Generic Environmental 

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 56 

Regarding Fermi 2 

Nuclear Power Plant

Final Report

 

Appendices

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 56 

Volume 2

Generic Environmental

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 56 

Regarding Fermi 

Nuclear Power Plant

Final Report

 

Appendices

Manuscript Completed: August 2016

Date Published: September 2016

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 56

Volume 2

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. 

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................................................................... 3-127

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 .................................................................. 3-150

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............................................................... 4-90

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............................................................................ 4-106

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

4.16.3 Water Resources........................................................................... 4-107

4.16.3.1 Surface Water Resources ............................................ 4-107

4.16.3.2 Groundwater Resources .............................................. 4-114

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 ............................... 4-129

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 ................................................................. 4-134

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

4.18 References .................................................................................................. 4-135

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................................................... 4-131

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 for comment; 

• conducted a public meeting to receive comments on the draft SEIS on 

December 2, 2015; and

• considered the public comments received during the draft SEIS 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 draft SEIS 

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
COMMENTS RECEIVED ON THE FERMI 2 

ENVIRONMENTAL REVIEW

A-1 

A. Comments Received on the FERMI 2 Environmental Review

A.1 Comments Received During the Scoping Period

The scoping process for the environmental review of the license renewal application (LRA) for 

Fermi 2 began on June 30, 2014, with the publication of the U.S. Nuclear Regulatory 

Commission’s (NRC’s) Notice of Intent to conduct scoping in Volume 79 of the Federal Register, 

page 36837 (79 FR 36837). The scoping process included two public meetings held in 

Monroe, Michigan, on July 24, 2014. Approximately 110 people attended the meetings. After 

the NRC’s prepared statements pertaining to the license renewal process, the meetings were 

open for public comments. Attendees provided oral statements that were recorded and 

transcribed by a certified court reporter. A summary and transcripts of the scoping meetings are 

available using the NRC’s Agencywide Documents Access and Management System (ADAMS). 

The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/readingrm/adams.html. The scoping meetings summary can be found under ADAMS 

No. ML14233A450. Transcripts for the afternoon and evening meetings can be found under 

ADAMS Nos. ML14254A465 and ML14254A470, respectively. In addition to comments 

received during the public meetings, comments were also received electronically and through 

the mail. 

Each commenter was given a unique numeric identifier (001 through 063) so that every 

comment can be traced back to its author. Table A–1 identifies the individuals who provided 

comments and an accession number to identify the source document of the comments in 

ADAMS. Each source document was assigned an alphabetic identifier (A through CC).

Specific comments were categorized and consolidated by topic. Comments with similar specific 

objectives were combined to capture the common essential issues raised by commenters. 

Comments have been grouped into the following general categories:

• Specific comments that address environmental issues within the purview of the NRC 

environmental regulations related to license renewal. These comments address 

Category 1 (generic) or Category 2 (site-specific) issues identified in NUREG–1437, 

Generic Environmental Impact Statement for License Renewal of Nuclear Plants

(GEIS), or issues not addressed in the GEIS. The comments also address 

alternatives to license renewal and related Federal actions.

• General comments in support of, or opposed to, nuclear power or license renewal or 

comments regarding the renewal process, the NRC’s regulations, and the regulatory 

process.

• Comments that address issues that do not fall within, or are specifically excluded 

from, the purview of the NRC’s environmental regulations related to license renewal. 

These comments typically address issues, such as the need for power, emergency 

preparedness, security, current operational safety issues, and safety issues related 

to operation during the renewal period.
Appendix A

A-2 

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

Each commenter is identified, along with an affiliation, and how the comment was submitted.

Commenter Affiliation (if stated) ID Comment Source ADAMS Number

Gabriel Agboruche DTE Electric Company 001 Evening 

Transcript (CC)

ML14254A470

Anonymous None given 002 Comment letter (S) ML14252A172

Mary Ann Baier None given 003 Comment letter (O) ML14252A142

Sandra Bihn Lake Erie Waterkeeper 004 Comment letter (U) ML14252A175

Paul Braunlich Frenchtown Charter 

Township Resort 

District Authority

005 Afternoon 

Transcript (BB)

ML14254A465

Greg Brede None given 006 Afternoon 

Transcript (BB)

ML14254A465

Barry Buschmann The Mannik & Smith 

Group

007 Afternoon Transcript 

(BB)

ML14254A465

Joanne Cantoni None given 008 Comment letter (N) ML14252A141

Corinne Carey Don't Waste Michigan 009 Comment letter (M) ML14252A140

Connie Carroll United Way of Monroe 

County

010 Afternoon Transcript 

(BB)

ML14254A465

Robert Clark City of Monroe 011 Afternoon Transcript 

(BB)

ML14254A465

Jessie Pauline Collins Citizens' Resistance at 

Fermi 2 

012 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470

Comment letter (F) ML14234A189

Comment letter (L) ML14252A139

Valerie Crow None given 013 Evening Transcript 

(CC)

ML14254A470

Eric Dover DTE Electric Company 014 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470

Nancy Dover None given 015 Afternoon Transcript 

(BB)

ML14254A465

Rosemary Doyle None given 016 Comment letter (R) ML14252A171

Michelle Dugan Monroe County 

Chamber of 

Commerce

017 Comment letter (E) ML14234A188

Bill Dyer Utilities Workers Union 

of America, Local 223 

—Fermi Division

018 Afternoon Transcript 

(BB)

ML14254A465

Mark Farris None given 019 Afternoon Transcript 

(BB)

ML14254A465
Appendix A

A-3 

Commenter Affiliation (if stated) ID Comment Source ADAMS Number

Evening Transcript 

(CC)

ML14254A470

Comment letter (Z) ML14252A186

Lynne Goodman DTE Electric Company 020 Evening Transcript 

(CC)

ML14254A470

Martha Gruelle Wildlife Habitat Council 021 Afternoon Transcript 

(BB)

ML14254A465

Keith Gunter Alliance to Halt 

Fermi 3

022 Afternoon Transcript 

(BB)

ML14254A465

Taiya Himebauch DTE Electric Company 023 Afternoon Transcript 

(BB)

ML14254A465

Sean Honell DTE Electric Company 024 Afternoon Transcript 

(BB)

ML14254A465

Carol Izant Alliance to Halt 

Fermi 3 

025 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470

Comment letter (V) ML14252A176

Kevin Kamps Beyond Nuclear 026 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470

Hedwig Kaufman None given 027 Evening Transcript 

(CC)

ML14254A470

Michael Keegan Don't Waste Michigan 028 Afternoon Transcript 

(BB)

ML14254A465

Comment letter (K) ML14252A138

Comment letter (Y) ML14252A180

Manfred Klein None given 029 Evening Transcript 

(CC)

ML14254A470

Dustin Krasny Office of Congressman 

Tim Walberg

030 Afternoon Transcript 

(BB)

ML14254A465

Tim Lake Monroe County 

Business Development 

Corporation

031 Evening Transcript 

(CC)

ML14254A470

Bobby Lambert Monroe County Board 

of Commissioners

032 Evening Transcript 

(CC)

ML14254A470

Ron Lankford None given 033 Afternoon Transcript 

(BB)

ML14254A465

Bill LaVoy Michigan House of 

Representatives

034 Evening Transcript 

(CC)

ML14254A470

Vic and Gail Macks None given 035 Comment letter (J) ML14234A339

Archana Manoharan American Nuclear 

Society/DTE Electric 

Company

036 Afternoon Transcript 

(BB)

ML14254A465
Appendix A

A-4 

Commenter Affiliation (if stated) ID Comment Source ADAMS Number

Bonnie Masserant DTE Electric Company 037 Evening 

Transcript (CC)

ML14254A470

Ed McArdle Sierra Club—Michigan 

Chapter

038 Comment 

letter (AA)

ML14259A341

Jim McDevitt Frenchtown Charter 

Township

039 Comment letter (D) ML14216A376

Rich McDevitt DTE Electric Company 040 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470

Stephen McNew Monroe County 

Intermediate School 

District

041 Comment letter (C) ML14219A583

Floreine Mentel Former Monroe 

County Commissioner

042 Afternoon Transcript 

(BB)

ML14254A465

Jeanne Micka Monroe County 

Garden Club

043 Afternoon Transcript 

(BB)

ML14254A465

Richard Micka None given 044 Afternoon Transcript 

(BB)

ML14254A465

Comment letter (G) ML14234A190

Jessica Miskena None given 045 Evening Transcript 

(CC)

ML14254A470

Sandy Mull Southern Wayne 

County Regional 

Chamber of 

Commerce

046 Afternoon Transcript 

(BB)

ML14254A465

Tracy Oberleiter Monroe County 

Economic 

Development 

Corporation

047 Afternoon Transcript 

(BB)

ML14254A465

Phyllis Oster None given 048 Comment letter (Q) ML14252A170

Sandy Pierce Monroe Center for 

Healthy Aging

049 Afternoon Transcript 

(BB)

ML14254A465

Joseph Plona DTE Electric Company 050 Afternoon Transcript 

(BB)

ML14254A465

Emilio Ramos None given 051 Evening Transcript 

(CC)

ML14254A470

Ken Richards None given 052 Comment letter (T) ML14252A173

Randy Richardville Michigan State 

Senator

053 Comment letter (B) ML14219A580

Angela Rudolph URS 054 Afternoon Transcript 

(BB)

ML14254A465

David Schonberger None given 055 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470
Appendix A

A-5 

Commenter Affiliation (if stated) ID Comment Source ADAMS Number

Comment letter (X) ML14252A178

Robert Simpson None given 056 Comment letter (P) ML14252A143

Comment letter (W) ML14252A177

Phillip Skarbek DTE Electric Company 057 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470

Jerry Sobczak DTE Shareholders 

United

058 Evening Transcript 

(CC)

ML14254A470

Robert Tompkins Detroit Edison Alliance 

of Retirees

059 Comment letter (A) ML14205A009

Tim Walberg U.S. Congress 060 Comment letter (I) ML14234A192

Emily Wood Women in 

Nuclear/DTE Electric 

Company

061 Afternoon Transcript 

(BB)

ML14254A465

Evening Transcript 

(CC)

ML14254A470

Grace Yackee Monroe County 

Community College

062 Afternoon Transcript 

(BB)

ML14254A465

Dale Zorn Michigan State 

Representative

063 Evening Transcript 

(CC)

ML14254A470

Comment letter (H) ML14234A191

Comments that are general or outside the scope of the environmental review for the Fermi 2 

license renewal are not addressed in this appendix, but they can be found in the Scoping 

Summary Report (ADAMS No. ML15252A015). To maintain consistency with the Scoping 

Summary Report, the unique identifier used in that report for each comment is retained in 

Appendix A. Comments addressed in Appendix A are provided in their original form at the end 

of the Scoping Summary Report.

Comments received during the scoping comment period applicable to this environmental review 

were placed into categories, which are based on topics contained in the Fermi 2 draft 

supplemental environmental impact statement (DSEIS). These categories and their 

abbreviation codes are listed in Table A–2 

Table A–2. Issue Categories

Comments were divided into the categories below. 

Code Technical Issue

AM Air Quality 

AL Alternatives to License Renewal

AE Aquatic Resources

CC Climate Change

GW Groundwater Resources

HC Historic and Cultural Resources

HH Human Health
Appendix A

A-6 

Code Technical Issue

PA Postulated Accidents, including Severe Accident 

Mitigation Alternatives (SAMAs)

RW Waste Management

SH Special Status Species and Habitats

TE Terrestrial Resources

The following pages contain the comments that have been copied directly from the comment 

source documents and are followed by the NRC staff response. Each comment is identified by 

the commenter’s identifier (ID), comment source document (as identified in Table A–1), and 

comment number and is grouped by the comment issue category (as identified in Table A–2). 

Similar comments are grouped together with a single response. Comments are presented in 

the same order as listed in Table A–2 

A.1.1 Air Quality (AM)

Comment 029-CC-6: Number six, in 2010, the tornado that we had damaged the power plant, 

damaged Fermi 2 to the point where it had to be shut down. Keep that one in mind. We're not--

we have not seen the last tornado or any other natural event for that matter.

Response: This comment voices concern regarding the impacts associated with tornadoes at 

Fermi. As noted by the commenter, on June 6, 2010, an EF2 tornado with maximum sustained 

winds of 130 to 135 miles per hour (209 to 217 kilometers per hour (km/h)) moved through 

Monroe County. 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 stabilized. There were no radiological releases 

from this event, and power was restored to the site.

The NRC requires licensees to design nuclear power plants to withstand the effects of tornado 

and high wind-generated missiles so as not to adversely impact the health and safety of the 

public in accordance with the requirements in General Design Criterion (GDC) 2, “Design Bases 

for Protection against Natural Phenomena,” and GDC 4, “Environmental and Dynamic Effects 

Design Bases,” of Appendix A, “General Design Criteria for Nuclear Power Plants,” to Title 10 of 

the Code of Federal Regulations (10 CFR) Part 50, “Domestic Licensing of Production and 

Utilization Facilities.” These are called design-basis requirements. Section 4.11.1.2 of the 

Fermi DSEIS discusses design-basis accidents and adopts the GEIS finding that the 

environmental impacts from externally initiated events, such as tornadoes, are SMALL.

A.1.2 Alternatives to License Renewal (AL)

Comment 012-F-4: DTE needs to document the viable alternatives to operating Fermi 2 

another 31 years, as opposed to building and operating both wind and photovoltaic options.

Comment 028-K-5: Wind Power as a viable option. DTE Electric Company (hereinafter, DTE) 

Environmental Report (hereinafter, ER) does not adequately evaluate the full potential for 

renewable energy sources, such as wind power, to replace the loss of energy production from 

Fermi 2, and to make the license renewal request from 2025 to 2045 unnecessary. In violation 

of the requirements of 10 CFR§ 51.53(c) (3) (iii) and of the GElS § 8.1, the DTE ER (§ 7.1.2.2.1) 

treats all of the alternatives to license renewal as unreasonable and does not provide a 

substantial analysis of the potential for significant alternatives, such as wind power, in the 

Region of Interest for the requested relicensing period of 2025 to 2045. While the ER plainly 
Appendix A

A-7 

states, “Whereas a single wind farm generation unit would not provide consistent power 

generation, multiple wind farms scattered within a reasonable region and interconnected 

together via the grid may potentially provide power generation that could approach base-load 

capacity.” On page 7-8, the ER states, “Placing wind farms offshore eliminates some of the 

obstacles encountered when siting wind farms on shore and limits conflicts with other planning 

interests.” 

Comment 019-CC-8: It has its flaws and you know, we also have to look at the -- the Germans 

are using solar and, you know, so that’s the direction they’re going. There – there’s advances 

taken off like gangbusters there and fortunately, the sun doesn’t have to be shining for solar 

technology to work. Of course, it works best without clouds, but it’ll work with cloud cover also.

Comment 019-CC-9: After my comments earlier, I talked to one of the folks here and they told 

me that Germany has a lot of problems now with particulate matter and, you know, gaseous 

emissions because of shutting down nuclear plants. Well, that’s true, however, we have to keep 

in mind that Germany made the same mistake that Detroit Edison made by not putting 

scrubbers in when they could have. The scrubbers out here at the coal burner, you know, that’s 

a step in the right direction and I’m sure the Germans will be working on that also.

Comment 012-CC-4: DET -- DTE also needs to document the viable alternatives to operating 

Fermi 2 another 31 years instead of doing it by a coal-fired plant somewhere else comparing it 

to -- I want them to actually do the -- the figures on -- in windmills, solar panels, sustainable 

energy. Do that now, not -- okay.

Comment 025-CC-3: But I -- I'm not insensitive to, you know, the -- the economic impact of a 

closure of Fermi 2. I -- I understand the economic impact that it would have on this community, 

but I also know that, you know, as we speak, more and more people around the world and in the 

United States are figuring out -- the cost of solar panels is coming down, wind, the whole -- the 

cost of the renewables is coming in cheaper and cheaper and more and more people are going 

to start to move off of the grid. It is -- we are going to move away from the, you know, a 

centralized grid and move into more of a distributed grid of energy.

And, you know, more and more people, the -- the -- you know, the low-hanging fruit of energy 

efficiency, I'm -- my husband and I had a very thorough, you know, attic insulation done a 

couple years ago and duct ceiling and air ceiling and our energy bills, our heating bills, now are 

30 percent less than -- than what they were. And this was even after this cold winter that we 

had this last year.

And -- and also, as kind of a side perk that I never even considered, it -- it keeps the house so 

much cooler in the summer so that -- and I don't have A/C, but I haven't hardly -- I mean, I 

haven't had to run my ceiling fans. I mean, it’s been -- now granted, we’ve had a pretty mild 

summer so far, but nevertheless, you know, and more and more this is what people are going to 

-- you know, nuclear power is such a heavily-subsidized industry. If only, you know, we could 

have the same opportunity to subsidize some of these other ways of generating electricity, I 

mean, you would see a far different, you know, picture.

And again, I -- I know, you know, the younger generation is coming up. They are definitely 

connecting the dots on all of this and the Passive House Movement, which is a net zero, you 

know, way to build a house so that it, you know, it doesn't consume any energy. If anything, it --

it produces electricity and that’s – that’s going to start to happen more and more.

Response. These comments are concerned with renewable energy replacement power and 

energy efficiency alternatives to Fermi 2. In evaluating alternatives to license renewal, the NRC 

staff considered energy technologies or options currently in commercial operation, as well as 
Appendix A

A-8 

technologies not currently in commercial operation but likely to be commercially available by the 

time the current Fermi 2 operating license expires in 2025. 

The NRC staff evaluated 17 alternatives to the proposed action in the Fermi 2 DSEIS. 

Alternatives that could not provide the equivalent of Fermi 2’s current generating capacity and, 

in some cases, those alternatives whose costs or benefits did not justify inclusion in the range of 

reasonable alternatives, were eliminated from detailed consideration. The NRC staff explained 

the reasons why each of these alternatives was eliminated from further consideration in 

Section 2.3 of the Fermi 2 DSEIS. The 17 replacement power alternatives were narrowed to 

4 alternatives considered in detail in Sections 2.2.2.1 through 2.2.2.4 of the Fermi 2 DSEIS. 

The NRC staff evaluated the environmental impacts of these four alternatives and the no-action 

alternative in Chapter 4 of the Fermi 2 DSEIS. 

A.1.3 Aquatic Resources (AE)

Comment 012-F-2: Another issue is Fermi 2's fish kills. DTE's 2009 study stated Fermi 2's 

Cooling Water Intake sucked up 3,102 live fish, and 62,566,649 fish eggs and larvae in a year's 

time. We need another such study to show how many fish the reactor is killing now.

025-V-17: In a nine month study, the Fermi, Unit 2 Cooling Water Intake impinged 3,102 live 

fish and more than 62.5 million fish eggs and larvae. This significant impact to the ecosystem of 

Lake Erie's western basin must be addressed in the SEIS.

012-BB-3: In the 19 – 2009 study that they did on the cooling water intake, it showed the 

cooling water intake sucked up, in an eight-month period, 3,102 live fish, over 63 million fish 

eggs and fish larva in normal operations. The world depends on the fish. And the water they 

put out is hot, inviting in invasive species.

012-CC-2: I want to put in the scoping process another issue to -- another study on the Fermi 2 

cooling water intake's fish kill. The 2009 study showed that they sucked up 3,102 live fish, 

62,566,649 fish eggs and fish larvae in less than a year. Another study needs to be a part of 

this environmental impact statement to see how many fish - - is there any left – I hope so -- in 

the ocean -- or lake.

Response: These comments refer to the “Aquatic Ecology Characterization Report Detroit 

Edison Company Fermi 3 Project, Final Report” prepared by AECOM Environment in 

November 2009 (AECOM 2009) and express concerns regarding the effects of entrainment and 

impingement of Lake Erie fish at Fermi 2’s cooling water intake structure. This report was one 

of the reports reviewed by NRC staff as part of the environmental review. Entrainment and 

impingement of fish are discussed in Sections 3.7 and 4.7 of this draft supplemental 

environmental impact statement (DSEIS). As discussed in Section 4.7, entrainment and 

impingement of aquatic organisms for nuclear power plants with cooling towers is a generic 

(Category 1) issue with an impact level of SMALL for all sites. During the review of the Fermi 2 

LRA, the NRC staff did not identify any new and significant information that would challenge the 

generic conclusion in the GEIS for this issue.

Regarding the need for new or additional studies of entrainment and impingement at Fermi 2, 

the requirements of Section 316(b) of the Clean Water Act of 1977, as amended 

(33 U.S.C. 1251 et seq.), determine the need for studies, such as the studies requested in 

comments. The requirements of Section 316(b) are addressed as part of the National Pollution 

Discharge Elimination System (NPDES) permitting process, which is meant for protection and 

propagation of the waterbody’s balanced, indigenous population of shellfish, fish, and 

wildlife. The State of Michigan, not the NRC, is responsible for administering the NPDES 

permitting program.
Appendix A

A-9 

Comment 035-J-1: Thermal loading of the Great Lakes by Nuclear Reactors

The Nuclear Regulatory Commission (NRC) has stated in Draft NUREG–2105, volume 1, 

October 2011, page 2-228: "Public and occupational health can be compromised by activities 

at the Fermi site that encourage the growth of disease-causing microorganisms (etiological 

agents). Thermal discharges from Fermi into the circulation water system and Lake Erie have 

the potential to increase the growth of thermophilic organisms. These microorganisms could 

give rise to potentially serious human concerns, particularly at high exposure levels."

There are 48 nuclear reactors in the Great Lakes basin. Each one has added to the thermal 

load on the Lakes in addition to designed and non-designed radioactive releases. The water 

usage from Lake Erie is 56,024 million gallons per day (Draft NUREG-2105, volume 1, p. 2-24). 

Of that, 50,518 million gallons per day are used by power plants. Nuclear power plants release 

some of that in water vapor and the rest goes back into Lake Erie heated. Without water 

cooling, reactors would melt their cores and explode as happened to three at Dai-ichi.

Toxic plumes on Lake Erie were a repeat occurrence in August 2014, shutting down water to 

Toledo and surrounding areas. The only allowable water use was to flush a toilet. We cannot 

live with safe water being made unavailable from multiple causes and most significantly, in this 

instance, from Fermi 2 and Davis Bessie, near Toledo, on Lake Erie.

Comment 028-K-16: Petitioner's request a public hearing to examine the impact of daily 

thermal discharges from Fermi 2 as an accelerator and contributor to harmful algal blooms 

(HABS). The Fermi 2 releases 45 million gallons of water per day into Lake Erie. This thermal 

discharge averages 18 degrees (F) above ambient lake temperature 365 days per year. 

Petitioner's contend that the Applicant's Environmental Report (ER) fails to consider new and 

updated environmental and public health data, unavailable at the time of issuance of the original 

Operating License; further, the Petitioner contends that the Applicant fails to adequately 

consider Mitigation Alternatives which could significantly reduce the alleged significant 

environmental and public health impact of Fermi, Unit 2 operations. Therefore, the Petitioner 

invokes NEPA requirements and contends that further analysis is called for. Illustration: 

Petitioner puts forth the following NOAA Satellite Image of Lake Erie from August 10, 2014 to 

illustrate how severe the algal bloom crisis has become. 

http://coastwatch.glerl.noaa.gov/webdata/cwops/htmi/modis/modis.php?region=e&pacqe=1&ite

mplate=sub&image=al.14222.1852.LakeErie.143.250m.jpg

Comment 012-L-1: Earlier this month, thousands of people in the vicinity of the Fermi 2 

nuclear reactor could not drink their water because of poison algae growth. And yet, back in 

2011, the NRC stated, "Public and occupational health can be compromised by activities at the 

Fermi site that encourage the growth of disease-causing micro-organisms (etiological agents). 

Thermal discharges from Fermi into the circulation water system and Lake Erie have the 

potential to increase the growth of thermophilic organisms. These microorganisms could give 

rise to potentially serious human concerns, particularly at high exposure levels.” (Draft 

NUREG–2105, Vol. 1, 10/2011, page 2-228)

So if the NRC knew if 2011 that DTE's discharges could poison the water, why did they let 

them? For profit, or were they/you covering the legal liability laws by declaring you make the 

potential degradation public, but hoping no one noticed. Your agency added in that same 

document, "Recent studies of the effects of climate change indicate that there could be declines 

in the overall Lake Erie water levels of 1 to 2 m (Hartig et al 2007). There are no known studies 

of potential future surface water use in the Lake Erie Basin or the entire Great Lakes Basin.” 

(p. 2-25) Maybe you couldn't see a future for the Lake at the rate its being poisoned.
Appendix A

A-10

Comment 004-U-1: About 500,000 people who are provided drinking water by the City of 

Toledo were told not to drink the water because the toxin microcystin exceeded World Health 

Organization drinking water standards. Fermi 2 is located at the western end of the western 

basin of Lake Erie. Fermi uses up to 50 mgd for cooling purposes which means that water 

exiting the plant is warmer than water entering the plant. Harmful algal blooms are triggered 

when the water gets warmer. Lake Erie's first mass of algae each year is generally in the 

Monroe DTE coal and nuclear plant mixing zones. Before relicensing, there needs to be an 

assessment of whether or not the thermal discharge mixing zone algae creation is contributing 

to a larger bloom of harmful algae- cyanobacteria - and/or if the thermal discharge contributes to 

an increased amount of microcystin released in the water.

Comment 029-CC-3: Number three, somebody spoke about loving the lake, as I do, even 

though I'm not a long- term resident of Monroe. We've only been here about 16 years. The fact 

of the matter is that the – the temperature -- the cooling water that comes out of Fermi is above 

the water temperature of the lake and it contributes to the algal blooms. If anybody would like to 

seen one or would've liked to have seen one last year, I could invite them down to my place and 

you could smell it before you got there.

Response: These comments express concerns regarding the effects of Fermi 2’s thermal 

discharge on harmful algal blooms in Lake Erie. Harmful algal blooms are discussed in 

Sections 3.7, 4.7, 4.14, and 4.16 of this DSEIS. As discussed in Section 4.7, algal blooms 

resulting from the operation of cooling systems are addressed as part of the generic 

(Category 1) issue, “Infrequently Reported Thermal Impacts.” As noted in Section 4.16.5 of this 

DSEIS, several research studies indicate that recent algal blooms in western Lake Erie are 

linked to nutrient loading, nutrient releases by zebra mussels, and selective feeding by zebra 

mussels, with much more research needed (EPA 2014). Based its review of available 

information for the Lake Erie algal blooms, the NRC staff determined that this information does 

not constitute new and significant information that would change the GEIS’s conclusion of 

SMALL for this issue.

DTE is required to address the thermal impacts from the operation of Fermi 2—including any 

possible mitigation that may be required—as part of the NPDES permitting process. The 

NPDES process is meant for the protection and propagation of the waterbody’s balanced, 

indigenous population of shellfish, fish, and wildlife and for enforcing Michigan State Water 

Quality Standards to protect the public health and welfare, to enhance and maintain the quality 

of water, and to protect the State’s natural resources. The State of Michigan, not the NRC, is 

responsible for administering the NPDES permitting process.

Comment 025-V-13: Thermal discharges into Lake Erie:

Within the Scope for review, the SEIS for the Fermi, Unit 2 LRA must include an updated and 

realistic analysis of current and projected public health impacts of authorized, routine, by-design 

thermal discharges by Fermi, Unit 2 into the surrounding environment. ATHF3 [Alliance to Halt 

Fermi 3] considers this issue to be in the category of "Significant New Unknown and 

Unanalyzed Conditions.” The SEIS must consider new and updated environmental and public 

health data, unavailable at the time of issuance of the original Operating License; further, the 

SEIS must adequately consider Mitigation Alternatives which could significantly reduce the 

alleged environmental and public health impacts of Fermi, Unit 2's operations. Thus, further 

analysis is called for, under NEPA. 

In support of this contention, ATHF3 submits into the docket the following analysis from the 

U.S. NRC, pertaining to the Fermi Nuclear Power Plant:
Appendix A

A-11

• The U.S. Nuclear Regulatory Commission (NRC) has stated in Draft NUREG–2105, 

volume 1, October 2011, page 2-228: "Public and occupational health can be 

compromised by activities at the Fermi site that encourage the growth of 

disease-causing microorganisms (etiological agents). Thermal discharges from 

Fermi into the circulation water system and Lake Erie have the potential to increase 

the growth of thermophilic organisms. These microorganisms could give rise to 

potentially serious human concerns, particularly at high exposure levels.” (emphasis 

added).

Indeed, the U.S. NRC has been vindicated, as the above analysis has proved to be both correct 

and prescient. The Governor of the State of Ohio recently declared a "State of Emergency" 

(summer 2014) in response to a clean drinking water supply crisis in and around the City of 

Toledo, Ohio. There is no doubt about the significance of this public health crisis. The question 

is to what extent Fermi, Unit 2 operations contributed to the conditions which led to the crisis in 

the first place, and what are the prospects for the future. ATHF3 contends that one significant

contributing factor is the routine thermal discharges from Fermi, Unit 2 which add cumulative 

stress impacts to the fragile ecosystem of Lake Erie's shallow western basin and shoreline. 

Lake Erie already suffers from numerous environmental stressors, including pollution from 

agricultural runoff (such as phosphorus), sewage overflows and routine, authorized releases of 

industrial toxic chemicals (including releases originating from Fermi, Unit 2). In addition, thermal 

pollution from nearby power plants is a known contributing factor to the conditions which 

produce toxic algal blooms and consequent hypoxic dead zones. The exact and precise extent 

to which Fermi, Unit 2 normal operations are directly causative, not just correlative, of significant 

environmental and public health impacts is "unknown and unanalyzed.” Therefore, ATHF3 

hereby invokes NEPA requirements and contends that a "hard look" and further analysis is 

called for, as a precondition for approval of the Applicant/Licensee's Fermi, Unit 2 License 

Renewal Application (LRA).

Additionally, ATHF3 demands an SEIS analysis of the environmental and public health impacts 

of the NRC's decision to approve Fermi, Unit 2 License Amendment No. 196, which allows an 

increase in thermal power from the facility. The largest algae blooms on Lake Erie occur in the 

shallow, warm water near DTE's nuclear and coal-fired power plants.

Comment 028-Y-4: Algae Bloom Contribution

Algae blooms of particular concern in Lake Erie is Microcystis spp., a phytoplanktonic species of 

blue-green alga that can produce a substance (microcystin) that is toxic to fish and other 

organisms when concentrations are high enough. Mycrocystis spp. Blooms can affect water 

quality as well as the health of human and natural resources. General consensus is that algae 

blooms initiate in the western Lake Erie basin. What is the Thermal Contribution of Fermi 2 to 

Algae Blooms, we are requesting that there be a multivariate analysis conducted by a qualified 

independent third party.

Thermal Discharge Impact on Algae Blooms

Another assault on Great Lakes water degradation is due to thermal discharges. Public and 

occupational health can be compromised by activities at the Fermi site that encourage the 

growth of disease-causing microorganism (etiological agents). Thermal discharges from 

Fermi 2 into the circulating water system and Lake Erie have the potential to increase the 

growth off thermophilic microorganisms. These microorganisms could give rise to potentially 

serious human health concerns, particularly at high exposure levels. This would endanger the 

whole bio-region, yet there is only tertiary discussion in the ER of thermal contribution from 

Fermi 2, and how it will be mitigated. Forty-five million gallons per day of discharge averaging 

18 degrees F above ambient Lake Erie temperature. This compounds the Algae Blooms
Appendix A

A-12

Response: These comments express concern regarding the sensitivity of the Lake Erie 

ecosystem to stressors, the effects of Fermi 2’s thermal discharge on harmful algal blooms in 

Lake Erie, and the effect of the thermal effluent on thermophilic organisms that can affect 

human health. Section 4.16.5 of this DSEIS addresses the sensitivity of the Lake Erie 

ecosystem. As discussed in Section 4.16.3, the EPA has initiated the Great Lakes Restoration 

Initiative, which is a consortium of 11 Federal agencies that were tasked with developing an 

action plan to address (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. More information on the Great Lakes Restoration Initiative can be found at 

http://greatlakesrestoration.us/. 

Sections 3.7, 4.7, 4.14, and 4.16.5 of this DSEIS discuss harmful algal blooms. As discussed in 

Section 4.7, algal blooms resulting from the operation of cooling systems are addressed as part 

of the generic (Category 1) issue, “Infrequently Reported Thermal Impacts.” As noted in Section 

4.16.5 of this DSEIS, several research studies indicate that recent algal blooms in western Lake 

Erie are linked to nutrient loading, nutrient releases by zebra mussels, and selective feeding by 

zebra mussels, with much more research needed (EPA 2014). Based its review of available

information for the Lake Erie algal blooms, the NRC staff determined that this information does 

not constitute new and significant information that would change the GEIS’s conclusion of 

SMALL for this issue. 

As discussed in Section 3.11.3 of this DSEIS, heated discharge from cooling system operations 

can result in the presence of thermophilic microorganisms, such as enteric pathogens, 

thermophilic fungi, bacteria, and the free living amoeba. 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. 

DTE is required to address the thermal impacts from the operation of Fermi 2—including any 

possible mitigation that may be required—as part of the NPDES permitting process. The 

NPDES process is meant for the protection and propagation of the waterbody’s balanced, 

indigenous population of shellfish, fish, and wildlife and for enforcing Michigan State Water 

Quality Standards to protect the public health and welfare, to enhance and maintain the quality 

of water, and to protect the State’s natural resources. The State of Michigan, not the NRC, is 

responsible for administering the NPDES permitting process.

A.1.4 Climate Change (CC)

Comment 038-AA-5: Because of the long time line of proposed operation until 2045 and the 

prospect of an additional 60 years allowed for decommissioning, much care must be taken to 

determine the environmental impacts for at least 90 years from now (until 2105 and possibly 

beyond).

As a result multiple scenarios must be considered; [...]

5. Overriding all of these concerns is the ongoing crisis of global warming and its effect on Lake 

levels and more severe weather events that are predicted.

Response: This comment voices concern about climate change implications, specifically the 

impacts on Lake levels and severe weather events. Section 4.15.3 of this DSEIS discusses 

projected climate change for the license renewal period of Fermi 2 (2025 to 2045) and climate 

change impacts to resource areas. 
Appendix A

A-13

As discussed in Section 4.15.3, water levels for Lake Erie have exhibited a downward trend 

since the 1860s, and 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;). 

However, 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.

Further, as discussed in Section 4.15.3, 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.

Comment 019-CC-5: We have to look at some of the reactors, you know, with the global 

disruption of weather. We're going to see as we have in the past, some nuclear power plants 

have had to shut down for a lack of cooling water. River levels drop. The water warms up and 

some nuclear plants have had to be shut down and I think that that's an issue we're going to be 

seeing a whole lot more of down the road.

Response: This comment voices concern about climate change implications to water 

resources, specifically the impacts of climate change on operation of nuclear power plants. 

Section 4.15.3, “Greenhouse Gas Emissions and Climate Change,” of this DSEIS discusses 

projected climate change for the license renewal period of Fermi 2 (2025 to 2045) and climate 

change impacts to resource areas. However, the impacts of climate change on operations and 

safety of Fermi 2 are considered outside the scope of the license renewal environmental review, 

which documents the potential impacts of continued operation on the environment. The NRC 

evaluates nuclear plant operation conditions and physical infrastructure to ensure continued 

safe operations through its ongoing inspection and oversight process. Furthermore, plant 

operations are dictated by NRC-issued operating license technical specifications. Technical 

specifications and operating procedures exist to ensure that adequate cooling water is available 

and is maintained to ensure safe operation of the facility. Licensees must operate within the

dictated technical specifications, or if they propose changes in operating conditions contrary to 

operating license specifications, the NRC staff conducts safety reviews of any such license 

amendment before allowing the specific licensee to continue operation.

A.1.5 Groundwater Resources (GW)

Comment 012-F-5: There exists a need for explanation as to why citizens within the radiation 

zone are no longer allowed to use their water well, and must have water brought into them if 

they are unable to hook up to a public water supply.

Comment 012-L-2: Groundwater was also noted to be affected back in 2011, "In wells within a 

5-mile radius of the Fermi site, elevated concentrations of arsenic above the EPA (2009a) 

maximum contaminate level (MCL) were found in groundwater samples (Detroit Edison 2011 a). 

p. 2-29

Comment 019-BB-2: And one issue I wanted to bring up momentarily, is that 2,500 gallons of 

diesel fuel that leaked here recently at the Fermi Plant, was this a large line or just a long-term 

leak that nobody paid attention to? Where was the NRC? You know, nobody mentioned, no 

comments from the NRC on this issue. That raises questions.

Comment 012-CC-5: There's also a great number of people within a 25-mile radius of the plant 

that are no longer allowed to use their water wells. They have to either buy their water or hook 

up to a public water supply. Why are their wells contaminated?
Appendix A

A-14 

Response: Section 3.5.2.3 of this DSEIS presents the NRC staff’s characterization of existing 

groundwater quality beneath the Fermi site. As discussed in Section 3.5.2.3, the groundwater 

outside the Fermi site has not been impacted by Fermi 2 activities. Within the site boundary, no 

significant concentrations of radionuclides above background have been found in the 

groundwater. In addition, DTE maintains a radioactive effluent monitoring and a radiological 

environmental monitoring program (REMP) at Fermi 2 to assess the radiological impact (if any) 

to its employees, the public, and the environment around the Fermi site. As part of the license 

renewal environmental review, the NRC staff specifically reviewed DTE’s most recent annual 

radiological environmental operating reports, which are submitted under the REMP, to look for 

any significant impacts to the environment or any unusual trends in the data. Based on the 

review of the radiological environmental monitoring data, the NRC staff found that there were no 

unusual and adverse trends and that there was no measurable impact to the offsite environment 

from Fermi 2 operations. The NRC’s ongoing inspection program periodically evaluates DTE’s 

programs for compliance with the NRC’s radiation protection standards. The NRC’s inspection 

program evaluates the data for compliance with radiation protection standards. If the data were 

to show a noncompliance with requirements, the NRC would take appropriate enforcement 

action.

However, within the site boundary, a few nonradiological spills of chemicals have occurred, as 

noted in Section 3.5.1.3 and further described in Section 3.5.2.3. All of these spills were 

reported by DTE to the Michigan Department of Environmental Quality and have been 

remediated. During the license renewal environmental review for Fermi 2, the NRC staff 

specifically considered the issue of such minor chemical spills as part of its review of information 

for “generic” surface water issues. The use of chemicals and fuels is common at industrial 

facilities and spills are always a possibility. Any such spills are regulated by State and other 

Federal environmental agencies, rather than the NRC. As stated in Section 4.5.1.1 of the 

DSEIS, the NRC staff did not identify any new and significant information with regard to the 

Category 1 (generic) surface water issues and found, in part, that the environmental impact of 

minor chemical spills is SMALL.

Finally, in Monroe County and other counties in Michigan, naturally occurring concentrations in 

the groundwater of arsenic and some nonhazardous water quality constituents may exceed 

drinking water standards. In wells within a 5-mi (8-km) radius of the Fermi site, elevated 

concentrations of arsenic above the EPA maximum contaminant level for drinking water have 

been found. The Fermi site did not cause the arsenic concentrations in these wells. In the local 

area and in other areas of Michigan 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. If the water in a private well is found to be high in 

arsenic one of the corrective actions that can be taken is to close the well and connect to a 

public water supply.

A.1.6 Historic and Cultural Resources (HC)

Comment 012-F-3: Next issue needing study is why the Walpole Island First Nation, which 

exists on unceded lands within the 50-mile evacuation zone, is not allowed to have input into 

these proceedings.

Comment 028-K-6: WALPOLE ISLAND FIRST NATIONS' EXCLUSION FROM 

PROCEEDINGS

Statement of the Contention and Comment
Appendix A

A-15

Purpose of Contention: To ensure that all Native American tribes and bands and First Nations 

have adequate notification by NRC of the proposed Fermi 2 licensing extension and 

environmental review proceedings, as due to them under applicable treaties, laws, and 

regulations; and to ensure that individual tribal members' interests are represented whether their 

tribal government intervenes or not on their behalf.

Comment 025-V-19: First Nations Treaty Rights:

All of the following recognized First Nations (Native American) communities have treaty rights at 

Fermi, Unit 2. Each of these communities has legal standing in the Matter of the Fermi, Unit 2 

LRA relicensing proceeding. ATHF3 contends that the SEIS must adequately address the 

impacts of continued operations at Fermi, Unit 2 on the health and well-being of the standing 

population:

• Grand Traverse Band of Ottawa and Chippewa

• Ottawa Tribe of Oklahoma

• Wyandotte Nation

• Saginaw Chippewa Indian Tribe of Michigan

• Sault Ste. Marie Tribe of Chippewa Indians of Michigan

• Ogema Little River Band of Ottawa Indians

• Little Traverse Bay Bands of Odawa Indians

• Delaware Nation

• Hannahville Indian Community

• Pokagon Band of Potawatomi Indians

• Bay Mills Indian Community

• Lac Vieux Desert Tribe

• Forest County Potawatomi Community of Wisconsin

• Shawnee Tribe

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

• Huron Potawatomi, Inc.

• Keweenaw Bay Indian Community

• Lac Vieux Desert Band of Lake Superior Chippewa Indians

Members of the above U.S. federally-recognized communities have treaty rights to hunt, fish 

and gather in the area of the Fermi, Unit 2 nuclear power plant. ATHF3 is concerned that if the 

NRC approves the proposed Fermi license extension, the health, safety and quality of life of the 

native population would be adversely affected. Numerous species of plants, fish, wild game and 

migratory birds are already being polluted by Fermi, Unit 2's routine discharges which 

bioaccumulate, thus making unhealthy or inedible the entire local food supply for current and 

future generations.

In addition, ATHF3 believes that the U.S. NRC should officially recognize the legal standing of 

the Walpole Island First Nations (WIFN), who reside within a 50-mile-radius of Fermi, Unit 2. 

WIFN is an unceded island located between Michigan and Canada, populated by natives who 
Appendix A

A-16

were never captured and who never surrendered; they are sovereign entities. However, the 

NRC has refused to allow WIFN to legally intervene in Fermi licensing proceedings because the 

NRC considers them to be Canadians not entitled to NRC-recognition or to U.S. treaty rights.

Comment 012-CC-3: The next issue I want in the record is why Walpole Island First Nation, 

which exists on unceded lands and is within the 50-mile evacuation zone, is not allowed to have 

input into the proceedings. 

Response: These comments concern the NRC’s recognition and notification of Indian tribal 

nations and the potential impacts from Fermi 2 license renewal on associated native 

populations. 

As discussed in Section 4.9 of the Fermi 2 DSEIS, the NRC initiated consultations with the 

Advisory Council on Historic Preservation, the Michigan State Historic Preservation Office 

(SHPO), and 17 Federally recognized Indian tribes. The NRC provided information about the 

proposed undertaking (license renewal); defined the area of potential effect; and indicated that 

the NRC would comply with Section 106 of the National Historic Preservation Act of 1966, as 

amended (54 U.S.C 300101 et seq.), through the requirements of the National Environmental 

Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.), and as outlined in 36 CFR 800.8. 

The NRC invited the Michigan SHPO and the tribes to participate in the identification of historic 

properties and any decisions potentially affecting historic properties and invited them to 

participate in the NEPA process.

Separate from these consultations, an Indian tribe from Ontario, Canada, the Walpole Island 

First Nation, 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. 

The DSEIS addresses potential human health impacts from Fermi 2 license renewal in 

Section 4.11. Section 4.12.1 presents an analysis of potential impacts specific to subsistence 

consumption of fish and wildlife by tribal populations. 

A.1.7 Human Health (HH)

Comment 035-J-3: Radiation Releases from Nuclear Reactors

National Academy of Sciences, Committee on the Biological Effects of Ionizing Radiation (BEIR) 

has stated that all ionizing radiation including low levels can produce broad spectrum 

non-malignant illnesses and cancer, morbidity, as well as genetic mutations. The BEIR report 

defines low level radiation as near zero to 100 millisieverts (mSv).

http://www8.nationalacademies.org/onpinews/newsitem.aspxRecordl D=11340

See also: http://www.radiation.org/about/index.html

This is ignored, dismissed, and trivialized by the NRC recurrently over decades of statements. 

Fermi 2, like all reactors has stipulated designed radiation releases into the biosphere 

continuously. Degraded equipment, operator error, and accidents expand the public exposure 

to ionizing radiation. The public is not provided with actual real time measurements and is 

misled by NRC/industry statements conflating "allowable" limits with "safe" or "legal" limits. 

"Legal limit" is also misleading in that there is no punishment, sanction, or penalty for exceeding 

it. The cumulative effect of release exposures, varying in dose, experienced over time, are 

addressed by the NRC as though each release were one time only in impact on human cell 

tissue and the rest of the biosphere. The reality ignored by the NRC is that years or a lifetime of 
Appendix A

A-17

exposure to releases from nuclear reactors, added to the fallout from nuclear weapons 

production and testing, nuclear medicine, X-rays, (all man made sources) have been producing 

illness, morbidity, and genetic mutations. It is convenient for the NRC, the National Nuclear 

Security Administration (NNSA) and the nuclear industry to address a given ionizing radiation 

exposure as though it existed in isolation and is not additive to all of the rest of releases and 

ongoing exposures around the region, the nation, and the world currently and historically and to 

behave as though once forgotten, ionizing radiation ceases to exist.

There is a cynicism in the NRC, the NNSA, and the nuclear industry not being upfront in stating 

clearly to the public that the decision was made in the 1940s, and continuing in the present, that 

there will be manmade ionizing radiation releases into the biosphere, that those releases will be 

whatever the nuclear regulators/industry decides and that the exposures will increase. Indeed, 

they have increased. Ionizing radiation and radionuclide particles move about the world, are 

ingested and breathed in and bioaccumulate up the food chain. They assault human cell tissue 

and the rest of the biosphere, in accord with their dose and half-lives. A problematic issue, 

obfuscated, unmeasured, unstudied---to that extent and intentional----doesn't exist in the public 

mind. A result desired and intended by nuclear advocates beginning with the Manhattan 

Project.

Response: This comment expresses concerns about the adequacy of radiation limits and the 

human health effects of exposure to radiation. The NRC’s mission is to protect the public health 

and safety and the environment from the effects of radiation from nuclear reactors, materials, 

and waste facilities. The NRC’s regulatory limits in 10 CFR Part 20 for radiological protection 

are set to protect workers and the public from the harmful health effects (i.e., cancer and other 

biological impacts) of radiation on humans. The dose limits are based on the recommendations 

of standards-setting organizations that reflect extensive scientific study by national and 

international organizations. The NRC actively participates in, and monitors the work of, these 

organizations to keep current on the latest trends in radiation protection.

Regarding the comment that the National Academy of Sciences report on radiation health 

effects (i.e., the Biological Effects of Ionizing Radiation (BEIR) report) concluded that there is no 

safe dose of radiation, the NRC disagrees with that assertion. The BEIR VII report entitled, 

“Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2,” does not 

assert that there is no safe level of exposure to radiation. Rather, the conclusions of the report 

are specific to estimating cancer risk. The report does not make any statements about “no safe 

level or threshold.” However, the report did note that the “BEIR VII Committee said that the 

higher the dose, the greater the risk; the lower the dose, the lower the likelihood of harm to 

human health.” Although the linear no-threshold model is still considered valid, the BEIR VII 

Committee concluded that the current scientific evidence is consistent with the hypothesis that 

there is a linear dose-response relationship between exposure to ionizing radiation and the 

development of radiation-induced solid cancers in humans. Further, the Committee concluded 

“that it is unlikely that a threshold exists for the induction of cancers but notes that the 

occurrence of radiation-induced cancers at low doses will be small.” The BEIR VII Committee 

concluded that the current scientific evidence is consistent with the hypothesis that there is a 

linear no-threshold dose-response relationship between exposure to ionizing radiation and the 

development of cancer in humans.

The linear, no-threshold dose response relationship describes the relationship between 

radiation dose and adverse impacts, such as incidents of cancer. Simply stated, in this model, 

any increase in dose, no matter how small, results in an incremental increase in health risk. 

This theory is accepted by the NRC as a conservative model for estimating health risks from 

radiation exposure, recognizing that the model probably overestimates those risks. Based on 

this theory, the NRC conservatively establishes limits for radioactive effluents and radiation 
Appendix A

A-18

exposures for workers and members of the public. Although the public dose limit in 

10 CFR Part 20 is 100 mrem (1 millisievert (mSv)) for all facilities licensed by the NRC, the NRC 

has imposed additional dose constraints on nuclear power reactors. Each nuclear power 

reactor has enforceable license conditions that limit the total annual whole body dose to a 

member of the public outside the facility to 25 mrem (0.25 mSv). The amount of radioactive 

material released from nuclear power facilities is well measured, well monitored, and known to 

be very small. The doses of radiation that are received by members of the public as a result of 

exposure to nuclear power facilities are so low (i.e., less than a few mrem) that resulting 

cancers attributed to the radiation have not been observed and would not be expected.

As part of its review of the Fermi 2 LRA, the NRC evaluated the projected environmental 

impacts from the operation of Fermi 2 during the license renewal term. The NRC staff reviewed 

Fermi 2’s radiological data on effluent releases and the environmental monitoring program. The 

NRC concluded that the radiological impacts to human health would be SMALL during the 

license renewal term. The NRC staff’s discussion of these issues appears in Sections 3.1.4 

and 4.11.1 of this DSEIS.

Comment 035-J-4: Cancer Deaths from Fermi 2

Center for Disease Control statistical analysis shows that there is a significantly higher 

incidence of cancer deaths for Monroe, MI residents compared with incidences for the U.S. as a 

whole. This increase in Monroe cancer deaths correlates with the Fermi 2 going to full power. 

This is ignored by the NRC and Detroit Edison:

RISING LOCAL CANCER RATE SUGGESTS LINK WITH FERMI REACTOR

January 14, 2009 - The cancer death rate in Monroe County has been rising since the late 

1980s, when the Fermi 2 nuclear reactor began operating, according to a new analysis.

The rise in cancer has been sharpest among children and adolescents, who are most 

susceptible to the harmful effects of radiation exposure. The analysis uses official data from the 

U.S. Centers for Disease Control and Prevention.

"The increasing cancer death rate among Monroe County residents, especially young people, 

suggests a link with the radioactive chemicals emitted from the Fermi reactor," says Joseph J. 

