintenance and infrastructure repairs) would 

result in insignificant or discountable effects, the NRC staff concludes that the proposed license 

renewal may affect, but is not likely to adversely affect, the red knot.

Piping Plover (Charadrius melodus)

• The Fermi site may provide marginal resting and feeding habitat for migrating piping 

plovers, but the occurrence of this species within the action area would be rare.

As with the red knot, it is possible, although unlikely, that the piping plover could experience 

injury or mortality resulting from collisions with plant structures during the proposed license 

renewal term. This impact and a summary of previous bird mortality surveys conducted at 

Fermi 2 are discussed above in the assessment of effects on the red knot. The NRC staff 

believes a piping plover collision is extremely unlikely to occur because the piping plover is 

relatively rare in the action area, the piping plover was not collected during DTE’s bird mortality 

study, the piping plover is only in the action area for a short period of time each year, and the 

piping plover is not likely to inhabit the inland developed portions of the site that contain collision 

hazards (NUS 1974; Niles et al. 2008; DTE 2014a, 2014c). Additionally, because the species 

has been listed under the ESA since 1985, the ESA has obligated the NRC and DTE to consult 

with the FWS if new information reveals effects of the action that may affect listed species in a 

manner, or to an extent, not previously considered (50 CFR 402.16(b)). No such information 

has been identified for which the NRC staff has determined that reinitiation of consultation is 

appropriate. Because no such collisions are known to have occurred to date and piping plovers 

are rare within the action area, the NRC staff finds it reasonable to assume that the likelihood of 

collisions would be very unlikely in the future.

In addition to collision hazards, the NRC staff also considered the likelihood of direct mortality;

loss of habitat or food resources; or behavioral changes resulting from continued operations, 

regular site maintenance, and infrastructure repairs during the proposed license renewal term. 

The nature of these effects is discussed above in the assessment of effects on the red knot. 

For example, DTE (2014a) presently anticipates no new construction or other ground-disturbing 

activities, changes in operations, or changes in existing land use conditions in natural areas 

because of license renewal. Similarly, operational and maintenance activities that DTE might 

undertake during the renewal term, such as maintenance and repair of plant infrastructure 

(e.g., roadways, piping installations, onsite transmission lines, fencing, and other security 

infrastructure), likely would be confined to previously disturbed areas of the Fermi site. 

When new activities that could impact the environment occur at Fermi 2, DTE would follow 

several procedures to ensure that potential effects to the piping plover are considered and are 

reported to the appropriate Federal agencies, as described in Section 4.6.1.2. The NRC staff 

did not identify any direct or indirect adverse effects to piping plovers that would result from 

continued operation during the proposed license renewal term. Therefore, the NRC staff 
Environmental Consequences and Mitigating Actions

4-44

determined that maintenance and infrastructure repair activities would result in insignificant or 

discountable effects. 

Given that the piping plover is rare within the action area, bird collisions with cooling towers or 

other plant infrastructure would be very unlikely and given that any impacts from continued 

operations (including maintenance and infrastructure repairs) would result in insignificant or 

discountable effects, the NRC staff concludes that the proposed license renewal may affect, but 

is not likely to adversely affect, the piping plover. 

Northern Long-Eared Bat (Myotis septentrionalis)

The FWS published a final rule to list the northern long-eared bat as threatened throughout its 

range on April 2, 2015 (80 FR 17973). The FWS did not propose to designate critical habitat for 

the species because it found that such habitat is “not determinable at this time” (80 FR 17973).

The FWS (80 FR 17973) identified the primary threat to northern long-eared bat as white nose 

syndrome, a disease caused by the fungus Geomyces destructans, and other sources of 

mortality to the species include wind-energy development, habitat modification, destruction and

disturbance (e.g., vandalism to hibernacula and roost tree removal), effects of climate change, 

and contaminants.

The Fermi site provides potential roosting and foraging habitat for the northern long-eared bat. 

This species has not been observed on site since wildlife studies began in 1973 (NUS 1974;

Black and Veatch 2009a; DECo 2011; NRC 2013a; Kogge and Heslinga 2013; Kogge 2014;

DTE 2014a, 2014c). However, DTE has not conducted onsite mist-net surveys for northern 

long-eared bats that follow protocols recommended by the FWS.

Over the duration of the proposed license renewal term, DTE (2014a, 2014c) presently has no 

plans for landscape-altering activities related to license renewal, such as those that might 

adversely affect northern long-eared bats or its habitat. For example, DTE has no plans to 

conduct refurbishment or replacement actions associated with license renewal to support the 

continued operation of Fermi 2. Furthermore, DTE (2014a) anticipates no new construction or 

other ground-disturbing activities, changes in operations, or changes in existing land use 

conditions in natural areas because of license renewal. Similarly, operational and maintenance 

activities that DTE might undertake during the renewal term, such as maintenance and repair of 

plant infrastructure (e.g., roadways, piping installations, onsite transmission lines, fencing, and 

other security infrastructure), likely would be confined to previously disturbed areas of the Fermi 

site. Noise levels and human activity would remain similar to the current operations and would 

not cause any additional disturbances that would cause northern long-eared bats to avoid or 

abandon habitat within the action area. Therefore, the NRC staff determined that activities 

during continued operations, such as maintenance and infrastructure repair activities, would 

result in insignificant or discountable effects to the northern long-eared bat. 

As part of regular site maintenance, DTE may need to remove trees that pose a safety concern. 

Although it is unlikely that DTE would need to remove trees in the forested tracts on the site 

where northern long-eared bats may roost, the NRC staff assumes that any tree removal could 

potentially affect the species if the trees have not been assessed for bat presence or use. 

When new activities that could impact the environment occur at Fermi 2, such as tree removal, 

DTE follows several procedures to ensure that it considers potential environmental effects and 

appropriately addresses them, as described in Section 4.6.1.2. These procedures detail

reporting requirements in the event that a Federally listed species is observed on site and 

requirements to update company and site-specific procedures for Federal requirements, such 

as those for Federally listed species (DTE 2014c). In addition, if work is to be performed in 

undeveloped areas of the site, a Protected Species Protection Plan must be developed 
Environmental Consequences and Mitigating Actions

4-45

(DTE 2014c), and personnel must be briefed on the plan before beginning work. Furthermore, 

in the Interim 4(d) Rule for the northern long-eared bat published on April 2, 2015 

(80 FR 17973), the FWS determined that activities that remove 1 ac (0.4 ha) or less of forested 

habitat are expected to have minimal impacts on the northern long-eared bat because changes 

to such a small area would have little or no impact on the ecological value and function of the 

forest. In addition, the Interim 4(d) Rule states that incidental takes caused by removal and 

management of hazardous trees (i.e., trees that need to be removed for the protection of human 

safety or human facilities) is not expected to adversely affect conservation and recovery efforts 

for the species (80 FR 17973). 

The proposed license renewal could affect the northern long-eared bat by causing direct 

mortality through collision with plant structures. Based on the available information on bat

mortality, the NRC staff finds that it is possible, although unlikely, that northern long-eared bat

individuals could experience injury or mortality resulting from collisions with plant structures 

during the proposed license renewal term. If a northern long-eared bat were to collide with plant 

structures or transmission lines during the proposed license renewal term, such a collision could 

result in a take, as defined by the ESA. The NRC staff believes that such a collision is 

extremely unlikely to occur because the northern long-eared bat is not common in the action 

area and because no northern long-eared bats have been observed at the Fermi site 

(NUS 1974; DTE 2014c). However, because this species was just recently listed on 

April 2, 2015 (80 FR 17973), the ESA has not afforded this species protection during operation 

of Fermi 2. Accordingly, the ESA has not necessitated the NRC and DTE to consult with the 

FWS in the event that an individual was found injured or dead as a result of collision with 

Fermi 2 plant structures. Although the NRC has no records indicating that such an event 

happened, the NRC staff cannot rely on the absence of records to predict the likelihood of future 

collisions because the ESA has not necessitated action following such an event. Thus, the 

NRC staff assumes that there is a potential for the northern long-eared bat to collide with plant 

structures or transmission lines during the proposed license renewal term, and such collisions 

could result in a take.

DTE (2014c) is in the process of developing a company-wide program to reduce operational 

risks resulting from bird and bat collisions. The program is based on an avian protection plan 

from the Avian Powerline Interaction Committee and on conversations with FWS personnel at 

the Lansing, Michigan, office (DTE 2014c). The program will address changes that are needed 

to prevent avian and bat fatalities and will require documentation of bird and bat strikes to help 

DTE determine whether reporting to local, State, or Federal agencies is required (DTE 2014c). 

DTE (2014c) expects to begin implementation of the program in early 2015. 

Several ongoing restoration projects would result in positive impacts to habitat for the northern 

long-eared bat during the license renewal term. These projects are discussed in Section 3.6 

and include two prairie restoration projects and the continued maintenance of the site’s 

delineated wetlands and the DRIWR Lagoona Beach Unit.

Given the above information, the NRC staff concludes that the proposed license renewal may 

affect, but is not likely to adversely affect, the northern long-eared bat. The conclusion is based 

on the following: 

• The FWS has identified the white-nose syndrome disease as the primary threat to 

northern long-eared bat; this disease typically spreads in the winter hibernacula, and 

such hibernacula do not occur on the Fermi site.

• DTE plans no landscape-altering activities.

• Bat collisions with cooling towers or other plant infrastructure would be very unlikely.
Environmental Consequences and Mitigating Actions

4-46

• Any impacts from continued operations (including maintenance and infrastructure 

repairs) would result in insignificant or discountable effects.

Indiana Bat (Myotis sodalis)

• The Fermi site provides some potential summer roosting areas for the Indiana bat. 

However, most of the trees within forested areas on the Fermi site are either too 

small or otherwise unsuitable for Indiana bat summer roosts (Black and Veatch 2011; 

NRC 2013a). In addition, other habitat features usually preferred by Indiana bats are 

generally lacking at the Fermi site (Black and Veatch 2011; NRC 2013a).

License renewal activities could result in direct mortality, loss of roosting or other habitat or food 

resources, or behavioral changes resulting from construction or refurbishment activities, regular 

site maintenance, and infrastructure repairs during the proposed license renewal term.

Over the duration of the proposed license renewal term, DTE (2014a, 2014c) reports no plans 

for landscape-altering activities related to license renewal, such as those that might adversely 

affect Indiana bats. For example, DTE (2014a) has no plans to conduct refurbishment or 

replacement actions associated with license renewal to support the continued operation of 

Fermi 2. Furthermore, DTE (2014a) anticipates no new construction or other ground-disturbing 

activities, changes in operations, or changes in existing land use conditions in natural areas 

because of license renewal. Similarly, operational and maintenance activities that DTE might 

undertake during the renewal term, such as maintenance and repair of plant infrastructure 

(e.g., roadways, piping installations, onsite transmission lines, fencing, and other security 

infrastructure), likely would be confined to previously disturbed areas of the Fermi site. Noise 

levels and human activity would remain similar to the current operations and would not cause

any additional disturbances that would cause Indiana bats to avoid or abandon habitat within the 

action area. Therefore, the NRC staff determined that activities during continued operations, 

such as maintenance and infrastructure repair activities, would result in insignificant or 

discountable effects to the Indiana bat. 

As part of regular site maintenance, DTE may need to remove trees that pose a safety concern. 

Although it is unlikely that DTE would need to remove trees in the forested tracts on the site 

where Indiana bats may roost, the NRC staff assumes that any tree removal could potentially 

affect the species if the trees have not been assessed for bat presence or use. When new 

activities that could impact the environment occur at Fermi 2, such as tree removal, DTE follows 

several procedures to ensure that it considers potential environmental effects and appropriately 

addresses them, as described in Section 4.6.1.2. These procedures detail reporting 

requirements in the event that a Federally listed species is observed on site and requirements to 

update company and site-specific procedures for Federal requirements, such as those for 

Federally listed species (DTE 2014c). In addition, if work is to be performed in undeveloped 

areas of the site, a Protected Species Protection Plan must be developed, and personnel must 

be briefed on the plan before beginning work (DTE 2014c). 

The proposed license renewal could affect the Indiana bat by causing direct mortality through 

collision with plant structures. Based on the available information on bat mortality, the NRC 

staff finds that it is possible, although unlikely, that Indiana bat individuals could experience 

injury or mortality resulting from collisions with plant structures during the proposed license 

renewal term. If an Indiana bat were to collide with plant structures or transmission lines during 

the proposed license renewal term, such a collision could result in a take, as defined by the 

ESA. The NRC staff believes that such a collision is very unlikely to occur because the Indiana 

bat is relatively rare in the action area and because no Indiana bats have been observed at the 

Fermi site (NUS 1974; MNFI 2007b; DTE 2014a). Additionally, because the species has been 

listed under the ESA since 1967, the ESA has obligated the NRC and DTE to consult with the 
Environmental Consequences and Mitigating Actions

4-47

FWS if new information reveals effects of the action that may affect listed species in a manner,

or to an extent, not previously considered (50 CFR 402.16(b)). No such information has been 

identified for which the NRC staff has determined that reinitiation of consultation is appropriate. 

Furthermore, as described above for the northern long-eared bat, DTE (2014c) is in the process 

of developing a company-wide program to reduce operational risks resulting from bird and bat 

collisions. Because no such collisions are known to have occurred to date and because Indiana 

bats are not common within the action area, the NRC staff finds it reasonable to assume that an 

Indiana bat collision with plant structures would be very unlikely in the future.

Several ongoing restoration projects would result in positive impacts to habitat for the Indiana 

bat during the license renewal term. These projects are discussed in Section 3.6 and include 

two prairie restoration projects and the continued maintenance of the site’s delineated wetlands 

and the DRIWR Lagoona Beach Unit.

During consultation with the FWS for the proposed construction and operation of Fermi 3, the 

FWS (2012) concurred with the NRC staff’s determination that the proposed construction and 

operation may affect, but is not likely to adversely affect, the Indiana bat. The types and 

intensity of potential effects from the proposed license renewal of Fermi 2 would likely be 

bounded by the potential effects from the proposed construction and operation of Fermi 3 

because the activities associated with Fermi 3 would include construction and operations, 

whereas the activities associated with the proposed license renewal for Fermi 2 would be limited 

to continued operations. 

Given the above information, NRC staff concludes that the proposed license renewal may 

affect, but is not likely to adversely affect, the Indiana bat. The conclusion is based on the 

following: 

• DTE plans no landscape-altering activities.

• Bat collisions with cooling towers or other plant infrastructure would be very unlikely.

• Any impacts from continued operations (including maintenance and infrastructure 

repairs) would result in insignificant or discountable effects.

Eastern Prairie Fringed Orchid (Platanthera leucophaea)

The eastern prairie fringed orchid may occur in areas of suitable habitat within the action area, 

such as lakeplain prairies or wetland habitats. Although emergent wetlands exist on the Fermi 

site, large portions of these emergent wetlands have been severely degraded by the common 

reed (Phragmites australis), an invasive plant (NRC 2013a). This species has not been 

observed on site since vegetation studies began in 1973 (NUS 1974; Black and Veatch 2009b;

DECo 2011; NRC 2013a; Kogge and Heslinga 2013; DTE 2014a). 

The Fermi 2 license renewal would include maintenance and operation activities within 

developed or previously disturbed areas and would not involve new construction, refurbishment, 

ground-disturbing activities, changes to conduct of operations, or changes to existing land use 

conditions in either natural or developed areas (DTE 2014a). If new activities are planned on 

the Fermi site, DTE follows several procedures to ensure that it considers potential 

environmental effects and appropriately addresses them, as described in Section 4.6.1.2. 

These procedures detail reporting requirements in the event that a Federally listed species is 

observed on site and requirements to update company and site-specific procedures for Federal 

requirements, such as those for Federally listed species (DTE 2014c). Furthermore, if work is to 

be performed in undeveloped areas of the site, a Protected Species Protection Plan must be 

developed (DTE 2014c), and personnel must be briefed on the plan before beginning work. In 

addition, several ongoing restoration projects would result in positive impacts to habitat for the 
Environmental Consequences and Mitigating Actions

4-48

eastern prairie fringed orchid during the license renewal term. These projects are discussed in 

Section 3.6 and include two prairie restoration projects and the continued maintenance of the 

site’s delineated wetlands and the DRIWR Lagoona Beach Unit. Therefore, the NRC staff 

determined that activities during continued operations, such as maintenance and infrastructure 

repair activities, would result in insignificant or discountable effects to the eastern prairie fringed 

orchid.

During consultation with the FWS for the proposed construction and operation of Fermi 3, the 

FWS (2012) concurred with the NRC staff’s determination that the proposed construction and 

operation may affect, but is not likely to adversely affect, the eastern prairie fringed orchid. The 

types and intensity of potential effects from the proposed license renewal of Fermi 2 would likely 

be bounded by the potential effects from the proposed construction and operation of Fermi 3 

because the activities associated with Fermi 3 would include construction and operations, 

whereas the activities associated with the proposed license renewal for Fermi 2 would be limited 

to continued operations. 

Because any impacts from continued operations (including maintenance and infrastructure 

repairs) would result in insignificant or discountable effects, because this species has not been 

observed on site since vegetation studies began in 1973, and because potential habitat for this 

species on the Fermi site is highly degraded, the NRC staff concludes that the proposed license 

renewal may affect, but is not likely to adversely affect, the eastern prairie fringed orchid. 

Species and Habitats under the National Marine Fisheries Service’s Jurisdiction

As discussed in Section 3.8, no species or habitats under the NMFS’s jurisdiction occur within 

the action area. Thus, the NRC staff concludes that the proposed action would have no effect

on Federally listed species or habitats under the NMFS’s jurisdiction.

Cumulative Effects

The ESA regulations at 50 CFR 402.12(f)(4) direct Federal agencies to consider cumulative 

effects as part of the proposed action effects analysis. Under the ESA, cumulative effects are 

defined as “those effects of future State or private activities, not involving Federal activities, that 

are reasonably certain to occur within the action area of the Federal action subject to 

consultation” (50 CFR 402.02). Unlike the definition of cumulative impacts under the National 

Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4321 et seq.) (Section 4.16), 

cumulative effects under the ESA do not include past actions or other Federal actions requiring 

separate ESA section 7 consultation. When formulating biological opinions under formal ESA 

section 7 consultation, the FWS and the NMFS (1998) consider cumulative effects when 

determining the likelihood of jeopardy or adverse modification. Therefore, consideration of 

cumulative effects under the ESA is necessary only if listed species will be adversely affected 

by the proposed action (FWS 2014d).

In the case of Fermi 2, because the NRC staff concluded earlier in this section that the 

proposed license renewal would have no effect on designated or proposed critical habitat and 

some species and that it may affect, but is not likely to adversely affect other species, 

consideration of cumulative effects is not necessary.

Reporting Requirements

In the future, a Federally listed species could be observed on the Fermi site. For example, as 

part of DTE’s Wildlife Management Plan and Wildlife Habitat Council certification, DTE would 

also continue biannual qualitative prairie vegetation surveys, which would be performed by a 

botanist from the FWS or the Michigan Natural Features Inventory (DTE 2014c). The Fermi 2 

Wildlife Habitat Team would also conduct periodic wildlife surveys of site-specific areas several 
Environmental Consequences and Mitigating Actions

4-49

times per year to monitor the site’s animal communities and to document the occurrence of any 

new species.

If, during these future activities or other onsite activities, a Federally listed species is observed 

on the Fermi site, the NRC has measures in place to ensure that the NRC staff would be 

appropriately notified so that it could determine the appropriate course of action, such as 

possibly reinitiating section 7 consultation under the ESA with the FWS at that time. Fermi 2’s 

operating license, Appendix B, “Environmental Protection Plan,” Section 4.1, “Unusual or 

Important Environmental Events,” requires DTE to report to the NRC within 24 hours any 

occurrence of a species protected by the ESA on the Fermi site (NRC 1985). Additionally, the 

NRC’s regulations concerning notification requirements require operating nuclear power 

reactors to report to the NRC within 4 hours “any event or situation, related to...protection of the 

environment, for which a news release is planned or notification to other government agencies 

has been or will be made” (Title 10 of the Code of Federal Regulations

(10 CFR) 50.72(b)(2)(xi)). Such notifications include reports regarding Federally listed species, 

as described in Section 3.2.12 of NUREG–1022, Event Report Guidelines: 10 CFR 50.72 

and 50.73 (NRC 2013b).

4.8.1.2 Species and Habitats Protected under the Magnuson–Stevens Act of 2006

As discussed in Section 3.8, the NMFS has not designated essential fish habitat pursuant to the 

Magnuson–Stevens Fishery Conservation and Management Act of 2006, as amended (MSA)

(16 U.S.C. 1801–1884), in Lake Erie. Thus, the NRC staff concludes that the proposed action 

would have no effect on essential fish habitat.

4.8.2 No-Action Alternative

Under the no-action alternative, Fermi 2 would shut down. Federally listed species and 

designated critical habitat can be affected not only by operation of nuclear power plants but also 

by activities during shutdown. The ESA action area for the no-action alternative would most 

likely be the same or similar to the action area described in Section 3.8. Because the plant 

would require substantially less cooling water, potential impacts to aquatic species and habitats 

would be reduced, although the plant would still require some cooling water for some period of 

time. The water in the immediate vicinity near the discharge would likely decrease in 

temperature due to the decrease in, or stopping of, thermal discharge. Changes in land use 

and other shutdown activities might affect terrestrial species differently than they would under 

continued operation.

Because Federally listed species or habitats occur in the action area, the NRC would assess the 

need for ESA consultation if any activities associated with plant shutdown have the potential to 

affect a Federally listed species and if they meet the criteria in 50 CFR Part 402 for initiation or 

reinitiation of section 7 consultation. The ESA forbids the “take” of a listed species, where “take” 

means “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to 

engage in any such conduct.” In the case of a take, ESA section 7 requires the NRC to initiate 

consultation with the FWS or the NMFS. The implementing regulations at 50 CFR 402.16 also 

direct Federal agencies to reinitiate consultation in circumstances in which (1) the incidental 

take limit in a biological opinion is exceeded, (2) new information reveals effects to Federally 

listed species or designated critical habitats that were not previously considered, (3) the action 

is modified in a manner that causes effects not previously considered, or (4) new species are 

listed or new critical habitat is designated that may be affected by the action. An ESA section 7

consultation could identify impacts on Federally listed species or critical habitat, require 

monitoring and mitigation to minimize such impacts, and provide a level of exempted take. 

Regulations and guidance regarding the ESA section 7 consultation process are provided in
Environmental Consequences and Mitigating Actions

4-50

50 CFR Part 402 and in the Endangered Species Consultation Handbook (FWS and 

NMFS 1998).

The effects on ESA-listed aquatic species would likely be smaller than the effects under 

continued operation but would depend on the listed species and habitats present when the 

alternative is implemented. The type of impacts on ESA-listed species would likely be similar to 

those described for terrestrial and aquatic resources in Sections 4.6 and 4.7. However, the 

magnitude of such impacts could be larger than that for terrestrial and aquatic resources 

because ESA-listed species are rare and more sensitive to environmental stressors. The 

magnitude of adverse impacts to ESA-listed species would depend on the shutdown activities 

and the listed species and habitats present when the alternative is implemented; therefore, the 

NRC cannot forecast a particular level of impact for this alternative.

4.8.3 NGCC Alternative

This alternative entails shutdown and decommissioning of Fermi 2 and construction of a new 

NGCC facility at the Fermi site. Section 4.8.2 discusses ESA considerations for the shutdown 

of Fermi 2.

Unlike license renewal or the new nuclear alternative, the NRC does not license NGCC 

facilities; therefore, it would not be responsible for initiating section 7 consultation if listed 

species or habitats might be adversely affected under this alternative. The facilities themselves 

would be responsible for protecting listed species because the ESA forbids take of a listed 

species for non-Federal entities.

If the NGCC alternative were to be built on the Fermi site, the ESA action area might be 

different, and the activities and structures associated with the site would be different from those 

described for the proposed license renewal. The type of impacts on ESA-listed species would 

likely be similar to those described for terrestrial and aquatic resources in Sections 4.6 and 4.7. 

However, the magnitude of such impacts could be larger than that for terrestrial and aquatic 

resources because ESA-listed species are rare and more sensitive to environmental stressors. 

Because the magnitude of adverse impacts to ESA-listed species would depend on the site

layout, plant design, operation, and species and habitats listed when the alternative is 

implemented, the NRC cannot forecast a particular level of impact for this alternative.

4.8.4 IGCC Alternative

This alternative entails shutdown and decommissioning of Fermi 2 and construction of a new 

IGCC facility at the Fermi site. Section 4.8.2 discusses ESA considerations for the shutdown of 

Fermi 2.

Unlike license renewal or the new nuclear alternative, the NRC does not license IGCC facilities; 

therefore, it would not be responsible for initiating section 7 consultation if listed species or 

habitats might be adversely affected under this alternative. The facilities themselves would be 

responsible for protecting listed species because the ESA forbids take of a listed species for 

non-Federal entities.

If the IGCC alternative were to be built on the Fermi site, the ESA action area might be different, 

especially if DTE constructs the facility on newly acquired land adjacent to the current Fermi 

site. In addition, the activities and structures associated with the site would be different from 

those described for the proposed license renewal. The type of impacts on ESA-listed species 

would likely be similar to those described for terrestrial and aquatic resources in Sections 4.6 

and 4.7. However, the magnitude of such impacts could be larger than that for terrestrial and 

aquatic resources because ESA-listed species are rare and more sensitive to environmental 
Environmental Consequences and Mitigating Actions

4-51

stressors. Because the magnitude of adverse impacts to ESA-listed species would depend on

the site layout and the extent to which new land is acquired, plant design, operation, and 

species and habitats listed when the alternative is implemented, the NRC cannot forecast a 

particular level of impact for this alternative.

4.8.5 New Nuclear Alternative

This alternative entails shutdown and decommissioning of Fermi 2 and construction of a new 

nuclear alternative on the Fermi site. Section 4.8.2 discusses ESA considerations for the 

shutdown of Fermi 2.

If the new nuclear alternative were to be built on the Fermi site, the ESA action area might be 

different, and the activities and structures associated with the site would be different from those 

described for the proposed license renewal. Because the NRC would remain the licensing 

agency under this alternative, the ESA would require the NRC to initiate consultation with the 

FWS, as applicable, before construction to ensure that the construction and operation of the 

new nuclear plant would not adversely affect any Federally listed species or adversely modify or 

destroy designated critical habitat.

The type of impacts on ESA-listed species would likely be similar to those described for 

terrestrial and aquatic resources in Sections 4.6 and 4.7. However, the magnitude of such 

impacts could be larger than that for terrestrial and aquatic resources because ESA-listed 

species are rare and more sensitive to environmental stressors. Because the magnitude of 

adverse impacts to ESA-listed species would depend on the site layout, plant design, operation, 

and species and habitats listed when the alternative is implemented, the NRC cannot forecast a 

particular level of impact for this alternative.

4.8.6 Combination Alternative (NGCC, Wind, and Solar)

This alternative entails shutdown and decommissioning of Fermi 2 and construction and 

operation of a new NGCC plant at the Fermi site and wind turbines and solar PV systems 

throughout the ROI. Section 4.8.2 discusses ESA considerations for the shutdown of Fermi 2.

Unlike license renewal and the new nuclear alternative, the NRC does not license NGCC, wind, 

and solar facilities; therefore, it would not be responsible for initiating section 7 consultation if 

listed species or habitats might be adversely affected under this alternative. The facilities 

themselves would be responsible for protecting listed species because the ESA forbids take of a 

listed species for non-Federal entities.

If the NGCC portion of the combination alternative were to be built on the Fermi site, the ESA 

action area might be different, and the activities and structures associated with the site would be 

different from those described for the proposed license renewal. The wind and solar portions of 

this alternative would not be built on the Fermi site; therefore, the listed species and habitats 

affected by this alternative would be different from those identified for the proposed license 

renewal. The type of impacts on ESA-listed species would likely be similar to those described 

for terrestrial and aquatic resources in Sections 4.6 and 4.7. However, the magnitude of such 

impacts could be larger than that for terrestrial and aquatic resources because ESA-listed 

species are rare and more sensitive to environmental stressors. Because the magnitude of 

adverse impacts to ESA-listed species would depend on the selected sites, alternative design, 

operation, and species and habitats listed when the alternative is implemented, the NRC cannot 

forecast a particular level of impact for this alternative.
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4.9 Historic and Cultural Resources

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on historic and cultural resources.

4.9.1 Proposed Action

The historic and cultural resource issue applicable to Fermi 2 during the license renewal term is 

listed in Table 4–10. Section 3.9 of this SEIS describes the historic and cultural resources that 

have the potential to be affected by the proposed action. 

Historic and Cultural Resources

Issue GEIS Section Category

Historic and Cultural Resources 4.7.1 2

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

The National Historic Preservation Act of 1966, as amended (NHPA)

(54 U.S.C. 300101 et seq.), requires Federal agencies to consider the effects of their 

undertakings on historic properties, and renewing the operating license of a nuclear power plant 

is an undertaking that could potentially affect historic properties. Historic properties are defined 

as resources eligible for listing in the National Register of Historic Places (NRHP). The criteria 

for eligibility are listed in 36 CFR Part 60.4 and include (1) association with significant events in 

history, (2) association with the lives of persons significant in the past, (3) embodiment of 

distinctive characteristics of type, period, or construction, and (4) sites or places that have 

yielded, or are likely to yield, important information.

The regulations issued by the Advisory Council on Historic Preservation in 36 CFR Part 800

define the process for identifying and evaluating historic properties (Section 106 of the NHPA).

In accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort 

to identify historic properties included in, or eligible for, inclusion in the NRHP in the area of 

potential effect. The area of potential effect for a license renewal action includes the power 

plant site; transmission lines up to the first substation; and immediate environs that may be 

affected by the license renewal decision, including land-disturbing activities associated with 

continued reactor operations during the license renewal term. For Fermi 2, the first substation is 

located on site at the 345-kilovolt switchyard (DTE 2014a).

If historic properties are present within the APE, the NRC is required to contact the State 

Historic Preservation Office (SHPO), assess potential adverse effects of the undertaking 

(license renewal) on historic properties, and resolve any possible adverse effects. In addition,

the NRC is required to notify the SHPO if historic properties would not be affected by license 

renewal or if no historic properties are present. In Michigan, the SHPO is part of the Michigan 

State Housing Development Authority.

Consultation

In accordance with 36 CFR 800.8(c), on July 8, 2014, the NRC initiated consultations with the 

Advisory Council on Historic Preservation, the Michigan SHPO, and the following 17 Federally 

recognized Indian Tribes (NRC 2014a, 2014b, 2014c) (see Appendix D):
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• Keweenaw Bay Indian Community,

• Bay Mills Indian Community,

• Grand Traverse Band of Ottawa and Chippewa Indians,

• Lac Vieux Desert Band of Lake Superior Chippewa Indians,

• Little Traverse Bay Bands of Odawa Indians,

• Pokagon Band of Potawatomi Indians,

• Sault Ste. Marie Tribe of Chippewa Indians of Michigan,

• Hannahville Indian Community,

• Nottawaseppi Huron Band of the Potawatomi,

• Saginaw Chippewa Indian Tribe of Michigan,

• Match-e-be-nash-she-wish Band of Pottawatomi Indians of Michigan,

• Little River Band of Ottawa Indians,

• Forest County Potawatomi,

• Shawnee Tribe,

• Delaware Nation,

• Wyandotte Nation, and

• Ottawa Tribe of Oklahoma.

By letter, the NRC provided information about the proposed undertaking (license renewal), 

defined the APE, and indicated that the Section 106 review would be coordinated with the 

NEPA process in accordance with 36 CFR 800.8. The NRC invited the SHPO and the Tribes to 

participate in the identification of historic properties and in any decisions potentially affecting 

historic properties. They were also invited to participate in the scoping process. To date, the 

NRC has not received any response or comments from any of the contacted Tribes. The NRC 

met with the Michigan SHPO in September 2014. The Michigan SHPO did not express any 

concerns about the proposed Fermi 2 license renewal during the meeting (NRC 2015a).

Separate from these consultations, an Indian Tribe from Ontario, Canada, the Walpole Island 

First Nation, sent a letter to the NRC stating that it would like an opportunity to thoroughly 

review the Fermi 2 license renewal process to ensure that their rights to fish and harvest 

resources in western Lake Erie and other nearby areas are not adversely impacted. 

Accordingly, the NRC invited the Tribe to provide input on the Fermi 2 license renewal 

environmental review process (NRC 2014f).

The entire 1,260-ac (510-ha) Fermi site has been surveyed using field observations and aerial 

photography (DTE 2014c). DTE currently has no plans for physical changes or 

ground-disturbing activities related to the license renewal of Fermi 2 (DTE 2014a). As 

described in Section 3.9, there are both NHRP-eligible (i.e., Fermi 1), and non-NRHP-eligible 

cultural resources present within the APE. In accordance with the stipulations of the 2012 

Memorandum of Agreement (MOA) between the NRC and the Michigan SHPO, DTE (1) created 

a permanent record of the Fermi 1 nuclear power plant, (2) created a historical public exhibit 

about Fermi 1 that opened at the Monroe County Community College in 2013, and (3) contacted 

potentially interested parties and local, State, and Federal agencies regarding the retention of 
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archival materials. In response to these actions, the Michigan SHPO concurred that all 

requirements of the MOA have been met (DTE 2014c).

DTE has established site procedures and work instructions to ensure the consideration of 

historic and cultural resources before the commencement of any ground-disturbing activities at 

the Fermi site (DTE 2014c). These procedures instruct DTE staff on how to handle possible 

impacts to historic and cultural resources and require work planned in previously undisturbed 

areas of the site to consider the potential for inadvertent discovery of historic and archaeological 

artifacts (DTE 2014c). Furthermore, these site procedures and related work instructions direct

DTE staff to stop work, protect exposed resources, and contact the appropriate DTE personnel 

and the SHPO in the event that such resources are inadvertently discovered during 

ground-disturbing activities (DTE 2014c).

Based on (1) the fulfillment of the MOA stipulations regarding the NRHP-eligible Fermi 1 nuclear 

power plant, (2) there currently being no other known NRHP-eligible historic properties on the 

Fermi site, (3) DTE’s establishment of site procedures and work instructions to protect cultural 

resources, (4) DTE’s assurance that no license renewal-related physical changes or 

ground-disturbing activities would occur outside developed areas, (5) the Michigan SHPO’s

input, and (6) this cultural resource assessment, no historic properties would be adversely 

affected by the license renewal decision (36 CFR Section 800.4(d)(1)).

4.9.2 No-Action Alternative

Not renewing the operating license and terminating reactor operations would have no effect on 

historic properties and cultural resources within the site boundaries of Fermi 2. In the 

decommissioning GEIS, the NRC determined that, for all nuclear plant sites at which 

decommissioning does not anticipate disturbing lands beyond existing site boundaries, impacts 

to cultural resources would be SMALL. If disturbance beyond the operational areas is 

anticipated, the impacts may or may not be detectable or destabilizing, depending on 

site-specific conditions, and cannot be predicted generically. In those cases, the potential 

impacts may be SMALL, MODERATE, or LARGE and must be determined through site-specific 

analysis (NRC 2002b).

The regulations at 10 CFR 50.82 require power reactor licensees to submit a post-shutdown 

decommissioning activities report (PSDAR). The PSDAR must be submitted within 2 years 

following permanent cessation of operations and must include a description of planned 

decommissioning activities. Until the PSDAR is submitted, the NRC does not know whether 

land disturbance would only occur within the existing site boundary after the nuclear plant is 

shut down. 

4.9.3 NGCC Alternative

This alternative assumes that a new NGCC facility would be built at the Fermi site separate from 

Fermi 1, Fermi 2, and the proposed location for Fermi 3. The new NGCC facility would require 

an estimated 24 ac (9.7 ha) of land for the power plant with the possibility of additional land 

requirements for gas pipeline ROWs. Areas of the Fermi site that could potentially be affected 

by the construction and operation of a new NGCC power plant may need to undergo additional 

field surveys to identify and record any potentially affected historic and cultural resources. 

Previously disturbed areas of the Fermi site known to not contain historic and cultural resources

could be used; however, if the NGCC plant were to be sited on undisturbed land, a survey could 

be conducted before construction to identify potentially affected historic and cultural resources. 

Power plant operators could also survey areas associated with any new pipelines, roads, 

transmission corridors, and other ROWs. Any resources found in these surveys would need to 
Environmental Consequences and Mitigating Actions

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be evaluated for eligibility on the NRHP, and mitigation of adverse effects would need to be 

addressed if eligible resources were encountered. Areas of greatest cultural sensitivity should 

be avoided. Visual impacts on significant cultural resources, such as the viewsheds of historic 

properties near the proposed NGCC power plant site, would need to be assessed and 

evaluated.

The potential for impacts on historic and cultural resources from the construction and operation 

of a new NGCC power plant would vary depending on the specific location chosen within the

Fermi site. Given the preference to site the power plant on previously disturbed land, avoidance 

of significant historic and cultural resources would be possible and could be effectively 

managed. However, historic and archaeological resources could potentially be affected, 

depending on the resource richness of the land required for a new gas pipeline; however, as 

with the plant site itself, avoidance of significant historic and cultural resources should be 

possible and effectively managed under current laws and regulations. Therefore, historic and 

cultural resource impacts from the construction and operation of a new NGCC power plant 

would be SMALL.

4.9.4 IGCC Alternative

This alternative assumes that a new IGCC power plant would be built at the Fermi site separate 

from Fermi 1, Fermi 2, and the proposed location for Fermi 3. The new IGCC facility would 

require an estimated 1,000 ac (405 ha) of land for the power plant and would require DTE to 

obtain additional parcels of land adjacent to the Fermi site. Areas of the Fermi site and adjacent 

parcels that could potentially be affected by the construction and operation of an IGCC power 

plant may need to undergo additional field surveys to identify and record any potentially affected 

historic and cultural resources. Previously disturbed areas of the Fermi site known to not 

contain historic and cultural resources could be used; however, if the IGCC plant were to be 

sited on undisturbed land, a survey could be conducted before construction to identify 

potentially affected historic and cultural resources. Power plant operators could also survey the 

land parcels acquired to support this alternative. Any resources found in these surveys would 

need to be evaluated for eligibility on the NRHP, and mitigation of adverse effects would need to 

be addressed if eligible resources were encountered. Areas of greatest cultural sensitivity 

should be avoided. Visual impacts on significant cultural resources, such as the viewsheds of 

historic properties near the proposed IGCC power plant site, would need to be assessed and 

evaluated.

The potential for impacts on historic and cultural resources from the construction and operation 

of a new IGCC power plant would vary, depending on the specific location chosen within the

Fermi site and adjacent land parcels. Given the preference to site the power plant on previously 

disturbed land and given that no major infrastructure upgrades would be necessary, avoidance 

of significant historic and cultural resources would be possible and could be effectively 

managed. However, historic and archaeological resources could potentially be affected, 

depending on the resource richness of the adjacent land parcels required to site the larger 

footprint of this facility. Therefore, historic and cultural resource impacts from the construction 

and operation of a new IGCC power plant would be SMALL to MODERATE.

4.9.5 New Nuclear Alternative

This alternative assumes that a new nuclear power plant would be built at the Fermi site

separate from Fermi 1, Fermi 2, and the proposed location for Fermi 3. The new nuclear plant 

would require an estimated 301 ac (122 ha) of land for the power plant and would require DTE 

to obtain additional parcels of land adjacent to the existing Fermi site. Areas of the Fermi site 
Environmental Consequences and Mitigating Actions

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and adjacent parcels that could potentially be affected by the construction and operation of a

new nuclear power plant may need to undergo additional field surveys to identify and record any 

potentially affected historic and cultural resources. Previously disturbed areas of the Fermi site 

known to not contain historic and cultural resources could be used; however, if the new nuclear 

power plant were to be sited on undisturbed land, a survey would need to be conducted before 

construction to identify potentially affected historic and cultural resources. Power plant 

operators would also need to survey all of the land parcels acquired to support this alternative. 

Any resources found in these surveys would need to be evaluated for eligibility on the NRHP, 

and mitigation of adverse effects would need to be addressed if eligible resources were 

encountered. Areas of greatest cultural sensitivity should be avoided. Visual impacts on 

significant cultural resources, such as the viewsheds of historic properties near the proposed 

nuclear power plant site, would need to be assessed and evaluated.

The potential for impacts on historic and cultural resources from the construction and operation 

of a new nuclear power plant would vary depending on the specific location chosen within the

Fermi site and adjacent land parcels. Given the preference to site the power plant on previously 

disturbed land and given that no major infrastructure upgrades would be necessary, avoidance 

of significant historic and cultural resources would be possible and could be effectively 

managed. However, historic and archaeological resources could potentially be affected, 

depending on the resource richness of the adjacent land parcels required to site the new 

nuclear power plant. New cooling towers could also impact historic property viewsheds. 

Therefore, historic and cultural resource impacts from the construction and operation of a new 

nuclear power plant would be SMALL to MODERATE.

4.9.6 Combination Alternative (NGCC, Wind, and Solar)

Land area potentially affected by the construction and operation of an NGCC power plant and 

wind and solar PV power-generating facilities could be surveyed before construction to identify 

and evaluate the potential effects to historic and archaeological resources. Any historic and 

cultural resources found during these surveys would need to be evaluated for eligibility on the 

NRHP, and mitigation of adverse effects would need to be addressed if eligible resources were 

encountered. Impacts to historic and cultural resources from the NGCC portion of this 

alternative would be similar to those described for the NGCC alternative in Section 4.9.3.

The wind component of this alternative would require an estimated 1,117 to 3,351 ac (452 to 

1,356 ha) of land at onshore wind farm sites across the ROI. The potential for impacts on 

historic and cultural resources from the construction and operation of the wind portion of this 

alternative would vary greatly, depending on the location of the proposed site(s). Areas with the 

greatest cultural sensitivity should be avoided or effectively managed. Construction of wind 

farms and their support infrastructure could impact historic and cultural resources because of 

ground-disturbing activities, and aesthetic changes to historic property viewsheds could be 

LARGE.

The solar component would require an estimated 3,577 ac (1,448 ha) of land across the ROI. 

The impacts from the construction of a new solar PV alternative on historic and cultural 

resources would vary, depending on where the solar power generating units are installed. 

Rooftop installations would minimize land disturbance and any modifications to the transmission 

system, thereby minimizing potential impacts to historic and cultural resources. Land-based 

solar installations would be larger than rooftop installations and would require some degree of 

land disturbance for installation, thus potentially causing greater impacts to historic and cultural 

resources. Aesthetic changes caused by the installation of both forms could have a noticeable 

effect on historic property viewsheds. Using previously disturbed sites for land-based 

installations and collocating any new transmission lines with existing ROWs could minimize 
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impacts to historic and cultural resources. Areas with the greatest cultural sensitivity should be 

avoided or effectively managed. Therefore, depending on the sites chosen for the NGCC, wind, 

and solar PV alternative, historic and cultural resource impacts could range from SMALL to 

LARGE.

4.10 Socioeconomics

This section describes the potential socioeconomic impacts of the proposed action (license 

renewal) and alternatives to the proposed action.

4.10.1 Proposed Action

Socioeconomic effects of ongoing reactor operations at Fermi 2 have become well established 

as regional socioeconomic conditions have adjusted to the presence of the nuclear power plant. 

These conditions are described in Section 3.10. Any changes in employment and tax payments 

caused by license renewal and any associated refurbishment activities could have a direct and 

indirect impact on community services and housing demand, as well as traffic volumes in the 

communities around a nuclear power plant.

Socioeconomic NEPA issues from Table B–1 in Appendix B to Subpart A of Part 51, applicable 

to the license renewal of Fermi 2 are listed in Table 4–11. The review conducted for the 

2013 revision to the GEIS did not identify any Category 2 socioeconomic NEPA issues 

(NRC 2013d).

Socioeconomic NEPA Issues

Issues GEIS Sections Category

Employment and income, recreation and tourism 4.8.1.1 1

Tax revenues 4.8.1.2 1

Community services and education 4.8.1.3 1

Population and housing 4.8.1.4 1

Transportation 4.8.1.5 1

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

The supplemental site-specific socioeconomic impact analysis for the license renewal of Fermi 2 

includes a review of DTE’s ER, scoping comments, other information records, and a 

data-gathering site visit to Fermi 2. The NRC staff did not identify any new and significant 

information during the review that would result in impacts that would exceed the predicted 

socioeconomic impacts evaluated in the GEIS, and no additional socioeconomic NEPA issues 

were identified beyond those listed in Table B–1.

In addition, DTE indicated that they have no plans to add nonoutage workers during the license 

renewal term and that increased maintenance and inspection activities could be managed using 

the current workforce. Consequently, people living in the vicinity of Fermi 2 are not likely to 

experience any changes in socioeconomic conditions during the license renewal term beyond 

what is currently being experienced. Therefore, the impact of continued reactor operations 

during the license renewal term would not exceed the socioeconomic impacts predicted in the 

GEIS. For these issues, the GEIS predicted that the impacts would be SMALL for all nuclear 

plants.
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4.10.2 No-Action Alternative

4.10.2.1 Socioeconomics

Not renewing the operating license and terminating reactor operations would have a noticeable 

impact on socioeconomic conditions in the communities located near Fermi 2. The loss of jobs 

and income would have an immediate socioeconomic impact. Some, but not all, of the 

approximately 890 employees would begin to leave after reactor operations are terminated, and 

overall tax revenue generated by plant operations would be reduced (DTE 2014a). DTE pays 

annual property taxes to Frenchtown Township, Monroe County, Michigan. The Frenchtown 

Township Treasurer collects DTE’s property tax payment and disperses it to various entities to 

partially fund their respective operating budgets. The property tax revenue is used to fund 

Monroe County Community College; Monroe County Intermediate Schools; Monroe County 

seniors; Lake Erie Transportation; additional voted school millage; local township operations;

and, when applicable, the Resort Authority (DTE 2014a). The loss of tax revenue could reduce 

or eliminate some public and educational services. Indirect employment and income generated 

by power plant operations would also be reduced.

Former Fermi 2 workers and their families could leave in search of employment elsewhere. The 

increase in available housing along with decreased demand could cause housing prices to fall. 

Since the majority of employees reside in Monroe and Wayne Counties, socioeconomic impacts 

from the termination of reactor operations would be concentrated in these Counties, with a 

corresponding reduction in purchasing activity and tax revenue in the regional economy. 

Income and revenue losses from the termination of reactor operations at Fermi 2 would directly 

affect Monroe County and nearby communities most reliant on income from power plant 

operations. However, the impact of the job loss may not be as noticeable in local communities 

given the amount of time required for decommissioning. The socioeconomic impacts from the 

termination of nuclear plant operations (which may not entirely cease until after 

decommissioning) would, depending on the jurisdiction, range from SMALL to LARGE.

4.10.2.2 Transportation

Traffic congestion caused by commuting workers and truck deliveries on roads in the vicinity of 

Fermi 2 would be reduced after power plant shutdown. Most of the reduction in traffic volume 

would be associated with the loss of jobs. The number of truck deliveries to Fermi 2 would be 

reduced until decommissioning. Traffic-related transportation impacts would be SMALL as a 

result of the shutdown of the nuclear power plant.

4.10.3 NGCC Alternative

4.10.3.1 Socioeconomics

Socioeconomic impacts are defined in terms of changes to the demographic and economic 

characteristics and social conditions of a region. For example, the number of jobs created by 

the construction and operation of a power plant could affect regional employment, income, and 

expenditures.

Two types of jobs would be created by this alternative: (1) construction jobs, which are 

transient, short in duration, and less likely to have a long-term socioeconomic impact, and 

(2) power plant operations jobs, which have the greater potential for permanent, long-term 

socioeconomic impacts. Workforce requirements for the construction and operation of a new 

NGCC power plant were evaluated to measure their possible effects on current socioeconomic 

conditions.
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The construction workforce could peak at 1,440 workers (NRC 1996). The relative economic 

effect of this many workers on the local economy and tax base would vary with the greatest 

impacts occurring in the communities where the majority of construction workers would reside 

and spend their income. As a result, local communities could experience a short-term economic 

“boom” from increased tax revenue and income generated by construction expenditures and the 

increased demand for temporary (rental) housing and public, as well as commercial services.

After construction, local communities could experience a return to preconstruction economic 

conditions. Based on this information and given the number of workers, socioeconomic impacts 

during construction in communities near an existing power plant site could range from 

MODERATE to LARGE.

An estimated 75 workers would be required during power plant operations (NRC 1996). Local 

communities would experience the economic benefits from increased tax revenue and income 

generated by operational expenditures and demand for housing and public, as well as 

commercial services. The amount of property tax payments under the NGCC alternative may 

also increase if additional land is required to support this alternative.

This alternative would also result in a loss of approximately 890 relatively high-paying jobs at 

Fermi 2 and a corresponding reduction in purchasing activity and revenue contributions to the 

regional economy. If Fermi 2 were to cease operations, there would be an immediate 

socioeconomic impact to local communities and businesses from the loss of jobs (some, but not 

all, of the 890 employees would begin to leave), and tax payments may be reduced. In addition, 

the housing market could also experience increased vacancies and decreased prices if 

operations workers and their families move out of the region. However, the impact of the job 

loss may not be noticeable in local communities given the amount of time required for 

decommissioning of the existing Fermi 2 facilities. Based on this information and given the 

number of operations workers, socioeconomic impacts during NGCC power plant operations on 

local communities could range from SMALL to MODERATE.

4.10.3.2 Transportation

Transportation impacts associated with construction and operation of a three-unit NGCC power 

plant would consist of commuting workers and truck deliveries of construction materials to the 

power plant site. During periods of peak construction activity, up to 1,440 workers could be 

commuting daily to the construction site. Workers commuting to the construction site would 

arrive via site access roads, and the volume of traffic on nearby roads could increase 

substantially during shift changes. In addition to commuting workers, trucks would be 

transporting construction materials and equipment to the work site, thus increasing the amount 

of traffic on local roads. The increase in vehicular traffic would peak during shift changes, 

resulting in temporary levels of service impacts and delays at intersections. Pipeline 

construction and modification of existing natural gas pipeline systems could also have a 

temporary impact. In addition, materials could be delivered by barge or rail, depending on 

location. Traffic-related transportation impacts during construction would likely range from 

MODERATE to LARGE.

Traffic-related transportation impacts would be greatly reduced after completing the installation 

of the NGCC alternative. Transportation impacts would include daily commuting by the 

operating workforce, equipment and materials deliveries, and the removal of commercial waste 

material to offsite disposal or recycling facilities by truck. The operations workforce of 

75 workers would not be noticeable relative to total traffic volumes on local roadways. Since 

fuel is transported by pipeline, the transportation infrastructure would experience little to no 

increased traffic from plant operations. Overall, given the relatively small operations workforce 

estimate of 75 workers, transportation impacts would be SMALL during power plant operations.
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4.10.4 IGCC Alternative

4.10.4.1 Socioeconomics

As explained in Section 4.10.3.1, two types of jobs would be created by this alternative: 

(1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

socioeconomic impact, and (2) power plant operations jobs, which have the greater potential for 

permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

operation of a new IGCC power plant were evaluated to measure their possible effects on 

current socioeconomic conditions.

The construction workforce could peak at 2,300 workers (DOE 2010). The relative economic 

effect of this many workers on the local economy and tax base would vary with the greatest 

impacts occurring in the communities where the majority of construction workers would reside 

and spend their income. As a result, local communities could experience a short-term economic 

“boom” from increased tax revenue and income generated by construction expenditures and the 

increased demand for temporary (rental) housing and public, as well as commercial services.

After construction, local communities could experience a return to preconstruction economic 

conditions. Based on this information and given the number of workers, socioeconomic impacts 

during construction in communities near an existing power plant site could range from 

MODERATE to LARGE.

An estimated 210 workers would be required during power plant operations (DOE 2010). Local 

communities would experience the economic benefits from increased tax revenue and income 

generated by operational expenditures and demand for housing and public, as well as 

commercial services. The amount of property tax payments under the IGCC alternative may

also increase if additional land is required to support this alternative.

This alternative would also result in a loss of approximately 890 relatively high-paying jobs at 

Fermi 2 and a corresponding reduction in purchasing activity and revenue contributions to the 

regional economy. If Fermi 2 were to cease operations, there would be an immediate 

socioeconomic impact to local communities and businesses from the loss of jobs (some, but not 

all, of the 890 employees would begin to leave), and tax payments may be reduced. In addition, 

the housing market could also experience increased vacancies and decreased prices if 

operations workers and their families move out of the region. However, the impact of the job 

loss may not be noticeable in local communities given the amount of time required for 

decommissioning of the existing Fermi 2 facilities. Based on this information and given the 

number of operations workers, socioeconomic impacts during IGCC power plant operations on 

local communities could range from SMALL to MODERATE.

4.10.4.2 Transportation

Transportation impacts associated with construction and operation of the two-unit, IGCC power 

plants would consist of commuting workers and truck deliveries of construction materials to the 

power plant site. During periods of peak construction activity, up to 2,300 workers could be 

commuting daily to the construction site. Workers commuting to the construction site would

arrive via site access roads, and the volume of traffic on nearby roads could increase 

substantially during shift changes. In addition to commuting workers, trucks would be 

transporting construction materials and equipment to the work site, thereby increasing the 

amount of traffic on local roads. The increase in vehicular traffic would peak during shift 

changes, resulting in temporary levels of service impacts and delays at intersections. Materials 

could also be delivered by rail or barge, depending on location. Traffic-related transportation 

impacts during construction would likely range from MODERATE to LARGE.
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Traffic-related transportation impacts on local roads would be greatly reduced after the 

completion of the power plant. The estimated maximum number of operations workers 

commuting daily to the power plant site could be 210 (DOE 2010). Frequent coal and limestone 

deliveries and ash removal by rail would add to the overall transportation impact. The increase 

in traffic on roadways would peak during shift changes, resulting in temporary levels of service 

impacts and delays at intersections. Onsite coal storage would make it possible to receive 

several trains per day at a site with rail access. If the IGCC power plant is located on navigable 

waters, coal and other materials could be delivered by barge. Coal and limestone delivery and 

ash removal via rail would cause levels of service impacts due to delays at railroad crossings. 

Overall, transportation impacts would be SMALL to MODERATE during IGCC power plant 

operations.

4.10.5 New Nuclear Alternative

4.10.5.1 Socioeconomics

As explained in Section 4.10.3.1, two types of jobs would be created by this alternative: 

(1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

socioeconomic impact, and (2) power plant operations jobs, which have the greater potential for 

permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

operation of a new nuclear power plant were evaluated to measure their possible effects on 

current socioeconomic conditions.

The construction workforce could peak at 2,900 workers (NRC 2013a). The relative economic 

effect of this many workers on the local economy and tax base would vary with the greatest 

impacts occurring in the communities where the majority of construction workers would reside 

and spend their income. As a result, local communities could experience a short-term economic 

“boom” from increased tax revenue and income generated by construction expenditures and the 

increased demand for temporary (rental) housing and public, as well as commercial services.

After construction, local communities could experience a return to preconstruction economic 

conditions. Based on this information and given the number of workers, socioeconomic impacts 

could range from MODERATE to LARGE.

Approximately 900 workers would be required during nuclear power plant operations

(NRC 2013a). Some Fermi 2 operations workers could transfer to the new nuclear power plant. 

Local communities near the new nuclear power plant would experience the economic benefits 

from increased tax revenue and income generated by operational expenditures and demand for 

housing and public, as well as commercial services. The amount of property tax payments 

under the new nuclear alternative may also increase if additional land is required to support this 

alternative.

This alternative would also result in a loss of approximately 890 relatively high-paying jobs at 

Fermi 2 and a corresponding reduction in purchasing activity and revenue contributions to the 

regional economy. If Fermi 2 were to cease operations, there would be an immediate 

socioeconomic impact to local communities and businesses from the loss of jobs (some, but not 

all, of the 890 employees would begin to leave), and tax payments may be reduced. In addition, 

the housing market could also experience increased vacancies and decreased prices if 

operations workers and their families move out of the region. However, the impact of the job 

loss may not be noticeable in local communities given the amount of time required for 

decommissioning of the existing Fermi 2 facilities. Based on this information and given the 

number of operations workers, socioeconomic impacts during nuclear power plant operations on 

local communities could range from SMALL to MODERATE.
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4.10.5.2 Transportation

Transportation impacts associated with construction and operation of a new nuclear power plant 

would consist of commuting workers and truck deliveries of construction materials to the power 

plant site. During periods of peak construction activity, up to 2,900 workers could be commuting 

daily to the construction site (NRC 2013a). Workers commuting to the construction site would 

arrive via site access roads, and the volume of traffic on nearby roads could increase 

substantially during shift changes. In addition to commuting workers, trucks would be 

transporting construction materials and equipment to the work site, thereby increasing the 

amount of traffic on local roads. The increase in vehicular traffic would peak during shift 

changes, resulting in temporary levels of service impacts and delays at intersections. Materials 

could also be delivered by rail or barge, depending on the location. Traffic-related 

transportation impacts during construction would likely range from MODERATE to LARGE.

Traffic-related transportation impacts on local roads would be greatly reduced after the 

completion of the power plant. The estimated maximum number of operations workers 

commuting daily to the new nuclear power plant site could be 900 (NRC 2013a). Transportation 

impacts would include daily commuting by the operating workforce, material deliveries, and the 

removal of commercial waste material to offsite disposal or recycling facilities by truck. Traffic 

on roadways would peak during shift changes and refueling outages, resulting in temporary 

levels of service impacts and delays at intersections. Overall, at the new nuclear power plant 

site, transportation impacts would be SMALL to MODERATE during operations.

4.10.6 Combination Alternative (NGCC, Wind, and Solar)

4.10.6.1 Socioeconomics

As explained in Section 4.10.3.1, two types of jobs would be created by this alternative: 

(1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

socioeconomic impact, and (2) operations jobs, which have the greater potential for permanent, 

long-term socioeconomic impacts. Workforce requirements for the construction and operation 

of the NGCC, wind, and solar generation components of this combination alternative were 

evaluated to estimate their possible effects on current socioeconomic conditions.

Fewer workers would be required to construct the single NGCC unit at the Fermi site than those 

required for the full-power NGCC alternative. Installation of an estimated 1,117 wind turbines 

would likely be done in stages and could employ up to 307 construction workers (NREL 2013). 

Additional workers would be required to install solar PV systems on existing buildings or 

structures at residential, commercial, or industrial sites that have already been developed. 

Similar to the wind farms, installation would likely be done in stages and could employ up to 

528 construction workers (DOE 2011).

Conversely, a small number of operations workers would be needed to operate the single 

NGCC unit, and additional small numbers of workers would be required to maintain the wind 

farms (187 workers) and solar PV systems (53 workers). Local communities could experience 

the economic benefits from increased tax revenue and income generated by operational 

expenditures and demand for housing and public, as well as commercial services. The amount 

of property tax payments under the wind and solar PV components may also increase if 

additional land is required to support this combination alternative.

This combination alternative would also result in a loss of approximately 890 relatively 

high-paying jobs at Fermi 2, and a corresponding reduction in purchasing activity, tax payments, 

and revenue contributions would occur in the surrounding regional economy. If Fermi 2 were to 

cease operations, there would be an immediate socioeconomic impact to local communities and 
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businesses from the loss of jobs (some, but not all, of the 890 employees would begin to leave), 

and tax payments may be reduced. In addition, the housing market could also experience 

increased vacancies and decreased prices if operations workers and their families move out of 

the region. However, the impact of the job loss may not be noticeable in local communities 

given the amount of time required for decommissioning of the existing Fermi 2 facilities. Based 

on this information and given the relatively small numbers of construction and operations 

workers, socioeconomic impacts during construction and operations on local communities would 

be SMALL.

4.10.6.2 Transportation

Transportation impacts during the construction and operation of the NGCC unit, as well as the 

wind and solar components, of this combination alternative would be less than the impacts for 

any of the previous alternatives discussed. This is because the construction workforce for each 

component and the volume of materials and equipment needing to be transported to the 

respective construction site would be smaller than those for any one of the individual 

replacement power alternatives. In other words, the transportation impacts would not be as 

concentrated as they would be for the other alternatives; instead, they would be spread out over 

a wider area.

Workers commuting to the construction site would arrive via site access roads, and the volume 

of traffic on nearby roads could increase during shift changes. In addition to commuting 

workers, trucks would be transporting construction materials and equipment to the work site, 

thereby increasing the amount of traffic on local roads. The increase in vehicular traffic would 

peak during shift changes, resulting in temporary levels of service impacts and delays at 

intersections. Transporting heavy and oversized components on local roads could have a 

noticeable impact over a large area. Some components and materials could also be delivered 

by rail or barge, depending on location. Traffic-related transportation impacts during 

construction could range from SMALL at the Fermi site and SMALL to MODERATE at the wind 

farms and solar installations, depending on current road capacities and average daily traffic 

volumes.

During operations, transportation impacts would be less noticeable during shift changes and 

maintenance activities. Given the small numbers of operations workers, the levels of service 

traffic impacts on local roads from NGCC, wind farm, and solar PV operations would be SMALL.

4.11 Human Health

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on human health resources. 

4.11.1 Proposed Action

The human health issues applicable to Fermi 2 are discussed below and are listed in

Table 4–12 for Category 1, Category 2, and uncategorized issues. Table B–1 in Appendix B to 

Subpart A of 10 CFR Part 51 contains more information on these issues.

Human Health Issues

Issue(a) GEIS Section Category

Radiation exposures to the public 4.9.1.1.1 1

Radiation exposures to plant workers 4.9.1.1.1 1

Human health impact from chemicals 4.9.1.1.2 1
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Issue(a) GEIS Section Category

Microbiological hazards to plant workers 4.9.1.1.3 1

Chronic effects of electromagnetic fields (EMFs)(b) 4.9.1.1.4 N/A(c)

Physical occupational hazards 4.9.1.1.5 1

Electric shock hazards(b) 4.9.1.1.5 2

(a) Microbiological hazards to the public for plants with cooling ponds or canals or cooling towers that discharge to a 

river is a Category 2 issue, but it is not applicable to Fermi 2.

(b) This issue applies only to the in scope portion of electric power transmission lines, which are defined as 

transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional 

power distribution system and transmission lines that supply power to the nuclear plant from the grid.

(c) N/A (not applicable). The categorization and impact finding definition does not apply to this issue.

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013d

4.11.1.1 Normal Operating Conditions

Generic Human Health Issues (Category 1)

The NRC staff did not identify any new and significant information during its review of DTE’s ER

(DTE 2014a), the site audit, or the scoping process for the Category 1 issues listed in

Table 4–12. In regard to the Category 1 issue, “Radiation exposures to the public,” the NRC 

staff reviewed a Radiation and Public Health Project (RPHP) report submitted during the public 

scoping process entitled, “Potential Health Risks Posed by Adding a New Reactor at the Fermi 

Plant: Radioactive contamination from Fermi 2 and changes in local health status,” authored by 

Joseph J. Mangano, MPH, MBA, RPHP Executive Director. The NRC concluded that the RPHP 

report does not constitute new and significant information that would change the GEIS’s 

conclusion of SMALL for this issue (Section 4.14). Therefore, there are no impacts related to 

these issues beyond those discussed in the GEIS. For these Category 1 issues, the GEIS 

concluded that the impacts are SMALL.

Chronic Effects of Electromagnetic Fields

The GEIS does not designate the chronic effects of 60-hertz electromagnetic fields (EMFs) from 

power lines as Category 1 or 2 (NRC 2013d); these effects will not be categorized as such until 

a scientific consensus is reached on the health implications of these fields.

The potential for chronic effects from these fields continues to be studied and is not known at 

this time. The National Institute of Environmental Health Sciences (NIEHS) directs related 

research through the DOE.

The report by NIEHS (NIEHS 1999) contains the following conclusion:

The NIEHS concludes that ELF-EMF (extremely low frequency-electromagnetic 

field) exposure cannot be recognized as entirely safe because of weak scientific 

evidence that exposure may pose a leukemia hazard. In our opinion, this finding 

is insufficient to warrant aggressive regulatory concern. However, because 

virtually everyone in the United States uses electricity and therefore is routinely 

exposed to ELF-EMF, passive regulatory action is warranted such as continued 

emphasis on educating both the public and the regulated community on means 

aimed at reducing exposures. The NIEHS does not believe that other cancers or 

non-cancer health outcomes provide sufficient evidence of a risk to currently 

warrant concern.
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This statement is not sufficient to cause the NRC staff to change its position with respect to the 

chronic effects of EMFs. The NRC staff considers the GEIS finding of “UNCERTAIN” still 

appropriate and will continue to follow developments on this issue.

Electric Shock Hazards

Based on the GEIS, the Commission found that electric shock resulting from direct access to 

energized conductors or from induced charges in metallic structures has not been a problem at 

most operating plants and generally is not expected to be a problem during the license renewal 

term. However, a site-specific review is required to determine the significance of the electric 

shock potential along the portions of the transmission lines that are within the scope of this 

SEIS.

As discussed in Section 3.11.4 of this SEIS, the transmission lines that connect Fermi 2 to the 

regional electrical distribution grid and that would remain energized only if the plant’s operating 

license were renewed are in-scope for evaluation in this SEIS. These in-scope transmission 

lines are entirely within the Fermi 2 owner-controlled area and span industrial areas within the 

Fermi site. As a result, the public does not have access to this area and could not come into 

contact with these energized transmission lines. Therefore, there is no potential shock hazard 

to members of the public from these transmission lines.

For plant workers, the Michigan Occupational Safety and Health Administration safety standards 

govern the nonradiological occupational safety and health of Fermi 2 workers and are 

incorporated into Fermi 2’s occupational health and safety program (DTE 2014a). Compliance 

with the Fermi 2’s operational safety requirements is expected for all plant workers.

Because transmission lines are not accessible to members of the public and because an 

occupational safety and health program is in place to prevent electric shock hazards to plant 

workers, the NRC staff concludes that the potential impacts from acute electric shock during the 

license renewal term would be SMALL.

4.11.1.2 Environmental Impacts of Postulated Accidents

This section describes the environmental impacts from postulated accidents that Fermi 2 might 

experience during the period of extended operation. The term “accident” refers to any 

unintentional event outside the normal plant operational envelope that results in a release or the 

potential for release of radioactive materials into the environment. The two classes of 

postulated accidents listed in Table 4–13—design-basis accidents (DBAs) and severe 

accidents—are contained in Table B–1 of Appendix B to Subpart A of 10 CFR Part 51 and are 

evaluated in detail in the GEIS.

Issues Related to Postulated Accidents

Issue GEIS Section Category

DBAs 4.9.1.2 1

Severe accidents 4.9.1.2 2

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013a

Design-Basis Accidents

To receive NRC approval to operate a nuclear power plant, an applicant for an initial operating 

license must submit a Safety Analysis Report (SAR) as part of its application. The SAR 

presents the design criteria and information for the proposed reactor, along with comprehensive 
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data on the proposed site. The SAR also discusses various hypothetical accident situations and 

the safety features that are provided to prevent and mitigate accidents. The NRC staff reviews 

the application to determine whether the plant design meets the Commission’s regulations and 

requirements, which include, in part, the nuclear plant design and its anticipated response to an 

accident.

DBAs are those accidents that both the applicant and the NRC staff evaluate to ensure that the 

plant can withstand normal and abnormal transients, and a broad spectrum of postulated 

accidents without undue hazard to the health and safety of the public. A number of these 

postulated accidents are not expected to occur during the life of the plant, but they are 

evaluated to establish the design basis for the preventive and mitigative safety systems of the 

nuclear power plant. The regulations at 10 CFR Part 50 and 10 CFR Part 100 describe the 

acceptance criteria for DBAs.

The environmental impacts of DBAs are evaluated during the initial licensing process, and the 

ability of the plant to withstand these accidents is demonstrated to be acceptable before 

issuance of the operating license. The results of these evaluations are found in licensee 

documentation, such as the applicant’s final SAR, the safety evaluation report, the final 

environmental statement, and this section of the SEIS. A licensee is required to maintain the 

acceptable design and performance criteria throughout the life of the plant, including any 

extended-life operation. The consequences for these events are evaluated for the hypothetical 

maximum exposed individual; as such, changes in the plant environment will not affect these 

evaluations. Because of the requirements to maintain acceptable design and performance 

criteria and to implement programs to manage the effects of aging during the period of extended 

operation, the environmental impacts as calculated for DBAs should not differ significantly from 

initial licensing assessments over the life of the plant, including the period of extended 

operation. Accordingly, the design of the plant relative to DBAs during the period of extended 

operation is considered to remain acceptable, and the environmental impacts of those accidents 

were not examined further in the GEIS.

The Commission has determined that the environmental impacts of DBAs are of SMALL 

significance for all plants because the plants were designed to successfully withstand these 

accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 

Category 1 issue. The early resolution of DBAs makes them a part of the current licensing 

basis of the plant; the licensee must maintain the current licensing basis of the plant under its 

current license; therefore, under the provisions of 10 CFR 54.30, it is not subject to review under 

license renewal.

No new and significant information related to DBAs was identified during the review of DTE’s 

ER (DTE 2014a), site audit, the scoping process, or evaluation of other available information. 

Therefore, there are no impacts related to these issues beyond those discussed in the GEIS.

Severe Accidents

Severe nuclear accidents are those that are more severe than DBAs because they could result 

in substantial damage to the reactor core, whether or not there are serious offsite 

consequences. In the GEIS, the NRC staff assessed the effects of severe accidents during the 

period of extended operation, using the results of existing analyses and site-specific information 

to conservatively predict the environmental impacts of severe accidents for each plant during 

the period of extended operation.

Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes, 

fires, and sabotage, have not traditionally been discussed in quantitative terms in final 

environmental statements (NRC 1996). However, the GEIS did evaluate existing impact 
Environmental Consequences and Mitigating Actions

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assessments performed by NRC and by the industry at 44 nuclear plants in the United States, 

including Fermi 2, and concluded that the risk from beyond-design-basis earthquakes at existing 

nuclear power plants is SMALL. The GEIS for license renewal performed a discretionary 

analysis of terrorist acts in connection with license renewal and concluded that the core damage 

and radiological release from such acts would be no worse than the damage and release 

expected from internally initiated events. In the GEIS, the Commission concludes that the risk 

from sabotage and beyond-design-basis earthquakes at existing nuclear power plants is small 

and additionally that the risks from other external events are adequately addressed by a generic 

consideration of internally initiated severe accidents (NRC 1996, 2013d).

Based on information in the GEIS, the NRC staff found the following to be true:

The probability weighted consequences of atmospheric releases, fallout onto 

open bodies of water, releases to ground water, and societal and economic 

impacts from severe accidents are small for all plants. However, alternatives to 

mitigate severe accidents must be considered for all plants that have not 

considered such alternatives.

The NRC staff identified no new and significant information related to postulated accidents

during the review of DTE’s ER for Fermi 2 (DTE 2014a), the site audit, the scoping process, or 

evaluation of other available information. Therefore, there are no impacts related to these 

issues beyond those discussed in the GEIS. However, in accordance with 

10 CFR 51.53(c)(3)(ii)(L), the NRC staff has reviewed severe accident mitigation alternatives 

(SAMAs) for Fermi 2. The results of the review are discussed below.

Severe Accident Mitigation Alternatives

If the NRC staff has not previously evaluated SAMAs for the applicant’s plant in an 

environmental impact statement (EIS) or related supplement or in an environmental 

assessment, 10 CFR Part 51.53(c)(3)(ii)(L) requires that license renewal applicants consider 

alternatives to mitigate severe accidents to ensure that plant changes (i.e., hardware, 

procedures, and training) with the potential for improving severe accident safety performance 

are identified and evaluated. Pursuant to 10 CFR 54.21, “Contents of Application—Technical 

Information,” the only changes that must be implemented by the applicant as part of the license 

renewal process are those that are related to adequately managing the effects of aging during 

the period of extended operation. SAMAs have not been previously considered for the Fermi 2; 

therefore, the remainder of this section summarizes the SAMA evaluation.

DTE submitted an assessment of SAMAs for Fermi 2 as part of its ER (DTE 2014a). This

assessment was based on the most recent Fermi 2 probabilistic risk assessment (PRA) 

available at that time; a plant-specific accident progression and source term analysis performed 

using the Modular Accident Analysis Program (MAAP), version 4.0.7, computer code; a 

plant-specific offsite consequence analysis performed using the MELCOR Accident 

Consequence Code System (MACCS2),version 3.7.0, computer code; and insights from the 

Fermi 2 individual plant examination (DECo 1992) and individual plant examination of external 

events (IPEEE) (DECo 1996).

In identifying and evaluating potential SAMAs, DTE considered SAMAs that addressed the 

major contributors to core damage frequency (CDF) and release frequency at Fermi 2, as well 

as SAMA candidates for other operating plants that have submitted license renewal

applications. DTE initially identified 220 potential SAMAs. This list was reduced to 79 unique 

SAMA candidates by eliminating SAMAs that are not applicable to Fermi 2 because of design 

differences, that have already been implemented at Fermi 2, that were combined with another 

SAMA candidate during the assessment, that have excessive implementation costs, that have a 

very low benefit to Fermi 2, or that are undergoing implementation at Fermi 2. DTE assessed 
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the costs and benefits associated with each of the 79 potential SAMAs and concluded in the ER 

that one SAMA candidate was potentially cost beneficial. Sensitivity analyses performed by 

DTE indicated that three additional SAMA candidates had the potential to be cost beneficial. 

Overview of SAMA Process

This section presents a summary of the SAMA evaluation for Fermi 2 as described in the ER 

(DTE 2014a); requests for additional information (RAIs) (DTE 2015b, 2015c, 2015d); and the 

review of those evaluations. The NRC staff performed its review with contract assistance from 

the Center for Nuclear Waste Regulatory Analyses. Appendix F includes the NRC staff’s

detailed review; the Fermi 2 SAMA evaluation is available in Attachment D to DTE’s ER.

The SAMA evaluation for Fermi 2 was conducted with a four-step approach. In the first step, 

DTE quantified the level of risk associated with potential reactor accidents using the 

plant-specific PRA and other risk models. In the second step, DTE examined the major risk 

contributors and identified possible ways (SAMAs) of reducing that risk. Common ways of 

reducing risk are changes to components, systems, procedures, and training. In the third step, 

DTE estimated the benefits and the costs associated with each of the candidate SAMAs. 

Estimates were made of how much each SAMA could reduce risk. Those estimates were 

developed in terms of dollars in accordance with NRC guidance for performing regulatory 

analyses. The costs of implementing the candidate SAMAs were also estimated. In the fourth 

step, DTE compared the cost and benefit of each of the remaining SAMAs to determine whether 

each SAMA was cost beneficial, meaning that the benefits of the SAMA exceeded its cost.

The NRC staff has reviewed DTE’s data and evaluation methods and concludes that the quality 

of the risk analyses is adequate to support an assessment of the risk reduction potential for 

candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the CDFs 

and offsite doses reported by DTE.

Potential Plant Improvements

DTE identified potential plant improvements (SAMAs) by reviewing industry documents and by 

considering other plant-specific enhancements that were not identified in the published industry 

documents. Appendix F identifies the industry documents that DTE reviewed.

Based on this review, DTE identified an initial set of 220 candidate SAMAs, referred to as 

Phase I SAMAs. In Phase I of the evaluation, DTE performed a qualitative screening of 

the initial list of SAMAs and eliminated SAMAs from further consideration using the 

following criteria:

• Not Applicable. If a proposed SAMA does not apply to the Fermi 2 design, it is 

not retained.

• Already Implemented. If the SAMA or equivalent was previously implemented, it is 

not retained.

• Combined with Another SAMA. If a SAMA is similar in nature and can be combined 

with another SAMA to develop a more comprehensive or plant-specific SAMA, only 

the combined SAMA is further evaluated.

• Excessive Implementation Cost. If the estimated cost of implementation is greater 

than the modified Maximum Averted Cost-Risk, the SAMA cannot be cost beneficial 

and is screened from further analysis.

• Very Low Benefit. If the SAMA is related to a non-risk significant system that is 

known to have negligible impact on the risk profile, it is not retained.
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• Implementation in Progress. If plant improvements that address the intent of the 

SAMA are already in progress, it is not retained.

During this process, 141 SAMA candidates were screened out based on the criteria listed 

above. Table D.2-1 of the ER (DTE 2014a) provides a description of each of the 79 Phase II 

SAMA candidates. In Phase II, a detailed evaluation was performed for each of the 79 

remaining SAMA candidates, as discussed in Sections F.4 and F.6 of Appendix F.

The NRC staff concludes that DTE used a systematic and comprehensive process for 

identifying potential plant improvements for Fermi 2 and that the set of SAMAs evaluated in the 

ER, together with those evaluated in response to NRC staff inquiries, is reasonably 

comprehensive and, therefore, acceptable. The NRC staff evaluation included reviewing 

insights from the Fermi 2 plant-specific risk studies that included internal initiating events as well 

as fire, seismic, and other external initiated events, and reviewing plant improvements 

considered in previous SAMA analyses. Section F.3 of Appendix F presents additional details 

on the NRC staff’s evaluation.

Evaluation of Risk Reduction and Costs of Improvements

DTE evaluated the risk-reduction potential of the 79 SAMAs retained for the Phase II evaluation 

in the ER (DTE 2014a). The SAMA evaluations were generally performed by DTE in a realistic 

or slightly conservative fashion that overestimates the benefit of the SAMA. In most cases, the 

failure likelihood with the added equipment is considered optimistically low, thereby 

overestimating the benefit of the SAMA. In other cases, it was assumed that the SAMA 

eliminated all of the risk associated with the proposed enhancement. The NRC staff notes that 

this bounding approach overestimates the benefit and is conservative.

Except for SAMAs associated with internal fires, DTE used model requantification to determine 

the potential benefits for most of the SAMAs. Reductions to the CDF, population dose, and 

offsite economic cost were estimated using the Fermi 2 PRA model. Section D.2.3 of the ER

describes changes made to the model to quantify the impact of each SAMA. Table 4–14

summarizes the assumptions used to estimate the risk reduction for each of the evaluated 

SAMAs, the estimated risk reduction in terms of percent reduction in CDF, the population dose, 

the offsite economic cost, and the estimated total benefit (present value) of the averted risk. 

The NRC staff reviewed the assumptions used in evaluating the benefit or risk reduction 

estimate of each of the SAMAs, as described in the ER Section D.2.3. Section F.4 of 

Appendix F discusses the resolution to RAIs that resulted from this review, and Section F.6 of 

Appendix F further discusses the determination of the benefits for the various SAMAs.