Mangano MPH MBA, Executive Director of the Radiation and Public Health Project research 

group. "Because Monroe County has a low risk population that is well educated, high income, 

and has few language barriers, rising cancer rates are unexpected, and all potential causes 

should be investigated by health officials."

Fermi 2 reactor began "operating" June 21, 1985. However, it ran very little after the initial 

low-power start-up until a warranty run in January of 1988, marking the commercial start-up of 

the reactor. In the early 1980s, the Monroe County cancer death rate was 36th highest of 

83 Michigan counties, but by the early 2000s, it had moved up to 13th highest. From

1979-1988, the cancer death rate among Monroe County residents under age 25 was 21.2% 

below the U.S. rate. But from 1989-2005, when Fermi 2 was fully operational, the local rate was 

45.5% above the U.S.

All nuclear reactors produce electricity by splitting uranium atoms, which creates high energy 

needed to heat water. This process also creates over 100 radioactive chemicals, not found in 

nature, including Strontium-90, Cesium-137, and Iodine-131.

While most of these chemicals are retained in reactors and stored as waste, a portion is 

routinely released into the local air and water. They enter human bodies through breathing and 

the food chain, and raise cancer risk by killing and injuring cells in various parts of the body. 

They are especially harmful to children.
Appendix A

A-19

The findings come at a time when a new nuclear reactor has been proposed at the Fermi plant. 

The original Fermi 1 reactor, which was the site of a "Partial Core-Melt Accident" in 1966, shut 

permanently in 1972.

DATA ON CANCER RISK FROM FERMI 2 RADIOACTIVE EMISSIONS

• The Fermi 2 reactor is located in Monroe County, and started on June 21, 1985, not 

becoming fully operational until January 1988.

• Fermi 2 came close to a meltdown on March 28, 2001 and August 14, 2003. (1)

• Fermi 2, like all reactors, routinely emits over 100 radioactive chemicals into air and 

water.

• Each of these chemicals causes cancer, and is most harmful to infants and children.

• For cancer deaths for all ages (whites only), Monroe County ranked

• 36th highest of 83 Michigan counties in 1979-1983 (before startup)

• 13th highest of 83 Michigan counties in 2000-2005 (latest data) (2)

• The Monroe County cancer death rate age 0-24

− was 21.1% below the U.S. in 1979-1988 (before/during startup)

− was 45.5% above the U.S. in 1989-2005 (after startup) (3)

• Monroe County has no obvious cancer risk. It has a high income, low poverty, well 

educated population with few language barriers and access to excellent medical care 

in nearby Detroit. (4)

Thus, an increase in cancer (especially to children) is unexpected. This change should be 

investigated, and one potential cause should be radioactive emissions from Fermi.

Sources:

1. Fermi 2 incurred "near miss" accidents on March 28, 2001 (emergency diesel generator was 

inoperable for over 7 days) and August 14, 2003 (loss of offsite power due to northeast 

blackout). Source: Greenpeace USA. An American Chernobyl: Nuclear "Near Misses" at 

U.S. Reactors since 1986. www.greenpeace.org, April 26, 2006.

2. U.S. Centers for Disease Control and Prevention, http://cdc.wonder.gov, underlying cause of 

death. Death rates are adjusted to 2000 U.S. standard population. Includes ICD-9 codes 

140.0-239.9 (1979-1983) and ICD-1 0 codes COO-D48.9 (2000-2005). Whites account for over 

95% of Monroe residents.

3. Cancer Death Rates, Monroe County vs. U.S. 1979-1988 and 1989-2005, age 0-24

Period

Monroe County 

Cancer Deaths Avg. Pop.

Deaths/100,000 Pop.

Monroe U.S. %vs. US

1979-1988 22 56,234 3.91 4.96 -21.2%

1989-2005 42 51,407 4.86 3.79 +45.5%

Source: U.S. Centers for Disease Control and Prevention, http://cdc.wonder.gov, underlying cause of 

death.
Appendix A

A-20

Includes ICD-9 codes 140.0-239.9 (1979-1983) and ICD-10 codes COO-D48.9 (2000-2005). 

Increase in rate significant at p < .05.

4. Demographic Comparison, Monroe County vs. U.S.

Indicator Monroe U.S.

2006 Population 155,035 299,398,484

2000 % Foreign Born 1.9 11.1

2000 % Language other than English spoken 

at home, age 5+

4.0 17.9

2000 % High School graduates, age 25+ 83.1 80.4

2000 % Homeownership 81.0 66.2

2004 Median Household Income $53,838 $44,344

2004 % Below Poverty 8.7 12.7

Source: U.S. Census Bureau, www.census.gov, 2000 population, State and County 

Quick facts

Comment 028-K-15: The Petitioner requests a public hearing to consider the following 

Contention pertaining to "Significant New Unknown and Unanalyzed Conditions" reflected by 

the Applicant/Licensee's incomplete and obsolete analysis of public health impacts of 

authorized, routine, by-design radioactive releases by Fermi, Unit 2 into the surrounding 

environment. The Petitioner contends that the Applicant's ER fails to consider new and updated 

public health data, unavailable at the time of issuance of the original Operating License; further, 

the Petitioner contends that the Applicant fails to adequately consider Mitigation Alternatives 

which could significantly reduce the alleged significant environmental and public health impact 

of Fermi, Unit 2 operations. Therefore, the Petitioner invokes NEPA requirements and contends 

that further analysis is called for. In support of this Contention, the Petitioner submits into the 

docket the following public health impacts study by the Radiation and Public Health Project 

(RPHP): Potential Health Risks Posed By Adding A New Reactor At The Fermi Plant: 

Radioactive contamination from Fermi 2 and changes in local health status, pages 1-21, 

January 10, 2012, Joseph J. Mangano, MPH, MBA, Executive Director, Radiation and Public 

Health Project (RPHP). 

http://www.beyondnuclear.orq/storage/Manqano_corrected_Fermi_report_Jan_11_2012.pdf

Comment 025-V-12: Public Health Impacts:

Within the Scope for review, the SEIS for the Fermi, Unit 2 LRA must include an updated and 

realistic analysis of current and projected public health impacts of authorized, routine, by-design 

radioactive releases by Fermi, Unit 2 into the surrounding environment. ATHF3 considers this 

issue to be in the category of "Significant New Unknown and Unanalyzed Conditions.” The 

SEIS must consider new and updated public health data, unavailable at the time of issuance of 

the original Operating License; further, the SEIS must adequately consider Mitigation 

Alternatives which could significantly reduce the alleged environmental and public health 

impacts of Fermi, Unit 2's operations. Thus, further analysis is called for, under NEPA. 

In support of this contention, ATHF3 submits into the docket the following public health impacts 

study by the Radiation and Public Health Project (RPHP):

Potential Health Risks Posed By Adding A New Reactor At The Fermi Plant: Radioactive 

contamination from Fermi 2 and changes in local health status, pages 1-21, January 10, 2012, 

Joseph J. Mangano, MPH, MBA, Executive Director, Radiation and Public Health Project 
Appendix A

A-21

(RPHP). http://www.beyondnuclear.org/storage/Mangano corrected Fermi report Jan 11 

2012.pdf

Additionally, making the case for scoping and material relevance, ATHF3 submits revised 

excerpts from the following press release issued by the Fermi, Unit 3 COLA Intervenors:

February 2, 2012

NEW REPORT SHOWS INCREASE IN CANCERS AND MORTALITIES SINCE FERMI 2 

NUCLEAR PLANT START UP

Thursday -- Monroe, MI -- A new report submitted to the U.S. Nuclear Regulatory Commission 

(NRC) shows dramatic increases in cancer and mortalities in Monroe County since the start-up 

of the Fermi 2 nuclear plant. Using data from the Centers for Disease Control and Prevention 

(CDC), the report was prepared by Joseph Mangano, MPH, MBA, Executive Director of the 

Radiation and Public Health Project (RPHP).

One of the most shocking statistics shows that cancer death rates of young people (up to 

age 24) living in Monroe County exceeded the U.S. national rate by 28% from 1985 to 2008, a 

large shift from 1979 to 1984, when the county rate was 24% below the national average. 

Cancer death rates for 25 to 44 year olds in Monroe County also jumped, from 22% below the 

U.S. national average to 4% above the national average. In 1985, Fermi 2 loaded fuel and 

began low power testing; full commercial operation began in January 1988.

There were nineteen (19) health indicators reviewed including infant mortalities, low birth 

weights and hospitalizations that showed increased incidence in Monroe County, compared to 

the U.S. national average. Ten (10) of these indicators were statistically significant, and four 

(4) others approached significance.

"These patterns in Monroe County raise serious questions about whether emissions from 

Fermi 2 harmed local residents," says Joseph Mangano. "Before any decision is made on the 

future of [nuclear power in Southeast Michigan,] unusual health patterns such as these must be 

studied thoroughly by federal and state health officials, and findings reported to the public," 

Mangano concluded.

Nuclear power plants emit numerous radioactive isotopes not only from accidents, but also as 

part of routine "normal" operations. In 2002, Fermi 2 was 10th highest in the U.S. for airborne 

emissions of Iodine-131 and 7th highest for Strontium-89. In 2007, Fermi 2 was 13th highest in 

emissions of Tritium. Fermi 2 experienced a serious accident Christmas Day 1993 that resulted 

in a discharge of two million gallons of slightly radioactive water into Lake Erie. The drinking 

water intakes for the City of Monroe and Frenchtown Township are located 1/4 mile downstream 

from the plant. Radioactive isotopes can bio-accumulate and bio-concentrate in the food chain 

much like DDT, PCB's and dioxins.

The Mangano Report was prepared for submission to the U.S. Nuclear Regulatory Commission 

(NRC) during the proposed Fermi 3 nuclear plant Draft Environmental Impact Statement (DEIS) 

public comment period. Mangano calls for more study before approval of a new Fermi 3 nuclear 

plant that is proposed adjacent to Fermi 2 and the closed Fermi 1. For these reasons, a 

growing Coalition of Fermi 3 Intervenors have called for Baseline Health Studies of Monroe 

County in order that elevated cancers from a proposed Fermi 3 could be measured.

The Mangano findings regarding Fermi 2 are consistent with studies from around the world, 

including:

A recent French study on childhood leukemia, posted at: 

http://www.beyondnuclear.org/home/2012/1 / 12/french-study-finds-childhood-leukemiadoubled-aroundnuclear.html
Appendix A

A-22

And the 2008 German study on childhood leukemia, posted at: 

http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2696975/?tool=pubmed

Both of these studies report elevated incidence of cancers associated with proximity to nuclear 

power plants.

Additionally, ATHF3 demands an SEIS analysis of the significant public health impacts of 

predictable accidental radioactive releases which can be expected to occur periodically due to 

human error or mechanical failure for the entire duration of Fermi, Unit 2's licensed operations. 

As an example, at least one hundred gallons of radioactive floodwaters (contaminated 

wastewater) reached the Monroe County public sewer system in December 2010 when a 

wastewater holding tank valve malfunctioned at Fermi, Unit 2.

Comment 055-CC-1: First, for Ms. Perkins, overseeing the NEPA environmental review, I'd like 

to discuss the impact of authorized routine radioactive releases at Fermi 2. I'd like to submit 

new and significant information into the official record, a study by Joe Mongano, NPH, of the 

radiation and public health project who has refuted the clean power argument.

He has documented that from 1979 to 1988, before Fermi 2 began operating, the cancer death 

rate among Monroe County residents under age 21 was 20 percent below the US average. 

However, from 1989 to 2005, after Fermi 2 became fully operational, the cancer death rate for a 

similar population rose to 45 percent above the US average. From 20 percent below to 

45 percent above the US average, so nuclear is not clean and that should be in the public 

record.

Response: These comments address a report that claims to show increases in cancer and 

mortalities in Monroe County attributable to the operation of Fermi 2. The NRC’s mission is to 

protect the public health and safety and the environment from the effects of radiation from 

nuclear reactors, materials, and waste facilities. The NRC’s regulatory limits in 10 CFR Part 20 

for radiological protection are set to protect workers and the public from the harmful health 

effects (i.e., cancer and other biological impacts) of radiation on humans. The dose limits are 

based on the recommendations of standards-setting organizations that reflect extensive 

scientific study by national and international organizations. The NRC actively participates in, 

and monitors the work of, these organizations to keep current on the latest trends in radiation 

protection.

The NRC staff evaluated the information contained in the report 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” (RPHP report) (Mangano 2012). 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 does 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 DSEIS. Based on its review, the NRC 

staff concluded that the dose to members of the public were within the NRC’s dose limits in 

10 CFR Part 20.
Appendix A

A-23

In addition, the NRC staff evaluated data from Fermi 2’s REMP in Section 3.1.4 of this DSEIS. 

The REMP monitors the local environment around the Fermi site, starting before the plant 

operates to establish background radiation levels and continues 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 the Fermi 2 plant. 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 discussed in Section 3.1.4 of this DSEIS. Therefore, as discussed in 

Section 4.11.1 of this DSEIS, the radiological impact to human health (i.e., radiation exposures 

to the public) remains a Category 1 issue with a SMALL impact.

Comment 038-AA-1: Because of the long time line of proposed operation until 2045 and the 

prospect of an additional 60 years allowed for decommissioning, much care must be taken to 

determine the environmental impacts for at least 90 years from now (until 2105 and possibly 

beyond).

As a result multiple scenarios must be considered;

1. Health and ecosystem impacts on the Monroe and Frenchtown Township drinking water from 

radioactive releases of normal operations, refurbishment and transport of large components.

Response: 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 DSEIS. Based on its 

review, the NRC staff concluded that the dose to members of the public were 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 DSEIS. 

The REMP monitors the local environment around the Fermi site, starting before the plant 

operates to establish background radiation levels and continues 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 the Fermi 2 plant. 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.

A.1.8 Postulated Accidents, including SAMA (PA)

Comment 028-K-1: The Applicant’s Fermi 2 Environmental Report fails to accurately and 

thoroughly conduct Severe Accident Mitigation Alternatives (SAMA) analysis to the 
Appendix A

A-24

long-recognized and unaddressed design vulnerability of the General Electric Mark I Boiling 

Water Reactor pressure suppression containment system and the environmental consequences 

of a to-be-anticipated severe accident post-Fukushima Daiichi.

Comment 003-O-3: Another contention concerns the General Electric Mark I Boiling Water 

Reactor, and its containment's, long known, fatal design flaws. Fermi 2 is largest GE Mark I 

BWR in the world, almost as big as the melted down Fukushima Daiichi Units 1 and 2 reactor

cores put together.

Comment 055-CC-3: Today I contend that the applicant's Fermi 2 environmental report is 

inadequate because it fails to accurately and thoroughly provide a severe accident mitigation

alternatives analysis, a SAMA analysis that addresses the well-known and unresolved design 

vulnerability of the GE Mark One boiling water reactor pressure suppression containment 

system and severe accident consequences.

Response: In general, the probabilistic risk assessment (PRA) is an analytical tool used to 

identify accident scenarios, estimate the likelihood of each accident scenario, and estimate the 

consequences of each accident scenario. Fermi plant-specific PRAs were used to develop the 

Fermi SAMA analysis. The SAMA analysis was submitted as part of the LRA and was 

evaluated by the NRC staff. Section 4.11.1.2 and Appendix F of the DSEIS contain the NRC 

staff’s evaluation.. 

The Fermi Level 2 PRA specifically simulates severe accident progression and containment 

challenges for a number of sequences that represent significant core damage scenarios and 

was used in the Fermi SAMA analysis to identify SAMAs. The analysis specifically addressed 

accident scenarios resulting in containment failures similar to those experienced at the 

Fukushima Dai-ichi plant and measures to mitigate or prevent those accidents. Specific design 

vulnerabilities of the General Electric Mark I Boiling Water Reactor pressure suppression 

containment system are being evaluated in the current term as part of the NRC’s Fukushima 

lessons learned process. The Commission has ordered changes to the GE Mark I and II plants 

to address containment performance during design based accidents and severe accidents. 

Additional information regarding the NRC’s actions to enhance the safety of reactors in the 

United States based on lessons learned from this accident may be found at 

http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html. 

While SAMA is a category 2 issue for Fermi 2, this comment is actually a challenge to the 

adequacy of the plant’s current licensing basis. The proper forum to raise safety concerns 

challenging the adequacy of the plant’s current licensing basis is through a petition under 

10 CFR 2.206 for NRC action on the current license.

Comment 028-K-4: Fermi 2 and Fermi 3's safety and environmental risks due to common 

mode failures, and the potential for mutually initiating/exacerbating radiological catastrophes, 

involving the common Transmission Corridor (TC) shared by both units' reactors and pools, 

have been inadequately addressed in DTE's Fermi 2 License Renewal Application (LRA) and 

Environmental Report (ER). Also, the cumulative impacts associated with the proposed new 

Fermi 3 reactor cannot be excluded from DTE's Fermi 2 LRA and ER as "remote" or 

"speculative," for it is DTE's own proposal, and is advanced in the Fermi 3 COLA proceeding. 

Such environmental and safety analysis is required on this unique local problem specific to 

Fermi 2 and 3. It can, and must, be dealt with in Severe Accident Mitigation Alternatives 

(SAMA) analyses, and must be treated as Category 2 Issues in the NRC's forthcoming Draft 

Supplemental Environmental Impact Statement (DSEIS), as required by NEPA and the AEA.
Appendix A

A-25

Comment 003-O-4: The final contention is about the interconnected risks between the 

age-degraded Fermi 2, and the untested, proposed new Fermi 3 atomic reactor, including the 

vulnerability of both sharing a common off-site electricity transmission corridor.

Response: These comments assert that the common TC which would be shared by both Fermi 

2 and 3 has been inadequately addressed in DTE’s Fermi 2 LRA and ER. These comments 

also assert that the cumulative impacts associated with the proposed new Fermi 3 reactor

cannot be excluded from DTE’s Fermi 2 LRA and ER. 

Fermi 2’s or Fermi 3’s compliance with requirements related to offsite power or availability of 

diesel generators, which is embedded in the commenter’s assumption that loss of the TC is a 

loss of defense-in-depth, is a current licensing basis issue that is being addressed now and is 

not unique to license renewal. Therefore, these assertions are outside the scope of license 

renewal. 

The comments appear to assert that Fermi 3 must be considered in Fermi 2’s site-specific 

SAMA analysis or else the SAMA analysis for Fermi 2’s license renewal proceeding is 

inadequate. The Commission’s rules regarding SAMA analysis are not so prescriptive as to 

require consideration of any particular method or set of events. 

Comment 028-K-12: Contention 8 is regarding Severe Accident Mitigation Alternatives (SAMA) 

analysis: Pertaining to critical input data, as follows: The Applicant's Fermi, Unit 2 LRA 

Environmental Report (ER) and SAMA analysis are materially deficient in that the input data 

concerning evacuation time estimates (ETE) and economic consequences are incorrect, 

resulting in incorrect conclusions about the costs versus benefits of possible mitigation

alternatives, such that further analysis is called for under NEPA. 

Basis: 

The first issue to address is Meteorology: The Fermi, Unit 3 COLA (Part 5, Appendix 4 

"Emergency Plan: Radiological Monitoring and Assessment," Feb. 2014) incorporates the 

Raddose-V software program to 'provide real-time (as the release is occurring), site specific 

predictions of atmospheric transport and diffusion . . . determined using a variable trajectory 

plume simulation model, along with real-time or simulated scenario meteorological data .... 

Raddose-V is currently in-use at the Fermi site [that is, Fermi, Unit 2].” (Emphasis added). The 

Petitioner agrees that the "variable trajectory" plume distribution model is more realistic and 

appropriate for the Fermi site than a "straight-line Gaussian" model would be, due to the Fermi 

site's lakeshore and riverside location (see, for example, Dr. Bruce Egan's testimony in support 

of the New York Attorney General's Intervention against the Indian Point LRA); however, the 

Petitioner contends that, for the same reason, the Fermi site's location necessitates a wider 

(larger) Emergency Planning Zone (EPZ) than is currently proposed by the Applicant and 

endorsed by the NRC. A "variable trajectory" model recognizes the uncertainties of predicting 

plume behavior, especially near bodies of water, and the Fermi site is also located near many 

major metropolitan urban communities. In other words, a "variable trajectory" model and a 

larger EPZ go hand-in-hand. Thus, while the Applicant's SAMA analysis assumes a 10-mile 

EPZ probabilistic model, the Petitioner contends that a 50-mile EPZ would be a more realistic 

and appropriate starting point for Fermi, Unit 2's location and would, importantly, yield different 

results. In fact, the Petitioner asserts that the Applicant's arbitrary and unrealistic EPZ 

probabilistic modeling served conveniently for underestimating and minimizing projected 

consequences of a Severe Accident.

Comment 025-V-9: Meteorology: The Fermi, Unit 3 COLA (Part 5, Appendix 4 "Emergency 

Plan: Radiological Monitoring and Assessment," Feb. 2014) incorporates the Raddose-V 

software program to "provide real-time (as the release is occurring), site specific predictions of 
Appendix A

A-26

atmospheric transport and diffusion... determined using a variable trajectory, plume simulation 

model, along with real-time or simulated scenario meteorological data.... Raddose-V is currently 

in-use at the Fermi site [that is, Fermi, Unit 2].” (Emphasis added). ATHF3 agrees that the 

"variable trajectory" plume distribution model is more realistic and appropriate for the Fermi site 

than a "straight-line Gaussian" model would be, due to the Fermi site's lakeshore and riverside 

location (see, for example, Dr. Bruce Egan's testimony in support of the New York Attorney 

General's Intervention against the Indian Point LRA); however, ATHF3 contends that, for the 

same reason, the Fermi site's location necessitates a wider (larger) Emergency Planning Zone 

(EPZ) than is currently proposed by the Applicant/Licensee (DTE) and endorsed by the NRC. A 

"variable trajectory" model recognizes the uncertainties of predicting plume behavior, especially 

near bodies of water, and the Fermi site is also located near many major metropolitan urban 

communities. In other words, a "variable trajectory" model and a larger EPZ go hand-in-hand. 

Thus, while DTE's SAMA analysis assumes a 10-mile EPZ probabilistic model, ATHF3 contends 

that a 50-mile EPZ would be a more realistic and appropriate starting point for Fermi, Unit 2's 

location and would, importantly, yield different results. In fact, ATHF3 asserts that DTE's 

arbitrary and unrealistic EPZ probabilistic modeling served conveniently for underestimating and 

minimizing projected consequences of a Severe Accident. Therefore, further analysis is called 

for, under NEPA. 

Evacuation Time Estimates (ETE): DTE's evacuation time estimates are unrealistically low 

because the estimates rely on (1) an arbitrary and scientifically inappropriate probabilistic model 

for the Fermi site --- a 10-mile EPZ and minimal "shadow evacuation zone" and (2) the incorrect 

and unwise assumption that not everyone within ten miles of the Fermi site would have to 

evacuate, rather only those in the peak radiation plume. DTE minimized "shadow evacuation" 

of those outside the 10-mile EPZ, and DTE's ETE input parameters failed to consider instances 

of serious road construction delays, severe Michigan snow conditions (beyond 20% 

impairment), and other pertinent factors including questionable local preparedness response 

capabilities required by 10 CFR 50.47(b)(1). Even after the Fukushima Dai-ichi disaster proved 

that the EPZ should be significantly expanded, DTE's analysis relies on the inappropriate, 

absurd and discredited 10-mile EPZ --- see Endnotes. Ironically: (a) the NRC's inconsistent 

guidelines (Dec. 2013) require Emergency Planning within fifty (50) miles of each plant for 

preventing the ingestion of releases, "such as through bans on contaminated food and water," 

according to the Congressional Research Service (Jan. 2014); and, (b) while the Raddose-V 

program is capable of calculating deposition at receptors in the 50-mile ingestion pathway, 

which appears to include, in the U.S., about 8 counties in Michigan and 8 counties in Ohio, 

DTE's Emergency Plan executes arrangements in support of emergency preparedness with 

only two county governments -- Monroe Co. and Wayne Co., Michigan. Thus, ATHF3 contends 

that the Applicant/Licensee's Emergency Plan is inadequate, and, therefore, further analysis is 

called for, under NEPA. 

Economic Consequences: DTE's cost calculations assume an arbitrary and scientifically 

inappropriate EPZ probabilistic model for the Fermi site and, as a result, that a radiological 

release will affect only a relatively small area. Proper inputs specific to the Fermi site indicate a 

far larger affected area ---- potentially including the densely populated centers of Metro Detroit 

(MI), Ann Arbor (MI), Monroe (MI), Toledo (OH) and Windsor (ON); such scenarios would result 

in longer evacuation times and greater costs and consequences. Radiation plume exposure 

from a prolonged or delayed evacuation and consequent projected health-related costs in the 

affected population would be greater if an appropriate probabilistic model and correct input 

parameters were used in DTE's ETE. ATHF3 contends that realistic and reasonably 

foreseeable scenarios were ignored or underestimated by the Applicant/Licensee's cost-benefit 

analysis. Importantly, a proper Severe Accident analysis significantly affects whether local 

communities will receive commensurate safety enhancements. Furthermore, ATHF3 contends 
Appendix A

A-27

that actual long-term recovery, remediation and redevelopment costs in a Severe Accident 

could be astronomical and that no reliable or credible cost analysis currently exists, given the 

uncertainties about long-term habitability criteria and cleanup standards. Therefore, ATHF3 

contends that the development of a long-term cleanup policy and strategy must be completed 

as a prerequisite for any further licensing or relicensing actions.

Endnotes:

(1) Elaborating on the inadequacy of the 10-mile Emergency Planning Zone (EPZ) as a 

probabilistic model or tool for properly estimating reasonably foreseeable costs and 

consequences of a Severe Accident, ATHF3 submits the following statement from 

the public record:

http://www.state.gov/p/eap/rls/rm/2011/03/158441.htm 

Statement by U.S. Ambassador John V. Roos on Japan’s Earthquake and Tsunamis

Remarks (excerpt) - Tokyo, Japan March 16, 2011

The United States Nuclear Regulatory Commission (NRC), the Department of 

Energy and other technical experts in the U.S. Government have reviewed the 

scientific and technical information they have collected from assets in country, as 

well as what the Government of Japan has disseminated, in response to the 

deteriorating situation at the Fukushima Nuclear Power Plant. Consistent with the 

NRC guidelines that apply to such a situation in the United States, we are 

recommending, as a precaution, that American citizens who live within 50 miles 

(80 kilometers) of the Fukushima Nuclear Power Plant evacuate the area or to take 

shelter indoors if safe evacuation is not practical.

We want to underscore that there are numerous factors in the aftermath of the 

earthquake and Tsunami, including weather, wind direction and speed, and the 

nature of the reactor problem that affect the risk of radioactive contamination within 

this 50 mile (80 km) radius or the possibility of lower-level radioactive materials 

reaching greater distances.

(2) ATHF3 contends that the Fermi site must have, at minimum, a readily-expandable 

50-mile-radius evacuation plan that can be implemented instantly and effectively in a 

severe accident that indiscriminately exposes the public to significant radioactive 

releases. Southeast Michigan needs a comprehensive regional evacuation plan with 

routes, destinations, immediate notification, long-term housing facilities and financial 

support for displaced and relocated families and individuals, competent medical care 

for victims of radiation exposure, full disclosure of real-time radioactive release 

measurements and plume tracking, and funding for adequate event response 

capabilities including assistance and preparation for evacuation of vulnerable 

populations such as indigent and limited-mobility individuals of all ages and for all 

reasons. The evacuation plan must be coordinated with the entire Great Lakes 

region, including Michigan, Ohio and Ontario, Canada. The plan must be a realistic, 

four-season strategy with contingencies for severe weather conditions and impaired 

visibility/driving conditions; the plan must have flexibility to accommodate and adapt 

to unexpected road construction delays or other foreseeable scenarios. It should not 

be assumed that the residents located within the perimeter "shadow evacuation 

zone" will react any differently from those in the central Emergency Planning Zone 

(EPZ). The regional emergency communications capabilities must be augmented. 

During and following an emergency event, there must be no suppression of public 

information and no transmission delay. To meet this standard, major infrastructural 
Appendix A

A-28

changes must be implemented immediately. The public does not accept effectively 

being told to shelter in place and suck it up.

(3) Evacuate Monroe County in two-lane traffic?

The Michigan Department of Transportation is considering whether the City of 

Monroe, MI (immediately near the Fermi site) can reconfigure S. Monroe Street 

(M-125) and reduce the traffic flow from five lanes to three. While this would add 

about 30 parking spots, it could create a serious problem if there were ever an 

emergency at Fermi. M-125 is an evacuation route for Fermi, as well as an alternate 

route should there be an accident on 1-75. More than 1,400 people have signed an 

on-line petition against this reconfiguration.

Comment 025-V-10: ATHF3 has a contrarian point of view on the basic validity of the MACCS 

and MACCS2 codes as a proper diagnostic tool to assess economic costs and consequences. 

ATHF3 refers to expert testimony supporting Pilgrim Watch's Petition to Intervene against the 

PNPS LRA: David Chanin, who coded the cost model of the MACCS and MACCS2, stated 

(Chanin Declaration for Pilgrim Watch, June 2007, ML071840568) that, "I have spent many 

many hours pondering how MACCS2 could be used to calculate economic costs and concluded 

it was impossible. and [sic] Speaking as the sole individual who was responsible for writing the 

FORTRAN in question, which was done many years prior to my original work in SAND 96-0957, 

I think it's foolish to think that any useful cost estimates can be obtained with the cost model 

built into MACCS2..The economic cost numbers produced by MACCS2 have absolutely no 

basis. If you want to discuss economic costs, I'd be glad to discuss SAND 96-0957, but the 

"cost model" of MACCS2 is not worth anyone's time."

For a cost analysis which supports ATHF3's argument, ATHF3 points to Sandia National 

Laboratory's CRAC-2 Report, "Calculation of Reactor Accident Consequences," (1982). The 

report stated that a core meltdown at Fermi, Unit 2 would have the following consequences: 

8,000 "Peak Early Fatalities," 340,000 "Peak Early Injuries," 13,000 "Peak Deaths from Cancer," 

and $136 billion in property damage costs. Note that these 1982 numbers are unadjusted for 

demographic and monetary inflation trends and do not account for the current or foreseeable 

amount of spent fuel stored onsite.

Comment 028-BB-3: Yes, indeed, we all love the tax revenue from Detroit Edison; we 

appreciate the jobs and the trickle down and so on, but in a heart beat, literally a heart beat, in a 

super prompt criticality of 1.6 seconds, that reactor can go through the roof, and that means that 

we will not be just evacuating, we will be permanently relocating, the size of the state of 

Pennsylvania.

In 1982, the Nuclear Regulatory Commission commissioned a study from Sandia Labs called 

the "CRAC-II.” This was the severe consequences of reactor accidents. At the Fermi 2, a 

reactor would be 136 billion dollars in property damage -- these are 1980 dollars -- 340,000 --

341,000 injuries; 13,000 deaths from cancer; 8,000 immediate deaths. Yes, we like the tax 

revenue, we like the jobs, but in a heart beat this reactor could be gone. And there has been no 

mitigation, Detroit Edison refuses to put in place hardened vent which would allow for the 

venting of the reactor if it over-pressurized.

Response: The information presented in these comments primarily discusses issues relating to 

emergency planning and cost calculations. The comments appear to assert that (1) Fermi’s 

10-mi (16-km) plume exposure EPZ is inadequate and (2) Fermi’s SAMA analysis is inadequate 

because of its evacuation modeling assumptions. Regarding the first item, emergency 

preparedness and evacuation planning are part of the current operating license and are outside 

the scope of the environmental analysis for license renewal. Emergency preparedness 
Appendix A

A-29

programs are required at all nuclear power plants and require specified levels of protection from 

each licensee regardless of plant design, construction, or license date. Requirements related to 

emergency planning are in 10 CFR 50.47 and Appendix E to 10 CFR Part 50. These 

requirements apply to all operating licenses and will continue to apply to facilities with renewed 

licenses. The NRC has regulations in place to ensure that existing emergency preparedness 

and evacuation plans are updated throughout the life of all plants. For example, nuclear power 

plant operators are required to update their ETEs after every U.S. Census or when changes in 

population would increase the estimate by either 25 percent or 30 minutes, whichever is less. 

Additionally, the NRC assesses the capabilities of the nuclear power plant operator to protect 

the public by requiring the performance of a full-scale exercise—that includes the participation 

of various Federal, state, local government agencies, and tribes—at least once every 2 years. 

These exercises are performed in order to maintain the skills of the emergency responders and 

to identify and correct weaknesses. Within the context of license renewal, the Commission 

considered the need for a review of emergency planning issues during the 1991 rulemaking 

proceedings on 10 CFR Part 54, which included public notice and comment. As discussed in 

the Statements of Consideration for the rulemaking (56 FR 64943, 64966–67;

December 13, 1991), the programs for emergency preparedness at nuclear power facilities 

apply to all nuclear power facility licensees and require the specified levels of protection from 

each licensee regardless of plant design, construction, or license date. As a result, the 

Commission determined that “[t]here is no need for a licensing review of emergency planning 

issues in the context of license renewal” (56 FR 64966–67). Therefore, issues related to 

emergency planning are outside the scope of the license renewal review.

Regarding the comments about evacuation modeling in Fermi’s SAMA probabilistic models, the 

NRC reviewed the evacuation assumptions and analysis and found them to be reasonable and 

acceptable for the purposes of the Fermi 2 SAMA analysis. Fermi’s evacuation modeling 

assumptions, as modeled in the MACCS2 computer code for offsite consequence analysis, are 

based on information from the Fermi Nuclear Power Plant Development of Evacuation Times 

Estimates (DTE 2014). This information includes time delays and travel speeds for a range of 

possible conditions. Fermi’s ETE report was prepared based on NRC guidance in NUREG/CR–

7002, Criteria for Development of Evacuation Time Estimate Studies (NRC 2011), and was 

reviewed for completeness. For the baseline Level 3 calculation found in Table D.1–24 of 

Attachment D to the ER (DTE 2014), DTE assumed 95 percent of the population within the EPZ

would evacuate. To account for population increases in the future, DTE lowered the assumed 

evacuation speed from the determined network-wide evacuation speed of 12.8 meters per 

second (m/s) (28.6 mph) to 10 m/s (22.4 mph). In response to an NRC staff request for addition 

information on the network-wide evacuation speed and total time for evacuation, DTE affirmed 

that the evacuation assessment considered site-specific conditions for Fermi 2 and described 

how spatial dependences of the highway network, as well as population density, were modeled 

(DTE 2015a). In a sensitivity analysis found in Table D.1–25 of Attachment D to the ER 

(DTE 2014), DTE reported an increase in the population dose risk by 1 percent due to an 

assumed factor-of-2 reduction in the average evacuation speed from 10 m/s (22.4 mph) to 5 m/s 

(11.2 mph). Sensitivity values for the evacuation fraction of 90 percent and 99.5 percent were 

found to have very small influences on the population dose risk (< 0.005 percent) (DTE 2014). 

As described by DTE, evacuation applies to the EPZ with a lower population compared to other 

areas surrounding the Fermi 2 site. The much larger population outside of the EPZ (about 

55 times larger) does not evacuate in the assessment and accounts for a majority of the total 

population dose. For these reasons, the total population dose is not directly proportional to the 

fraction of individuals in the EPZ who do not evacuate. Because DTE used site-specific 

information, applied more conservative (lower) fractions for the evacuating population in the 

EPZ compared to guidance values (NRC 1997), and considered the effect of population 
Appendix A

A-30

increases on evacuation parameter values, NRC staff concludes that the evacuation 

assumptions and analysis are reasonable and acceptable for the purposes of the SAMA 

analysis at Fermi 2.

The commenter also contends that there are no reliable or credible severe accident cost 

analyses that exist, implying that Fermi’s SAMA analysis is inadequate because of its analysis 

of economic consequence analysis. Fermi’s SAMA analysis uses the MACCS2 computer code 

for probabilistic offsite consequence analysis of a nuclear accident postulated to occur at some 

unknown time in the future. The MACCS2 code is the only system that models all the 

components of a nuclear accident offsite consequence analysis in a fully coupled fashion, 

including atmospheric transport and deposition, emergency phase and long-term phase 

protective actions, exposure pathways, dosimetry, health effects, and economic consequences. 

In addition, MACCS2 enables the use of site-specific population and economic data and allows 

sampling of site-specific weather data to account for weather uncertainty at the time of the 

postulated accident. MACCS2 is an NRC-approved code for use in offsite consequence 

analysis in a SAMA analysis. In addition, the parameter values used by the applicant in its 

MACCS2 analysis were reviewed by the NRC staff and are considered reasonable for the 

purpose of a SAMA analysis.

The CRAC-2 report referred to by the commenters is the “Calculation of Reactor Accident 

Consequences” which is a study performed by Sandia Labs in 1982 for the NRC. The report 

estimated the consequences of the worst case accidents at nuclear power plants in the United 

States. The NRC has devoted considerable research resources, both in the past and currently, 

to evaluating accidents and the possible public consequences of severe reactor accidents. The 

NRC’s most recent studies have confirmed that early research into the topic led to extremely 

conservative consequence analyses that are not useful for attempting to quantify the possible 

effects of very unlikely severe accidents. They often used unnecessarily conservative estimates 

or assumptions concerning possible damage to the reactor core, the possible radioactive 

contamination that could be released, and possible failures of the reactor vessel and 

containment buildings. These previous studies also failed to realistically model the effect of 

emergency preparedness. The NRC performed a state-of-the-art assessment of possible 

severe accidents as part of its ongoing effort to evaluate the consequences of such accidents. 

The State-of-the-Art Reactor Consequence Analyses (SOARCA) project incorporates the results 

of more than 25 years of research to analyze the realistic outcomes of postulated severe reactor 

accidents, even though it is considered highly unlikely that such accidents could occur. The 

SOARCA project combined up-to-date information about the pilot plants’ layout and operations 

with local population and weather data and emergency preparedness plans. Plant changes that 

were accounted for included system improvements, training, emergency procedures, and offsite 

emergency response, as well as mitigation enhancements in response to the terrorist attacks of 

September 11, 2001. The SOARCA project is documented in NUREG–1935, State-of-the-Art 

Reactor Consequence Analyses Report (NRC 2012b), and in a public communications 

brochure, NUREG/BR–0359, Modeling Potential Reactor Accident Consequences

(NRC 2012c). These reports can be accessed at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1935/ and http://www.nrc.gov/reading-rm/doccollections/nuregs/brochures/br0359/, respectively. In light of these more recent and more 

realistic analyses, these comments do not provide any new and significant information; 

therefore, no changes were made to the DSEIS.

Comment 025-V-4: B) That higher power output levels at Fermi, Unit 2 increase the risk of 

core melt through because of reactor penetrations placed on the bottom of the reactor in the 

BWR design.
Appendix A

A-31

Comment 022-BB-3: And we've also come to realize that you don't need an earthquake or a 

tsunami to produce a condition on plant property known as "station blackout," where you have a 

failure of the primary electrical power and -- and a subsequent -- and a concurrent failure of 

backup electrical power.

Comment 026-CC-3: The fear being that as plants went up in flames, they would have to be 

abandoned and all control would be lost. And I put forth that Fermi 2, the old reactor with the 

breakdown phase risks, Fermi 3, the new reactor with the break-in phase risks, these are the 

worst of both worlds on the same site. A multiple reactor accident scenario.

Response: These comments are concerned with different types of accidents that could occur 

at Fermi 2. As discussed in Section 4.11.1.2 of this DSEIS, at the time of initial licensing, an 

applicant must demonstrate that the plant can withstand normal and abnormal transients and a 

broad range of postulated accidents without undue hazard to the health and safety of the public. 

A number of the postulated accidents are not expected to occur during the life of the plant but 

are evaluated to establish the design basis for the preventative and mitigative safety systems of 

the plant. 

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.

A.1.9 Waste Management (RW)

Comment: 025-V-15: Severe Accident Analysis of Fermi, Unit 2's Spent Fuel Pool:

ATHF3 hereby appeals to the U.S. NRC for reconsideration of a misguided ASLB ruling which is 

described below and which pertains directly and materially to the Scope of this relicensing 

action, including the Fermi, Unit 2 LRA Environmental Review and SEIS.

Submitted for Reference: 

--- The Petitions, Contentions and legal filings pertaining to a Petition to Intervene (Contentions 

1 - 5) and subsequent adjudication, in the Matter of the Pilgrim Nuclear Power Station (PNPS) 

License Renewal Application (2006 - ) -- Docket No. 05000293 (including Pilgrim Watch's 

Motion to Intervene, Contention 4, May 2006 - ADAMS Accession Number ML061630125). 

Petitioners included Pilgrim Watch (http://www.pilgrimwatch.org) and the Commonwealth of 

Massachusetts Office of Attorney General.

Basis: 

The ASLB and the NRC Staff have failed to apply their own rules and regulations pertaining to 

Severe Accidents involving spent fuel pools, which are vulnerable structures integral to a 

facility's normal operation. Consistently and incorrectly, the NRC has argued that all spent fuel 

issues are Category 1 and, therefore, "off the table" for practical purposes, having been 

generically resolved for all plants and not subject to further analysis in any relicensing 

proceeding. However, the NRC Rules say otherwise. The NRC applies the wrong section of 

the Rules and consequently misinterprets the whole regulation. The correct and appropriate 

interpretation of 10 CFR 51.53 is found in Section 5, not Section 6, in NUREG–1437 (GEIS). 

Section 6 of the GEIS specifically deals with "The Uranium Fuel Cycle and Solid Waste 

Management" under normal operations; Section 5 deals with "Environmental Impacts of 

Postulated Accidents," including Category 1 generic "Design-Basis Accidents" and Category 2 

site-specific "Severe Accidents.” Section 5 includes definitions of "severe" and "accident" and 

does not limit these to reactor core accidents. Section 5 focuses on potential consequences to 

determine whether or not a potential accident is severe ---- and, thus, under Section 5, spent 
Appendix A

A-32

fuel pool fires are a Category 2 issue, within the Scope of a site-specific Severe Accident 

Mitigation Alternatives (SAMA) analysis and, therefore, are a fundamental part of an Applicant's 

Environmental Report (ER) and subject to NEPA SEIS review and remedy. In other words, it is 

the consequences of an accident, not the source or cause, which determines whether such 

accident is properly categorized as “Severe.”

Of course, spent fuel pools typically contain a large inventory of high-level radioactive waste 

(HLRW) with an inherent and undisputed potential for catastrophic consequences in the context 

of an accident; ironically, a spent fuel pool event could conceivably cause a reactor core 

accident, thereby greatly magnifying cumulative consequences. Thus, the idea that a spent fuel 

pool is somehow outside the realm and scope of a SAMA analysis or SEIS and that even if 

mitigation alternatives are readily available and cost-effective (which they are) the plant 

nevertheless need not consider them, is ridiculous and absurd.

As a consequence of several re-racks implemented as part of an extremely misguided, 

NRC-endorsed policy, the Fermi, Unit 2 spent fuel pool currently stores approximately twice the 

amount of spent fuel as it was originally designed to hold (4600 vs. 2300 design), resulting in a 

precariously vulnerable condition which must be actively managed at all times. Indeed, Fermi, 

Unit 2 has the largest spent fuel pool capacity of any operating boiling water reactor in the 

country -- hence, the potentially greater magnitude of consequences of severe leaks, fires, or 

other structural breaches of the pool. Adding to the danger is the fact that the GE Mark 1 BWR 

design locates the spent fuel pool on the 5th floor, in an elevated, structurally vulnerable 

position. It is reasonable to estimate that, during the 20-year License Renewal period, Fermi, 

Unit 2 would generate an amount of spent fuel from normal operations equal to about 

fifty percent (50%) of that which it produced during the original 40-year Operating License 

period. At the same time, the current "structured coordination" between the Nuclear Energy 

Institute (NEI) and the NRC appears to be heading towards potentially indefinite "continued 

storage" of spent fuel with no technical specifications in place, now or for the foreseeable future.

Given that the Applicant/Licensee is charged with the primary responsibility for safely and 

securely handling its own high-level radioactive waste (HLRW) generated during the licensed 

life of the reactor, ATHF3 contends that there is a "gap of accountability" in DTE's plan as it is 

currently written in the Fermi, Unit 2 LRA and associated documents. The NRC's SEIS must 

finally address the unaddressed issue of financial accountability to the public taxpayers and 

utility ratepayers, who deserve a seat at the table on the issue of whether to assume new, 

additional, and uncertain future long-term liabilities implicit in the LRA.

Under 10 CFR 2.309, a Petitioner is required to show that the issue raised in a Contention is 

within the Scope of the proceeding. Contentions that seek compliance with NEPA must be 

based on the Applicant's Environmental Report (ER). (10 CFR 2.309(f)(2)). Under 

10 CFR part 51 (c)(3)(ii), the Applicant is required to provide an ER that contains analyses of

the environmental impacts of the proposed action associated with license renewal and the 

impacts of operation during the renewal term for those issues identified as Category 2 issues. 

"Severe Accidents" are listed as a Category 2 issue in the applicable section on "Postulated 

Accidents.” Contentions implicating Category 2 issues ordinarily are deemed to be within the 

Scope of License Renewal proceedings. See Turkey Point, supra at 11-13.

In conclusion, ATHF3 contends that DTE's Fermi, Unit 2 LRA Environmental Report (ER) utterly 

fails to address Severe Accident Mitigation Alternatives which could substantially reduce the 

risks and consequences associated with onsite storage of high level radioactive waste (HLRW), 

especially, spent fuel pool water loss and fires. Likewise, the NRC's site-specific SEIS must 

address, within the scope of review, the significant environmental and public health 
Appendix A

A-33

consequences of a Severe Accident involving Fermi, Unit 2's spent fuel pool and include an 

analysis and discussion of mitigating and fundamental alternatives. 

Comment 035-J-6: Withdrawn Nuclear Reactor Fuel Rods

“Spent” fuel is highly flammable as well as radioactive, yet is primarily stored in densely packed 

pools of water that contain several times more fuel than the nuclear reactor itself. If a fuel pool 

is damaged or loses its cooling system, fuel rods could be exposed, overheat, and catch fire, 

releasing massive quantities of radioactive material. NRC refuses to address the incredible 

risks these facilities pose, pretending the low likelihood of an accident makes the extreme 

consequences irrelevant. Hardened On-Site Storage systems (HOSS) should be used to store 

spent fuel more safely and securely at or near nuclear plants. HOSS reduces the immediate 

dangers spent fuel poses, without creating unnecessary risks. 

75% of the total (72,000 metric tons, plus 2,000 tons more per year) of spent fuel is in fuel pools 

and allowed to remain there for as much as 60 years beyond licensed life of reactor operations. 

The Generic Environmental Impact Statement (GEIS) on Waste Confidence, NUREG–2157 

underestimates the risk of fuel pool fires and ignores the safer alternative of hardened on site 

storage at the nuclear plant sites. Dry cast storage at Dai-ichi survived the number 9 earth 

quake, tsunami, loss of the electrical grid, and loss of back up diesel generators much better 

than the reactors themselves and their fuel pools.

There is a consensus among the U.S. government and the nuclear industry for more than 

60 years that withdrawn spent fuel rods are lethal in minutes unless shielded. To continue to 

produce them and intend to abandon them into the biosphere (deep underground dump) is 

profoundly immoral and a burden and a curse on future generations into eternity. It is 

premeditated murder.

There is no basis in science, engineering, the behavior of the nuclear industry and the Nuclear

Regulatory Commission (NRC) for confidence that high level radioactive withdrawn fuel rods 

(“spent fuel”) can or will be managed with no risk to the biosphere for as long as the radioactivity 

last. For the NRC and the nuclear industry to assert probabilistic assessments of what will 

happen to radioactive material over 240,000 (plutonium) to a billion years for some 

radionuclides, is a fraud and a con game. There is insufficient data for such probabilistic 

assessments to have validity. Apart from that, even a small likelihood of the risk of a serious 

untoward event involving spent fuel could be catastrophic for all life forms, air, water and land. 

Nuclear accidents cannot be undone.

NRC's Waste Confidence policy assumes that all nuclear spent fuel is the same. This is far 

from the truth. The industry is moving toward new fuel types, such as MOX (mixed oxide) and 

high-burnup fuels, which are more radioactive, dangerous, thermally hot and difficult to store 

and transport safely.

Fermi 2 has an over crowded fuel pool with 600 tons of spent fuel. It is the largest GE Mark 1 

reactor. It is at risk for weather events, loss of coolant, or terrorist attack. Like Dai-ichi reactors 

and all 23 GE Mark 1 reactors in the U.S., it's cooling pool does not have back up cooling. It 

has no diesel generators for cooling pool water circulation to rely on in loss of electrical grid 

emergency. There are 1,331 highly radioactive irradiated spent nuclear fuel assemblies in 

Fukushima Dai-ichi Unit 4's storage pool. Fermi 2's high-level radioactive waste storage pool 

contained 2,898 irradiated nuclear fuel assemblies by spring 2010, according to 

U.S. Department of Energy projections documented in the Yucca Mountain Final Environmental 

Impact Statement (Feb. 2002, Table A–7, Proposed Action spent nuclear fuel inventory). 

Fermi 2 could generate another 443 irradiated nuclear fuel assemblies between spring 2010 

and spring 2014, meaning by then, a total of 2,898 + 443 = 3,341 irradiated nuclear fuel 
Appendix A

A-34

assemblies. So, Fermi 2's storage pool would hold 2.5 times as much high-level radioactive 

withdrawn fuel rods than Fukushima Dai-ichi Unit 4's pool! A cooling pool fire at Fermi 2 would 

be worse than a meltdown of the Fermi 2 reactor itself in its release of a larger dose of radiation 

into the environment, resulting in widespread illness, deaths, and genetic mutations. If the 

radioactivity releases from either location (the reactor, or the irradiated nuclear fuel storage 

pool) are bad enough, the entire site might have to be evacuated. No intervention would then 

be possible. Not only could reactor meltdowns proceed out of control, but high-level radioactive 

spent fuel storage pool fires could result -- emitting orders of magnitude more hazardous 

radioactivity into the environment than even a reactor meltdown, as the pools are not contained 

within a radiological containment structure. Fermi 2 is lacking hundreds of structural welds on 

various floors of the reactor building, never put in place like they were supposed to have been 

some 40 years ago. This has meant that it could not safely withstand the weight of the crane 

and cask necessary to move the sufficiently cooled spent fuel to Hardened Onsite Storage 

(HOSS).

Comment 028-K-2: The Environmental Report for Fermi 2 does not satisfy the National 

Environmental Policy Act (“NEPA”) or 10 C.F.R. § 51.45(c) because it does not consider a 

range of mitigation measures to mitigate the risk of catastrophic fires in the densely packed, 

closed-frame spent fuel storage pools at Fermi 2.

Comment 028-K-3: The Environmental Report for Fermi 2 does not satisfy the Atomic Energy 

Act or NEPA because (1) it does not make any site-specific safety and environmental findings 

regarding the storage and ultimate disposal of the spent fuel that will be generated during the 

license renewal term and (2) the NRC has no valid generic findings on which the Environmental 

Report could rely.

Comment 003-O-1: The first is about the risk of catastrophic irradiated nuclear fuel storage 

pool fires. Fermi 2's storage pool holds around 600 tons of irradiated nuclear fuel, more than all 

four destroyed units at Fukushima Daiichi put together (419 tons).

Comment 003-O-2: The second radioactive waste contention is about the lack of safety and 

environmental assurances, since the U.S. Nuclear Regulatory Commission's (NRC) "Nuclear 

Waste Confidence" policy was declared null and void two years ago by the D.C. Circuit Court of 

Appeals, and NRC has not yet replaced it.

Comment 038-AA-2: Because of the long time line of proposed operation until 2045 and the 

prospect of an additional 60 years allowed for decommissioning, much care must be taken to 

determine the environmental impacts for at least 90 years from now (until 2105 and possibly 

beyond).

As a result multiple scenarios must be considered; [...]

(2) Assuming that the recent NRC plan to allow storage of rods in on site pools with 

stands court challenges, what effect does this present for the 600 tons already stored 

since the reactor started operation in 1988. 600 tons is beyond the design capacity 

now, so if DTE is unable to transfer them to outside dry casks, what plan and 

impacts are there for continued production of this high level waste. It is our 

understanding that DTE's plan to transfer the high level waste to dry casks is 

impaired because of defective welds.

Comment 038-AA-3: Because of the long time line of proposed operation until 2045 and the 

prospect of an additional 60 years allowed for decommissioning, much care must be taken to 

determine the environmental impacts for at least 90 years from now (until 2105 and possibly 

beyond).
Appendix A

A-35

As a result multiple scenarios must be considered; [...]

(3) If no final disposal site is developed or the disposal is projected for far into the future 

and DTE needs to transfer the waste to outside casks, detailed analysis must be 

performed.

Comment 038-AA-4: Because of the long time line of proposed operation until 2045 and the 

prospect of an additional 60 years allowed for decommissioning, much care must be taken to 

determine the environmental impacts for at least 90 years from now (until 2105 and possibly 

beyond).

As a result multiple scenarios must be considered; [...]

(4) The impact of storage and transport of low level and intermediate level radioactive 

waste must also be considered.

Comment 025-BB-2: As it stands right now, there's some 700-plus tons of eradiated spent 

fuel, a much more dangerous substance than when it first went in. When it comes out, it is a 

material that is just deadly and the -- the dangers associated with this cannot be, you know, 

underestimated over -- anyway, you get my point.

So, and my understanding is that the welds that are in place up there, on top of the reactor and 

the pools that contain this spent fuel, those welds are not -- don't have enough integrity, that 

allow removal of the spent fuel. Even if -- even if DTE was willing to commit to a dry cask 

storage on site there, it's my understanding that they can't even get the material safely down, 

out of the existing pools, so it's just -- you know, so to continue to extend the license, continue 

to pile up material that has no place to go, is not logical, it's not rational; it's extremely 

dangerous.

Comment 028-BB-4: Meanwhile, the product out there that they are really producing, that lasts 

forever, is high-level nuclear waste. If you refine it a bit, you could turn it into a nuclear weapon. 

This is the most volatile material in the world and yet this is what they produce and this is what 

they don't know what to do with to this day. They have been authorized since 2010 to remove 

that fuel from the fuel pool, they have not been able to do so. Because when they looked at the 

blueprints, they found that we're missing welds on the fifth floor, 768 missing welds on -- on the 

fifth floor. The crane would not support the load to break it down 100 feet, five floors; they still 

don't know what to do with it, but yet they'll make more. They'll make promises: we'll figure it 

out later. We'll adhere to a human and senseless paradigm, that we are so smart today in this 

room that: well, we don't know what to do just yet, but we'll figure it out later.

Comment 026-BB-2: So, you know, you draw a line around Fermi 2. Fermi 2 is identically 

designed, only it's as big as Fukushima Daiichi Units 1 and 2 put together and scaled up. And 

the issue has been mentioned of the radioactive waste. The radioactive waste risks here are 

actually much greater than at Fukushima Daiichi and if the official version of things is true at 

Fukushima Daiichi, we very narrowly avoided a pool fire there. I mean, you may remember 

St. Patrick's Day of 2011, the desperate attempts to drop water into Unit 4 by helicopter, very 

reminiscent of scenes from Chernobyl. And the official version is: Oh, that wasn't necessary. It 

turns out there was water in the pool the whole time.

Obviously, there was a lot of concern that that was not the case, and so much so that once you 

lose the water, you can't send people in, because they'll get a fatal dose of radioactivity from the 

uncovered waste within a very short period of time.

So, here at Fermi, as was mentioned earlier by Carol Izant, there is well over 600 tons of 

high-level radioactive waste perched at the top of Fermi 2. They've had a permit to bring it 

down for several years, but they can't because of structural deficiencies in the reactor building. 
Appendix A

A-36

And even when they bring it down, it's planned to be put into whole tech (ph) casks and an 

industry whistleblower named Oscar Suranyi from Hominoff (ph) Edison, an NRC whistleblower, 

Dr. Ross Landsman from Region 3, questioned the structural integrity of the whole tech casks 

sitting still, on-site storage, because of major quality assurance violations in their design and 

manufacture, let alone moving down the railroads at 60 miles per hour, which is the plan at 

some point.

So, as was mentioned earlier by Michael Keegan, radioactive waste -- you know, we may enjoy 

the benefits of the electricity and the money that's flowing in the present -- radioactive waste is a 

curse on all future generations; they're going to get to deal with this. We're 70 years into this, 

we have a mountain of radioactive waste 70 year high, and we don't know what to do with the 

first cupful that was generated by Enrico Fermi on December 2nd, 1942, as a part of the 

Manhattan Project.

Comment 026-CC-4: And my concluding thoughts will be about nuclear waste. The nuclear 

waste confidence report that came out today we look forward to reading and we will be ready to 

go back to court, if need be. Our coalition of environmental groups and states, including the 

states of New York and Vermont, are very interested in what the NRC has to say at this point 

about nuclear waste confidence, about expedited transfer of a radiated nuclear fuel from pools 

to dry casts.

We call for hardened on-site storage. The NRC staff's study of this issue revealed that a - - 

even a small pool fire could render 9,400 square miles uninhabitable resulting in 4.1 million 

nuclear evacuees. We -- we put forth a petition for rule making earlier this year calling for this 

license extension proceeding, its rules, to be revised in light of this new information and we 

called for a stay on this proceeding, but were denied just last week by the Nuclear Regulatory 

Commission.

Comment 013-CC-1: I'm coming also to speak on behalf of myself, but also mother earth 

because if we ruin the mother, we won't -- we will be homeless and soon gone the way of the 

dinosaurs, a failed experiment, which leads to my complaint that's been the same ever since 

Davis-Besse and Fermi 2 were built. What are you going to do with the waste?

We're almost through a license period and we still don't have that answer. We were all told that 

they'll build a place for it. Of course, we weren't in that mentality of not in my backyard. It 

wasn't going to stay here, but it sure looks like it's going to stay here, and until we know what 

we're doing, you know, we're sitting right on Lake Erie. The chance -- if we have an accident, 

what happens?

I'm sure you're all knowledgeable people with credentials and quite bright, but I have to question 

even more then: what are you thinking? Is this the legacy you want to leave for your kids and 

your grandkids, truly?

I guess my final word is if you don't know what you're going to do with it, don't make more. 

Thank you.

Comment 019-CC-1: In regards to waste storage in Yucca Mountain, we've got to realize that 

not only are we dealing with spent fuel rods, but you all have to understand the reactor cores 

themselves become high level radioactive waste. No -- I don't hear anybody talking about this. 

Nobody has an answer for this.

These reactors are not going to end up at Yucca Mountain and, you know, for an example of a 

decommissioning of a plant, the shipping port reactor, the first commercial reactor in America, a 

tiny reactor -- I think it was 60, 61 megawatts -- was hauled to the state of Washington for burial. 

Now you're not going to do that with a Fermi 2 reactor, 1,140 megawatts, whatever.
Appendix A

A-37

My understanding is the building – when decommissioning comes -- rolls around, the reactor

building will have to be flooded and the reactor core will have to be cut up with torches 

underwater and then we still know -- you know, nobody knows what's going to happen.

So Yucca Mountain is not a solution either and actually if -- even if Yucca Mountain were in 

operation, let's say we're going to haul some fuel rods out to Nevada. I can imagine sitting in a 

construction zone on I-75 next to a semi carrying a - - a bunch of casts. I guarantee you're 

going to get a whole lot more than a dental x-ray.

Comment 025-CC-6: You -- you again, it's just -- it's wild, you know, when you think about the 

fact that there's 600-plus tons sitting up in those pools and not a – not a single ounce of it has 

been removed and placed into some kind of hardened on-site storage. I mean, there's no talk 

of that. It's -- you know, and to continue to just continue to produce more and stockpile it on 

site, this is -- this is not logical; and I thank you.

Comment 029-CC-5: Number five, the Fukushima disaster -- excuse me -- was attributable as 

much to the failure of their supplemental – supplemental generators as it was to the tidal wave 

that came over the seawall and which means in our terms, if something were to go wrong with 

the supplemental -- in the case of an emergency at Fermi, without electricity, the storage pool 

will begin -- will begin to disintegrate in about four hours and twelve minutes. This is from DTE 

documentation. All right.

Comment 027-CC-1: I live in a part of Frenchtown where we have septic tanks. Now, what 

does that have to do with Fermi? Not a whole lot, but flushing your toilet's a pretty important part 

of your life. Being able to flush it and have things go where they're supposed to go is pretty 

important and I think we're flushing the toilet of nuclear waste and we don't have a seepage bed 

for it. We don't have a sewage treatment plant and we don't have a seepage bed.

I don't think we should play political games with nuclear waste as I heard earlier tonight. I don't 

think we need to blame one party or another. I don't think that's the answer. The government 

unwisely assumed the job of disposing of nuclear waste from nuclear power plants a long time 

ago.

The -- I -- I do feel that if the nuclear power plants had to take care of their own nuclear waste, 

we wouldn't be here. I've also heard talk about reprocessing nuclear waste. That's not a very 

good answer. Look it up on the internet. You can find out a lot more about it. Bomb grade 

plutonium is one of the byproducts of the reprocessing of nuclear waste as is a lot of pollution of 

water and the bomb grade plutonium is piling up and who knows who'll get a hold of it if things 

go bad.

The -- oh, there -- there was talk about Yucca Mountain. There's more nuclear waste in the 

United States that can fill Yucca Mountain. So Yucca Mountain, even if it were filled up, 

wouldn't be the answer to the nuclear waste that are sitting right in the United States as we talk.

Let's see here. Oh, Manny already mentioned that the Michigan State Legislature opposes the 

disposal site in Ontario while they approve of a place like Fermi 2 and it's a little bit inconsistent 

as far as I'm concerned. I'm wondering what other industry in our country has the opportunity to 

have its waste products taken care of by the government? That's us, folks.

Even DTE coal plant here in Monroe is responsible for their fly ash and their emissions and 

they've built that responsibility into their rate structure. We're paying for it. It's being -- it's being 

controlled. It's meeting standards that have been set by the EPA, so I say that the cost of 

disposal of nuclear -- if -- if the costs of the disposal of nuclear waste were part of nuclear 

power's operating expenses, I doubt if we would be here.
Appendix A

A-38

And I hope that the environmental impact statement considers even though it isn't really legally 

a part of the whole picture, the fact that we do have the problem of nuclear waste. It's going to 

affect the environment somehow somewhere, even if -- if -- if it isn't in the official statements. 

Thank you.

Response: The NRC’s regulations require that spent nuclear fuel be stored and maintained in 

a safe and secure manner while the plant is operating and after the plant operating license 

expires. The spent fuel remains under the direct control of the licensee and the regulatory 

oversight of the NRC until its ultimate disposition.

DTE is required to safely handle, process, and store spent fuel in accordance with NRC 

regulations. Spent fuel is stored onsite in a combination of two types of NRC-approved 

methods: storage in a spent fuel pool and in dry casks. Both of these methods maintain the 

spent fuel in a safe configuration. Additionally, to ensure the long-term safety of spent fuel, DTE 

is required by 10 CFR 50.54(bb) to maintain adequate funding for the safe long-term storage of 

spent fuel on site.

The issue of an accident involving spent fuel (i.e., spent fuel fire) was specifically addressed by 

the NRC in two Petitions for Rulemaking (PRM) (PRM 51-10 and PRM 51-12) submitted by the 

Attorney General of the Commonwealth of Massachusetts and the Attorney General of the State 

of California, respectively. The Federal Register Notice containing the details of the petitions 

and the NRC’s evaluation are available to the public on the NRC’s Web site (www.NRC.gov) 

under ADAMS No. ML081890124. 

The Petitioners requested that the NRC initiate a rulemaking concerning the environmental 

impacts of the high density storage of spent nuclear fuel in spent fuel pools. The Petitioners 

asserted that ‘‘new and significant information’’ shows that the NRC incorrectly characterized 

the environmental impacts of high-density spent fuel storage as ‘‘insignificant’’ in its GEIS

(NUREG–1437) for the renewal of nuclear power plant licenses. Specifically, the Petitioners 

asserted that spent fuel stored in high-density spent fuel pools is more vulnerable to a zirconium 

fire than the NRC concluded in its NEPA analysis. 

The Commission denied the petition for rulemaking, concluding as follows:

Based upon its review of the petitions, the NRC has determined that the studies upon which the 

Petitioners rely do not constitute new and significant information. The NRC has further 

determined that its findings related to the storage of spent nuclear fuel in pools, as set forth in 

NUREG–1437 and in Table B–1, of Appendix B to Subpart A of 10 CFR Part 51, remain valid. 

Thus, the NRC has met and continues to meet its obligations under NEPA. For the reasons 

discussed previously, the Commission denies PRM-51-10 and PRM-51-12.

In Section 4.11.1.2 of this DSEIS, the NRC staff concluded that the impact of design-basis 

accidents and severe accidents at Fermi 2 during the license renewal term would be SMALL.

For the ultimate disposal of spent fuel, the NRC is aware that geologic disposal at Yucca 

Mountain or elsewhere may not be available in the timeframe that was originally envisioned. As 

an alternative, the Commission has considered the storage of spent fuel on reactor sites where 

it is generated. Section 4.11.1.2, “Onsite Storage of Spent Nuclear Fuel,” in the NRC’s 2013 

GEIS (NUREG–1437) (NRC 2013b) discusses the impacts from the onsite storage of spent fuel 

at nuclear power plant sites during the license renewal term. Based on its evaluation, the NRC 

concluded that the environmental impact for the onsite storage of spent nuclear fuel during the 

license renewal term was small at all nuclear power plants.

In Section 4.13 of this DSEIS, the NRC staff concluded that impacts from the onsite storage of 

spent nuclear fuel during the license renewal term would be SMALL.
Appendix A

A-39

Regarding the long-term storage of spent nuclear fuel beyond the licensed life for operation of a 

reactor, on August 26, 2014, the Commission approved the Continued Storage Rule at 

10 CFR 51.23 and associated NUREG–2157, Generic Environmental Impact Statement for 

Continued Storage of Spent Nuclear Fuel (NRC 2014b). The Continued Storage Rule adopts 

the generic impact determinations made in NUREG–2157 and codifies the NRC’s generic 

determinations regarding the environmental impacts of continued storage of spent nuclear fuel 

beyond a reactor’s operating license (i.e., those impacts that could occur as a result of the 

storage of spent nuclear fuel at at-reactor or away-from-reactor sites after a reactor’s licensed 

life for operation and until a permanent repository becomes available). Therefore, the NRC staff 

concludes that the information in NUREG–2157 provides the appropriate NEPA analyses of the 

potential environmental impacts associated with the continued storage of spent fuel beyond the 

licensed life for reactor operations at Fermi 2. The environmental impacts assessed in 

NUREG–2157 regarding continued storage are deemed incorporated by rule into the Fermi 2 

license renewal DSEIS pursuant to 10 CFR 51.23(b).

On the issue of requiring DTE to store spent fuel in a hardened onsite storage (HOSS) facility, 

the NRC is addressing the issue of HOSS through the rulemaking process; therefore, the issue 

of requiring HOSS is outside the scope of the NRC’s environmental review. Current status, as 

well as all information submitted in support of the ongoing rulemaking, can be found by 

accessing www.regulations.gov and searching for the docket number NRC-2009-0558.

On the issue of financial accountability, the NRC assumes that the comment is addressing 

financial accountability following a reactor accident. Financial liability issues resulting from a 

reactor accident are governed by the Price–Anderson Nuclear Industries Indemnity Act of 1957, 

as amended (Price–Anderson Act) (42 U.S.C. 2210). The Price–Anderson Act is a Federal law 

that governs liability-related issues for all nonmilitary nuclear facilities constructed in the United 

States before 2026. The main purpose of the Price–Anderson Act is to provide prompt and 

orderly compensation to the public who may incur damages from a nuclear incident, no matter 

who might be liable. The Price–Anderson Act provides “omnibus” coverage—the same 

protection available for a covered licensee or contractor indemnifies any persons who may be 

legally liable, regardless of their identity or relationship to the licensed activity. Because the 

Price–Anderson Act channels the obligation to pay compensation for damages to the licensee, 

any party with a claim only needs to bring its claim to the licensee or contractor.

Comment 019-CC-4: Some of the waste is being removed. They're -- they're -- they're 

dumping it in Iraq. They're using it as munitions, the depleted uranium munitions. We're 

spreading this stuff in the Middle East and the birth defect rate is skyrocketing. I think it's 

criminal. It's criminal.

Response: This comment expresses concern that radiological waste generated from nuclear 

power plant operations is being used in the manufacture of depleted uranium munitions. 

Depleted uranium is produced during the uranium enrichment process and is typically found in 

spent fuel elements or waste material generated during uranium recovery (referred to as 

byproduct tailings or residues). Depleted uranium has some commercial applications, including 

in counterweights and in the manufacturing of ammunitions used to pierce armor plating, such 

as those found on tanks, in missile nose cones, and as a component of tank armor. 

Additionally, depleted uranium can be blended with highly enriched uranium, such as that from 

weapons, to make reactor fuel.

As described in Section 3.1.4.4, spent fuel generated from the operation of Fermi 2 is stored on

site in either the spent fuel pool or on an independent spent fuel storage installation pad. 

Radioactive waste from commercial nuclear power plants licensed by the NRC is not used to 

make weapons, and there are currently no other approved uses of spent fuel that would allow 
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for the extraction of any depleted uranium from the spent fuel. The NRC requires its licensees 

to maintain strict control over the use, storage, transportation, and disposal of radioactive 

material and waste. Spent nuclear fuel is stored at the reactor site under strict controls for its 

safety and security in accordance with NRC regulations.

For additional information on depleted uranium, please refer to the NRC’s Web site on the topic: 

http://www.nrc.gov/about-nrc/regulatory/rulemaking/potential-rulemaking/uw-streams/bg-infodu.html. 

A.1.10 Special Status Species and Habitats (SH)

Comment 025-V-16: Endangered Species at the Fermi site:

Within the Scope for review, the SEIS for the Fermi, Unit 2 LRA must include an updated 

analysis of current and projected impacts of operations at Fermi, Unit 2 on the threatened and 

endangered species of fish and wildlife (flora and fauna) which rely on the Fermi site for habitat 

and ecosystem services. ATHF3 considers this issue to be in the category of "Significant New 

Unknown and Unanalyzed Conditions.” The SEIS must address the current list of state and 

federally-protected species, updated since the time of issuance of the original Operating 

License; further, the SEIS must adequately consider Mitigation Alternatives which could 

significantly reduce the environmental impacts of Fermi, Unit 2's operations. Thus, further 

analysis is called for, under NEPA. 

In support of this contention, ATHF3 submits into the docket the following information:

• The Bald Eagle, the Eastern Fox Snake and the Mississauga Rattlesnake live at the 

Fermi site and must be included in the SEIS and the Applicant's LRA.

• Also at the Fermi site are two bird species (Red Knot and Piping Plover) and two bat 

species (Northern Long-Eared Bat and Indiana Bat).

Other species at the Fermi site include:

• Karner Blue Butterfly

• Eastern Prairie fringed Orchid

• Three species of mussels: Northern Riffleshell, Snuffbox Mussel, and the Rayed 

Bean.

Response: The comment expresses concern regarding the impacts from operation of Fermi 2 

on rare species, such as State and Federally listed species.

The NRC staff analyzed the potential impacts to Federally listed species in Sections 3.8 and 4.8 

of this DSEIS, including potential impacts to the red knot (Calidris canutus), piping plover 

(Charadrius melodus), northern long-eared bat (Myotis septentrionalis), Indiana bat (Myotis 

sodalist), eastern prairie fringed orchid (Platanthera leucophaea), Karner blue butterfly 

(Lycaeides melissa samuelis), northern riffleshell (Epioblasma torulosa rangiana), snuffbox 

mussel (Epioblasma triquetra), and rayed bean (Villosa fabalis). In addition, the NRC staff is 

consulting with the U.S. Fish and Wildlife Service (FWS) pursuant to Section 7 of the 

Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 et seq.) (Appendix C to 

the DSEIS). If the NRC staff determined that continued operations could have an adverse effect 

on Federally listed species, as part of the ESA Section 7 consultation process, the NRC would 

issue a biological assessment, and the FWS would issue a Biological Opinion in accordance 

with the provisions of formal consultation at 50 CFR 402.14. The FWS could include a list of 

reasonable and prudent measures in a Biological Opinion necessary or appropriate to minimize 
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impacts on Federally listed species. However, as described in Section 4.8 and Appendix C to 

the DSEIS, the NRC staff determined that continued operation of Fermi 2 is not likely to 

adversely affect any Federally listed species. Therefore, formal consultation and mitigation

measures (in the form of reasonable and prudent measures) would not be appropriate. 

In Sections 3.6 and 4.6 of the DSEIS, the NRC staff analyzed the potential impacts to the bald 

eagle, the eastern fox snake, and other rare and State-listed species. The NRC staff 

determined that impacts to all terrestrial resources (including rare and State-listed species) 

would be SMALL for all Category 1 and Category 2 issues. For noncooling system impacts, the 

NRC staff made this determination because 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. In addition, 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, mitigation measures would not be 

appropriate. 

Regarding the eastern massasauga rattlesnake, in Section 3.6 of the DSEIS, the NRC staff 

determined that this species is not likely to occur near the Fermi site. This determination was 

based, in part, on consultation with FWS pursuant to ESA Section 7. During this consultation, 

the NRC and FWS did not identify the eastern massasauga rattlesnake as a species that has 

the potential to be affected by the proposed license renewal. In addition, the Michigan State 

University Extension (MSUE) (2013), on behalf of the Michigan Department of Natural 

Resources, conducted a review that included examination of records from the Michigan Natural 

Features Inventory natural heritage database on known occurrences and localities of rare 

species on and near the Fermi site. The MSUE (2013) identified seven species with known 

occurrences within 1.5 mi (2.4 km) of the Fermi site. This list did not include the eastern 

massasauga rattlesnake. Accordingly, the NRC does not specifically address this species in the 

DSEIS.

Comment 028-Y-2: Bald Eagle - The U.S. Fish and Wildlife inform:

Your list should also include the bald eagle, as they are documented to nest in and near the 

project area. Although no longer protected under the Endangered Species Act, bald eagles, 

along with their foraging and winter roosting habitat, remain protected pursuant to the Bald and 

Golden Eagle Protection Act (BGEPA) and Migratory Bird Treaty Act (MBTA). Disturbance of 

these birds should be minimized and any resulting take must be permitted by the U.S. Fish and 

Wildlife Service (Service).

Response: This comment expresses concern regarding the NRC staff’s analysis of potential 

impacts to the bald eagle. In Sections 3.6 and 4.6 of the DSEIS, the NRC staff examined the 

potential effects to the bald eagle and described the protections afforded to this species and 

other birds under the Bald and Golden Eagle Protection Act of 1940, as amended 

(16 U.S.C. 668 et seq.), and Migratory Bird Treaty Act of 1918, as amended 

(16 U.S.C. 703 et seq.). In Section 4.6, the NRC staff determined that impacts to all terrestrial 

resources would be SMALL for all Category 1 and Category 2 issues. For noncooling system 

impacts, the NRC made this determination because 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. In addition, 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.
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A.1.11 Terrestrial Resources (TE)

Comment 012-F-7: And then, there is the continued issue of the Eastern Fox Snake.

Response: The comment expresses concern for the proposed Fermi 2 license renewal’s 

impact on the eastern fox snake. The NRC addresses the eastern fox snake in Section 3.6 of 

this DSEIS. Section 4.6 of this DSEIS describes the impacts of the proposed license renewal 

on terrestrial resources, which include the eastern fox snake. As discussed in Section 4.6 of 

this DSEIS, the NRC staff determined that impacts to all terrestrial resources (including rare and 

State-listed species) would be SMALL for all Category 1 and Category 2 issues. For noncooling 

system impacts, the NRC staff made this determination because 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. In addition, 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.

Comment 028-Y-1: Beaver Impact On Wetlands:

No where in the Fermi 2 License Renewal Application Environment Report is mention made of 

the rise of beaver population in Monroe County and how their growth and presence may affect 

the wetlands, those to be impacted and the new ones to be built to replace the proposed 

destroyed ones. (Beaver Population on Rise in Monroe County, Monroe Evening News 

12/4/2012) The omission leaves questions about whether other issues did not receive 

assessment, since beavers were not mentioned.

Detroit River again becoming home to beaver reads the AP story from March 18, 2013. The 

story as it appears:

"Updated 9:53 am, Monday, March 18, 2013

DETROIT (AP) There's new evidence that the Detroit River once again is becoming home to the 

beaver, according to officials working improve the health of the river.

A trail camera set up at DTE Energy Co.'s River Rouge Power Plant in 2013 recorded images of 

a beaver dragging a small tree into the river, the Detroit Free Press reported 

(http://on.freep.com/146tqQM) Monday. It could be part of a sustained comeback.

"They could be expanding their range," said John Hartig, manager of the Detroit River 

International Wildlife Refuge.

Following a long absence, a beaver sighting was reported in 2009 at DTE's Conners Creek 

power plant along the Detroit River. He moved on during that summer, but later was spotted 

having returned with a family. Beaver sightings also have been reported on Belle Isle.

http://www.seattlepi.comlbusiness/energy/article/Detroit-River-again-becoming-home-to-beaver4362805.php

Read more: http://www.seattlepi.conmbusiness/energy/article/Detroit-River-again-becominghome-to-beaver-4362805.php#ixzz2NvanEiJ7

Read more: http://www.seattlepi.conibusiness/energy/article/Detroit-River-again-becominghome-to-beaver-4362805.php#ixzz2NvaTrFZS”

The Environmental Report is inclomplete [sic]. Beavers have the capability of suddenly and 

devastatingly altering wetlands, nothing in the Environmental Report has addressed this beaver 

concern. We request that a ER be done to include beaver wetland modification potential at the 

Fermi site through year 2045.
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Response: The comment expresses concern for the impact of beavers on wetlands in Monroe 

County. Although the NRC staff recognizes the potential for beavers to alter hydrological 

regimes and natural habitats, such as wetlands, the available wildlife surveys do not indicate the 

presence of beavers on, or in the vicinity of, the Fermi site. However, the NRC staff addresses

the types and quality of wetland habitats on the Fermi site in Section 3.6 of this DSEIS, and 

Section 4.6 of this DSEIS considers the impacts of the proposed license renewal on terrestrial 

resources, including wetlands. As discussed in Section 4.6 of this DSEIS, the NRC staff 

determined that impacts to all terrestrial resources (including rare and State-listed species) 

would be SMALL for all Category 1 and Category 2 issues. For noncooling system impacts, the 

NRC made this determination because 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. In addition, 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.

Comment 028-Y-3: Bird Kills From Cooling Towers

The License Renewal Application has not taken into consideration the number of bird kills 

resulting from two Cooling Towers at Fermi 2 that will result over extended 20 year license 

renewal. Please enter into the record the attached 1979 study entitled Cooling Towers as 

Obstacles in Bird Migration which took a look at bird kills at Davis-Besse which has one Cooling 

Tower. Recently the Kirkland Warbler was identified as being potentially impacted by 

Davis-Besse. There is no discussion of this federally endangered species in the Fermi 2 LRA. 

Please see that this is addressed.

Response: The comment expresses concern for the potential for birds to collide with the 

Fermi 2 cooling towers during the proposed license renewal period. The comment also 

specifically expresses concern for the potential for the Kirtland’s warbler, a Federally listed 

species, to be impacted by the Fermi 2 cooling towers. In the GEIS, the NRC staff determined 

that bird collisions with plant structures is a generic (Category 1) issue with an impact level of 

SMALL for all sites. During its review of the Fermi 2 ER, the NRC staff considered whether any 

new or significant information exists that would conflict with the generic conclusion in the GEIS 

that impacts would be SMALL. The NRC staff also summarized available bird collision data for 

the Fermi site in Section 3.6 of this DSEIS. Sections 3.8 and 4.8 of the DSEIS address 

Federally listed species, including all Federally listed birds that have the potential to occur within 

the ESA action area, as defined at 50 CFR 402.02. The potential for these species to collide 

with cooling towers is addressed, as appropriate. Regarding the Kirtland’s warbler specifically, 

during consultation with the FWS pursuant to ESA Section 7, the NRC and FWS did not identify 

the Kirtland’s warbler as a species that has the potential to be affected by the proposed license 

renewal. Appendix D to this DSEIS describes ESA Section 7 consultation. 

A.1.12 References

10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Agency rules of practice 

and procedure.”

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.”
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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.”

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor site 

criteria.”

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of historic properties.”

50 CFR 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

“Interagency cooperation—Endangered Species Act of 1973, as amended.”

79 FR 36837. U.S. Nuclear Regulatory Commission. “Notice of intent to prepare an 

environmental impact statement and conduct scoping process for license renewal application for 

Fermi 2; DTE Electric Company.” Federal Register 79(125):36837–36839. June 30, 2014.

[AECOM] AECOM. 2009. Aquatic Ecology Characterization Report: Detroit Edison Company 

Fermi 3 Project. November. ADAMS No. ML093380373.

Bald and Golden Eagle Protection Act of 1940, as amended. 16 U.S.C. § 668 et seq.

Clean Water Act of 1977, as amended. 33 U.S.C. § 1251 et seq.

[DTE] DTE Electric Company. 2014. Fermi 2 License Renewal Application. Appendix E: 

Applicant’s Environmental Report, Operating License Renewal Stage, Fermi 2. April 2014. 

ADAMS Nos. ML14121A538, ML14121A539, and ML14121A540.

[DTE] DTE Electric Company. 2015a. Letter from V. Kaminskas, Site Vice President, DTE, to 

NRC Document Control Desk. Subject: Response to NRC Request for Additional Information 

for the Review of the Fermi 2 License Renewal Application—Severe Accident Mitigation 

Alternatives. January 9, 2015. ADAMS No. ML15037A229.

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

[EPA] U.S. Environmental Protection Agency. 2014. “Detroit River-Western Lake Erie Basin 

Indicator Project. INDICATOR: Algal Blooms in Western Lake Erie. Large Lakes and Rivers 

Forecasting Branch.” Updated December 5, 2014. Available at 

<http://www.epa.gov/med/grosseile_site/indicators/algae-blooms.html> (accessed 

5 December 2014). 

Mackey SD. 2012. Great Lakes Nearshore and Coastal Systems. U.S. National Climate 

Assessment Midwest Technical Input Report. In: Winkler J, Andresen J, Hatfield J, Bidwell D, 

Brown D, coordinators. U.S. National Climate Assessment Midwest Technical Input Report. 

Great Lakes Integrated Sciences and Assessments (GLISA) Center. Available at

<http://glisa.umich.edu/media/files/NCA/MTIT_Coastal.pdf> (accessed 2 January 2015).

Mangano JJ. 2012. Potential Health Risks Posed by Adding a New Reactor at the Fermi Plant: 

Radioactive contamination from Fermi 2 and changes in local health status. Radiation and 

Public Health Project. January 10, 2012. Available at 

<http://static1.1.sqspcdn.com/static/f/356082/16362768/1328128276340/Mangano_corrected_F

ermi_report_Jan_11_2012.pdf?token=gBLNCTkz%2B14KsQF62i1RyPquUuo%3D> 

Migratory Bird Treaty Act of 1918, as amended. 16 U.S.C. § 703 et seq. 
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[MSUE] Michigan State University Extension. 2013. Letter from M. Sanders, Environmental 

Review Specialist/Zoologist, Michigan Natural Features Inventory (MSUE), to L. Goodman, 

DTE Energy Company. Subject: Enhanced Rare Species Review #1271—DTE Electric 

Fermi 2 Nuclear Station License Renewal, Monroe County, MI T6S, R10E 

Sections 16, 17, 19, 20, 20, 28 & 29. September 17, 2013. ADAMS No. ML14121A540 (in 

DTE’s Fermi 2 Environmental Report, Appendix C).

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

National Historic Preservation Act of 1966, as amended. 16 U.S.C. § 470 et seq.

[NRC] U.S. Nuclear Regulatory Commission. 1997. Regulatory Analysis Technical Evaluation 

Handbook. Washington, DC: NRC. NUREG/BR–0184, January 1997. 308 p. ADAMS 

No. ML050190193.

[NRC] U.S. Nuclear Regulatory Commission. 2011. Criteria for Development of Evacuation 

Time Estimate Studies. Washington, DC: NRC. NUREG/CR–7002. November 2011. 

[NRC] U.S. Nuclear Regulatory Commission. 2012b. State-of-the-Art Reactor Consequence 

Analyses (SOARCA) Report, Part 1 and Part 2. Washington, DC: NRC. NUREG–1935. 

November 2012.

[NRC] U.S. Nuclear Regulatory Commission. 2012c. Modeling Potential Reactor Accident 

Consequences. Washington, DC: NRC. NUREG/BR–0359. December 2012. 

[NRC] U.S. Nuclear Regulatory Commission. 2013a. Environmental Impact Statement for the 

Combined License (COL) for Enrico Fermi Unit 3, Final Report. Washington, DC: NRC. 

NUREG–2105, Volumes 1 and 2. January 2013. ADAMS Nos. ML12307A172 and 

ML12307A176.

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

for License Renewal of Nuclear Plants. Revision 1. Washington, DC: NRC. NUREG–1437, 

Volumes 1, 2, and 3. June 30, 2013. 1,535 p. ADAMS No. ML13107A023.

[NRC] U.S. Nuclear Regulatory Commission. 2014a. NRC Staff’s Answer to Citizens’ 

Resistance at Fermi 2 (CRAFT) Petition for Leave to Intervene and Request for Public Hearing. 

Washington, DC: NRC. September 12, 2014. ADAMS No. ML14255A495.

[NRC] U.S. Nuclear Regulatory Commission. 2014b. Generic Environmental Impact Statement

for Continued Storage of Spent Nuclear Fuel: Final Report, Volume 1. Washington, DC: NRC.

NUREG–2157. September 2014. 

Price–Anderson Act Nuclear Industries Indemnity Act of 1957, as amended. 42 U.S.C. § 2210

et seq.

[USGCRP] U.S. Global Change Research Program. 2014. Climate Change Impacts in the 

United States: The Third National Climate Assessment. Melillo JM, Richmond TC, Yohe GW, 

editors. May 9, 2014. ADAMS No. ML14129A233.
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A.2 Comments Received on the Draft Supplement Environmental Impact 

Statement

On October 26, 2015, the NRC issued the Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants, Supplement 56, Regarding Fermi 2 Nuclear Power Plant, Draft 

Report for Comment (NUREG–1437) (DSEIS) to Federal, tribal, state, local governmental 

agencies, and interested members of the public. The U.S. Environmental Protection Agency 

(EPA) published in the Federal Register a Notice of Availability regarding the DSEIS on 

November 13, 2015 (80 FR 70206). The public comment period began on November 13, 2015, 

with the issuance of EPA’s notice and ended on December 28, 2015. As part of the process to 

collect comments on the DSEIS, the staff did the following: 

• placed a copy of the DSEIS into the NRC’s Public Electronic Reading Room, on the 

license renewal Web site,

• placed a copy of the DSEIS on the license renewal website at: 

<http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/supplement56/>, 

• provided a copy of the DSEIS for review at the Ellis Library and Reference Center in 

Monroe, Michigan, 

• published a notice of availability of the DSEIS in the Federal Register on 

November 6, 2015 (80 FR 68881), and

• held one public meeting on December 2, 2016, at the Monroe County Community 

College, La-Z-Boy Center, in Monroe, Michigan.

Approximately 40 people attended the meeting on December 2, 2015, with 24 people providing 

oral comments. A certified court reporter prepared written transcripts of the meeting. The NRC 

received 48 written submittals (via Regulations.gov, letters or e-mails with comments and 

written comments provided at the public meeting). Several people provided both oral and 

written comments. The total number of commenters is 65.

Each comment is identified by the commenter’s ID number and comment source document 

(as identified in Table A–3), and comment number. In addition to the comments received at the 

December 2015 public meeting, comments were submitted through Regulations.gov, letters, 

and e-mails. Comments are grouped by issue category (as identified in Table A–4). Similar 

comments are grouped together with a single response.

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

Commenters are listed in alphabetical order.

Commenter Affiliation ID

Comment 

Source ADAMS No.

Anonymous 1 None given 1 Regulations.gov ML16011A024

Anonymous 2 None given 2 Regulations.gov ML16011A026

Anonymous 3 None given 3 Regulations.gov ML16011A027

Mary Ann Baier None given 4 Regulations.gov ML16011A025

Pam Barker None given 5 Letter ML16011A028

Martina Barnard None given 6 Regulations.gov ML16011A019

Kathryn Barnes Don’t Waste Michigan –

Sherwood Chapter

7 Letter ML16011A036
Appendix A

A-313

Commenter Affiliation ID

Comment 

Source ADAMS No.

Barry Buschmann The Mannik & Smith Group 8 Meeting 

Transcript

ML16004A049

Connie Carrol United Way of Monroe 

County

9 Meeting 

Transcript

ML16004A049

Robert Clark Mayor, City of Monroe 10 Meeting 

Transcript

ML16004A049

Jessie Pauline Collins1 Citizens Resistance at Fermi 

Two (CRAFT)

11 Letter

Letter

ML16007A009

ML16011A010

Carolyn Doherty None given 12a

12b

Meeting 

Transcript

E-mail

ML16004A049

ML16004A145

Eric Dover DTE Energy Company 13 Meeting 

Transcript

ML16004A049

Michelle Dugan Monroe County Chamber of 

Commerce

14 Letter ML16011A031

Paul Fessler DTE Energy Company 15 Meeting 

Transcript

ML16004A049

Sarah Flum None given 16 Regulations.gov ML16011A020

Martha Gruelle Wildlife Habitat Council 17 Letter ML15343A420

Keith Gunter Alliance to Halt Fermi 3

(ATHF3)

18 Meeting 

Transcript

ML16004A049

Craig A. Haugen Superintendent of Schools, 

Jefferson Schools

19 Letter ML16007A006

Scott Hicks U.S. Department of Interior, 

Fish and Wildlife Service

20 Letter ML16029A074

David Hoffman Monroe County Board of 

Commissioners

21 Meeting 

Transcript

ML16004A049

Michael Hormel None given 22 Regulations.gov ML16011A023

Carol Izant Alliance to Halt Fermi 3 23 Meeting 

Transcript

ML16004A049

Vito Kaminskas DTE Energy Company 24 Letter ML15356A368

Kevin Kamps2 Beyond Nuclear 25 E-mail ML16011A014

Michael Keegan2 Don’t Waste Michigan 26a

26b

E-mail

E-Mail

ML16011A013

ML16011A015

Tim Lake Monroe County Business 

Development Corporation

27 Meeting 

Transcript

ML16004A049

Ron Lankford None given 28a

28b

Meeting 

Transcript

Other

ML16004A049

ML16011A032

Gerald Lee None given 29 Regulations.gov ML16011A021

J. Henry Lievens Monroe County Board of 

Commissioners

30 Letter ML16020A337

Barbara Loe None given 31 Regulations.gov ML16011A029
Appendix A

A-314

Commenter Affiliation ID

Comment 

Source ADAMS No.

Ed McArdle Sierra Club – Michigan 

Chapter

32 Meeting 

Transcript

ML16004A049

Jim McDevitt Frenchtown Charter 

Township

33 Letter ML15356A371

Rich McDevitt DTE Energy Company 34 Meeting 

Transcript

ML16004A049

Stephen McNew Monroe County Intermediate 

School District

35 Letter ML15329A303

Floreine Mentel Former Monroe County 

Commissioner

36 Letter ML15343A014

Susan Michetti None given 37 Letter ML16011A012

Jeanne Micka Lotus Garden Club 38 Letter ML16011A034

Richard Micka None given 39a

39b

Meeting 

Transcript

Letter

ML16004A049

ML16011A033

Mark Muhich Jackson Sierra Club 40 E-mail ML16011A011

Sandy Mull Southern Wayne County 

Regional Chamber of 

Commerce

41 Meeting 

Transcript

ML16004A049

Arthur Myatt Alliance to Halt Fermi 3 42a

42b

Letter3

Letter

ML16011A008

ML16021A437

Lindy Nelson U.S. Department of Interior, 43 Letter ML16011A009

Tracy Oberleiter Monroe County Economic 

Development Corporation

44 Meeting 

Transcript

ML16004A049

Mark Paff University of Michigan ANS 45 Meeting 

Transcript

ML16004A049

Sandra Pierce Monroe Center for Healthy 

Aging

46 Letter ML16007A005

Nancy Poprafsky Alliance to Halt Fermi 3 47 Meeting 

Transcript

ML16004A049

Kojo Quartey Monroe County Community 

College

48 Meeting 

Transcript

ML16004A049

Sue Riopelle None given 49 Regulations.gov ML16011A022

Ethyl Rivera Alliance to Halt Fermi 3 50 Meeting 

Transcript

ML16004A049

Kathleen Russeau Community Foundation of 

Monroe County

51 Letter ML16011A035

Timothy Schacht None given 52 Regulations.gov ML16011A018

David Schonberger Alliance to Halt Fermi 3 53a

53b

Meeting 

Transcript

Letter3

ML16004A049

ML16011A030

Larry Smith Frenchtown RDA 54 Meeting 

Transcript

ML16004A049

Jerry Sobczak DTE Shareholders United 55 Letter ML15345A439
Appendix A

A-315

Commenter Affiliation ID

Comment 

Source ADAMS No.

Robert Tompkins DEAR 56 Letter ML16021A435

Ralph Tusher None given 57 Regulations.gov ML16011A016

Unknown None given 58 Letter ML16020A336

Roberta Urbani None given 59 Meeting 

Transcript

ML16004A049

Joanne Van Aken International Wildlife Refuge 

Alliance

60 Letter ML15337A079

Gerald Vande Velde None given 61 Regulations.gov ML16011A017

Robert M Vergiels None given 62 Regulations.gov ML16007A007

Kenneth Westlake U.S. Environmental 

Protection Agency, Region 5

63 Letter ML16007A008

Robert Wicke None given 64a

64b

Meeting 

Transcript

Letter

ML16004A049

ML16021A436

Dale Zorn State of Michigan, Senator

from District 17 

65 Letter ML16049A584

1 The two letters submitted by Ms. Collins are identical except the first letter contained the wrong document number 

and the second letter was submitted with the correct document number (i.e., NUREG–1147 instead of 

NUREG–1437).

2 Mr. Kamps (Beyond Nuclear) and Mr. Keegan (Don’t Waste Michigan) also fully endorse and support the 

comments submitted by CRAFT (Commenter 11) and ATHF3 (Commenters 42a and 53b).

3 In the letters submitted by Mr. Myatt and Mr. Schonberger (Commenters 42a and 53b, respectively) for ATHF3, it 

was stated that ATHF3 “wholly reiterates and resubmits” the comments submitted on August 29, 2014, by ATHF3 

during the scoping period (ADAMS No. ML14252A176). Responses to the comments in the August 29, 2014, 

submittal were addressed in the Fermi 2 Scoping Summary Report (ADAMS No. ML15251A015) and in 

Section A.1 of the Fermi 2 DSEIS, NUREG–1437, Supplement 56, and will not be repeated in this section.

Table A–4. Issue Categories

Comments were divided into the following categories:

Code Technical Issue

Appendix A 

Section

AQ Air Quality and Climate Change A.2.1

AL Alternative Energy Sources A.2.2

AR Aquatic Resources A.2.3

CU Cumulative Impacts A.2.4

ED Editorial Comments Received A.2.5

GW Groundwater Resources A.2.6

HC Historic and Cultural Resources A.2.7

HH Human Health A.2.8

LR License Renewal Process A.2.9

OP Opposed to License Renewal A.2.10

OS Outside of Scope A.2.11
Appendix A

A-316

Code Technical Issue

Appendix A 

Section

PA Postulated Accidents and Severe Accident 

Mitigation Alternatives (SAMA)

A.2.12

SO Socioeconomics A.2.13

SH Special Species and Habitats A.2.14

SP Support for License Renewal A.2.15

SW Surface Water Resources A.2.16

TR Terrestrial Resources A.2.17

WM Waste Management A.2.18

The following pages contain summaries of the comments and the NRC staff responses. The full 

text of all the comments follow Section A.2.19, “References.”

A.2.1 Air Quality and Climate Change

Comment 18-3: This comment states that nuclear power does not help climate change and 

that according to a Massachusetts Institute of Technology (MIT) report, an additional 

1,500 nuclear power plants would have to be built world-wide to have an appreciable impact on 

global climate change.

Response: This comment disputes the claim that nuclear power reduces the impact of climate 

change. Since the title and date of the MIT report mentioned in the comment were not included 

with the comment, attempts by the NRC staff to locate the report were not successful. 

However, according to an MIT summary report published in 2010, nuclear power was a major 

candidate for reducing greenhouse gas emissions from the electricity sector in the United 

States. As of 2010, nuclear power plants in the United States provided about 70 percent of the 

zero-carbon electricity. The MIT summary report can be found at: 

http://mitei.mit.edu/publications/reports-studies/future-nuclear-fuel-cycle-summary-report

(accessed April 14, 2016).

This comment provides no new information. The SEIS has not been revised as a result of this 

comment.

A.2.2 Alternative Energy Sources

Comments 11-7, 11-12, 12a-4, 28a-2, 42b-1, and 53a-4: These comments express general 

disagreement with the types of alternative energy sources evaluated in the SEIS.

Response: These comments express dissatisfaction with the energy alternatives evaluated in 

the SEIS. These comments also state that cleaner energy is needed and that renewables 

should be developed now. As stated in Chapter 2 of the SEIS, the NRC’s decisionmaking 

authority in license renewal is limited to deciding whether to renew the nuclear power plant’s 

operating license for an additional 20 years. However, under NEPA, the NRC staff is required 

to consider the environmental impacts of the proposed action of license renewal, of the 

no-action alternative of not renewing the operating license, and of reasonable energy 

alternatives to renewing the operating license. The alternatives evaluated in the SEIS are 

energy technologies or options currently in commercial operation, or technologies that are not 

currently available but could provide replacement power and are likely to be available by the 

time the current Fermi 2 license expires on March 20, 2025.
Appendix A

A-317

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

Comments 42a-11, 42a-13, 42a-18, 53b-11, 53b-13, and 53b-18: These comments state that 

the SEIS failed the “hard look” in the solar and energy efficiency analyses. These comments 

also state that the alternatives analysis in the SEIS relies on misleading assumptions and the 

climate change implications for operating Fermi 2 are considered outside the scope of the 

license renewal environmental review. These comments also state that the NRC staff failed to 

further evaluate alternatives that do not rely on a conventionally fueled baseload power source.

Response: In evaluating alternatives to license renewal, the NRC considered energy 

replacement technologies or options currently in commercial operation, including solar 

photovoltaic (PV) systems, as well as technologies not currently in commercial operation but 

that could provide replacement power and are likely to be commercially available by the time the 

current Fermi 2 operating license expires. Other means of generating electricity, as well as the 

offsetting demand for electricity using conservation and energy efficiency measures 

(demand-side management) or purchasing sufficient power to replace the capacity supplied by 

Fermi 2 were considered. The impacts of renewing the operating license and the continued 

operation of Fermi 2 were then compared to the environmental impacts of reasonable 

replacement power alternatives. This 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. Although the NRC’s decisionmaking 

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

NEPA requires the NRC to consider the environmental impacts of potential alternatives to 

renewing a plant’s operating license.

Consequently, the evaluation of alternatives in the context of license renewal is limited to an 

assessment of their environmental impacts relative to those of continued operations of a nuclear 

power plant during the license renewal term. The NRC does not, however, make energy policy 

decisions or decide whether to use a nuclear power plant or an energy alternative; this decision 

is reserved for state, other Federal, and utility decisionmakers and is based on economics, 

energy reliability goals, and other objectives over which the other entities may have jurisdiction.

The climate change implications for operations at Fermi 2 during the proposed license renewal 

period are described in Section 4.15.3. 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 considered alternatives that include 

wind power or solar PV power and a combination of both technologies.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

A.2.3 Aquatic Resources

Comments 3-5, 4-5, 5-4, 11-2, 28a-7, 37-2, 58-1, and 63-1: These comments are related to 

the temperature of the discharge water released back into Lake Erie. These comments also 

question why the National Pollution Discharge Elimination System (NPDES) permit has no 

thermal limit for the cooling water discharged into Lake Erie and call on the NRC to impose 

thermal limits.