DTE estimated the costs of implementing the 79 Phase II SAMAs through the use of other 

licensees’ estimates for similar improvements and the development of site-specific cost 

estimates, where appropriate.

DTE indicated that it used the cost ranges in Table 4–15 based on the review of previous SAMA

applications and an evaluation of expected implementation costs at Fermi 2.

DTE stated that the Fermi 2 site-specific cost estimates were based on the engineering 

judgment of project engineers experienced in performing design changes at the facility and were 

compared, where possible, to estimates developed and used at plants of similar design 

and vintage.

In response to an NRC staff RAI to provide further information as to what was included in the 

Fermi 2 cost estimates, DTE indicated that cost estimates were developed based on initial 

hardware and installation costs only and not on reoccurring costs (DTE 2015b). The estimates 

did not include costs for replacement power during SAMA implementation, lifetime maintenance, 
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and procedure costs. DTE indicated that the only exceptions are the cost estimates for 

SAMA 145 to increase training and operating experience feedback to improve operator 

response and a new SAMA evaluated in response to an RAI to implement an inspection 

program for the piping associated with the risk-significant internal flooding initiators. SAMA 145 

is training related; therefore, costs estimated by DTE included additional operator training for the 

life of the plant. Because the new SAMA pertains to a proposed inspection program, DTE 

included reoccurring costs associated with plant walkdowns of piping segments that are 

significant to the internal flooding risk (DTE 2015b).

The NRC staff reviewed the applicant’s cost estimates presented in Table D.2-1 of the ER 

(DTE 2014a). For certain improvements, the NRC staff also compared the cost estimates to 

estimates developed elsewhere for similar improvements, including estimates developed as part 

of other licensees’ analyses of SAMAs for operating reactors. With the requested clarifications 

presented in Section F.5 of Appendix F, the NRC staff concludes that the cost estimates 

provided by DTE are sufficient and appropriate for use in the SAMA evaluation.
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Potentially Cost-Beneficial SAMAs for Fermi Unit 2(a)

Individual SAMA and Assumption

% Risk Reduction Total Benefit ($)(b)

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Larger R

Baselin

Sensit

112 - Revise emergency operating procedures to 

improve ISLOCA identification <1 6 3 119K 297

Assumption: This analysis was used to evaluate the change in plant risk from reducing the frequency of ISLOCA events a

operator’s ability to cope with ISLOCAs. To assess this potential benefit, the frequency of all ISLOCA initiating events was 

25 percent.

113 - Improve operator training on ISLOCA coping <1 6 3 119K 297

Assumption: This analysis was used to evaluate the change in plant risk from reducing the frequency of ISLOCA events a

operator’s ability to cope with ISLOCAs. To assess this potential benefit, the frequency of all ISLOCA initiating events was 

25 percent.

115 - Revise procedures to control vessel injection 

to prevent boron loss or dilution following standby 

liquid control injection

2 4 4 122K 304

Assumption: This analysis was used to evaluate the change in plant risk from controlling vessel injection to ensure adequ

concentration is maintained in the core following an ATWS. To determine the benefit from revising procedures to improve 

injection, the failure probability of the human actions control level early during an ATWS sequence and to control level late 

sequence were each improved by 10 percent.

206 - Improve the ability of operators to manually 

close a damper to isolate the third floor of the 

reactor building from hardened vent path

13 13 13 438K 1.1

Assumption: During the IPEEE, it was determined that the human action to manually close a damper to isolate the third fl

Building from the hardened vent path when the non-interruptible air supply had failed was not feasible. Even though the fa

associated with fire, it accounts for 1.55x10-6 per year of the Control Room and 6.09x-10-7 per year of the northeast quadra

Building fire CDF in the modified Fermi fire assessment results. A backup air bottle supply and local control for this dampe

action to be performed. The SAMA is assessed by assuming that all of the fire CDF associated with the damper for the tw

above is removed from the results. This results in a reduction of 2.15x10-6 per year in the fire CDF. This reduction in CDF 

proportionately to each release category.
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Individual SAMA and Assumption

% Risk Reduction Total Benefit ($)(b)

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Larger R

Baselin

Sensit

(a) Potentially cost-beneficial SAMAs from DTE’s baseline and sensitivity analyses are listed. Refer to Section F.6.2 of Appendix F for th

SAMAs determined by DTE to be potentially cost beneficial as a result of questions raised by the NRC staff during the SAMA evaluat

(b) DTE identified potentially cost-beneficial SAMAs by comparing the largest total benefit with sensitivity to the estimated implementation 

(c) In response to the NRC staff’s RAIs, DTE updated the assessment related to several SAMAs not listed in this table (SAMAs 023, 031

183, and 187, as described in Section F.4 of Appendix F).

(d) The NRC staff calculated corrected benefits for several SAMAs not listed in this table (SAMAs 021, 024, 050, 054, 067, 078, 123, 145

194, as listed in Table F–6 of Appendix F).

Key: ATWS = anticipated transients without scram, CDF = core damage frequency, ISLOCA = interfacing systems loss-of-coolant accid

NRC = U.S. Nuclear Regulatory Commission, OECR = offsite economic cost risk, SAMA = severe accident mitigation alternative.

Source: DTE 2014a
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Estimated Cost Ranges of SAMA Implementation Costs at Fermi Unit 2 

Type of Change Estimated Cost Range

Procedural only $50K

Procedural change with engineering or training required $50K to $200K

Procedural change with engineering and testing or training required $200K to $300K

Hardware modification $100K to >$1,000K

Cost-Benefit Comparison

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 

was determined not to be cost beneficial. If the SAMA benefit exceeded the estimated cost, the 

SAMA candidate was considered to be potentially cost beneficial. DTE’s baseline cost-benefit 

analysis identified one SAMA candidate as potentially cost-beneficial. From the sensitivity

analysis for the 95th percentile uncertainty in the CDF, DTE identified an additional three SAMA 

candidates as potentially cost beneficial. Table F–5 in Appendix F presents the results of the 

cost-benefit evaluation. Considering the results from the baseline and sensitivity analyses, the 

full set of potentially cost-beneficial SAMAs for Fermi 2 is as follows:

• SAMA 112: Revise emergency operating procedures to improve identification of 

interfacing system loss-of-coolant accidents (ISLOCA).

• SAMA 113: Improve operator training on coping with ISLOCA.

• SAMA 115: Revise procedures to control vessel injection to prevent boron loss or 

dilution following standby liquid control injection.

• SAMA 206: Improve the ability of operators to manually close a damper to isolate 

the third floor of the reactor building from the hardened vent path.

As described in Section F.3.2 of Appendix F, the NRC staff asked the applicant to evaluate 

potentially lower cost alternatives to the SAMA candidates. In response to questions raised by 

the NRC staff, DTE concluded that the following new SAMAs would be potentially cost 

beneficial (DTE 2015b):

• Install a flood barrier or curb between the direct current switchgear room and 

Division 2 alternating current switchgear room.

• Develop a new procedure to close valves to terminate the flood from emergency 

equipment cooling water in the AB3 switchgear room.

• Revise existing alarm response procedures to direct operators to the direct current

switchgear room and the Division 2 alternating current switchgear room following 

indication of leakage in the reactor building closed cooling water/emergency 

equipment cooling water system piping.

These three potentially cost-beneficial SAMAs are not listed in Table 4–14

DTE indicated that the seven SAMAs, the four numbered ones and the three additional 

unnumbered SAMAs, will be incorporated into the evaluation process and evaluated considering 

other planned changes.
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Conclusions

DTE considered 220 candidate SAMAs based on risk-significant contributors at Fermi 2 from 

updated probabilistic safety assessment models, SAMA-related industry documentation, 

plant-specific enhancements not found in published industry documentations, and its review of 

SAMA candidates from potential improvements primarily at eight other plants. Phase I 

screening reduced the list to 79 unique SAMA candidates by eliminating SAMAs that were not 

applicable to Fermi 2, that had already been implemented at Fermi 2, that were combined into a 

more comprehensive or plant-specific SAMA, that had excessive implementation cost, that had 

a very low benefit, or that related to in-progress implementation of plant improvements that 

addressed the intent of the SAMA. For the remaining SAMA candidates, DTE performed a 

cost-benefit analysis with results shown in Table F–5 of Appendix F. The baseline cost-benefit 

analysis identified one SAMA candidate as potentially cost beneficial. From a sensitivity 

analysis, DTE identified an additional three SAMA candidates as potentially cost beneficial. In 

response to questions raised by the NRC staff, DTE concluded that three new SAMAs would be 

potentially cost beneficial. Because the potentially cost-beneficial SAMAs do not relate to aging 

management during the period of extended operation, their implementation is not required as 

part of license renewal pursuant to 10 CFR Part 54, “Requirements for Renewal of Operating 

Licenses for Nuclear Power Plants.” Nevertheless, DTE indicated that these seven SAMAs will 

be incorporated into the evaluation process and evaluated considering other planned changes

The NRC staff reviewed DTE’s SAMA analysis and concludes that, subject to the discussion in 

Appendix F, the methods used and implementation of the methods were sound. The NRC 

staff’s concerns were addressed by DTE’s responses and the NRC staff’s review. Furthermore, 

a calculation performed by the NRC staff with DTE’s information did not change the 

identification of cost-beneficial SAMAs. Based on the applicant’s treatment of SAMA benefits 

and costs, NRC staff finds that the SAMA evaluations performed by DTE are reasonable and 

sufficient for the license renewal submittal. The NRC staff agrees with DTE’s conclusion that 

seven SAMA candidates are potentially cost beneficial for Fermi 2 and notes that DTE’s 

assessment was based on a generally conservative treatment of costs, benefits, and 

uncertainties. Furthermore, this conclusion of a relatively small number of potentially 

cost-beneficial SAMAs is consistent with a low level of residual risk indicated in the Fermi 2 

PRA. Based on the NRC staff’s review of DTE’s SAMA evaluations, including DTE’s response 

to the NRC staff’s RAIs, the NRC staff concludes that DTE has adequately identified areas in 

which risk can be further reduced through the implementation of the identified potentially 

cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff 

agrees that further evaluation by DTE of the seven potentially cost-beneficial SAMAs is 

warranted. 

Additionally, the NRC staff evaluated whether the identified potentially cost-beneficial SAMAs 

are subject to aging management. The evaluation considered any structures, systems, and 

components associated with these SAMAs that perform intended functions without moving parts 

or without a change in configuration or properties and that would not be subject to replacement 

based on a qualified life or specified time period. Because the potential cost-beneficial SAMAs 

are associated with procedure changes, new hardware to improve a manual action, and a new 

structure between switchgear rooms, the NRC staff determined that these SAMAs do not relate 

to adequately managing the effects of aging during the period of extended operation. 

Therefore, they need not be implemented as part of license renewal in accordance with 

10 CFR Part 54. Nevertheless, DTE will consider potentially cost-beneficial SAMAs 

incorporated into the evaluation process and evaluated considering other planned plant 

modifications. The NRC staff accepts this course of action.
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4.11.2 No-Action Alternative

Human health risks would be smaller following plant shutdown. A shutdown reactor unit would 

emit less radioactive gaseous, liquid, and solid material to the environment than an operating 

reactor unit would. In addition, following shutdown, the variety of potential accidents at the plant 

(radiological or industrial) are reduced to a limited set associated with shutdown events and fuel 

handling and storage. In Section 4.11.1, the NRC staff concluded that the impacts of continued 

plant operation on human health would be SMALL, except for “Chronic effects of EMFs,” for 

which the impacts are UNCERTAIN. In Section 4.11.1.2, the NRC staff concluded that the 

impacts of accidents during operation were SMALL. Therefore, as radioactive emissions to the 

environment decrease and as the likelihood and types of accidents decrease following 

shutdown, the NRC staff concludes that the risk to human health following plant shutdown 

would be SMALL.

4.11.3 NGCC Alternative

Impacts on human health from construction of the NGCC alternative would be similar to effects 

associated with the construction of any major industrial facility (NRC 2013d). Compliance with 

worker protection rules would control those impacts on workers at acceptable levels. Impacts 

from construction on the public would be minimal since crews would limit active construction 

area access to authorized individuals. Based on the above, the NRC staff concludes that the 

impacts on human health from the construction of the NGCC alternative would be SMALL.

Impacts from the operation of an NGCC facility include the introduction of public risk from 

inhalation of gaseous emissions. The risk may be attributable to nitrogen oxide emissions that 

contribute to ozone formation, which in turn contribute to health risk. Regulatory agencies, 

including the EPA and state agencies, base air emission standards and requirements on human 

health impacts. These agencies also impose site-specific emission limits as needed to protect 

human health. Given the regulatory oversight exercised by EPA and state agencies, the NRC 

staff concludes that the human health impacts from the NGCC alternative would be SMALL.

4.11.4 IGCC Alternative

Impacts on workers are expected to be similar to those experienced during construction of any 

major industrial facility (NRC 2013d). Construction would increase traffic on local roads, which 

could affect the health of the public. Human health impacts would be the same as those found 

at an existing nuclear plant. Personal protective equipment, training, and engineered barriers 

would protect the workforce (NRC 2013d). Therefore, the NRC staff concludes that the impacts 

on human health from the construction of a coal facility would be SMALL.

The coal alternative introduces worker risks from coal and limestone mining, worker and public 

risk from coal and lime/limestone transportation, worker and public risk from disposal of 

coal-combustion waste, and public risk from inhalation of stack emissions. In addition, human 

health risks are associated with the management and disposal of coal combustion waste. Coal 

combustion generates waste in the form of ash, and equipment for controlling air pollution 

generates additional ash and scrubber sludge. Human health risks may extend beyond the 

facility workforce to the public, depending on the public’s proximity to the coal combustion waste 

disposal facility. The character and the constituents of coal combustion waste depend on both 

the chemical composition of the source coal and the technology used to combust it. Generally, 

the primary sources of adverse consequences from coal combustion waste are from exposure 

to sulfur oxides and nitrogen oxides in air emissions and radioactive elements like uranium and 
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thorium, as well as the heavy metals and hydrocarbon compounds contained in fly ash, bottom 

ash, and scrubber sludge (NRC 2013d).

Regulatory agencies, including the EPA and state agencies, base air emission standards and 

requirements on human health impacts. These agencies also impose site-specific emission 

limits as needed to protect human health. Given the regulatory oversight exercised by EPA and 

state agencies, the NRC staff concludes that the human health impacts from radiological doses 

and inhaled toxins and particulates generated from the coal alternative would be SMALL.

4.11.5 New Nuclear Alternative

Impacts on human health from construction of a new nuclear power plant would be similar to 

impacts associated with the construction of any major industrial facility. Compliance with worker 

protection rules would control those impacts on workers at acceptable levels. Impacts from 

construction on the general public would be minimal since limiting active construction area 

access to authorized individuals is expected. Therefore, impacts on human health from the 

construction of a new nuclear power plant would be SMALL. 

The human health impacts from the operation of a new nuclear power plant would be similar to 

those of the existing Fermi 2. As presented in Section 4.11.1.1, impacts on human health from 

the operation of Fermi 2 would be SMALL, except for “Chronic effects of electromagnetic fields

(EMFs),” for which the impacts are UNCERTAIN. Therefore, the impacts on human health from 

the operation of a new nuclear power plant would be SMALL.

4.11.6 Combination Alternative (NGCC, Wind, and Solar)

Impacts on human health from construction of a combination of NGCC, wind, and solar PV

technologies would be similar to effects associated with the construction of any major industrial 

facility (NRC 2013d). Compliance with worker protection rules would control those impacts on 

workers at acceptable levels. Impacts from construction on the public would be minimal since 

crews would limit active construction area access to authorized individuals. Based on the 

above, the NRC staff concludes that the impacts on human health from the construction of the 

NGCC, wind, and solar alternative would be SMALL.

Operational hazards at an NGCC facility are discussed in Section 4.11.3 and are SMALL.

Operational hazards at a wind facility for the workforce include working at heights, near rotating 

mechanical or electrically energized equipment, and in extreme weather. Potential impacts to 

workers and the public include ice thrown from rotor blades and broken blades thrown due to 

mechanical failure. Potential impacts also include EMF exposure, aviation safety, and exposure 

to noise and vibration from the rotating blades (NRC 2013d).

Operational hazards at a solar PV facility may involve exposure to airborne toxic metals 

(e.g., cadmium) and silicon if the solar PV cell loses its integrity, for example, due to fire. 

Workers could also inhale silicon dust if the solar PV cell was smashed by an object or from a 

fall to the ground. (NRC 2013d)

However, given the expected compliance with worker protection rules and remediation efforts to 

contain the toxic material, the NRC staff concludes that the impacts to workers at the facility and 

offsite exposure to the public would be SMALL.
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4.12 Environmental Justice

This section describes the potential human health and environmental effects of the proposed 

action (license renewal) and alternatives to the proposed action on U.S. minority and 

low-income populations and special pathway receptors.

4.12.1 Proposed Action

The environmental justice NEPA issue from Table B–1 in Appendix B to Subpart A of 

10 CFR Part 51 applicable to the license renewal of Fermi 2 is listed in Table 4–16. 

Section 3.12 identifies U.S. minority and low-income populations living in the vicinity of Fermi 2.

Environmental Justice NEPA Issue

Issue GEIS Section Category

Minority and low-income populations 4.10.1 2

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

The NRC addresses environmental justice matters for license renewal by (1) identifying the 

location of U.S. minority and low-income populations that may be affected by the continued 

operation of the nuclear power plant during the license renewal term, (2) determining whether 

there would be any potential human health or environmental effects to these populations and 

special pathway receptors, and (3) determining whether any of the effects may be 

disproportionately high and adverse.

Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 

impacts on human health. Disproportionately high and adverse human health effects occur 

when the risk or rate of exposure to an environmental hazard for a minority or low-income 

population is significant and exceeds the risk or exposure rate for the general population or for 

another appropriate comparison group. Disproportionately high environmental effects refer to 

impacts or risks of impacts on the natural or physical environment in a minority or low-income 

community that are significant and appreciably exceed the environmental impact on the larger 

community. Such effects may include biological, cultural, economic, or social impacts.

Figures 3–18 and 3–19 show the location of predominantly minority and low-income population 

U.S. Census block groups residing within a 50-mi (80-km) radius of Fermi 2. This area of 

impact is consistent with the impact analysis for public and occupational health and safety, 

which also focuses on U.S. populations within a 50-mi (80-km) radius of the plant. Chapter 4 of 

this SEIS presents the assessment of environmental and human health impacts for each 

resource area. The analyses of impacts for all environmental resource areas indicated that the 

impact from license renewal would be SMALL.

Potential impacts on U.S. minority and low-income populations (including migrant workers or 

Native Americans) would mostly consist of socioeconomic and radiological effects; however, 

radiation doses from continued operations during the license renewal term are expected to 

continue at current levels, and they would remain within regulatory limits. Section 4.11.1.2 of 

this SEIS discusses the environmental impacts from postulated accidents that might occur 

during the license renewal term, which include both design basis and severe accidents. In both 

cases, the Commission has generically determined that impacts associated with design basis 

accidents are SMALL because U.S. nuclear plants are designed and operated to successfully 
Environmental Consequences and Mitigating Actions

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withstand such accidents, and the probability weighted consequences of severe accidents are 

SMALL.

Therefore, based on this information and the analysis of human health and environmental 

impacts presented in Chapter 4 of this SEIS, there would be no disproportionately high and 

adverse human health and environmental effects on U.S. minority and low-income populations 

from the continued operation of Fermi 2 during the license renewal term.

As part of addressing environmental justice concerns associated with license renewal, the NRC 

also assessed the potential radiological risk to special population groups (such as migrant 

workers or Native Americans) from exposure to radioactive material received through their 

unique consumption practices and interaction with the environment, including subsistence 

consumption of fish and wildlife, native vegetation, surface waters, sediments, and local 

produce; absorption of contaminants in sediments through the skin; and inhalation of airborne 

radioactive material released from the plant during routine operation. This analysis is presented 

below.

Subsistence Consumption of Fish and Wildlife

The special pathway receptors analysis is an important part of the environmental justice

analysis because consumption patterns may reflect the traditional or cultural practices of 

minority and low-income populations in the area, such as migrant workers or Native Americans.

Section 4–4 of Executive Order 12898 (59 FR 7629) directs U.S. Federal agencies, whenever 

practical and appropriate, to collect and analyze information about the consumption patterns of 

populations that rely principally on fish and/or wildlife for subsistence and to communicate the 

risks of these consumption patterns to the public. In this SEIS, the NRC considered whether 

there were any means for U.S. minority or low-income populations to be disproportionately 

affected by examining impacts on American Indian, Hispanic, migrant worker, and other 

traditional lifestyle special pathway receptors. The assessment of special pathways considered 

the levels of radiological and nonradiological contaminants in vegetation, crops, soils and 

sediments, groundwater, surface water, fish, and game animals on or near Fermi 2.

Radionuclides released to the atmosphere may deposit on soil and vegetation and, therefore, 

may eventually be incorporated into the human food chain. To assess the impact of Fermi 2

operations to humans from the ingestion pathway, samples of milk, green leafy vegetables, and 

groundwater are collected and analyzed for radioactivity. The following describes DTE’s 

radiological environmental monitoring program.

DTE has an ongoing comprehensive Radiological Environmental Monitoring Program (REMP)

to assess the impact of Fermi 2 operations on the environment. To assess the impact of 

nuclear power plant operations, samples are collected from the environment and analyzed for 

radioactivity. A plant effect would be indicated if the radioactive material detected in a sample 

were larger or higher than background levels. Two types of samples are collected. The first 

type, a control sample, is collected from areas that are beyond the influence of the nuclear 

power plant or any other nuclear facility. These samples are used as reference data to 

determine normal background levels of radiation in the environment. These samples are then 

compared with the second type of samples, indicator samples, collected near the nuclear power 

plant. Indicator samples are collected from areas where any contribution from the nuclear 

power plant will be at its highest concentration. These samples are then used to evaluate the 

contribution of nuclear power plant operations to radiation or radioactivity levels in the 

environment. An effect would be indicated if the radioactivity levels detected in an indicator 

sample were larger or higher than those in the control sample or background levels.
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Samples were collected from the aquatic and terrestrial environment in the vicinity of Fermi 2 

in 2013. The aquatic environment includes groundwater, surface water, fish, and shoreline 

sediment. Aquatic monitoring results for 2013 of water, sediment, and fish showed only 

naturally occurring radioactivity and radioactivity associated with fallout from past atmospheric 

nuclear weapons testing and were consistent with levels measured before the operation of 

Fermi 2. No nuclear plant-related radioactivity was detected greater than the minimum 

detectable activity in any aquatic sample during 2013, and no adverse long-term trends were 

identified in aquatic monitoring data (DTE 2014b).

The terrestrial environment includes airborne particulates, milk, and food products (i.e., broccoli, 

Brussel sprouts, cabbage, cauliflower, collards, and horseradish). Terrestrial monitoring results 

for 2013 of milk, groundwater and leafy garden vegetable samples showed only naturally 

occurring radioactivity. The radioactivity levels detected were consistent with levels measured 

before the operation of Fermi 2. No nuclear plant-related radioactivity was detected greater 

than the minimum detectable activity in any terrestrial samples during 2013. The terrestrial 

monitoring data also showed no adverse trends in the terrestrial environment (DTE 2014b).

Analyses performed on all samples collected from the environment at Fermi 2 in 2013 showed 

no significant measurable radiological constituent above background levels. Overall, 

radioactivity levels detected in 2013 were consistent with previous levels and with radioactivity 

levels measured before the operation of Fermi 2. REMP sampling in 2013 did not identify any 

nuclear plant-related radioactivity above the minimum detectable activity (DTE 2014b).

In a decision issued on February 6, 2015, the Atomic Safety and Licensing Board admitted three 

contentions for litigation in the Fermi 2 license renewal adjudicatory proceeding (Atomic Safety 

and Licensing Board, Memorandum and Order, LBP-15-5, February 6, 2015 (ADAMS 

No. ML15037A618)). One of those admitted contentions, which had been filed by Citizens’ 

Resistance at Fermi 2, was concerned with DTE’s lack of discussion of whether members of the 

Walpole Island First Nation would be negatively affected by the renewal of the Fermi 2 operating 

license due to impacts on tribal hunting and fishing rights, especially with respect to the potential 

for the consumption of contaminated foods. In a decision issued on September 8, 2015, the 

Commission reversed the Board’s decision admitting the contention regarding the Walpole 

Island First Nation and directed the Atomic Safety and Licensing Board to terminate the 

adjudicatory proceeding (CLI-15-18, Memorandum and Order, September 8 2015 (ADAMS 

No. ML15251A049)). Nevertheless, the subsistence consumption of fish and wildlife analysis 

presented in this section addresses whether any subsistence consumption activities, including 

those of the Walpole Island First Nation, would be negatively affected by the renewal of 

Fermi 2’s operating license. Significantly, the analysis presented addresses the potential 

consumption of contaminated foods by providing the sampling results from the REMP.

Based on the radiological environmental monitoring data from Fermi 2, the NRC finds that no 

disproportionately high and adverse human health impacts would be expected in special 

pathway receptor populations in the region as a result of subsistence consumption of water, 

local food, fish, and wildlife. Continued operation of Fermi 2 would not have disproportionately 

high and adverse human health and environmental effects on these populations.

4.12.2 No-Action Alternative

This section evaluates the potential for disproportionately high and adverse human health and 

environmental effects on U.S. minority and low-income populations that could result from the 

no-action alternative. Impacts on U.S. minority and low-income populations would depend on 

the number of jobs and the amount of tax revenues lost by communities in the immediate 

vicinity of the power plant after Fermi 2 ceases operations. Not renewing the operating license 
Environmental Consequences and Mitigating Actions

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and terminating reactor operations would have a noticeable impact on socioeconomic conditions 

in the communities located near Fermi 2. The loss of jobs and income would have an 

immediate socioeconomic impact. Some, but not all, of the approximately 890 employees 

would begin to leave after reactor operations are terminated, and overall tax revenue generated 

by plant operations would be reduced. The reduction in tax revenue would decrease the 

availability of public services in Monroe County. This decrease in the availability of services 

could disproportionately affect minority and low-income populations that may have become 

dependent on these services. (See also Appendix J to NUREG–0586, Supplement 1 

(NRC 2002b), for additional discussion of these impacts.)

4.12.3 NGCC Alternative

This section evaluates the potential for disproportionately high and adverse human health and 

environmental effects on U.S. minority and low-income populations that could result from the 

construction and operation of a new NGCC plant. Some of these potential effects have been 

identified in resource areas discussed in this SEIS. For example, increased demand for rental 

housing during replacement power plant construction could disproportionately affect low-income 

populations. Everyone living near the proposed power plant site could be affected by the 

construction and operation of a new NGCC power plant, including minority and low-income 

populations.

Potential impacts to U.S. minority and low-income populations from the construction and 

operation of a new NGCC plant at the Fermi site would mostly consist of environmental and 

socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 

dust impacts from construction would be short term and primarily limited to onsite activities. 

Minority and low-income populations residing along site access roads would be affected by 

increased commuter vehicle traffic during shift changes and truck traffic. However, these effects 

would be temporary during certain hours of the day and would not likely be high and adverse. 

Increased demand for rental housing during construction could affect low-income populations in 

the vicinity of the Fermi site. However, given the proximity of Fermi 2 to the Detroit and Toledo 

metropolitan areas, many construction workers could commute to the site, thereby reducing the 

potential demand for rental housing.

Emissions from the NGCC plant during power plant operations could disproportionately affect 

U.S. minority and low-income populations living in the vicinity of the new power plant. However, 

permitted air emissions are expected to remain within regulatory standards.

Based on this information and on the analysis of human health and environmental impacts 

presented in this SEIS, the construction and operation of a new NGCC plant would not likely 

have disproportionately high and adverse human health and environmental effects on 

U.S. minority and low-income populations. However, this determination would depend on the 

location, plant design, and operational characteristics of the new power plant. Therefore, the 

NRC cannot determine whether this alternative would result in disproportionately high and 

adverse human health and environmental effects on minority and low-income populations.

4.12.4 IGCC Alternative

This section evaluates the potential for disproportionately high and adverse human health and 

environmental effects on U.S. minority and low-income populations that could result from the 

construction and operation of a new IGCC power plant. Some of these potential effects have 

been identified in resource areas discussed in this SEIS. For example, increased demand for 

rental housing during replacement power plant construction could disproportionately affect 

low-income populations. Everyone living near the proposed power plant site could be affected 
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by the construction and operation of a new IGCC power plant, including minority and 

low-income populations.

Potential impacts to U.S. minority and low-income populations from the construction and 

operation of a new IGCC plant at the Fermi site would consist of environmental and 

socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 

dust impacts from construction would be short term and primarily limited to onsite activities. 

Minority and low-income populations residing along site access roads would be affected by 

increased commuter vehicle traffic during shift changes and truck traffic. However, these effects 

would be temporary during certain hours of the day and would not likely be high and adverse. 

Increased demand for rental housing during construction could affect low-income populations. 

However, given the proximity of some existing power plant sites to the Detroit and Toledo 

metropolitan areas, many construction workers could commute to the site, thereby reducing the 

potential demand for rental housing.

Emissions from the IGCC plant during power plant operations could disproportionately affect 

U.S. minority and low income populations. However, permitted air emissions are expected to 

remain within regulatory standards.

Based on this information and the analysis of human health and environmental impacts 

presented in this SEIS, the construction and operation of a new IGCC plant would not likely 

have disproportionately high and adverse human health and environmental effects on 

U.S. minority and low-income populations. However, this determination would depend on the 

location, plant design, and operational characteristics of the new power plant. Therefore, the 

NRC cannot determine whether this alternative would result in disproportionately high and 

adverse human health and environmental effects on minority and low-income populations.

4.12.5 New Nuclear Alternative

This section evaluates the potential for disproportionately high and adverse human health and 

environmental effects on U.S. minority and low-income populations that could result from the 

construction and operation of a new nuclear power plant. Some of these potential effects have 

been identified in resource areas discussed in this SEIS. For example, increased demand for 

rental housing during replacement power plant construction could disproportionately affect 

low-income populations. Everyone living near the proposed power plant site could be affected 

by the construction and operation of a new nuclear power plant, including minority and 

low-income populations.

Potential impacts to U.S. minority and low-income populations from the construction and 

operation of a new nuclear power plant at the Fermi site would mostly consist of environmental 

and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise 

and dust impacts from construction would be short term and primarily limited to onsite activities. 

Minority and low-income populations residing along site access roads would be affected by 

increased commuter vehicle traffic during shift changes and truck traffic. However, these effects 

would be temporary during certain hours of the day and would not likely be high and adverse. 

Increased demand for rental housing during construction could affect low-income populations. 

However, given the proximity of some existing nuclear power plant sites to the Detroit and 

Toledo metropolitan areas, many construction workers could commute to the site, thereby 

reducing the potential demand for rental housing.

Potential impacts to U.S. minority and low-income populations from new nuclear power plant 

operations would mostly consist of radiological effects; however, radiation doses are expected 

to be well below regulatory limits. All people living near the nuclear power plant would be 
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exposed to the same potential effects from power plant operations, and permitted air emissions 

are expected to remain within regulatory standards.

Based on this information and the analysis of human health and environmental impacts 

presented in this SEIS, the construction and operation of a new nuclear power plant would not 

likely have disproportionately high and adverse human health and environmental effects on 

U.S. minority and low-income populations. However, this determination would depend on the 

location, plant design, and operational characteristics of the new power plant. Therefore, the 

NRC cannot determine whether this alternative would result in disproportionately high and 

adverse human health and environmental effects on minority and low-income populations.

4.12.6 Combination Alternative (NGCC, Wind, and Solar)

This section evaluates the potential for disproportionately high and adverse human health and 

environmental effects on U.S. minority and low-income populations that could result from the 

construction and operation of a combination of NGCC, wind, and solar PV electrical 

power-generating activities. Some of these potential effects have been identified in resource 

areas discussed in this SEIS. For example, increased demand for rental housing during 

construction could disproportionately affect low-income populations. Everyone living near the 

new NGCC, wind farms, and solar PV installations could be affected by construction activities 

and facility operations, including minority and low-income populations.

Potential impacts to U.S. minority and low-income populations from the construction and 

operation of a new NGCC plant, wind turbines, and solar PV installations would mostly consist 

of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing 

impacts). Noise and dust impacts from construction would be short term and primarily limited to 

onsite activities. Minority and low-income populations residing along site access roads would 

be affected by increased commuter vehicle traffic during shift changes and truck traffic. 

However, these effects would be temporary during certain hours of the day and would not likely 

be high and adverse. Increased demand for rental housing during construction could affect 

low-income populations. However, given the small number of construction workers and the 

possibility that many workers could commute to these construction sites, the potential need for 

rental housing would not be significant.

Minority and low-income populations living in close proximity to wind farm and solar PV

power-generating installations could be disproportionately affected by maintenance and 

operations activities. However, operational impacts from the wind turbines and solar PV

installations would mostly be limited to noise and aesthetic effects.

Based on this information and on the analysis of human health and environmental impacts 

presented in this SEIS, the construction and operation of a new NGCC plant, wind farms, and 

solar PV installations would not likely have disproportionately high and adverse human health 

and environmental effects on U.S. minority and low-income populations. However, this 

determination would depend on the location, plant design, and operational characteristics of 

these new power-generating facilities. Therefore, the NRC cannot determine whether this 

alternative would result in disproportionately high and adverse human health and environmental 

effects on minority and low-income populations.

4.13 Waste Management and Pollution Prevention

This section describes the potential impacts of the proposed action (license renewal) and 

alternatives to the proposed action on waste management and pollution prevention.
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4.13.1 Proposed Action

The waste management issues applicable to Fermi 2 are discussed below and listed in

Table 4–17. Table B–1 of Appendix B to Subpart A of 10 CFR Part 51 contains more 

information on these issues.

Waste Management Issues

Issue GEIS Section Category

Low-level waste storage and disposal 4.11.1.1 1

Onsite storage of spent nuclear fuel 4.11.1.2(a) 1

Offsite radiological impacts of spent nuclear fuel and high-level waste

disposal

4.11.1.3(b) 1

Mixed-waste storage and disposal 4.11.1.4 1

Nonradioactive waste storage 4.11.1.5 1

(a) The environmental impact of this issue for the timeframe beyond the licensed life for reactor operations is 

discussed in NUREG–2157 (NRC 2014e).

(b) The technical feasibility of disposal in a geologic repository is discussed in NUREG–2157 (NRC 2014e).

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

The NRC staff’s evaluation of the environmental impacts associated with spent nuclear fuel is 

addressed in two issues in Table 4–17, “Onsite storage of spent nuclear fuel,” and “Offsite 

radiological impacts of spent nuclear fuel and high-level waste disposal.” The onsite storage of 

spent nuclear fuel issue now incorporates the generic environmental impact determinations 

codified in Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 and in the revision to 

10 CFR 51.23 pursuant to the Continued Storage Rule (79 FR 56238). The offsite radiological 

impacts of spent nuclear fuel and high-level waste disposal issue are codified in Table B–1 in 

Appendix B, Subpart A, to 10 CFR Part 51, and the technical feasibility of disposal in a geologic 

repository is discussed in NUREG–2157, Generic Environmental Impact Statement for 

Continued Storage of Spent Nuclear Fuel (NRC 2014e). For this issue, the Commission 

concludes that the impacts would not be sufficiently large to require the NEPA conclusion, for 

any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the Commission has not assigned a single level of significance for the 

impacts of spent fuel and high level waste disposal, this issue is considered Category 1.

The NRC staff did not identify any new and significant information related to waste management 

issues listed in Table 4–17 during its review of the applicant’s ER (DTE 2014a), the site visit, or 

the scoping process. Therefore, there are no impacts related to these issues beyond those 

discussed in the GEIS (NRC 2013d) and in Volumes 1 and 2 of NUREG–2157 (NRC 2014e). 

During the license renewal term, the GEIS concludes that the impacts for these Category 1 

issues are SMALL.

4.13.2 No-Action Alternative

If the no-action alternative were implemented, Fermi 2 would cease operation no later than the 

end of the initial operating license and would enter decommissioning. Fermi 2 would cease to 

generate spent nuclear fuel and would emit less gaseous and liquid radioactive effluents into the 

environment than those emitted during operation. In addition, following shutdown, the variety of 

potential accidents at the plants (radiological and industrial) would be reduced to a limited set 
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associated with shutdown events and fuel handling and storage. In Section 4.15.2 of this SEIS,

the NRC staff concludes that the impacts from decommissioning would be SMALL. Therefore, 

as radioactive emissions to the environment decrease and as the likelihood and variety of 

accidents decrease following shutdown and decommissioning, the NRC staff concludes that 

impacts from implementation of the no-action alternative would be SMALL.

4.13.3 NGCC Alternative

Construction-related debris would be generated during plant construction activities and would 

be recycled or disposed of in approved landfills.

Waste generation from NGCC technology would be minimal. The only significant waste 

generated at a NGCC power plant would be spent selective catalytic reduction (SCR) catalyst, 

which is used to control nitrogen oxide emissions.

The spent SCR catalyst would be regenerated or disposed of offsite in approved landfills. Other 

than the spent SCR catalyst, waste generation at an operating natural gas-fired plant would be 

limited largely to typical operations and maintenance nonhazardous waste. Overall, the NRC 

staff concludes that waste impacts from the NGCC alternative would be SMALL.

4.13.4 IGCC Alternative

Construction-related debris would be generated during plant construction activities and would 

be recycled or disposed of in approved landfills.

Coal combustion generates waste in the form of fly ash and bottom ash. In addition, equipment 

for controlling air pollution generates additional ash, spent SCR catalyst, and scrubber sludge. 

The management and disposal of the large amounts of coal combustion waste is a significant 

part of the operation of a coal-fired power-generating facility.

Although a coal facility is likely to use offsite disposal of coal combustion waste, some 

short-term storage of coal combustion waste (either in open piles or in surface impoundments) 

is likely to take place on site, thus establishing the potential for leaching of toxic chemicals into 

the local environment.

The impacts of managing the significant amounts of solid waste, especially fly ash and scrubber 

sludge generated during operation of this alternative, would be significant (NRC 1996). The 

amount of the construction waste would be small compared to the amount of waste generated 

during the operational stage, and much of it could be recycled (i.e., marketed for beneficial use). 

Therefore, the NRC staff concludes that the overall waste management impacts from 

construction and operation of this alternative would be MODERATE.

4.13.5 New Nuclear Alternative

Construction-related debris would be generated during construction activities and would be

recycled or disposed of in approved landfills. During normal plant operations, routine plant

maintenance and cleaning activities would generate low-level radioactive waste, spent nuclear

fuel, high-level radioactive waste, and nonradioactive waste. Sections 3.1.4 and 3.1.5 of this 

SEIS discuss radioactive and nonradioactive waste management at Fermi 2. Quantities of 

radioactive and nonradioactive waste generated from the operation of a new nuclear power 

plant would be similar to that generated by Fermi 2. According to the GEIS (NRC 2013d), the 

generation and management of radioactive and nonradioactive solid waste during the license 

renewal term are not expected to result in significant environmental impacts. Therefore, the

waste impacts from the operation of a new nuclear power plant alternative would be SMALL.
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4.13.6 Combination Alternative (NGCC, Wind, and Solar)

Construction-related debris would be generated during construction activities and would be 

recycled or disposed of in approved landfills.

Waste generation from NGCC technology is discussed in Section 4.13.3, and the impacts would 

be SMALL.

Waste generation from a combination of wind and solar PV technologies would be minimal, 

consisting of debris from routine maintenance and the disposal of worn or broken parts. Based 

on this information, the NRC staff concludes that waste impacts from the construction and 

operation of a combination NGCC, wind, and solar PV alternative would be SMALL.

4.14 Evaluation of New and Potentially Significant Information

New and significant information is information that must be new, based on a review of the GEIS

(NRC 2013d) and codified in Table B–1 of Appendix B to Subpart A of 10 CFR Part 51, and 

must bear on the proposed action or its impacts, presenting a seriously different picture of the 

impacts from those envisioned in the GEIS (i.e., impacts of greater severity than impacts 

considered in the GEIS, considering their intensity and context).

In accordance with 10 CFR 51.53(c), the ER that the applicant submits must provide an analysis 

of the Category 2 issues in Table B–1 of Appendix B to Subpart A of 10 CFR Part 51. 

Additionally, it must discuss actions to mitigate any adverse impacts associated with the 

proposed action and environmental impacts of alternatives to the proposed action. In 

accordance with 10 CFR 51.53(c)(3), the ER does not need to contain an analysis of any 

Category 1 issue unless there is new and significant information on a specific issue.

The NRC process for identifying new and significant information is described in NUREG–1555,

Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: 

Operating License Renewal (NRC 2013e). The search for new information includes the 

following activities:

• review of an applicant’s ER and the process for discovering and evaluating the 

significance of new information;

• review of public comments;

• review of environmental quality standards and regulations;

• coordination with Federal, state, local, and tribal environmental protection and 

resource agencies; and

• review of the technical literature.

New information that the NRC staff discovers is evaluated for significance using the criteria set 

forth in the GEIS. For Category 1 issues in which new and significant information is identified, 

reconsideration of the conclusions for those issues is limited in scope to assessment of the 

relevant new and significant information; the scope of the assessment does not include those

facets of an issue that are not affected by the new information.

The NRC staff reviewed the discussion of environmental impacts associated with operation 

during the renewal term in the GElS and has conducted its own independent review, including a 

public involvement process (e.g., public meetings) to identify new and significant issues for the 

Fermi 2 license renewal application environmental review. Based on its review of available 

information and on comments provided during the scoping period, the NRC staff identified new 
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and potentially significant information relevant to the following three environmental issues

related to operation of Fermi 2 during the renewal term: (1) bird collisions with plant structures, 

(2) algal blooms in Lake Erie, and (3) the effects of radiation exposures to the public. The NRC 

staff’s evaluation of this information follows.

Bird Collisions with Plant Structures

Regarding the Category 1 issue, “Bird collisions with plant structures and transmission lines,” 

the NRC staff reviewed the licensee’s bird collision records for the past 10 years (2005 to 2014) 

and bird strike surveillance data from 2008 and 2009. These records are summarized in 

Section 3.6.6. Aside from two larger bird collision events (50 birds in 1973 and 45 birds in 

October 2007), DTE has relatively few records of bird collisions with plant structures or 

transmission lines, and these records indicate that impacts fall well within those discussed in 

Section 4.6.1.1 of the GEIS for this issue. None of DTE’s records include Federally or 

State-listed species. Additionally, DTE has implemented some measures at Fermi 2 that were 

determined to reduce bird collision hazards during consultations between DTE, the FWS, and 

the Federal Aviation Administration for the proposed Fermi 3. These measures include 

installation of flashing strobe lights on the top of the cooling towers (DTE 2014c). DTE (2014c) 

is also in the process of developing a company-wide program to reduce operational risks 

resulting from avian and bat collisions. The program is based on an avian protection plan from 

the Avian Powerline Interaction Committee and on conversations with FWS personnel at the 

Lansing, Michigan, office (DTE 2014c). The program will address changes that are needed to 

prevent avian or bat fatalities and will require documentation of bird or bat strikes to help 

DTE (2014c) determine whether reporting to local, State, or Federal agencies is required. 

DTE (2014c) expects to begin implementation of the program in early 2015. The NRC staff 

concludes that DTE’s bird strike information does not constitute new and significant information 

that would change the GEIS’s conclusion of SMALL for this issue.

Algal Blooms in Lake Erie

During the scoping period for Fermi 2, the NRC received several public comments expressing 

concern regarding the role of Fermi’s effluent on harmful algal blooms. Toledo’s drinking water 

crises in August 2014 has raised public concern over large harmful algal blooms in Lake Erie, 

which has been increasingly susceptible to such blooms since 2002 (University of 

Michigan 2014). Fermi lies about halfway between Toledo, Ohio, and Detroit, Michigan, on the 

shore of the western basin of Lake Erie—the lake basin where the algal blooms have been most 

prominent. The public interest in these blooms and the possible role of temperature increases 

in extending or exacerbating Lake Erie algal blooms constitute new information that the GEIS

had not considered.

Algae are natural components of freshwater ecosystems, and when conditions are favorable, 

they can rapidly multiply and cause “blooms.” Favorable conditions for algal blooms include 

eutrophication, one definition of which is: 

[Eutrophication is] the enrichment of bodies of fresh water by inorganic plant 

nutrients (e.g., nitrate, phosphate). It may occur naturally but can also be the 

result of human activity (cultural eutrophication from fertilizer runoff and sewage 

discharge) and is particularly evident in slow-moving rivers and shallow lakes 

[USGS 2014].

One group of algae, the cyanobacteria (called blue-green algae in the past), has members that 

can produce toxins that can have harmful effects on people and natural resources (EPA 2014d). 

These toxins are produced and contained internally in the cyanobacterial cells and are released 

during the death and rupture of the cells (EPA 2014c). The most commonly occurring genera 

that produce such toxins are Microcystis, Anabaena, and Planktothrix (also called Oscillatoria), 
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and the most commonly identified groups of cyanotoxins (toxins produced by cyanobacteria) 

identified in U.S. waters are microcystins, cylindrospermopsins, anatoxins, and saxitoxins 

(EPA 2014c). These toxins can cause skin irritations, liver and nerve damage, and 

gastrointestinal distress in humans; stress the structure and functioning of lake ecosystems; and 

adversely affect the aesthetics and ecological services that the lakes provide to people 

(EPA 2014c; Michalak et al. 2013; NOAA undated(c)). Detection of the microcystin toxins in the 

western basin of Lake Erie left nearly half a million Ohio and Michigan residents without drinking 

water for several days in early August 2014 (University of Michigan 2014).

Lake Erie is the shallowest, most biologically productive, and most southern of the Laurentian 

Lakes, and these factors have contributed to substantial eutrophication over the past half 

century, with concomitant nuisance algal blooms (Michalak et al. 2013). Although 

eutrophication is a natural process in lakes, it can be accelerated by human activities, 

particularly high phosphorus and nitrogen inputs, in a process known as cultural eutrophication 

(EPA 2014i). By the 1960s the public had recognized that Lake Erie was highly eutrophic due 

to recognizable symptoms such as large algal blooms, large areas of attached algae along 

shorelines, decomposing algae washing up on beaches, cyanobacteria causing taste and odor 

problems in water supplies, and low dissolved oxygen levels in deeper areas of the lake from 

decomposing algae (EPA 2014i). In response, the United States and Canada signed the 

Great Lakes Water Quality Agreement in 1972 to reduce phosphorus inputs to the Great Lakes,

which resulted in better water quality and large algal blooms of decreasing intensity and 

frequency by the 1970s.

In the 1980s, two invasive nuisance species of Asiatic clams, zebra and quagga mussels, were 

introduced into the Great Lakes and caused dramatic food web changes because of their 

numbers and ability to remove planktonic algae from the water through their filter feeding. In 

Lake Erie, algal production switched from phytoplankton to bottom-dwelling plants and algae, 

and water clarity increased. By the 1990s, large algal blooms began to reappear in western 

Lake Erie, and the frequency and intensity of the blooms has increased since then. Massive 

blooms of the cyanobacteria genus Microcystis occurred in the western Lake Erie basin in 

the 2000s in the area offshore of the Detroit and Maumee Rivers (EPA 2014i).

The Lake Erie ecosystem is complicated and poorly understood. The recent algal blooms may 

be linked to nutrient loading, nutrient releases by zebra mussels, and selective feeding by zebra 

mussels (EPA 2014i). Very large algal blooms occurred in western Lake Erie in 2003, 2006, 

2009, 2011, and 2014.

Bridgeman et al. (2012) studied the algal bloom of 2009 involving the cyanobacteria 

Mycrocystis, which is planktonic, and the then newly emergent cyanobacteria Lyngbia wollei, 

which forms mats on the lake bottom. They found that the Maumee River had higher 

concentrations of phosphorus than Lake Erie, that significant populations of Microcystis develop 

in the river before developing in the lake, and that the Maumee River may be a major source not 

only of nutrients that feed the blooms but also of the Microcystis seed populations that develop 

into blooms. 

A subsequent cyanobacterial bloom of record-setting magnitude and duration occurred in 

western Lake Erie in 2011. The bloom was initially composed almost entirely of Microcystis, 

which then declined and was replaced by Anabaena sp. (another potentially toxic 

cyanobacteria) in a secondary bloom. Michalak et al. (2013) investigated possible causes of the 

bloom, including increases in agricultural nonpoint sources of bioavailable phosphorus; the 

presence of invasive mussel species, specifically Dreissena rostriformis bugensis (quagga 

mussels) and D. polymorpha (zebra mussels); and internal phosphorus loading to Lake Erie’s 

central basin that increases in response to hypoxic conditions. They attributed the intensity and 
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duration of that algal bloom to long-term trends in agricultural land usage that has resulted in 

increased phosphorus loads and decreased wind speeds that caused weak lake circulation and 

warm and quiescent lake conditions. Temperature and mixing conditions are important in 

promoting these blooms because cyanobacteria have a higher temperature optimum (around 

25 °C (77 °F)) than that of eukaryotic phytoplankton, and temperature-dependent gas vacuoles 

increase Microcystis buoyancy, which causes them to rise to more favorable light and 

temperature conditions under quiescent lake conditions. They also predict that if the long-term 

trends in agricultural land use and trends in climate change continue (such as decreasing wind 

speeds that weaken lake circulation), such blooms may become more common in the future. 

The NPDES permit for Fermi 2 authorizes a maximum discharge to Lake Erie of 45.1 mgd 

(171,000 m3

/day) of cooling tower blowdown, processed radioactive wastewater, residual heat 

removal system service water, chemical metal cleaning wastes, and nonchemical metal 

cleaning wastes through Outfall 001 (DTE 2014a). The temperature of the discharge water is 

typically about 18 °F (10 °C) higher than that of the intake water, and the NPDES permit has no 

numerical temperature limits for this outfall other than daily reporting (DTE 2014a). The plant 

extracts cooling water from Lake Erie and presently does not add phosphorus or nitrogen 

compounds, so that the cooling water system adds no net loading of these plant nutrients to the 

lake (DTE 2014a). Water evaporates from the closed cycle cooling system and cooling pond, 

however, and so concentrations of these plant nutrients will be higher in the effluent than in the 

intake. The NPDES permit has no numerical limits on nitrogen and phosphorus compounds for 

Outfall 001.

Lowe (2012) assessed possible discharge effects on cyanobacteria for the proposed Fermi 3 

discharge, which is close to the present Fermi 2 discharge. Lowe reports that, in 

September 2011, 10 replicate petite Ponar grab samples of lake bottom were collected near the 

Fermi 2 discharge and at the proposed Fermi 3 diffuser outlet, and subsamples of about 2 to 

4 cubic centimeters (0.12 to 0.24 cubic inch) from each grab were examined for benthic algae. 

Lowe found no evidence of Lyngbya mats. The algal communities were heavily dominated by 

diatoms and represented “a typical and healthy [italics in original] assemblage of benthic algal 

community.” Mycrocystis, a potentially toxic species, was present in these benthic samples at 

low levels of about “four units out of 10,000 algal units counted.” Mycrocystis is a planktonic 

species, not a benthic species, and the NRC staff is unaware of any clear relationship between 

planktonic concentrations and benthic concentrations for this species. Lowe also reports that he 

reviewed ship and dive logs from a Detroit Edison Energy research vessel and Scuba dive team 

that has sampled for the REMP since the plant began operation. The REMP program requires 

sediment sampling in the spring and fall of each year. Lowe found that “logs contained no 

notations about the appearance/occurrence of algal mats at Fermi 2 REMP sediment sampling 

sites.” Lowe also interviewed the company divers and found that “[b]ased on visual (naked eye) 

inspection, they confirmed the absence of algae at nuisance levels in the vicinity of Fermi 2.” 

Lowe concludes that “Lyngbya and other nuisance algal species are not present at the current 

Fermi 2 discharge location” and that the “samples indicated that a healthy algal community 

typical of sandy-bottom areas of Lake Erie was present with no evidence of Lyngbya wollei.”

The Fermi 2 discharge is warmer than, and contains somewhat higher concentrations of 

nitrogen and phosphorus compounds than, the ambient intake water of Lake Erie. 

Conceptually, these conditions might extend the duration and intensity of harmful algal blooms 

locally at the effluent. The affected area would be limited, however, due to mixing and diffusion, 

and harmful algal blooms at the Fermi 2 discharge have not been reported from empirical 

observation. This information does not contradict the conclusion on page 4-98 of the GEIS

(NRC 2013d), which states, “Impacts of thermal discharges on the geographic distribution of 

aquatic organisms are considered to be of SMALL significance if populations in the overall 
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region are not reduced. This is because heat is usually dissipated rapidly from power plant 

discharge plumes, and heated plumes are often small relative to the size of the receiving water 

body.”

The NRC staff has reviewed new site-specific information regarding the possible effects of the 

Fermi 2 discharge on harmful algae blooms in Lake Erie. The information does not contradict 

the generic conclusion of the GEIS that the level of impact would be SMALL.

The Effects of Radiation Exposures to the Public

During the scoping process, the NRC staff received information in the form of a report (the 

RPHP report described in Section 4.11.1.1) that members of the public claim shows increases 

in cancer and mortalities in Monroe County, Michigan, attributable to the operation of Fermi 2. 

The RPHP report contains data on demographic characteristics, types of cancers, death rates, 

and cancer death rates for selected time periods reported for Monroe County, Michigan; the 

State of Michigan; and the United States. Additionally, the RPHP report contains selected data 

on radioactive effluent releases from Fermi 2 and other U.S. nuclear power plants.

Based on the NRC staff’s review, the report is a compilation of selected data from publically 

available documents. The data do not provide a technical basis linking the cancer and death 

rate data to the radiological impacts from the operations of the Fermi 2 plant. The NRC staff 

found that the RPHP report does not contain information to determine the cause of the cancers.

The NRC staff reviewed the radiation doses to members of the public from radioactive effluent 

releases from the Fermi 2 plant in Section 3.1.4 of this SEIS. Based on its review, the NRC 

staff concluded that the dose to members of the public was within the NRC’s dose limits in 

10 CFR Part 20.

In addition, the NRC staff evaluated data from Fermi 2’s REMP in Section 3.1.4 of this SEIS. 

The REMP monitors the local environment around the Fermi site, starting before the plant 

operates to establish background radiation levels and continuing throughout its operating 

lifetime. The REMP provides a mechanism for determining the levels of radioactivity in the 

environment to determine whether there is any buildup of radioactivity from plant operations. 

The REMP also measures radioactivity from other nuclear facilities that may be in the area 

(i.e., other nuclear power plants, hospitals using radioactive material, research facilities, or any 

other facility licensed to use radioactive material) and from natural background radiation and 

fallout from atomic weapons testing and nuclear accidents. Thus, the REMP monitors the 

cumulative impacts from all sources of radioactivity in the vicinity of Fermi 2. Based on its 

review of Fermi 2’s REMP, the NRC staff concluded that there was no indication of an adverse 

trend (i.e., increased buildup) in radioactivity levels in the area and that there is no measurable 

impact to the environment from operations at Fermi 2.

The NRC staff does not agree that the RPHP report contains information that supports that 

there are significant radiological impacts associated with Fermi 2 operations greater than those 

determined in the GEIS. This conclusion is based on the NRC staff’s review of radiological data 

from Fermi 2 (Section 3.1.4). Therefore, as discussed in Section 4.11.1 of this SEIS, the 

radiological impact to human health (i.e., radiation exposures to the public) remains a 

Category 1 issue with a SMALL impact.

4.15 Impacts Common to All Alternatives

This section describes the impacts that are considered common to all alternatives discussed in 

this SEIS, including the proposed action and replacement power alternatives. The continued 

operation of a nuclear power plant and replacement fossil fuel power plants both involve mining, 
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processing, and the consumption of fuel that result in comparative impacts (NRC 2013d). In 

addition, the following sections discuss termination of operations and the decommissioning of 

both a nuclear power plant and replacement fossil fuel power plants and GHG emissions.

4.15.1 Fuel Cycle

This section describes the environmental impacts associated with the fuel cycles of the 

proposed action and replacement power alternatives. Most replacement power alternatives 

employ a set of steps in the use of their fuel sources, which can include extraction, 

transformation, transportation, and combustion. Emissions generally occur at each stage of the 

fuel cycle (NRC 2013d).

4.15.1.1 Uranium Fuel Cycle

The uranium fuel cycle issues applicable to Fermi 2 are discussed below and are listed in

Table 4–18 for Category 1 issues. Table B–1 of Appendix B to Subpart A of 10 CFR Part 51 

contains more information on these issues.

Issues Related to the Uranium Fuel Cycle

Issue GEIS Section Category

Offsite radiological impacts—individual impacts from other than the 

disposal of spent fuel and high-level waste

4.12.1.1 1

Offsite radiological impacts—collective impacts from other than the 

disposal of spent fuel and high-level waste

4.12.1.1 1

Nonradiological impacts of the uranium fuel cycle 4.12.1.1 1

Transportation 4.12.1.1 1

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

The uranium fuel cycle includes uranium mining and milling, the production of uranium 

hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation 

of radioactive materials, and management of low-level wastes and high-level wastes related to 

uranium fuel cycle activities. The generic potential impacts of the radiological and 

nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear 

fuel and wastes are described in detail in NUREG–1437 (NRC 1996, 1999, 2013d).

The NRC staff did not identify any new and significant information related to the uranium fuel 

cycle issues listed in Table 4–18 during its review of the applicant’s ER (DTE 2014a), the site 

visit, and the scoping process. Therefore, there are no impacts related to these issues beyond 

those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the 

impacts are SMALL, except for the issue, “Offsite radiological impacts—collective impacts from 

other than the disposal of spent fuel and high-level waste,” to which the NRC has not assigned 

an impact level. This issue assesses the 100-year radiation dose to the U.S. population 

(i.e., collective effects or collective dose) from radioactive effluent released as part of the 

uranium fuel cycle for a nuclear power plant during the license renewal term compared to the 

radiation dose from natural background exposure. It is a comparative assessment for which 

there is no regulatory standard to base an impact level.
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4.15.1.2 Replacement Power Plant Fuel Cycles

Fossil Fuel Energy Alternatives

Fuel cycle impacts for a fossil fuel-fired plant result from the initial extraction of fuel, cleaning 

and processing of fuel, transport of fuel to the facility, and management and ultimate disposal of 

solid wastes from fuel combustion. These impacts are discussed in more detail in 

Section 4.12.1.2 of the GEIS (NRC 2013d) and can generally include the following:

• significant changes to land use and visual resources;

• impacts to air quality, including release of criteria pollutants, fugitive dust, VOCs, and 

coalbed methane in the atmosphere;

• noise impacts;

• geology and soil impacts due to land disturbances and mining;

• water resource impacts, including degradation of surface water and groundwater

quality;

• ecological impacts, including loss of habitat and wildlife disturbances;

• historic and cultural resources impacts within the mine footprint;

• socioeconomic impacts from employment of both the mining workforce and service 

and support industries;

• environmental justice impacts;

• health impacts to workers from exposure to airborne dust and methane gases; and

• generation of coal and industrial wastes.

New Nuclear Energy Alternatives

Uranium fuel cycle impacts for a nuclear plant result from the initial extraction of fuel, transport 

of fuel to the nuclear plant, and management and ultimate disposal of spent fuel. The 

environmental impacts of the uranium fuel cycle are discussed in Section 4.15.1.1.

Renewable Energy Alternatives

The term “fuel cycle” has varying degrees of relevance for renewable energy facilities. The term 

has meaning for renewable energy technologies that rely on combustion of fuels, such as 

biomass grown or harvested for the express purpose of power production. The term is 

somewhat more difficult to define for renewable technologies, such as wind, solar, geothermal, 

and ocean wave and current. Those natural energy resources exist regardless of any effort to 

harvest them for electricity production. The common technological strategy for harvesting 

energy from such natural resources is to convert the kinetic or thermal energy inherent in that 

resource to mechanical energy or torque. The torque is then applied directly (e.g., as in the 

case of a wind turbine) or indirectly (e.g., for those facilities that use conventional steam cycles 

to drive turbines that drive generators) to produce electricity. However, because those 

renewable technologies capture very small fractions of the total kinetic or thermal energy 

contained in those resources, impacts from the presence or absence of the renewable energy 

technology are often indistinguishable (NRC 2013d).
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4.15.2 Terminating Power Plant Operations and Decommissioning

This section describes the environmental impacts associated with the termination of operations 

and the decommissioning of a nuclear power plant and replacement power alternatives. All 

operating power plants will terminate operations and be decommissioned at some point after the 

end of their operating life or after a decision is made to cease operations. For the proposed 

action, license renewal would delay this eventuality for an additional 20 years beyond the 

current license period, which ends in 2025.

4.15.2.1 Existing Nuclear Power Plant

Environmental impacts from the activities associated with the decommissioning of any reactor

before or at the end of an initial or renewed license are evaluated in Supplement 1 of 

NUREG–0586 (NRC 2002b). Additionally, the GEIS discusses the incremental environmental 

impacts associated with decommissioning activities resulting from continued plant operation 

during the renewal term.

Table 4–19 lists the Category 1 issue in Table B–1 of Appendix B to Subpart A of 

10 CFR Part 51 that is applicable to Fermi 2 decommissioning following the license renewal 

term.

Issues Related to Decommissioning

Issue GEIS Section Category

Termination of plant operations and decommissioning 4.12.2.1 1

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

Decommissioning would occur whether Fermi 2 were shut down at the end of its current 

operating license or at the end of the license renewal term. In its ER, DTE stated that it is not 

aware of any new and significant information on the environmental impacts of Fermi 2 during 

the license renewal term (DTE 2014a). The NRC staff has not found any new and significant 

information during its independent review of DTE’s ER, the site visit, or the scoping process. 

Therefore, the NRC staff concludes that there are no impacts related to this issue beyond those 

discussed in the GEIS. For this issue, the NRC staff concluded in the GEIS that the impacts are 

SMALL.

4.15.2.2 Replacement Power Plants

Fossil Fuel Energy Alternatives

The environmental impacts from the termination of power plant operations and 

decommissioning of a fossil fuel-fired plant are dependent on the facility’s decommissioning 

plan. General elements and requirements for a fossil fuel plant decommissioning plan are 

discussed in Section 4.12.2.2 of the GEIS and can include the removal of structures to at least 

3 ft (1 m) below grade; removal of all coal, combustion waste, and accumulated sludge; removal 

of intake and discharge structures; and the cleanup and remediation of incidental spills and 

leaks at the facility. The decommissioning plan outlines the actions necessary to restore the 
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site to a condition equivalent in character and value to the site on which the facility was first 

constructed (NRC 2013d).

The environmental consequences of decommissioning are discussed in Section 4.12.2.2 of the 

GEIS and can generally include the following:

• short-term impacts on air quality and noise from the deconstruction of facility 

structures,

• short-term impacts on land use and visual resources,

• long-term reestablishment of vegetation and wildlife communities,

• socioeconomic impacts due to decommissioning the workforce and the long-term 

loss of jobs, and

• elimination of health and safety impacts on operating personnel and general public.

New Nuclear Alternatives

Termination of operations and decommissioning impacts for a nuclear plant include all activities 

related to the safe removal of the facility from service and the reduction of residual radioactivity 

to a level that permits release of the property under restricted conditions or unrestricted use and 

termination of a license (NRC 2013d). The environmental impacts of the uranium fuel cycle are 

discussed in Section 4.15.1.1.

Renewable Alternatives

Termination of power plant operation and decommissioning for renewable energy facilities 

would be similar to the impacts discussed for fossil fuel-fired plants above. Decommissioning 

would involve the removal of facility components and operational wastes and residues to restore 

the site to a condition equivalent in character and value to the site on which the facility was first 

constructed (NRC 2013d).

4.15.3 Greenhouse Gas Emissions and Climate Change

The following sections discuss GHG emissions released from operation of Fermi 2 and the 

environmental impacts that could occur from changes in climate conditions. The cumulative 

impacts of GHG emissions on climate are discussed in Section 4.16.11.

4.15.3.1 Greenhouse Gas Emissions from the Proposed Project and Alternatives

Gases found in the Earth’s atmosphere that trap heat and play a role in Earth’s climate are 

collectively termed GHGs. GHGs include carbon dioxide, methane, nitrous oxide (N2O), water 

vapor, and fluorinated gases such as hydrofluorocarbons, perfluorocarbons, and sulfur 

hexafluoride (SF6). The Earth’s climate responds to changes in concentration of GHGs in the 

atmosphere because GHGs affect the amount of energy absorbed and heat trapped by the 

atmosphere. Increasing GHG concentration in the atmosphere generally increases Earth’s 

surface temperature. Atmospheric concentrations of carbon dioxide, methane, and nitrous 

oxide have significantly increased since 1750 (IPCC 2007a). Carbon dioxide, methane, nitrous 

oxide, water vapor, and fluorinated gases (termed long-lived GHGs) are well mixed throughout 

the Earth’s atmosphere, and their impact on climate is long lasting as a result of their long 

atmospheric lifetime (EPA 2009a). Carbon dioxide is of primary concern for global climate 

change due to its long atmospheric lifetime, and it is the primary gas emitted as a result of 

human activities. Climate change research indicates that the cause of the Earth’s warming over 

the last 50 years is due to the buildup of GHGs in the atmosphere resulting from human 
Environmental Consequences and Mitigating Actions

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activities (USGCRP 2014). The EPA has determined that GHGs “may reasonably be 

anticipated both to endanger public health and to endanger public welfare” (74 FR 66496).

Proposed Action

Operation of Fermi 2 does not directly emit GHG emission because fossil fuel is not used to 

generate electricity. However, plant operations at Fermi 2 release GHG emissions (primarily 

carbon dioxide) from stationary combustion sources, such as auxiliary boilers, diesel 

generators, and combustion turbines on site. Other sources include mobile combustion sources 

(e.g., employee vehicles and nonroad equipment) and refrigerant appliances at Fermi 2 that

contain fluorinated gases (DTE 2014c). Fluorinated gases are typically emitted in small 

quantities but their impacts could be substantial because of their high global warming potential

(GWP).

Annual GHG emissions at Fermi 2 are presented in Table 4–20 for the 2009 to 2013 period. 

The GHG emissions presented include stationary combustion sources, mobile combustion 

sources, and refrigerant sources. The GHG emissions resulting from operations at Fermi are 

below the EPA’s threshold of 25,000 MT (27,558 tons) per year of CO2eq, which requires 

facilities to report GHG emissions to EPA annually in accordance with 40 CFR Part 98.

Estimated GHG Emissions from Operations at Fermi 2

Year

Stationary 

Combustion 

Related 

Sources(a)

(CO2eq MT/year)

Onsite 

Vehicles and 

Nonroad 

Equipment 

(CO2eq

MT/year)

Worker 

Vehicles

(CO2eq

MT/year)

Refrigerant 

Sources

(CO2eq

MT/year)

Total

(CO2eq

MT/year)(b)

2009 9,023 476 3,775 - 13,300

2010 9,193 496 3,775 - 13,500

2011 10,249 477 3,775 65 14,600

2012 5,498 317 3,775 - 9,600

2013 8,827 324 3,775 - 13,000

(a) These sources include emissions from diesel generator, combustion turbines, and auxiliary boiler.

(b) The values are rounded.

Key: CO2eq = carbon dioxide equivalents, and MT = metric ton.

Source: DTE 2014c

No-Action Alternative

As discussed in previous no-action alternative sections, the no-action alternative represents a 

decision by the NRC not to renew the operating license of a nuclear power plant beyond the 

current operating license term. At some point, all nuclear plants will terminate operations and 

undergo decommissioning. Under the no-action alternative, plant operations for Fermi 2 would 

terminate at or before the end of the current license. When the plant stops operating, a 

reduction in GHG emissions from activities related to plant operation, such as use of diesel 

generators and employee vehicles, will occur. GHG emissions are anticipated to be less than 

those presented in Table 4–20.
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NGCC Alternative

As discussed in Section 2.2.2.1, the NRC staff evaluated an NGCC alternative that consists of 

three 400-MWe units for a total of 1,200 MW. The GEIS presents lifecycle GHG emissions 

associated with natural gas power generation. As presented in Table 4.12-5 of the GEIS, 

lifecycle GHG emissions from natural gas can range from 120 to 930 grams (g) of carbon 

equivalent per kilowatt-hour (g Ceq/kWh). The NRC staff estimates that operation of the NGCC 

alternative directly will emit about 3.9 million tons of CO2eq per year (3.5 million MT/year).

IGCC Alternative

As discussed in Section 2.2.2.2, the NRC staff evaluated the IGCC plant alternative that would 

consist of two 618-MWe units for a total 1,236 MW. The GEIS presents lifecycle GHG 

emissions associated with coal power generation. As presented in Table 4.12-4 of the GEIS, 

lifecycle GHG emissions from coal power generation can range from 264 to 1,689 g Ceq/kWh. 

However, these lifecycle emission factors are for conventional coal power plants; recent studies 

report lifecycle GHG emissions for an IGCC estimate of 937 kg of CO2eq per megawatt-hour 

(937 g CO2eq/kWh) (NETL 2010b). The NRC staff estimates that operation of the IGCC 

alternative directly will emit about 6.9 million tons of CO2eq per year (6.2 million MT/year).

New Nuclear Alternative

As discussed in Section 2.2.2.3 the NRC staff evaluated the new nuclear power plant alternative 

that would consist of one ESBWR reactor with approximate generating capacity of 1,170 MWe. 

The GEIS presents lifecycle GHG emissions associated with nuclear power generation. As 

presented in Tables 4.12-4 through 4.12-6 of the GEIS, lifecycle15F

13 GHG emissions from nuclear 

power generation can range from 1 to 288 g Ceq/kWh. Operation of nuclear power plants does 

not burn fossil fuels to generate electricity and, therefore, does not directly emit GHG emissions. 

Sources of GHG emissions would include stationary combustion sources (e.g., diesel 

generators, auxiliary boilers, and combustion turbines) and mobile sources (e.g., worker 

vehicles, onsite heavy equipment, and support vehicles). As discussed in Section 4.3.5, it is 

anticipated that air emissions from a new nuclear power plant would be similar to those from 

Fermi 2. Therefore, it is anticipated that GHG emissions from the new nuclear alternative would 

be similar to those presented in Table 4–21.

Combination Alternative (NGCC, Wind, and Solar)

As discussed in Section 2.2.2.4, the NRC staff evaluated an alternative that relies on NGCC 

(33 percent), wind (50 percent), and solar (17 percent) capacity to replace Fermi 2. The total 

installed capacity for the combination alternative would be 400 MWe for NGCC, 1,052 MWe for 

solar PV, and 2,000 MWe for onshore wind. For this combination alternative, it is assumed that 

the majority of the GHG emissions result from the NGCC portion only because renewable 

portions (wind and solar PV) do not burn fossil fuels to generate electricity. As discussed in 

Section 4.3.3., GHG emissions associated with the operation of the NGCC portion are reduced 

proportionally because its electricity output is approximately 33 percent that of the NGCC 

alternative. The NRC staff estimates that operation of the combination alternative will directly 

result in about 1.3 million tons of CO2eq per year (1.2 million MT/year).

Summary of GHG Emissions from the Proposed Action and Alternatives

Table 4–21 presents the direct GHG emissions from operation of the proposed action and 

alternatives. The GHG emissions from the proposed action (continued operation at Fermi 2) 

and the new nuclear alternative would be lowest compared to those from the other alternatives. 

 13 Lifecycle carbon emissions analyses consider construction, operation, decommissioning, and associated 

processing of fuel (e.g., gas and coal).
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The GHG emissions for IGCC, NGCC, and combination alternatives are higher than those for 

the proposed action and a new nuclear alternative by several orders of magnitude. 

Direct GHG Emissions(a) from Operation of the 

Proposed Action and Alternatives

Technology CO2eq (MT/year)

Fermi 2 continued operation(b) 10,250

New nuclear 10,250

NGCC 3.5x106

IGCC 6.2x106

Combination(c) 1.2x106

(a) The GHG emissions presented include only direct emissions from operation of the electricity-generating 

technology. For the NGCC and IGCC alternatives, GHG emissions result from direct combustion. For the 

proposed action and new nuclear alternative, direct GHG emissions are a result of combustion sources, such as 

diesel generators, auxiliary boilers, and turbines.

(b) Emissions include operation of combustion sources (i.e., diesel generators, auxiliary boiler, and turbines). The 

data reflect the highest GHG emissions from the most recent 5 years of Fermi 2 operation (DTE 2014c). 

(c) Only the NGCC portion of GHG emissions is shown.

Key: CO2eq = carbon dioxide equivalents, and MT = metric ton.

4.15.3.2 Climate Change Impacts to Resource Areas

Climate change is the decades or longer change in climate measurements (e.g., temperature

and precipitation) that has been observed on a global, national, and regional level (EPA 2012c; 

IPCC 2007a; USGCRP 2014). Climate change can vary regionally, spatially, and seasonally 

depending on local, regional, and global factors. Just as the regional climate differs throughout 

the world, the impacts of climate change can vary between locations. 

On a global level from 1901 to 2012, the Earth’s average surface temperatures have risen at a 

rate of 0.15 °F (0.08 °C) per decade, and precipitation has increased at an average rate of 

0.2 percent per decade (EPA 2014b). The observed global changes in average surface 

temperature and precipitation have been accompanied by an increase in sea surface 

temperatures, a decrease in global glacier ice, an increase in sea level, and changes in extreme 

weather events. Such extreme events include increases in frequency of heat waves, heavy 

precipitation, and minimum and maximum temperatures (EPA 2012c; IPCC 2007a; 

USGCRP 2009, 2014). 

In the United States, the U.S Global Change Research Program (USGCRP) reports that, 

from 1895 to 2012, average surface temperature has increased from 1.3 °F to 1.9 °F (0.72 to 

1.06 °C), and since 1900, average annual precipitation has increased by 5 percent 

(USGCRP 2014). On a seasonal basis, warming has been the greatest in winter and spring. 

From 1895 to 2011, an increase in the length of the freeze-free season, the period between the 

last occurrence of 0 °C (32 °F) in the spring and first occurrence of 0 °C (32 °F) in the fall, has 

been observed for the contiguous United States; between 1991 and 2011, the average 

freeze-free season was 10 days longer than that between 1901 and 1960 (USGCRP 2014). 

Since the 1970s, the United States has warmed at a faster rate as the surface temperature rose 

at an average rate of 0.17 to 0.25 °C (0.31 to 0.45°F) per decade. In addition, the year 2012 

was the warmest on record (USGCRP 2014). Observed climate-related changes in the 

United States include increases in the frequency and intensity of heavy precipitation, earlier 
Environmental Consequences and Mitigating Actions

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onset of spring snowmelt and runoff, rise of sea level in coastal areas of the United States, 

increase in occurrence of heat waves, and a decrease in occurrence of cold waves (EPA 2012c;

NOAA 2013a; USGCRP 2009, 2014).

Temperature data indicate that the Midwest region, where Fermi 2 is located, experienced a 

0.06 °C (0.11 °F) per decade increase in annual mean temperature during the 1900 to 2010 

period (NOAA 2013b). Temperature data for the recent past indicate an increased rate of 

warming for the Midwest: 0.12 °C (0.22 °F) per decade for the 1950 to 2010 time period and a 

0.26 °C (0.47 °F) temperature increase for the 1979 to 2010 time period. Average annual 

precipitation data for the Midwest exhibit an increasing trend of 0.31 inch (in.) (0.79 centimeter 

(cm)) per decade for the long-term period (1895 to 2011) (NOAA 2013b). Precipitation data 

over the 1958 to 2007 period exhibit clear trends toward more very heavy precipitation events 

(defined as the heaviest 1 percent of all daily events) for the Nation as a whole and particularly 

in the Northeast and Midwest. 

The NRC staff analyzed temperature and precipitation trends for the period of 1865 to 2014 in 

the southeastern region of Michigan (NCDC 2014). Average annual temperatures during this 

time period show large year-to-year variations, although a clear upward trend in temperature is 

observed starting since the 1960s. Since 1865, temperatures have increased 0.2 °F (0.1 °C)

per decade, and since 1960, temperatures have increased at a rate of 0.5 °F (0.2 °C) per 

decade. Average annual precipitation also displays year-to-year variations, although 

precipitation has increased at a rate of 0.4 in. (1.0 cm) per decade. The Great Lakes have 

experienced higher water temperatures and less ice cover as a result of changes in regional 

climate (USGCRP 2014; NOAA 2013b). Since the early 1970s, total winter ice coverage has 

decreased by 63 percent. Water levels for Lake Erie have exhibited a downward trend since 

the 1860s (NOAA 2013b). The NRC staff obtained modeled monthly Lake Erie surface water

temperatures from the National Oceanic and Atmospheric Administration’s (NOAA’s) Great 

Lake Environmental Research Laboratory for 1950 to 2012; these water surface temperatures 

were derived from the NOAA’s Great Lakes continuous evaporation model (Croley 2005). For 

the years 1950 to 2012, Lake Erie annual surface water temperatures increased at a rate of 

0.037 °C (0.067 °F) per decade (NOAA 2014). Additionally, the NRC staff obtained daily Lake 

Erie surface water temperatures from satellite measurements for the years 1995 to 2013 

(NOAA undated(a)); daily annual mean surface water temperatures during this period increased 

at a rate of 0.045 °C (0.081 °F) per year. However, these measurements are based on satellite 

imagery, and Nizoli (2002) has noted that satellite-derived lake temperatures have a seasonal 

warm or cool bias when compared to actual Great Lakes buoy measurements. 

Future GHG emission concentration and climate models are commonly used to project possible 

climate change. Climate models indicate that over the next few decades, temperature 

increases will continue due to current GHG emissions concentrations in the atmosphere 

(USGCRP 2014). Over the longer term, the magnitude of temperature increases and climate 

change effects will depend on both past and future GHG emissions (IPCC 2007a; 

USGCRP 2009, 2014). 