Response: These comments suggest that the temperature of the cooling water being 

discharged into Lake Erie is adversely impacting the lake and that the NRC staff should impose 

a thermal limit for the discharge water. The comments are correct that the NPDES permit does 

not impose any temperature limits for the water being discharged back into Lake Erie. As stated 
Appendix A

A-318

in Section 5.5.1.3 of the SEIS, NRC licensees must comply with the Clean Water Act (CWA), 

including all associated requirements imposed by the U.S. Environmental Protection Agency 

(EPA) or the state as part of the NPDES permitting system under Section 402 of the CWA and 

state water quality certification requirements under Section 401 of the CWA. Nuclear power 

plants cannot operate without a valid NPDES permit and current Section 401 Water Quality 

Certification. However, the NPDES permit is outside the scope of the NRC’s regulatory 

authority. EPA is the Federal agency with oversight of the CWA and the NPDES permits.

The CWA allows EPA to delegate authority of the NPDES permits to states. In Michigan, EPA 

has delegated the authority for issuing NPDES permits to the State of Michigan, Department of 

Environmental Quality (MDEQ). MDEQ issues NPDES permits on a 5-year cycle. In Michigan, 

all NPDES permits proposed for issuance will have a 30-day public notice period for the public 

to review the proposed discharge permit and provide comments to MDEQ. Information on 

MDEQ’s NPDES permitting system and laws and regulations can be found at: 

http://www.michigan.gov/deq/0,4561,7-135-3313_71618_3682_3713---,00.html. 

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

Comments 12a-2, 28a-4, 42a-8, and 53b-8: These comments suggest that the Fermi 2 

discharges into Lake Erie contribute to the algal blooms that occur in Lake Erie.

Response: These comments suggest that the heated cooling water discharged from Fermi 2 is 

responsible for the algal blooms that occur in Lake Erie. Algal blooms in Lake Erie are 

discussed in Section 4.14 of the SEIS. Nonradiological liquid effluents are covered by the 

plant’s NPDES permit and are outside the scope of the NRC’s regulatory authority. In Michigan, 

the MDEQ issued the NPDES permit under which Fermi 2 is currently operating. The NPDES 

permit specifies the discharge standards and monitoring requirements for levels of chemicals 

and thermal quality of wastewater and stormwater discharges. As noted in the SEIS, the 

Fermi 2 discharge water is warmer and may contain somewhat higher concentrations of 

nitrogen and phosphorus compounds than the ambient Lake Erie water, but the affected area 

would be limited due to the mixing and diffusion of the discharge water with lake water.

The health of the Great Lakes is important to both the United States and Canada. In 1972, the 

United States and Canada first signed the Great Lakes Water Quality Agreement (GLWQA) and 

amended it in 1983 and 1987. The GLWQA is a commitment between the United States and 

Canada to restore and protect the waters of the Great Lakes and provides a framework for 

identifying priorities and implementing actions that improve water quality. EPA coordinates 

U.S. activities that fulfill the Agreement.

The GLWQA was updated in 2012 to enhance water quality programs that ensure the 

“chemical, physical, and biological integrity” of the Great Lakes. New provisions to the GLWQA 

address aquatic invasive species, habitat degradation, and the effects of climate change, and 

they support continued work on existing threats from harmful algae, toxic chemicals, and 

discharges from vessels.

In June 2015, the Governors of Michigan and Ohio and the Premier of the Province of Ontario 

signed the Western Basin of Lake Erie Collaborative Agreement in an effort to work together to 

improve the water quality and environmental conditions in the Western Lake Erie Basin. The 

goals are to achieve a 40-percent total load reduction in the amount of total and dissolved 

reactive phosphorus entering Lake Erie’s western basin by the year 2025. The text of the 

agreement can be found at: http://www.michigan.gov/documents/snyder/

Western_Basin_of_Lake_Erie_Collaborative_Agreement--Lieutenant_Governor_491709_7.pdf.
Appendix A

A-319

On January 14, 2016, MDEQ, Water Resources Division, published Michigan’s Implementation 

Plan for the Western Lake Erie Basin Collaborative. The purpose of Michigan’s implementation 

plan is to define the actions the State of Michigan needs to take to help meet the Western Basin 

of Lake Erie Collaborative Agreement. The full text of the report can be found at: 

https://www.michigan.gov/documents/deq/wrd-western-lake-erie_503547_7.pdf.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

A.2.4 Cumulative Impacts

Comments 11-5, 37-4: These comments suggest that the cumulative impacts of MODERATE 

and LARGE are solely due to the impacts from Fermi 2.

Response: The NRC staff considered the potential cumulative impacts from the continued 

operation of Fermi 2 in combination with the impacts from other past, present, and reasonably 

foreseeable future activities. Chapter 4 of the SEIS discusses the impact levels by resource 

area from renewing the Fermi 2 operating license and for the energy alternatives. SEIS 

Table 2–2 contains the summary of the environmental impact levels by resource area for license 

renewal and for the energy alternatives. The impact level for the Fermi 2 license renewal is 

SMALL in most resource areas.

SEIS Appendix E describes the activities, other than the license renewal of Fermi 2, which were 

considered in the NRC staff’s analysis of the potential cumulative impacts. Large cumulative 

impacts can result from individually minor impacts from actions that take place over a long time 

and when considered with other impacts in the vicinity.

This comment provides no new information. The SEIS has not been revised as a result of this 

comment.

Comment 63-2: This comment states that it is unclear from the DSEIS whether the cumulative 

impacts analysis included Fermi 3 and that Fermi 3 was not included in Table E–1, “Actions and 

Projects Considered in Cumulative Analysis.” 

Response: The Fermi 3 project is included in Table E–1, on page E–4 under “Fermi Projects.” 

Additionally, discussion of Fermi 3 is included throughout SEIS Chapter 3, “Affected 

Environment.” Section 4.16 of the SEIS, includes contributions from the cumulative impacts of 

Fermi 3 during the proposed license renewal period. This comment provides no new 

information. The SEIS has not been revised as a result of this comment.

A.2.5 Editorial Comments Received 

Comments on Executive Summary and Chapter 1: 24-1, 24-98, 24-99, 24-100, 24-101, 

24-102, 24-103, 24-104, 24-105, and 24-106. These comments identified minor edits or 

clarifications that were needed in the Executive Summary and Chapter 1 of the SEIS.

Response: The majority of these comments are editorial and provided no new and significant 

information. The NRC staff reviewed the text mentioned in each comment, agrees with the 

proposed changes, and revised the Executive Summary and Chapter 1 accordingly. All text 

changes are marked on the side of the page with change bars.

Comments on Chapter 2: 24-2, 24-3, 24-4, 24-5, 24-6, 24-51, 24-57, 24-104, 24-108, 

and 24-109

Response: These comments are editorial and provided no new and significant information. 

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed 
Appendix A

A-320

changes, and revised Chapter 2 accordingly. All text changes are marked on the side of the 

page with change bars.

Comments on Chapter 3: 24-7, 24-8, 24-10, 24-11, 24-12, 24-13, 24-14, 24-15, 24-16, 24-17, 

24-18, 24-19, 24-20, 24-21, 24-22, 24-23, 24-25, 24-28, 24-29, 24-24, 24-41, 24-42, 24-110, 

24-111, 24-112, 24-113, 24-114, 24-115, 24-116, 24-117, 24-118, 24-119, 24-120, 24-121, 

24-122, 24-123, 24-124, 24-125, 24-126, 24-127, 24-128, 24-129, 24-130, and 24-131

Response: These comments are editorial and provided no new and significant information. 

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed 

changes, and revised Chapter 3 accordingly. All text changes are marked on the side of the 

page with change bars.

Comments on Chapter 4: 24-29, 24-35, 24-36, 24-37, 24-38, 24-44, 24-45, 24-46, 24-47, 

24-48, 24-50, 24-52, 24-53, 24-54, 24-55, 24-56, 24-58, 24-59, 24-60, 24-61, 24-62, 24-63, 

24-64, 24-66, 24-67, 24-68, and 24-69, 24-70, 24-132, 24-133, 24-134, 24-135, 24-136, 24-137, 

24-138, 24-139, 24-140, 24-141, 24-142, 24-143, 24-144, 24-145, 24-146, 24-147, 24-148, 

24-149, 24-150, 24-151, 24-152, 24-153, 24-154, 24-155, 24-156, 24-157, 24-158, 24-159, 

24-160, 24-161, 24-162, 24-163, 24-164, 24-165, 24-166, 24-167, 24-168, 24-169, 24-170, 

and 24-171

Response: These comments are editorial and provided no new and significant information. 

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed 

changes, and revised Chapter 4 accordingly. All text changes are marked on the side of the 

page with change bars.

Comments on Chapter 7, Appendices A, B, C, D, and F: 24-73, 24-74, 24-75 24-75, 24-76, 

24-77, 24-78, 24-79, 24-80, 24-81, 24-82, 24-83, 24-84, 24-85, 24-86, 24-87, 24-88, 24-89, 

24-90, 24-91, 24-92, 24-93, 24-94, 24-95, 24-96, 24-97, 7-24-171, 24-172, 24-173, 24-174, 

24-175, 24-176, 24-177, 24-178, 24-179, 24-180, 24-181, 24-182, 24-183, and 24-184

Response: These comments are editorial and provided no new and significant information. 

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed 

changes, and revised Chapter 7 and Appendices A, B, C, and D, accordingly. All text changes 

are marked on the side of the page with change bars.

A.2.6 Groundwater Resources

Comment 24-4: This comment states that the SEIS incorrectly indicates there are onsite 

drinking water wells at Fermi 2.

Response: SEIS Section 2.2.2.3 stated that existing drinking water wells would be expected to 

serve a replacement new nuclear plant alternative. However, drinking water for Fermi 2 is 

obtained from a local water utility. Section 2.2.2.3 of the SEIS has been revised to reflect that 

water supply lines would be used to deliver drinking water to the site.

Comment 24-9: This comment disputes the Fermi site potable water demand of 20,000 gallons 

per day.

Response: The value for the Fermi 2 site-wide potable water demand cited by the NRC staff in 

the SEIS is derived from Figure 2.2–4 in the Environmental Report (ER), which is a water 

balance/flow diagram. The figure indicates that the total volume of water supplied by the 

Frenchtown municipal system is 25,000 gallons per day, with 7,000 gallons per day sent to the 

demineralizer system. The difference (rounded) between the values was used in the SEIS as a 

conservative estimate of Fermi 2’s potable/sanitary water demand. No changes have been 

made to the SEIS as a result of this comment.
Appendix A

A-321

Comment 24-24: This comment suggests clarifying the number of wells that had detectable 

levels of tritium. 

Response: The text in Section 3.5.2.3, “Groundwater Quality,” has been updated with respect 

to tritium concentrations reported in the 2015 Annual Radioactive Effluent Release Report and 

Radiological Environmental Operating Report.

A.2.7 Historic and Cultural Resources

Comments 3-10, 4-10, and 11-10: These comments state that there are numerous Native 

American and First Nation tribes, including the Walpole Island First Nation, in the vicinity of 

Fermi 2, but there was no evaluation on the impact to the Native Americans from operating 

Fermi 2 for an additional 20 years.

Response: In Section 4.9 of the SEIS, the NRC staff documented the consultation with the 

Advisory Council on Historic Preservation (ACHP), the Michigan State Historic Preservation 

Officer (SHPO) and 17 Federally recognized Native American Tribes. The Native American 

Tribes were invited to participate in the scoping process; however, the NRC received no scoping 

comments from any of the Tribes. The NRC staff met with the Michigan SHPO in 

September 2014 to discuss the Fermi 2 license renewal. The SHPO did not express any 

concerns about the proposed Fermi 2 license renewal.

Additionally, the Walpole Island First Nation, an Indian Tribe from Ontario, Canada, sent a letter 

to the NRC stating that the Tribe 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. By letter dated October 31, 2014, the 

NRC invited the Walpole Island First Nation to provide input on the Fermi 2 SEIS environmental 

review, as well as the NRC’s overall license renewal process. In November 2015, a copy of the 

Fermi 2 DSEIS was sent to the Walpole Island First Nation requesting comments. However, the 

Walpole Island First Nation did not provide comments.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

A.2.8 Human Health

Comments 3-4, 3-6, 4-4, 4-6, 5-3, 7-2, 11-14, 12a-1, 42a-9, and 53b-9: These comments 

indicate that nuclear power causes cancer and other illnesses, that the radiation standards are 

inadequate to protect children, and that radioactive emissions from the plant endanger the 

people.

Response: The NRC’s mission is to protect public health and safety and the environment from 

the effects of radiation from nuclear reactors, materials, and waste facilities. A discussion of 

these responsibilities beginning with the Atomic Energy Act of 1954 can be found on the NRC 

Web site at http://www.nrc.gov/about-nrc/history.html. The NRC’s regulatory limits for 

radiological protection are set to protect workers and the public from the harmful health effects 

(i.e., cancer and other biological impacts) of radiation. The limits are based on the 

recommendations of standards-setting organizations. Radiation standards reflect extensive 

scientific study by national and international organizations. The NRC actively participates in and 

monitors the work of these organizations to keep current on the latest trends in radiation 

protection. If the NRC determines that there is a need to revise its radiation protection 

regulations, it will initiate a rulemaking. Members of the public who believe that the NRC should 

revise or update its regulations may request that the NRC do so by submitting a petition for 

rulemaking.
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The NRC has based its dose limits and dose calculations on a descriptive model of the human 

body referred to as “standard man.” However, the NRC has always recognized that dose limits 

and calculations based on a “standard man” must be informed and adjusted in some cases for 

factors such as age and gender. For example, the NRC has different occupational dose limits 

for pregnant women workers, once they have declared (i.e., made known) they are pregnant, 

because the rapidly developing human fetus is more radiosensitive than an adult woman. NRC 

dose limits are also much lower for members of the public, including children and elderly people, 

than for adults who receive radiation exposure as part of their occupation. Finally, NRC dose 

calculation methods include age-specific dose factors for each radionuclide to consider the 

varied sensitivity to radiation exposure by infant, child, and teen bodies, which are also 

generally smaller than adult bodies. In addition, the calculation methods have always 

recognized that the diets (amounts of different kinds of food) of infants, children, and teens are 

different from those of adults.

Two comments mention the findings of the Biological Effects of Ionizing Radiation (BEIR) VII 

report. BEIR VII is the seventh in a series of publications from the National Academies 

concerning radiation health effects, referred to as the BEIR reports. The BEIR VII report entitled 

“Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII – Phase 2” (National 

Research Council 2006) focuses on the health effects of low levels of low linear energy transfer 

(LET) ionizing radiation. Low-LET radiation deposits less energy in the cell along the radiation 

path and is considered less destructive per radiation track than high-LET radiation. Examples of 

low-LET radiation, the subject of this report, include X-rays and γ-rays (gamma rays). Health 

effects of concern include cancer, hereditary diseases, and other effects, such as heart disease. 

The NRC accepts the linear, no-threshold (LNT) dose-response model (see additional 

information at http://www.nrc.gov/about-nrc/radiation/health-effects/rad-exposure-cancer.html. 

The BEIR VII Committee concluded that the current scientific evidence is consistent with the 

hypothesis that there is an LNT dose-response relationship between exposure to ionizing 

radiation and the development of cancer in humans. Having accepted this model, the NRC 

believes that it is conservative when applied to workers and members of the public who are 

exposed to radiation from nuclear facilities. This is based on the fact that numerous 

epidemiological studies have not shown increased incidences of cancer at low doses. Some of 

these studies included: (1) the 1990 National Cancer Institute study (NCI 1990) of cancer 

mortality rates around 52 nuclear power plants, (2) the University of Pittsburgh study that found 

no link between radiation released during the 1979 accident at the Three-Mile Island nuclear 

power station and cancer deaths among residents, and (3) the 2001 study performed by the 

Connecticut Academy of Sciences and Engineering that found no meaningful associations 

between exposures to radionuclides around the Haddam Neck nuclear power plant in 

Connecticut and the cancers studied. In addition, a position statement entitled “Radiation Risk 

in Perspective” by the Health Physics Society (August 2004) made the following points 

regarding radiological health effects: (1) radiological health effects (primarily cancer) have been 

demonstrated in humans through epidemiological studies only at doses exceeding 5–10 rem 

delivered at high dose rates. Below this dose, estimation of adverse effect remains speculative; 

and (2) epidemiological studies have not demonstrated adverse health effects in individuals 

exposed to small doses (less than 10 rem delivered over a period of many years).

The comments also state that low-dose effects of radiation can cause cancer and genetic 

damage at an increased magnitude than previously seen. The BEIR VII report makes no 

assertion that there is no safe level of exposure to radiation. Rather, the conclusions of the 

report are specific to estimating cancer risk. The report notes that the “BEIR VII Committee said 

that the higher the dose, the greater the risk; the lower the dose, the lower the likelihood of harm 

to human health.” Further, the report notes that “[t]he Committee maintains that other health 

effects, such as heart disease and stroke, occur at high radiation doses but that additional data 
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must be gathered before an assessment of any possible dose response can be made of 

connections between low doses of radiation and non-cancer health effects.” Although the LNT 

model is still considered valid, the BEIR VII Committee concluded that the current scientific 

evidence is consistent with the hypothesis that there is a linear dose-response relationship 

between exposure to ionizing radiation and the development of radiation-induced solid cancers 

in humans. Further, the Committee concluded “that it is unlikely that a threshold exists for the 

induction of cancers but notes that the occurrence of radiation-induced cancers at low doses will 

be small.”

Although radiation may cause cancers at high doses, currently there are no reputable 

scientifically conclusive data that unequivocally establish the occurrence of cancer following 

exposure to low doses (i.e., below about 10 rem [0.1 Sv]). However, radiation protection 

experts conservatively assume that any amount of radiation may pose some risk of causing 

cancer or a severe hereditary effect and that the risk is higher for higher radiation exposures. 

Therefore, an LNT dose-response relationship is used to describe the relationship between 

radiation dose and adverse impacts, such as incidents of cancer. Simply stated, in this model 

any increase in dose, no matter how small, results in an incremental increase in health risk. 

This theory is accepted by the NRC as a conservative model for estimating health risks from 

radiation exposure, recognizing that the model probably over-estimates those risks. Based on 

this theory, the NRC conservatively establishes limits for radioactive effluents and radiation 

exposures for workers and members of the public. Although the public dose limit in 

10 CFR Part 20 is 100 mrem (1 mSv) for all facilities licensed by the NRC, the NRC has 

imposed additional constraints on nuclear power reactors. Each nuclear power reactor has 

enforceable license conditions that limit the total annual whole body dose to a member of the 

public outside the facility to 25 mrem (0.25 mSv). The amount of radioactive material released 

from nuclear power facilities is well measured, well monitored, and known to be very small. The 

doses of radiation that are received by members of the public as a result of exposure to nuclear 

power facilities are very low (i.e., less than a few millirem) such that resulting cancers attributed 

to the radiation have not been observed and would not be expected. As stated in 

NUREG–1437, “Generic Environmental Impact Statement for License Renewal of Nuclear 

Plants” (GEIS), the NRC believes the public and occupational impacts during the license 

renewal term would be SMALL.

Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have 

been conducted, no studies to date accepted by the scientific community show a correlation 

between radiation dose from nuclear power facilities and cancer incidence in the general public. 

The following is a list of some of the most recent radiation health studies that the NRC 

recognizes:

• In June 2000, investigators from the University of Pittsburgh found no link between 

radiation released during the 1979 accident at the Three Mile Island power plant and 

cancer deaths among nearby residents. Their study followed 32,000 people who 

lived within 5 miles of the plant at the time of the accident.

• In 2000, the American Cancer Society concluded that although reports about cancer 

clusters in some communities have raised public concern, studies show that clusters 

do not occur more often near nuclear plants than they do by chance elsewhere in the 

population. Likewise, there is no evidence that links strontium-90 with increases in 

breast cancer, prostate cancer, or childhood cancer rates. Radiation emissions from 

nuclear power plants are closely controlled and involve negligible levels of exposure 

for nearby communities.
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• In 2000, the Illinois Public Health Department compared childhood cancer statistics 

for counties with nuclear power plants to similar counties without nuclear plants and 

found no statistically significant difference.

• In January 2001, the Connecticut Academy of Sciences and Engineering issued a 

report on a study around the Haddam Neck nuclear power plant in Connecticut and 

concluded that radiation emissions were so low as to be negligible and found no 

meaningful associations with the cancers studied.

• In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that 

there are striking increases in cancer rates in southeastern Florida counties caused 

by increased radiation exposures from nuclear power plants. However, using the 

same data to reconstruct the calculations, on which the claims were based, Florida 

officials were not able to identify unusually high rates of cancers in these counties 

compared with the rest of the state of Florida and the nation.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

Comment 24-40: This comment indicates that the 3-year average annual collective dose per 

reactor may be incorrect.

Response: This comment notes that the 3-year average annual collective dose per reactor for 

boiling water reactors (BWRs) is incorrectly stated. The NRC staff agrees with this comment 

and the information in Section 3.11.1 has been updated with information contained in 

NUREG–0713, “Occupational Radiation Exposure at Commercial Nuclear Power Reactors and 

Other Facilities 2014: Forty-Seventh Annual Report, (Volume 36),” to reflect the correct 

collective dose numbers.

Comment 24-65: This comment states that SEIS Table 4–17 should be corrected.

Response: This comment notes that SEIS Table 4–19 is incorrect regarding the information 

contained in Table B–1 of Appendix B to 10 CFR Part 51. The NRC staff agrees with this 

comment and updated the information in SEIS Table 4–19 to correctly list “Termination of plant 

operations and decommissioning” as the only Table B–1 issue related to decommissioning.

Comment 42a-16, 53b-16: These comments disagree with the decommissioning discussion in 

the SEIS. 

Response: These comments express disagreement with how decommissioning impacts are 

assessed for license renewal. The commenters have concerns with decommissioning being a 

Category 1 issue. All operating nuclear power plants will terminate operations and be 

decommissioned at some point after the end of their operating licenses or after a decision is 

made to cease operations. License renewal could potentially delay this eventuality for an 

additional 20 years beyond the current license period. The impacts of decommissioning nuclear 

plants were evaluated in the Generic Environmental Impact Statement for Decommissioning 

Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, 

NUREG–0586. The effects of license renewal on the impacts of terminating nuclear power 

plant operations and decommissioning are considered a single environmental issue. Because 

the impacts are expected to be SMALL at all plants and for all environmental resources, it is 

considered a Category 1 issue. No new and significant information regarding decommissioning 

of Fermi 2 was identified during the review of DTE’s ER, the site audit, or the scoping process. 

The commenters also raise issues with decommissioning regarding radiological exposures to 

plant workers and to members of the public as a result of an additional 20 years of operation. 

During decommissioning activities, workers are exposed to radioactive materials that are 
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present in the reactor and support facilities, and members of the public may be exposed to 

radioactive materials that are released to the environment. Many activities during 

decommissioning are similar to the activities that occur during normal maintenance outages, 

such as decontamination of piping and surfaces; removal of piping, pumps, and valves; and 

removal of heat exchangers. Some of the activities, such as removal of the reactor vessel or 

demolition of facilities, are unique to decommissioning. Public and occupational radiation 

exposures from decommissioning activities as a result of an additional 20 years of operation are 

presented in Section 4.12.2 of the GEIS. During an additional 20 years of plant operation, only 

the quantities of long-lived radionuclides would increase, and, therefore, only the dose caused 

by the long-lived radionuclides would increase. For plant workers as well as members of the 

public, an additional 20 years of operation would result in a negligible dose increase of less than 

0.1 person-rem. Therefore, the NRC concluded that the impact of an additional 20 years of 

plant operation on the radiological doses to workers and to members of the public would be 

SMALL. No new information was provided by this comment. Therefore, no changes to the 

SEIS were made.

These comments also express concern with security and safeguards during decommissioning of 

the plant. The license renewal GEIS discusses plant security and safeguards in Section 1.7.4, 

“Safeguards and Security.” The NRC requires that nuclear power plants be both safe and 

secure. Safety refers to operating the plant in a manner that protects the public and the 

environment. Security refers to protecting the plant (using people, equipment, and fortifications) 

from intruders who wish to damage or destroy it to harm people and the environment. Security 

issues such as safeguards planning are not tied to a license renewal action but are considered 

to be issues that need to be dealt with continuously as a part of a nuclear power plant’s current 

(and renewed) operating license. Security issues are periodically reviewed and updated at 

every operating plant. These reviews continue throughout the period of an operating license, 

whether it is the original or a renewed license. If issues related to security are discovered at a 

nuclear plant (such as the issue brought up about unauthorized access), they are addressed 

immediately, and any necessary changes are reviewed and incorporated under the operating 

license. As such, decisions and recommendations concerning safeguards and security at 

nuclear power plants are ongoing and outside the regulatory scope of license renewal and the 

GEIS. No new information was provided by this comment. Therefore, no changes to the SEIS 

were made.

Finally, these comments express concern with the effects of climate change on 

decommissioning. Changes in climate have the potential to affect air and water resources, 

ecological resources, and human health, and were taken into consideration when developing 

this SEIS. SEIS Section 4.15.3.2, “Climate Change Impacts to Resource Areas,” discusses 

those impacts for an additional 20 years of operation of Fermi 2. As discussed in Chapter 2 of 

the SEIS, there are no site-specific issues related to decommissioning and the Fermi SEIS only 

addresses environmental impacts that arise directly from plant shutdown. Climate change 

impacts on decommissioning activities are outside the scope of license renewal.

No new information was provided by this comment. Therefore, no changes to the SEIS were 

made.

A.2.9 License Renewal Process 

Comments 1-2, 11-1, 11-13, 42a-2, and 53b-2: These comments state that the GEIS is flawed

and that that the NRC overuses the GEIS and generic impacts. These comments also state 

that the GEIS dismisses viable energy alternatives and ignores recent advances in renewable

energy. One comment disagreed that license renewal is a preferable option.
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Response: The GEIS was developed to establish an effective licensing process. It contains 

the results of a systematic evaluation of the environmental consequences of renewing an 

operating license and operating a nuclear power facility for an additional 20 years. Those 

environmental issues that could be resolved generically were analyzed in detail and were 

resolved in the GEIS. Those issues that were unique because of a site-specific attribute, a 

particular site setting or unique facility interface with the environment, or variability from site to 

site, were deferred and would be resolved at the time that an applicant sought license renewal. 

In the license renewal process, these issues are addressed by a site-specific SEIS. The GEIS 

is used to avoid duplication and allow the staff to focus specifically on those issues that are 

important for a particular plant (i.e., issues that are not generic).

Under NEPA, the NRC is required to consider reasonable energy alternatives, including the 

no-action alternative (not issuing the renewed operating license). The NRC staff evaluation of 

alternatives in an SEIS is limited to assessing their environmental impacts rather than 

recommending energy alternatives. The purpose of NEPA is to ensure that an agency has 

examined and disclosed the potential environmental impacts of proposed actions before the 

action is approved. The NRC is responsible for ensuring the safe operation of nuclear power 

facilities. 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 or 

an alternative energy source should be developed instead.

These comments provide no new information and no revisions were made to the SEIS.

Comment 11-8: This comment questions why safety, disposition of spent nuclear fuel, 

emergency preparedness, security and safeguards, and need for power are outside the scope 

of the environmental review.

Response: Plant safety, emergency preparedness, security and safeguards, and the need for 

power are outside the scope of the environmental review for license renewal. The NRC’s 

mission is to protect public health and safety and the environment from the effects of radiation 

from nuclear reactors, materials, and waste facilities. Plant safety, emergency preparedness, 

and security and safeguards are part of the current licensing basis and are part of the 

day-to-day functioning at nuclear power plants.

The NRC provides continuous oversight for the safe operation of nuclear power plants through 

its ongoing reactor oversight process to verify that they are being operated and maintained in 

accordance with NRC regulations. This oversight includes having full-time NRC inspectors 

located at the plant and periodic safety inspections conducted by NRC inspectors based in an 

NRC Regional Office. The inspections look at a licensee’s compliance with NRC’s regulations, 

which include the following: plant safety (routine and accident scenarios), radiation protection of 

plant workers and members of the public, radioactive effluent releases, radiological 

environmental monitoring, emergency preparedness, radioactive waste storage and 

transportation, quality assurance, and training. Should the NRC discover an unsafe condition, 

or that a licensee is not complying with its licensing basis, the NRC has full authority to take 

whatever action is necessary to protect public health and safety.

Emergency preparedness and physical security plans are required at all nuclear power plants 

and require specified levels of protection from each licensee regardless of plant design, 

construction, or license date. Requirements related to emergency planning are in the 

regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50. Requirements related to 

physical security are in the regulations at 10 CFR Part 73. These requirements apply to all 

operating licenses and will continue to apply to facilities with renewed licenses.
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Additionally, the NRC assesses the capabilities of the nuclear power plant operator to protect 

the public by requiring the performance of a full-scale exercise—that includes the participation 

of various Federal, state, and local government agencies—at least once every 2 years. These 

exercises are performed in order to maintain the skills of the emergency responders and to 

identify and correct weaknesses. As such, the NRC, in 10 CFR 50.47, has determined that 

there is no need for a special review of emergency preparedness issues in the environmental 

review for license renewal.

The need for power is considered to be outside the scope of license renewal 

(10 CFR 51.95 (c)(2)). The purpose and need for the proposed action of issuing a renewed 

license is to provide an option that allows for power generation capability beyond the term of a 

current nuclear power plant operating license to meet future system generating needs, but such 

needs will be determined by other energy-planning decisionmakers.

These comments provide no new information and no revisions to the SEIS have been made.

Comments 11-11, 42a-15, and 53b-15: These comments question why DTE did not identify 

refurbishment activities related to license renewal.

Response: Refurbishment activities are either physical activities or changes to the facility or 

site that are needed to prepare a nuclear power plant to operate following license renewal. 

Refurbishment activities can include replacement of large components of the nuclear steam 

supply system (e.g., steam generator or pressurizer), repair or replacement of pumps, pipes, 

control rod systems, electronic circuitry, electrical and plumbing systems, or motors. DTE did 

not identify any refurbishment activities needed for license renewal.

These comments provide no new information and no revisions were made to the SEIS.

Comments 42a-3, 53b-3: These comments stated that the commenters reiterates and 

resubmits the public comments submitted by the Alliance to Halt Fermi 3 in the scoping

comment letter dated August 29, 2014 (ADAMS No. ML14252A176).

Response: Comments submitted during the scoping period were addressed in Appendix A of 

the SEIS and in the “Environmental Impact Statement Scoping Summary Report” issued 

October 2015 (ADAMS No. ML15252A015). No new information was provided in this comment 

and the SEIS was not revised.

Comments 42a-4, 53b-4: These comments stated that the NRC failed to comply with the “hard 

look” requirements because relicensing is “inimical to the health and safety of the public.”

Response: The NRC’s mission is to protect public health and safety and the environment from 

the effects of radiation from nuclear reactors, materials, and waste facilities. In addition to the 

environmental review, which is documented in the SEIS, the license renewal process includes a 

safety review, inspections, and an independent review by the Advisory Committee on Reactor 

Safety (ACRS). The purpose of the safety review is to determine if the licensee has adequately 

demonstrated that the effects of aging will not adversely affect any safety-related systems, 

structures, or components that are relied upon to remain functional during and following 

design-basis events. The licensee must demonstrate that the effects of aging will be managed 

so that the intended functions of passive or long-lived structures will be maintained during the 

license renewal period. The NRC staff’s review of the licensee’s aging management program is 

documented in the safety evaluation report (SER).

The NRC’s inspection program relies upon resident inspectors, who are stationed at each plant, 

and region-based inspectors, to assess whether day-to-day activities are properly conducted 

and that equipment is adequately maintained to ensure safe operation. The NRC also 

established an inspection program for license renewal that examines the information provided 
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by the licensee in the renewal application. The site inspections are assessments of the 

applicant’s implementation of and compliance with the regulations in 10 CFR Part 54. The 

inspection team includes technical, program, and operational experts from the NRC and its 

consultants. The intent of the inspections is to determine whether the effects of aging will be 

managed such that the facility can be operated during the period of extended operation without 

undue risk to the health and safety of the public and to ensure the consistency of the applicant’s 

programs to manage aging within the current licensing basis.

The ACRS is an advisory committee mandated by the Atomic Energy Act of 1954, as amended, 

under the Federal Advisory Committee Act (FACA). The Committee has three primary 

purposes:

• to review and report on safety studies and reactor facility license and license renewal 

applications,

• to advise the Commission on the hazards of proposed and existing reactor facilities 

and the adequacy of proposed reactor safety standards, and

• to initiate reviews of specific generic matters or nuclear facility safety-related items.

The ACRS is independent of the NRC staff and reports directly to the Commission, which 

appoints its members. The ACRS is composed of recognized technical experts in their fields. It 

is structured so that experts representing many technical perspectives can provide independent 

advice, which can be factored into the NRC’s decisionmaking process. Most ACRS meetings 

are open to the public and any member of the public may request an opportunity to make an 

oral statement during the committee meeting. For license renewal of nuclear power plants, 

ACRS acts as an independent third-party oversight group that reviews the NRC staff’s SER and 

makes recommendations to the Commission on the safety aspects of license renewal.

These comments provide no new information and no revisions to the SEIS have been made.

Comments 42a-5, 53b-5: These comments state that the SEIS is deficient because it does not 

include information about uranium mining and processing.

Response: The radiological and nonradiological environmental impacts of the uranium fuel 

cycle were reviewed and discussed in the 1996 GEIS. The review included a discussion of the 

values presented in Table S–3 of 10 CFR Part 51, an assessment of the release and impact of 

Rn222 and of Tc99, and a review of the regulatory standards and experience of fuel cycle 

facilities. As stated in the 1996 GEIS, the NRC uses the standard that the impacts are of small 

significance if doses and releases do not exceed permissible levels in the Commission’s 

regulations. Given the available information regarding the compliance of fuel-cycle facilities with 

applicable regulatory requirements, the NRC has concluded the actual impacts of the fuel cycle 

are at or below existing regulatory limits. Accordingly, the NRC has concluded that individual 

radiological impacts of the fuel cycle (other than the disposal of spent fuel and high-level waste) 

are SMALL. With respect to the nonradiological impacts of the uranium fuel cycle, data 

concerning land requirements, water requirements, the use of fossil fuel, gaseous effluent, liquid 

effluent, and tailings solutions and solids, all listed in Table S–3 of 10 CFR Part 51, have been 

reviewed to determine the significance of the environmental impacts of a power reactor

operating an additional 20 years. The nonradiological environmental impacts attributable to the 

relicensing of an individual power reactor were found to be of small significance. The individual 

radiological and the nonradiological effects of the uranium fuel cycle are Category 1 issues.

These comments provide no new information and no revisions to the SEIS have been made.

Comment 63-3: This comment recommends clearer distinctions between NRC-assigned 

categories of SMALL, MODERATE, or LARGE
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Response: This comment recommends providing a better explanation of thresholds or metrics 

at which an impact will increase from SMALL to MODERATE and MODERATE to LARGE and 

to indicate whether mitigation is a factor in assigning a lower impact level. Impacts to resources 

affected by license renewal and the various alternatives are defined in the GEIS. The GEIS 

established a standard of significance for each license renewal environmental impact issue 

based on the Council on Environmental Quality (CEQ) terminology for “significantly” (see 

40 CFR 1508.27). Since the significance and severity of an impact can vary with the setting of 

the proposed action, both “context” and “intensity,” as defined in CEQ regulations in 

40 CFR 1508.27, were considered. Context is the geographic, biophysical, and social context in 

which the effects will occur. In the case of license renewal, the context is the environment 

surrounding the nuclear power plant and intensity refers to the severity of the impact in 

whatever context it occurs. Based on this, the NRC established three levels of significance for 

potential impacts:

SMALL—environmental effects are not detectable or are so minor that they will neither 

destabilize nor noticeably alter any important attribute of the resource. For the purposes of 

assessing radiological impacts, the Commission has concluded that those impacts that do not 

exceed permissible levels in the Commission’s regulations are considered SMALL.

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.

These definitions are reiterated in Section 1.4 of this SEIS, “Generic Environmental Impact 

Statement.” Section 1.4 includes definitions for the three key words:

• 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.

As explained in Section 1.5 of the GEIS and Section 1.4 of this SEIS, the NRC staff uses the 

above definitions in its evaluations of the impacts associated with the various alternatives. 

Ranges are provided when there are multiple options and multiple unknowns associated with 

the alternatives. For example, the potential impact on the land use resource as a result of the 

integrated gasification combined-cycle (IGCC) will vary greatly depending upon the location 

selected for the new IGCC facility. As explained in Chapter 4, the impacts on Land Use during 

construction of a new IGCC facility would range from MODERATE to LARGE based on such 

factors as: the location chosen, the historical use of the location, and the amount of previously 

undisturbed land impacted by the construction and operation of the new facility. There are too 

many unknowns to better describe the range and transition from MODERATE to LARGE.

In summary, the NRC staff has defined the thresholds for environmental impacts on resource 

areas in the GEIS and reiterates these thresholds in Chapter 1 of this SEIS. More specifics 

regarding the range of impacts associated with many of the alternatives cannot be better 

defined unless more specifics are available for the each alternative.

The NRC staff did not make changes to the SEIS text as a result of this comment.
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A.2.10 Opposed to License Renewal

Comments: 1-1, 2-1, 3-11, 5-1, 6-1, 7-1, 11-9, 11-16, 12b-1, 16-1, 18-5, 22-1, 25-1, 26a-1, 

26b-1, 28a-6, 29-1, 31-1, 37-1, 37-5, 42a-1, 53b-1, 42a-7, 53b-7, 49-1, 52-1, 53a-3, 57-1, 

61-1, 64a-1, and 64b-1: These comments are generally opposed to license renewal for the 

following reasons: the demand for electricity is down, Fermi 1 and 2 never functioned properly, 

renewable energy sources are needed instead of nuclear energy, the plant is generating toxic 

waste, nuclear power is dangerous, the plant has many safety problems, unsuspecting people 

are using nearby parks and state-managed land is being used by unsuspecting people and the 

plant is a target for terrorism.

Response: These comments are generally opposed to the license renewal of Fermi 2 for the 

myriad of reasons stated above. These comments provide no new information. The SEIS has 

not been revised as a result of these comments.

A.2.11 Outside of Scope

Comments 1-3, 3-3, 3-7, 4-3, 4-7, 12a-3, 28a-5, and 40-1: These comments are generally 

related to emergency planning, evacuation during an accident, and the issuance of potassium 

iodide pills.

Response: Emergency preparedness is part of the current operating license and is outside the 

scope of the environmental analysis for license renewal. Emergency preparedness plans are 

required at all nuclear power plants and require specified levels of protection from each 

licensee, regardless of plant design, construction, or license date. Requirements related to 

emergency planning are in the regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50. 

These requirements apply to all operating licenses and will continue to apply to facilities with 

renewed licenses.

The Federal Emergency Management Agency (FEMA) and the NRC are the two Federal 

agencies responsible for evaluating emergency preparedness at and around nuclear power 

plants. The NRC is responsible for assessing the adequacy of onsite emergency plans 

developed by the utility, and FEMA is responsible for assessing the adequacy of offsite 

emergency planning. The NRC relies on FEMA’s findings in determining that there is 

reasonable assurance that adequate protective measures can and will be taken in the event of a 

radiological emergency.

The NRC has regulations in place to ensure that existing plans are updated throughout the life 

of all plants. For example, nuclear power plant operators are required to update their 

evacuation time estimates after every U.S. Census, or when changes in population would 

increase the estimate by either 25 percent or 30 minutes, whichever is less. Additionally, the 

NRC assesses the capabilities of the nuclear power plant operator to protect the public by 

requiring the performance of a full-scale exercise—that includes the participation of various 

Federal, state, and local government agencies—at least once every 2 years. These exercises 

are performed to maintain the skills of the emergency responders and to identify and correct 

weaknesses.

As such, the NRC, in 10 CFR Part 50.47, has determined that there is no need for a special 

review of emergency preparedness issues in the environmental review for license renewal.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.
Appendix A

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Comments 1-3, 3-1, 4-1, 18-2, 23-1, and 53a-2: These comments generally state that the 

plant is unsafe because of the GE BWR Mark I containment and the large number of licensee 

event reports submitted to the NRC by DTE. 

Response: The NRC provides continuous oversight for the safe operation of nuclear power 

plants through its ongoing reactor oversight process to verify that they are being operated and 

maintained in accordance with NRC regulations. This oversight includes having full-time NRC 

inspectors located at the plant and periodic safety inspections conducted by NRC inspectors 

based in an NRC Regional Office. The inspections look at a licensee’s compliance with NRC’s 

regulations, which include the following: plant safety (routine and accident scenarios), radiation 

protection of plant workers and members of the public, radioactive effluent releases, radiological 

environmental monitoring, emergency preparedness, radioactive waste storage and 

transportation, quality assurance, and training. Should the NRC discover an unsafe condition, 

or that a licensee is not complying with its licensing basis, the NRC has full authority to take 

whatever action is necessary to protect public health and safety.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

Comments 3-9, 4-9, 8-4, 42a-17, and 53b-17: These comments refer to the Fukushima 

accident.

Response: The NRC has taken significant action to enhance the safety of reactors in the 

United States based on the lessons learned from the Fukushima accident. Because these 

lessons learned are applicable to many nuclear power plants in the United States, the NRC has 

established a process, which is separate from the license renewal process, to identify and 

implement the lessons it has learned. The NRC Japan Lessons-Learned Web site 

(http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html) provides the 

current status of these activities.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

Comments 5-2, 28a-3, 28b-1, 53a-1, and 53a-2: Topics of these comments include building 

Fermi 3 would add to the radioactive waste stored on site, the Fermi 1 accident, how building 

codes change over time, and that there is inadequate police support in the county.

Response: Opposition to building Fermi 3, the accident at Fermi 1, and building codes are 

outside the scope of the environmental review and will not be discussed further.

Comment 28b-1 describes instances where there is an appearance of inadequate police 

support in Monroe County, which is outside the scope of NRC’s regulatory authority. The NRC 

requires nuclear power plants to have adequate physical security on site to protect the facility. 

Physical security at Fermi 2 is part of the current operating license and is outside the scope of 

the environmental analysis for license renewal. All nuclear power plants are required to have 

physical security plans and have specified levels of protection, regardless of plant design, 

construction, or license date. Requirements related to physical security are in the regulations at 

10 CFR Part 73.

These comments provide no new information and no revisions to the SEIS have been made.

Comments 1-1, 3-2, 4-2, 42a-12, 42b-2, and 53b-12: These comments state that the SEIS is 

deficient because it does not include an evaluation of the need for power.

Response: The need for power is considered to be outside the scope of license renewal 

(10 CFR 51.95 (c)(2)). The purpose and need for the proposed action (issuance of a renewed 

license) is to provide an option that allows for a power generation capability beyond the term of 
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a current nuclear power plant’s operating license to meet future system generating needs, as 

such needs will 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, 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.

These comments provide no new information and no revisions to the SEIS have been made.

A.2.12 A.2.12 Postulated Accidents and Severe Accident Mitigation Alternatives 

(SAMAs) 

Comment 11-6: This comment questions why operating an aged reactor does not increase the 

possibility of severe accidents, why any improvements toward safety are not cost effective, and 

also whether the taxpayer money spent on the Fukushima lessons learned was wasted.

Response: License renewal requirements for power reactors are based on two key principles:

• The regulatory process is adequate to ensure that the licensing basis of all currently 

operating plants maintains an acceptable level of safety, with the possible exceptions 

of the detrimental aging effects on certain functions of certain structures, systems or 

components, as well as a few other safety-related issues, during the period of 

extended operation.

• The plant-specific licensing basis must be maintained during the renewal term in the 

same manner and to the same extent as during the original licensing term

Thus, in the review of a license renewal application, the focus is on the detrimental effects of 

aging. The safety of the reactor is an ongoing process currently and throughout the period of 

extended operation. The lessons learned from the Fukushima accident are being considered 

for the entire nuclear fleet, regardless of whether the applicant is pursuing license renewal.

This comment provides no new information and no revisions to the SEIS have been made.

Comments 42a-19 and 53b-19: These comments state that the NRC’s severe accident 

analysis relies on misleading assumptions, question whether any of the original SAMA

candidates were within the scope of license renewal, and suggest that the MACCS2 computer 

code is flawed.

Response: These comments contend that the SAMA analysis is deficient in that it is 

fundamentally based on misleading assumptions that serve to underestimate and minimize the 

projected economic costs and consequences of a severe accident and that the applicant’s 

approach was performed using the current guidance for preparing a SAMA analysis provided in 

Revision A of Nuclear Energy Institute (NEI) 05-01, “Severe Accident Mitigation Alternatives 

(SAMA) Analysis” (NEI 2005), which was endorsed by the staff for use in a SAMA analysis. 

Various input parameters and associated assumptions are described in NEI 05-01 and the ER. 

An important step in the analysis is the sensitivity analysis, which evaluates how changes in 

SAMA analysis assumptions and uncertainties would affect the cost-benefit analysis. This helps 

to bound the analysis to account for any nonconservative assumptions.

These comments also contend that the original 220 SAMA candidates evaluated are within the 

scope of license renewal, pursuant to 10 CFR Part 54. The applicant performed the SAMA 

analysis consistent with the guidance provided in NEI 05-01. The applicant evaluates or 

screens all of the original 220 SAMA candidates using specific criteria unrelated to aging. Aging 
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is evaluated at the end of the analysis to identify those items that must be implemented 

specifically for license renewal. If aging were used to screen out SAMAs for additional 

consideration at the beginning of the process, the SAMA analysis would be a less 

comprehensive evaluation of mitigation alternatives because most of the SAMAs would be 

screened out in the beginning of the analysis since most SAMAs are not age-related.

These commenters also contend that using the MACCS2 computer code model for probabilistic 

offsite consequence analysis of a nuclear accident is inappropriate because the NRC is using a 

discredited, unreasonable, and illegitimate methodological modeling software tool to assess the 

economic costs and consequences of a postulated severe accident at Fermi 2. The MACCS2 

code was developed at Sandia National Laboratories for the NRC to simulate the impact of 

severe accidents at nuclear power plants on the surrounding environment. NUREG/CR-7009, 

“MACCS Best Practices as Applied in the State-of-the-Art Reactor Consequence Analyses 

(SOARCA) Project,” provides a description of MACCS modeling capabilities used to represent 

important aspects of radionuclide atmospheric transport, emergency response, and dose

response to radiation exposure. In 2006, an Expert Review Panel recommended 

enhancements to the MACCS code that were implemented for the SOARCA Project. Some of 

the enhancements include:

• atmospheric transport and dispersion modeling improvements,

• increasing angular resolution to 64 compass directions up from 16,

• increasing the limit to 200 plume segments instead of the previous limit of 4,

• increasing the limit to 20 emergency phase cohorts instead of the original limit of 3, 

and

• enhancing the treatment of evacuation speed and direction to better reflect the 

spatial and temporal response of individual cohorts.

The MACCS2 code provides a reasonable assessment for SAMA under NEPA standards.

Climate change and its related impacts on the environmental characteristics of the Fermi 2 site 

are discussed in Sections 4.15.3 and 4.16.11 of this SEIS. For the Level 3 analysis using the 

MACCS2 code, the applicant used site-specific meteorological data (not speculative) in 

accordance with the guidance provided in NEI 05-01. This was determined to be a reasonable 

approach given that the results of previous Level 3 analyses have shown little sensitivity to 

year-to-year differences in meteorological data.

The NRC is evaluating the inputs used in the MACCS2 code, and is in the process of updating 

some of the values used in the cost-benefit analysis. However, the staff disagrees with using 

generic core damage frequencies (CDFs) and benefits. The site-specific, plant-specific 

probabilistic risk assessment (PRA) takes into account site-specific hazards, the design of the 

plant, and plant-specific operational practices that affect how a particular plant responds to 

potential challenges. This site-specific PRA is expected to yield a much more accurate estimate 

of risk (including CDF) than a generic evaluation. The SAMA analysis for license renewal is a 

Category 2 issue for plants where SAMAs have not been previously considered in an 

environmental analysis, which means that it should be evaluated on a site-specific basis. In the 

Fermi 2 case, DTE calculates the current CDF using plant-specific fault trees, event trees, and 

reliability information. This approach is consistent with the current guidance for preparing a 

SAMA analysis provided in Revision A of Nuclear Energy Institute (NEI) 05-01, “Severe 

Accident Mitigation Alternatives (SAMA) Analysis” (NEI 2005), which was endorsed by the staff 

for use in performing a SAMA analysis. This document provides the applicant guidance in using 

the plant-specific PRA model. Based on this site-specific information, the applicant is to 
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estimate the severe accident risk, offsite dose, and economic impacts of a severe accident. The 

staff believes that the plant-specific estimate, based on the most current information regarding 

the plant design, appears to be the most accurate measure of risk at Fermi 2.

The NRC staff did note, in a request for information (RAI), that a Phase I SAMA to install a 

filtered containment vent to remove decay heat was combined with Phase II SAMA 123 for an 

ATWS-sized filtered containment vent. Because a filtered vent to remove decay heat is 

considerably smaller than that required for an ATWS event, the evaluation of SAMA 123 does 

not appear to be valid for the decay heat-sized SAMA. In response, DTE indicated that the 

SAMA 123 ATWS-sized filtered vent had a rough conceptual cost of $40,000,000, estimated in 

2013 from an industry group discussion on a filtered vent. At that time, the cost was assumed 

by industry to be in the range of $40,000,000 to $50,000,000. DTE also noted in response to an 

NRC request for additional information that NEI submitted cost estimates for a filtered vent with 

a small filter and severe accident capable water makeup and for a large filter with severe 

accident capable water makeup. Neither filter was sized for an ATWS. The cost estimates 

provided were conceptual in nature. With contingency and subtracting the estimated $3.7M 

cost of the water makeup, the estimated costs were $31.7M for the small filter and $51.2M for 

the large filter. These cost estimates were based on incremental costs of filter installation 

relative to current conceptual designs planned for a hardened containment vent in compliance 

with NRC Order EA-13-109. Given that these estimates are for a vent that is not specifically 

sized for an ATWS, the cost is appropriate for the normal decay heat SAMA and is lower than 

the cost of an ATWS-sized vent. Even considering the cost for the smaller filter of $31.7M, the 

normal decay heat SAMA is not cost-beneficial (DTE 2015a). As provided in SECY-12-0157, 

sensitivity studies and analyses using values of event frequency and accident consequence in 

the upper range of the uncertainty bands result in the calculated benefits potentially justifying 

the likely costs of improved venting systems. However, as provided in Table F–6 of this SEIS, 

the benefit of SAMA 123 at Fermi 2 is only $3,290,000. This benefit includes the uncertainty 

factor applied to the adjusted cost benefit. Therefore, even if the “estimated $15 million” 

implementation cost suggested by the 2014 NAS report was used, SAMA 123 would still not be 

cost-beneficial because the cost of implementation exceeds the benefit.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

A.2.13 Socioeconomics

Comment 24-43: There appears to be a difference in methodology between the DSEIS and the 

DTE ER in the Environmental Justice (EJ) section.