For the license renewal period of Fermi 2 (2025 to 2045), climate simulations (between 2021 to 

2050 relative to the reference period (1971 to 1999)) indicate an increase in annual mean 

temperature in the Midwest region of 2.5 to 3.5 °F (1.4 to 1.9 °C) for both a low- and 

high-emission-modelled scenario (NOAA 2013b). The predicted increase in temperature during 

this time period occurs for all seasons with the largest increase occurring in the summertime 

(June, July, and August). Climate model simulations (for the time period 2021 to 2050) suggest 

spatial differences in annual mean precipitation changes for the Midwest with northern areas 

experiencing an increase in precipitation and the southern areas experiencing a decrease in 

precipitation. For Michigan, the models indicate a 0- to 6-percent increase in annual mean 
Environmental Consequences and Mitigating Actions

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precipitation, with the fall, winter, and spring seasons experiencing precipitation change 

increases and the summer season experiencing a decrease in precipitation for both a low- and 

high-emission-modeled scenario. However, these changes in precipitation were not significant 

under a low-emission-modeled scenario, and the models indicate changes that are less than 

normal year-to-year variations (NOAA 2013b). The average lake level of Lake Erie could 

decrease by 7.8 to 9.8 in. (20 to 25 cm) compared to the current long-term mean by 2050 

(Mackey 2012; USGCRP 2014). Future lake level changes are highly uncertain and climate 

models have a low confidence level associated with estimated water level changes. Future lake 

levels will depend on evaporative losses, local precipitation changes, wind speeds, and storm 

frequency. Furthermore, models project that water surface temperatures by 2050 will increase 

by 1.6 to 3.2 °C (2.8 to 5.7 °F) under a low-emission-modeled scenario and 1.5 °C to 3.9 °C

(2.7 to 7.0 °F) under a high-emission-modelled scenario (Mackey 2012).

Changes in climate have broader implications for public health, water resources, land use and 

development, and ecosystems. For instance, changes in precipitation patterns and increase in 

air temperature can affect water availability and quality; distribution of plant and animal species;

land use patterns; and land cover, which can in turn affect terrestrial and aquatic habitats. The 

sections below discuss how future climate change may impact air quality, water resources, land

use, terrestrial resources, aquatic resources, and human health in the ROI for Fermi 2. 

Although the exact future climate change is uncertain, the discussions provided below 

demonstrate the potential implications of climate change on resources. 

Air Quality

As discussed above, a noticeable increase in average temperatures in Michigan have been 

observed. Despite the strong year-to-year variations, climate models project continued warming 

in the Midwest region during the license renewal period. Air pollutant concentrations result from 

complex interactions between physical and dynamic properties of the atmosphere, land, and 

ocean. The formation, transport, dispersion, and deposition of air pollutants depend, in part, on 

weather conditions (IPCC 2007b). Air pollutant concentrations are sensitive to winds, 

temperature, humidity, and precipitation (EPA 2009a). Hence, climate change can impact air 

quality as a result of the changes in meteorological conditions.

Ozone has been found to be particularly sensitive to climate change (IPCC 2007b; EPA 2009b). 

Ozone is formed, in part, as a result of the chemical reaction of nitrogen oxides and VOCs in the 

presence of heat and sunlight. Nitrogen oxides and VOC sources include both natural 

emissions (e.g., biogenic emissions from vegetation or soils) and human activity-related 

emissions (e.g., motor vehicles and power plants). Sunshine, high temperatures, and air 

stagnation are favorable meteorological conditions to higher levels of ozone (IPCC 2007b;

EPA 2009a). The emission of ozone precursors also depends on temperature, wind, and solar 

radiation (IPCC 2007b); both nitrogen oxide and biogenic VOC emissions are expected to be 

higher in a warmer climate (EPA 2009b). Although surface temperatures are expected to 

increase in the Midwest, this may not necessarily result in an increase in ozone concentrations. 

The observed correlation between increased ozone concentrations and temperature has been 

found to occur in polluted and urban regions (those areas where ozone concentration are 

greater than 60 parts per billion). Additionally, increases in ozone concentrations correlated 

with temperature increases occur in combination with cloud-free regions and air stagnation 

episodes (Jacob and Winner 2009; IPCC 2013). Furthermore, climate models do not agree on 

the sign of ozone response to climate change. Some models indicate increases in ozone 

concentrations with climate change for the Midwest and Northeast (e.g., Wu et al. 2008), and 

others project decreases in ozone concentrations with climates for the Northern regions of the 

United States (e.g., Tagaris et al. 2009). Climate change may make it difficult for regions to 

meet ozone NAAQS (USGCRP 2009).
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Water Resources

Predicted changes in the timing, intensity, and distribution of precipitation would likely result in 

changes in surface water runoff affecting water availability across the Midwest. As discussed 

above, the Midwest may experience increased mean precipitation during the fall, winter, and 

spring. Additionally, increases in the frequency and intensity of extreme (heavy) precipitation 

are projected across the entire region, particularly in the eastern part of the region where 

Fermi 2 is located (USGCRP 2014). As cited by the USGCRP, in spite of increased annual 

average precipitation, the loss of moisture from soils because of higher temperatures along with 

increased evapotranspiration from vegetation and the increased average number of days 

without precipitation is likely to intensify short-term (seasonal or shorter) droughts across the

region into the future (USGCRP 2009, 2014). Such conditions can potentially reduce the 

amount of water available for surface runoff and streamflow on a seasonal timeframe. Runoff 

and streamflow at a regional scale for the Midwest region indicate no clear trend during the last 

half century; however, annual runoff and river flow are projected to increase in the upper 

Midwest. Increases in the frequency and magnitude of extreme precipitation events projected 

for the winter and spring months will contribute to higher seasonal lake levels (USGCRP 2014;

Mackey 2012). However, annual mean water levels for Lake Erie are projected to be below 

historical levels. The average lake level of Lake Erie could decrease by 7.8 to 9.8 in. (20 to 

25 cm) compared to the current long term-mean by 2050 (Mackey 2012; USGCRP 2014). As 

for water quality implications, increases in the frequency intensity of very heavy precipitation 

events can result in increases in nutrients; sediment loads; and contaminants into Lake Erie, 

which can lower the overall lake water quality (Mackey 2012). The effects of climate change 

are projected to significantly increase water demand across most of the United States. 

However, when accounting for changes in proposed population and climate change projections, 

the southern regions of Michigan (where Fermi 2 is located) do not experience increases in 

water demand; conversely, northern areas of Michigan may experience an increase of up to 

10 percent (USGCRP 2014, Figure 3.11). 

Increased precipitation in the fall, winter, and spring is likely to result in increased groundwater

recharge. More precipitation during these seasons (as opposed to summer) would percolate 

into the groundwater because it would experience lower evaporation and transpiration rates. 

Furthermore, a portion of the winter precipitation would fall as snow. Instead of running off the 

land, much of the snow is likely to slowly melt in place and contribute to groundwater recharge. 

Future climate change is not likely to affect groundwater supplies near the site. Local aquifers 

under the site are in hydrologic communication with Lake Erie. If groundwater levels in the local 

aquifers rise, more water will be discharged by these aquifers to Lake Erie. Alternatively, should 

groundwater levels in the local aquifers decrease, more water would flow from the lake into the 

local aquifers. Any future climate impacts on Lake Erie water levels are not anticipated to 

change this natural rhythm. This phenomenon is illustrated in Figure 3–13 (Bed Rock Water 

Levels and Lateral Groundwater Flow Direction) in Section 3.5.2.1 of this SEIS. Figure 3–13 

shows groundwater flowing from Lake Erie as a result of quarry dewatering activities and 

groundwater flowing into the lake in those areas that are not impacted by dewatering activities. 

The Fermi site does not use groundwater. Future climatic changes should not result in changes 

to site operations, which could result in increased impacts to the availability and quality of 

groundwater resources. 

Land Use

Anthropogenic land use is both a contributor to climate change, as well as a receptor of climate 

change impacts (Dale 1997). As described previously in this section, the Midwest will likely 

experience rising temperatures and heavier precipitation events during the proposed license 

renewal period. Agriculture (the major land use in the vicinity of Fermi 2) and growing urban 
Environmental Consequences and Mitigating Actions

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areas will further exacerbate these changes by continuing to inhibit natural ecosystem functions 

that could moderate climate change effects. For instance, air temperatures and near-surface 

moisture levels change in areas where natural vegetation is converted to agricultural use, and 

higher temperatures have been observed in the Midwest as a result of converting land to 

agricultural use (USGCRP 2014). The USGCRP (2014) indicates that land use changes, such 

as the continued expansion of urban areas, paired with climate change effects, such as heaver 

precipitation events, can exacerbate climate change effects, including reduced water filtration 

into the soil and increased surface runoff due to increases in impervious surface area. Although

anthropogenic land uses will contribute to climate change in these and other ways, land uses 

will also be affected by climate change in several ways. For instance, plant winter hardiness 

zones are likely to shift one-half to one full zone by the end of the proposed license renewal 

period (USGCRP 2014). This shift will affect the ability to grow certain crops because the 

Midwest will likely contain plants now associated with the Southeast by the end of the century 

(USGCRP 2014). Additionally, the USGCRP (2014) projects that the Midwest will experience a 

loss in cropland cover and an expansion in exurban and suburban areas. Changes in cropland 

cover and expansion of exurban and suburban areas can then reduce the quality and availability 

of land resources and agricultural productivity. Changes or fluctuations in lake water levels 

could result in land use changes along affected water bodies and in impacts to infrastructure. 

Such changes or fluctuations could necessitate infrastructure redesign and replacement. For 

example, decreases in lake levels can result in increases in dredging of commercial channels 

(Mackey 2012). 

Aquatic Resources

Climate change can affect the flow of energy, water, and other materials through ecosystems, 

which, in turn, affect living aquatic resources. Mackey (2012) identified three climate stressors 

on the Great Lakes and near shore coastal systems: (1) changing water level regimes, 

(2) changing patterns of storms and precipitation, and (3) altered thermal regimes. These affect 

the physical characteristics and processes of shorelines and coastal and aquatic habitats, which 

then affect biological communities and ecosystems. Some of these effects on aquatic 

resources are discussed below.

The Midwest is warming. The USGCRP (2014) reports that between 1900 and 2010, average 

Midwest air temperatures increased more than 1.5 °F (0.85 °C). Mackey (2012) projected that 

Lake Erie surface water temperatures could increase 1.6 to 3.2 °C (2.8 to 5.7 °F) under a 

low-emission-modeled scenario and 1.5 °C to 3.9 °C (2.7 to 7.0 °F) under a 

high-emission-modeled scenario by 2050. Higher water temperatures are not only a direct 

stressor to aquatic resources, but they can exacerbate other existing environmental stressors, 

such as excess nutrients, sedimentation, and lowered dissolved oxygen associated with 

eutrophication (USGCRP 2014). Warmer water temperatures combined with increased nutrient 

loads can increase the growth and duration of algal blooms that adversely affect water quality 

and habitats. For example, Michalak et al. (2013) predict that if the long-term trends in 

agricultural land use (which have increased phosphorus loads) and trends in climate change 

continue (such as decreasing wind speeds that weaken lake circulation), harmful algal blooms 

in Lake Erie may become more common in the future. 

The Midwest will likely experience an increased frequency of extreme rainfall events, which will 

cause erosion and will lead to a decline in water quality (Mackey 2012; USGCRP 2014). 

Increased agricultural runoff, which can increase phosphorus and nitrogen loadings to water 

resources, can contribute to low-oxygen zones in Lake Erie. Species that require cleaner 

waters, such as freshwater mussels, could experience further population declines. 

USGCRP (2014) predict habitat loss and local extinctions of fish and other aquatic species 

throughout the United States from the combined effects of water withdrawal and climate change
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and shifts in species assemblages and distributions as climate change continues. For instance, 

in the Great Lakes, increases in lakebed erosion could result in coarsening of lakebed 

substrates and in more favorable habitat for invasive zebra mussels. Special status species, 

such as those that are Federally protected under the ESA, would be most sensitive to climate 

changes because those populations are already stressed and at low levels. Invasions of 

non-native species that thrive under a wide range of environmental conditions could further 

disrupt the current composition of aquatic communities.

Furthermore, changes in lake water levels would also affect aquatic habitat. Mackey (2012) 

found that although future lake level projections are uncertain, long-term average projections 

indicate a decrease in Lake Erie water levels of 20 to 25 cm (7.9 to 9.8 in.) by 2050. Decreases 

in lake water levels can change the location and distribution of nearshore fish spawning and 

nursery habitats and may affect the depth of the thermocline, which would also affect the habitat 

of midwater species. 

Terrestrial Resources

As described above, the Midwest will likely experience rising temperatures and heavier 

precipitation events during the proposed license renewal period. As the climate changes, 

terrestrial resources will either need to be able to tolerate the new physical conditions or shift 

their population range to new areas with a more suitable climate. Scientists currently estimate 

that species are shifting their ranges at a rate of between 6.1 to 11 m (20 to 36 ft) in elevation 

per decade and 6.1 to 16.9 km (3.8 to 10.5 mi) in latitude per decade (Chen et al. 2011; 

Thuiller 2007). Although some species may readily adapt to a changing climate, others may be 

more prone to experience adverse effects. For example, species whose ranges are already 

limited by habitat loss or fragmentation or who require very specific environmental conditions 

may not be able to successfully shift their ranges over time. Migratory birds that travel long 

distances may also be disproportionately affected because they may not be able to pick up on 

environmental clues that a warmer, earlier spring is occurring in the United States while they are

overwintering in tropical areas. Fraser et al. (2013) found that songbirds overwintering in the 

Amazon did not leave their winter sites earlier, even when spring sites in the Eastern 

United States experienced a warmer spring. As a result, the song birds missed periods of peak 

food availability. For many Midwest species, migration to changed habitats is projected to be 

slow due to flat topography; high latitudes; and fragmented habitats, including the Great Lakes 

(USGCRP 2014). Special status species and habitats, such as those that are Federally 

protected by the ESA, would likely be more sensitive to climate changes because these species’ 

populations are already experiencing threats that are endangering their continued existence 

throughout all, or a significant portion of, their ranges. For instance, in its final rule to list the red 

knot (Calidris canutus rufa), a shorebird that uses the Great Lakes during spring and fall 

migration, the FWS cites several effects resulting from climate change as factors contributing to 

the decline of the species (79 FR 73705). These effects include habitat loss from sea level rise, 

asynchronies in the timing of annual cycles, and increased frequency of severe storm events. 

Habitat ranges for forest systems in the Midwest, such as paper birch (Betula papyrifera), 

balsam fir (Abies balsamea), and black spruce (Picea mariana), are projected to decline as they 

shift northward, and species that are common farther south, such as oaks (Quercus spp.) and 

pines (Pinus spp.), will expand their range north into the Midwest region (USGCRP 2014). 

Climate changes could also favor non-native invasive species and promote population 

increases of insect pests and plant pathogens, which may be more tolerant to a wider range of 

climate conditions.

Changes in water level regimes can alter the composition of the Great Lakes coastal 

wetland-dependent fish communities and other aquatic organisms. The Great Lakes coastal 

wetlands provide essential habitat for more than 80 species of fish and habitats for a diverse 
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number of nesting birds, amphibians, and reptiles (Mackey 2012). Coastal wetlands are 

vulnerable to hydrologic isolation during periods of low water levels. Isolation from adjacent 

tributaries and lake water bodies disconnects potential spawning and nursery habitats, which 

can reduce or alter available food resources for birds, amphibians, reptiles, and other 

wetland-dependent terrestrial organisms.

Historic and Cultural Resources

Increases in river and lake water levels because of changes in meteorological conditions due to 

climate change could result in the loss of historic and cultural resources from flooding, erosion, 

or inundation. Because of water-level changes, some resources could be lost before they could 

be documented or otherwise studied. However, as discussed above, future lake water level 

changes are uncertain and confidence levels regarding model projections are low. The limited 

extent of climate change that could occur during the 20-year license renewal term would not 

have a significant effect on historic and cultural resources at Fermi.

Socioeconomics

Rapid changes in climate conditions could have an impact on the availability of jobs in certain 

industries. For example, tourism and recreation are major job creators in some regions, 

bringing billions of dollars to regional economies. Across the Nation, fishing, hunting, and other 

outdoor activities make important economic contributions to rural economies and are also a part 

of the cultural tradition. A changing climate would mean reduced opportunities for some 

activities in some locations and expanded opportunities for others. Hunting and fishing 

opportunities could also change as animals’ habitats shift and as relationships among species 

are disrupted by their different responses to climate change (USGCRP 2014). For instance, 

surface water thermal changes might cause a northward shift of warm- and cold-water fish; 

changes in the abundance and distribution of fish can potentially impact commercial and 

recreational fishing (Mackey 2012). Water-dependent recreation could also be affected 

(USGCRP 2009). The USGCRP reports that increasing heat and humidity associated with 

climate change in parts of the Midwest region by the year 2050 could create unfavorable 

conditions for summertime outdoor recreation and tourism activity (USGCRP 2014). Reduced 

ice cover may benefit commerce by lengthening the navigation and shipping season. On the 

other hand, changes in lake water levels could affect Great Lakes port operations. However, 

the limited extent of climate change that could occur during the 20-year license renewal term 

would not cause any significant changes in socioeconomic conditions in the vicinity of Fermi.

Human Health

Changes in climate conditions could have an impact on human health, such as increased 

respiratory, cardiovascular, and infectious diseases (USGCRP 2014). However, changes in 

climate conditions that may occur during the license renewal term will not result in any change 

to the impacts discussed in Section 3.11 from Fermi’s radioactive and nonradioactive effluents. 

Increased water temperatures in Lake Erie as discussed above, however, may increase the 

potential to support the survival of thermophilic organisms and the potential adverse effects that 

these organisms can present to human health.

Environmental Justice

Rapid changes in climate conditions could disproportionately affect minority and low-income 

populations. The USGCRP (2014) indicates that “infants and children, pregnant women, the 

elderly, people with chronic medical conditions, outdoor workers, and people living in poverty 

are especially at risk from a variety of climate-related health effects.” Examples of these effects 

include increased heat stress; air pollution; extreme weather events; and diseases carried by 

food, water, and insects. The greatest health burdens related to climate change are likely to fall 
Environmental Consequences and Mitigating Actions

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on the poor, especially those lacking adequate shelter and access to other resources, such as 

air conditioning. Elderly people living on a fixed income are more likely to be poor and are more 

likely to have debilitating chronic diseases or limited mobility. In addition, elderly people can 

have a reduced ability to regulate their own body temperature or to sense when they are too 

hot. According to the USGCRP (2009), they “are at greater risk of heart failure, which is further 

exacerbated when cardiac demand increases in order to cool the body during a heat wave.” 

The USGCRP (2009) study also found that people taking medications, such as diuretics for high 

blood pressure, have a higher risk of dehydration. The USGCRP (2014) study reconfirmed the 

previous report findings regarding the risks of climate change on low-income populations and 

warns that climate change could affect the availability and access to local plant and animal 

species, thus impacting the people that have historically depended on them for food or 

medicine. For instance, in the Great Lakes regions, wild rice, a sacred food and medicine to the 

Anishinaabe people, has declined due to warming winters and changing water levels 

(USGCRP 2014). However, because of the limited extent of climate change that could occur 

during the 20-year license renewal term, minority and low-income populations living near

Fermi 2 are not expected to experience disproportionately high and adverse impacts from the 

limited extent of climate change in the environment that could occur during the license renewal 

term.

4.16 Cumulative Impacts of the Proposed Action

The NRC staff considered potential cumulative impacts in the environmental analysis of

continued operation of Fermi 2 during the 20-year license renewal period. Cumulative impacts 

may result when the environmental effects associated with the proposed action are overlaid or 

added to temporary or permanent effects associated with other past, present, and reasonably

foreseeable actions. Cumulative impacts can result from individually minor, but collectively

significant, actions taking place over a period of time. An impact that may be SMALL by itself 

possibly could result in a MODERATE or LARGE cumulative impact when it is considered in

combination with the impacts of other actions on the affected resource. Likewise, if a resource

is regionally declining or imperiled, even a SMALL individual impact could be important if it

contributes to, or accelerates, the overall resource decline. 

For the purposes of this cumulative analysis, past actions are those before the receipt of the

license renewal application; present actions are those related to the resources at the time of

current operation of the power plant; and future actions are those that are reasonably

foreseeable through the end of plant operation, including the period of extended operation. 

Therefore, the analysis considers potential impacts through the end of the current license term, 

as well as the 20-year renewal license term. The geographic area over which past, present,

and reasonably foreseeable actions would occur depends on the type of action considered and

is described below for each resource area.

To evaluate cumulative impacts, the incremental impacts of the proposed action, as described

in Sections 4.2 to 4.15, are combined with other past, present, and reasonably foreseeable

future actions regardless of which agency (Federal or non-Federal) or person undertakes such

actions. The NRC staff used the information provided in DTE’s ER; responses to RAIs; 

information from other Federal, State, and local agencies; scoping comments; and information 

gathered during the visits to the Fermi site to identify other past, present, and reasonably 

foreseeable actions. To be considered in the cumulative analysis, the NRC staff determined 

whether the project would occur within the noted geographic areas of interest and within the 

period of extended operation, whether it was reasonably foreseeable, and whether there would 

be a potential overlapping effect with the proposed project. For past actions, consideration 

within the cumulative impacts assessment is resource and project specific. In general, the 
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effects of past actions are included in the description of the affected environment in Chapter 3, 

which serves as the baseline for the cumulative impacts analysis. However, past actions that 

continue to have an overlapping effect on a resource that potentially could be affected by the 

proposed action are considered in the cumulative analysis. 

Appendix E describes other actions and projects identified during this review and considered in 

the NRC staff’s analysis of the potential cumulative effects. Not all actions or projects listed in 

Appendix E are considered in each resource area because of the uniqueness of the resource 

and its geographic area of consideration.

4.16.1 Air Quality and Noise

This section addresses the direct and indirect effects of license renewal on air quality and noise 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. As described in Section 4.3.1, the incremental impacts on air quality and noise levels 

from the proposed license renewal would be SMALL.

4.16.1.1 Air Quality

The geographic area considered in the cumulative air quality analysis is the County where the 

proposed action is located as air quality designations for criteria air pollutants are generally 

made at the County level. The Fermi site is located in Monroe County, Michigan. With regard 

to the NAAQS criteria pollutants, Monroe County is designated a maintenance area for the 

8-hour ozone 1997 standard and the PM2.5 1997 and 2006 standard (EPA 2014e). Counties are 

further grouped together based on a common airshed—known as an Air Quality Control Region 

(AQCR)—to provide for the attainment and maintenance of the NAAQS. Monroe County, along 

with two Counties (Lucas County and Wood County) in the State of Ohio are part of the

Metropolitan Toledo Interstate AQCR (40 CFR 81.43).

As noted in Section 3.3.2, the U.S. EPA regulates six criteria pollutants under the NAAQS, 

including carbon monoxide, lead, nitrogen dioxide, ozone, sulfur dioxide, and PM. Criteria 

pollutant air emissions from Fermi 2 are presented in Table 3–5 of Section 3.3.2. No 

refurbishment-related activities will occur during the license renewal period. However, DTE will 

be installing generators and pumps at Fermi 2 in response to the NRC’s order 

(Order EA-12-049) (NRC 2012) to maintain or restore core cooling, containment, and spent fuel

cooling. DTE has obtained a permit to install (Permit No. 3-14) from MDEQ for these additional 

air emission sources (DTE 2014c). While not associated with license renewal, operation of this 

additional equipment will be intermittent for periodic routine testing, similar to current permitted 

sources at Fermi 2; therefore, additional emissions will be limited and in accordance with the 

requirements set forth in the air emissions permit. As a result, the NRC staff expects similar 

emissions during the license renewal period, as presented in Section 3.3.2. 

Appendix E provides a list of present and reasonably foreseeable projects that could contribute 

to cumulative impacts to air quality. Operating projects listed in Appendix E are not anticipated 

to increase air emissions above their current levels, and most projects are not located in Monroe 

County and, therefore, are unlikely to contribute to a cumulative impact due to their distance or 

location. The following existing power plants listed in Appendix E are within Monroe County: 

• J.R. Whiting Power Plant and

• Monroe Power Plant.

These facilities are classified as major sources of air emissions (EPA 2014f). The EPA’s 

Enforcement and Compliance History Online database identifies an additional 6 facilities that 

are major sources and 42 facilities that are minor sources of air emissions in Monroe County 
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(EPA 2014f). Major sources emit, or have the potential to emit, 10 tons per year of any one 

HAP, 25 tons per year of any combination of HAPs, or 100 tons per year of any other regulated 

air contaminant (MDEQ undated). A minor source has a potential to emit air emissions that are

less than the threshold levels for a major source (MDEQ 2005). As discussed in Section 3.3.2, 

Fermi 2 is a synthetic minor source because conditions in the facility’s air permit restricts 

emissions below the threshold levels for a major source. A minor source classification typically 

indicates that the facility has little to no potential for significantly impacting air quality or 

interfering with plans to achieve compliance with the NAAQS (IEPA 2014). In 2011, 

J.R. Whiting Power Plant and Monroe Power Plant were responsible for 74, 88, 99, and 

69 percent of carbon monoxide, nitrogen oxides, sulfur dioxide and PM10 emissions, 

respectively, in Monroe County. Therefore, J.R. Whiting Power Plant and Monroe Power Plant 

are the dominant sources that can contribute to air quality impacts. However, J.R. Whiting 

Power Plant ceased operations in 2016, and Monroe Power Plant completed refurbishment of

controls to reduce emissions resulting from operation (DTE 2014d). Any new sources of 

emissions that would be established in Monroe County would be required to apply for an air 

permit from MDEQ and must be operated in accordance with Federal regulatory requirements.

For instance, construction and operation of Fermi 3 can result in an increase in criteria 

pollutants; air emission sources will be permitted and operated in accordance with State and 

Federal regulatory requirements. The potential impacts from construction and operation of 

Fermi 3 on air quality are expected to be SMALL (NRC 2013a).

Climate change can impact air quality as a result of changes in meteorological conditions. Air 

pollutant concentrations are sensitive to winds, temperature, humidity, and precipitation 

(EPA 2009a). As discussed in Section 4.15.3.2, ozone levels have been found to be particularly 

sensitive to climate change influences (EPA 2009b; Solomon et al. 2007). Climate change may 

make it difficult for regions to meet ozone NAAQS (USGCRP 2009). However, as discussed in 

Section 4.15.3, although surface temperatures are expected to increase in the Midwest, this 

increase in temperatures may not necessarily result in an increase in ozone concentrations. 

Changes in air emission concentrations will depend on the combination of higher temperatures, 

current levels of ozone, stagnant air masses, sunlight, and emissions of precursors. 

Furthermore, climate models do not agree on the direction of ozone changes (increase or 

decrease) in response to climate change for the Midwest (Wu et al. 2008; Tagaris et al. 2009).

Because of the small quantity of emissions from Fermi 2 and no expected emissions increase 

associated with license renewal, the potential for Fermi 2 to contribute to a cumulative impact 

with other air pollutant sources is SMALL. The NRC staff concludes that, combined with the 

emissions from other past, present, and reasonably foreseeable future actions, cumulative 

impacts on air quality from hazardous and criteria air pollutant emissions from Fermi 2-related 

actions would be SMALL.

4.16.1.2 Noise

Section 3.3.3 presents a summary of noise sources at Fermi 2 and in the vicinity of the site. 

Major noise sources at Fermi 2 that are audible beyond the site boundary include the cooling 

towers, firing range, and transmission lines (DECo 2011). 

Noise levels in the vicinity of a nuclear power plant could increase from planned activities 

associated with urban, industrial, and commercial development. The magnitude of cumulative 

impacts depends on the nuclear plant’s proximity to other noise sources. A 3-dBA change in 

sound level is considered barely discernible, as discussed in Section 3.3.3. A 3-dBA increase 

would occur with the placement of another identical source over an existing source (e.g., double 

the traffic volume). Ongoing or foreseeable future projects in and around the Fermi site, as 

identified in Appendix E, can increase noise levels only in the vicinity of their noise sources, and 
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combined noise levels are not expected to be high enough to cause noise issues. For instance, 

construction and operation of Fermi 3 will introduce additional noise sources. However, noise 

levels are not expected to be greater than current levels surrounding the Fermi site, and impacts 

on noise are expected to be SMALL (NRC 2013a). Furthermore, as indicated in Appendix E, 

most of the projects are not located within 1 mi (1.6 km) of Fermi 2. Generally, as distance is 

doubled from a point source, noise levels decrease by 6 dBA (MPCA 2014). Therefore, noise 

levels from present and future actions are not anticipated to contribute to noise impacts in the 

vicinity of Fermi 2. Cumulative impacts on noise environment are expected to be SMALL.

4.16.2 Geology and Soils

This section addresses the direct and indirect effects of license renewal on geology and soils 

when they are added to the aggregate effects of other past, present, and reasonably 

foreseeable future actions. As described in Section 4.4.1, the incremental impacts on geology 

and soils from continued operations of Fermi 2 during the license renewal term would be 

SMALL. Ongoing operation and maintenance activities at the Fermi site are expected to be 

confined to previously disturbed areas. Any use of geologic materials, such as aggregates, to 

support operation and maintenance activities would be procured from local and regional 

sources. These materials are abundant in the region.

Construction activities for a new reactor (Fermi 3) represent the largest source of potential 

soil-related environmental impacts on the Fermi site. The site for the new reactor is well

defined, and access is restricted. Soil-disturbing activities will be localized to the site and are 

distant from surrounding populations. Soil erosion will be minimized by adherence to 

regulations and permits and the use of BMPs (NRC 2013a). In addition, operation of Fermi 3

would not prevent access to economically valuable mineral resources. Geologic materials, such 

as aggregates and engineered backfill, needed to support construction would be procured from 

local and regional sources. These materials are abundant in the region. 

As described in Section 3.4.2, the local site soils are poorly drained low-lying soils that are in 

hydrologic communication with Lake Erie. Future changes in climate are unlikely to change the 

soils or result in changes to site operations that could impact local soils. Geologic conditions 

are not expected to change during the license renewal term. Thus, activities associated with 

continued operations are not expected to affect the geologic environment. Considering ongoing 

activities and reasonably foreseeable actions, the NRC staff concludes that the cumulative 

impacts on geology and soils during the Fermi 2 license renewal term would be SMALL.

4.16.3 Water Resources

This section addresses the direct and indirect effects of license renewal on surface water and 

groundwater when they are added to the aggregate effects of other past, present, and 

reasonably foreseeable future actions.

4.16.3.1 Surface Water Resources

This section addresses the direct and indirect effects of the proposed action (license renewal) 

on surface water resources when they are added to the aggregate effects of other past, present, 

and reasonably foreseeable future actions. As described in Section 4.5.1.1, the incremental 

impacts on surface water resources from continued operations of Fermi 2 during the license 

renewal term would be SMALL. The NRC staff has also evaluated other projects and actions 

for consideration in determining their cumulative impacts on surface water resources (Table E–1 

in Appendix E).
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The description of the affected environment in Section 3.5.1 serves as the baseline for the 

cumulative impacts assessment for surface water resources. The geographic area of analysis 

considered for the surface water resources component of the cumulative impacts analysis 

comprises the western basin of Lake Erie and further focuses on a 15-mi (24-km) radius 

surrounding Fermi 2’s intake and discharge structures. As such, this review focused on those 

projects and activities that would withdraw water from, or discharge effluent to, the western 

basin of Lake Erie and to its connecting waterways. The cumulative impacts on surface water 

use and quality, along with associated climate change considerations, are presented below.

Water Use Considerations

The Great Lakes Commission (GLC), in partnership with the Great Lakes–St. Lawrence River 

Basin Water Resources Council and its Regional Body, maintains a regional water use tracking 

and reporting database (the Great Lakes–St. Lawrence River Regional Water Use Database) 

that provides comparable water use information on withdrawals, diversions, and consumptive 

uses.

The GLC issues annual water use reports with information summarized by jurisdiction and lake 

watershed based on data collected and reported by the states and provinces. The energy 

sector is the largest water user in the Great Lakes Basin region, most significantly for 

thermoelectric power generation followed by public water supply. This excludes in-stream water 

use for hydroelectric power generation, which is not considered a water withdrawal use or 

potential consumptive use. This usage pattern is true for the Lake Erie watershed as well 

(GLC 2014a).

In 2013, the GLC prepared an interim cumulative impact assessment for the period of 2006 to 

2012. The assessment was prepared as required by the Great Lakes–St. Lawrence River Basin 

Sustainable Water Resources Agreement and Compact and focused on hydrologic effects of 

consumptive uses and water diversion losses within individual watersheds and the basin as a 

whole. For each watershed, total diversion losses and consumptive uses are compared to the 

average water budget for the watershed. This provides a net accounting of water flows into and 

out of the watershed. In the GLC’s assessment, all flows are reported in cubic feet per second

rather than in million gallons per day to facilitate comparisons. In summary, the latest 

assessment indicates that the net effect of consumptive uses and diversion losses was positive 

over the timeframe (i.e., more water was diverted into the Great Lakes–St. Lawrence River 

Basin as a whole than the total combined amount of water diverted out of the basin or 

withdrawn and not returned). Furthermore, consumptive use and diversion losses remained 

very small relative to the total inflow to the basin, with inflows encompassing estimated 

precipitation, surface runoff, diversions into the watershed, and channel flow into the watershed. 

Specific to the Lake Erie watershed, the hydrologic effect of annualized consumptive uses and 

diversions was also found to be small relative to inflows. For the 2006 to 2010 period, the 

annual average percentage of inflow consumptively used or diverted remained relatively steady 

between about 3.9 and 4.3 percent. The estimated net volume of consumptive uses and 

diversion losses showed an increase from 2010 to 2011 (from 4.3 to 4.8 percent of the water 

withdrawn) followed by a decrease from 2011 to 2012 (4.8 to 4.3 percent) (GLC 2014a); this

trend was evident for 2013, as further discussed below.

Based on the latest available data for 2013, reported water withdrawals from the entire Lake 

Erie watershed totaled 51,623 mgd. Consumptive uses totaled 444.94 mgd and intra-basin 

diversions to Lake Ontario through the Welland Canal totaled 4,936.34 mgd. This represents a 

total loss from the watershed of about 3.40 percent in 2013 as compared to the estimated 

annual average inflow of 244,739 cfs (6,914 m3

/s or 158,202 mgd) (GLC 2014a, 2014b). 

However, although the water conveyed through the Welland Canal is lost from Lake Erie, it is 
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not lost to the Great Lakes Basin as a whole. By comparison, of the total water withdrawn from 

the Michigan portion of the Lake Erie watershed, facilities in Michigan withdrew 5,012 mgd of 

water with a consumptive use of 191.5 mgd, which is 3.8 percent of the total volume withdrawn

(Table 4–22). Demands by the largest water use sectors include 3,885.15 mgd for 

thermoelectric power production (once-through cooling), 620.54 mgd for public water supply, 

441.06 mgd for industrial use, and 48.15 mgd for thermoelectric power production (recirculated 

cooling).

It should be noted that substantial uncertainty exists in drawing definitive conclusions from these

data, particularly on larger scales. As previously noted in Section 3.5.1.1 of this SEIS, there is 

inherent uncertainty in calculating Lake Erie’s water balance with respect to watershed inflows 

and outflows, including in the estimates of consumptive use by specific entities and across 

water use sectors. For example, it is estimated that the uncertainty associated with estimated 

inflow and outflow data is larger than the total consumptive use for the basin. In addition, the 

reporting jurisdictions implemented new water use data collection and reporting protocols 

beginning with the 2012 water use data. Any changes, such as in consumptive water use, may 

in fact reflect improvements in data quality along with other factors (GLC 2014a). For the 

purposes of this cumulative impacts assessment, the information and comparisons pertaining to 

the Michigan portion of the Lake Erie watershed (western basin) are the most relevant and 

insightful.

Cumulative Surface Water Withdrawals from the Michigan Portion of the Lake

Erie Watershed by Water Use Sector (2013)

Water Use Sector Withdrawals (mgd)

Consumptive Use (mgd)(a)

(% Consumptive Use)

Public water supply 620.54 77.57 (12)

Commercial/institutional 0.15 0.02 (13)

Irrigation 15.07 13.56 (90)

Livestock 0.15 0.12 (80)

Industrial 441.06 44.11 (10)

Thermoelectric power 

(Once-through cooling)

3,885.15 37.23 (1)

Thermoelectric power 

(Recirculated cooling)

48.15 18.89 (39)

Off-stream hydroelectric power 0.0 0.0

In-stream hydroelectric 0.0 0.0

Other 2.24 0.0

Total 5,012.5 191.5 (3.8)

Note: Michigan reported no diversions of water out of the Lake Erie watershed in 2013.

(a) Some values are rounded. To convert million gallons per day (mgd) to million cubic meters (m3), divide by 264.2. 

To convert million gallons per day to cubic feet per second (cfs), multiply by 1.547.

Source: GLC 2014b

DTE’s Monroe Power Plant, with a generation capacity of 3,280 MWe, is the single largest user 

of water from the western basin of Lake Erie. The Monroe Power Plant’s makeup water 

demand averages 1,550 mgd, primarily for once-through condenser cooling, with cooling and 
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associated wastewater return discharges of 1,546 mgd (MDEQ 2015a), which indicates a 

consumptive use of less than 1 percent. The Monroe Power Plant illustrates a very high water 

withdrawal rate coupled with very low consumptive use, which is typical of power plants using

once-through cooling (as indicated in Table 4–22). Table 4–22 also represents other power 

plants using once-through cooling and withdrawing water from the western basin of Lake Erie, 

including the J.R. Whiting Power Plant, the Trenton Channel Power Plant, and the Bayshore 

Power Plant. (See Table E–1 in Appendix E for additional information on these facilities.) All 

these power plants withdraw cooling water from, and discharge heated effluent into, the western 

basin of Lake Erie (NRC 2013a). The combined water demands for once-through cooling 

accounted for 78 percent of the total volume of water withdrawn from the Michigan portion of the 

Lake Erie watershed in 2013 and accounted for 19 percent of the total volume of water used

consumptively. However, the J.R. Whiting Power Plant was shut down in April 2016, and the 

Trenton Channel Power Plant retired all but one generating unit that same month. Meanwhile, 

the Monroe Power Plant has completed a major refurbishment and is projected to stay in 

operation into the license renewal term for Fermi 2. The shuttering of generation capacity at the 

J.R. Whiting Power Plant and Trenton Channel Power Plant will result in a substantial reduction 

in cooling water makeup demand and return wastewater discharge on the western basin of Lake 

Erie. 

Surface water withdrawals for the public water supply represent the second largest user of the 

western basin’s waters (Table 4–22). The two public water providers within the geographic area 

of analysis include Frenchtown Township and the City of Monroe. The Frenchtown Township 

Water Department has a supply capacity of 8 mgd and current demands of approximately 

4 mgd. Frenchtown Township withdraws water from Lake Erie via an intake located south of the 

Fermi site at Pointe Aux Peaux that it shares with the City of Monroe. The City of Monroe’s 

water filtration plant has a water supply and treatment capacity of 18 mgd and a current demand 

of approximately 8 mgd (NRC 2013a). Although Table 4–22 indicates a consumptive use rate 

of approximately 12 percent for the public water supply sector, some of the reported 

consumptive use may otherwise be returned to the western basin as treated sanitary effluent 

from one of the several publicly owned treatment works in the region (Table E–1 listing in 

Appendix E). 

Other than for power generation, surface water demands for various other industrial uses (as 

summarized in Table E–1 in Appendix E) reflect the developed nature of the western basin of 

Lake Erie. As shown in Table 4–22, the reported consumptive use rate of these general 

industry users is about 10 percent. 