Response: In identifying minority and low-income populations, the NRC staff follows the 

Commission’s “Policy Statement on the Treatment of Environmental Justice Matters in NRC 

Regulatory and Licensing Actions” (69 FR 52040), which states, “Under current NRC staff 

guidance, a minority or low-income community is identified by comparing the percentage of the 

minority or low-income population in the impacted area to the percentage of the minority or 

low-income population in the County (or Parish) and the State. If the percentage in the 

impacted area significantly exceeds that of the State or the County percentage for either the 

minority or low-income population then EJ will be considered in greater detail.

‘‘Significantly’’ is defined by staff guidance to be 20 percentage points. Alternatively, if either the 

minority or low-income population percentage in the impacted area exceeds 50 percent, EJ

matters are considered in greater detail.”
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Identifying populations with 20 percentage points greater than the percentage in the geographic 

area is simply used to determine whether EJ matters should be considered in greater detail 

rather than to identify them.

NRC guidance in LIC-203, Revision 3, also states, “Minority and low-income populations” are 

identified when (1) the minority and/or low-income population of an impacted area exceeds 

50 percent or (2) the minority and/or low-income population percentage of the impacted area is 

meaningfully greater than the minority and/or low-income population percentage in the general 

population or other appropriate unit of geographic analysis (e.g., 50-mile radius geographic area 

or county). All block groups with minority and/or low-income percentages higher than the 

geographic area should be identified on 50-mile radius maps.” (See LIC-203, pages D–5 and 

D–6). This approach is consistent with Commission policy.

No changes were made to the SEIS as a result of this comment.

Comments 28a-1: This comment indicates that the number of counties identified in the SEIS 

Section 2.2 may be incorrect.

Response: Section 2.2 of the SEIS indicates that Fermi 2 is owned and operated by DTE and 

provides electricity through the Midcontinent Independent System Operator to an 11-county 

service area. This comment states that the correct number of counties should be 13, based on 

information obtained from the Internet about DTE. DTE does provide electricity to the 

13 southeastern counties of Michigan; however, the electricity is from all of DTE’s generating 

capacity, which includes coal, natural gas, fuel oil, and Fermi 2. However, Fermi 2 only 

provides electricity to 11 counties in the service area.

This comment provides no new information. No changes were made to the SEIS.

Comments 42a-14 and 53b-14: These comments state that the environmental justice impacts 

on Monroe County residents were not evaluated in the SEIS.

Response: All human health and environmental risks are considered during nuclear 

plant-specific license renewal environmental reviews. In addition, all minority and low-income 

people are considered in the NRC’s assessment of environmental justice impacts, in 

accordance with Executive Order 12898 and the Commission’s “Policy Statement on the 

Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions” 

(69 FR 52040).

As discussed in Section 4.12.1, 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 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 appreciably exceed 

the environmental impact on the larger community. Such effects may include biological, 

cultural, economic, or social impacts.

Except for Fermi 1 decommissioning, DTE currently has no other reasonably foreseeable future 

planned activities at Fermi 2 beyond continued reactor operations and maintenance. When 
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combined with other past, present, and reasonably foreseeable future activities, the contributory 

effects of continuing reactor operations and maintenance activities would not likely cause any 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations residing near Fermi 2 beyond what is currently being experienced.

Also, the environmental impacts of postulated accidents, including severe accidents, are 

discussed in Chapter 4, Section 4.11.1.2. The Commission has generically determined that 

impacts associated with such accidents are SMALL, because nuclear plants are designed to 

successfully withstand design-basis accidents and the probability-weighted consequences (risk) 

of severe accidents are also SMALL.

The NRC’s mission is to protect people and the environment from the effects of radiation from 

nuclear reactors, materials, and waste facilities. All nuclear plants were licensed with the 

expectation that they would release some radioactive material to both the air and water during 

normal operation. NRC regulations require that radioactive gaseous and liquid releases from 

nuclear power plants meet the radiation dose-based limits specified in 10 CFR Part 20, the “as 

low as is reasonably achievable” (ALARA) dose criteria in Appendix I to 10 CFR Part 50, and 

EPA’s regulations in 40 CFR Part 190. Regulatory limits are placed on the radiation dose that 

members of the public might receive from radioactive material released by nuclear plants. The 

NRC regulations are dose based, such that the dose resulting from the radioactive effluent is 

the value used by the NRC to determine compliance with regulatory limits.

The NRC evaluated human health effects of ongoing reactor operations at Fermi 2 in 

Chapters 3 and 4 of the SEIS. The NRC staff also reviewed radiological environmental 

monitoring program (REMP) reports, which show that concentrations of radioactive 

contaminants related to nuclear power plants in the vicinity of Fermi 2 are very low (at or near 

the threshold of the survey instrument’s detection capability) and seldom above background 

levels. Based on the review of this data, no disproportionately high and adverse human health 

impacts would be expected in minority and low-income populations.

Additionally, in a report published in 2001, the American Cancer Society concluded that 

although reports about cancer case clusters in communities surrounding nuclear power plants 

have raised public concern, studies show that clusters do not occur more often near nuclear 

plants than they do by chance elsewhere in the population. The National Council on Radiation 

Protection and Measurements has observed no statistically significant data that support an 

increased incidence of biological effects due to exposures at levels typical of worldwide fallout. 

The American Cancer Society recognizes that public concern about environmental cancer risks 

often focuses on risks for which no carcinogenicity has been proven or on situations where 

known exposures to carcinogens are at such low levels that risks are negligible. The report 

states that “ionizing radiation emissions from nuclear facilities are closely controlled and involve 

negligible levels of exposure for communities near such plants.”

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

A.2.14 Special Status Species and Habitats

Comments 3-8, 4-8: These comments indicate that while the Fermi site has numerous 

endangered species on site, there was no analysis of the special status species in the SEIS.

Response: The NRC staff’s discussion of threatened and endangered species is in 

Sections 3.8 and 4.8 of the SEIS. The Federally listed species in Monroe County, Michigan, are 

in SEIS Table 3–23. Section 4.8 of the SEIS discusses the potential impacts on the special 

status species listed in Table 3–23. SEIS Table 4–9 lists the NRC staff’s effects determinations 
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for the Federally listed species from license renewal of Fermi 2 and for the energy alternatives

evaluated. A copy of the SEIS was sent to the U.S. Department of Interior, Fish and Wildlife 

Service (FWS), by letter dated October 28, 2015 (ADAMS No. ML15288A167), requesting that 

the FWS review the NRC staff’s assessment of special status species. On December 7, 2015, 

the FWS sent a letter (ADAMS No. ML16029A074) stating that it concurs with the NRC staff’s 

determination.

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

Comments 20-1 and 43-1: These are the comments provided by the U.S Department of 

Interior and the FWS regarding the NRC staff’s evaluation of special status species.

Response: These comments are in response to the NRC staff’s request for the FWS to review 

and concur with the effects determination for special status species discussed in the SEIS. On 

December 7, 2015, the FWS sent a letter (ADAMS No. ML16029A074) stating that it concurs 

with the NRC staff’s determination. On December 28, 2015, the U.S. Department of the Interior 

submitted a letter (ADAMS No. ML16011A009) stating that the Department had no further 

comments on the SEIS. No changes were made to the SEIS as a result of these comments.

In September 2015, the FWS proposed adding the eastern massasauga rattlesnake as a 

threatened species. Sections 3.8 and 4.8 of the SEIS were revised to add a discussion of this 

rattlesnake. As noted in Section 4.8.1, the NRC determined that license renewal of Fermi 2 

would have “no effect” on the eastern massasauga rattlesnake because it is not likely to be 

found within the area of the plant.

A.2.15 Support for License Renewal 

Comments 9-1, 10-1, 14-1, 19-1, 30-1, 33-1, 34-1, 35-1, 44-1, 46-1, 48-1, 55-1, and 62-1: 

These comments are supportive of the Fermi 2 license renewal for the economic contribution 

DTE makes to the region.

Response: These comments are in support of Fermi 2’s license renewal, generally due to the 

economic support the plant provides to the area. These comments provide no new information, 

and will not be addressed further. The SEIS has not been revised as a result of these 

comments.

Comments 17-1, 39a-1, and 39b-1: These comments are supportive of the Fermi 2 license 

renewal because of DTE’s support for environmental projects in Monroe Harbor and with the 

Detroit River International Wildlife Refuge.

Response: These comments are in support of Fermi 2’s license renewal due to the support the 

plant provided to the surrounding wildlife area. These comments provide no new information 

and will not be addressed further. The SEIS has not been revised as a result of these 

comments.

Comments 8-1, 13-1, 15-1, 21-1, 27-1, 36-1, 38-1, 44-1, 51-1, 56-1, 59-1, 60-1, and 65-1: 

These comments are supportive of Fermi 2 license renewal for both economic and 

environmental reasons.

Response: These comments are in support of Fermi 2’s license renewal for both economic 

and environmental reasons. These comments provide no new information and will not be 

addressed further. The SEIS has not been revised as a result of these comments.
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A.2.16 Surface Water Resources

Comments 11-3, 11-4, and 37-3: These comments express disapproval of taking large 

amounts of water from Lake Erie as cooling water for Fermi 2 and then discharging the water 

back into the lake at a higher temperature. These comments also state that discharging the 

heated water into Lake Erie violates the Great Lake Water Quality Act and other legal 

protections pertaining to water issues of the Great Lakes.

Response: These comments express disapproval of taking large amounts of water from Lake 

Erie as cooling water for Fermi 2 and then discharging the water back into the lake at a higher 

temperature. Sections 3.1.3, 3.5.1, and 3.7.1 discusses various aspects of the NPDES permit 

for Fermi 2. While nuclear power plants cannot operate without a valid NPDES permit, the 

NPDES permit is outside the scope of the NRC’s regulatory authority. The NPDES permit for 

Fermi 2 is issued and overseen by the MDEQ.

In June 2015, the Governors of Michigan and Ohio and the Premier of the Province of Ontario 

signed the Western Basin of Lake Erie Collaborative Agreement in an effort to work together to 

improve the water quality and environmental conditions in the Western Lake Erie Basin. The 

goals are to achieve a 40-percent total load reduction in the amount of total and dissolved 

reactive phosphorus entering Lake Erie’s western basin by the year 2025. The text of the 

agreement can be found at: http://www.michigan.gov/documents/snyder/

Western_Basin_of_Lake_Erie_Collaborative_Agreement--Lieutenant_Governor_491709_7.pdf. 

On January 14, 2016, MDEQ, Water Resources Division, published Michigan’s Implementation 

Plan for the Western Lake Erie Basin Collaborative. The purpose of the plan is to define the 

actions the State of Michigan needs to take to help meet the Western Basin of Lake Erie 

Collaborative Agreement. The full text of the report can be found at 

https://www.michigan.gov/documents/deq/wrd-western-lake-erie_503547_7.pdf. 

These comments provide no new information. The SEIS has not been revised as a result of 

these comments.

A.2.17 Terrestrial Resources

Comment 24-26: This comment states that Table 3–11 does not include the eastern fox snake 

and also may provide contradictory information relating to the eastern fox snake being observed 

on the plant property.

Response: This comment notes that text in Section 3.6.5.1 and in Table 3–11 of the SEIS 

appears to present contradictory information regarding the observation of the eastern fox snake 

on the Fermi site in 2008 and 2009. Upon reviewing the SEIS, the NRC staff did not find 

contradictory information. Table 3–11 specifically applies to a wildlife survey conducted by 

Black & Veatch. The eastern fox snake was not recorded as occurring on the site during this 

survey. However, as indicated in Section 3.6.5.1 of the SEIS, the species was observed within 

site wetlands west of Doxy Road in May and June 2008, during the Ducks Unlimited wetland 

delineation effort. For clarity, the NRC has revised Table 3–11 in Section 3.6.3 to include the 

eastern fox snake with a footnote indicating that the species was not formally observed during 

the Black & Veatch wildlife survey.

Comment: 24-27: This comments states that the number of bird strikes listed in SEIS 

Table 3–15 is incorrect.

Response: This comment notes that the NRC omitted a bird strike record for May 22, 2008, in 

SEIS Table 3–15. This table has been revised to include the omitted record.
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Comment: 24-49: This comment states that the use of the phrase “protected area” in SEIS 

Section 4.6.1.1 should be revised because this section is describing impacts to terrestrial 

resources and the phrase “protected area” has a distinct meaning with regard to plant security.

Response: This comment suggests that the phrase “developed area” be used in place of the 

phrase “protected area” when describing site landscape maintenance activities. The phrase 

“protected area” is defined in 10 CFR Part 73, “Physical Protection of Plants and Materials,” with 

regard to plant security. Using the phrase “developed area’ will avoid confusion with the specific 

meaning of the term “protected area.” The NRC agrees with the commenter’s suggested 

language and revised the text in Section 4.6.1.1.

Comment 24-50: This comment indicates that DTE’s cooperative agreement with the FWS for 

management of part of the Fermi site within the Detroit River International Wildlife Refuge was 

attributed to the wrong source.

Response: The NRC staff agrees with this comment. The NRC staff has corrected this error 

and revised the text in Section 4.6.1.1 accordingly.

Comment 24-71: The comment suggests that a discussion of the recovery of mayfly 

populations in more recent years be added. 

Response: The NRC staff agrees with this comment. A sentence that notes the recovery of 

mayfly populations and possible causes of the recovery was added to SEIS Section 4.16.5.

A.2.18 Waste Management

Comment 11-15: This comment questions who regulates the solid radioactive waste system’s 

portable solidification and dewatering system that was supplied and operated by a vendor.

Response: Regardless of whether the licensee or a vendor is operating equipment on site, the 

licensee must ensure the equipment is being used in accordance with plant procedures. The 

NRC has regulatory authority over any equipment that is associated with the plant’s radioactive 

waste. Two NRC Resident Inspectors are assigned to each plant on a full-time basis and 

oversee the day-to-day plant operations.

No new information was provided by these comments. Therefore, no changes to the SEIS were 

made.

Comments 18-1, 42a-6, 42a-10, 53b-6, and 53b-10: These comments express disapproval 

that radioactive waste is being generated and stored at Fermi 2. These comments also state 

that the current best practice for storing spent nuclear fuel (SNF) is hardened onsite storage.

Response: SEIS Section 3.1.4.4, “Radioactive Waste Storage,” discusses that SNF is stored 

at Fermi 2 in the spent fuel pool and in dry casks. The spent fuel pool is constructed of 

steel-reinforced concrete walls, has a stainless steel liner, and is filled with water. The spent 

fuel pool is located inside the plant’s protected area. The spent fuel pool and the dry storage 

casks are evaluated and inspected as part of the day-to-day operations of Fermi 2. The NRC 

regularly inspects Fermi 2’s spent fuel storage program to ensure the safety of the SNF stored 

in the spent fuel pool. The NRC’s safety requirements for the storage of SNF during licensed 

operations, including requirements related to the spacing of spent fuel rods in the pool, ensure 

that the expected increase in the volume of SNF during the license renewal term can be safely 

stored on site.

The regulations for storing SNF are contained in 10 CFR Part 72. SNF must be stored in casks 

that have been reviewed and have a current Certificate of Compliance. Fermi 2 stores SNF in 

NRC-approved dry cask canisters made of leak-tight welded and bolted steel at an onsite 
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independent spent fuel storage installation (ISFSI). The ISFSI is discussed in Section 3.1.4.4, 

“Radioactive Waste Storage,” where it is noted that there is capacity for 64 dry casks, with the 

ability to expand the ISFSI to accommodate 32 additional dry casks, if needed. Therefore, 

Fermi 2 has adequate onsite storage for SNF. The NRC staff’s evaluation of impacts from the 

onsite storage of SNF, offsite radiological impacts of SNF, high-level waste disposal, and the 

uranium fuel cycle are addressed in Section 4.13.1 of this SEIS. There are no NRC regulations 

requiring licensees to use hardened onsite storage to store SNF.

No new information was provided by these comments. Therefore, no changes to the SEIS were 

made.

A.2.19 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

protection against radiation.”

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.”

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

transportation of radioactive material.”

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.”

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical protection of 

plants and materials.” 

[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.

[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. 2002. Generic Environmental Impact Statement

Decommissioning of Nuclear Plants. Washington, DC: U.S. Nuclear Regulatory Commission. 

NUREG–0586, Supplement 1. November 2002. ADAMS No. ML023500395.
Appendix A

A-341

[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. MACCS Best Practices as Applied in the 

State-of-the-Art Reactor Consequence Analyses (SOARCA) Project. Washington, DC: U.S. 

Nuclear Regulatory Commission. NUREG/CR–7009. August, 2014. 197 p. ADAMS 

No. ML14234A148.

[NRC] U.S. Nuclear Regulatory Commission. 2014b. 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 No. ML14279A562.

[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. 
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APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS

B-1 

B. Applicable laws, Regulations, and Other Requirements

There are a number of Federal laws and regulations that affect environmental protection, health, 

safety, compliance, and/or consultation at every nuclear power plant licensed by the 

U.S. Nuclear Regulatory Commission (NRC). Certain Federal environmental requirements have 

been delegated to state authorities for enforcement and implementation. Furthermore, states 

have also enacted laws to protect public health and safety and the environment. It is the NRC’s 

policy to make sure nuclear power plants are operated in a manner that provides adequate 

protection of public health and safety and protection of the environment through compliance with 

applicable Federal and state laws, regulations, and other requirements.

The requirements that may be applicable to the operation of NRC-licensed nuclear power plants 

encompass a broad range of Federal laws and regulations, addressing environmental, historic 

and cultural, health and safety, transportation, and other concerns. Generally, these laws and 

regulations are relevant to how the work involved in performing a proposed action would be 

conducted to protect workers, the public, and environmental resources. Some of these laws 

and regulations require permits or consultation with other Federal agencies or state, tribal, or 

local governments.

The Atomic Energy Act of 1954, as amended (AEA) (42 U.S.C. 2011 et seq.) authorizes the 

NRC to enter into agreement with any state to assume regulatory authority for certain activities 

(see 42 U.S.C. 2021). Michigan has not yet entered into an agreement with the NRC to assume 

regulatory responsibility over certain byproduct, source, and quantities of special nuclear 

materials not sufficient to form a critical mass. Although not an Agreement State, the Michigan 

Department of Environmental Quality (MDEQ) does maintain a network of environmental

monitoring stations around each nuclear power plant site in the State. In addition, the MDEQ 

maintains a Radiological Emergency Preparedness Program to provide response capabilities to 

radiological accidents or emergencies at any of Michigan’s commercial nuclear power plants

(MDEQ undated). 

In addition to carrying out some Federal programs, state legislatures develop their own laws. 

State statutes supplement, as well as implement, Federal laws for protection of air, water 

quality, and groundwater. State legislation may address solid waste management programs, 

locally rare or endangered species, and historic and cultural resources. 

The Clean Water Act (33 U.S.C. 1251 et seq., herein referred to as CWA) allows for primary 

enforcement and administration through state agencies, given that the state program is at least 

as stringent as the Federal program. The state program must conform to the CWA and to the 

delegation of authority for the Federal National Pollutant Discharge Elimination System 

(NPDES) program from the U.S. Environmental Protection Agency (EPA) to the state. The 

primary mechanism to control water pollution is the requirement for direct dischargers to obtain 

an NPDES permit, or, as is the case for Michigan, the authority has been delegated from EPA, a 

State Pollutant Discharge Elimination System permit, under the CWA. 

One important difference between Federal regulations and certain state regulations is the 

definition of waters regulated by the state. Certain state regulations may include underground 

waters, whereas the CWA only regulates surface waters. The MDEQ Water Resources Division 

provides regulatory oversight for all public water supplies, issues permits to regulate the 

discharge of industrial and municipal wastewaters—including discharges to groundwater and 

monitors State water resources for water quality (MDEQ undated).
Appendix B

B-2 

B.1 Federal and State Requirements 

Fermi 2 is subject to Federal and State requirements. Table B–1 lists the principal Federal and 

State regulations and laws that are used or mentioned in this supplemental environmental 

impact statement for Fermi 2.

Table B–1. Federal and State Requirements 

Law/regulation Requirements

Current operating license and license renewal

Atomic Energy Act, 

42 U.S.C. 2011 et seq.

The Atomic Energy Act (AEA) of 1954, as amended, and the Energy 

Reorganization Act of 1974 (42 U.S.C. 5801 et seq.) give the NRC the 

licensing and regulatory authority for nuclear energy uses within the 

commercial sector. These regulations give the NRC responsibility for 

licensing and regulating commercial uses of atomic energy and allow the 

NRC to establish dose and concentration limits for protection of workers 

and the public for activities under NRC jurisdiction. The NRC implements 

its responsibilities under the AEA through regulations set forth in Title 10, 

“Energy,” of the Code of Federal Regulations (CFR).

National Environmental 

Policy Act of 1969, 

42 U.S.C. 4321 et seq.

The National Environmental Policy Act (NEPA), as amended, requires 

Federal agencies to integrate environmental values into their 

decisionmaking process by considering the environmental impacts of 

proposed Federal actions and reasonable alternatives to those actions. 

NEPA establishes policy, sets goals (in Section 101), and provides means 

(in Section 102) for carrying out the policy. Section 102(2) contains 

action-forcing provisions to ensure that Federal agencies follow the letter 

and spirit of the Act. For major Federal actions significantly affecting the 

quality of the human environment, Section 102(2)(C) of NEPA requires 

Federal agencies to prepare a detailed statement that includes the 

environmental impacts of the proposed action and other specified 

information.

10 CFR Part 51 Regulations in 10 CFR Part 51, “Environmental protection regulations for 

domestic licensing and related regulatory functions,” contain 

environmental protection regulations applicable to the NRC’s domestic 

licensing and related regulatory functions.

10 CFR Part 54 Regulations in 10 CFR Part 54, “Requirements for renewal of operating 

licenses for nuclear power plants,” are NRC regulations that govern the 

issuance of renewed operating licenses and renewed combined licenses 

for nuclear power plants licensed pursuant to Sections 103 or 104b of the 

AEA, as amended, and Title II of the Energy Reorganization Act of 1974 

(88 Stat. 1242). The regulations focus on managing adverse effects of 

aging. The rule is intended to ensure that important systems, structures, 

and components will maintain their intended functions during the period of 

extended operation.
Appendix B

B-3 

Law/regulation Requirements

10 CFR Part 50 Regulations in 10 CFR Part 50, “Domestic licensing of production and 

utilization facilities,” are NRC regulations issued under the AEA, as 

amended (68 Stat. 919), and Title II of the Energy Reorganization Act 

of 1974 (88 Stat. 1242), to provide for the licensing of production and 

utilization facilities. This part also gives notice to all persons who 

knowingly supply—to any licensee, applicant, contractor, or 

subcontractor—components, equipment, materials, or other goods or 

services that relate to a licensee’s or applicant’s activities subject to this 

part that they may be individually subject to NRC enforcement action for 

violation of 10 CFR 50.5.

Air quality protection

Clean Air Act,

42 U.S.C. 7401 et seq.

The Clean Air Act (CAA) is intended to “protect and enhance the quality of 

the Nation’s air resources so as to promote the public health and welfare 

and the productive capacity of its population.” The CAA establishes 

regulations to ensure maintenance of air quality standards and authorizes 

individual states to manage permits. Section 118 of the CAA requires 

each Federal agency, with jurisdiction over properties or facilities engaged 

in any activity that might result in the discharge of air pollutants, to comply 

with all Federal, state, interstate, and local requirements with regard to the 

control and abatement of air pollution. Section 109 of the CAA directs the 

U.S. Environmental Protection Agency (EPA) to set National Ambient Air 

Quality Standards (NAAQS) for criteria pollutants. The EPA has identified 

and set NAAQS for the following criteria pollutants: particulate matter, 

sulfur dioxide, carbon monoxide, ozone, nitrogen dioxide, and lead. 

Section 111 of the CAA requires establishment of national performance 

standards for new or modified stationary sources of atmospheric 

pollutants. Section 160 of the CAA requires that specific emission 

increases must be evaluated before permit approval to prevent significant 

deterioration of air quality. Section 112 requires specific standards for 

release of hazardous air pollutants (including radionuclides). These 

standards are implemented through plans developed by each state and 

approved by EPA. The CAA requires sources to meet standards and 

obtain permits to satisfy those standards. Nuclear power plants may be 

required to comply with the CAA Title V, Sections 501–507, for sources 

subject to new source performance standards or sources subject to 

National Emission Standards for Hazardous Air Pollutants. Emissions of 

air pollutants are regulated by EPA in 40 CFR Parts 50 to 99.

Michigan Compiled Laws, 

Chapter 324, “Natural 

Resources and 

Environmental Protection,” 

Part 55, “Air Pollution 

Control” 

This part of the Michigan Compiled Laws (MCLs) implements the 

requirements of the CAA.
Appendix B

B-4 

Law/regulation Requirements

Water resources protection

Clean Water Act,

33 U.S.C. 1251 et seq., and 

the NPDES

(40 CFR Part 122)

The Clean Water Act (CWA) was enacted to “restore and maintain the 

chemical, physical, and biological integrity of the Nation’s water.” The Act 

requires all branches of the Federal Government, with jurisdiction over 

properties or facilities engaged in any activity that might result in a 

discharge or runoff of pollutants to surface waters, to comply with Federal, 

state, interstate, and local requirements. As authorized by the CWA, the 

National Pollutant Discharge Elimination System (NPDES) permit program 

controls water pollution by regulating point sources that discharge 

pollutants into waters of the United States. The NPDES program requires 

all facilities that discharge pollutants from any point source into waters of 

the United States obtain an NPDES permit. A nuclear power plant may 

also participate in the NPDES General Permit for Industrial Stormwater 

due to stormwater runoff from industrial or commercial facilities to waters 

of the United States. EPA is authorized under the CWA to directly 

implement the NPDES program; however, EPA has authorized many 

states to implement all or parts of the national program. Section 401 of 

the CWA requires states to certify that the permitted discharge would 

comply with all limitations necessary to meet established state water 

quality standards, treatment standards, or schedule of compliance. 

The U.S. Army Corps of Engineers (USACE) is the lead agency for 

enforcement of CWA wetland requirements (33 CFR Part 320). Under 

Section 401 of the CWA, EPA or a delegated state agency has the 

authority to review and approve, condition, or deny all permits or licenses 

that might result in a discharge to waters of the state, including wetlands.

Coastal Zone Management 

Act of 1972, as amended 

(16 U.S.C. 1451 et seq.)

Congress enacted the Coastal Zone Management Act (CZMA) in 1972 to 

address the increasing pressures of over-development upon the Nation’s 

coastal resources. The National Oceanic and Atmospheric Administration 

administers the Act. The CZMA encourages states to preserve, protect, 

develop, and, where possible, restore or enhance valuable natural coastal 

resources such as wetlands, floodplains, estuaries, beaches, dunes, 

barrier islands, and coral reefs, as well as the fish and wildlife using those 

habitats. Participation by states is voluntary. To encourage states to 

participate, the CZMA makes Federal financial assistance available to any 

coastal state or territory, including those on the Great Lakes, which are 

willing to develop and implement a comprehensive coastal management 

program.

Wild and Scenic Rivers Act, 

16 U.S.C. 1271 et seq.

The Wild and Scenic River Act created the National Wild and Scenic 

Rivers System, which was established to protect the environmental values 

of free flowing streams from degradation by impacting activities, including 

water resources projects.

MCL, Chapter 324, “Natural 

Resources and 

Environmental Protection,” 

Part 31, “Water Resources 

Protection,” and Part 41, 

“Sewerage Systems”

These parts of the MCL implement the requirements of the CWA.
Appendix B

B-5 

Law/regulation Requirements

MCL, Chapter 324, “Natural 

Resources and 

Environmental Protection,”

Part 325, “Great Lakes 

Submerged Lands”

This part of the MCL sets forth the standards for the construction and 

maintenance—which includes dredging—of artificial waterways along the 

Great Lakes.

Waste management and pollution prevention

Resource Conservation and 

Recovery Act, 

42 U.S.C. 6901 et seq.

The Resource Conservation and Recovery Act (RCRA) requires EPA to 

define and identify hazardous waste; establish standards for its 

transportation, treatment, storage, and disposal; and require permits for 

persons engaged in hazardous waste activities. Section 3006 

(42 U.S.C. 6926) allows states to establish and administer these permit 

programs with EPA approval. The EPA regulations implementing the 

RCRA are found in 40 CFR Parts 260 through 283. Regulations imposed 

on a generator or on a treatment, storage, and/or disposal facility vary 

according to the type and quantity of material or waste generated, treated, 

stored, and/or disposed. The method of treatment, storage, and/or 

disposal also impacts the extent and complexity of the requirements.

Pollution Prevention Act, 

42 U.S.C. 13101 et seq.

The Pollution Prevention Act establishes a national policy for waste 

management and pollution control that focuses first on source reduction, 

then on environmental issues, safe recycling, treatment, and disposal.

10 CFR Part 20 Regulations in 10 CFR Part 20, “Standards for protection against 

radiation,” establish standards for protection against ionizing radiation 

resulting from activities conducted under licenses issued by the NRC. 

These regulations are issued under the AEA of 1954, as amended, and 

the Energy Reorganization Act of 1974, as amended. The purpose of 

these regulations is to control the receipt, possession, use, transfer, and 

disposal of licensed material by any licensee in such a manner that the 

total dose to an individual (including doses resulting from licensed and 

unlicensed radioactive material and from radiation sources other than 

background radiation) does not exceed the standards for protection 

against radiation prescribed in the regulations in this part.

MCL, Chapter 324, “Natural 

Resources and 

Environmental Protection,” 

Part 111, “Hazardous Waste 

Management”

This part of the MCL sets forth the standards for the generation, 

disposition, storage, treatment, and transportation of hazardous waste.

MCL, Chapter 324, “Natural 

Resources and 

Environmental Protection,” 

Part 211, “Underground 

Storage Tank Regulations”

This part of the MCL sets forth the standards for underground storage 

tanks.

Act 429 of 1980, the South 

Carolina Radioactive Waste 

Transportation and Disposal 

Act

This Act sets forth the standards for the transportation of radioactive waste 

into or within South Carolina.

Tennessee Department of 

Environment and 

Conservation Rule 

1200-2-10-32

This rule establishes the requirements for the licensing of shippers of 

radioactive material into or within Tennessee.
Appendix B

B-6 

Law/regulation Requirements

Utah Administrative Code, 

R313, “Environmental 

Quality, Radiation Control,” 

Rule R313-26, “Generator 

Site Access Permit 

Requirements for Accessing 

Utah Radioactive Waste 

Disposal Facilities”

This rule establishes the requirements for the issuance of permits to 

generators for accessing a land disposal facility located within Utah and 

requirements for shippers.

Protected species

Endangered Species Act,

16 U.S.C. 1531 et seq.

The Endangered Species Act (ESA) was enacted to prevent the further 

decline of endangered and threatened species and to restore those 

species and their critical habitats. Section 7 of the Act requires Federal 

agencies to consult with the U.S. Fish and Wildlife Service or the National 

Marine Fisheries Service (NMFS) on Federal actions that may affect listed 

species or designated critical habitats.

Magnuson–Stevens Fishery 

Conservation and 

Management Act, 

16 U.S.C. 1801-1884 

The Magnuson–Stevens Fishery Conservation and Management Act, as 

amended, governs marine fisheries management in U.S. Federal waters. 

The Act created eight regional fishery management councils and includes 

measures to rebuild overfished fisheries, protect essential fish habitat, and 

reduce bycatch. Under Section 305 of the Act, Federal agencies are 

required to consult with NMFS for any Federal actions that may adversely 

affect essential fish habitat.

Historic preservation and cultural resources

National Historic 

Preservation Act,

16 U.S.C. 470 et seq.

The National Historic Preservation Act was enacted to create a national 

historic preservation program, including the National Register of Historic 

Places and the Advisory Council on Historic Preservation. Section 106 of 

the Act requires Federal agencies to take into account the effects of their 

undertakings on historic properties. The Advisory Council on Historic 

Preservation regulations implementing Section 106 of the Act are found in 

36 CFR Part 800. The regulations call for public involvement in the 

Section 106 consultation process, including Indian tribes and other 

interested members of the public, as applicable.

B.2 Operating Permits and Other Requirements

Table B–2 lists the permits and licenses issued by Federal, State, and local authorities for 

activities at Fermi 2.

Table B–2. Licenses and Permits

Permit Number Dates Responsible Agency

Operating License NPF-43 Issued: 07/15/1985

Expires: 03/20/2025

NRC

NPDES Permit MI0037028 Issued: 06/03/2010

Expires: 10/01/2014(a)

MDEQ Water Resources 

Division

Industrial/Non-Domestic User 

Discharge Permit

1020 Issued: 08/28/2015

Expires: 8/31/2018

City of Monroe
Appendix B

B-7 

Permit Number Dates Responsible Agency

Federal Clean Air Act

Renewable Operating Permit

MI-ROP-B4321-2013 Issued: 11/01/2013

Expires: 11/01/2018

MDEQ Air Quality 

Division

Hazardous Waste Generator 

Identification

MID087056685 Not Applicable MDEQ

Great Lakes Submerged 

Lands Permit

11-58-0055-P Issued: 04/25/2012

Expires: 04/25/2017

MDEQ

Underground Storage Tank 

Registration Certificate

00010793 Renewed annually MDEQ

Great Lakes Submerged 

Lands Permit (After-the-Fact)

13-58-0013-P Issued: 06/25/2013

Expires: 06/25/2018

MDEQ

Federal Water Pollution 

Control Act Section 404 

Individual Permit

LRE-1988-10408-L15 Issued: 09/10/2015

Expires: 09/10/2025

USACE 

Federal Water Pollution 

Control Act Section 404 

Letter of Permission

LRE-1988-10408-N13 Issued: 03/20/2013

Expires: 08/22/2023

USACE

Hazardous Materials 

Certificate of Registration

060115550071XZ Issued: 06/01/2015

Expires: 06/30/2018

U.S. Department of 

Transportation, Pipeline 

and Hazardous Materials 

Safety Administration

Permit to transport 

radioactive waste

0233-21-13 Renewed annually South Carolina 

Department of Health and 

Environmental Control

License to deliver radioactive 

material

T-MI004-L13 Renewed annually Tennessee Department 

of Environment and 

Conservation

Permit to deliver radioactive 

material

0203001330 Renewed annually Utah Department of 

Environmental Quality

(a) Administratively extended pending review of DTE Electric Company’s application for reissuance.

Source: DTE 2014

B.3 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 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

renewal of operating licenses for nuclear power plants.”

40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122, 

“EPA administered permit programs: the National Pollutant Discharge Elimination System.”
Appendix B

B-8 

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

Clean Air Act of 1963, as amended. 42 U.S.C. § 7401 et seq.

Clean Water Act of 1977, as amended. 33 U.S.C. § 1251 et seq.

Coastal Zone Management Act of 1972, as amended. 16 U.S.C. § 1451 et seq.

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

Renewal Stage, Fermi 2. Newport, MI: DTE. April 2014. ADAMS Nos. ML14121A538, 

ML14121A539, and ML14121A540.

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

Energy Reorganization Act of 1974. 42 U.S.C. § 5801 et seq.

Fish and Wildlife Coordination Act of 1934, as amended. 16 U.S.C. § 661 et seq.

[MDEQ] Michigan Department of Environmental Quality, Office of Waste Management and 

Radiological Protection. Undated. Available at <http://www.michigan.gov/deq/0,1607,7-135-

3312_4120---,00.html> (accessed 12 January 2015).

[MDEQ] Michigan Department of Environmental Quality, Water Resources Division. Undated. 

Available at <http://www.michigan.gov/deq/0,1607,7-135-3313---,00.html> (accessed 

12 January 2015).

Marine Mammal Protection Act of 1972, as amended. 16 U.S.C. § 1361 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. 16 U.S.C. § 470 et seq.

Pollution Prevention Act of 1990. 42 U.S.C. § 13101 et seq.

Resource Conservation and Recovery Act of 1976, as amended. 42 U.S.C. § 6901 et seq.

Wild and Scenic Rivers Act, as amended. 16 U.S.C. § 1271 et seq.
CONSULTATION CORRESPONDENCE

C-1 

C. Consultation Correspondence

C.1 Section 7 Consultation

C.1.1 Federal Agency Obligations under ESA Section 7 

As a Federal agency, the U.S. Nuclear Regulatory Commission (NRC) must comply with the 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.; herein referred to as 

ESA), as part of any action authorized, funded, or carried out by the agency, such as the 

proposed agency action that this supplemental environmental impact statement (SEIS) 

evaluates: whether to issue a renewed license for the continued operation of Fermi 2 for an 

additional 20 years beyond the current license terms. Under section 7 of the ESA, the NRC 

must consult with the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries 

Service (NMFS) (referred to jointly as “the Services” and individually as “Service”), as 

appropriate, to ensure that the proposed agency action is not likely to jeopardize the continued 

existence of any endangered or threatened species or result in the destruction or adverse 

modification of designated critical habitat. 

The ESA and the regulations that implement ESA section 7 (Title 50 of the Code of Federal 

Regulations (50 CFR) Part 402, “Interagency cooperation—Endangered Species Act of 1973, 

as amended”) describe the consultation process that Federal agencies must follow in support of 

agency actions. As part of this process, the Federal agency shall either request that the 

Services provide a list of any listed or proposed species or designated or proposed critical 

habitats that may be present in the action area or request that the Services concur with a list of 

species and critical habitats that the Federal agency has created (50 CFR 402.12(c)). If it is 

determined that any such species or critical habitats may be present, the Federal agency is to 

prepare a biological assessment to evaluate the potential effects of the action and determine 

whether the species or critical habitat are likely to be adversely affected by the action 

(16 U.S.C. 1536(c); 50 CFR 402.12(a)). Furthermore, biological assessments are required for 

any agency action that is a “major construction activity” (50 CFR 402.12(b)), which the ESA 

regulations define to include major Federal actions significantly affecting the quality of the 

human environment under the National Environmental Policy Act of 1969, as amended 

(42 U.S.C. 4321 et seq.; herein referred to as NEPA) (50 CFR 402.02).

Federal agencies may fulfill their obligations to consult with the Services under ESA section 7 

and to prepare a biological assessment in conjunction with the interagency cooperation 

procedures required by other statutes, including NEPA (50 CFR 402.06(a)). In such cases, the 

Federal agency should include the results of the ESA section 7 consultation in the NEPA 

document (50 CFR 402.06(b)). Accordingly, Section C.3 explains why this SEIS fulfills NRC’s

obligation to prepare a biological assessment under ESA section 7, and Section C.4 describes 

the chronology and results of the ESA section 7 consultation.

C.2 Biological Assessment

The NRC considers this SEIS to fulfill its obligation to prepare a biological assessment under 

ESA section 7. Accordingly, the NRC did not prepare a separate biological assessment for the 

proposed Fermi 2 license renewal.

Although the contents of a biological assessment are at the discretion of the Federal agency 

(50 CFR 402.12(f)), the ESA regulations suggest information that agencies may consider for 

inclusion. The NRC has considered this information in the following sections.
Appendix C

C-2 

Section 3.8 describes the action area and the Federally listed and proposed species and 

designated and proposed critical habitat that have the potential to be present in the action area. 

This section includes information pursuant to 50 CFR 402.12(f)(1), (2), and (3).

Section 4.8 provides an assessment of the potential effects of the proposed Fermi 2 license 

renewal on the species and critical habitat present and the NRC’s effect determinations, which 

are consistent with those identified in Section 3.5 of the Endangered Species Consultation 

Handbook (FWS and NMFS 1998). The NRC also addresses cumulative effects and 

alternatives to the proposed action. This section includes information pursuant to 

50 CFR 402.12(f)(4) and (5).

C.3 Chronology of ESA Section 7 Consultation

Upon receipt of DTE Electric Company’s (DTE) license renewal application (LRA), the NRC staff 

considered whether any Federally listed or proposed species or designated or proposed critical 

habitats may be present in the action area (as defined at 50 CFR 402.02) for the proposed 

Fermi 2 license renewal. No species under the NMFS’s jurisdiction occur within the action area. 

Therefore, the NRC staff did not consult with the NMFS. With respect to species under the 

FWS’s jurisdiction, the NRC staff compiled a list of ESA-protected species and critical habitats 

within the vicinity of the facility and requested the FWS’s concurrence with this list in 

accordance with the ESA section 7 regulations at 50 CFR 402.12(c) in a letter dated 

July 1, 2014. The FWS concurred with the NRC staff’s list in its letter dated July 30, 2014. The 

NRC staff used this list as a starting point for its analysis of effects to Federally listed species 

and critical habitat, which appears in Sections 3.8 and 4.8 of this SEIS. Since publishing the 

draft supplemental environmental impact statement (DSEIS), NRC staff updated the species list 

to reflect the proposed listing of the eastern massasauga (Sistrurus catenatus) as a threatened 

species. 

Because the SEIS constitutes the biological assessment, the NRC staff submitted a copy of the 

DSEIS, upon its issuance, to the FWS for review in accordance with 50 CFR 402.12(j). In 

comments on the DSEIS, FWS (2015) stated that they concur with the NRC’s determination that 

the proposed action would have “no effect” on the Karner blue butterfly (Lycaeides melissa 

samuelis), northern riffleshell (Epioblasma torulosa rangiana), snuffbox mussel (Epioblasma 

triquetra), and rayed bean mussel (Villosa fabalis). FWS (2015) also notes that its concurrence 

on the NRC’s “no effect” determination is not required.. In addition, FWS (2015) concurred with 

the NRC’s determination that the proposed action “may affect, but is not likely to adversely 

affect” five listed species, the red knot (Calidris canutus), piping plover (Charadrius melodus), 

Indiana bat (Myotis sodalis), eastern prairie fringed orchid (Platanthera leucophaea), and 

northern long-eared bat (Myotis septentrionalis), which may occur within the action area. 

Since the publication of the DSEIS, the NRC staff has not identified any new information that 

would change its “no effect” determinations regarding Federally listed or proposed species or 

critical habitats. Thus, the NRC has fulfilled its obligations under section 7 of the ESA with 

respect to its review of the Fermi license renewal application. Table C–1 lists the letters, 

e-mails, and other correspondence related to the NRC’s ESA review. Because this SEIS 

constitutes the NRC’s biological assessment, the NRC staff will submit a copy of this SEIS, 

upon its issuance, to the FWS for review in accordance with 50 CFR 402.12(j).
Appendix C

C-3 

Table C–1. ESA Section 7 Consultation Correspondence

Date

Sender and 

Recipient Description ADAMS No. (a)

July 1, 2014 D. Wrona (NRC)

to T. Melius (FWS)

Request for concurrence with list of 

Federally listed species and habitats for 

the proposed Fermi license renewal

ML14164A037

July 30, 2014 T. Dandridge (FWS)

to M. Moser (NRC)

Concurrence with the NRC’s list of 

Federally

listed species and habitats

ML14219A743

October 28, 2015 D. Wrona (NRC) to S. 

Hicks (FWS)

Availability of the DSEIS for the 

proposed Fermi license renewal and the 

NRC’s ESA determinations

ML15288A167

December 7, 2015 S. Hicks (FWS) to D. 

Wrona (NRC)

Concurrence with NRC’s effect 

determination for Federally listed species

ML16029A074

These documents can be accessed through the NRC’s Agencywide Documents Access and Management System 

(ADAMS) at http://adams.nrc.gov/wba/. 

C.4 Essential Fish Habitat Consultation

The NRC must comply with the Magnuson–Stevens Fishery Conservation and Management 

Act, as amended (16 U.S.C. 1801–1884, herein referred to as Magnuson–Stevens Act) for any 

actions authorized, funded, or undertaken, or proposed to be authorized, funded, or undertaken 

that may adversely affect essential fish habitat (EFH). 

In Sections 3.8 and 4.8 of this SEIS, the NRC staff concludes that NMFS has not designated 

EFH under the Magnuson–Stevens Act in Lake Erie and that the proposed Fermi 2 license 

renewal would have no effect on EFH. Thus, the Magnuson–Stevens Act does not require the 

NRC to consult with NMFS for the proposed Fermi 2 license renewal.

C.5 Section 106 Consultation

The National Historic Preservation Act of 1966, as amended (NHPA), requires Federal agencies 

to consider the effects of their undertakings on historic properties and consult with applicable 

state and Federal agencies, tribal groups, and individuals and organizations with a 

demonstrated interest in the undertaking before taking action. Historic properties are defined as 

resources that are eligible for listing on the National Register of Historic Places. The historic 

preservation review process (Section 106 of the NHPA) is outlined in regulations issued by the 

Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800. In accordance with 

36 CFR 800.8(c), the NRC has elected to use the NEPA process to comply with its obligations 

under Section 106 of the NHPA.

Table C–2 lists the chronology of consultation and consultation documents related to the NRC 

Section 106 review of the Fermi 2 license renewal. The NRC staff is required to consult with the 

noted agencies and organizations in accordance with the statutes listed above.
Appendix C

C-4 

Table C–2. NHPA Correspondence

Date

Sender and 

Recipient Description ADAMS No. (a)

July 8, 2014 D. Wrona (NRC) to 

B. Conway, 

Michigan Historical

Center

Request for scoping comments/

notification of Section 106 review

ML14157A383

July 8, 2014 D. Wrona (NRC) to 

R. Nelson (ACHP)

Request for scoping comments/

notification of Section 106 review

ML14155A207

July 8, 2014 D. Wrona (NRC) to 

D. Shalifoe Sr., 

President, 

Keweenaw Bay 

Indian Community 

Request for scoping comments

concerning the Fermi 2 LRA review 

(notification of Section 106 review) 

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

L. Carrick, Sr., 

Chairman, 

Bay Mills Indian 

Community

Request for scoping comments

concerning the Fermi 2 LRA review 

(notification of Section 106 review) 

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

A. Pedwaydon, 

Council Chair, 

Grand Traverse 

Band of Ottawa 

and Chippewa 

Indians

Request for scoping comments

concerning the Fermi 2 LRA review 

(notification of Section 106 review) 

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

J. Williams Jr., 

Tribal Chairman, 

Lac Vieux Desert 

Band of Lake 

Superior

Chippewa Indians

Request for scoping comments

concerning the Fermi 2 LRA review 

(notification of Section 106 review) 

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

F. Kiogima, Tribal 

Chairman, 

Little Traverse Bay 

Bands of Odawa 

Indians

Request for scoping comments

concerning the Fermi 2 LRA review 

(notification of Section 106 review) 

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

J. Warren, 

Chairman, 

Pokagon Band of 

Potawatomi Indians

Request for scoping comments

concerning the Fermi 2 LRA review 

(notification of Section 106 review) 

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

A. Payment, Tribal 

Chairperson, 

Sault Ste. Marie 

Tribe of Chippewa

Indians of Michigan

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354
Appendix C

C-5 

Date

Sender and 

Recipient Description ADAMS No. (a)

July 8, 2014 D. Wrona (NRC) to 

K. Meshigaud, Tribal 

Chairperson, 

Hannahville Indian 

Community

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

H. Mandoka, 

Chairman, 

Nottawaseppi Huron 

Band of the 

Potawatomi

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

S. Pago, Chief, 

Saginaw Chippewa 

Indian Tribe of 

Michigan

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

D. Sprague, Tribal 

Chairman, Matche-be-nash-she-wish 

Band of 

Pottawatomi Indians 

of Michigan

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

L. Romanelli, 

Ogema, 

Little River Band of 

Ottawa Indians

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

H. Frank, Chairman, 

Forest County 

Potawatomi

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

R. Sparkman, Chief, 

Shawnee Tribe

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

C. Watkins, Acting 

President, Delaware 

Nation

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

B. Friend, Chief, 

Wyandotte Nation

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354

July 8, 2014 D. Wrona (NRC) to 

E. Cook, Chief, 

Ottawa Tribe of 

Oklahoma

Request for scoping comments 

concerning the Fermi 2 LRA review 

(notification of Section 106 review)

ML14157A354
Appendix C

C-6 

Date

Sender and 

Recipient Description ADAMS No. (a)

November 3, 2015 D. Wrona (NRC) to 

R. Nelson, Office of 

Federal Agency 

Programs, Advisory 

Council on Historic 

Preservation

Notice of availability of Fermi 2 DSEIS ML15294A101

November 3, 2015 D. Wrona (NRC) to 

B. Conway, 

Michigan Historical 

Center

Notice of availability of Fermi 2 DSEIS ML15294A196

November 3, 2015 D. Wrona (NRC) to 

W. Swartx, 

President, 

Keweenaw Bay 

Indian Community

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

L. Carrick, 

Chairman, Bay Mills 

Indian Community

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

A. Pedwaydon,

Council Chair, 

Grand Traverse 

Band of Ottawa and 

Chippewa Indians

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

J. Williams, Jr., 

Tribal Chairman, 

Lac Vieux Desert 

Band of Lake 

Superior

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

R. Gasco-Bentley, 

Tribal Chairperson, 

Little Traverse Bay 

Bands of Odawa 

Indians

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

J. Warren, 

Chairman, Pokagon 

Band of Potawatomi 

Indians

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

A. Payment, Tribal 

Chairperson, Sault 

Ste. Marie Tribe of 

Chippewa Indians of 

Michigan

Notice of availability of Fermi 2 DSEIS ML15293A442
Appendix C

C-7 

Date

Sender and 

Recipient Description ADAMS No. (a)

November 3, 2015 D. Wrona (NRC) to 

K. Meshigaud, Tribal 

Chairperson, 

Hannahville Indian 

Community

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

D. Green, 

THPO/Chief 

Planning Officer, 

Nottawaseppi Huron 

Band of Potawatomi

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

S. Pego, Chief, 

Saginaw Chippewa 

Indian Tribe of 

Michigan

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

D. Sprague, Tribal 

Chairman, 

Matche-be-nashshe-which Band of 

Potawatomit Indians 

of Michigan

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

L. Romanelli, 

Ogema, Little River 

Band of Ottawa 

Indians

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

H. Frank, Chairman, 

Forest County 

Potawatomi

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

R. Sparkman, Chief, 

Shawnee Tribe

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

K. Holton, President, 

Delaware Nation

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

B. Friend, Chief, 

Wyandotte Nation

Notice of availability of Fermi 2 DSEIS ML15293A442

November 3, 2015 D. Wrona (NRC) to 

E. Cook, Chief, 

Ottawa Tribe of 

Oklahoma

Notice of availability of Fermi 2 DSEIS ML15293A442

These documents can be accessed through the NRC’s Agencywide Documents Access and Management System 

(ADAMS) at http://adams.nrc.gov/wba/. 
Appendix C

C-8 

C.6 References

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of historic properties.”

50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

“Interagency cooperation—Endangered Species Act of 1973, as amended.”

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

[FWS] U.S. Fish and Wildlife Service. 2013. “Consultations: Frequently Asked Questions.” 

Available at <http://www.fws.gov/endangered/what-we-do/faq.html#8> (accessed 

20 June 2014).

[FWS] U.S. Fish and Wildlife Service. 2015. Letter from S. Hicks, FWS, to D. Wrona, NRC, 

Subject: Re: Submittal of Draft Supplemental Environmental Impact Statement for License 

Renewal of Fermi 2 and request for concurrence under section 7 of the Endangered Species 

Act. December 7, 2015. ADAMS No. ML16029A074. 

[FWS and NMFS] U.S. Fish and Wildlife Service and National Marine Fisheries Service. 1998. 

Endangered Species Consultation Handbook: Procedures for Conducting Consultation and 

Conference Activities under Section 7 of the Endangered Species Act. March 1998. 315 p. 

Available at <http://www.fws.gov/endangered/esa-library/pdf/esa_section7_handbook.pdf> 

(accessed 8 July 2013).

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

16 U.S.C. § 1801–1884.

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.
CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

D-1 

D. Chronology of Environmental Review Correspondence

This appendix, along with Appendix C, contains a chronological listing of correspondence 

between the U.S. Nuclear Regulatory Commission (NRC) and external parties as part of its 

environmental review for Fermi 2. Appendix C contains the chronological listing of consultation 

correspondence associated with the Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.), 

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

(16 U.S.C. 1801–1884), and the National Historic Preservation Act, as amended 

(54 U.S.C. 300101 et seq.). Appendix D contains all other correspondence. 

All documents, with the exception of those containing proprietary information, are available 

electronically in the NRC’s Library, which is found on the Internet at the following Web address: 

http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC’s 

Agencywide Documents Access and Management System (ADAMS), which provides text and 

image files of the NRC’s public documents. The ADAMS number for each document is included 

in the following list. If you need assistance in accessing or searching in ADAMS, contact the 

Public Document Room Staff at 1-800-397-4209.

D.1 Environmental Review Correspondence

Table D–1 lists the environmental review correspondence in date order beginning with the 

request by DTE Electric Company (DTE or the applicant) to renew the operating license for 

Fermi 2.

Table D–1. Environmental Review Correspondence

Date Correspondence Description ADAMS No.

Apr 24, 2014 DTE Electric Company (DTE) LRA for Fermi 2 ML14121A554

May 5, 2014 U.S. Nuclear Regulatory Commission (NRC) Federal Register 

Notice (FRN) of Receipt and Availability of the LRA for Fermi 2

ML14098A284

May 5, 2014 NRC Letter to DTE, Notice of Receipt and Availability ML14097A168

Jun 11, 2014 NRC Letter to DTE, Determination of Acceptability and 

Sufficiency for Docketing, Proposed Review Schedule, and 

Opportunity for a Hearing Regarding the Application from DTE 

for Renewal of the Operating License for Fermi 2

ML14150A416

Jun 11, 2014 NRC FRN of Acceptability and Opportunity Request Hearing ML14150A340

Jun 20, 2014 NRC Letter to DTE, Notice of Intent To Prepare an 

Environmental Impact Statement and Conduct Scoping Process 

for License Renewal for Fermi 2

ML14160B055

Jun 20, 2014 NRC FRN of Notice of Intent To Prepare an Environmental 

Impact Statement and Conduct Scoping Process for License 

Renewal for Fermi 2

ML14161A016

Jul 3, 2014 NRC Letter to Michigan Department of Natural Resources 

(MDNR), Notice of Intent To Prepare an Environmental Impact 

Statement and Conduct Scoping Process for License Renewal 

of Fermi 2

ML14171A427

Jul 8, 2014 NRC Letter to Advisory Council on Historic Preservation,

Fermi 2 LRA Review

ML14155A207
Appendix D

D-2 

Date Correspondence Description ADAMS No.

Jul 8, 2014 NRC Letter to Michigan State Historic Preservation Officer

(SHPO), Fermi 2 LRA Review

ML14157A383

Jul 21, 2014 Scoping Comment of Jim McDevitt on Behalf of Frenchtown 

Charter Township

ML14216A376

Jul 21, 2014 Scoping Comment of Dr. Stephen J. McNew on Behalf of 

Monroe County Intermediate School District

ML14219A583

Jul 22, 2014 Scoping Comment of Randy Richardville ML14219A580

Jul 23, 2014 Fermi 2 License Renewal Process and Environmental Scoping 

Public Meeting Slides

ML14204A058

Jul 24, 2014 Scoping Comment of Michelle Dugan on Behalf of Monroe 

County Chamber of Commerce

ML14234A188

Jul 24, 2014 Transcript from the Fermi 2 Scoping Meeting—Afternoon 

Session

ML14254A465

Jul 24, 2014 Transcript from the Fermi 2 Scoping Meeting—Evening Session ML14254A470

Jul 24, 2014 Scoping Comment of Jessie Pauline Collins ML14234A189

Jul 24, 2014 Scoping Comment of Dick Micka ML14234A190

Jul 24, 2014 Scoping Comment of State Representative Dale W. Zorn on 

Behalf of Michigan State 56th District

ML14234A191

Jul 24, 2014 Scoping Comment of Robert Tompkins on Behalf of DEAR 

Alliance

ML14205A009

Aug 19, 2014 Scoping Comment of Vic and Gail Macks ML14234A339

Aug 19, 2014 Scoping Comment of U.S. Representative Tim Walberg on 

Behalf of State of Michigan, 7th District

ML14234A192

Aug 26, 2014 Scoping Comment of Corinne Carey on Behalf of Don’t Waste 

Michigan

ML14252A140

Aug 26, 2014 Scoping Comment of Joanne Cantoni ML14252A141

Aug 27, 2014 Scoping Comment of Rosemary Doyle ML14252A171

Aug 27, 2014 Scoping Comment of Robert Simpson ML14252A143

Aug 27,2014 Scoping Comment of Mary Ann Baier ML14252A142

Aug 27, 2014 Scoping Comment of Phyllis Oster ML14252A170

Aug 28, 2014 Scoping Comment of Unknown Individual ML14252A172

Aug 28, 2014 Scoping Comment of Ed McArdle on Behalf of Sierra Club, 

Michigan Chapter

ML14259A341

Aug 28, 2014 Scoping Comment of Ken Richards ML14252A173

Aug 28, 2014 Scoping Comment of Sandra Bihn ML14252A175

Aug 29, 2014 Scoping Comment of Jessie Pauline Collins ML14252A139

Aug 29, 2014 Scoping Comment of Carol Izant ML14252A176

Aug 29, 2014 Scoping Comment of David Schonberger ML14252A178

Aug 29, 2014 Scoping Comment of Michael J. Keegan ML14252A138

Aug 29, 2014 Scoping Comment of Michael Keegan on Behalf of Don’t Waste 

Michigan

ML14252A180

Aug 29, 2014 Scoping Comment of Robert Simpson ML14252A177

Aug 29, 2014 Scoping Comment of Mark Farris ML14252A186
Appendix D

D-3 

Date Correspondence Description ADAMS No.

Sep 3, 2014 NRC Letter to DTE, License Renewal Environmental Site Audit 

Regarding Fermi 2

ML14224A353

Sep 18, 2014 NRC Summary of Public Meeting To Discuss the License 

Renewal and Environmental Scoping Processes for Fermi 2

ML14233A450

Sep 22, 2014 Letter from Dan Miskokomon, Chief, Walpole Island First Nation, 

to NRC, Fermi 2 Nuclear Reactor License NPF-43 Extension 

Application

ML14265A490

Oct 3, 2014 NRC Letter to DTE, License Renewal Environmental Site Audit 

Regarding Fermi 2 Severe Accident Mitigation Alternatives 

(SAMAs)

ML14252A831

Oct 15, 2014 NRC Letter to DTE, Summary of the Site Audit Related to the 

Review of the LRA for Fermi 2

ML14274A304

Oct 28, 2014 NRC Letter to DTE, Project Manager Change for the License 

Renewal of Fermi 2

ML14294A792

Oct 31, 2014 Letter from NRC to Dan Miskokomon, Chief, Walpole Island 

First Nation, on the Fermi 2 Nuclear Reactor License NPF-43 

Extension Application

ML14295A239

Nov 10, 2014 NRC Letter to DTE, Requests for Additional Information (RAIs) 

for the Environmental Review of the Fermi 2 LRA

ML14275A004

Nov 17, 2014 Summary of the SAMAs Environmental Site Audit for Fermi 2 ML14294A812

Nov 18, 2014 NRC Letter to DTE, RAIs for the Review of the Fermi 2 SAMAs

Review of the Fermi 2 LRA

ML14308A358

Nov 20, 2014 Summary of Telephone Conference Call Held on 

October 14, 2014, Between NRC and DTE Concerning RAIs 

Pertaining to the Fermi 2 LRA Environmental Review

ML14308A530

Nov 20, 2014 Summary of Telephone Conference Call Held on 

October 20, 2014, Between NRC and DTE Concerning RAIs 

Pertaining to the Fermi 2 LRA Environmental Review

ML14308A598

Dec 9, 2014 DTE Letter to NRC, Response to License Renewal 

Environmental Review RAIs

ML14344B000

Dec 15, 2014 Summary of Telephone Conference Call Held on 

November 17, 2014, Between NRC and DTE Concerning RAIs 

Pertaining to the Fermi 2 LRA Environmental Review

ML14330A263

Jan 9, 2015 DTE Letter to NRC, Response to NRC RAI for the Review of the 

Fermi 2 LRA—SAMAs

ML15009A358

Jan 12, 2015 Summary of Telephone Conference Call Held on 

December 18, 2014, Between NRC and DTE Concerning 

Responses to RAIs Pertaining to the Fermi 2 LRA 

Environmental Review

ML15005A538

Feb 3, 2015 NRC Letter to DTE, RAIs for the Environmental Review of the 

Fermi 2 LRA—SAMAs

ML15026A307

Feb 18, 2015 DTE Letter to NRC, Revision to Response to License Renewal 

Environmental RAI SSSH-1

ML15050A682

Feb 25, 2015 NRC Letter to DTE, Schedule and Project Manager Change ML15051A348

Mar 5, 2015 DTE Letter to NRC, Response to NRC RAI for the Review of the 

Fermi 2 LRA—SAMAs

ML15064A099
Appendix D

D-4 

Date Correspondence Description ADAMS No.

Apr 9, 2015 NRC Letter to DTE, RAI for the Environmental Review of the 

Fermi 2 LRA—SAMAs

ML15092A945

May 8, 2015 DTE Letter to NRC, Response to NRC RAI for the 

Environmental Review of the Fermi 2 LRA—SAMAs Set 3

ML15141A163

May 18, 2015 Summary of March 27, 2015 Telephone Conference Call Held 

Between the U.S. NRC and DTW Electric Company Concerning 

Requests for Additional Information Pertaining to the SAMA

Review of the Fermi 2 License Renewal Application

ML15132A427

Jun 29, 2015 NRC Letter to DTE, Change in the Environmental Review 

Schedule

ML15160A297

Oct 29, 2015 NRC Letter to DTE, Notice of availability of Fermi 2 draft SEIS

(DSEIS)

ML15289A433

Oct 29, 2015 NRC Letter to U. S. EPA, Region 5, Notice of availability of 

Fermi 2 DSEIS

ML15292A378

Nov 6, 2015 Letter from S. McNew, Monroe County Intermediate School 

District, Comments on DSEIS

ML15329A303

Nov 16, 2015 Letter from R. Tompkins, DEAR, Comments on DSEIS ML16021A435

Nov 18, 2015 Letter from M. Dugan, Monroe County Chamber of Commerce, 

Comments on DSEIS

ML16011A031

Nov 24, 2015 Letter from J. Lievens, Monroe County Board of Directors, 

Comments on DSEIS

ML16020A337

Nov 24, 2015 Letter from R. Vergiels, Comments on DSEIS ML16007A007

Nov 30, 2015 Letter from J. Sobczak, DTE Shareholders United, Comments 

on DSEIS

ML15345A439

Nov 30, 2015 Letter from F. Mentel, Comments on DSEIS ML15343A014

Nov 30, 2015 Letter from C. Haugen, Jefferson Schools ML16007A006

Nov 30, 2015 Letter from J. McDevitt, Frenchtown Charter Township ML15356A371

Dec 2, 2015 Letter from S. Pierce, Monroe Center for Health Aging, 

Comments on DSEIS

ML16007A005

Dec 2, 2015 Regulations.gov submittal from M Gruelle, Comments on DSEIS ML15343A420

Dec 2, 2015 Letter from K. Russeau, Community Foundation of Monroe 

County, Comments on DSEIS

ML16011A035

Dec 3, 2015 Letter from R. Micka, Comments on DSEIS ML16011A033

Dec 15, 2015 Letter from V. Kaminskas, DTE, Comments on DSEIS ML15356A368

Dec 17, 2015 E-mail from C. Doherty, Comments on DSEIS ML16004A145

Dec 20, 2015 Regulations.gov submittal from S. Flum, Comments on DSEIS ML16011A020

Dec 20, 2015 Regulations.gov submittal from M. Baier, Comments on DSEIS ML16011A025

Dec 20, 2015 Regulations.gov submittal from G. Lee, Comments on DSEIS ML16011A021

Dec 20, 2015 Regulations.gov submittal from an anonymous individual, 

Comments on DSESI

ML16011A024

Dec 20, 2015 Regulations.gov submittal from T. Schacht, Comments on 

DSEIS

ML16011A018

Dec 20, 2015 Regulations.gov submittal from an anonymous individual, 

Comments on DSEIS

ML16011A026
Appendix D

D-5 

Date Correspondence Description ADAMS No.

Dec 20, 2015 Regulations.gov submittal from M. Hormel, Comments on 

DSEIS

ML16011A023

Dec 20, 2015 Regulations.gov submittal from S. Riopelle, Comments on 

DSEIS

ML16011A022

Dec 20, 2015 Regulations.gov submittal from R. Tuscher, Comments on

DSEIS

ML06011A016

Dec 20, 2015 Regulations.gov submittal from G. Vande Velde, Comments on 

DSEIS

ML16011A017

Dec 20, 2015 Regulations.gov submittal from M. Barnard, Comments on 

DSEIS

ML16011A019

Dec 21, 2015 Letter from K. Westlake, U.S. EPA, Region 5, Comments on 

DSEIS

ML16007A008

Dec 27, 2015 Regulations.gov submittal from P. Barker, Comments on DSEIS ML16011A028

Dec 28, 2015 Regulations.gov submittal from B. Loe, Comments on DSEIS ML16011A029

Dec 28, 2015 Regulations.gov submittal from D. Schonberger, Alliance to Halt 

Fermi 3, Comments on DSEIS

ML16011A030

Dec 30, 2015 E-mail from J. Collins, Citizens’ Resistance at Fermi 2 (CRAFT), 

Comments on DSEIS

ML16007A009

Jan 1, 2016 E-mail from A. Myatt, Alliance to Halt Fermi 3, Comments on 

DSEIS

ML16011A008

Jan 4, 2016 E-mail from M. Muhich, Sierra Club Nuclear Free Michigan, 

Comments on DSEIS

ML16011A011

Jan 4, 2016 Letter from L. Nelson, U.S. Department of Interior (transmitted 

via e-mail from V. Darby), Comments on DSEIS

ML16011A009

Jan 4, 2016 E-mail from S. Michetti, Comments on DSEIS ML16011A012

Jan 4, 2016 E-mail from K. Barnes, Comments on DSEIS ML16011A036

Jan 4, 2016 E-mail from J. Collins, CRAFT, Comments on DSEIS ML16011A010

Jan 5, 2016 E-mail from M. Keegan, Don’t Waste Michigan, Comments on 

DSEIS

ML16011A015

Jan 5, 2016 E-mail from K. Kamps, Beyond Nuclear, Comments on DSEIS ML16011A014

Jan 6, 2016 Letter from J. Micka, Comments on DSEIS Ml16011A034

Jan 6, 2016 Letter from R. Lankford, Comments on DSEIS ML16011A032

Jan 6, 2016 Regulations.gov submittal from an anonymous individual, 

Comments on DSEIS

ML16011A027

Jan 6, 2016 E-mail from M. Keegan, Don’t Waste Michigan, Comments on 

DSEIS

ML16011A013

Jan 13, 2016 Letter from D. Zorn, District 17 Senator, State of Michigan, 

Comments on DSEIS

ML16049A584

Jan 21, 2016 Letter from R. Wicke, Comments on DSEIS ML16021A436

Jul 7, 2016 Letter from NRC to DTE, SAMA RAIs for the Review of the 

Fermi 2 s LRA

ML16188A192

Jul 19, 2016 Letter from DTE to NRC, Response to SAMA RAIs ML16188A192

ACTIONS AND PROJECTS CONSIDERED IN CUMULATIVE ANALYSIS 

E-1 

E. Actions and Projects Considered in Cumulative Analysis

Table E–1 identifies actions and projects considered in the U.S. Nuclear Regulatory 

Commission (NRC) staff’s analysis of cumulative impacts related to the environmental analysis 

of the continued operation of Fermi 2. Potential cumulative impacts associated with these 

actions and projects are addressed in Section 4.16 of this supplemental environmental impact 

statement. Not all actions or projects listed in this appendix are considered in each resource 

area because of the uniqueness of the resource and its geographic area of consideration.

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

Project Name Summary of Project

Approximate Location 

(Relative to Fermi) Status

Nuclear projects

Davis-Besse Nuclear 

Power Station Unit 1 

Nuclear power plant

One 908-MWe Babcock & 

Wilcox pressurized water 

reactor

Ottawa County, OH 

27 mi (43 km) southeast of 

Fermi site on Lake Erie 

Operational 

(FENOC 2014)

Davis-Besse independent 

spent fuel storage 

installation

Dry spent fuel storage On Davis-Besse site Operational 

(NRC 2014)

Coal-fired energy projects

Monroe Power Plant 3,280-MW coal-fired plant 6 mi (10 km) southwest of 

Fermi site on Lake Erie

Operational; completed 

major 

emissions-control

refurbishment in 2014 

(CDB 2014a, 2014b)

Trenton Channel Power 

Plant

520-MW coal-fired plant 12 mi (19 km) 

north-northeast of Fermi 

site on the Detroit River

Operational; DTE 

retired two of the three 

units in 2016 and 

reduced the plant 

capacity from 730 MW 

to 520 MW 

(CDB 2014b; 

News-Herald 2016)

J.R. Whiting Power Plant 328-MW coal-fired plant 14 mi (23 km) 

south-southwest of Fermi 

site on Lake Erie

Retired in 2016 

(Consumers 

Energy 2014; 

EIA 2014; Monroe 

News 2016)

Bayshore Power Plant 136-MW coal-fired plant 20 mi (32 km) 

south-southwest of Fermi 

site on Lake Erie at 

Maumee Bay

Operational 

(FirstEnergy 2014)

River Rouge Power Plant 540-MW coal-fired plant 26 mi (42 km) 

north-northeast of Fermi

site on the Detroit River

Operational 

(DTE 2014)
Appendix E

E-2 

Project Name Summary of Project

Approximate Location 

(Relative to Fermi) Status

Natural Gas-fired energy projects

Oregon Clean 

Energy Center

869-MW natural gas 

combined cycle plant

21 mi (34 km)

south-southwest of Fermi 

site

Under construction; 

scheduled to become 

operational in 2017

(OPSB 2014; 

CME 2016)

Mining Projects

Rockwood Quarry Crushed and broken 

limestone quarry

2.5 mi (4 km)

north-northeast of Fermi

site

Closed (EPA 2014a)

Stoneco Newport Crushed and broken 

limestone quarry

2.5 mi (4 km)

north-northeast of Fermi

site

Operational

(EPA 2014b)

Sylvania Minerals Crushed and broken 

limestone and crushed

silica quarry

6 mi (10 km) 

north-northwest of Fermi 

site

Operational 

(EPA 2014c)

Stoneco Denniston Crushed and broken 

limestone quarry

9 mi (14 km) southwest of 

Fermi site

Operational

(EPA 2014d)

Stoneco Maybee Crushed and broken 

limestone quarry

13 mi (21 km)

west-northwest of Fermi 

site

Operational

(EPA 2014e)

Sibley Quarry Crushed and broken 

limestone quarry

14 mi (23 km) 

north-northeast of Fermi

site

Operational

(EPA 2014f)

Landfills

Rockwood Landfill Industrial landfill; 

construction and debris 

landfill

2.5 mi (4 km) 

north-northeast of Fermi

site

Closed (MDEQ 2014a, 

2016) 

Carleton Farms Municipal solid waste

landfill 

12 mi (19 km) northwest of 

Fermi site

Operational 

(MDEQ 2015)

Riverview Land Preserve Municipal solid waste

landfill

13 mi (21 km) 

north-northeast of Fermi

site

Operational

(MDEQ 2014b)

Sibley Quarry Industrial landfill 14 mi (23 km) 

north-northeast of Fermi

site

Operational

(MDEQ 2014c)

Water supply and treatment facilities

Berlin Township 

Wastewater Treatment 

Plant

Wastewater treatment 

plant that discharges to 

Swan Creek near its 

confluence with Lake Erie

1.1 mi (2 km) northwest of 

Fermi site

Operational 

(EPA 2015a)

Frenchtown Township 

Water Plant

Water treatment plant that 

withdraws water from 

Lake Erie

2 mi (3 km) southwest of 

Fermi site

Operational 

(Frenchtown 

Township 2014)
Appendix E

E-3 

Project Name Summary of Project

Approximate Location 

(Relative to Fermi) Status

Monroe Metropolitan 

Wastewater Treatment 

Facility

Wastewater treatment 

plant that discharges to 

Lake Erie-Plum 

Creek-Levee Channel

6 mi (10 km) southwest of 

the Fermi site on Lake 

Erie

Operational 

(EPA 2015b)

Monroe Water Filtration 

Plant

Water treatment plant that 

withdraws water from 

Lake Erie

7 mi (11 km) southwest of 

Fermi site

Operational 

(EPA 2015c)

Carleton Wastewater 

Treatment Plant

Wastewater treatment 

plant that discharges to 

Swan Creek

9 mi (14 km) northwest of 

Fermi site

Operational; permit 

expired in 2014 

(EPA 2015d, 2016)

Luna Pier Wastewater 

Treatment Plant

Wastewater treatment 

plant that discharges to 

La Pointe Drain

14 mi (23 km) 

south-southwest of Fermi 

site

Operational 

(EPA 2015e)

Various minor NPDES

wastewater discharges

Various businesses with 

smaller wastewater 

discharges

Within 10 mi (16 km) Operational

Manufacturing facilities

Spartan Steel Coating 

LLC

Hot-dipped galvanized 

steel coil processing 

facility

5 mi (8 km) west of Fermi 

site

Operational 

(EPA 2014g)

JCIM Plastics injection molding 

facility

5 mi (8 km) 

west-southwest of Fermi 

site

Operational 

(EPA 2014h)

Spiratex Company Thermoplastic extrusion 

manufacturing facility

5 mi (8 km) 

west-southwest of Fermi 

site

Operational 

(EPA 2014i)

Ventower Industries Wind turbine tower 

manufacturing facility

6 mi (10 km) southwest of 

Fermi site

Operational 

(EPA 2014j)

Guardian Industries Glass plant manufacturing 

facility that discharges into 

Swan Creek

10 mi (16 km) 

north-northwest of Fermi 

site

Operational 

(EPA 2014k)

Oil refineries Plants that refine crude oil 

for other applications

Various locations 

throughout region

Operational

Transportation Projects

Cleveland-Toledo-Detroit

Passenger Rail Line 

Addition to regional 

transportation hub with rail 

lines connecting 

Cleveland, Buffalo, 

Toronto, Pittsburgh, 

Cincinnati, and Detroit

Rail line would pass 

through Monroe County 

on its way to Detroit

Proposed; schedule 

undetermined 

(TMACOG 2011; 

DTE 2014)

Interstate 75 

Improvements

Reconstructing 6 mi 

(10 km) of I-75 through 

Monroe County 

Between Dixie Highway 

and I-275

Construction 

commenced in 2015

with completion 

scheduled for late 2016

(MDOT 2016)
Appendix E

E-4 

Project Name Summary of Project

Approximate Location 

(Relative to Fermi) Status

Parks and recreation sites

Sterling State Park Approximately 1,300 ac 

(530 ha) park on Lake Erie 

coast with campgrounds, 

trails, boat launches, and 

swimming area

Approximately 5 mi (8 km) 

southwest

Operational; managed 

by Michigan 

Department of Natural 

Resources 

(MDNR 2014a)

Maumee Bay State Park 1,336 ac (541 ha) park on 

Lake Erie coast with 

campgrounds, trails, boat 

launches, and swimming 

area

Approximately 20 mi 

(32 km) south-southwest

Operational; managed 

by Ohio State Parks 

(ODNR 2014)

Detroit River International 

Wildlife Refuge

Approximately 6,000 ac 

(2,400 ha) of islands, 

coastal wetlands, 

marshes, shoals, and 

waterfront lands along 

48 mi (77 km) of Detroit 

River and Western Lake 

Erie shorelines. Only 

international wildlife refuge 

in North America. 

Comprised of multiple 

refuge units extending 

north and south of Fermi 

site. The Lagoona Beach 

Unit is adjacent to Fermi.

Operational; managed 

by U. S. Fish and 

Wildlife Service. The 

Lagoona Beach Unit is 

managed cooperatively 

by the refuge in 

partnership with DTE 

Energy (FWS 2014)

River Raisin National 

Battlefield Park

National Battlefield 

commemorating the River 

Raisin Battles during the 

War of 1812 

Approximately 7 mi 

(11 km) southwest

Operational; managed 

by U.S. National Park 

Service (NPS 2014)

Point Mouillee State

Game Area

4,000 ac (1,600 ha) 

freshwater marsh 

restoration project open to 

wildlife viewing and public 

hunting 

Approximately 4.5 mi 

(7 km) northeast

Operational; managed 

by Michigan 

Department of Natural 

Resources 

(MDNR 2014b)

Recreational Areas Various parks, boat 

launches, campgrounds, 

swimming areas 

Within 10 mi (16 km) Operational

Fermi projects

Fermi Nuclear Power 

Plant Unit 1 

Decommissioning of 

shutdown nuclear power

plant

On the Fermi site SAFSTOR (NRC 2014)

Fermi Nuclear Power 

Plant Unit 3

Proposed construction and 

operation of 1,535-MWe 

nuclear power plant

On the Fermi site Combined License

issued May 1, 2015 

(NRC 2015)

Independent spent fuel

storage installation for 

Fermi 2

Dry spent fuel storage On the Fermi site Operational; 

commenced spent fuel

storage in 2014

(DTE 2014; 

DTE Energy 2016)
Appendix E

E-5 

Project Name Summary of Project

Approximate Location 

(Relative to Fermi) Status

Other projects

Future Urbanization Construction of housing 

units and associated 

commercial buildings; 

roads, bridges, and rail; 

and water and wastewater 

treatment and distribution 

facilities and associated 

pipelines as described in 

local land-use planning 

documents

Throughout region Construction may occur 

in the future as 

described in State and 

local land-use planning 

documents

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Appendix E

E-6 

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Appendix E

E-7 

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Appendix E

E-8 

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Rail2.pdf> (accessed 22 December 2014).
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 

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 Introduction

DTE Electric Company (DTE) submitted an assessment of severe accident mitigation 

alternatives (SAMAs) for the Fermi Unit 2 Nuclear Station (Fermi 2), as part of its Environmental 

Report (ER) (DTE 2014). 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 (IPE) (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 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. 

Based on a review of DTE’s SAMA assessment and the onsite SAMA audit held on

October 6–8, 2014 (NRC 2014c), the U.S. Nuclear Regulatory Commission (NRC) staff issued 

requests for additional information (RAI) to DTE by letters dated November 14, 2014 

(NRC 2014a), February 3, 2015 (NRC 2015a), and April 9, 2015 (NRC 2015b). Key questions 

concerned the modeling of loss of offsite power (LOOP) and station blackout (SBO) sequences, 

the comparison of the results of the Fermi 2 PRA with those for other similar plants, results of 

the peer review on the PRA, truncation cutoff used for the Level 2 release category and Level 1 

CDF analyses, additional details on the Level 2 and 3 PRA models including the basis for 

representative sequences for each release category, thermal power levels following a power 

uprate, justification of population estimates, the identification and screening of candidate 

SAMAs, the evaluation of the risk reduction of certain SAMAs, and the basis for the SAMA cost 

estimates. Subsequent followup NRC staff RAIs (NRC 2015a, 2015b) concerned: common 

cause failure of combustion turbine generators (CTGs) due to severe weather, the treatment 

and impact of unaccounted for release category frequency, the impact on SAMA cost benefit 

analysis of a nonconservative treatment of some accident sequences, a reanalysis of the benefit 

of certain SAMAs, and the development of the population within 50 miles (mi) (80 kilometers 

(km)) of Fermi 2. DTE submitted additional information by letters dated January 9, 2015;

March 5, 2015; and May 8, 2015 (DTE 2015a, 2015b, 2015c). DTE’s responses to questions by 

the NRC staff resulted in three new potentially cost-beneficial SAMAs. The NRC staff’s 

concerns were addressed by DTE’s responses and calculations performed by the NRC staff 

during its review. 

An assessment of SAMAs for Fermi 2 is presented below.
Appendix F

F-2 

F.2 Estimate of Risk for Fermi 2 

DTE’s estimates of offsite risk at Fermi 2 are summarized in Section F.2.1. The summary is 

followed by the NRC staff’s review of DTE’s risk estimates in Section F.2.2.

F.2.1 DTE’s Risk Estimates

DTE combined two distinct analyses to form the basis for the risk estimates used in the SAMA

analysis: (1) Level 1 and Level 2 PRA models for Fermi 2 and (2) a supplemental analysis of 

offsite consequences and economic impacts (essentially a Level 3 PRA model) developed 

specifically for the SAMA analysis. The Level 1 model is a significant upgrade and revision of 

the IPE Level 1 model while the Level 2 model is an update of the IPE Level 2 model. The 

SAMA analysis is based on the most recent Level 1 and Level 2 PRA models available for 

Fermi 2 at the time of the ER, referred to as the Fermi 2 Version 9 (FermiV9) PRA model. The 

scope of this Fermi 2 PRA includes internal floods but does not include a separate PRA for 

external events at Fermi 2. 

The Fermi 2 CDF from internal events is approximately 1.5×10−6 per year (DTE 2014). DTE did 

not explicitly include the contribution from external events within the Fermi 2 SAMA risk 

estimates; however, it did account for the potential risk reduction benefits associated with 

external events by multiplying the estimated benefits for internal events by 11. This is 

discussed further in Section F.2.2.2. 

The breakdown of CDF by initiating event is provided in Table F–1. As shown in this table, 

events initiated by a total LOOP, a turbine trip with bypass, and a medium loss-of-coolant

accident (LOCA) below the top of the active fuel are the dominant contributors to the CDF. DTE 

identified that SBO contributes 8.4×10−8 per year, or 5.6 percent of the total internal events CDF 

while anticipated transients without scram (ATWS) contribute 2.0×10−7 per year, or 

approximately 13 percent, of the total CDF (DTE 2014). 

Table F–1. Fermi 2 CDF for Internal Events

Initiating Event

CDF(a)

(per year)

Percent CDF

Contribution

Total LOOP 2.1×10−7 14

Turbine Trip with Bypass 2.0×10−7 13

Medium LOCA below the Top of Active Fuel 1.6×10−7 10

Nominal Rupture in Fire Protection System Line in Auxiliary Building 

Propagating to Relay Room

1.1×10−7 7

Medium LOCA in Low-Pressure Coolant Injection (LPCI) Line 1.1×10−7 7

Medium LOCA in Feedwater (FW) Line 6.0×10−8 4

Loss of Condenser Vacuum 5.3×10−8 4

Major Rupture in Circulating Water Pipe or Expansion Joints in 

Turbine Building.

5.2×10−8 3

Interfacing System LOCA in Residual Heat Removal (RHR) 

Shutdown Cooling Line (X-12)

5.1×10−8 3

Manual Shutdown 4.4×10−8 3

Partial LOOP for Division 2 3.8×10−8 3

Loss of Bus #301 3.7×10−8 2
Appendix F

F-3 

Initiating Event

CDF(a)

(per year)

Percent CDF

Contribution

Nominal Rupture in Reactor Building Closed Cooling Water 

(RBCCW)/ Emergency Equipment Cooling Water (EECW) 

Division 2 Line in Direct Current (DC) Switchgear Room

3.3×10−8 2

Other Initiating Events(b) 3.5×10−7 24

Total (Internal Events)(c) 1.5×10−6 100

(a) CDF based on Fussell-Vesely importance (DTE 2015a) and total CDF.

(b) Other initiating event each contributing less than 2 percent to total CDF. 

(c)Column totals may be different because of rounding.

Source: DTE 2015a

The Fermi 2 Level 2 PRA model that forms the basis for the SAMA was “...developed as part of 

the FermiV9 internal events PRA model” (DTE 2014) and incorporates the significant 

improvement in severe accident response coupled with plant modifications and improved 

understanding of severe accident core melt progression since the original IPE model 

(DTE 2015a).

The Level 2 model utilizes containment event trees (CETs) to assess the accident progression 

following a core damage event and contains both phenomenological and containment system 

status events. The Level 1 core damage sequences are binned into plant damage states 

(PDSs) or accident classes, which provide the interface between the Level 1 and Level 2 CET 

analysis. Each PDS bin is then entered into the CET. The CET is linked directly to the Level 1 

event trees, and CET nodes are evaluated using supporting fault trees.

The result of the Level 2 PRA is a set of 13 release categories, with their respective frequency 

and release characteristics. The results of this analysis for Fermi 2 are provided in 

Tables D.1–10, D.1–14, and D.1–15 of the ER (DTE 2014). The categories were defined based 

on the timing of release (three release time ranges) and the magnitude of release (four release 

magnitude ranges). One additional release category was included for an intact containment. 

Releases with intact containment were evaluated using the maximum design basis leakage of 

0.5 percent of the containment air weight per day.

For use in the SAMA analysis, the release category for high magnitude and early timing was 

divided into two bins (one for containment isolation and one without). Due to the small release 

category contributions from 3 categories, the number of release category bins was reduced to 

11 cases. The frequency of each release category was obtained by summing the frequency of 

the individual accident progression CET endpoints binned into the release category. Source 

terms were developed for each of the 13 release categories using the results of MAAP 

Version 4.0.7 computer code calculations (DTE 2014). 

DTE computed offsite consequences for potential releases of radiological material using the 

MACCS2 version 3.7.0 code and analyzed exposure and economic impacts from DTE’s

determination of offsite and onsite risks. Inputs for these analyses include plant-specific and 

site-specific input values for core radionuclide inventory, source term and release 

characteristics, site meteorological data, projected population distribution and growth within a 

50-mi (80-km) radius, emergency response evacuation modeling, and economic data. The 

estimation of onsite impacts (in terms of cleanup and decontamination costs and occupational 

dose) is based on guidance in NUREG/BR–0184 (NRC 1997a). In its calculation for 

replacement power costs, DTE accounted for the increased electric power output of Fermi 2 
Appendix F

F-4 

compared to the generic reactor power output presented in NUREG/BR–0184 (NRC 1997a) and 

adopted by the Nuclear Energy Institute’s (NEI) guidance document (NEI 2005).

In the ER, DTE estimated the dose risk to be 0.0491 person-sievert (Sv) per year 

(4.91 person-rem per year) to the population within 50 mi (80 km) of the Fermi 2 site. The 

offsite economic cost risk was calculated to be $15,600 per year. The breakdown of the 

population dose risk by containment release mode is summarized in Table F–2. The two 

categories for high magnitude, early releases accounted for approximately 78 and 68 percent of 

the population dose risk and offsite economic cost risk, respectively. The high magnitude, 

intermediate release category accounted for 14 and 24 percent of the population dose risk and 

offsite economic cost risk, respectively.

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

Economic Cost Risk for Internal Events

Release Mode Population Dose Riska Offsite Economic Cost Risk

IDb

Frequency

(per year) person-rem/yr % Contribution $/yr % Contribution

H/E-BOCc 5.9×10−8 1.3×100 26 1.8×103 12

H/E 3.1×10−7 2.5×100 52 8.8×103 56

H/I 7.2×10−8 6.9×10−1 14 3.8×103 24

H/L 2.5×10−10 2.2×10−3 <0.1 4.1×100 <0.1

M/E 6.2×10−8 1.5×10−1 3 5.2×102 3

M/Id 3.7×10−8 1.0×10−1 2 2.3×102 2

L/E 4.4×10−8 9.9×10−3 0.2 9.9×10−1 <0.1

L/Id 5.5×10−8 1.2×10−1 2 4.5×102 3

LL/E 5.0×10−10 6.6×10−6 <0.1 1.9×10−4 <0.1

LL/Id 7.8×10−8 1.0×10−2 0.2 3.1×10−1 <0.1

CI 7.8×10−7 5.1×10−5 <0.1 1.5×10−6 <0.1

Total 1.5×10−6 4.9×100 100 1.6×104 100

a Unit Conversion Factor: 1 Sv = 100 rem

b Release Mode Nomenclature (Magnitude/Timing)

c Contributions to Large Early Release Frequency from break outside containment (BOC) and interfacing system 

LOCA initiators 

d The release categories for Late (L) timing were subsumed into the Intermediate (I) release categories for Medium 

(M), Low (L), and Low-Low (LL) releases. 

Magnitude: 

High (H) - Greater than 10 percent release fraction for cesium iodide (CsI)

Medium (M) - 1 to 10 percent release fraction for CsI

Low (L) - 0.1 to 1 percent release fraction for CsI

Low-Low (LL) - Less than 0.1 percent release fraction for CsI

Containment intact (CI) - Much less than 0.1 percent release fraction for CsI

Timing: 

Early (E) - Less than 4 hours

Intermediate (I) - 4 to 24 hours

Late (L) - Greater than 24 hours

Source: DTE 2014
Appendix F

F-5 

F.2.2 Review of DTE’s Risk Estimates

DTE’s determination of offsite risk at the Fermi 2 site is based on the following three major 

elements of the analysis:

(1) Level 1 risk model that supersedes the 1992 IPE submittals (DECo 1992) and the 

fire, seismic, and other external event analyses of the 1996 IPEEE submittal 

(DECo 1996);

(1) Revised Level 2 risk model and MAAP source term analysis;

(2) MACCS2 analyses performed by DTE to translate fission product source terms and 

release frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed by the NRC staff to determine the acceptability of DTE’s 

risk estimates for the Fermi 2 SAMA analysis, as summarized below. 

F.2.2.1 Internal Events CDF Model

The NRC staff’s review of the Fermi 2 IPE is described in its 1994 NRC memorandum 

(NRC 1994). Based on its review of the Fermi 2 nuclear power plant IPE submittal and 

associated documentation, the NRC staff concluded that the licensee met the intent of Generic 

Letter 88-20 (NRC 1988). As indicated in the NRC staff review, while the licensee concluded 

that no vulnerabilities exist at Fermi 2, the licensee identified many insights that were later used 

to identify enhancements for Fermi 2. These are discussed in Section F.3.2.

There have been numerous revisions to the Fermi 2 PRA since the original 1992 IPE submittal. 

A listing of the complete revision history of the Fermi 2 PRA since the original IPE submittal was 

provided in the ER (DTE 2014) and in response to an NRC staff request for additional 

information (RAI) (DTE 2015a) and is summarized in Table F–3. A comparison of the internal 

events CDF between the 1992 IPE and the current PRA model indicates there has been a 

reduction in total CDF from 5.7×10−6 per year to 1.3×10−6 per year.

1

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

PRA 

Model Summary of Significant Changes from Prior Model

CDF(a)

(per year)

LERF(a)

(per year)

IPE (1992) IPE Submittal 5.7×10−6 8.0x10−7

PSA97C

(1997)

Numerous changes to reflect plant modification and model 

enhancements

7.1×10−6 1.2×10−6

FermiV2

(2002)

CDF Model Converted from RISKMAN

to CAFTA

5.0×10−6 Not Available

FermiV3

(2002)

Normal PRA model maintenance including Fermi-specific data 

used to update initiating event frequencies, component failure 

frequencies, and common cause event data

Test and maintenance based upon data obtained from plant 

operating experience

CAFTA Level 2 Model developed

3.3×10−6 2.5×10−7

FermiV4

(2003)

Test and maintenance unavailability based upon the 

Maintenance Rule performance criteria

5.8×10−6 9.3×10−7

 

1 The 1.3×10−6 per year total CDF excludes the internal flood CDF as it is not included in the IPE value.
Appendix F

F-6 

PRA 

Model Summary of Significant Changes from Prior Model

CDF(a)

(per year)

LERF(a)

(per year)

FermiV6(b)

(2004)

Normal PRA model maintenance

Included revised HRA using HRA Calculator

Incorporated several recommendations from the 1997 peer 

review

6.1×10−6 4.8×10−7

FermiV7

(2006)

Included HRA dependent action basic events 

Added Black Start DG with 11-2,11-3, and 11-4 CTGs

Updated LOOP initiating event frequencies

Incorporated additional recommendations from the 1997 peer 

review

1.4×10−5 5.5×10−7

FermiV8

(2010)

Periodic update

Expanded the mutually exclusive event file to exclude many 

nonrepresentative maintenance configurations

Updated the maintenance unavailability terms 

Changed RPS mechanical and electrical “failure to scram” 

values to align with current accepted industry benchmark 

values

2.3×10−6 3.1×10−7

FermiV9

DRAFT

Complete model upgrade including: initiating events, success 

criteria, data, system notebooks, HRA, internal flood, 

MAAP 4.0.7 analyses, and Level 2/LERF

Test and maintenance unavailability based upon data 

obtained from plant operating experience

1.3×10−6 3.9×10−7

FermiV9

(2013)

Changes to respond to peer review findings including:

elimination of credit for terminating certain flood events, 

corrected HPCI/RCIC fail to start type code failure rate, and 

added dependent human failure event to operate high

pressure injection systems

Corrected other significant modeling issues including: 

elimination of some ATWS and LERF non-minimal cutsets 

and lowered human error probability based on added time 

available from MAAP analysis

1.5×10−6 3.7×10−7

(a) Models FermiV4, FermiV6, FermiV7, and FermiV8 included pre-IPE internal flood initiating event modeling. The 

FermiV9 model includes a new internal flood analysis.

(b) The FermiV5 model was not issued.

Key: CDF = core damage frequency; CTG = combustion turbine generator; DG = diesel generator; HPCI = high 

pressure coolant injection; HRA = human reliability analysis; IPE = individual plant examination; LERF = large 

early release frequency; LOCA = loss-of-coolant accident; LOOP = loss of offsite power; NRC = U.S. Nuclear 

Regulatory Commission; PRA = probabilistic risk assessment; RCIC = reactor core isolation cooling; 

RPS = reactor protection system

Sources: DTE 2014 and DTE 2015a

The CDF value from the 1992 IPE (5.7×10−6 per year) is well below the average of the CDF 

values reported in the IPEs for boiling water reactors (BWR) 3/4 plant units. NUREG–1560 

gives the average for the group of BWR 3/4 units to be 2×10−5 per year with the reported values 

ranging from 9×10−8 per year to 8×10−5 per year (NRC 1997b). It is recognized that other plants 

have updated the values for CDF subsequent to the IPE submittals to reflect modeling and 

hardware changes.
Appendix F

F-7 

The current internal events CDF result for Fermi 2 (1.5×10−6 per year) is considerably less than 

that for other plants of similar vintage and characteristics. In response to an NRC staff RAI to 

explain the reasons for this disparity, DTE identified the following Fermi 2 features that are 

responsible for this low CDF (DTE 2015a):

• Fermi 2 has a standby feedwater system that is not found at other BWRs. It consists 

of two motor driven pumps, although only one is needed for most scenarios. One 

pump is powered by Division 2 and the other pump is powered by Division 1, which 

has combustion turbine generators (CTGs) backup. This system is credited early in 

general transient and LOOP scenarios and is a backup to high-pressure coolant 

injection (HPCI) and reactor core isolation coolant (RCIC). 

• Fermi 2 has a residual heat removal (RHR) complex, which contains two divisions of 

the ultimate heat sink. This facility contains the emergency diesel generators

(EDGs), RHR service water (RHRSW) pumps, diesel generator service water 

pumps, and EESW pumps. This building is protected from design basis tornados. 

The ultimate heat sink has adequate inventory for 7 days without makeup.

• Fermi 2 has two independent switchyards. Division 1 offsite power is provided by a 

120 kV switchyard fed from three offsite lines. Division 2 offsite power is provided by 

a 345 kV switchyard fed from two offsite lines. These switchyards are electrically 

and spatially separated. There is the ability to cross-tie from one division to the other 

using a maintenance tie breaker.

• Fermi 2 has four EDGs (two EDGs support Division 1 and two EDGs support 

Division 2). One EDG can provide adequate power to shut down the plant in general 

transients and LOOP. Fermi 2 also has four CTGs. The CTGs provide power to the 

Division 1 switchyard, which in turn can provide power to the standby feedwater 

system. CTG 11-1 has blackstart capability from the control room for SBOs, and 

units 11-2, 11-3, and 11-4 can be manually aligned for blackstart using a standby 

diesel generator.

• Fermi 2 has several closed cooling water systems used to cool plant systems. The 

benefit is that these closed cooling water systems have a finite amount of water that

leads to a reduced internal flooding impact.

The NRC staff considered the peer review performed for the Fermi 2 PRA, and the potential 

impact of the review findings on the SAMA evaluation. In the ER (DTE 2014), DTE described 

the August 2012 Boiling Water Reactor Owners Group (BWROG) peer review of the Fermi 2 

PRA. In response to an NRC staff RAI, DTE clarified that the peer review was performed on a 

draft of the FermiV9 PRA (DTE 2015a). The peer review was stated to be performed consistent 

with Regulatory Guide 1.200, Rev. 2 (NRC 2009) and utilized the American Society of 

Mechanical Engineers (ASME) PRA standards (ASME and ANS 2009). DTE stated that the 

peer review resulted in 28 findings and provided a tabulation of the status and resolution of each 

finding.

All but four of the findings were considered “closed” by DTE. The NRC staff reviewed the stated 

resolution of the “closed” findings. On the basis of this review and DTE’s response 

(DTE 2015a) to an NRC staff RAI requesting clarification, the NRC staff agrees that those 

findings could be considered closed for the purposes of the SAMA analysis.

The four findings not considered “closed” were described by DTE as having been “addressed.” 

These findings were related to the methodology employed by DTE in performing the human 

reliability analysis (HRA) dependency analysis and its appropriateness. Although the 

methodology employed was not considered an industry standard method by the peer review 
Appendix F

F-8 

team, DTE stated “that a review of the quantitative results by an Expert Panel (composed of 

personnel from two nonaffiliated PRA consulting firms and members of the DTE PRA staff) prior 

to the Peer Review concluded that the quantification results (including HRA) dependency 

groupings) were representative of the as-built, as-operated plant and were reasonable with 

respect to similar plants. Based upon this quantification analysis, findings related to the HRA 

dependency analysis are deemed by DTE to not significantly affect risk-informed applications 

including the SAMA analysis. On the basis of the conclusions of the expert panel review and 

DTE clarification (DTE 2015a) that the same PRA model (FermiV9 draft) was the subject of both 

the peer review and the expert panel review and only one change to correct an error found by 

the peer review was made in the HRA dependency analysis between the FermiV9 draft and the 

versions used for the license renewal (FermiV9), the NRC staff concludes that the Fermi 2 HRA 

dependency analysis is adequate for the SAMA application.

The NRC staff has determined that DTE’s disposition of the peer review findings is consistent 

with the NEI guidance (NEI 2005). The NRC staff also finds the final resolution of the findings 

provides reasonable assurance of minimal impacts on the results of the SAMA analysis.

In an RAI, the NRC staff requested that DTE briefly discuss the modeling of the LOOP and SBO 

scenarios, including how the CTGs are incorporated in the model and if common cause loss of 

alternating current (AC) due to weather is considered. As discussed above, at Fermi 2 there are 

two separate switchyards (120 kV and 345 kV), each of which supplies offsite power to a single 

“division” of engineered safety feature (ESF) and balance of plant power. The LOOP initiators 

are referred to as “divisional Loss of Offsite Power (LOOP)” or partial LOOP events. These 

partial LOOP events are processed via the general transient event tree. Consequential losses 

of offsite power are modeled as “total” LOOPs and are processed via the LOOP event tree. The 

failure of the emergency AC power systems following a LOOP would result in what is commonly 

referred to as SBO or the complete loss of all AC power to the unit. At Fermi 2, this result 

requires the failure of the AC power from both switchyards, failure of the emergency diesels 

available to the unit, and failure of the interconnection with the onsite gas turbines. The SBO 

event tree considers the ability for direct current (DC)-powered high pressure systems (HPCI 

and/or RCIC) to provide high pressure reactor pressure vessel (RPV) makeup, manual 

depressurization per the emergency operating procedures, the ability to recover offsite power 

(at various time points in the sequence), and the ability to successfully mitigate core damage in 

the long term following successful recovery of offsite power.