Fermi 2, a closed-cycle (recirculated cooling) power plant, is also represented in Table 4–22; it 

accounts for withdrawals totaling 48.15 mgd with consumptive use of 18.9 mgd (about 

40 percent of the total reported withdrawal). Fermi 2 has a power generation capacity of about 

one-third that of DTE’s Monroe Power Plant. As compared to the Monroe Power Plant, Fermi 2 

demonstrates not only the relatively low cooling water makeup water demands for closed-cycle 

power plants as compared to those for once-through plants but also their substantially higher 

consumptive water use necessary to ensure optimal cooling of return water. During the 5-year 

period from 2009 to 2013, Fermi 2’s reported surface water withdrawals have averaged 

approximately 52.3 mgd. Return discharges to Lake Erie have averaged 32.9 mgd, which 

represents a consumptive use rate averaging 37 percent or about 19 mgd (Section 3.5.1.2 of 

this SEIS). As documented in NUREG–2105 (NRC 2013a), the proposed Fermi 3 nuclear 

power plant would withdraw an average of 28,993 gpm of lake water (equivalent to 41.7 mgd) 

with consumptive use of about 14,488 gpm (20.8 mgd), which reflects a consumptive use rate of 

about 50 percent. Fermi 3 would also use approximately 35 gpm (0.05 mgd) of potable water 

supplied by the Frenchtown Township Water Department. The NRC previously concluded that 
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Fermi 3’s incremental water withdrawal and consumptive use would have a SMALL impact on 

surface water resources in Lake Erie because of the minor change in lake water availability and 

no measurable effect on other industrial and public water supply users with no mitigation

required (NRC 2013a).

Fermi 2 and Fermi 3 combined would withdrawal an annual average of up to 94 mgd of water 

from the western basin of Lake Erie with consumptive use of approximately 40 mgd, which 

reflects a consumptive use rate of about 42 percent. These combined water withdrawals and 

consumptive uses would equate to 1.9 and 21 percent of the current total withdrawals and 

consumptive water use, respectively, from the Michigan portion of the Lake Erie watershed, as 

summarized in Table 4–22. This consumptive use is extremely small compared to the volume 

of Lake Erie (about 128 trillion gal (0.48 trillion m3

)), as well as only about 0.03 percent of the 

average daily volume of water (i.e., about 133,300 mgd) that naturally outflows from Lake Erie 

to Lake Ontario through the Niagara River. 

Nevertheless, the Lake Erie watershed is home to over 12.5 million people, which is more than 

one-third of the entire population of the Great Lakes Basin (GLC 2014a); the population is 

expected to grow along with associated water demands. In predicting future water demands 

relative to the construction and operation of proposed Fermi 3, the NRC relied on projections 

that the population within a 50-mi (80-km) radius of the Fermi site could increase by as much as 

40 percent by 2060 (NRC 2013a). This projection used year 2000 data as a baseline year. The 

growth that has, in fact, occurred has been more modest (Section 3.10 of this SEIS); 

Table 4–22 presents the actual available water use data for this growth. More recent data from 

DTE (2014a) indicate that the region’s population (50-mi (80-km) radius) may grow by about 

5 percent between 2010 and 2045. Similarly, projections from the Southeast Michigan Council 

of Governments, reported by the Monroe County Planning Department and Commission (2010),

forecast growth of 3.4 percent in southeast Michigan by 2035, with about an 11-percent growth 

in Monroe County where the Fermi site is located. 

Any growth would partially overlap with the proposed period of continued operations for Fermi 2 

(2025 to 2045) and operation of Fermi 3, if constructed. Assuming that the population growth 

will be 40 percent and that its demand has a direct and equal correlation across the water use 

sectors identified in Table 4–22, total annualized water withdrawals from the Michigan portion of 

the Lake Erie watershed could be as much as 7,018 mgd with a consumptive use of 

approximately 268 mgd. These growth-induced water demands would far eclipse operational 

water demands associated with the continued operations of Fermi 2 combined with those 

associated with the proposed Fermi 3. This scenario could have implications for regional water 

supply infrastructure and could potentially affect water supply availability. However, increases 

in water demand proportional to the more modest growth projections of around 5 to 10 percent

could produce total annualized water withdrawals of as much as 5,514 mgd with a consumptive 

use of approximately 211 mgd. Such a modest increase in demand could likely be 

accommodated through routine infrastructure planning and upgrades without any measurable 

adverse impacts on water supply availability. The contribution of Fermi 2’s consumptive water 

use (averaging 19 mgd) would continue to be a relatively small percentage (about 9 percent) of 

consumptive use in the western basin during the license renewal term. 

With respect to water use regulation under the Compact, any water withdrawals within the Great 

Lakes Basin, including those within the State of Michigan that would result in a new or increased 

consumptive use of 5 mgd (18,925 m3

/day) are subject to review by all the Compact members. 

Fermi 3 and other new or increased consumptive water uses would be subject to such a review. 

The MDEQ has established a water withdrawal permitting program to meet the consumptive use 

and water diversion requirements of the Compact (Section 3.5.1.2). As a result, water use 

regulation undertaken by the Compact members would be expected to ensure that water 
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withdrawals and consumptive water uses are managed to support the beneficial uses and safe 

yield of Lake Erie waters. 

Water Quality Considerations

Ambient water quality of the western basin of Lake Erie is the product of past and present 

activities (e.g., water withdrawal, effluent discharges, and accidental spills and releases) 

associated with urban development, industrial and commercial development, agricultural 

practices, and shoreline development and waterway maintenance and improvement projects 

(e.g., dredging) within the Lake Erie watershed. Hartig et al. (2007) noted that nearly 40 years 

of U.S. and Canadian pollution prevention and control efforts have led to substantial 

improvements in overall resource and water quality in the western basin of Lake Erie. These 

improvements have included reductions in oil, phosphorus, chloride, and untreated waste from 

combined sewer overflow discharges; declines in contaminants in fish and wildlife; and 

substantial progress in remediating contaminated sediment. Nonetheless, the following water 

quality-related challenges remain: (1) population growth and accompanying land use changes, 

(2) nonpoint pollutant sources, (3) toxic substances, (4) degradation and loss of habitat, 

(5) introduction of exotic species, and (6) GHGs (Hartig et al. 2007). In addition, the EPA’s 

Great Lakes National Program Office has initiated the Great Lakes Restoration Initiative 

program, a consortium of 11 Federal agencies that developed an action plan to address 

environmental issues. These issues fall into five areas: (1) cleaning up toxins and areas of 

concern, (2) combating invasive species, (3) promoting nearshore health by protecting 

watersheds from polluted runoff, (4) restoring wetlands and other habitats, and (5) tracking 

progress and working with strategic partners. The results of this long-term initiative are aimed 

at addressing water quality concerns in Lake Erie (NRC 2013a).

Development projects can result in water quality impacts if they increase sediment loading to 

nearby surface water bodies. The magnitude of cumulative impacts would depend on the 

nature and location of the actions relative to surface water bodies; the number of actions 

(e.g., facilities or projects); and whether facilities comply with regulating agency requirements 

(e.g., land use restrictions, habitat avoidance and restoration requirements, stormwater 

management, and wastewater discharge limits). Table E–1 in Appendix E of this SEIS identifies 

a number of ongoing and reasonably foreseeable future actions. However, in accordance with 

the Compact (Section 3.5.1.2 of this SEIS), the State of Michigan and its partners are charged 

with enacting and administering laws necessary to protect the waters of the Great Lakes Basin. 

Wastewater discharges from existing and new and modified industrial and large commercial 

facilities would be subject to regulation under the Federal Water Pollution Control Act of 1972, 

as amended (the current CWA) (33 U.S.C. 1251 et seq.). Across a particular watershed, 

Section 303(d) of the Federal CWA requires states to identify all “impaired” waters for which 

effluent limitations and pollution control activities are not sufficient to attain water quality 

standards and to establish total maximum daily loads to ensure future compliance with water 

quality standards. On an individual facility basis, State-administered NPDES permits issued 

under Section 402 of the CWA set limits on wastewater, stormwater, and other point source 

discharges to surface waters. Ongoing cooling and associated wastewater discharges from 

Fermi 2, which are subject to a Michigan-issued NPDES permit (Section 3.5.1.3 of this SEIS),

are a very small contributor to the pollutant and thermal loading to Lake Erie. Discharges from 

the proposed Fermi 3 plant would likewise be subject to NPDES permit requirements, which 

would effectively limit the facility’s chemical and thermal contributions to Lake Erie in 

accordance with Michigan’s water quality-based effluent limitations. In summary, a substantial 

regulatory framework exists to address current and potential future sources of water quality 

degradation within the Great Lakes Basin while addressing legacy issues. 
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Climate Change Considerations

The NRC staff also considered the USGCRP’s most recent compilations of the state of 

knowledge relative to global climate change effects (USGCRP 2009, 2014). As detailed in 

Section 4.15.3.2 of this SEIS, an increase in average temperatures in Michigan has been

observed, and climate models project continued warming in the Midwest region during the 

license renewal period. This warming coupled with predicted changes in the timing, intensity, 

and distribution of precipitation, which have already been observed, would have implications for 

surface water availability in the western basin of Lake Erie and ambient water quality.

In the NUREG–2105 prepared for the Fermi 3 COL review (NRC 2013a), the NRC staff 

projected that water levels could decrease by up to 1.5 ft (0.5 m) by about 2050 to 2060 

because of rising lake water temperatures, resulting in the reduction of the volume of Lake Erie 

by 2 percent. This decrease in lake water levels, in turn, would measurably reduce its storage 

volume from an estimated 128 trillion gal (0.48 trillion m3

) of water to 125 trillion gal 

(0.47 trillion m3

) (annualized as 342,466 mgd). Assuming a linear correlation between 

volumetric loss in Lake Erie and outflow from Lake Erie to Lake Ontario (excluding the Welland 

Canal diversion), this projected loss would reduce natural outflow via the Niagara River from 

about 206,202 cfs (5,825 m3

/s or 133,292 mgd) to 202,078 cfs (5,798 m3/s or 130,626 mgd). 

Under this possible scenario, Fermi 2 and Fermi 3’s combined consumptive use of 40 mgd

would remain a very small percentage (i.e., 0.01 percent) of the annualized volume of Lake Erie 

and about 0.03 percent of the average daily volume of water that would drain from Lake Erie to 

Lake Ontario. On a cumulative basis, the projected future consumptive water use (211 mgd, 

given a 10-percent population growth) for all users withdrawing water from the Michigan portion 

of the western basin of Lake Erie would equate to 0.06 percent of the annualized volume of 

Lake Erie and approximately 0.16 percent of the average daily volume of water that would drain 

from Lake Erie to Lake Ontario.

Nevertheless, the analysis (NRC 2013a) was based on the USGCRP’s report (USGCRP 2009)

and companion studies that predicted greater temperature and associated lake level impacts 

(i.e., a 1.5-ft (0.5-m) decline) under the highest emissions scenario. Although great uncertainty 

persists with respect to regional warming, future precipitation patterns, and related factors, the 

latest projections indicate that Lake Erie surface water temperatures could increase by 2.8 to 

5.7 °F (1.6 to 3.2 °C) under a low-emission-modeled scenario and 2.7 to 7.0 °F (1.5° C to 

3.9 °C) under a high-emission-modeled scenario by 2050. This projection is driven by 

increased evaporative losses despite the increases in the frequency and intensity of extreme 

(heavy) precipitation across the region. Furthermore, annual mean water levels for Lake Erie 

are projected to be below historical levels, with the potential for average water levels to 

decrease by 7.8 to 9.8 in. (20 to 25 cm) as compared to the current long-term mean by 2050 

(Mackey 2012). As a result, the volumetric loss in Lake Erie may be lower than that presented 

by NUREG–2105 (NRC 2013a).

Climate change is projected to increase water demand across most of the United States. 

However, when accounting for changes in proposed population coupled with predicted climate 

change impacts, current projections indicate that southern regions of Michigan (where Fermi 2

is located) will not experience increases in water demand; conversely, northern areas of 

Michigan may experience an increase of up to 10 percent attributable to climate change 

(USGCRP 2014, Figure 3.11).

As for direct water quality implications, higher temperatures and increased runoff associated 

with heavy precipitation events would impact the near-shore thermal regime of Lake Erie along 

with increases in runoff laden with nutrients, sediment, and other contaminants. More 

specifically, higher surface water temperatures decrease the cooling efficiency of thermoelectric 
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power generating facilities and plant capacity because of the need to reduce the discharge of 

thermal effluent (USGCRP 2014). As intake water temperatures warm, cooling water makeup 

requirements increase. Degraded surface water quality also increases the costs of water 

treatment for both industrial cooling water and potable water because of the need for increased 

filtration and higher additions of chemical treatments, including for disinfection. Power plants, 

other industrial interests, and public water supply facilities would have to account for such 

changes in operational practices and procedures and perhaps would require investment in 

additional infrastructure and capacity. Specific to Fermi 2 and the proposed Fermi 3, the 

warming of lake waters would lead to an increase in the average monthly use of cooling water 

and would result in a slightly larger volume of heated water discharged back to the lake, along 

with an increase in the size of their thermal plumes and associated mixing zones (NRC 2013a). 

As previously indicated, thermal and chemical discharges would be required to meet applicable 

NPDES permit requirements under the Federal CWA, local and regional health standards, and 

total maximum daily loads imposed by the State of Michigan. Such provisions would also apply 

in other states where the pollutant sources reside within their jurisdiction.

In summary, the waters of Lake Erie are extensively used, and the region has surface water

planning, allocation, related environmental quality improvement, and development systems and 

programs in place to manage the use of the surface water resources of the Great Lakes Basin 

as a whole. The withdrawal of surface water and associated consumptive water use to support 

Fermi 2 operations have a very small impact on the availability of surface water, and the 

discharge of cooling and associated wastewater in accordance with NPDES permit provisions is

a very small contributor to the pollutant and thermal loading to Lake Erie. Consumptive water 

use by continued operations of Fermi 2, combined with consumptive use by other present and 

potential future users in the western basin of Lake Erie, will continue to be a very small 

percentage of the annualized volume of Lake Erie and of the average daily volume of water that 

drains from Lake Erie to Lake Ontario. Furthermore, it is reasonable to assume that water 

quality-based effluent limits imposed by NPDES permits on cooling water, wastewater, and 

stormwater discharges and similar limits on sources of development, agricultural, and urban 

runoff will continue to maintain or improve ambient surface water quality across the western 

basin of Lake Erie.

Based on this evaluation, the NRC staff concludes that the cumulative impacts from past, 

present, and reasonably foreseeable future actions and trends on surface water resources 

during the license renewal term would be SMALL to MODERATE. A SMALL impact would be 

expected under the condition of minimal climate change associated with the lowest emissions 

scenario and lower population growth and development. A MODERATE impact would be 

expected under the highest emissions scenario, which is expected to produce the highest 

increases in air and water temperatures, and higher population growth and development. 

Projected increases in air and water temperature combined with water supply and treatment 

demands could noticeably alter water levels and affect near-shore water quality, but the impacts 

are not expected to destabilize the dependent resources and the surrounding environment. 

This conclusion is based, in part, on consideration of the cooperative planning and regulatory 

framework established by the regional and international partners under the Compact and the 

2005 Great Lakes–St. Lawrence River Basin Sustainable Water Resources Agreement.

4.16.3.2 Groundwater Resources

This section addresses the direct and indirect effects of license renewal on groundwater use 

and quality when added to the aggregate effects of other past, present, and reasonably 

foreseeable future actions. In 2013, the NRC published a final EIS that considered the 

cumulative impacts of the continued operation of Fermi 2 and the construction and operation of 

a new reactor (Fermi 3) at the Fermi site. This evaluation concluded that the cumulative 
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impacts of preconstruction, construction, and operation of the proposed new reactor and the 

continued operation of Fermi 2 on groundwater resources would be SMALL (NRC 2013a).

Laterally, the geographic area of interest is considered to be the area within 15 mi (24 km) of the 

Fermi site and vertically to be the unconsolidated material beneath the Fermi site and the Bass 

Islands Group aquifer. From a local standpoint, changes within the unconsolidated material 

would not affect any other groundwater users. From a regional standpoint, the Bass Islands 

Group aquifer is tapped for public water supply, industrial use, thermoelectric power generation, 

agricultural irrigation, golf course irrigation, and dewatering for quarry mining operations. In 

Monroe County, only a small percentage (0.59 percent) of the total water use in 2004 was from 

groundwater. Of that amount, approximately 1.6 percent was used for public water, and 

82.5 percent was used to supply industrial facilities (MDEQ 2015b). Groundwater elevations in 

the vicinity of the Fermi site have declined between 10 and 15 ft (3 to 4.6 m) since the 

early 1990s as a result of dewatering from offsite quarry operations elsewhere in Monroe 

County. It is estimated that by 2060, total freshwater groundwater withdrawals in Monroe 

County would increase from about 28 mgd in 2000 to 49 mgd (106,000 to185,000 m3

/d) 

(NRC 2013a).

For the proposed Fermi 3 reactor, preconstruction and construction dewatering operations 

would temporarily lower groundwater levels in the vicinity of the Fermi site. However, the 

wetlands on and around the site are expected to be unaffected because they are hydraulically 

connected to Lake Erie. Because of their low yield and spatial discontinuity, the unconsolidated 

sediments are not used or likely to be used in the future as a source of groundwater at the 

Fermi site or the area immediately surrounding the site. The unconsolidated sediments are in 

direct contact with Lake Erie in many places. Slurry walls will be in place around the dewatering 

operation to limit groundwater inflows from the unconsolidated sediments into building 

excavations. Consequently, it is unlikely that there would be a noticeable drawdown in 

unconsolidated sediments outside the new reactor construction area. 

To construct the new reactor, dewatering wells for building excavations will only pump 

groundwater from the Bass Islands Group aquifer. Groundwater wells that could be affected by 

drawdown from dewatering during the building of Fermi 3 are nearby residential/private wells, 

irrigation wells, and other wells that extract water from the Bass Islands Group aquifer. It is 

estimated that, at a distance of 1.5 mi (2.4 km) from the Fermi site, water levels in the Bass 

Islands Group aquifer would at most be lowered by 1 ft (0.3 m) below current water levels. 

According to groundwater modeling scenarios, the offsite well with the highest amount of 

projected drawdown is a domestic water supply well located about 3,800 ft (1,158 m) from the 

center of the Fermi 3 reactor power block area where drawdown would be up to 2 ft (0.6 m) 

(NRC 2013a). 

The proposed Fermi 3 reactor and the existing Fermi 2 reactor would not use groundwater for 

operations. There would be no discharges to groundwater from either reactor. Temporary 

dewatering operations during preconstruction and construction activities for the proposed new 

reactor would have limited spatial effect and would not affect the overall productivity of the Bass 

Islands Group aquifer. Operations of the existing and proposed new reactor are not expected to 

impact the quality of groundwater in any aquifers that are a current or potential future source of 

water for offsite users.

As discussed in Section 4.15.3.2, increased precipitation in the fall, winter, and spring is likely to 

result in increased groundwater recharge. Precipitation falling in the fall, winter, and spring 

would experience lower evaporation and transpiration rates (as opposed to the summer), and 

more water would percolate into the ground and down to the water table. Furthermore, a 
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portion of the winter precipitation would fall as snow. Instead of running off the land, much of 

the snow is likely to slowly melt in place and contribute to groundwater recharge.

Groundwater supplies near the site are not likely to be impacted by future climate change. 

Local aquifers under the site are in hydrologic communication with Lake Erie. If groundwater

levels in the local aquifers rise, more water will be discharged by these aquifers to Lake Erie. 

Alternatively, should groundwater levels in the local aquifers decrease, more water would flow 

from the lake into the local aquifers. Any future climate impacts on Lake Erie water levels are 

not anticipated to change this natural rhythm. Figure 3–13 in Section 3.5.2.1 illustrates the 

phenomenon, which shows groundwater flowing from Lake Erie as a result of quarry dewatering 

activities and groundwater flowing into the lake in those areas that are not impacted by 

dewatering activities.

The Fermi site does not use groundwater. Future climatic changes should not result in changes 

to site operations. There should not be any increased impacts to the availability and quality of 

groundwater resources.

Considering ongoing activities and reasonably foreseeable actions, the NRC staff concludes 

that the cumulative impacts on groundwater use and quality during the Fermi license renewal 

term would be SMALL.

4.16.4 Terrestrial Resources

This section addresses the direct and indirect effects of license renewal on terrestrial resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. Section 4.6 of this SEIS finds that the direct and indirect impacts on terrestrial 

resources from the proposed license renewal when considered in the absence of the aggregate 

effects would be SMALL. The cumulative impact is the total effect on terrestrial resources of all 

actions taken, no matter who has taken the actions (the second principle of cumulative effects 

analysis in CEQ 1997).

Two related concepts bound the analysis of cumulative impacts: (1) the timeframe and 

(2) geographic extent. The timeframe for cumulative analyses for ecological resources extends 

far enough into the past to understand the processes that affect the present resource conditions 

and to examine whether and why terrestrial resources are stable or unstable, which the NRC’s

definitions of impact levels require. The timeframe for cumulative impact analysis is more 

extensive than that for the direct and indirect impact analysis.

The geographic extent considered in this cumulative terrestrial resource analysis depends on 

the particular cumulative impacts being discussed. Direct and indirect impacts from Fermi 2

operation are largely limited to the Fermi site and immediate vicinity. However, projects or 

actions located beyond this geographic area could directly or indirectly affect terrestrial 

resources in this area. This section focuses on the cumulative effects of such actions.

The level of cumulative impacts is measured against a baseline. Consistent with other Federal 

agencies’ and the Council on Environmental Quality’s (CEQ 1997) NEPA guidance, the term 

“baseline” pertains to the condition of the resource without the action (i.e., under the no-action 

alternative). Under the no-action alternative, the plant would shut down, and the resource would 

conceptually return to its condition without the plant (which is not necessarily the same as the 

condition before the plant was constructed). The baseline, or benchmark, for assessing 

cumulative impacts on terrestrial resources takes into account the preoperational environment 

as recommended by EPA (1999) for its review of NEPA documents.
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Past Development and Habitat Alteration 

As discussed in Section 3.6, the Fermi site was partially disturbed during construction of 

Fermi 2. Of the site’s 1260 ac (510 ha), 212 ac (86 ha) were permanently converted for 

industrial use to support the decommissioned Fermi 1 and Fermi 2 buildings and infrastructure. 

A series of quarry lakes were formed when water filled abandoned rock quarries that were 

created during construction, which further reduced the site’s terrestrial habitat. Much of the land 

was also graded to raise the site elevation, which temporarily destroyed existing terrestrial 

habitats. Scattered stumps in forested tracts along the southern edge of the site indicate that 

the site was likely logged before Fermi 2 construction (DTE 2014a). Many of the site’s natural 

areas have since recovered from these activities but may not have the species diversity or 

richness they once contained. Green ash (Fraxinus pennsylvanica) was formerly common 

within the site’s forests before the emerald ash borer (Agrilus planipennis), an invasive beetle, 

killed most of the ash trees on the site (DTE 2014a). Other areas of the site, such as the land 

managed by the FWS as part of the DRIWR, has remained unaltered.

In the broader area—the Southern Lower Peninsula within the Maumee Lake Plain Level IV 

Ecoregion—native tallgrass prairies, wetlands, and floodplain forests have been converted to 

agricultural and urban land, which now account for the major land use types (MDNR 2006a). 

Habitat loss, in general, can negatively affect breeding success, dispersal success, predation 

rate, and other animal behaviors (Fahrig 2003). Habitat fragmentation (the breaking up of a 

larger area of habitat into smaller patches of smaller total area) can also negatively affect 

terrestrial biota. In a study of breeding bird communities in 24 Illinois grassland fragments, 

Herkert (1994) found that fragmentation was likely a factor in Midwestern grassland bird 

population declines. A study conducted in 2012 on the partridge pea (Chamaecrista fasciculata)

(Mannouris and Byers 2013) concludes that native prairie plant species that occur in smaller, 

isolated prairie fragments are likely to suffer a reduction in genetic fitness. The Michigan 

Department of Natural Resources (MDNR 2006a) reports that almost all of the original tallgrass 

and wet prairies have been converted to farmland, and most of the oak savannahs in the State 

have been eliminated or converted to closed-canopy forest due to fire suppression. 

Accordingly, remaining native populations in these habitats are likely to suffer from reduced 

genetic fitness, which is further exacerbated by fragmentation. 

Energy Production and Development

One nuclear power plant site with one operating reactor (Davis-Besse Nuclear Power Station, 

Unit 1 (Davis-Besse)) lies within 50 mi (80 km) of the Fermi site. Because the effects of this 

facility would primarily be limited to the terrestrial resources on the Davis-Besse site and 

immediate vicinity, the operation of Davis-Besse during the proposed Fermi 2 license renewal 

term would not result in cumulative effects to the terrestrial resources affected by Fermi 2

operation.

The construction and operation of Fermi 3, a proposed new nuclear plant on the Fermi site, 

could result in cumulative impacts on terrestrial resources during the license renewal term. The 

NRC (2013a) has previously concluded that the impacts of construction and operation of 

Fermi 3 on terrestrial resources would be SMALL to MODERATE (with MODERATE impacts 

limited to the eastern fox snake). These impacts would primarily result from construction-related 

loss or disturbance of upland and wetland habitat and associated plant and animal species on

site and along transmission line corridors (NRC 2013a). Construction would also necessitate 

DTE (2014c) to modify its cooperative agreement with the FWS for management of the DRIWR 

to allow for temporary construction buildings and laydown area and construction of permanent 

site access roads and a meteorological tower. Proposed wetland and wildlife habitat mitigation

would offset some impacts, including those potential impacts to the eastern fox snake 
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(State-listed as threatened) and its habitat (NRC 2013a). Fermi 3 operational impacts would be 

similar to those discussed in Section 4.6.1 for the proposed license renewal of Fermi 2.

Decommissioning activities associated with Fermi 1, which terminated operations in 1972, 

would likely be confined to the developed portion of the Fermi site and would not result in 

noticeable cumulative effects to the terrestrial environment.

Four coal-fired energy facilities operate in the region (Table E–1 in Appendix E) and vary in 

proximity from 6 mi (10 km) to 26 mi (42 km) from the Fermi site. An additional natural gas-fired 

facility, Oregon Clean Energy Center, is under construction, and other coal and gas energy 

projects may arise over the proposed license renewal term. Air emissions from these facilities 

include GHGs, such as nitrogen oxides, carbon dioxide, and methane, all of which can have 

far-reaching consequences because they cumulatively contribute to climate change. The 

effects of climate change on terrestrial resources are discussed in Section 4.15.3.2.

Development, Urbanization, and Habitat Fragmentation 

As the region surrounding the Fermi site becomes more developed, habitat fragmentation will 

increase and the amount of forested, prairie, and wetland habitat is likely to decline further. 

Transmission lines and associated corridors established to connect Fermi 2 and other 

energy-producing facilities to the regional electric grid represent past habitat fragmentation 

because some of the corridors split otherwise continuous tracts of habitat. Construction of 

transmission lines associated with new energy projects may also result in habitat fragmentation 

if the lines are not collocated within existing corridors or sited within previously developed areas. 

Edge species that prefer open or partially open habitats will likely benefit from the 

fragmentation, whereas species that require interior forest or wetland habitat will likely suffer. 

Continued urbanization in the future will likely include construction of additional housing units 

and associated commercial buildings; roads, bridges, and rail; and water or wastewater 

treatment and distribution facilities and associated pipelines. Increased development will likely 

decrease the overall availability and quality of terrestrial habitats. Species that require larger 

ranges, especially predators, will likely suffer reductions in their populations. Similarly, species 

with threatened or endangered Federal or State status or otherwise declining populations would 

be more sensitive to declines in habitat availability and quality. Native prairie plants will likely 

continue to experience reductions in genetic fitness, as previously discussed.

Wildlife Refuges, State Parks, and Recreational Areas

A number of wildlife refuges, State parks, and recreational areas located near Fermi 2

(Table E–1 in Appendix E) provide valuable habitat to native wildlife, migratory birds, and 

protected terrestrial species and habitats. As fragmentation and land use changes continue, 

these protected areas will become ecologically more important because they provide large, 

uninterrupted areas of minimally disturbed habitat. The DRIWR, which comprises nearly 

6,000 ac (2,400 ha) of coastal wetlands, marshes, shoals, waterfront lands, and islands along 

48 shoreline miles (77 km) along the lower Detroit River and western shore of Lake Erie, 

provides particularly high-quality habitat to many species of native wildlife and migrating birds.

As discussed in Sections 3.2 and 3.6.5.2, the Lagoona Beach Unit of the DRIWR is managed by 

the FWS through a cooperative agreement between DTE and the FWS that the parties entered 

into in 2003. DTE intends to maintain the cooperative agreement with the FWS for 

management of the DRIWR Lagoona Beach Unit throughout the proposed license renewal term. 

However, if Fermi 3 is built, modifications to the agreement, which are discussed above under

the section entitled, “Energy Production and Development,” would be made that could result in 

temporary and permanent reductions in terrestrial habitat.
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4.16.4.1 Conclusion

NRC staff concludes that the cumulative impacts on terrestrial resources in the vicinity of the 

Fermi site are MODERATE to LARGE based on past, present, and reasonably foreseeable 

future actions. This level of impact is primarily the result of past habitat alteration and loss on 

the Fermi site and within the larger Maumee Lake Plain Level IV Ecoregion. The environmental 

effects of these actions are clearly noticeable and have destabilized important attributes of 

certain terrestrial communities. The loss of genetic fitness of native prairie species and the loss 

of tallgrass prairies, wet prairies, and oak savannahs are demonstrative of such effects. The 

incremental, site-specific impact from the continued operation of Fermi 2 during the license 

renewal period would be an unnoticeable or minor contributor to cumulative impacts on 

terrestrial resources.

4.16.5 Aquatic Resources

This section addresses the direct and indirect effects of license renewal on aquatic resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. The geographic area considered in the cumulative aquatic resources analysis includes 

the western basin of Lake Erie, along which the Fermi site is located.

Consistent with NEPA guidance from other agencies and the CEQ (1997), the term “baseline” 

pertains to the condition of the resource without the action (i.e., under the no-action alternative). 

Under the no-action alternative, the plant would shut down, and the resource would 

conceptually return to its condition without the plant (which is not necessarily the same as the 

condition before the plant was constructed). The baseline, or benchmark, for assessing 

cumulative impacts on aquatic resources takes into account the preoperational environment as 

recommended by EPA (1999) for its review of NEPA documents.

Designating existing environmental conditions as benchmark may focus the environmental 

impact assessment too narrowly, thus overlooking cumulative impacts of past and present 

actions or limiting assessment to the proposed action and future actions. For example, if the 

current environmental condition were to serve as the condition for assessing the impacts of 

relicensing a dam, the analysis would only identify the marginal environmental changes 

between the continued operation of the dam and the existing degraded state of the 

environment. In this hypothetical case, the affected environment has been seriously degraded 

for more than 50 years with accompanying declines in flows, reductions in fish stocks, habitat 

loss, and disruption of hydrologic functions. If the assessment took into account the full extent 

of continued impacts, the significance of the continued operation would more accurately express 

the state of the environment and thereby better predict the consequences of relicensing the 

dam.

Other power plants that affect or may affect the aquatic resources near the Fermi site include 

the Monroe Power Plant and the proposed Fermi 3 nuclear generating station that would be 

built on the Fermi site. The Monroe Power Plant is a coal-fired power plant that is also located 

in Monroe, Michigan, on the western shore of Lake Erie 6 miles (10 km) southwest of the Fermi 

site. It is owned by DTE, a subsidiary of DTE Energy. The plant has four generating units, each 

with an output of 850 MW, and it is the eleventh largest electric plant in the United States. The 

plant has a once-through cooling water system that withdraws and discharges cooling water 

from Lake Erie under NPDES Permit No. MI0001848. The permit authorizes the plant “to 

discharge a maximum of 1,978 MGD of noncontact cooling water, fly ash transport water, 

bottom ash transport water, coal pile runoff, chemical metal cleaning wastes, nonchemical metal 

cleaning wastes, boiler water drained from boilers during outages, treated flue gas 

desulfurization wastewater, flue gas desulfurization pre-treatment system backwash, 
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demineralizer regeneration wastes, miscellaneous low volume wastes, and storm water runoff.” 

The permit has no temperature limits, but it does require monitoring of discharge temperature 

and a maximum thermal loading to the lake of 15,500 million BTU per hour.

Jensen (1982) applied a fisheries stock assessment model to assess the entrainment and 

impingement impact of the Monroe Power Plant on the yellow perch standing stock and fishery 

in the western basin of Lake Erie. He found that the impact of the Monroe Power Plant is 

relatively small in that it decreases biomass and the maximum sustainable yield of the yellow 

perch stock by only a few percent. 

Several other coal-fired power plants with once-through cooling water systems are located and 

operated near the Fermi site, including the 520 MW Trenton Channel Power Plant, located 

12 miles (19 km) north-northeast on the Detroit River; the 136 MW Bayshore Power Plant, 

located 20 miles (32 km) south-southwest on Lake Erie at Maumee Bay; and the 540 MW River 

Rouge Power Plant, located 26 miles (42 km) north-northeast on the Detroit River. All of these 

power plants adversely affect aquatic resources though entrainment, impingement, and thermal 

discharges, although the NRC staff did not find any reports quantifying these effects at these 

power plants.

Davis-Besse is a single-unit nuclear power plant located in Ottawa County, Ohio, 27 mi (43 km) 

southeast of the Fermi site on Lake Erie. Davis-Besse uses closed-cycle cooling with a cooling 

tower to recirculate up to 95 percent of the cooling water. The plant is licensed for an electrical 

output of 2,817 megawatt thermal (MWt) and 908 MWe. The closed-cycle cooling reduces the 

need for cooling water, which minimizes the effects of impingement, entrainment, and the 

thermal discharge. In studies of phytoplankton, zooplankton, benthic invertebrates, and 

ichthyoplankton at 25 sites in Lake Erie from 1972 through 1979, Reutter et al. (1980) reported 

finding no clear correlations between any aquatic populations and Davis-Besse’s thermal 

discharge. In 1980, CLEAR conducted studies of the effects of impingement (Reutter 1981b) 

and entrainment (Reutter 1981a) at Besse-Davis. Reutter (1981a) concluded that the 

entrainment losses at Davis-Besse were relatively small when compared to lake-wide 

populations and that the loss of gizzard shad, walleye, and perch eggs and larvae accounted for 

a loss of fecundity of less than 0.2 percent of the number captured in sport fishing in 1980. 

NRC (2015b) reviewed these studies and others and found that the direct and indirect impacts 

of license renewal for Davis-Besse would be SMALL according to the NRC’s definitions of level 

of impact for the purposes of NEPA. The NRC (2015b) also found that the cumulative impact of 

past, present, and reasonably foreseeable future actions on aquatic resources in the western 

basin of Lake Erie where the Davis–Besse site (as well as the Fermi site) is located would be 

LARGE because of the effects of invasive species, fishing, energy development, urbanization 

and shoreline development, and climate change. 

In 2008, Detroit Edison Company submitted to the NRC an application for a COL for Fermi 3 to 

be located on the Fermi site adjacent to the existing Fermi 1 and Fermi 2. The proposed plant 

would have a thermal power rating of 4,500 MWt and would use a closed-cycle, wet cooling 

system with a natural-draft cooling tower for heat dissipation. The NRC (2013a) reviewed the 

application and concluded that the impacts of preconstruction and construction activities on 

aquatic biota and habitats would be SMALL and that, because “NRC-authorized construction 

activities represent only a portion of the analyzed activities, the NRC staff concludes that the 

impacts of NRC-authorized construction activities would be SMALL.”

To categorize levels of environmental impact, the NRC uses criteria based on (1) whether the 

impact is discernable or observable and (2) whether the impact has destabilized an important 

attribute of the resource in question. In considering the cumulative impacts of license renewal 

to aquatic resources of Lake Erie in the vicinity of Fermi 2, the NRC staff finds that the ecology 
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of Lake Erie exhibits readily observable cumulative impacts that have destabilized the aquatic 

ecosystem, even though the direct and indirect effects of Fermi 2 are small. The following 

discussion summarizes how the aquatic community became destabilized.

The action area for license renewal is very small in relation to the size of Lake Erie and the 

Great Lakes Basin, but the processes that affect Lake Erie affect the action area. Degradation 

of Lake Erie has a long history, and much has been written about its causes, processes, and 

mitigation. It probably began early in the 1800s with massive forest cutting, construction of 

sawmills and dams, and the draining of wetlands. The human population and the economy of 

the Great Lakes watershed increased dramatically between about 1900 and the 1950s, which 

increased the load of plant nutrients to the lakes that caused anthropogenic eutrophication. 

Major industrial expansion occurred in the 1940s, prompted by the demands for chemicals, 

steel, rubber, and other products for the Second World War, and brought with it large-scale 

chemical and heavy metal discharges to the lakes. Peak pollution may have occurred in 

the 1960s and 1970s, and Lake Erie was called “America’s Dead Sea.” In the 1970s, the United 

States and Canada initiated a bi-national effort in nutrient and pollution abatement—the Great 

Lakes Water Quality Agreement signed first in 1972 and renewed in 1978 (EPA 2012a)—and 

those effort continue. The CWA of 1973 initiated a major U.S. effort to restore water quality in 

the Great Lakes, and it has had dramatic results (Burlakova et al. 2014).

One definition of eutrophication (Art 1993; USGS 2014) is as follows:

The process by which a body of water acquires a high concentration of nutrients, 

especially phosphates and nitrates. These typically promote excessive growth of 

algae. As the algae die and decompose, high levels of organic matter and the 

decomposing organisms deplete the water of available oxygen, causing the 

death of other organisms, such as fish. Eutrophication is a natural, slow-aging 

process for a water body, but human activity greatly speeds up the process.

The western basin of Lake Erie, where the Fermi site is located, has experienced severe 

eutrophication with accompanying blooms of toxic algae and low dissolved oxygen levels. 

Burlakova et al. (2014) provide a history of eutrophication and its effects on Lake Erie ecology, 

particularly in the benthos. Before human-driven eutrophication, mayflies (Ephemeroptera) and 

caddisflies (Trichoptera) were very abundant in western Lake Erie. Members of both of these 

insect orders typically live most of their lives as immature aquatic larvae followed by a very 

short-lived flying adult reproductive stage. In the 1930s, the benthic community of the western 

basin was dominated by the mayfly (Hexagenia) and the caddisfly (Oecetis), with average 

mayfly densities of 300 to 500 meter−2 (m-2

) (yard-2) (yd-2) and a maximum average to up to 

1,000 m−2 (yd-2

). These extensive Hexagenia populations were devastated in September 1953 

as a result of the first recorded significant large-scale depletion of dissolved oxygen in the 

western basin. Densities of mayflies somewhat recovered in 1954 but then were reduced again 

almost to extirpation in 1960s. The western basin is highly susceptible to human-caused 

eutrophication because of its shallow depth (average depth 7.4 m (24 ft)); discharge of the 

major tributaries (the Detroit and Maumee rivers, which account for 90 percent of the organic 

loading and 84 percent of the water volume entering the lake); and its proximity to large urban 

centers, such as Detroit and Toledo. Extensive changes have occurred in other groups of 

benthos, including a sharp decline in the density of Oecetis and a large increase in the taxa 

tolerant to organic enrichment, particularly tubificid worms and midge larvae (flies of the family

Chironomidae). Hexagenia populations in Lake Erie started to recover in the 1990s, most likely 

due to pollution abatement programs and ecological changes brought about by the invasive 

non-native zebra mussel Dreissena polymorpha.
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Under the Great Lakes Water Quality Agreement of 1972, the United States and Canada 

undertook an extensive binational effort to reduce and eliminate sources of pollution to Lake 

Erie, including bans on the sale of phosphate detergents, improvements in organic waste 

collection and treatment systems, and reductions in industry discharges. The results were 

dramatic and, in some cases, occurred more rapidly than expected. Water quality in the lake 

responded to those measures; open-lake concentrations of total phosphorus, chlorophyll a, 

phytoplankton abundance, and biomass were reduced by the mid-1980s, and the pelagic 

ecosystem became less eutrophic (Burlakova et al. 2014).