The LOOP models include weather-centered total and partial LOOP events along with a 

common cause failure of all four CTGs. The model specifically includes the following: 

(1) common cause failure of all four CTGs in the event of a weather-centered “total” LOOP, and

(2) common cause failure of all four CTGs in the event of a weather-centered loss of the 120 kV 

(Division 1) switchyard. 

The NRC staff noted in an RAI, that the common cause failure of all four CTGs in the event of a 

weather-centered loss of the 345 kV switchyard is not included in the model. DTE indicated that 

there were several reasons for not including weather-centered loss in the model. First, the 

CTGs are electrically connected to the 120 kV switchyard. Second, the common cause failure 

of a weather-centered loss of 345 kV switchyard and all four CTGs without affecting the 120 kV 

switchyard is not deemed a credible scenario due to the large spatial separation between the 

120 kV and 345 kV switchyards. If there were a weather phenomenon large enough to affect 

both the 345 kV switchyard and the CTGs, it would also affect the 120 kV switchyard

(DTE 2015b).

DTE stated that the FermiV9 model reflects the Fermi 2 as-built, as-operated configuration as of 

June 30, 2011. One subsequent plant modification included in the model is the addition of a 
Appendix F

F-9 

third breaker row to the existing ring bus configuration in the 345-kV switchyard. In addition, 

one planned modification, the measurement uncertainty recapture (MUR) power uprate, is 

included in the SAMA analysis. The small change in the current licensed power, an increase of 

1.64 percent, does not have any impact on the PRA model, but the increase in power is 

included in the Level 3 analysis for the calculation of maximum averted cost risk (MACR). In 

response to an NRC staff RAI, DTE confirmed that a review of all modifications since the freeze 

date have been evaluated. Other than the items discussed above, DTE indicated that pending 

Fukushima modifications will not have an adverse impact on the SAMA analysis, and that in 

addition, no operating practice/procedure changes have been identified that would have an 

adverse impact on the SAMA assessment (DTE 2015a). 

On the basis of the NRC staff’s evaluation of internal events previously described in this 

subsection, the NRC staff concludes that the internal events Level 1 PRA model is of sufficient 

quality to support the SAMA evaluation.

F.2.2.2 External Events

As previously indicated, the Fermi 2 PRA used for the SAMA analysis does not include external 

events. In the absence of such an analysis, DTE used the Fermi 2 IPEEE to identify the highest 

risk accident sequences and the potential means of reducing the risk posed by those sequences 

and to estimate the benefit of potential SAMAs, as discussed below and in Section F.3.2.

The Fermi 2 IPEEE was submitted in March 1996 (DECo 1996) in response to Supplement 4 of 

Generic Letter (GL) 88-20 (NRC 1991). The submittal included a seismic margin assessment 

(SMA), a fire assessment using the Electric Power Research Institute (EPRI) fire-induced 

vulnerability evaluation (FIVE) guidance (EPRI 1992), and a screening analysis for other 

external events, such as high winds, floods, and other external events (HFO). Detroit Edison 

did not provide a definition of a vulnerability and did not identify any vulnerabilities in the 

seismic, fire, or HFO areas. The licensee did, however propose various plant improvements in 

the seismic and fire areas. In its safety evaluation report (SER) (NRC 2000a), the NRC staff 

concluded that the applicant’s IPEEE process is capable of identifying the most likely severe 

accidents and severe accident vulnerabilities for external events and, therefore, that the Fermi 2 

IPEEE has met the intent of Supplement 4 to GL 88-20.

The Fermi 2 IPEEE seismic analysis was a focused-scope SMA following NRC guidance (Chen 

et al. 1991; NRC 1991). The SMA approach is deterministic in nature and does not result in 

probabilistic risk information. The SMA was performed using a Safe Shutdown Equipment List 

(SSEL) with plant walkdowns in accordance with the guidelines and procedures documented in 

EPRI Report NP-6041-SL (EPRI 1991). Two success paths, each capable of mitigating the 

effects of a seismically induced small break LOCA, were identified based on a review of the 

guidance and plant documentation. The components on the SSEL were then evaluated for 

seismic capacity using a review level earthquake (RLE) of 0.3 g.

EPRI Report NP-6041-SL provides a set of screening guidelines to be used by the seismic

review team (SRT) to screen structures and equipment, against the RLE, during plant 

walkdowns. The screening also relies on the judgment and the experience of the SRT. More 

detailed evaluations may be required to establish the seismic capability of items (outliers) that 

do not meet the screening criteria or are judged by the SRT to warrant further review.

Particular emphasis was placed on equipment anchorage and identification of potential spatial 

interaction problems. A bounding anchorage evaluation was prepared to evaluate the capability 

of SSEL component anchorages to resist the RLE loads. High confidence in low probability of 
Appendix F

F-10

failure (HCLPF) calculations were performed for several critical items including masonry block 

and shield walls, and reactor internals.

As a result of the seismic screening evaluation and walkdown of the structures and 

components, several field conditions and concerns resulting in the need for plant maintenance 

were identified. Most of these items consisted of loose, missing, or damaged hardware and 

were handled by initiating plant maintenance work requests. Several conditions required design 

modifications. The majority of the outliers involved seismic interaction concerns that were 

resolved through some corrective actions. Others were resolved either by Conservative 

Deterministic Failure Margin (CDFM) capacity analysis to show the capacity well beyond 

review-level earthquake demand or by maintenance or modifications. These outliers were 

considered further in the Phase I SAMA identification, discussed in Section F.3 below.

As indicated by the licensee, detailed HCLPF calculations were not performed for all outliers. 

The approach was to utilize existing design basis documentation to extrapolate a minimum 

HCLPF of 0.3g PGA, based on the EPRI SMA Methodology found in Report NP-6041-SL. This 

was primarily accomplished by reviewing the conservative bias of the original design methods 

versus the guidelines in EPRI Report NP-6041-SL for determining CDFM and/or by taking 

advantage of existing design margins between capacity and demand.

With respect to the completion of the plant modifications and corrective maintenance activities,

the licensee reached the following conclusion (DECo 1996): “all outliers identified during the 

seismic evaluation and walkdowns are shown to have adequate capability to withstand the 

prescribed RLE without degradation of the components or pertinent systems.” The license 

further noted: “[a]s a result, this study has demonstrated, by using the above-described 

methodology, that the plant seismic HCLPF at Fermi 2 is equal to or greater than 0.3 g.” 

Improvements to Fermi 2 resulting from the IPEEE were (DECo 1996, DTE 2014):

• fastening adjacent panels containing relays to prevent impacts during a seismic

event; 

• replacement of low ruggedness relays; 

• additional seismic restraints for the large nonsafety-related air dryer tank; 

• rectification of a weakness in the seismic load path for two large control center 

heating, ventilating, and air conditioning instrument panels; 

• additional training incorporated into the continuing maintenance training program to 

increase the awareness level and emphasize the importance of mounting hardware 

installation and restoration during and after maintenance activities; and

• operations training to include a LOOP and permanent loss of CTG 11 Unit 1 

(CTG 11-1) scenario and in dealing with spurious alarms resulting from low seismic

ruggedness relay chatter. 

DTE actions in response to the 50.54(f) letter (NRC 2012a) requesting information related to the 

Fukushima Daiichi Near Term Task Force (NTTF) recommendations, confirmed that all of the 

above items have been addressed and are considered resolved (DTE 2012a). It is further noted 

that the DTE response to Recommendation 2.3 identified 27 potentially adverse seismic

conditions, but none were determined to have an immediate impact to the safe operation of the 

plant and are being addressed through the NRC’s agencywide program for responding to the 

Fukushima Daiichi accident. This program includes additional seismic evaluations as outlined in 

the NRC’s 50.54(f) letter dated March 12, 2012 (NRC 2012a).
Appendix F

F-11

Because the SMA approach used in the IPEEE does not involve the determination of seismic

CDF, a seismic CDF from the Generic Issue (GI) 199 risk assessment (NRC 2010) for the 

Fermi 2 site was used. The weakest link seismic CDF value of 4.2×10−6 per year from GI-199 

was used for determining the external events multiplier. The NRC staff notes that EPRI has 

provided initial estimates of updated seismic CDFs from new seismic hazard curves developed 

following the Fukushima Daiichi accident (EPRI 2014). In response to an NRC staff RAI to 

consider the impact of this updated seismic CDF on the Fermi 2 SAMA analysis, DTE indicated 

that, using the same methodology as GI-199, the new seismic hazard curves would result in a 

seismic CDF for Fermi 2 of 2.3×10−6 per year (DTE 2015a). This is discussed in more 

detail below.

The Fermi 2 IPEEE included an internal fire analysis employing EPRI’s FIVE methodology 

(EPRI 1992). FIVE is fundamentally a prescriptive fire PRA-based screening approach, which 

uses progressively more detailed phases of screening. The Fermi 2 analysis utilized the major 

steps of a FIVE assessment including fire area/compartment identification, safe shutdown 

equipment location, qualitative screening using spatial failure analysis, a Fire Compartment 

Interaction Analysis (FCIA), quantitative screening, including determining the safe shutdown 

failure probability for unscreened fire initiators using the PRA models, a fire propagation 

analysis, and a confirmatory walkdown (NRC 2000a).

The CDF of the areas that did not screen out in the final screening phase totaled 1.7×10−5 per 

year in the original IPEEE submittal (DECo 1996). As a result of a response to an NRC RAI on 

the IPEEE, the total CDF increased to approximately 2.2×10−5 per year (DECo 1999). 

Table F–4 provides a summary of the final phase of screening results from the Fermi 2 IPEEE 

fire analysis. As the NRC staff noted in the Fermi 2 IPEEE SER (NRC 2000a), the CDF from 

the remaining (those with a CDF of less than 1×10−6 per year) compartments subjected to the 

detailed analysis is 1.5×10−5 per year. This yields a total fire CDF of 3.7×10−5 per year, the 

impact of which is discussed below. 

Table F–4. Fermi 2 Important Contributors(a) to Fire CDF

Fire Area Fire Zone Description CDF (per year)

09AB Control Room 7.4×10−6

04ABN Division 1 Switchgear 4.5×10−6

03AB Relay Room 2.8×10−6

12AB Division 2 Switchgear 2.5×10−6

11ABE Division 1 Portion Miscellaneous Room 1.9×10−6

02RBNE Northeast Quadrant Reactor Building 1.5×10−6

RB06 Reactor Building 2nd Floor 1.0×10−6

Total 2.2×10−5

Key: CDF = core damage frequency

(a) Fire areas are those included in the final phase of screening with a CDF of at least 1.0×10−6 per 

year.

The Fermi 2 IPEEE fire assessment does not provide a definition of the term “fire vulnerability,” 

but concludes that the risk from fires is acceptable and thus presents no vulnerability. The 

single fire insight from the IPEEE fire analysis resulted from the evaluation of the second floor 

Reactor Building (RB06). The dominating contributors for this area are cabinets used for 
Appendix F

F-12

dedicated shutdown and whose loss would isolate the affected equipment from the main control 

room (MCR), thereby causing loss of the equipment function. Even though the potential for this 

loss was considered to be adequately addressed by the current operator training, additional fire 

brigade drills in the vicinity of these cabinets were planned to increase the awareness of the 

brigade members to the need to quickly isolate and extinguish such cabinet fires. DTE states 

that this training activity was tracked with a training work request and was subsequently 

incorporated into the training program (DTE 2014).

The Fermi 2 IPEEE analysis of high winds and tornadoes, external floods, and transportation 

and other nearby facility accidents followed the screening and evaluation approaches 

specified in Supplement 4 to GL 88-20 (NRC 1991). For these events, the IPEEE concluded 

that Fermi 2, while designed prior to the issuance of the 1975 Standard Review Plan 

(NRC 1975), conforms to the 1975 criteria. Therefore, the contribution to CDF from these 

events meets the IPEEE screening criterion of 1×10−6 per year in NUREG–1407

(Chen et al. 1991). No vulnerabilities or enhancements were identified.

As discussed in the ER and in the NRC staff’s SER of the IPEEE (NRC 2000a), an issue related 

to the potential for a common cause failure of diesel generator cooling function due to ice 

formation was identified during the same time frame that the IPEEE was performed. This was 

addressed subsequent to the IPEEE submittal. In order to prevent ice formation in service 

water pumps causing common mode failure of diesel generators, the following actions were 

taken (DTE 2014): (1) implemented procedures to check on this condition, (2) installed 

permanent temperature monitoring equipment, (3) installed fiberglass curtain to reduce wind 

chill effects on portion of pump columns below the RHR complex slab and above the reservoir 

water surface, and (4) modified terminations of RHR cold weather (bypass of mechanical draft 

cooling tower) lines to below reservoir water level to eliminate water forces on the curtain. 

The NRC staff notes that DTE’s response to the NRC’s 50.54(f) letter (NRC 2012a) requesting 

information related to the Fukushima Daiichi NTTF recommendations includes a flooding 

hazards reevaluation and a flooding walkdown. The flooding hazards reevaluation (DTE 2013) 

concluded “...the results from the updated flood evaluations analyses for Fermi 2 are less than 

the design bases flood protection. Therefore, an interim evaluation is not required and there are 

no additional actions taken or planned.” The flooding walkdown identified three conditions 

adverse to quality as follows: degraded boot seal, small gap between sealing surfaces in the 

outer railroad airlock door, and absence of seals for four electrical conduits inside the railroad 

airlock. Work orders were generated to resolve these issues. The walkdown also collected and 

documented information concerning the available physical margins (APM) for flooding. No 

conditions related to small APM with large consequences (indicative of a potential cliff-edge 

effect) were identified (DTE 2012b). The NRC staff’s SER on the walkdown (NRC 2014b) 

stated, “The staff concludes that the licensee, through the implementation of the walkdown 

guidance activities and, in accordance with plant processes and procedures, verified the plant 

configuration with the current flooding licensing basis; addressed degraded, nonconforming, or 

unanalyzed flooding conditions; and verified the adequacy of monitoring and maintenance 

programs for protective features.”

As discussed in the ER, since there are no up-to-date quantitative external event models for 

Fermi 2, it is necessary to develop a multiplier that can be applied to the internal events PRA 

results to account for the risk contribution from external events in the SAMA evaluation. For the 

seismic contribution to risk, DTE used the previously described GI-199 seismic CDF value of 

4.2×10−6 per year. For the fire contribution to risk, DTE used a fire CDF of 1.08×10−5 per year. 

This value is one half of the total CDF of the unscreened fire area CDFs from the FIVE analysis 

given in Table F–4. DTE noted that the FIVE analysis is expected to give conservative results. 

In addition, the IPEEE fire analysis utilized the IPE internal events model with a CDF of 5.7×10−6
Appendix F

F-13

per year, approximately four times the current internal events CDF of 1.5×10−6 per year. DTE 

indicated that it could be reasonably assumed that an update of the FIVE analysis with the 

current internal events model would result in a fire CDF equal to one-fourth of the original fire 

CDF. DTE conservatively utilized a factor of two reduction to arrive at the fire CDF of 1.08×10−5

per year.

Based on the aforementioned results, DTE indicated in the ER that the total external events 

CDF is approximately 1.5×10−5 per year (based on a seismic CDF of 4.2×10−6 per year, a fire 

CDF of 1.08×10−5 per year). DTE did not include CDFs for high winds, external flooding, or 

transportation and other nearby accidents on the basis that these events were addressed by 

demonstrating compliance with the 1975 Standard Review Plan (SRP) and that compliance with 

the SRP and no adverse finds from walkdowns, justifies the conclusion that the hazard’s 

contribution to CDF is less than 10−6 per year. Therefore, these events are not significant 

contributors to external event risk. Because quantitative analysis of these events is not 

practical, the external event multiplier was developed based on seismic and fire risk 

(DTE 2014). The total CDF (internal and external events) is then approximately 1.65×10−5 per 

year or 11 times the internal events CDF. This multiplier was used by DTE in the SAMA

analysis in the ER to account for the impact of external events on the benefits determined from 

the internal events PRA.

As noted in an NRC staff RAI, the NRC staff’s evaluation report on the IPEEE indicated the CDF

of 1.5×10−5 per year from the remaining areas screened (with CDFs less than 1×10−6 per year) 

was subjected to the same detailed analysis as the unscreened areas. Because this 1.5×10−5

per year CDF was not included in the 2.15×10−5 per year CDF from the unscreened fire areas, 

DTE was asked to provide justification for not including it in the total fire CDF used in the SAMA

analysis and/or assess the impact on the SAMA cost-benefit evaluation, particularly with respect 

to determining the external events multiplier. In response, DTE performed two sensitivity 

analyses. The first analysis, similar to that described above, used the updated seismic CDF

(2.26×10−6 per year) and the total fire CDF including the contribution from the screened areas 

reduced by a factor of 2 (3.65×10−5 per year). This resulted in an external events multiplier of 

14.7. In the second sensitivity analysis, the total fire CDF including the contribution from the 

screened areas was reduced by the ratio of the current internal events CDF less the internal 

flood contribution (1.27×10−6 per year) to the IPEs internal events contribution (5.7×10−6 per 

year). This ratio (0.223) then yielded a fire CDF, based on the total IPEEE fire CDF, of 8.1×10−6

per year. Internal floods were excluded from the current CDF since they were not included in 

the IPE and internal flood contributions to CDF would not impact the fire CDF. This second 

sensitivity yields an external events multiplier of 7.9. DTE concluded that since the average of 

these two values for the external events multiplier of 11.3 is approximately the same as the 

value of 11 used in the ER, the continued use of this value is acceptable (DTE 2015a).

The NRC staff agrees with the applicant’s overall conclusion concerning the multiplier used to 

represent the impact of external events and finds that the applicant’s use of a multiplier of 11 will 

reasonably account for external events in the SAMA evaluation.

F.2.2.3 Level 2 Fission Product Release Analysis

The NRC staff reviewed the general process used by DTE to translate the results of the Level 1 

PRA into containment releases and the results of the Level 2 analysis, as described in the ER 

(DTE 2014) and responses to NRC staff RAIs (DTE 2015a). DTE indicated that the Fermi 2 

Level 2 PRA model used for the SAMA analysis is a full Level 2 model developed as part of the

FermiV9 internal events PRA model (DTE 2014), which included the conversion of the
Appendix F

F-14

RISKMAN-based Computer-Aided Fault Tree Analysis (CAFTA) Level 2 to an upgraded CAFTA 

Level 2 model based on first principles.

PDSs provide the interface between the Level 1 and Level 2 analyses. The Level 1 PRA 

identifies accident sequences that contribute to the CDF and represent the spectrum of possible 

challenges to containment. The Level 1 sequences that result in core damage are grouped into 

PDS bins. Each bin collects all of those sequences for which the progression of core damage, 

the release of fission products from the fuel, the status of the containment and its safeguards 

systems, and the potential for mitigating the potential radiological source terms are similar. The 

PDS bins for Fermi 2 are characterized by:

• integrity of the primary system, 

• primary system pressure, 

• decay heat removal, 

• integrity of the containment, and

• relative timing of core damage. 

Based on these parameters, five accident classes were created and subsequently further 

divided into 16 subclasses as listed in ER Table D.1–8. The PDS designators listed in 

Table D.1–8 represent the core damage end-state categories from the Level 1 analysis that are 

grouped together as entry conditions for the Level 2 analysis. The Level 2 accident progression 

for each of the PDS is evaluated using a CET to determine the appropriate release category for 

each Level 2 sequence. In response to an NRC staff RAI relative to the definition of accident 

classes, DTE indicated that for Class IV (ATWS), two of the subclasses (IVT and IVV) were not 

used since the modeling conservatively precludes these subclasses and that the other two 

subclasses (IVA and IVL) were combined because the Level 2 modeling of these subclasses 

was very similar (DTE 2015a).

The Fermi 2 Level 2 model consists of a set of three CETs, which contain both 

phenomenological and containment system protection status functional nodes, and assess the 

accident progression following a core damage event. In response to an NRC staff RAI, DTE 

indicated that the Level 1 and Level 2 models are linked to ensure that dependencies on Level 1 

failures and successes are appropriately accounted for (DTE 2015a).

Table D.1–4 of the ER lists the 18 functional nodes and the associated success criteria used in 

the Fermi 2 Level 2 CET model. The nodes are quantified using subordinate trees and logic 

rules that are based on deterministic analysis of physical process for a spectrum of severe 

accident progressions, and a probabilistic analysis component in which the likelihood of the 

various outcomes are assessed. In response to an NRC staff RAI to provide more information 

concerning the treatment of containment isolation failures and credit taken for containment 

sprays, DTE indicated that all containment isolation failure sequences, in conjunction with core 

damage, were assumed to result in a high early (H/E) release. Relative to containment sprays, 

DTE indicated that drywell spray is credited as directed by the Severe Accident Guidelines in 

the Level 2 and associated MAAP analysis and noted that the primary functions of drywell spray 

in the Level 2 model are to put water on the containment floor, quench ex-vessel debris 

following vessel breach, and to “scrub” fission products from the containment atmosphere. 

(DTE 2015a)

Each CET end state represents a radionuclide release to the environment and is assigned to a 

release category. As previously described, the release categories were defined based on the

timing and magnitude of release. In response to an NRC staff RAI, DTE discussed the basis for 

assigning each end state to a release category. Level 2 sequence end states were assigned to 
Appendix F

F-15

a release category based on key attributes of the Level 2 sequence (e.g., accident class, 

mitigating strategies employed, location of release point out of containment) that ultimately 

impact the timing and magnitude of a release. Based on the body of Fermi 2 specific 

deterministic calculations and assignment “rules,” an understanding of accident phenomenology 

was inferred to allow the available MAAP 4.0.7 calculations to be used to support the 

determination of radionuclide release end states for all Level 2 sequences with non-negligible 

frequency (DTE 2015a). DTE also clarified that leakage from the drywell was modeled instead 

of the torus air volume because drywell leakage yielded a higher release fraction for cesium 

iodide (CsI) (DTE 2015a). The NRC staff finds this treatment acceptable, because it is 

consistent with the technical specification for the plant and inclusion of the release category for 

intact containment provides additional confidence that estimated releases and consequences 

have not been underestimated.

In an RAI (NRC 2014a), the NRC staff noted that the SAMA submittal describes a situation in 

which a lower release category frequency was used in the SAMA analysis compared to the 

value in the Fermi 2 PRA documentation. DTE indicated the cause to be “an issue with under 

counting of Class II contribution” in the PRA. In response to this RAI, DTE explained the cause 

of this “undercounting” and its potential impact on the SAMA analysis. The undercounting was 

caused by use of 1×10−12 per year as the truncation cutoff value for the Level 2 analysis. The 

undercounting (equal to 3.14×10−9 per year) was described to remove a number of Level 2 

sequences when the same truncation cutoff value (1×10−12 per year) was used for the Level 2 

release category and Level 1 CDF analyses. The undercounting was eliminated when a lower 

truncation cutoff is used for the Level 2 analysis (DTE 2015a). The impact of this undercounting 

on the overall consequence was assessed in the ER as minimal based on the assumption that 

the consequences were the same as the moderate/early (M/E) release category. 

A followup RAI by the NRC staff (NRC 2015a), questioned the evaluation assumption that the 

3.14×10−9 per year undercounting had a consequence equivalent to the M/E release category. 

In response, DTE concluded based on further evaluation that the unaccounted frequency would 

more appropriately split between the M/E and H/E release categories. DTE’s sensitivity study 

assumed that the entire undercounting was attributed to the H/E category and resulted in a 

$16,200 increase in the MACR for both internal and external events (DTE 2015b), which 

represents an increase of less than a 0.5 percent in the base case MACR given in 

Section F.6.1. The impact of this undercounting on the SAMA cost-benefit analysis is discussed 

in Section F.6.2. DTE developed the accident progression and associated release 

characteristics for each release category, by using the results of MAAP Version 4.0.7 computer 

code calculations. A MAAP case was identified as a representative case for each of the Fermi 2 

Level 2 PRA release categories. In response to an NRC staff RAI, DTE provided a description 

of the representative cases for each release category and additional information on the 

selection of these representative cases. DTE noted that MAAP scenarios are chosen based on 

a frequency-weighted approach (i.e., the MAAP scenario representing the most dominant 

sequence(s) or bounding the most dominant sequence is typically chosen) and that this 

approach provides a better representation of the release category then choosing the scenario 

with the very most conservative conditions, such as the highest CsI release fraction

(DTE 2015a).

During the SAMA audit (NRC 2014c), it was noted that documentation of the selection of 

representative sequences included a situation in which an MAAP scenario or sequence with a 

CsI release fraction of 0.72 was subsumed into the H/E release category modeled in the ER 

using MAAP case with a CsI release fraction of 0.24. In response to NRC staff RAIs to discuss 

the potential for underestimating the benefit of any SAMA that mitigates non-dominant but 

higher release fraction scenarios, DTE provided additional discussion of the development of the 
Appendix F

F-16

representative scenarios for the three most important release categories (H/E-BOC, H/E, and 

H/I), which collectively account for 92 percent of the total offsite population dose risk and cost 

risk (DTE 2015a). 

DTE indicated that because the H/E-BOC release category has one representative MAAP 

scenario, it is therefore adequately represented by that case. For the specific example cited 

above, DTE indicated that the frequency of the sequence with the 0.72 CsI release fraction is

less than 1 percent of the H/E release category frequency; therefore, using this sequence to 

represent the entire release category would not be appropriate. 

In the initial RAI response (DTE 2015a), DTE showed two Accident Class IIA sequences 

(sequences involving a loss of containment heat removal with the RPV initially intact and core 

damage induced post-containment failure) included in the H/E release category with CsI and/or 

cesium hydroxide (CsOH) release fractions greater than those for the representative sequence 

chosen for this release category. If it is conservatively assumed that the Class IIA sequences 

have the same consequences as the high/early break outside containment (H/E-BOC) release

category, the revised Class IIA contribution is 2.69 times the calculated person-rem/yr and 

1.08 times the OECR contributions when they are included in the H/E base case release 

category. This approach increases the total dose risk by 15 percent (to 5.64 person-rem/yr) but 

increases the cost risk by only 0.6 percent (to $15,700/yr) over the base case values of 

4.91 person-rem/yr and $15,600/yr, respectively. Refer to Table F–2 of this appendix for the 

base case results presented in the ER. Based on the conservatism of this analysis and 

considering the offsite exposure cost is only approximately 34 percent of the baseline MACR, 

this dose risk increase would be much less significant to the total MACR, and DTE concluded 

that the representative sequence used in the original ER analysis adequately represents the 

H/E release category even with the inclusion of Class IIA sequences in this release category

(DTE 2015a). While the NRC staff agrees with the conclusion that the reassignment of the 

Class IIA sequences to a different, higher consequence, release category would not have a 

significant impact on the total base case benefit (the MACR), it would lead to an underestimate 

of the benefit for any SAMA that mitigates the Class IIA sequences. This topic is discussed 

further in Section F.6.2. DTE indicated the H/I release category is conservatively represented 

by a scenario that bounds all the dominant H/I sequence CsI and CsOH release fractions 

(DTE 2015a).

In response to an NRC staff RAI to provide the duration of the MAAP analysis for each release 

category and to provide an assessment of the adequacy of the time to characterize the release 

fractions, DTE indicated that the run times and therefore the release fraction for two (H/E-BOC 

and H/E) of the three (H/E-BOC, H/E, and H/I) important release categories was 40 hours 

(or approximately 36 hours following core damage), which is less than the time frame of 

48 hours used in the SOARCA (State-of-the-Art Reactor Consequence Analyses) project 

(NRC 2012b). SOARCA assumed that adequate mitigating measures could be brought onsite, 

connected, and functioning within 48 hours. The run time for the third important release 

category (H/I) was 191 hours. DTE reported an increase of 0.01 of the core inventory or about 

3 to 4 percent of the 40-hour release fractions for CsI and CsOH (key contributors to offsite 

dose and cost risk) from the 40-hour values used in the SAMA analysis. DTE concluded that 

this increase is not significant and the use of the release fraction values based on the 48 hour 

run times is adequate (DTE 2015a). On the basis of the small impact on release fractions, the 

NRC staff agrees that results calculated with run times of 40 hours are acceptable for the SAMA 

analysis.

In response to an NRC staff RAI, DTE stated that the input for the Fermi 2 MAAP 4.0.7 analysis 

utilizes both element masses and nuclide activities as recommended by the MAAP 4.0.7 code 

and is consistent with the guidance in MAAP-FLAASH #68 (DTE 2015a).
Appendix F

F-17

As discussed above, the draft FermiV9 PRA model was evaluated in the 2012 BWROG peer 

review. All findings, including those pertaining to the Level 2 large early release frequency 

(LERF) model, were considered by the NRC staff to be satisfactorily resolved for the SAMA

application.

On the basis of the NRC staff’s review of DTE’s Level 2 model, the peer review performed on 

the draft FermiV9 PRA model, and DTE’s responses to NRC staff RAIs, the NRC staff 

concludes that, subject to the further discussion of cost-benefit analysis in Section F.6.2, the 

Level 2 PRA is of sufficient quality to support the SAMA evaluation.

F.2.2.4 Level 3 Offsite Consequence Analysis

The NRC staff reviewed DTE’s process to propagate the containment performance (Level 2) 

portion of the PRA to an assessment of offsite consequences (Level 3 PRA). Using the 

MACCS2 version 3.7.0 code, DTE determined the offsite consequences from potential releases 

of radioactive material (DTE 2014). In the Level 3 analysis, DTE combined release fractions 

and release categories, discussed in Section F.2.2.3, with the calculated core inventory to yield 

a source term of radionuclide releases to the outside environment. In response to an NRC staff 

RAI, DTE provided additional information on the source of the Fermi 2 radionuclide inventory 

that was calculated with the SCALE version 4.4 SAS2H software (DTE 2015a). The NRC staff 

finds the MACCS2 and SCALE codes to be acceptable for the SAMA evaluation because the 

codes are widely used for radiological dose calculations resulting from airborne releases of 

radioactive material and radionuclide source term determinations, respectively.

In response to an NRC staff RAI, DTE provided the rationale for the selection of radionuclides 

included in the core inventory. Specifically, DTE clarified that radioactive cobalt is not included 

in the core inventory for Fermi 2 (DTE 2015a) and indicated that core inventory relates to the 

alternative radiological source term developed in accordance with Regulatory Guide 1.183

(NRC 2000b). In response to a license amendment request, the NRC staff previously evaluated 

the radionuclide inventory (NRC 2004a) and stated:

The licensee projected the core inventory of fission products using the 

ORIGEN-S computer code. The ORIGEN-S computer code is acceptable to the 

NRC staff for estimating the core inventory. The licensee assumed a core 

licensed power level of 3,430 megawatts thermal (MWt) and applied an 

uncertainty correction of 102 percent to arrive at the analysis input of 3499 MWt.

The NRC staff notes that the input power level of 3,499 MWt exceeds the approved uprated 

power of 3,486 MWt (DTE 2015a). Because larger power levels are conservative with respect 

to the source term and radiological consequences, the NRC finds the greater power level and 

radionuclide inventory acceptable for use in the SAMA analysis. DTE confirmed that no uprates 

are planned following the license amendment approval in 2014 for an MUR uprate to 3,486 MWt 

and that assessed impacts from increases in the power level did not result in additional SAMAs

becoming cost beneficial (DTE 2015a). In response to an NRC staff RAI on thermal power 

levels, DTE reported the radionuclide core inventory in Table D.1–23 of the ER (DTE 2014) was 

based on a thermal power of 3,430 MWt, which was the licensed power level when the SAMA 

analysis was performed, and also indicated that a license amendment was approved in 2014 for 

a power uprate to 3,486 MWt (DTE 2015a). DTE performed a sensitivity analysis to assess the 

impacts of this power uprate on the radionuclide inventory, Level 3 offsite consequences, and 

averted cost risk attributable to each SAMA. DTE concluded that the increased power level to 

3,486 MWt did not result in additional SAMAs becoming cost beneficial (DTE 2015a). The NRC 

staff finds DTE’s sensitivity results to be reasonable and acceptable because no changes to the 

list of cost-beneficial SAMAs would be expected from the small 1.6 percent increase in thermal 
Appendix F

F-18

power considering that the original SAMA analysis results in the ER showed that SAMAs 

deemed as not cost beneficial using the most conservative 95th percentile values for averted 

cost risk were more than 2 percent below estimated costs for SAMA implementation. DTE 

stated there are currently no plans for further power uprates at Fermi 2 (DTE 2015a). DTE also 

confirmed that future fuel management practices or fuel design changes are not expected to 

influence the core inventory because DTE plans to continue using the same reactor fuel and 

fuel cycle duration (DTE 2015a). The NRC staff finds that the SAMA analysis is consistent with 

DTE’s plans on fuel management and concludes that the current radionuclide inventory 

calculations (DTE 2014, 2015a) are adequate for the estimation of offsite consequences.

DTE presented the major input parameter values and assumptions of the offsite consequence 

analyses in Attachment D of the ER (DTE 2014). DTE considered site-specific meteorological 

data for calendar years 2003, 2005, and 2007. Meteorological data from 2007 were selected for 

input to the MACCS2 code because they resulted in the highest population dose risk and offsite 

economic cost risk (DTE 2014). Meteorological data included wind speed, wind direction, 

atmospheric stability class, precipitation, and atmospheric mixing heights acquired from the 

Fermi 2 meteorological monitoring system and the U.S. Environmental Protection Agency. In 

response to an NRC staff RAI, DTE described the weather bin sampling for modeling 

precipitation events that results in a rainfall intensity distribution for the 16 compass directions 

and confirmed that boundary weather parameters include precipitation (DTE 2015a). The NRC 

staff finds the modeling of precipitation to be acceptable because it is linked to site-specific 

annual meteorological data and implemented using widely accepted software. Because DTE’s 

assumption of precipitation in cells beyond the 80-km (50-mi) radial boundary would neither 

underestimate population doses nor economic costs, the NRC staff finds the assumed 

precipitation in boundary cells to be acceptable. Because selection of the 2007 meteorological 

data set resulted in the highest population dose risk and offsite economic cost risk, the NRC 

staff accepts its use in the SAMA evaluation. 

DTE estimated missing meteorological data by data substitution. For 1 hour of missing data, 

interpolation was performed with valid data immediately before and after the data gap. For data 

gaps greater than 1 hour, data were replaced with data from days with similar meteorological 

conditions immediately before and after the data gap. In response to a question on the amount 

of missing data, DTE indicated that the percentages of missing data replaced by substitution 

were 3.59, 0.35, and 1.88 percent in the respective years 2003, 2005, and 2007. Because 

these percentages of missing data are reasonable and the methods used to substitute missing 

data are common remedies, the NRC staff finds these approaches to be acceptable for use in 

the SAMA analysis. As previously described, the sources of data and models for atmospheric 

dispersion used by the applicant are appropriate for calculating consequences from potential 

airborne releases of radioactive material. The NRC staff notes that results of previous SAMA 

analyses have shown little sensitivity to year-to-year differences in meteorological data and 

concludes that the selection of the 2007 meteorological data for use in the SAMA analysis is

appropriate.

The NRC staff requested additional information on the modeling assumption for watershed 

drainage, given the Fermi 2 site is located near a large body of water. DTE described that 

modeling drainage by rivers was conservative compared to drainage by large bodies of water 

because radionuclide contaminants would have a greater retention in the area due to less 

removal by drainage (DTE 2015a). The NRC staff accepts this parameter selection because it 

is conservative and will overestimate radionuclide concentrations as well as offsite population 

doses.

In response to an NRC staff RAI, DTE assessed the sensitivity of Level 3 results to the 10-MW 

plume heat output applied to each release category (except intact containment). Specifically, 
Appendix F

F-19

DTE indicated that the modified MACR (MMACR) would increase by 0.76 percent with no plume 

heat output and decrease by 1.32 percent with a plume heat output of 20 MW. Because these 

plume heat outputs bracket sample values in SAMA guidance (NEI 2005), and DTE showed a 

minimal sensitivity of averted cost risk to plume heat, the NRC staff finds that DTE’s modeling of 

plume heat is acceptable because alternative plume heat values would not change the 

identification of cost beneficial SAMAs.

Because the conservative modeling assumptions were included in the assessment and input 

data were either obtained for the Fermi 2 site or found to be consistent with guidance values, 

the NRC staff concludes that data and modeling assumptions for the Level 3 analysis are 

appropriate for the SAMA evaluation.

DTE projected the population distribution and expected growth within a radius of 50 mi (80 km) 

of the Fermi site out to the year 2045 and used the areal weighting from the SECPOP2000 

Version 3.13.1 code to populate the spatial elements of the computer model (DTE 2014). In 

response to RAIs by NRC staff (DTE 2015c), DTE clarified the accounting of the Canadian 

population with additional details on the distribution of U.S. permanent population, Canadian 

permanent, and transient populations estimated for the year 2045. These data clearly show 

Canadian populations to the east and northeast of the Fermi 2 site. DTE also considered 

transient population contributions based on tourism data for Michigan, Ohio, and Ontario, 

Canada. DTE reported that the total population within 50 mi (80 km) of the Fermi 2 site was 

projected to be 6,055,850 for the year 2045. The value of land in Canada within 50 mi (80 km) 

of the Fermi 2 site was also considered in the analysis (DTE 2015c). Since the original ER 

submittal and additional information provided by DTE satisfactorily addressed the questions 

raised by NRC staff and showed that population inputs would not underestimate potential 

consequences, NRC staff finds the methods and assumptions for estimating population 

reasonable and acceptable for purposes of the SAMA evaluation.

For the 16-km (10-mi) emergency planning zone at Fermi 2, DTE considered information from 

the Fermi Nuclear Power Plant Development of Evacuation Times Estimates report in its 

determination of evacuation times, time delays, and travel speeds (DTE 2014). For the baseline 

Level 3 calculation in Table D.1–24 of the ER (DTE 2014), DTE assumed 95 percent of the 

population within the emergency planning zone would evacuate. To account for population 

increases in the future, DTE lowered the assumed evacuation speed from the determined 

network-wide evacuation speed of 12.8 meters per second (28.6 miles per hour) to 10 meters 

per second (22.4 miles per hour). In response to an NRC staff RAI on the network-wide 

evacuation speed and total time for evacuation, DTE affirmed that the evacuation assessment 

considered site-specific conditions for Fermi 2 and described how spatial dependences of the 

highway network as well as population density were modeled (DTE 2015a). In a sensitivity 

analysis shown in Table D.1–25 of the ER (DTE 2014), DTE reported an increase in the 

population dose risk by 1 percent due to an assumed factor-of-2 reduction in the average 

evacuation speed from 10 meters per second to 5 meters per second. Sensitivity values for the 

evacuation fraction of 90 percent and 99.5 percent were shown in Table D.1–26 of the ER to 

have very small influences on the population dose risk (less than 0.005 percent) (DTE 2014). 

As described by DTE, evacuation applies to the emergency planning zone with a lower 

population compared to other areas surrounding the Fermi 2 site. The much larger population 

outside of the emergency planning zone (about 55 times larger) does not evacuate in the 

assessment and accounts for a majority of the total population dose. For these reasons, the 

total population dose is not directly proportional to the fraction of individuals in the emergency 

planning zone who do not evacuate. Because DTE used site-specific information, applied more 

pessimistic (lower) fractions for the evacuating population in the emergency planning zone 

compared to guidance values (NRC 1997a), and considered the effect of population increases 
Appendix F

F-20

on evacuation parameter values, the NRC staff concludes that the evacuation assumptions and 

analysis are reasonable and acceptable for the purposes of the SAMA analysis at Fermi 2. 

DTE calculated land values using an economic multiplier with economic data from 2002. The 

economic multiplier was based on the slope of the consumer price index between 2000 and 

2012. DTE extrapolated this slope to the year 2013 to obtain an economic multiplier of 1.2964 

(DTE 2014). The NRC staff reviewed DTE’s assessment of economic data, including the 

assumptions associated with land values and the destruction of crops exposed to radioactive 

material from modeled radionuclide releases. This crop destruction applies to the year of the 

event. In subsequent years, the acceptability of food production is evaluated with projected 

individual dose criteria to determine if loss of use of farmland is included in offsite costs 

(DTE 2015a). Because farmland interdiction applies to all crop categories, the cost for 

destruction of all crops will be included as long as the dose criterion is exceeded. Additionally, 

there is an implicit assumption that food doses will not increase over time. For the large areas 

of land modeled in the assessment, the NRC staff agrees that increases in crop doses would 

not be expected from a short-term release. The annual crop evaluation extends up to 8 years 

beyond the event. If the annual individual doses from ingestion of crops exceed the dose 

criterion throughout this time frame, the farmland is treated as condemned (DTE 2015a). If the 

dose criterion is not exceeded in one of the years evaluated, crop consumption is allowed in that 

year and in subsequent years, and population doses due to crop consumption are included in 

the assessment (DTE 2015a). 

DTE estimated present dollar values based on the internal events PRA at Fermi 2 and applied a 

multiplication factor of 11 to account for external events, as described in Section F.2.2.2. As 

shown in Table D.1–35 of the ER, offsite economic and offsite exposure costs provided the 

greatest contributions to the total dollar value at approximately 55 and 35 percent, respectively 

(DTE 2014). Onsite cleanup and replacement power costs collectively contributed 11 or 

10 percent to the total dollar value for real discount rates of 7 percent (baseline) or 3 percent 

(sensitivity), respectively. Onsite exposure costs contributed less than 1 percent. Section F.6 

provides more detailed information on the cost-benefit calculation and its evaluation.

Applicable guidance in NUREG/BR–0184 (NRC 1997a) or the NEI 05-01 report (NEI 2005) 

does not require that the SAMA analysis include replacement power costs from an undamaged, 

operational unit being shut down for a prolonged period of time following a severe accident at 

another unit on the same site. Nevertheless, the NRC staff performed a scoping calculation to 

assess if the added costs from a prolonged shutdown of Fermi 3, which received a combined 

operating license in 2015 and could possibly be built and operate during the license renewal 

period for Fermi 2, would change the determination of cost-beneficial SAMAs for Fermi 2. In 

response to an NRC staff RAI, DTE indicated that 1,585 MWe would be a conservative value for 

the maximum net electrical power of Fermi 3 (DTE 2015c). The NRC staff assumed that the 

10-year outage time for Fermi 3 would occur at the worst time from a replacement power cost 

perspective (i.e., timing of the 10-year outage results in the largest replacement power cost) and 

found that the additional replacement power costs from an extended outage at Fermi 3 following 

a severe accident at Fermi 2 would not change the selection of cost-beneficial SAMAs for 

Fermi 2. 

Based on its review of DTE’s submissions, the NRC staff concludes that DTE’s methodology to 

estimate offsite consequences for Fermi 2 provides an acceptable basis to assess the risk 

reduction potential for candidate SAMAs. Accordingly, the NRC staff based its assessment of 

offsite risk on the core damage frequencies, population doses, and offsite economic costs 

reported by DTE.
Appendix F

F-21

F.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the 

improvements evaluated in detail by DTE are discussed in this section.

F.3.1 Process for Identifying Potential Plant Improvements 

DTE identified potential plant improvements (SAMAs) by reviewing industry documents and 

considering other plant-specific enhancements not identified in the published industry 

documents. Industry documents reviewed included the following:

• NEI 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance 

Document (NEI 2005); 

• Industry BWR SAMA analysis documentation discussing potential plant 

improvements:

− FitzPatrick Nuclear Power Plant SAMA Analysis, 

− Columbia Generating Station SAMA Analysis, 

− Cooper Nuclear Station SAMA Analysis, 

− Oyster Creek Nuclear Generating Station SAMA Analysis, 

− Monticello Nuclear Generating Plant SAMA Analysis, 

− Brunswick Steam Electric Plant SAMA Analysis, 

− Pilgrim Nuclear Power Station SAMA Analysis, 

− Susquehanna Steam Electric Station SAMA Analysis, 

− Vermont Yankee Nuclear Station SAMA Analysis, 

− Duane Arnold Energy Center SAMA Analysis, and 

− Grand Gulf Nuclear Station SAMA Analysis; 

• The Fermi 2 IPE, Fermi 2 IPEEE reports, and their updates; 

• NUREG–1742, Perspectives Gained from the Individual Plant Examination of 

External Events (IPEEE) Program (NRC 2002); and

• The Fermi 2 updated PRA model lists of risk significant contributors in Tables D.1–2 

and D.1–5 of the ER (DTE 2014). 

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.
Appendix F

F-22

• 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 MMACRSAMA, 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, which is 

known to have negligible impact on the risk profile, it is not retained.

• 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 2014) 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 below. To account for the potential impact of 

external events, the estimated benefits based on internal events were multiplied by a factor of 

11, as discussed in Section F.2.2.2.

F.3.2 Review of DTE’s Process

DTE’s efforts to identify potential SAMAs focused primarily on areas associated with internal 

initiating events. The NRC staff reviewed the listing of Phase I candidate SAMAs as part of the 

October 2014 audit meeting at the Fermi site (NRC 2014c). The primary source of candidate 

SAMAs (146 of a total of 220) was the list of BWR SAMA candidates contained in NEI 05-01 

(NEI 2005). The review of other SAMA analysis documentation led to identifying 48 additional 

candidate SAMAs. Review of the risk contribution to CDF and LERF from a risk reduction worth 

(RRW) perspective at Fermi 2 led to identifying 14 additional SAMAs, while review of the IPEEE 

lead to 12 additional SAMA candidates.

As discussed above, DTE initially identified 146 Phase I candidate SAMAs from the NEI 05-01 

list of SAMA candidates. While the number of SAMA candidates resulting from the Fermi 2 

PRA RRW review (14) appears rather low, the majority of the risk significant basic events in the 

RRW were assessed to be mitigated by the previously identified SAMA candidate.

In the ER, DTE provided a tabular listing of the Level 1 PRA basic events sorted according to 

their RRW (DTE 2014). These results were reviewed by DTE to identify those potential risk 

contributors that made a significant contribution to CDF. The RRW rankings were reviewed 

down to 1.005. Events below this point would influence the CDF by less than 0.5 percent and 

are judged to be highly unlikely contributors for the identification of cost-beneficial 

enhancements. These basic events, which include component failures, operator actions, and

initiating events, were reviewed to determine if additional SAMA actions may need to 

be considered. 

The NRC staff notes that a RRW of 1.005 corresponds to a MACR (including external events) of 

approximately $17,000 if it is assumed that a SAMA is 100 percent effective in eliminating the 

event’s contribution to CDF and that the total cost-risk is proportional to CDF. Even if 

uncertainty is included, as is discussed later, the value becomes approximately $42,000. 

Because this potential benefit is less than the minimum cost for a simple procedure change of 

$50,000, the NRC staff concludes that DTE’s minimum RRW review threshold of 1.005 is 

acceptable for identifying potential cost-beneficial SAMAs.
Appendix F

F-23

DTE also provided tabular listings of the Level 2 PRA basic events for the combined LERF 

categories in the ER. DTE used an RRW cutoff of 1.005 when reviewing these basic events for 

additional SAMA candidates. As indicated in Table F–2, the LERF release categories dominate 

the population dose and offsite economic cost risks.

In the NRC staff’s review of these importance lists and the SAMAs identified by DTE, a number 

of concerns with DTE’s assessments were documented in RAIs. The following list summarizes 

these concerns and DTE’s responses (DTE 2015a).

• SAMA 001 regarding the addition of DC power supplies is not a Phase II SAMA, as it

was screened out on the basis of being already implemented per DTE addressing 

NRC Order 12-049 requirements with a FLEX (diverse and flexible coping capability) 

portable, DC generator. DTE clarified that FLEX includes a portable AC generator 

and that it would be used to supply the installed battery chargers and the 

combination would have the capacity to supply all necessary DC loads.

• Relative to considering a SAMA to automate the starting of the mechanical draft 

cooling tower fan, DTE performed a cost-benefit assessment that indicated the 

maximum benefit would be $682,000, including external events and uncertainty. 

Considering a cost of $2.4 million, such a SAMA would not be cost beneficial

(DTE 2015b, 2015c).

• In DTE’s ER Table D.1-2, “Correlation of Level 1 Risk Significant Terms to SAMAs,”

several internal flooding events relating to the failure of condenser circulating water 

inlet and outlet expansion joints were cited to be addressed through the External 

Surfaces Monitoring Program for external degradation and the Internal Surfaces 

Miscellaneous Piping and Ducting Components Programs for internal degradation 

(SAMA 129). These aging management programs are primarily visual inspections of 

the internal and external surfaces. DTE clarified that these license renewal 

programs will be fully implemented prior to the period of extended operation and that 

neither monitoring program is credited in the Fermi 2 PRA model. DTE also clarified

that there is an existing preventive maintenance program to visually examine the 

condenser circulating water inlet and outlet expansion joints performed every other 

outage. Furthermore, DTE described the design features currently installed to 

detect, minimize, or mitigate the consequences of flooding due to an expansion joint 

failure, such as the sump alarms to detect flooding, pump switches to prevent 

overpressurization, and the prevention of water-hammer strategies. Thus,

consideration of additional SAMAs is not warranted.

• SAMA 031 cited to mitigate HPCI or RCIC failures during subsequent cycles, is said 

in one place in the ER to evaluate upgrading HPCI throttling capability to reduce the 

number of start/stops required. In another place, SAMA 031 is said to revise 

procedures to allow intermittent operations of HPCI and RCIC. DTE clarified that 

current operating procedures allow for cycling of the HPCI/RCIC (on at reactor water 

Level 2 and off at Level 8) before operators take manual control of the pumps to 

throttle flow and maintain RPV water at a constant level, thus preventing additional 

cycling. A SAMA to address these HPCI or RCIC basic events would involve 

revision to procedures and training to allow operators to take manual control of 

HPCI/RCIC earlier in the event to prevent cycling on and off of the pumps. The 

maximum benefit of eliminating these failures was determined to be $39,300, 

including uncertainty, which is less than the minimum cost for a procedure change; 

therefore, this SAMA is not cost beneficial.
Appendix F

F-24

• SAMA 009 to reduce the DC dependence between high pressure injection and 

automatic depressurization system (ADS) is cited to mitigate failure of the 

turbine-driven HPCI pump to start. This SAMA would not mitigate the cited failure 

since the common cause failure of DC would not be included in this event. DTE 

agreed that SAMA 009 would not mitigate the cited failure and indicated that the 

maximum benefit, including uncertainty, of making a 40-percent reduction in the 

HPCI pump failure to start would be $12,500, which is less than the cost of potential 

SAMAs. 