Algal blooms resulted from the eutrophication. By the mid- to late-1960s, seasonal algal blooms 

were reported over the entire portion of the western basin of Lake Erie. Mats of algae washed 

ashore, fouling beaches. In the 1970s, algal blooms occurred annually, predominated by 

Aphanizomenon flos-aquae, but such blooms were reported as decreasing in intensity and 

number. No massive algal blooms were reported during the early 1980s, and algal blooms, 

when present, were predominated by A. flos-aquae. In the mid-1980s, zebra and quagga 

mussels arrived in Lake Erie, and their effects are discussed below. In 1995 and 1998, large 

algal blooms of Microcystis, a toxic cyanobacteria or blue-green alga, were reported in western 

Lake Erie. During the 2000s, blooms of toxic Microcystis were common in the western basin. In 

August 2003, a massive bloom of Microcystis aeruginosa formed in western Lake Erie and 

persisted for nearly a month. Recent research indicates that recent algal blooms in western 

Lake Erie are linked to nutrient loading, nutrient releases by zebra mussels, and selective 

feeding by zebra mussels, but much more work needs to be done (EPA 2014i).

The Great Lakes Water Quality Agreement brought about substantial improvements in water 

quality (Munawar et al. 2005), but the factors disrupting Great Lakes aquatic ecosystems are 

not limited to chemical contamination and nutrient pollution that results in eutrophication and low 

dissolved oxygen levels. Invasive non-native species have and are destabilizing the 

Great Lakes ecosystems. Knowing the exact number of invasive species at any time is difficult. 

Sharp (2007) estimates that a new non-native species is discovered in the Great Lakes about 

once every 7 months. Gunderson (undated) reports that the Great Lakes harbor 182 non-native 

species, including 55 rooted plants, 27 species of algae, 49 invertebrates, 18 mollusks, 

20 crustaceans, 23 pathogens, and 28 species of fish. Of the 28 fish, 9 were intentionally 

stocked, and 19 were unintentionally introduced.

At one time, Niagara Falls prevented many non-native species from migrating to the Upper 

Great Lakes (i.e., those above Lake Ontario, including Lake Erie). Construction of locks and 

canals allowed species to migrate into the lakes or to come in with ship ballast water. The 

Great Lakes are now connected to the Mississippi River and Gulf of Mexico by means of a 

diversion out of Lake Michigan, to James Bay and Hudson Bay through a diversion into 

Lake Superior, and to the Hudson River Drainage through the Erie Canal (Gunderson undated).

Perhaps the first non-native invasive species to enter the Great Lakes were sea lampreys 

(Petromyzon marinus) and alewives (Alosa pseudoharengus), which were initially recorded in 

Lake Ontario in the 1800s after the opening of the Erie Canal in 1825 (Sharp 2007). Niagara 

Falls kept invasive species out of the four Upper Lakes—Erie, Huron, Michigan and Superior—

until 1829 when the Welland Canal opened a waterway between Lakes Ontario and Erie. Sea 

lamprey were first reported in Lake Erie in 1921, 2 years after the Welland Canal was enlarged. 

Sea lamprey are predatory fish that attach themselves to other fish species, and their prey may 

then die from the wound, from a secondary infection, or from predation due to weakened 

condition and increased vulnerability. Combined with overfishing and pollution, sea lamprey 

had driven native lake trout (Salvelinus namaycush) populations almost to extinction (Domske 

and O’Neill undated).
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Alewife, a small-sized member of the herring family, may have moved through the Erie Canal 

into the Great Lakes Basin from the Atlantic drainage, or they may have been stocked into the 

lake accidentally after being misidentified as juvenile shad (the two look very similar in their 

early life stages). Alewives have affected the ecosystem because they are superior competitors 

that have been able to outcompete native fishes like lake herring (Coregonus artedi), bloaters 

(C. hoyi), and whitefish (C. clupeaformis) and because they also feed readily on young native 

fish species, including lake trout, yellow perch (Perca flavescens), walleye (Sander vitreus), and 

whitefish (Domske and O’Neill undated).

When the populations of the top predators that might have fed on alewives were decimated, 

alewife populations dramatically increased until they comprised up to 80 percent of the fish 

biomass in the Great Lakes (Sharp 2007). Beginning in 1966, the states around the lakes 

attempted to control the alewife population by introducing non-native predatory Pacific salmon, 

chinook (Oncorhynchus tshawytscha) and coho (O. kisutch), to prey on alewives (Sharp 2007). 

The alewife population in Lake Erie has become the primary food resource of adult non-native 

Pacific salmon and native lake trout (Domske and O’Neill undated). Alewives feed primarily on 

plankton, and another invasive non-native species, the zebra mussel (Dreissena polymorpha), 

consumed so much plankton in Lake Huron by 2003 that alewives disappeared, which caused 

the salmon fishery to collapse (Sharp 2007). 

Zebra mussels are one of two related bivalve species; the other is the quagga mussel 

(D. bugensis). together often called dreissenids, that were carried to the United States as 

planktonic larvae in the freshwater ballast of freighters coming from the Black and Caspian Sea 

regions of eastern Europe and western Asia. Although small individually, these mussels can 

filter up to 2 liters (2 quarts) of water per day per adult mussel from which they primarily 

consume phytoplankton (the microscopic plant life that forms the base of the aquatic food 

chain), small zooplankton (tiny aquatic animals), and bacteria. Filtered material is expelled and 

drops to the bottom as feces (consumed matter) or pseudofeces (unconsumed matter) and is 

removed from the water column. Colonies of these mussels can reach densities of up to 

several hundred thousand mussels per square meter (1.2 square yards), and their removal of 

plankton from the lakes has dramatically increased water clarity. An individual female 

dreissenid can produce up to a million eggs per year, and the planktonic larvae are dispersed by 

waves and water currents before they settle out of the water column, attach, and form colonies 

(Domske and O’Neill undated).

Zebra mussels have profoundly affected the Great Lakes ecosystem (EPA 2015a). Through 

their filter-feeding, they divert nutrients from open water to lake bottom systems. 

Bottom-feeding fish (and their predators) then gain advantage over fish, such as alewife and 

smelt (and their predators), that feed in the open water. Aquatic rooted plants (macrophytes) 

and their associated communities (which include largemouth bass) thrive in water cleared by 

zebra mussels, whereas habitat is reduced for species, such as walleye that are adapted to 

turbid waters. In areas where zebra mussels abound, common algae-eating species of 

microbenthos have been replaced by opportunistic omnivorous and bacteria-eating species 

(EPA 2015a). In Lake Erie, declines in phytoplankton size structure and changes in community 

composition along with significant declines in primary productivity in the west basin, where the 

Fermi site is located, have occurred following invasion by dreissenid mussels (Munawar et 

al. 2005).

Both non-native dreissenid mussels and the non-native round goby (Neogobius melanostomus) 

have shifted the food web from a pelagic-based to a benthic-based one, and this change 

potentially creates a new pathway for contaminant transfer to top predators (Hogan et al. 2007). 

Round goby is a relatively new invasive fish species in the Great Lakes that was first identified 

in the St. Clair River in 1990 and has already spread to Lakes Erie, Huron, Michigan, and 
Environmental Consequences and Mitigating Actions

4-123

Superior (EPA 2015a). Domske and O’Neill (undated) describe round gobies as an aggressive 

fish that outcompete native fish, such as sculpins, for food and territory. They are benthic fish 

with highly developed sensory systems that allow them to find food and avoid predation much 

better than the native species. They can also feed at night, which gives them an advantage 

over many native fish that typically feed only during the day. Round gobies can spawn several 

times each year, and the males guard the nests filled with eggs. This behavior reduces 

predation on the eggs and increases survival rates, and round goby populations have 

proliferated throughout the Great Lakes Basin (Domske and O’Neill undated). 

Studies by Hogan et al. (2007) in Lake Erie suggest that round gobies may influence the trophic 

transfer of mercury up the food chain to top predators and perhaps humans. Round gobies feed 

on dreissenids, which filter vast amounts of water and accumulate some contaminants. 

Smallmouth bass (Micropterus dolomieu) have a high consumption of round gobies and have 

been accumulating high levels of mercury. As smallmouth bass continue to consume round 

gobies during their lives, their mercury concentrations may continue to increase, which would 

potentially increase the risk of mercury contamination to humans.

Common carp (Cyprinus carpio) come from the Caspian Sea and parts of Asia. The U.S. Fish 

Commission originally stocked common carp in the Great Lakes Basin in the late 1800s as a 

source of “cheap” food for the future, although carp quickly fell out of favor as a food species. 

Common carp were often stocked in farm ponds from where they often escaped into nearby 

ecosystems during periods of flooding. Once released into the Great Lakes Basin, carp spread 

quickly and easily. The common carp is a very hardy species, capable of surviving in less than 

optimal habitats. As a result of their feeding behavior (they pull out plants and root around in 

the bed of lakes and streams), they degrade lakes by causing excessive turbidity (cloudiness 

caused by disturbed silt), which can lead to declines in submerged aquatic plants and 

organisms, waterfowl, and important native fish species. Common carp are also prolific 

breeders, inflicting substantial competition for habitat on other more desirable species. 

Common carp may prey on the eggs of other native fish species and, therefore, reduce 

breeding stocks of native populations. Carp negatively alter their aquatic environment and are 

generally considered a nuisance species wherever they occur (Domske and O’Neill undated)

Several other invasive species have adversely affected the Great Lakes ecosystems, including 

the cladoceran crustaceans spiny waterflea (Bythotrephes cederstroemi), fishhook waterflea 

(Cercopagis pengoi), and others. A present concern is that Asian carp may soon be introduced.

Arkansas commercial fish farmers imported bighead and silver carp (Hypophthalmichthys 

nobilis and H. molitrix) in the early 1970s to eat algae in fishponds. When the Mississippi River 

flooded the ponds in the 1980s, some of these carp escaped into the wild (some authorities 

believe that fish farmers also deliberately released carp that had grown too large) and they still 

were escaping from flooded Missouri fish farms as late as 1994. Asian carp could enter the 

Great Lakes via the Chicago Sanitary and Ship Canal, which lies about 30 mi (48 km) below 

Lake Michigan and connects Lake Michigan with the Illinois–Mississippi River system. Asian 

carp have been reported from the Canal. In 2003, Illinois researchers set nets in the Illinois 

River about 250 river miles (400 river kilometers) from Lake Michigan and reported catching 

several tons of silver and bighead carp in only 30 minutes. In 2007, Congress introduced 

legislation to provide funds for completing a permanent electronic barrier on the canal 

(Sharp 2007).

Silver carp and bighead carp grow to about 70 and 110 pounds (lb) (30 and 50 kilograms (kg)), 

respectively, in their native waters in Southeast Asia; however, in North America, the maximum 

sizes reported have so far been about 20 lb (9 kg) for silver carp and 50 lb (23 kg) for bighead 

carp. Silver carp have been in news reports because they leap 10 to 15 ft (3 to 4.5 m) out of the 
Environmental Consequences and Mitigating Actions

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water when spooked by boats, and several boaters have suffered injuries that include broken 

jaws, noses, ribs, arms, and legs after being hit by flying carp. Both species consume up to 

more than half their own weight in algae and zooplankton every day, and fisheries scientists fear 

they could completely disrupt the food web in the Great Lakes. Everywhere they have turned 

up, Asian carp have become an overwhelmingly dominant species that replaces native species, 

including bass (various species), crappies (Pomoxis spp.), bluegills (Lepomis macrochirus), 

buffalo fish (Ictiobus spp.), and catfish (Ictalurus spp.). Some fisheries scientists believe that 

Asian carp could become at least as destructive to the Great Lakes ecosystems and fisheries as 

sea lampreys and zebra mussels (Sharp 2007).

In summary, the Great Lakes aquatic ecosystem has been constantly destabilized over many 

decades by the cumulative effects of chemical contamination, nutrient pollution that results in 

eutrophication and low dissolved oxygen levels, and invasive non-native species. Lake Erie has 

undergone cycles of degradation and remediation, and these lake-wide effects affect the aquatic 

resources near the Fermi site. Continued releases of nutrients, particularly from non-point 

sources, continued introductions of invasive non-native species, continued Federal and State 

remediation efforts, and continued changes in temperature and rainfall due to climate change 

will prevent stabilization over the period of license renewal. Even without these changes, 

stability would take decades, if not centuries, to occur. Although the direct and indirect effects 

of Fermi 2 are small, the cumulative impacts of all stressors combined are readily observable 

and have destabilized the aquatic ecosystem; therefore, the level of cumulative impact is 

LARGE.

4.16.6 Historic and Cultural Resources

This section addresses the direct and indirect effects of license renewal on historic and cultural 

resources when they are added to the aggregate effects of other past, present, and reasonably 

foreseeable future actions. The geographic area considered in this analysis is the area of 

potential effect associated with the proposed undertaking, as described in Section 3.9.

The archaeological record for the region indicates prehistoric and historic occupation of the 

Fermi site and its immediate vicinity. The construction of Fermi 1 and Fermi 2 may have 

resulted in the destruction of cultural resources within the Fermi site and surrounding area. 

Previous historic land development in the vicinity of Fermi also resulted in impacts on, and the 

potential loss of, cultural resources on the Fermi site and its immediate vicinity. However, there 

remains the possibility for additional historic or cultural resources to be located within the Fermi 

site. The present and reasonably foreseeable projects that could affect these resources,

reviewed in conjunction with license renewal, are noted in Appendix E to this document. Direct 

impacts would occur if historic and cultural resources in the area of potential effect were 

physically removed or disturbed. Indirect visual or noise impacts could occur from new 

construction or maintenance. Fermi 1 decommissioning activities and Fermi 3 construction and 

operation are the projects located within the area of potential effect that were considered for 

cumulative impacts to cultural resources.

As described in Section 4.9, no cultural resources would be adversely affected by Fermi 2

license renewal activities because no physical changes or ground-disturbing activities would 

occur beyond ongoing maintenance activities during the license renewal term (DTE 2014a). 

Fermi 1 decommissioning activities and Fermi 3 construction and operation have the potential to 

result in impacts on cultural resources through inadvertent discovery during ground-disturbing 

activities. However, as discussed in Section 4.9, DTE has established site procedures and work 

instructions to ensure cultural resources at the Fermi site are considered in project planning 

during Fermi 2 operations. Therefore, the NRC staff concludes that the cumulative impact of 

license renewal on historic and cultural resources within the area of potential effect, when 
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combined with other past, present, and reasonably foreseeable future activities, would be 

SMALL.

4.16.7 Socioeconomics

This section addresses socioeconomic factors that have the potential to be directly or indirectly 

affected by changes in operations at Fermi 2 in addition to the aggregate effects of other past, 

present, and reasonably foreseeable future actions. The primary geographic area of interest 

considered in this cumulative analysis is Monroe and Wayne Counties where approximately 

78 percent of Fermi 2 employees reside (Table 3–25 in Section 3.10.1). This area is where the 

economy, tax base, and infrastructure would most likely be affected because the majority of 

Fermi 2 workers and their families reside, spend their incomes, and use their benefits within 

these two Counties.

As discussed in Section 4.10, continued operation of Fermi 2 during the license renewal term 

would have no impact on socioeconomic conditions in the region beyond what is already being 

experienced. Because DTE has no plans to hire additional workers during the license renewal 

term, overall expenditures and employment levels at Fermi 2 would remain relatively unchanged 

with no new or increased demand for housing and public services. Based on this and other 

information presented in Chapter 4, there would be no contributory effect on socioeconomic 

conditions in the region during the license renewal term from the continued operation of Fermi 2

beyond what is currently being experienced. Therefore, the only contributory effects would 

come from reasonably foreseeable future planned activities at Fermi 2, unrelated to the 

proposed action (license renewal), and other reasonably foreseeable planned offsite activities. 

For example, offsite residential development is planned throughout the Fermi 2 region. The 

availability of new housing could attract individuals and families from outside the region, thus

increasing the local population and subsequently increasing traffic on local roads and the

demand for public services. 

Fermi 1 Decommissioning

Full decommissioning of Fermi 1 is expected to be complete before initiation of Fermi 3

construction. DTE has not determined whether to remove the Fermi 1 external structure after 

the site is decommissioned and after its NRC license is terminated (NRC 2013a). Potential 

socioeconomic effects from decommissioning Fermi 1 include fluctuations in the size of the 

workforce at the Fermi site and associated changes in the demand for public services and

housing and in traffic volumes in the region. 

Construction and Operation of Fermi 3

Construction (including preconstruction) impacts could range from MODERATE to LARGE in 

Monroe and Wayne Counties for 9 to 12 years. Up to 2,900 construction workers working daily 

at the Fermi 3 site would create a considerable demand for temporary rental housing and other 

commercial and public services in the two-County region. In addition, the high volume of 

construction and commuter vehicles on local roads during shift changes would have a 

noticeable impact on traffic conditions. An estimated maximum of 2,900 workers would be 

commuting daily to the Fermi 3 construction site (NRC 2013a).

Conversely, impacts during Fermi 3 nuclear power plant operations would be SMALL to 

MODERATE. An estimated 900 Fermi 3 operations workers would need permanent housing 

and commercial and public services, such as schools, police and fire, and public water and 

electric services (NRC 2013a). The addition of 900 Fermi 3 operations workers to the current 

workforce commuting daily to the Fermi site would also have a noticeable impact on traffic 

conditions on local roads during shift changes.
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The additional 900 Fermi 3 operations workers would likely reside in the same Counties and in 

the same pattern as the current Fermi 2 workforce. Most of the operations workers would be 

expected to settle where there is readily available housing in Monroe and Wayne Counties.

4.16.7.1 Conclusion

When combined with other past, present, and reasonably foreseeable future activities (e.g., the 

decommissioning of Fermi 1 and the construction and operation of Fermi 3), the contributory 

effects of continued reactor operations at Fermi 2 would have no new or increased impact on 

socioeconomic conditions in the region beyond what is currently being experienced. The 

contributory effects from the construction and operation of Fermi 3 on socioeconomic conditions 

in the 50-mi (80-km) region are described in NUREG–2105 (NRC 2013a) and could range from 

SMALL to LARGE depending on the affected community.

4.16.8 Human Health

The NRC and EPA established radiological dose limits for protection of the public and workers 

from both acute and long-term exposure to radiation and radioactive materials. These dose 

limits are codified in 10 CFR Part 20 and 40 CFR Part 190. As discussed in Section 4.11.1, the 

NRC staff concluded impacts to human health from continued plant operations are SMALL.

For the purposes of this cumulative analysis, the geographical area considered is the area 

included within an 80-km (50-mi) radius of the Fermi site. One other nuclear power plant is 

located within the applicable geographical area; Davis-Besse, Unit 1, in Ottawa County, Ohio, is 

approximately 43km (27mi) southeast of the Fermi site. On the Fermi site, in addition to the 

Fermi 2 operating reactor, there is the Fermi 1 nuclear unit that was shut down in 1972 and is 

undergoing decommissioning. In addition to storing its spent nuclear fuel in a storage pool, 

Fermi 2 also stores some of its spent nuclear fuel in an onsite independent spent fuel storage 

installation. One other reasonably foreseeable project has the potential to contribute to the 

cumulative radiological impacts—the construction and operation of a new reactor unit (Fermi 3)

on the Fermi site (DTE 2014a). 

The NRC staff evaluated the potential cumulative impacts from the construction and operation 

of Fermi 3 in NUREG–2105 (NRC 2013a). The NRC staff concluded that the cumulative 

radiological impacts to human health from onsite and offsite sources of radiation would be 

SMALL (NRC 2013a). 

The EPA’s regulations in 40 CFR Part 190 limit the dose to members of the public from all 

sources in the nuclear fuel cycle, including nuclear power plants, fuel fabrication facilities, waste 

disposal facilities, and transportation of fuel and waste. As discussed in Section 3.1.4.4, 

Fermi 2 has conducted a REMP since 1978. This program measures radiation and radioactive 

materials in the environment from Fermi 2 and from all other onsite and offsite sources. The 

NRC staff reviewed the radiological environmental monitoring results for the 5-year period 

from 2009 to 2013 as part of the cumulative impacts assessment. The NRC staff’s review of 

DTE’s data showed no indication of an adverse trend in radioactivity levels in the environment 

from Fermi 2 or other sources. The data showed that there was no measurable impact to the 

environment from the operations at Fermi 2. 

The NRC staff concludes that the cumulative radiological impacts of the proposed license 

renewal, when combined with other past, present, and reasonably foreseeable future activities, 

would be SMALL. This conclusion is based on the NRC staff’s review of REMP data, 

radioactive effluent release data, DTE’s expected continued compliance with Federal radiation 

protection standards during continued operation of Fermi 2, decommissioning of Fermi 1, 

proposed construction and operation of Fermi 3, use of an independent spent fuel storage 
Environmental Consequences and Mitigating Actions

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installation to store spent nuclear fuel, and regulation of any future development or actions in 

the vicinity of the Fermi site by the NRC and the State of Michigan.

4.16.9 Environmental Justice

The environmental justice cumulative impact analysis evaluates the potential for 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations that could result from past, present, and reasonably foreseeable future 

actions, including the continued operational effects of Fermi 2 during the renewal term. 

Everyone living near Fermi experiences the operational effects of Fermi 2, including minority 

and low-income populations. As explained in Section 4.12, the NRC addresses environmental 

justice matters for license renewal by identifying the location of minority and low-income 

populations, determining whether there would be any potential human health or environmental 

effects to these populations, and determining if any of the effects may be disproportionately high 

and adverse.

Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 

impacts on human health. Disproportionately high and adverse human health effects occur 

when the risk or rate of exposure to an environmental hazard for a minority or low-income 

population is significant and exceeds the risk or exposure rate for the general population or for 

another appropriate comparison group. Disproportionately high environmental effects refer to 

impacts or risks of impacts on the natural or physical environment in a minority or low-income 

community that are significant and that appreciably exceed the environmental impact on the 

larger community. Such effects may include biological, cultural, economic, or social impacts. 

Some of these potential effects have been identified in resource areas presented in preceding 

sections of Chapter 4 in this SEIS. As previously discussed in this chapter, the impact from 

license renewal for all resource areas (e.g., land, air, water, ecology, and human health) would 

be SMALL.

As explained in Section 4.12 of this SEIS, there would be no disproportionately high and 

adverse impacts on minority and low-income populations from the continued operation of 

Fermi 2 during the license renewal term. Because DTE has no plans to hire additional workers 

during the license renewal term, employment levels at Fermi 2 would remain relatively constant, 

and there would be no additional demand for housing or increased traffic. Based on this 

information and the analysis of human health and environmental impacts presented in the 

preceding sections, disproportionately high and adverse contributory effects on minority and 

low-income populations from the continued operation of Fermi 2 during the license renewal term

are unlikely. Therefore, the only contributory effects would come from the other reasonably 

foreseeable future planned activities at Fermi 2, unrelated to the proposed action (license 

renewal), and other reasonably foreseeable planned offsite activities.

Fermi 1 Decommissioning

Full decommissioning of Fermi 1 is expected to be complete before initiation of Fermi 3

construction. DTE has not determined whether to remove the Fermi 1 external structure after 

the site is decommissioned and after its NRC license is terminated (NRC 2013a). Potential 

effects from decommissioning Fermi 1 would mostly consist of environmental effects 

(e.g., noise, dust, traffic, and housing impacts). If the external structure were to be demolished, 

noise and dust impacts during demolition would be temporary and would be limited to onsite 

activities. Minority and low-income populations residing along site access roads could 

experience increased truck and commuter vehicle traffic as decommissioning workers commute 

to the site and as material is removed for disposal. Increased demand for inexpensive 

temporary housing by decommissioning workers could disproportionately affect low-income 
Environmental Consequences and Mitigating Actions

4-128

populations; however, given the availability of rental housing in the region, impacts to minority 

and low-income populations would be limited. Radiation doses during decommissioning are 

expected to remain within regulatory limits.

Based on this information and the analysis of human health and environmental impacts 

presented in this section of the SEIS, the decommissioning of Fermi 1 would not have 

disproportionately high and adverse human health and environmental cumulative effects on 

minority and low-income populations residing in the vicinity of the Fermi site.

Construction and Operation of Fermi 3

Potential impacts to minority and low-income populations from the construction of Fermi 3 would 

mostly consist of environmental effects (e.g., noise, dust, traffic, and housing impacts). Noise 

and dust impacts during construction would be temporary and limited to onsite activities. 

Minority and low-income populations residing along site access roads could experience 

increased truck material and equipment delivery and commuter vehicle traffic especially during 

shift changes. Increased demand for inexpensive temporary housing by construction workers 

could disproportionately affect low-income populations; however, given the availability of rental 

housing in the region, impacts to minority and low-income populations would be limited. 

Radiation doses during power plant operations are expected to remain within regulatory limits.

Based on this information and on the analysis of human health and environmental impacts 

presented in this section of the SEIS, construction and operation of Fermi 3 would not have 

disproportionately high and adverse human health and environmental cumulative effects on 

minority and low-income populations residing in the vicinity of the Fermi site.

4.16.9.1 Conclusion

When combined with other past, present, and reasonably foreseeable future activities (e.g., the 

decommissioning of Fermi 1 and the construction and operation of Fermi 3), the contributory 

effects of continued reactor operations at Fermi 2 would not likely cause disproportionately high 

and adverse human health and environmental effects on minority and low-income populations 

residing in the vicinity of Fermi 2. The contributory effects from the construction and operation 

of Fermi 3 on minority and low-income populations in the 50-mi (80-km) region are described in 

NUREG–2105 (NRC 2013a).

4.16.10 Waste Management and Pollution Prevention

This section describes waste management impacts during the license renewal term when added 

to the aggregate effects of other past, present, and reasonably foreseeable future actions. For 

the purpose of this cumulative impacts analysis, the area within a 50-mi (80-km) radius of 

Fermi 2 was considered. In Section 4.13 of this SEIS, the NRC staff concluded that the 

environmental impacts from Fermi 2’s radioactive and nonradioactive wastes generated during 

the license renewal term would be SMALL.

As discussed in Sections 3.1.4 and 3.1.5 of this SEIS, DTE maintains waste management 

programs for radioactive and nonradioactive waste generated at Fermi 2 and is required to 

comply with Federal and State permits and other regulatory requirements for the management 

of waste material. Current waste management activities at the Fermi site (i.e., Fermi 1 

and Fermi 2) would likely remain unchanged during the license renewal term, and continued 

compliance with Federal and State requirements for radioactive and nonradioactive waste is 

expected. The NRC staff evaluated the potential cumulative impacts from the construction and 

operation of Fermi 3 in NUREG–2105 (NRC 2013a). The NRC staff concluded that the 

cumulative impacts from radioactive and nonradioactive wastes from all sources (i.e., Fermi 1, 

Fermi 2, and Davis-Besse) would be SMALL (NRC 2013a). 
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Based on the above, the NRC staff concludes that the potential cumulative impacts from 

radioactive and nonradioactive waste from multiple sources during the license renewal term 

would be SMALL. Continued compliance with Federal and State requirements for radioactive 

and nonradioactive waste management by Fermi 2 is expected.

4.16.11 Global Climate Change

This section addresses the impact of GHG emissions resulting from continued operation of 

Fermi 2 on global climate change when added to the aggregate effects of other past, present, 

and reasonably foreseeable future actions. The impacts of climate change on air, water, and 

ecological resources are discussed in Section 4.15.3. Climate is influenced by both natural and 

human-induced factors; the observed global warming (increase in the Earth’s surface 

temperature) in the 21st century has been attributed to the increase in GHG emissions resulting 

from human activities (USGCRP 2009, 2014). Climate model projections indicate that future 

climate change is dependent on current and future GHG emissions (IPCC 2007c; 

USGCRP 2009, 2014). As described in Section 4.15.3, operations at Fermi Unit 2 emit GHG. 

Therefore, it is recognized that GHG emissions from continued Fermi Unit 2 operation may 

contribute to climate change. 

The cumulative impact of a GHG emission source on climate is global. GHG emissions are 

transported by wind and become well mixed in the atmosphere as a result of their long 

atmospheric residence time; therefore, the extent and nature of climate change is not specific to 

where GHGs are emitted. In April 2014, EPA published the official U.S. inventory GHG 

emissions, which identifies and quantifies the primary anthropogenic sources and sinks of 

GHGs. The EPA’s GHG inventory is an essential tool for addressing climate change and 

participating with the United Nations Framework Convention on Climate Change to compare the 

relative global contribution of different emission sources and GHGs to climate change. In 2012, 

the United States emitted 6,525.6 teragrams (Tg) of CO2eq (6,525.6 million MT of CO2eq); total 

U.S. emissions have increased by 4.7 percent from 1990 to 2012 (EPA 2014g). In 2012 

and 2011, the total amount of CO2eq emissions related to electricity generation was 2,022.7 Tg

(2,022.7 million MT) and 2,158.5 Tg (2,158.5 million MT), respectively (EPA 2014g). The 

Energy Information Administration (EIA) reported that, in 2011, electricity production alone in 

Michigan was responsible for 64.5 million MT of CO2eq (EIA 2014). Facilities that emit 

0.025 million MT of CO2eq or more per year are required to annually report their GHG emissions 

to the EPA. These facilities are known as direct emitters, and the data are publicly available in 

EPA’s Facility Level Information on Green House Gases Tool (FLIGHT). In 2012, FLIGHT 

identified six facilities in Monroe County, Michigan, where the Fermi Unit 2 is located, that 

emitted a total of 17 million MT of CO2eq (EPA 2014h). In 2012, FLIGHT identified 224 facilities 

in Michigan that emitted a total of 92 million MT of CO2eq (EPA 2014h).

Appendix E provides a list of present and reasonable foreseeable projects that could contribute 

to GHG emissions. Permitting and licensing requirements and other mitigative measures can 

minimize the impacts of GHG emissions. For instance, in 2012, the EPA issued a final GHG 

Tailoring Rule (77 FR 41051) to address GHG emissions from stationary sources under CAA

permitting requirements; the GHG Tailoring Rule establishes when an emission source will be 

subject to permitting requirements and control technology to reduce GHG emissions. On 

June 25, 2013, the Climate Action Plan was set forward to reduce carbon pollution. The 

Climate Action Plan will reduce carbon pollution, prepare the United States for the impacts of 

climate change, and lead international efforts to combat global climate change. Under the 

Climate Action Plan, EPA has proposed rules to reduce carbon pollution from new and existing 

power plants. For instance, on August 3, 2015, EPA finalized the Clean Power Plan Rule 

(EPA 2015b) whereby EPA proposes to reduce carbon pollution from the power sector by 
Environmental Consequences and Mitigating Actions

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32 percent from 2005 levels (870 million tons less). The Clean Power Plan sets forth carbon 

dioxide emission performance rate standards for power plants that should be achieved by 2030. 

Furthermore, the Michigan Department of Community Health (MDCH) has received grants to 

develop and implement a strategic plan for responding to public health effects of climate change 

in Michigan. The plan has identified strategies to prevent, prepare for, and respond to, health 

impacts (MDCH 2010, 2011). Future actions and steps taken to reduce GHG emissions will 

lessen the impacts on climate change. 

The EPA’s U.S. inventory of GHG emissions illustrates the diversity of GHG sources emitters,

such as electricity generation, industrial processes, and agriculture. As discussed in 

Section 4.15.3, GHG emissions resulting from operations at Fermi 2 for the 2009 to 2013 

timeframe ranged between 9,600 and 14,600 MT of CO2eq. In comparing Fermi 2 GHG 

emission contributions to different emissions sources, whether it is total U.S. GHG emissions, 

emissions from electricity production in Michigan, or emissions on a County level, GHG 

emissions from Fermi 2 are relatively minor, which is evident from the information presented in 

Table 4–23. Climate models indicate that short-term climate change (through the year 2030) is 

dependent on past GHG emissions. Therefore, climate change is projected to occur with or 

without present and future GHG emissions from Fermi 2. The NRC staff concludes that the 

impact from the contribution of GHG emissions from continued operation of Fermi 2 on climate 

change would be SMALL. As discussed in Section 4.15.3.2, climate change and climate-related 

changes have been observed on a global level and climate models indicate that future climate 

change will depend on present and future GHG emissions. The USGCRP concludes that 

climate change and related impacts are happening. Climate models indicate that, even if GHG 

emissions were to be completely eliminated, the Earth’s average surface temperature will 

continue to increase and climate-related changes will persist over the next few decades 

(USGCRP 2014). The magnitude of continued increase in GHG emission rates will determine 

the amount of additional future warming. In summary, the cumulative impact of GHG emissions 

on climate change during the license renewal timeframe (2025 to 2045) is noticeable but not 

destabilizing. The NRC staff concludes that the cumulative impacts on climate change from the 

proposed license renewal and other past, present, and reasonably foreseeable projects would 

be MODERATE. 

Comparison of GHG Emission Inventories

Source CO2eq (million MT/year)

Global emissions (2011)(a) 45,450

U.S. emissions (2012)(b) 6,525.6

Michigan (2012)(c) 92

Monroe County, Michigan (2011)(c) 17

Fermi 2 emissions(d) 0.015

(a) Source: WRI (2011)

(b) Source: EPA (2014g)

(c) GHG emissions account only for direct emitters, those facilities that emit 25,000 MT (0.025 million MT) or more a 

year (EPA 2014h).

(d) Emissions include direct and indirect emissions from operation of Fermi 2, and the highest emission from 2009 to 

2013 is presented (DTE 2014c).

Key: million MT/year = million metric tons per year
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4.16.12 Summary of Cumulative Impacts

The NRC staff considered the potential impacts resulting from the operation of Fermi 2 during 

the period of extended operation and other past, present, and reasonably foreseeable future 

actions near Fermi 2. The preliminary determination is that the potential cumulative impacts 

would range from SMALL to LARGE, depending on the resource. Table 4–24 summarizes the 

cumulative impacts on resource areas.

Summary of Cumulative Impacts on Resource Areas

Resource Area Cumulative Impact

Air Quality and 

Noise

Past, present, and reasonably foreseeable future activities exist in the geographic 

areas of interest (local for noise and local and regional for criteria pollutants) that 

could affect air quality and noise resources. However, the incremental contribution of 

impacts on air quality and noise resources from plant operations at Fermi 2 would be 

minimal. The NRC staff concludes that cumulative impacts from Fermi 2-related 

actions and other past, present, and reasonably foreseeable future actions on air 

quality and noise resources in the geographic areas of interest would be SMALL.

Geology and 

Soils

Any use of geologic materials, such as aggregates to support operation and 

maintenance activities, would be procured from local and regional sources. These 

materials are abundant in the region, and geologic conditions are not expected to 

change during the license renewal term. Thus, activities associated with continued 

operations are not expected to affect the geologic environment. Considering ongoing 

activities and reasonably foreseeable actions, the NRC staff concludes that the 

cumulative impacts on geology and soils during the Fermi 2 license renewal term 

would be SMALL.

Water 

Resources

The Fermi 2 facility does not use groundwater nor discharge to it; therefore, the 

availability and quality of groundwater resources would not be affected by Fermi 2

license renewal activities. Consumptive surface water use from Fermi 2 operations 

would continue to be a very small percentage of the total water available in the 

western basin of Lake Erie, and ongoing and future surface water demands by users 

are expected to be supported. Surface water discharges to Lake Erie by Fermi 2 and 

other industrial users would be monitored and kept at acceptable limits via NPDES

permits. The cumulative impact on surface water is further dependent on future 

climate change considerations, with SMALL impacts associated with minimal climate 

change conditions and with MODERATE impacts associated with more extensive 

conditions. Therefore, considering ongoing activities and reasonably foreseeable 

actions, the NRC staff concludes that cumulative impact of the proposed license 

renewal when combined with other past, present, and reasonably foreseeable future 

activities would be SMALL on groundwater use and quality and would be SMALL to 

MODERATE on surface water resources. 

Terrestrial 

Resources

The cumulative impacts on terrestrial resources in the vicinity of the Fermi site are 

MODERATE to LARGE based on past, present, and reasonably foreseeable future 

actions. This level of impact is primarily the result of past habitat alteration and loss 

on the Fermi site and within the larger region. The environmental effects of these 

actions are clearly noticeable and have destabilized important attributes of certain 

terrestrial communities. The incremental site-specific impact from the continued 

operation of Fermi 2 during the license renewal period would be an unnoticeable or 

minor contributor to cumulative impacts on terrestrial resources.
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Resource Area Cumulative Impact

Aquatic 

Resources

The Great Lakes aquatic ecosystem has been destabilized for decades by the 

cumulative effects of chemical contamination, nutrient pollution that results in 

eutrophication and low dissolved oxygen levels, and invasive non-native species. 

Lake Erie has undergone cycles of degradation and remediation, and these lake-wide 

effects affect the aquatic resources near the Fermi site. Continued releases of 

nutrients, introductions of invasive non-native species, Federal and State remediation 

efforts, and changes in temperature and rainfall due to climate change will prevent 

stabilization over the period of license renewal. The direct and indirect effects of 

Fermi 2 on aquatic ecology are SMALL. However, because the cumulative impacts of 

all stressors combined are readily observable and have destabilized the aquatic 

ecosystem, the NRC staff concludes that the level of cumulative impact on the aquatic 

ecology is LARGE.

Historical 

and Cultural 

Resources

As described in Section 4.9, no cultural resources would be adversely affected by 

Fermi 2 license renewal activities because no associated changes or 

ground-disturbing activities would occur. DTE has established site procedures and 

work instructions to ensure that cultural resources are considered in project planning 

during normal operation of Fermi 2. Therefore, the NRC staff concludes that the 

cumulative impact of the proposed license renewal when combined with other past, 

present, and reasonable foreseeable future activities on historic and cultural 

resources would be SMALL.

Socioeconomics When combined with other past, present, and reasonably foreseeable future activities, 

the contributory effects from the continued operation of Fermi 2 during the license 

renewal period would have no new or increased impact on socioeconomic conditions 

beyond what is currently being experienced. The contributory effects from the 

construction and operation of Fermi 3 on socioeconomic conditions in the 50-mi 

(80-km) region are described in NUREG–2105 (NRC 2013a) and could range from 

SMALL to LARGE.

Human Health The cumulative radiological impacts of the proposed Fermi 2 license renewal when 

combined with other past, present, and reasonably foreseeable future activities would 

be SMALL.

Environmental 

Justice

The contributory effects of continued reactor operations at Fermi 2 when combined 

with other past, present, and reasonably foreseeable future activities would not likely 

cause disproportionately high and adverse human health and environmental effects 

on minority and low-income populations residing in the vicinity of Fermi 2. The 

contributory effects from the construction and operation of Fermi 3 on minority and 

low-income populations in the 50-mi (80-km) region are described in NUREG–2105

(NRC 2013a).

Waste 

Management 

and Pollution 

Prevention 

NRC staff concludes that the potential cumulative impacts from radioactive and 

nonradioactive waste from multiple sources during the license renewal term would be 

SMALL. Continued compliance with Federal and State requirements for radioactive 

and nonradioactive waste management by Fermi 2 is expected.

Global Climate 

Change

Climate change and climate-related changes have been observed on a global level, 

and climate models indicate that future climate change will depend on present and 

future GHG emissions. Climate models project that the Earth’s average surface 

temperature will continue to increase and climate-related changes will persist. 

Therefore, the cumulative impact of GHG emissions on climate change during the 

Fermi 2 license renewal timeframe would be noticeable but not destabilizing. The 

NRC staff concludes that the cumulative impacts from the proposed license renewal 

and other past, present, and reasonably foreseeable projects would be MODERATE.
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4.17 Resource Commitments Associated with the Proposed Action

4.17.1 Unavoidable Adverse Environmental Impacts

Unavoidable adverse environmental impacts are impacts that would occur after implementation 

of all workable mitigation measures. Carrying out any of the energy alternatives considered in 

this SEIS, including the proposed action, would result in some unavoidable adverse 

environmental impacts.

Minor unavoidable adverse impacts on air quality would occur due to emission and release of 

various chemical and radiological constituents from power plant operations. Nonradiological 

emissions resulting from power plant operations are expected to comply with EPA emissions 

standards, although the alternative of operating a fossil fuel-based power plant in some areas 

may worsen existing attainment issues. Chemical and radiological emissions would not exceed 

the National Emission Standards for Hazardous Air Pollutants.

During nuclear power plant operations, workers and members of the public would face 

unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 

exposed to radiation and chemicals associated with routine plant operations and the handling of 

nuclear fuel and waste material. Workers would have higher levels of exposure than members 

of the public, but doses would be administratively controlled and would not exceed standards or 

administrative control limits. In comparison, the alternatives involving the construction and 

operation of a nonnuclear power generating facility would also result in unavoidable exposure to 

hazardous and toxic chemicals to workers and the public.

The generation of spent nuclear fuel and waste material, including low-level radioactive waste, 

hazardous waste, and nonhazardous waste, would also be unavoidable. In comparison, 

hazardous and nonhazardous wastes would also be generated at nonnuclear power-generating 

facilities. Wastes generated during plant operations would be collected, stored, and shipped for 

suitable treatment, recycling, or disposal in accordance with applicable Federal and State 

regulations. Because of the costs of handling these materials, power plant operators would be 

expected to carry out all activities and to optimize all operations in a way that generates the 

smallest amount of waste possible.

4.17.2 Relationship between Short-Term Use of the Environment and Long-Term 

Productivity

The operation of power generating facilities would result in short-term uses of the environment, 

as described in this chapter. “Short term” is the period of time that continued power-generating 

activities take place.

Power plant operations require short-term use of the environment, commitment of resources, 

and commitment of certain resources (e.g., land and energy) indefinitely or permanently. 

Certain short-term resource commitments are substantially greater under most energy 

alternatives, including license renewal, than they are under the no-action alternative because of 

the continued generation of electrical power and the continued use of generating sites and 

associated infrastructure. During operations, all energy alternatives require similar relationships 

between local short-term uses of the environment and the maintenance and enhancement of 

long-term productivity.

Air emissions from power plant operations introduce small amounts of radiological and 

nonradiological constituents to the region around the plant site. Over time, these emissions 

would result in increased concentrations and exposure, but they are not expected to impact air 
Environmental Consequences and Mitigating Actions

4-134

quality or radiation exposure to the extent that public health and long-term productivity of the 

environment would be impaired.

Continued employment, expenditures, and tax revenues generated during power plant 

operations directly benefit local, regional, and State economies over the short term. The 

investment of project-generated tax revenues into infrastructure and other required services by 

local governments could enhance economic productivity over the long term.

The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous 

waste, and nonhazardous waste require an increase in energy and consume space at 

treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet 

waste disposal needs would reduce the long-term productivity of the land.

Power plant facilities are committed to electricity production over the short term. After 

decommissioning these facilities and restoring the area, the land could be available for other 

future productive uses.

4.17.3 Irreversible and Irretrievable Commitment of Resources

This section describes the irreversible and irretrievable commitment of resources that have 

been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit 

the future options for a resource. An irretrievable commitment refers to the use or consumption 

of resources that are neither renewable nor recoverable for future use. Irreversible and 

irretrievable commitment of resources for electrical power generation include the commitment of 

land, water, energy, raw materials, and other natural and manmade resources required for 

power plant operations. In general, the commitment of capital, energy, labor, and material 

resources are also irreversible.

The implementation of any of the energy alternatives considered in this SEIS would entail the 

irreversible and irretrievable commitment of energy; water; chemicals; and, in some cases, fossil 

fuels. These resources would be committed during the license renewal term and over the entire 

lifecycle of the power plant, and they would be unrecoverable.

Energy expended would be in the form of fuel for equipment, vehicles, and power plant 

operations and electricity for equipment and facility operations. Electricity and fuel would be 

purchased from offsite commercial sources. Water would be obtained from existing water 

supply systems. These resources are readily available, and the amounts required are not 

expected to deplete available supplies or exceed available system capacities.

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10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

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10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor site 

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5-1

5.0 CONCLUSION

This supplemental environmental impact statement (SEIS) contains the environmental review of 

the application for renewed operating license for Fermi, Unit 2 (Fermi 2), submitted by DTE 

Electric Company, as required by Title 10 of the Code of Federal Regulations (10 CFR) Part 51. 

The regulations at 10 CFR Part 51 implement the National Environmental Policy Act of 1969, as 

amended (42 U.S.C. 4321 et seq.). This chapter presents conclusions and recommendations 

from the site-specific environmental review of Fermi 2. Section 5.1 summarizes the 

environmental impacts of license renewal; Section 5.2 presents a comparison of the 

environmental impacts of license renewal and energy alternatives; and Section 5.3 presents the 

U.S. Nuclear Regulatory Commission (NRC) staff’s conclusions and recommendation.

5.1 Environmental Impacts of License Renewal

The NRC staff’s review of site-specific environmental issues in this SEIS leads to the conclusion 

that issuing a renewed license for Fermi 2 would have SMALL impacts for the Category 2 issues 

applicable to license renewal at Fermi 2. The NRC staff considered mitigation measures for 

each Category 2 issue, as applicable. The NRC staff concluded that no additional mitigation 

measure is warranted.

5.2 Comparison of Alternatives

In Chapter 4, the NRC staff considered the following alternatives to the Fermi 2 license renewal:

• no-action alternative;

• natural gas combined-cycle (NGCC) alternative;

• integrated gasification combined-cycle (IGCC) alternative;

• new nuclear alternative; and

• combination alternative (NGCC, wind, and solar).

Based on the summary of environmental impacts provided in Table 2–2, the NRC staff 

concluded that the environmental impacts of renewal of the operating license for Fermi 2 would 

be smaller than those of feasible and commercially viable alternatives. The no-action 

alternative, the act of shutting down Fermi 2 on or before its license expires, would have SMALL 

environmental impacts in most areas with the exception of socioeconomic impacts, which would 

have SMALL to LARGE environmental impacts. Continued operations would have SMALL 

environmental impacts in all areas. The NRC staff concluded that continued operation of 

Fermi 2 is the environmentally preferred alternative.

5.3 Recommendations

The NRC staff’s recommendation is that the adverse environmental impacts of license renewal 

for Fermi 2 are not so great that preserving the option of license renewal for energy-planning 

decisionmakers would be unreasonable. This recommendation is based on the following:

• the analysis and findings in NUREG–1437, Generic Environmental Impact 

Statement for License Renewal of Nuclear Plants, Volumes 1 and 2;

• the environmental report submitted by DTE Electric Company;
Conclusion

5-2

• consultation with Federal, state, tribal, and local agencies;

• the NRC staff’s environmental review; and

• consideration of public comments received during the environmental review 

(during the scoping process and on the draft SEIS).
6-1

6.0 LIST OF PREPARERS

Members of the U.S. Nuclear Regulatory Commission’s (NRC’s) Office of Nuclear Reactor 

Regulation (NRR) prepared this supplemental environmental impact statement with assistance 

from other NRC organizations and support from the Center for Nuclear Waste Regulatory 

Analysis (CNWRA) and Idoneous Consulting. CNWRA provided support as identified in 

Table 6–1. Idoneous Consulting provided support for technical editing reviews. Table 6–1 

identifies each contributor’s name, affiliation, and function or expertise.

List of Preparers

(in alphabetical order)

Name & Affiliation Education/Experience Function or Expertise

NRC Staff

Russell Chazell J.D, Law; M.S., Nuclear Engineering; 

B.S., Liberal Studies; Certificate in 

Project Management; Certificate in 

NEPA; approximately 9 years 

analytical/environmental laboratory 

experience, 5 years analytical project 

management experience, 4 years 

technical business development 

experience, 4 years engineering project 

management experience, and 2 years 

NEPA experience

Nonradioactive waste

Jerry Dozier M.S., Reliability Engineering; M.B.A., 

Business Administration; B.S., 

Mechanical Engineering; 30 years of 

experience including operations, 

reliability engineering, technical reviews, 

and NRC branch management

Severe Accident Mitigation Alternative 

(SAMA)

Kevin Folk M.S., Environmental Biology; B.A., 

Geoenvironmental Studies; 25 years of 

experience in NEPA compliance; 

geologic, hydrologic, and water quality 

impacts analysis; utility infrastructure 

analysis, and environmental regulatory 

compliance and water supply and 

wastewater discharge permitting

Water Resources: Surface Water

William Ford M.S., Geology; 41 years of combined 

industry and government experience 

working on groundwater, surface water,

and geology projects

Geology; Water Resources: 

Groundwater

Briana Grange B.S., Conservation Biology; 10 years of 

experience in environmental impact 

analysis, section 7 consultations, and 

essential fish habitat consultations

Land Use and Visual Resources; 

Terrestrial Resources
List of Preparers

6-2

Name & Affiliation Education/Experience Function or Expertise

Robert Hoffman B.S., Environmental Resource 

Management; 29 years of experience in 

NEPA compliance, environmental impact 

assessment, alternatives identification 

and development, and energy facility 

siting

Historic and Cultural Resources

Stephen 

Klementowicz

M.S., Health Physics; 33 years of 

commercial and regulatory experience in 

reactor health physics, radiological 

effluent and environmental monitoring 

programs, and radioactive waste

Human Health; Waste Management and 

Pollution Prevention

Elaine Keegan B.S., Health Physics; 35 years of 

combined commercial and regulatory 

experience in reactor health physics, 

radiological effluent and environmental 

monitoring programs, radioactive waste, 

and spent fuel storage

Senior Project Manager

Dennis Logan Ph.D., Marine Studies and Biological 

Oceanography; M.S., Biological 

Sciences, Marine Biology; B.S., Zoology; 

40 years of experience in ecological 

studies, ecological risk assessment, 

environmental impact assessment, 

protected resource management, and 

project management

Aquatic Resources; Microbiological 

Hazards

Nancy Martinez B.S., Earth and Environmental Science; 

A.M., Earth and Planetary Science; 4 

years of experience in environmental 

impact analysis

Greenhouse Gas Emissions and 

Climate Change; Air Quality, 

Meteorology, and Noise 

Michelle Moser M.S., Biological Sciences; B.S., 

Environmental Sciences; 13 years of 

experience in ecological studies, 

environmental impact assessment, and 

protected resource management

Special Status Species and Habitats

Jeffrey Rikhoff M.R.P., Regional Planning; M.S., 

Economic Development and Appropriate 

Technology; 23 years of experience in 

NEPA compliance, socioeconomics and 

environmental justice impact analysis, 

cultural resource impacts, and 

comprehensive land-use and 

development planning

Environmental Justice; Socioeconomics

Brian Wittick M.E., Acoustical Engineering; M.B.A. 

with minor in Environmental 

Management; B.S., Systems 

Engineering;

Branch Chief - Management oversight

David Wrona B.S., Electrical Engineering; 30 years of 

experience as an engineering inspector, 

including as an NRC resident inspector;

reactor engineer; project manager; and 

projects and technical branch manager.

Branch Chief - Management oversight
List of Preparers

6-3

Name & Affiliation Education/Experience Function or Expertise

SAMA Contractors – Center for Nuclear Waste Regulatory Analyses

Bob Schmidt M.S., Nuclear Engineering; B.S. 

Mechanical Engineering; 50 years of 

nuclear industry experience including 35 

years of experience in performing, 

managing, and reviewing Probabilistic 

Risk Assessments

SAMA

Roland Benke Ph.D., Nuclear Engineering; M. Eng., 

Radiological Health Engineering; B.S., 

Nuclear Engineering; Certified Health 

Physicist with nearly 20 years of 

experience in nuclear engineering, health 

physics, and risk analysis.

SAMA

7-1

7.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS

TO WHOM COPIES OF THIS SEIS ARE SENT

List of Agencies, Organizations, and Persons to Whom Copies 

of This SEIS Are Sent

Name and Title Affiliation

Mary Ann Baier None given

Sandra Bihn None given

Paul Braunlich Frenchtown Charter Township Resort District Authority

2979 Nadeau Road

Monroe, MI 48162

Barry Buschmann, Senior Vice President The Mannik & Smith Group, Inc.

Joanne Cantoni None given

Corinne Carey Don’t Waste Michigan

Levi Carrick, Sr., Chairman Bay Mills Indian Community

12104 W. Lakeshore Drive

Brimley, MI 49715

Jeff Chivis, Tribal Historic Preservation 

Officer

Nottawaseppi Huron Band of the Potawatomi

1485 Mno-Bmadzewen Way

Fulton, MI 49052

Jessie Pauline Collins Citizens’ Resistance at Fermi 2 (CRAFT)

17397 Five Points Street

Redford, MI 48240

Brian Conway, State Historic Preservation 

Officer

State Historic Preservation Office

Michigan Historical Center

P.O. Box 30740

702 W. Kalamazoo Street

Lansing, MI 48909-8240

Ethel Cook, Chief Ottawa Tribe of Oklahoma

13 South 69 A

Miami, OK 74354

Eric Dover DTE Energy Company

Heather Dover DTE Energy Company

Nancy Dover None given

Michelle Dugan, Executive Director Monroe County Chamber of Commerce

P.O. Box 626

Monroe, MI 48161

EIS Filing Section U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20004

Mark Farris None given

Harold “Gus” Frank, Chairman Forest County Potawatomi

5416 Everybody's Road

Crandon, WI 54520
List of Agencies, Organizations, and Persons

7-2

Name and Title Affiliation

Billy Friend, Chief Wyandotte Nation

64700 E. Highway 60

Wyandotte, OK 74370

Martha Gruelle Wildlife Habitat Council

Keith Gunter, Co-Chair Alliance to Halt Fermi 3

Rick Hambleton None given

Carol Izant, Co-Chair Alliance to Halt Fermi 3

Kevin Kamps Beyond Nuclear

Hedwig Kaufman None given

Michael Keegan Don’t Waste Michigan

Fred Kiogima, Tribal Chairman Little Traverse Bay Bands of Odawa Indians

7500 Odawa Circle

Harbor Springs, MI 49740

Manfred Klein None given

Dustin Krasny Office of Congressman Tim Walberg

110 1st Street, Suite 2

Jackson, MI 49201

Tim Lake, President and CEO Monroe County Business Development Corporation

102 E. Front St.

Monroe, MI 48161

Bobby Lambert, Vice-Chairman Monroe County Board of Commissioners

125 E. 2nd Street

Monroe, MI 48161

Ron Lankford None given

Bill LaVoy, State Representative Michigan House of Representatives

N-990 House Office Building

P.O. Box 30014

Lansing, MI 48909-7514

Laura Loveland DTE Energy Company

Vic and Gail Macks None given

Russ Mason, Chief Michigan Department of Natural Resources

Wildlife Division

P.O. Box 30028

Lansing, MI 48909

Ed McArdle, Conservation Committee 

Co-Chair

Sierra Club, Michigan Chapter

Jim McDevitt, Supervisor Frenchtown Charter Township

2744 Vivian Road

Monroe, MI 48162-9249

Dr. Stephen McNew, Superintendent Monroe County Intermediate School District

1101 S. Raisinville Road

Monroe, MI 4161-9047

Tom Melius, Midwest Regional Director U.S. Fish and Wildlife Service

American Boulevard West, Suite 990

Bloomington, MN 55437-1458

Floreine Mentel Former Monroe County Commissioner
List of Agencies, Organizations, and Persons

7-3

Name and Title Affiliation

Kenneth Meshigaud, Tribal Chairperson Hannahville Indian Community

N14911 Hannahville B-1 Road

Wilson, MI 49896

Dick Micka Lake Erie Clean-Up Committee

Jeanne Micka Monroe County Garden Club

Dan Miskokomon, Chief Walpole Island First Nation

R.R. #3

Walpole Island

Ontario, Canada N8A 4K9

Sandy Mull, President and Executive 

Director

Southern Wayne County Regional Chamber of Commerce

20904 Northline Road

Taylor, MI 48180-4719

Reid Nelson, Director Advisory Council on Historic Preservation

Office of Federal Agency Programs

1100 Pennsylvania Avenue, N.W., Suite 803 

Washington, DC 20004

Tracy Oberleiter, Chair Monroe County Economic Development Corporation

125 E. Second Street

Monroe, MI 48161

Phyllis Oster None given

Steve Pago, Chief Saginaw Chippewa Indian Tribe of Michigan

7070 E. Broadway Road

Mount Pleasant, MI 48858

Aaron Payment, Tribal Chairperson Sault Ste. Marie Tribe of Chippewa Indians of Michigan

523 Ashmun Street

Sault Ste. Marie, MI 49783

Cindy Pederson, Regional Administrator U.S. Nuclear Regulatory Commission

Region III

2443 Warrenville Road

Lisle, IL 60532

Al Pedwaydon, Council Chair Grand Traverse Band of Ottawa and Chippewa Indians

2605 N. West Bay Shore Drive

Peshawbestown, MI 49682

Sandy Pierce Monroe Center for Healthy Aging

Elizabeth Poole, Environmental Scientist NEPA Implementation Section

U.S. Environmental Protection Agency

77 W. Jackson Blvd. E-19J

Chicago, IL 60604

Ken Richards None given

Randy Richardville, State Senator Michigan State Senate

S-106 Capitol Building

P.O. Box 30036

Lansing, MI 48909-7536

Larry Romanelli, Ogema Little River Band of Ottawa Indians

375 River Street

Manistee, MI 49660

David Schonberger Resident
List of Agencies, Organizations, and Persons

7-4

Name and Title Affiliation

Senior Resident Inspector

Donald Shalifoe, Sr., President Keweenaw Bay Indian Community

16429 Beartown Road

Baraga, MI 49908

Phil Skarbek DTE Energy Company

Cindy Smith DTE Energy Company

Michael Smith AFL-CIO/United Way

Jerome Sobczak DTE Shareholders United

P.O. Box 321067

Detroit, MI 48232

Ron Sparkman, Chief Shawnee Tribe

P.O. Box 189

29 S. Highway 69A

Miami, OK 74355

D. K. Sprague, Tribal Chairman Match-e-be-nash-she-wish Band of Pottawatomi Indians of 

Michigan

1743 142nd Avenue

P.O. Box 218

Dorr, MI 49323

Stephen Tait DTE Energy Company

Robin Thompson DTE Energy Company

Tim Walberg, Member of Congress U.S. House of Representatives

2436 Rayburn House Office Building

Washington, DC 20515

John Warren, Chairman Pokagon Band of Potawatomi Indians

58620 Sink Road

P.O. Box 180

Dowagiac, MI 49047

C.J. Watkins, Acting President Delaware Nation

P.O. Box 825

Anadarko, OK 73005

James Williams Jr., Tribal Chairman Lac Vieux Desert Band of Lake Superior Chippewa Indians

P.O. Box 249

Watersmeet, MI 49969

Madelyn Williams DTE Energy Company

Emily Wood Women in Nuclear/DTE Electric Company

Grace Yackee Monroe County Community College

1555 S. Raisinville Road

Monroe, MI 48161

Dale Zorn, State Representative Michigan House of Representatives

N-990 House Office Building

P.O. Box 30014

Lansing, MI 48909-7514
8-1

8.0 INDEX

A

accidents ..................................xxiv, 3-154, 

4-69, 4-70, 4-71, 4-72, 4-77, 4-79, 4-82, 

4-88, 4-94, A-6, A-17, A-19, A-21, A-23, 

A-24, A-29, A-30, A-31, A-32, A-34, A-39, 

A-337, B-1, F-12, F-13

Advisory Council on Historic 

Preservation (ACHP) ...............xxvii, 1-7, 

3-179, 4-55, 4-56, 4-153, 7-3, A-16, 

A-322, B-6, C-3, C-4, C-6, D-1

alternatives.............................. iii, xxiv, 1-5, 

2-1, 2-3, 2-4, 2-5, 2-14, 2-17, 2-18, 2-21, 

2-24, 4-1, 4-4, 4-6, 4-19, 4-20, 4-21, 4-23, 

4-27, 4-29, 4-32, 4-35, 4-36, 4-38, 4-40, 

4-42, 4-55, 4-60, 4-66, 4-67, 4-71, 4-77, 

4-81, 4-87, 4-89, 4-94, 4-96, 4-101, 

4-139, 4-140, 5-1, 6-2, A-1, A-6, A-7, A-8, 

A-24, A-25, A-32, A-33, A-317, A-318, 

A-320, A-326, A-327, A-330, A-334, 

A-338, B-2, C-2, F-26, F-27, F-52

archaeological resources...........1-6, 4-58, 

4-59, 4-60

B

biota......................3-76, 4-36, 4-122, 4-125

boiling water reactor (BWR)..............xxvii, 

xxix, 2-1, 2-2, 2-11, 3-5, 3-26, 4-15, A-24, 

A-31, A-32, A-325, A-332, F-6, F-21, F-22

burnup ......................................... 3-5, A-34

C

chronic effects ..................2-24, 4-68, 4-69

Clean Air Act (CAA) ..................xxvii, 3-34, 

3-166, 4-9, 4-10, 4-13, 4-135, 4-142, 

4-143, 4-145, 4-146, B-3, B-7, B-8

closed-cycle cooling.................2-12, 4-27, 

4-40, 4-41, 4-125

core damage frequency (CDF) ..........xxvii, 

4-72, 4-74, 4-75, 4-76, 4-77, A-334, F-1, 

F-2, F-3, F-5, F-6, F-7, F-11, F-12, F-13, 

F-14, F-15, F-22, F-25, F-26, F-28, F-29, 

F-30, F-36, F-42, F-43, F-44, F-45, F-46, 

F-50, F-51, F-53

Council on Environmental Quality 

(CEQ) .............................xxvii, 1-3, 3-154, 

3-155, 3-166, 4-121, 4-124, 4-143, A-330

critical habitat....................... 3-119, 3-120, 

3-121, 3-122, 3-123, 3-124, 3-125, 3-126, 

3-127, 3-128, 3-161, 3-162, 4-42, 4-43, 

4-47, 4-51, 4-52, 4-53, 4-54, B-6, C-1, 

C-2

cultural resources ........................xxiii, 2-4, 

2-23, 3-32, 3-129, 3-132, 3-133, 4-55, 

4-57, 4-58, 4-59, 4-60, 4-96, 4-107, 

4-130, 4-138, B-1, B-6

D

decommissioning.......................xxxiii, 2-2, 

2-3, 3-26, 4-1, 4-2, 4-26, 4-35, 4-39, 4-53, 

4-54, 4-57, 4-58, 4-62, 4-63, 4-64, 4-65, 

4-66, 4-88, 4-94, 4-96, 4-97, 4-98, 4-99, 

4-100, 4-130, 4-131, 4-132, 4-133, 4-134, 

4-140, A-13, A-23, A-35, A-37, A-325, 

A-326, A-336

design-basis accident.......................xxviii, 

4-1, 4-69, A-6, A-39, A-337

discharges .................................... 3-5, 3-9, 

3-46, 3-49, 3-50, 3-51, 3-76, 3-119, 

3-150, 3-152, 3-160, 4-25, 4-27, 4-29, 

4-30, 4-31, 4-40, 4-93, 4-114, 4-115, 

4-116, 4-117, 4-118, 4-119, 4-120, 4-124, 

4-125, 4-126, 4-137, A-9, A-10, A-11, 

A-12, A-16, A-319, B-1, E-2, E-3

dose ..........................................xxxiii, 3-11, 

3-13, 3-14, 3-15, 3-149, 3-150, 3-160, 

4-74, 4-94, 4-95, 4-132, 4-154, A-17, 

A-18, A-22, A-23, A-24, A-30, A-34, A-36, 

A-323, A-324, A-325, A-326, A-334, 

A-335, A-337, B-2, B-5, F-3, F-4, F-16, 

F-17, F-18, F-19, F-20, F-23, F-28, F-49, 

F-51, F-52, F-55, F-56

E

education.............................. 3-142, 3-146, 

3-147, 4-61

electromagnetic fields ...................... 2-24, 

4-67, 4-68, 4-80

endangered and threatened species...B-6
Index

8-2

Endangered Species Act ............xxiii, xxix, 

1-6, 1-7, 1-9, 2-4, 2-27, 3-118, 3-161, 

3-169, 3-172, 4-42, 4-43, 4-141, 4-144, 

4-147, A-41, A-44, B-6, B-8, C-1, C-8, D-1

entrainment ...............................3-86, 3-87, 

3-88, 3-90, 3-94, 3-95, 3-96, 3-97, 3-98, 

3-99, 3-101, 3-103, 3-104, 3-105, 3-110, 

3-111, 3-112, 3-113, 3-114, 3-116, 3-119, 

4-38, 4-39, 4-40, 4-41, 4-124, 4-125, A-8, 

A-9

environmental justice (EJ)...................2-4, 

3-155, 3-162, 4-81, 4-82, 4-96, 4-133, 

4-141, 6-3, A-335, A-336

essential fish habitat (EFH) ................xxiii, 

xxviii, 3-129, 4-42, 4-52, 6-2, B-6, C-3

F

Fish and Wildlife Coordination Act 

(FWCA).............................................. B-8

G

Generic Environmental Impact Statement 

(GEIS)..................................... iii, xxi, xxii, 

xxiii, xxv, xxix, 1-3, 1-4, 1-5, 1-6, 1-7, 1-9, 

2-1, 2-2, 2-3, 2-4, 2-15, 2-17, 2-29, 2-30, 

3-74, 3-137, 3-153, 3-180, 4-1, 4-2, 4-6, 

4-7, 4-12, 4-22, 4-24, 4-25, 4-32, 4-33, 

4-34, 4-35, 4-36, 4-38, 4-39, 4-40, 4-41, 

4-42, 4-55, 4-57, 4-60, 4-61, 4-67, 4-68, 

4-69, 4-70, 4-71, 4-81, 4-87, 4-88, 4-89, 

4-90, 4-91, 4-93, 4-94, 4-95, 4-97, 4-98, 

4-100, 4-152, 4-153, 5-2, A-1, A-6, A-8, 

A-10, A-12, A-23, A-32, A-33, A-38, A-39, 

A-43, A-45, A-46, A-313, A-324, A-325, 

A-326, A-327, A-329, A-330, A-341, 

A-342, E-7

greenhouse gases ......................2-8, 3-48, 

4-8, 4-142

groundwater........................xxiii, 3-6, 3-17, 

3-45, 3-50, 3-52, 3-54, 3-56, 4-23, 4-24, 

4-25, 4-26, 4-28, 4-29, 4-30, 4-31, 4-82, 

4-83, 4-96, 4-104, 4-112, 4-119, 4-120, 

4-137, 6-1, A-14, B-1

H

hazardous waste..........3-18, 3-151, 4-139, 

4-140, B-5

high-level waste ............................xxii, 1-4, 

4-87, 4-95, A-329, A-341

I

impingement............................. 3-86, 3-88, 

3-89, 3-90, 3-93, 3-94, 3-96, 3-97, 3-98, 

3-99, 3-101, 3-104, 3-110, 3-111, 3-112, 

3-113, 3-114, 3-116, 3-119, 4-39, 4-40, 

4-41, 4-124, 4-125, A-8, A-9

independent spent fuel storage 

installation................................. xxx, 3-1, 

4-132, 4-133, A-40, A-341, E-1

L

low-level waste................................... 4-95

M

Magnuson–Stevens Fishery 

Conservation and Management Act 

(MSA)................................. xxxi, 1-6, 1-7, 

1-9, 3-118, 3-129, 4-52, B-6, B-8, C-3, 

C-8, D-1

Marine Mammal Protection Act (MMPA)

...........................................................B-8

mitigation....................................xxii, xxxiii, 

1-3, 1-4, 1-5, 3-70, 3-132, 4-8, 4-19, 4-41, 

4-53, 4-58, 4-59, 4-60, 4-76, 4-115, 

4-122, 4-125, 4-139, 4-154, 5-1, A-10, 

A-12, A-24, A-25, A-29, A-31, A-32, A-34, 

A-41, A-330, A-334, F-25, F-45

mixed waste............. xxx, 3-11, 3-18, 3-160

N

National Environmental Policy Act 

(NEPA)......................................xxii, xxxii, 

1-1, 1-8, 1-9, 2-1, 2-29, 3-154, 3-155, 

3-166, 4-51, 4-56, 4-60, 4-61, 4-81, 4-87, 

4-121, 4-124, 4-125, 4-143, 4-145, 4-151, 

4-152, 5-1, 6-1, 6-2, 6-3, 7-3, A-9, A-11, 

A-16, A-20, A-21, A-22, A-25, A-26, A-27, 

A-32, A-33, A-34, A-38, A-39, A-40, A-45, 

A-317, A-318, A-327, A-333, A-334, 

A-341, B-2, B-8, C-1, C-3, C-8

National Historic Preservation Act.....xxiii, 

xxxii, 1-6, 1-7, 1-9, 2-4, 2-29, 4-55, 4-151, 

A-16, A-45, B-6, B-8, C-3, C-8, D-1

National Marine Fisheries Service 

(NMFS)....................................xxxii, 3-92, 

3-93, 3-118, 3-129, 3-179, 4-42, 4-51, 

4-52, 4-147, B-6, C-1, C-2, C-3, C-8
Index

8-3

National Pollutant Discharge Elimination 

System (NPDES).............................xxxii, 

3-9, 3-45, 3-46, 3-48, 3-49, 3-50, 3-51, 

3-52, 3-80, 3-118, 3-150, 3-152, 3-160, 

3-168, 3-176, 4-26, 4-27, 4-28, 4-29, 

4-30, 4-31, 4-33, 4-41, 4-92, 4-117, 

4-118, 4-124, 4-137, 4-150, A-9, A-10, 

A-12, A-318, A-319, A-339, B-1, B-4, B-6, 

B-7, E-3

Native American...............................3-130, 

3-131, 3-175, 3-178, 4-81, 4-82, A-15, 

A-322

nonattainment ............................3-34, 3-35

O

once-through cooling ......3-6, 4-32, 4-113, 

4-114, 4-124, 4-125, 4-149

P

postulated accidents 4-1, 4-69, 4-70, 4-71, 

4-82, A-31, A-337

pressurized water reactor............. 2-2, E-1

R

radon...........................................3-11, 3-17

reactor ..........................................xxi, xxvii, 

xxxiii, 2-1, 2-2, 2-3, 2-10, 2-11, 2-12, 

2-26, 3-1, 3-5, 3-6, 3-10, 3-14, 3-15, 3-20, 

3-26, 3-32, 3-34, 3-37, 3-129, 3-132, 

3-150, 3-161, 4-1, 4-39, 4-56, 4-57, 4-58, 

4-60, 4-61, 4-62, 4-70, 4-71, 4-72, 4-75, 

4-77, 4-79, 4-84, 4-87, 4-97, 4-100, 

4-111, 4-119, 4-120, 4-122, 4-132, 4-134, 

4-138, 6-2, 6-3, A-6, A-8, A-9, A-18, A-19, 

A-24, A-25, A-27, A-29, A-30, A-31, A-32, 

A-33, A-34, A-35, A-36, A-37, A-39, A-40, 

A-324, A-325, A-326, A-327, A-329, 

A-332, A-333, A-336, A-337, A-341, F-4, 

F-6, F-7, F-8, F-10, F-18, F-23, F-25, 

F-27, F-32, F-37, F-38, F-41, F-42, F-45, 

F-50, F-51, F-61

replacement power ......................xxiv, 2-3, 

2-5, 2-18, 4-1, 4-26, 4-31, 4-67, 4-74, 

4-84, 4-85, 4-94, 4-96, A-8, A-317, A-318, 

F-3, F-20, F-48, F-50, F-53

S

scoping .. iii, xxi, xxii, xxv, 1-1, 1-2, 1-6, 1-8, 

4-2, 4-7, 4-22, 4-24, 4-25, 4-33, 4-39, 

4-56, 4-61, 4-68, 4-70, 4-71, 4-88, 4-90, 

4-91, 4-93, 4-95, 4-97, 4-109, 5-2, A-1, 

A-5, A-8, A-21, A-31, A-44, A-316, A-322, 

A-325, A-328, C-4, C-5, F-20

seismic......................................xxxiv, 3-10, 

3-38, 3-45, 4-73, F-5, F-9, F-10, F-11, 

F-12, F-13, F-25

severe accident mitigation alternative 

(SAMA) ...................................xxiv, xxxiii, 

4-71, 4-72, 4-73, 4-74, 4-75, 4-76, 4-77, 

4-78, 4-151, 6-1, 6-3, A-6, A-24, A-25, 

A-26, A-29, A-30, A-32, A-317, A-333, 

A-334, A-335, D-4, D-5, F-1, F-2, F-3, 

F-5, F-7, F-8, F-9, F-10, F-11, F-12, F-13, 

F-15, F-16, F-17, F-18, F-19, F-20, F-21, 

F-22, F-23, F-24, F-25, F-26, F-27, F-28, 

F-29, F-30, F-32, F-37, F-39, F-44, F-45, 

F-46, F-47, F-48, F-50, F-51, F-52, F-53, 

F-54, F-55, F-56, F-57, F-59

severe accidents ......................... xxiv, 4-1, 

4-69, 4-71, 4-82, A-24, A-30, A-39, A-333, 

A-334, A-337, F-9, F-50

solid waste........................... xxv, 2-4, 2-19, 

2-20, 3-11, 3-12, 3-13, 3-15, 3-16, 3-18, 

3-150, 3-160, 4-15, 4-89, 4-95, B-1, E-2

spent fuel...................................... xxii, 1-4, 

3-16, 4-88, 4-95, 4-96, 4-109, 6-2, A-28, 

A-32, A-33, A-34, A-35, A-37, A-38, A-39, 

A-40, A-329, A-340, E-1, E-4

State Historic Preservation Office 

(SHPO)...................................xxxiv, 2-23, 

3-129, 3-130, 3-132, 3-133, 3-176, 3-179, 

4-56, 4-57, 4-153, 7-1, A-16, A-322, D-2

surface water............................ 3-42, 3-45, 

3-46, 3-47, 3-50, 3-51, 3-52, 3-61, 3-77, 

3-78, 3-82, 3-100, 3-101, 3-102, 3-104, 

3-143, 4-23, 4-24, 4-25, 4-26, 4-27, 4-28, 

4-29, 4-30, 4-31, 4-82, 4-83, 4-96, 4-102, 

4-104, 4-105, 4-107, 4-112, 4-115, 4-116, 

4-117, 4-118, 4-119, 4-137, 6-1, A-10, 

A-14, B-1, B-4

T

taxes...................................... 3-145, 3-146, 

3-147, 3-148, 4-61
Index

8-4

transmission lines ......................2-8, 2-10, 

2-11, 2-12, 2-21, 3-19, 3-21, 3-26, 3-32, 

3-37, 3-62, 3-74, 3-75, 3-90, 3-119, 

3-129, 3-153, 4-2, 4-5, 4-6, 4-27, 4-31, 

4-32, 4-33, 4-37, 4-39, 4-41, 4-44, 4-45, 

4-46, 4-47, 4-48, 4-49, 4-56, 4-60, 4-68, 

4-69, 4-90, 4-111, 4-123

tritium ...................................... 3-56, A-322

U

U.S. Department of Energy (DOE).... xxviii, 

2-4, 2-7, 2-9, 2-11, 2-12, 2-14, 2-15, 2-16, 

2-17, 2-18, 2-19, 2-25, 2-26, 2-27, 2-28, 

2-29, 2-31, 4-8, 4-12, 4-19, 4-63, 4-64, 

4-66, 4-68, 4-143, 4-144, 4-151, A-34

U.S. Environmental Protection Agency 

(EPA) ..............................xxviii, 2-4, 2-10, 

2-19, 2-20, 2-21, 2-25, 2-27, 2-28, 3-13, 

3-14, 3-15, 3-26, 3-34, 3-36, 3-37, 3-48, 

3-56, 3-57, 3-80, 3-81, 3-82, 3-96, 3-100, 

3-144, 3-150, 3-160, 3-169, 3-170, 3-174, 

4-7, 4-9, 4-10, 4-13, 4-14, 4-18, 4-25, 

4-41, 4-79, 4-80, 4-91, 4-92, 4-98, 4-99, 

4-101, 4-102, 4-103, 4-109, 4-110, 4-116, 

4-121, 4-124, 4-126, 4-127, 4-128, 4-132, 

4-135, 4-136, 4-139, 4-142, 4-145, 4-146, 

7-1, 7-3, A-10, A-12, A-14, A-34, A-38, 

A-45, A-313, A-316, A-319, A-337, B-1, 

B-3, B-4, B-5, B-7, D-4, D-5, E-2, E-3, 

E-5, E-6, E-7, F-18

U.S. Fish and Wildlife Service 

(FWS).......................... xxix, 1-6, 1-8, 2-7, 

2-12, 2-13, 2-31, 3-21, 3-26, 3-48, 3-59, 

3-62, 3-68, 3-70, 3-71, 3-74, 3-75, 3-78, 

3-79, 3-118, 3-119, 3-121, 3-122, 3-123, 

3-124, 3-125, 3-126, 3-127, 3-128, 3-161, 

3-162, 3-164, 3-167, 3-168, 3-170, 3-171, 

3-172, 3-173, 3-180, 3-181, 4-3, 4-33, 

4-34, 4-35, 4-42, 4-43, 4-44, 4-45, 4-46, 

4-47, 4-48, 4-50, 4-51, 4-52, 4-54, 4-90, 

4-106, 4-121, 4-122, 4-123, 4-142, 4-147, 

7-2, A-41, A-42, A-44, A-338, A-340, B-6, 

C-1, C-2, C-3, C-8, E-4, E-7

uranium................................ 2-7, 2-11, 3-5, 

4-1, 4-3, 4-4, 4-35, 4-36, 4-37, 4-80, 4-94, 

4-95, 4-96, 4-98, A-19, A-39, A-40, A-329, 

A-341






NUREG-1437

Supplement 56

Volume 1

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Regarding Fermi 2 Nuclear Power Plant