• SAMA 101 to improve leak detection procedures, is cited for a number of internal 

flooding events. This SAMA was not included as a Phase II SAMA because the 

currently in-progress implementation of a risk informed in-service inspection program 

based on ASME Code Case N-716 (N-716) explicitly addresses internal flooding 

initiators for inclusion in the program for in-service inspection. N-716 includes 

risk-informed in-service criteria to provide a method of ensuring that any plantspecific piping locations that are important to safety are identified. Therefore, even 

though ASME Section XI does not include or require any non-destructive

examination requirements for Safety Class 3 and non-nuclear safety class piping, 

N-716 would add such piping if it were determined to be high-safety significant based 

on the results of an internal flooding PRA. However, DTE indicated that based on 

the Fermi 2 PRA results, it is not likely that the important internal flooding initiators 

will meet the criteria for inclusion in the N-716 program, therefore a new SAMA was 

evaluated. This SAMA would be the implementation of an inspection program for the 

piping associated with the risk-significant internal flooding initiators. This change 

would be implemented by adding visual inspection of these pipes to the regular shift 

rounds procedure. The SAMA was evaluated by assuming the inspections would 

result in a 25-percent reduction in the initiating event frequency for these initiators. 

The maximum benefit was determined to be $104,000, including external events and 

uncertainty. The cost of preparing the procedures and the labor to perform the 

inspections was estimated to be $209,000. Therefore, DTE concluded that this 

SAMA was not cost beneficial (DTE 2015b, 2015c).

• Regarding the potential for a flood barrier to prevent flood propagation to adjacent 

flood areas through openings and/or failed flood doors, DTE performed some 

additional cost-benefit analyses as follows (DTE 2015a, 2015b, 2015c): 

− Installing a flood/watertight door between the auxiliary building and relay room 

would lead to a maximum benefit of $111,000, including external events and 

uncertainty. Subsequently, DTE concluded that such a SAMA would not be cost 

beneficial.

− Making the turbine building to auxiliary building isolation door failure-proof 

(presently assumed to have a failure probability of 1×10−4

) or adding barrier

capability that would lead to a maximum benefit of $56,800, including external 

events and uncertainty. Subsequently, DTE concluded that such a SAMA would 

not be cost beneficial.

− Adding a flood barrier or curb between the DC switchgear room and the

Division 2 AC switchgear room would lead to a maximum benefit of $225,000, 

including external events and uncertainty. DTE noted that this benefit is from a 

revised base case that took some credit for operator isolation of the initiating pipe 

breaks compared to the normal base case in which no credit was conservatively 

taken for this action. Subsequently, DTE concluded that a SAMA to install such 
Appendix F

F-25

a flood barrier or curb between DC switchgear room and the Division 2 AC 

switchgear room would be potentially cost beneficial.

• The current Fermi 2 design and PRA is such that if the reactor building heating 

ventilation and air conditioning (HVAC) to standby gas treatment system isolation 

valve fails to close when the containment is vented to prevent overpressure, the 

HVAC duct may fail. There is then a pathway for steam and other releases to the 

third floor of the reactor building, which results in the potential for damage to 

important mitigation equipment. In the ER, DTE stated that the response to NRC 

Order EA-12-050 (NRC 2012c) is to include measures that would increase the 

likelihood of successful containment venting to prevent containment overpressure. 

In response to an NRC staff RAI to clarify the impact of this order on the above 

situation, DTE noted that the NRC has rescinded Order EA-12-050 and replaced it 

with Order EA-13-109, “Order to Modify Licenses with Regard to Reliable Hardened 

Containment Vents Capable of Operation under Severe Accident Conditions”

(NRC 2013), which establishes numerous functional requirements for a hardened 

containment venting system (HCVS). Development of a HCVS system, by 

modification of the existing system or installation of a new system, will result in a 

robust and reliable venting system and will also mitigate the valve and duct failure 

event. Specifically, compliance with the requirements to minimize unintended cross 

flow of vented fluids within a unit and to minimize the potential for hydrogen gas 

migration and ingress into the reactor building will prevent or significantly reduce the 

likelihood of this event because the flow path from the vent to the reactor building 

HVAC system will be reduced.

In response to an NRC staff RAI on how SAMAs from the 11 previous industry SAMA analyses 

were selected for incorporation into the Fermi 2 Phase I SAMA identification, DTE indicated that 

the review of industry SAMA analyses was focused on identifying SAMA candidates proved to 

be potentially cost beneficial for other plants. These SAMA candidates were then screened 

based on their applicability to the Fermi 2 plant design, if they had already been implemented, 

or if they were covered by a SAMA candidate already retained for a cost-benefit analysis. DTE 

noted that no potentially cost-beneficial SAMA candidates for other sites were screened from 

the Fermi 2 analysis based on excessive implementation costs (DTE 2015a).

As noted above, while no vulnerabilities were found in the IPE, several opportunities for 

enhancements were identified. The NRC staff SER on the IPE notes that the hard-piped 

containment venting was installed but indicates that several potential plant improvements were 

identified for further consideration. The NRC staff noted in an RAI that the status of these 

enhancements is not addressed in the ER and are not included in the Phase I list of candidate 

SAMAs. DTE responded by providing a summary description of the implementation of each of 

the IPE-identified enhancements and confirmed that they all have been implemented 

(DTE 2015a).

Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, 

together with those identified in response to NRC staff RAIs, addresses the major contributors 

to the internal events CDF. 

As discussed in Section F.2.2.2, although the IPEEE did not identify any fundamental 

vulnerabilities or weaknesses related to external events, a number of “outliers” were identified 

from the IPEEE seismic assessment (DECo 1996). The IPEEE items in the Phase I list of 

candidate SAMAs include the six seismic outliers identified in Section F.2.2.2. As discussed 

above, DTE’s actions in response to the 50.54(f) letter (NRC 2012a) that requested information 
Appendix F

F-26

related to the Fukushima Daiichi NTTF recommendations, confirmed that all of these items have 

been addressed and are considered resolved (DTE 2012a). 

DTE’s review of the IPEEE fire analysis led to the development of six candidate SAMAs 

addressing the risk from the important fire CDF contributors listed in Table F–4. These

candidate SAMAs were included in the Phase I (and Phase II) SAMA analysis.

As stated earlier, DTE’s IPEEE analysis of other external hazards (high winds, tornadoes, 

external floods, and other external events) did not identify any opportunities for improvements 

for these events.

As discussed above, the NRC staff notes that the Fermi 2 external flooding design and 

capability was assessed in the engineering walkdowns and evaluations required for the 

response to the Fukushima Near-Term Task Force’s Recommendation 2.3 (DTE 2012b; 

NRC 2012a). The NRC staff's SER on the walkdown (NRC 2014b) stated, “The staff concludes

that the licensee, through the implementation of the walkdown guidance activities and, in 

accordance with plant processes and procedures, verified the plant configuration with the 

current flooding licensing basis; addressed degraded, nonconforming, or unanalyzed flooding 

conditions; and verified the adequacy of monitoring and maintenance programs for protective 

features.” 

As discussed above, DTE eliminated numerous Phase I SAMA candidates from further 

consideration using a number of criteria. As part of the onsite audit (NRC 2014c), the NRC staff 

reviewed the documentation of this screening and asked DTE to provide additional information 

concerning the basis for eliminating certain Phase I SAMAs from further consideration. The 

additional information provided resolved all of the NRC staff’s concerns, and no additional 

Phase II SAMAs were identified based on this review of the Phase I screening.

The NRC staff did note in an RAI that a Phase I SAMA to install a filtered containment vent to 

remove decay heat was combined with Phase II SAMA 123 for an ATWS sized filtered 

containment vent. Because a filtered vent to remove decay heat is considerably smaller than 

that required for an ATWS event, the evaluation of SAMA 123 does not appear to be valid for 

the decay heat sized SAMA. In response, DTE indicated that the cost of the SAMA 123 

ATWS-sized filtered vent was a rough conceptual cost of $40 million, estimated in 2013 from an 

industry group discussion on a filtered vent. At that time, the cost was assumed to be in the 

range of $40 million to $50 million. DTE also noted in response to an NRC request that NEI 

submitted cost estimates for a filtered vent with a small filter and severe accident capable water 

makeup and for a large filter with severe accident capable water makeup. Neither filter was 

sized for an ATWS. The cost estimates provided were conceptual in nature. With contingency 

and subtracting the estimated $3.7 million cost of the water makeup, the estimated costs were

$31.7 million for the small filter and $51.2 million for the large filter. These cost estimates were 

based on incremental costs of filter installation relative to current conceptual designs planned 

for hardened containment vent in compliance with NRC Order EA-13-109. Given these 

estimates are for a vent that is not specifically sized for an ATWS, the cost is appropriate for the 

normal decay heat SAMA and is lower than what it would cost for an ATWS-sized vent. Even 

considering the cost for the smaller filter of $31.7 million, the normal decay heat SAMA is not 

cost beneficial (DTE 2015a).

The NRC staff questioned DTE about potentially lower cost alternatives to some of the SAMAs 

evaluated (NRC 2014a), including:

• A SAMA to improve training specifically for basic event “Operators fail to shutdown 

from outside the main control room” instead of SAMA 145 regarding increased 

training and operating experience feedback to improve operator response, which is 
Appendix F

F-27

much broader in scope. In response to the RAI, DTE noted, that with a risk reduction 

worth of 1.13, the risk significance of this basic event is well known and that this 

event is specific to flooding events that require abandonment of the main control 

room (MCR). An analysis was performed to determine the benefit from increased 

training specifically for this event assuming a 50-percent decrease in the failure 

probability to shut down from outside the MCR. The analysis resulted in a maximum 

assessed benefit of $71,200, including external events and uncertainty. Since a 

simple procedure change is not anticipated to result in significant improvement for 

this operator action, procedure changes with training would be required. Therefore, 

implementation of this SAMA would not be cost beneficial

(DTE 2015a, 2015b, 2015c).

• SAMAs including only leak detection as alternatives to SAMAs 213 and 214 (both of 

which involve providing leak detection and automatic isolation valves for emergency 

equipment cooling water (EECW) piping) might provide sufficient time for manual 

actions to isolate the flood source, thereby limiting the failures due to flooding, 

particularly in adjacent rooms. In response to the RAI, DTE provided a discussion of 

the flood scenarios in the DC switchgear room and the Division 2 switchgear room 

and the time associated with flood propagation into the adjacent rooms. DTE 

concluded that providing only leak detection might be cost beneficial. However, 

upon further investigation of the existing alarms on the systems associated with the 

flooding, the timing available to take action and the proximity of these rooms to the 

MCR, DTE concluded that revising existing alarm response procedures (ARPs) to 

direct operators to these rooms following indication of leakage in reactor building 

component cooling water (RBCCW)/EECW system piping could be a potentially 

cost-beneficial SAMA and will be retained for further evaluation (DTE 2015a).

The NRC staff notes that the set of SAMAs submitted is not all-inclusive, because additional, 

possibly even less expensive, alternatives can always be postulated. However, the NRC staff 

concludes that the benefits of any additional modifications are unlikely to exceed the benefits of 

the modifications evaluated and that the alternative improvements would not likely cost less 

than the least expensive alternatives evaluated, when the subsidiary costs associated with 

maintenance, procedures, and training are considered.

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 potential plant 

improvements identified by DTE is reasonably comprehensive and, therefore, acceptable. This 

search included reviewing insights from the plant-specific risk studies and reviewing plant 

improvements considered in previous SAMA analyses. While explicit treatment of external 

events in the SAMA identification process was limited, the NRC staff determined that the prior 

implementation of plant modifications, the absence of external event vulnerabilities, and DTE’s 

compliance with the approved alternative approach for addressing external events provide a 

reasonable justification to primarily examine the internal events risk results for the purpose of 

identifying SAMAs. 

F.4 Risk Reduction Potential of Plant Improvements

DTE evaluated the risk-reduction potential of the 79 SAMAs retained for the Phase II evaluation 

in the ER (DTE 2014). 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 taken to be optimistically low, thereby 

overestimating the benefit of the SAMA. In other cases, it was assumed that the SAMA 
Appendix F

F-28

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. Changes made to the 

model to quantify the impact of each SAMA are described in Section D.2.3 of the ER. 

Table F–5 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, population 

dose, and offsite economic cost, and the estimated total benefit (present value) of the averted 

risk. The determination of the benefits for the various SAMAs is further discussed in 

Section F.6.

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. The resolution of RAIs 

that resulted from this review follow.

For SAMA 023 regarding developing procedures to repair or replace failed 4-kV breakers, the 

benefit was estimated by eliminating failure of the operator to cross tie non-emergency buses, 

failure to recover AC power from plant and switchyard-centered events, as well as failure during 

operation of non-emergency 4.16-kV buses. In response to an NRC staff RAI concerning other 

4-kV breaker failures that can be mitigated by this SAMA, DTE responded that this SAMA 

originated from a vulnerability identified in the IPE at another plant. Because this vulnerability 

does not exist at Fermi 2, DTE concluded that this SAMA should have been screened out in 

Phase I (DTE 2015a). In a further response, DTE evaluated the benefit of a 20-percent

reduction in the failure probabilities for all breakers greater than 600 volts. The averted cost 

including external events and uncertainty was found to be $35,600; therefore, DTE concluded 

that this SAMA is not cost beneficial (DTE 2015b).

The title of SAMA 031, revise procedures to allow intermittent operations of HPCI and RCIC, is 

not consistent with the stated intent and basis of the evaluation of the SAMA to eliminate the 

intermittent operation of HPCI/ RCIC by allowing flow to be throttled, thus preventing intermittent 

starts and stops. In response to an NRC staff RAI to clarify the SAMA description and intent 

indicated that SAMA 031 apparently originated from a situation at two other BWRs where it was 

desirable to operate HPCI or RCIC in such a manner as to slow the rate of depressurization of 

the RPV, thereby maintaining the vessel at a higher pressure and extending the duration at 

which RPV pressure can support successful operation of HPCI/RCIC. DTE indicated that this 

situation does not exist at Fermi 2 and consequently SAMA 031 as defined in NEI 05-01 is not 

applicable to Fermi 2 (DTE 2015a). As discussed above in Section F.3.2, a new SAMA 

involving a procedure change aimed at reducing the number of HPCI/RCIC on/off cycles was 

not cost beneficial upon further evaluation. 

For SAMA 074 to improve pneumatic components of safety relief valves (SRVs) and main 

steam isolation valves (MSIVs), the benefit was determined by eliminating the air dependency of 

these valves. In response to an NRC staff RAI on how this benefit models the improvement of 

the reliability of SRVs and MSIVs, DTE provided the results of an alternate evaluation that 

assumed the independent and common cause hardware (as well as AC and DC power to the 

valves) was improved by 15 percent. The result was a maximum benefit of $2,400, and DTE 

concluded that this SAMA was not cost beneficial (DTE 2015a). In addition, in response to an 

NRC staff RAI, DTE discussed the design and modeling features of Fermi 2 that led to this low 

benefit. The major factor was a high level of redundancy, particularly with respect to the SRVs. 

This factor combined with a low frequency of serious demands results in a relatively low 

importance of valve failures (DTE 2015b).
Appendix F

F-29

In an NRC staff RAI, DTE was asked to provide further information and justification for the 

modeling of the benefit of SAMA 078 to enable flooding of the drywell head seal including the 

expected containment failure location(s), why only Class II and IV large rupture sequences were 

considered and why the benefit is so small considering that Class IV (ATWS sequences) would 

be expected to make up a significant part of release category H/E, which is the major contributor 

to risk. DTE indicated that drywell head leakage, mitigated by this SAMA, is a dominant 

containment failure mode only for accident scenarios involving high and intermediate 

containment temperatures. Most of the Class II and Class IV sequences involve containment 

failure prior to core damage and therefore do not involve high or intermediate containment 

temperatures. DTE provided an alternative bounding evaluation of the benefit of this SAMA by 

assuming that the drywell never fails in the Level 2 analysis. This resulted in a maximum 

benefit of $244,000 including uncertainty. Compared to an estimated cost of $1 million (from 

the Vermont Yankee LRA), DTE concluded this SAMA is not cost beneficial (DTE 2015a). 

In response to an NRC staff RAI concerning SAMA 154, to modify procedures to allow switching 

of the combustion turbines to buses while running, DTE stated that such procedures already 

exist and this SAMA should have been screened during Phase I (DTE 2015a).

The NRC staff in an RAI noted that while SAMAs 165 and 166 both address mitigating the 

failure of emergency core cooling system low pressure permissive with an order-of-magnitude 

improvement in the operator action to bypass the low pressure permissive resulted in a 

3 percent reduction in CDF, the human error probability for this operator action does not appear 

in the Level 1 importance list. DTE responded that this human error basic event was mistakenly 

omitted from the Table D.1–2 importance list because it had a value of 1.0 and was assumed to 

be a flag event rather than representing an actual failure event.

DTE indicated that a search for other events omitted from the importance analyses tables for 

the same reason was performed. One additional Level 1 basic event was identified 

representing failure to terminate the flood from EECW in an AB3 switchgear room. A new 

SAMA evaluation was performed for this event to evaluate the potential improvement from 

crediting a new procedure for manually closing the valves that isolates the flood. The probability 

of the event was changed from 1.0 to 0.1 resulting in a maximum benefit of $302,000 including 

external events and uncertainty. Based on this result, DTE concluded that this SAMA would be 

potentially cost beneficial even when assuming a cost in the high range for procedures 

(e.g., $200,000) (DTE 2015a, 2015b, 2015c). 
F-30

Table F–5. SAMA Cost/Benefit Screening Analysis for Fermi 2 Station(a)

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

009 - Reduce direct current dependence between 

high-pressure injection systems and ADS 1 <1 <1 6K 

Assumption: HPCI uses Division 2 direct current power while automatic depressurization system (ADS) valves are powere

therefore, the intent of this SAMA is met with the current design. However, to assess the benefit from eliminating the direc

of ADS, failure of the Division 1 130V direct current batteries was eliminated.

012 - Improve 4.16-kV bus cross-tie ability 5 2 2 79K 

Assumption: Improving the ability to cross-tie the 4.16-kV busses would increase the availability of onsite alternating curre

the potential benefit, the existing cross-ties between the Division 1 and Division 2 engineered safety feature (ESF) buses a

fail.

014 - Install an additional, buried off-site power source 5 8 13 345K 

Assumption: Installing an additional, buried offsite power source, or burying offsite power lines would decrease the probab

weather-related events. To assess the potential benefit, a bounding analysis was performed by eliminating all weather-rel

LOOP events.

016 - Install tornado protection on gas turbine 

generator 3 5 9 245K 

Assumption: Installing tornado protection on the gas turbine generator would eliminate or reduce weather-related failures 

bounding analysis was performed by eliminating all weather-induced failures of the CTG.

018 - Improve uninterruptible power supplies <0.1 <1 <1 8K 

Assumption: Improving the reliability of uninterruptible power supplies would reduce the frequency of loss of power to ess

instruments. A bounding analysis was performed by eliminating the failure of the modular power units, which provide the u

supply to essential plant instruments.

021 - Use fire water system as a backup source for 

diesel cooling 4 6 9 257K(d) 

Assumption: This analysis was used to evaluate the change in plant risk from improving the reliability of diesel cooling by 

source of cooling. The analysis was performed by assuming that the diesel driven fire pump would be manually aligned to 

cooling. The manual action was given a failure probability of 0.1. The benefit of adding an entirely new source of diesel c

comparable to that of using the fire water system, but the cost of implementation would be much higher.
F-31

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

023 - Develop procedures to repair or replace failed 

4-kV breakers(c) <0.1 <1 <1 8K 

Assumption: Developing procedures to repair or replace failed 4 kV breakers would increase the probability of recovery fr

that transfer 4.16 kV non-emergency buses from unit station transformers. An analysis was performed by eliminating failu

cross-tie non-emergency buses, failure to recover alternating current power from plant and switchyard centered events, as 

operation of non-emergency 4.16 kV buses.

024 - In training, emphasize steps in recovery of offsite 

power after an SBO <1 <0.1 <1 6K(d) 

Assumption: Increased training with emphasis on recovery could reduce the human error in steps to recover offsite power 

Because enhanced training is not likely to improve the ability to recover offsite power from grid and severe weather-related 

evaluation assumed that only the probability to recover offsite power after plant centered and switchyard centered events 

The analysis assumed a 25-percent improvement in recovery of offsite power for Level 1 events (i.e., 30-minute, 4- and 12

common failure to respond to SBO was also eliminated.

026 - Bury offsite power lines 5 8 13 345K 

Assumption: Installing an additional, buried offsite power source, or burying offsite power lines would decrease the probab

weather-related events. To assess the potential benefit, a bounding analysis was performed by eliminating all weather-rel

LOOP events.

028 - Provide an additional high pressure injection 

pump with independent diesel 28 6 6 288K 

Assumption: Installing an additional high pressure injection pump with an independent diesel would reduce the frequency 

LOCA and SBO sequences. To assess the change in plant risk from installing an additional high pressure injection pump, 

performed by eliminating failures of the existing standby feedwater pumps to provide sufficient flow, which includes power 

analysis also conservatively eliminated standby feedwater failures induced from failure of balance-of-plant batteries.

029 - Raise HPCI/RCIC backpressure trip set points 2 <0.1 <0.1 10K 

Assumption: Raising the HPCI and RCIC backpressure trip set points would increase the system availability when the sup

temperature is high. To assess the change in plant risk, the HPCI and RCIC turbine trip and automatic turbine isolation du

exhaust pressure were eliminated.

031 - Revise procedure to allow intermittent operations 

of HPCI and RCIC(c) 3 <1 <1 16K 
F-32

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: This analysis was used to evaluate the change in plant risk from increasing the throttling ability of HPCI and 

the number of system stops/restarts. The analysis was performed by eliminating the failure of both HPCI and RCIC during 

034 - Modify automatic depressurization system

components to improve reliability <0.1 <0.1 <0.1 <1K 

Assumption: Modifying automatic depressurization system components to improve their reliability would reduce the freque

core damage sequences. To assess the change in plant risk for this SAMA, analysis was performed by eliminating the fai

demand of all safety relief valves (SRVs), both ADS and non-ADS SRVs.

041 - Provide capability for alternate injection via 

reactor water cleanup <1 <1 <1 6K 

Assumption: This analysis was used to evaluate the change in plant risk from improving injection capability through either 

pump or reactor water cleanup. The analysis was performed by assuming that the diesel fire pump never failed (for injecti

modeled functions), as well as assuming that the flowpath for RPV injection via the diesel fire pump never failed.

046 - Improve ECCS suction strainers 2 2 2 73K 

Assumption: This analysis was used to evaluate the change in plant risk from improving the reliability of the ECCS suction 

analysis was performed by eliminating all plugging of the ECCS suction strainers.

050 - Change procedures to allow cross connection of 

motor cooling for RHRSW pumps

<1 <1 <1 13K(d) 

Assumption: This analysis was used to evaluate the change in plant risk from revising procedures to increase the availabi

by allowing cross connection of motor cooling for the RHRSW pumps. A bounding analysis was performed by eliminating 

Division 1 and Division 2 RHRSW pumps.

051 - Add redundant direct current control power for 

service water pumps <0.1 <0.1 <0.1 1K 

Assumption: Adding redundant direct current control power for service water pumps would increase the availability of serv

the change in plant risk, it was assumed that long-term power to the RHRSW pumps where battery chargers are required 

053 - Provide self-cooled ECCS seals 3 6 10 264K 

Assumption: Providing self-cooled ECCS seals would eliminate the dependency of ECCS on the component cooling syste

spray pumps are the only ECCS pumps that require pump cooling for the probabilistic risk assessment mission time, a bou

performed by eliminating the failure of core spray pump cooling.

054 - Enhance procedural guidance for use of 

cross-tied component cooling or service water pumps <1 <0.1 <0.1 3K(d) 
F-33

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: Enhancing procedural guidance for use of cross-tied component cooling or service water pumps would reduc

loss of these systems. An analysis was performed by allowing cross-connection of Division 1 and 2 emergency equipmen

Additionally, the analysis also eliminated all hardware failure initiating events of the general service water.

055 - Implement modifications to allow manual 

alignment of the fire water system to RHR heat 

exchangers

<1 <0.1 <0.1 2K 

Assumption: Implementing modifications to allow manual alignment of the fire water system to RHR heat exchangers wou

cool the RHR heat exchangers. To evaluate the change in plant risk, the fire water system was modeled as an additional 

and Division 2 RHR complex.

067 - Enhance procedure to trip unneeded RHR or 

core spray pumps on loss of room ventilation <1 <0.1 <0.1 1K(d) 

Assumption: This analysis was used to evaluate the change in plant risk from extending the availability of the RHR or core 

reduction in room heat load. To evaluate the change in plant risk, probability of failure of the crew to limit the number of op

was decreased by an order of magnitude to simulate enhanced procedures.

068 - Stage backup fans in switchgear rooms <0.1 <0.1 <0.1 <1K 

Assumption: Room cooling is not required for alternating current power switchgear rooms. However, Division 2 ESF direc

charger room does require cooling or ventilation. An operator action currently exists to open a door per procedure in case 

The analysis performed decreased the failure probability of this operator action by two orders of magnitude.

071 - Modify procedure to provide ability to align diesel 

power to more air compressors <0.1 <0.1 <0.1 <1K 

Assumption: Providing the ability to align diesel power to more air compressors would increase the availability of instrume

event. To evaluate the change in plant risk from providing diesel power to the air compressors, all power dependencies of 

were removed.

072 - Replace service and instrument air compressors 

with more reliable compressors that have 

self-contained air cooling by shaft driven fans

2 3 3 100K 
F-34

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: Replacing the service and instrument air compressors could eliminate the instrument air system dependence 

water. Providing an additional portable compressor to be aligned to the supply header would reduce the risk associated w

air. A bounding analysis was performed by eliminating the failure of air supply from both divisions of the noninterruptible a

failure of the station air compressors.

074 - Improve SRV and MSIV pneumatic 

components(c) <0.1 <0.1 <0.1 <1K 

Assumption: This analysis was used to evaluate the change in plant risk from modifications to improve the reliability of SR

bounding analysis was performed by eliminating the air dependency of MSIV components and the Division 1 SRVs (which 

valves).

077 - Cross-tie open cycle cooling system to enhance 

drywell spray system <0.1 <0.1 <1 3K 

Assumption: This analysis was used to evaluate the change in plant risk from modifications to cross-tie the RHRSW syste

availability of containment heat removal. A bounding analysis was performed by eliminating the failure of both drywell spra

078 - Enable flooding of the drywell head seal(c) <0.1 <1 <1 9K(d) 

Assumption: Enabling flooding of the drywell head seal would reduce the probability of leakage through the seal. To eval

plant risk, it was assumed that flooding the drywell head seal would eliminate all Class II or Class IV accident sequences w

failures.

083 - Enhance procedure to maintain ECCS suction 

on condensate storage tank as long as possible <0.1 <0.1 <0.1 <1K 

Assumption: Maintaining ECCS suction on the condensate storage tank as long as possible would reduce the chance of p

high suppression pool temperature. A bounding analysis was performed by assuming that the condensate storage tank w

long-term makeup for HPCI and RCIC.

091 - Improve vacuum breaker reliability by installing 

redundant valves in each line <1 2 2 53K 

Assumption: Installing redundant valves in each line would improve vacuum breaker reliability and decrease the conseque

breaker failure to reseat. To evaluate the change in plant risk, a bounding analysis was performed by eliminating random 

failures, tailpipe vacuum breakers sticking open, as well as common cause failure of vacuum breakers.

093 – Provide post-accident containment inerting 

capability <0.1 3 3 96K 
F-35

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: Providing post-accident containment inerting capability, or installing a passive hydrogen control system woul

of hydrogen and carbon monoxide gas combustion. To evaluate the change in plant risk, a bounding analysis was perform

hydrogen deflagrations that results in containment or drywell failure.

100- Institute simulator training for severe accident 

scenarios 9 8 10 310K 

Assumption: This analysis was used to evaluate the change in plant risk from increasing training to improve the success p

operator actions. The change in plant risk was evaluated by decreasing the likelihood of failure for important human action

operator actions with a risk reduction worth of greater than 1.005 were improved by 10 percent.

103 - Install a passive hydrogen control system <0.1 3 3 96K 

Assumption: Providing post-accident containment inerting capability, or installing a passive hydrogen control system woul

of hydrogen and carbon monoxide gas combustion. To evaluate the change in plant risk, a bounding analysis was perform

hydrogen deflagrations that results in containment or drywell failure.

107 - Increase leak testing of valves in ISLOCA paths <1 6 3 119K 

Assumption: This analysis was used to evaluate the change in plant risk from reducing the frequency of ISLOCA events, a

operators’ ability to cope with ISLOCAs. To assess this potential benefit, the frequency of all ISLOCA-initiating events was 

25 percent.

108 - Improve MSIV design <1 <1 <1 12K 

Assumption: Improving the MSIV design would decrease the likelihood of containment bypass scenarios. To assess this 

of the inboard and outboard MSIV to close (including common cause) was eliminated. Additionally, hardware failures asso

failing to remain open, MSIV pneumatics support failures, and random MSIV closures were all eliminated from the model.

112 - Revise emergency operating procedures to 

improve ISLOCA identification <1 6 3 119K 

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 

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.
F-36

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

115 - Revise procedures to control vessel injection 

to prevent boron loss or dilution following standby 

liquid control injection

2 4 4 122K 

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.

117 - Increase boron concentration in the standby 

liquid control system 1 1 1 43K 

Assumption: This analysis was used to evaluate the change in plant risk from increasing the boron concentration in the st

system, which would reduce the time required to achieve shutdown concentration. To assess the benefit, the failure proba

actions to initiate the standby liquid system, both early and late, were each improved by 25 percent.

121 - Increase SRV reseat reliability <1 1 1 35K 

Assumption: Increasing the reseat reliability of SRVs will reduce the risk of boron dilution due to SRV failure to reseat afte

injection. A bounding analysis was performed by eliminating all stuck open relief valve and inadvertent open relief valve e

123 – Install an ATWS-sized filtered containment vent 

to remove decay heat <1 35 38 1.1M(d) 

Assumption: To evaluate the change in plant risk from installing an ATWS-sized filtered containment vent, an analysis wa

decreasing the concentration of all radionuclides, excluding noble gases, by 50 percent. Because no modifications were m

Level 2 probabilistic risk assessment model, there was no change in CDF or release category frequency. The averted cos

by comparing the base MMACRBaseline to the MMACRSAMA using a 50 percent reduction in radionuclide concentrations.

141 - Install digital large break LOCA protection 

system 1 2 2 68K 

Assumption: This analysis was used to evaluate the change in plant risk from installing digital large break LOCA (leak-bef

system. The analysis was performed by eliminating all large LOCA-initiating events.

145 - Increase training and operating experience 

feedback to improve operator response 9 8 10 310K(d) 

Assumption: This analysis was used to evaluate the change in plant risk from increasing training to improve the success p

operator actions. The change in plant risk was evaluated by decreasing the likelihood of failure for important human action

operator actions with a risk reduction worth of greater than 1.005 were improved by 10 percent.
F-37

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

149 - Provide a portable EDG fuel oil transfer pump:

This SAMA provides additional means of supplying the 

EDG day tank in the event a common cause failure 

prevents operation of the existing pumps

<0.1 <0.1 <0.1 <1K 

Assumption: This analysis was used to evaluate the change in plant risk from eliminating the dependency of EDGs on die

analysis was performed by eliminating all failures of the fuel oil support system for each EDG.

151 - Provide a diverse swing diesel generator air start 

compressor

1 <1 <1 21K 

Assumption: This analysis was used to evaluate the change in plant risk from installing a diverse swing diesel generator a

bounding analysis was performed by eliminating all fails to start events, including common cause, from each diesel genera

152 - Proceduralize all potential 4-kV AC bus cross-tie 

actions 1 1 1 25K(d) 

Assumption: Proceduralizing all potential 4 kV AC bus cross-tie actions would improve the availability of the 4 kV power s

was performed by assuming a 50 percent improvement for operator actions to align 4 kV AC cross-ties.

154 - Modify procedures to allow switching of the 

combustion turbines to buses while running <1 <1 <1 7K 

Assumption: This analysis was used to evaluate the change in plant risk from increasing the availability of onsite AC powe

of the combustion turbines to buses while running. A bounding analysis was performed by eliminating all failures during op

including the startup diesel generator. Additionally, failures of the CTGs transformers during operation were also eliminate

155 - Protect transformers from failure 4 4 5 146K 

Assumption: This analysis was used to evaluate the change in plant risk from reducing the LOOP frequency by protecting 

failure. The analysis was performed by decreasing initiating event frequencies for the LOOP by two orders of magnitude.

165 - Modify procedures to defeat the low reactor

pressure interlock circuitry that inhibits opening the 

LPCI or core spray injection valves following sensor or 

logic failures that prevent all low pressure injection 

valves from opening

3 <1 1 26K 

Assumption: This analysis was used to evaluate the change in plant risk from eliminating the probability of ECCS low pres

failing. An analysis was performed by improving the operator action to bypass the low pressure permissive by an order of 
F-38

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

166 - Install a bypass switch to allow operators to 

bypass the low reactor pressure interlock circuitry that 

inhibits opening the LPCI or core spray injection valves 

following sensor or logic failures that prevent all low 

pressure injection valves from opening

3 <1 1 26K 

Assumption: This analysis was used to evaluate the change in plant risk from eliminating the probability of ECCS low pres

failing. An analysis was performed by improving the operator action to bypass the low pressure permissive by an order of 

167 - Improve training on alternate injection via the fire 

water system, increasing the availability of alternate 

injection

<1 <1 <1 6K 

Assumption: This analysis was used to evaluate the change in plant risk from improving injection capability through either 

pump or reactor water cleanup. The analysis was performed by assuming that the diesel fire pump never failed (for injecti

modeled functions), as well as assuming that the flowpath for RPV injection via the diesel fire pump never failed.

169 - Revise procedures to allow the ability to 

cross-connect the circulating water pumps and the 

service water going to the turbine equipment cooling 

system heat exchangers, allowing continued use of the 

power conversion system after service water is lost

1 1 1 22K 

Assumption: This analysis was used to evaluate the change in plant risk from continued use of the power conversion syst

is lost. The analysis was performed by eliminating failures of the turbine building closed cooling water, which includes failu

the turbine building closed cooling water heat exchangers, and LOOP.

175 - Operator procedure revisions to provide 

additional space cooling to the EDG room via the use 

of portable equipment

3 1 2 61K 

Assumption: This analysis was used to evaluate the change in plant risk from revising procedures to provide additional co

EDG rooms via opening doors or through the use of portable equipment. The analysis was performed by adding an opera

temporary ventilation to the EDGs.

176 - Develop a procedure to open the door to the 

EDG buildings upon the high temperature alarm 3 1 2 61K 
F-39

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: This analysis was used to evaluate the change in plant risk from revising procedures to provide additional co

EDG rooms via opening doors or through the use of portable equipment. The analysis was performed by adding an opera

temporary ventilation to the EDGs.

177 - Provide an alternate means of supplying the 

instrument air header: This SAMA involves 

procurement of an additional portable compressor to 

be aligned to the supply header to reduce the risk 

associated with loss of instrument air

2 3 3 99K(d) 

Assumption: Replacing the service and instrument air compressors could eliminate the instrument air system dependence 

water. Providing an additional portable compressor to be aligned to the supply header would reduce the risk associated w

air. A bounding analysis was performed by eliminating the failure of air supply from both divisions of the noninterruptible a

failure of the station air compressors.

183 - Improve alternate shutdown panel(c) 1 1 1 30K 

Assumption: Installing additional transfer and isolation switches would reduce the number of spurious actuations during a 

alternate shutdown panel would increase the ability to shut down the plant from outside the MCR. This SAMA was evalua

the additional train will reduce the conditional core damage probability of operation from the alternate shutdown panel by a 

187 - Upgrade the alternate shutdown panel to include 

additional system controls for opposite division(c) 1 1 1 30K 

Assumption: Installing additional transfer and isolation switches would reduce the number of spurious actuations during a 

alternate shutdown panel would increase the ability to shut down the plant from outside the MCR. This SAMA was evalua

the additional train will reduce the conditional core damage probability of operation from the alternate shutdown panel by a 

188 - Increase fire pump house building integrity to 

withstand higher winds so that the fire system would 

be capable of withstanding a severe weather event

<1 <1 <1 7K 

Assumption: This analysis was used to evaluate the change in plant risk from increasing the ability of the building contain

diesel driven fire pump to withstand higher winds. A bounding analysis was performed by eliminating all failures of both th

driven fire pumps to perform their functions (condensate storage tank makeup and RPV injection).

190 - Implement insights from trip and shutdown risk 

modeling into plant activities, decreasing the

probability of trips/shutdown

4 5 6 189K 
F-40

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: This analysis was used to evaluate the change in plant risk from decreasing the probability of trip/shutdown r

performed by decreasing manual shutdown, loss of condenser vacuum and turbine trip with bypass initiating event frequen

194 - Provide ability to maintain suppression pool 

temperature lower (especially during summer months) 1 1 1 29K(d) 

Assumption: This analysis was used to evaluate the change in plant risk from improving the ability to maintain the suppres

lower. To estimate the change in plant risk, the events representing insufficient flow from RHR heat exchangers, inadequa

valve to RHR complex, heat exchanger unavailable due to maintenance, and misalignment of RHRSW Division 1 were elim

initial temperature of the suppression pool may give operators enough extra time to restore RHRSW before the limits are r

the system is down for maintenance or is misaligned.

195 - Improve reliability of control rod drive mechanical 

components 1 2 2 77K 

Assumption: This analysis was used to evaluate the change in plant risk from reducing ATWS frequency by improving the 

drive mechanical components. The analysis was performed by decreasing the failure probability of the control rod drive hy

10 percent.

196 - Provide redundant HPCI auxiliary oil pump or 

backup motive force for HPCI valves 1 <0.1 <0.1 5K 

Assumption: This analysis was used to evaluate the change in plant risk from reducing the failure risk of the auxiliary oil p

the hydraulic force to operate the HPCI turbine valves. The analysis was performed by excluding the failure to start of the 

pump.

197 - Upgrade flood barrier between direct current 

switchgear room and Division 2 alternating current 

switchgear room

1 3 3 90K 

Assumption: This analysis was used to evaluate the change in plant risk from physical upgrades to the doors between the 

switchgear room and the Division 2 alternating current switchgear room to prevent flooding in one room from propagating 

analysis was performed by assuming that flooding in one room could not propagate to the other.

198 - Provide automatic method of refilling the 

condensate storage tank 3 2 2 72K 

Assumption: This analysis was used to evaluate the change in plant risk from physical upgrades to provide an automatic m

condensate storage tank. The analysis was performed by excluding the condensate storage tank failures caused by an in

operator failure to refill the condensate storage tank.
F-41

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

199 - Increase surveillance of small break LOCA 

initiators 1 <1 <1 15K 

Assumption: This analysis was used to evaluate the change in plant risk from additional monitoring of piping and compon

small break LOCA if failed. The analysis was performed by assuming that increased surveillance would result in a 25 perc

initiating events for small break LOCAs.

200 - Improve capability of general service water 

pumps to operate during summer months 2 2 2 65K 

Assumption: This analysis was used to evaluate the change in plant risk from increasing successful operation of general s

during summer months. A bounding analysis was performed by assuming that the general service water pumps never fail

months.

201 - Install redundant high water level trip for RCIC 2 <0.1 <0.1 11K 

Assumption: This analysis was used to evaluate the change in plant risk from adding a redundant Level 8 trip device for R

was performed by eliminating the failure of the RCIC Level 8 Trip.

202 - Replace or upgrade reactor building closed 

cooling water pressure control valve 1 1 1 37K 

Assumption: This analysis was used to evaluate the change in plant risk from improving the reliability of the reactor buildin

system by replacing or upgrading the reactor building closed cooling water pressure control valve. The analysis was perfo

the initiating event frequency by two orders of magnitude for the loss of reactor building closed cooling water.

203 - Improve EDG maintenance procedures to 

decrease unavailability time 1 <1 <1 16K 

Assumption: This analysis was used to evaluate the change in plant risk from improving EDG maintenance procedures to 

which they are unavailable due to maintenance. The analysis was performed by assuming that improved procedures wou

unavailability due to maintenance for all EDGs by 50 percent, including times when multiple EDGs are unavailable.

204 - Improve test and maintenance procedures on

standby feedwater pumps to decrease their 

unavailability time

<1 <1 <1 8K 

Assumption: This analysis was used to evaluate the change in plant risk from improving standby feedwater pump test and 

procedures to decrease the time in which standby feedwater is unavailable due to maintenance. The analysis was perform

improved procedures would decrease the unavailability due to test and maintenance for the standby feedwater pump by 5
F-42

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

205 - Improve test and maintenance procedures on

HPCI pump/turbine to decrease unavailability time 2 <0.1 <1 9K 

Assumption: This analysis was used to evaluate the change in plant risk from improving HPCI pump/turbine test and main

decrease the time in which HPCI is unavailable due to maintenance. The analysis was performed by assuming that impro

decrease the unavailability due to test and maintenance for HPCI by 50 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 

Assumption: During the IPEEE, it was determined that the human action to manually close a damper to isolate the third flo

building from the hardened vent path when the non-interruptible air supply had failed was not feasible. Even though the fa

with fire, it accounts for 1.55x10-6 per year of the Control Room and 6.09x10-7 per year of the northeast quadrant of the Re

in the modified Fermi fire assessment results. A backup air bottle supply and local control for this damper would allow this 

performed.

207 - Add incipient fire detection and suppression to 

selected cabinets in the Division 1 switchgear room

8 8 8 270K 

Assumption: Four components in the Division 1 Switchgear Room (04ABN) account for approximately 66% of the fire CDF 

components are the 480V 72C Bus/Transformer, 480V 72B Bus/Transformer, 4160V 64C Bus and the 4160V 64B Bus. T

fire detection and automatic actuation systems for these components will reduce the CDF of these fires significantly. To d

this modification, the assumption is made that the detection/auto suppression system has a failure probability of 0.05. It is 

CCDP for a fire with successful suppression is equal to the CCDP associated with a non-severe fire. Non-severe fires will 

equipment in the room, while severe fires will result in failure of all equipment in the room. Therefore, the severe fire scen

components are revised from one scenario to two scenarios: one with successful suppression and one with failed suppres

modification, the fire CDF is reduced by 1.36×10−6 per year. This reduction in fire CDF was applied proportionately to eac

208 - Add incipient fire detection and suppression to 

selected cabinets in the Relay room 5 5 5 169K 
F-43

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: Three panels in the Relay room (03AB) account for approximately 70 percent of the fire CDF in the room. Th

P620, P613, and P622. The addition of incipient fire detection and automatic actuation systems for these components will 

these fires significantly. To determine the impact of this modification, the assumption is made that the detection/auto supp

failure probability of 0.05. It is also assumed that the conditional core damage probability for a fire with successful suppres

order of magnitude compared to the original conditional core damage probability. Therefore, the original fire scenarios for 

revised from one scenario to two scenarios; one with successful suppression and one with failed suppression. With this m

CDF is reduced by 8.3×10−7 per year. This reduction in fire CDF was applied proportionately to each release category.

209 - Add incipient fire detection and suppression to 

selected cabinets in the Division 2 switchgear room 5 5 5 179K 

Assumption: Five components in the Division 2 switchgear room (12AB) account for approximately 76 percent of the fire C

These components are the 480V 72F Bus/Transformer, 480V 72E Bus/Transformer, 4160V 65F Bus, 4160V 65E Bus, and 

The addition of incipient fire detection and auto actuation systems for these components will reduce the CDF of these fires 

determine the impact of this modification, the assumption is made that the detection/auto suppression system has a failure 

is also assumed that the conditional core damage probability for a fire with successful suppression is equal to the condition

probability associated with a non-severe fire. Non-severe fires will not propagate to other equipment in the room, while se

failure of all equipment in the room. Therefore, the severe fire scenarios for these components are revised from one scen

one with successful suppression and one with failed suppression. With this modification, the fire CDF is reduced by 8.74×

reduction in fire CDF was applied proportionately to each release category.

210 - Add incipient fire detection and suppression to 

selected cabinets in the Division 1 portion of the 

Miscellaneous room

3 3 3 98K 

Assumption: Three cabinets in the Division 1 portion of the Miscellaneous room (11ABE) account for approximately 60 pe

the room. These cabinets are MCC 2PA-1, MCC 2PB-1, and Cabinet 2PA-2. The addition of incipient fire detection and a

systems for these cabinets will reduce the CDF of these fires significantly. To determine the impact of this modification, th

that the detection/auto suppression system has a failure probability of 0.05. It is also assumed that the conditional core da

fire with successful suppression is reduced by an order of magnitude compared to the original conditional core damage pr

the original fire scenarios for these components are revised from one scenario to two scenarios: one with successful supp

failed suppression. With this modification, the fire CDF is reduced by 4.85×10−7 per year. This reduction in fire CDF was a

to each release category.

211 - Add incipient fire detection and suppression to 

selected cabinets on the second floor of the Reactor 

Building (RB06)

1 1 1 44K 
F-44

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Assumption: Three cabinets on the second floor of the Reactor Building (RB06) account for approximately 50 percent of t

room. These cabinets are R1600S003J, H2100P627, and R1600S003D. The addition of incipient fire detection and auto 

these cabinets will reduce the CDF of these fires significantly. To determine the impact of this modification, the assumptio

detection/auto suppression system has a failure probability of 0.05. It is also assumed that the conditional core damage p

successful suppression is reduced by an order of magnitude compared to the original conditional core damage probability

original fire scenarios for these components are revised from one scenario to two scenarios; one with successful suppress

suppression. With this modification, the fire CDF is reduced by 2.09×10−7 per year. This reduction in fire CDF was applie

each release category.

212 - Diversify standby liquid control explosive valve 

operation 2 6 7 76K 

Assumption: This analysis was used to evaluate the change in plant risk from diversifying standby liquid control explosive 

decrease the probability of common cause failures. A bounding analysis was performed by eliminating all common cause 

liquid control squib valves.

213 - Provide leak detection and automatic isolation 

valves on EECW piping in the direct current

switchgear room

2 3 3 99K 

Assumption: This analysis was used to evaluate the change in plant risk from providing the capability to detect and isolate 

piping in the direct current switchgear room. The analysis was performed by assuming that a flood from this piping would 

of any electrical equipment in the direct current switchgear room.

214 - Provide leak detection and automatic isolation 

valves on EECW piping in the Division 2 switchgear 

room

1 1 1 44K 

Assumption: This analysis was used to evaluate the change in plant risk from providing the capability to detect and isolate 

piping in the Division 2 switchgear room (Area A3G10). The analysis was performed by assuming that a flood from this pip

the failure of any electrical equipment in the Division 2 switchgear room.

(a) SAMAs in bold are potentially cost-beneficial. Refer to Section F.6.2 for three additional SAMAs determined by DTE to be potentially 

of questions raised by the NRC staff during the SAMA evaluation review.

(b) DTE identified potentially cost-beneficial SAMAs by comparing the largest total benefit with sensitivity to the estimated implementation 

(c) In response to requests by the NRC staff for additional information, DTE updated the assessment related to SAMAs 023, 031, 074, 07

described in Section F.4.

(d) The NRC staff calculated corrected benefits in Table F–6 for SAMAs 021, 024, 050, 067, 078, 123, 145, 152, 177, and 194.
F-45

Individual SAMA and Assumption

% Risk Reduction Total B

CDF Population 

Dose OECR

Baseline 

(Internal + 

External)

Key: ADS = automatic depressurization system; ATWS = anticipated transients without scram; CCDP = conditional core damage proba

damage frequency; CTG = combustion turbine generator; EECW = emergency equipment cooling water; ECCS = emergency core co

EDG = emergency diesel generator; gpm = gallons per minute; HPCI = high pressure coolant injection; ISLOCA = interfacing-systems 

LPCI = low-pressure coolant injection; LOCA = loss-of-coolant accident; MCR = main control room; MSIV = main steam isolation valv

Regulatory Commission; OECR = offsite economic cost risk; RCIC = reactor core isolation cooling; RHR = residual heat removal; SAM

mitigation alternative; SBFW = standby feedwater; SRV = safety relief valve

Source: DTE 2014
Appendix F

F-46

The review of the LERF events identified four additional events that should be considered. DTE 

indicated that the first event, Failure of Combustible Gas Venting, will be addressed by 

implementation of NRC Order EA-13-109, “Order to Modify Licenses with Regard to Reliable 

Hardened Containment Vents Capable of Operation under Severe Accident Conditions.” Since 

DTE intends to comply with the Order, there is no need to address this event with a specific 

SAMA. The second event, Hydrogen Deflagration Occurs Globally, is addressed by SAMAs 93 

(Provide post-accident containment inerting capability) and 103 (Install a passive hydrogen 

control system). A bounding analysis was performed for these SAMAs by eliminating all 

hydrogen deflagrations that result in containment or drywell failures. None of these SAMAs was

found to be cost beneficial. Mitigating the third event, Control Rods Melt Prior to Fuel Rods, 

was evaluated by considering a SAMA to replace the current control rods with rods that have 

metal cladding with a higher melting point than the fuel. This SAMA was evaluated by revising 

the probability of this event from 1.0 to 5×10−2 and requantifying the model. The result was a 

maximum benefit of $33,000 including external events and uncertainty. DTE concluded that the 

cost of replacing control rods and disposing of the existing rods is estimated to greatly exceed 

the benefit of this SAMA, so this SAMA is not cost beneficial. A new SAMA evaluation was 

performed for the fourth event, Operator Fails to Isolate Path Given Isolation Signal Fails, 

assuming the probability of the event was revised from 1.0 to 0.1. This resulted in a maximum 

benefit of $30,000 including external events and uncertainty. DTE concluded that this SAMA is 

not cost beneficial even when considering low cost changes such as new procedures 

(DTE 2015a, 2015c).

The NRC staff noted in an RAI that SAMAs 183 and 187 both involve improvements to the 

alternate shutdown panel that would reduce the conditional core damage probability (CCDP) of 

operation from the alternate shutdown panel following control room evacuation due to fire 

events and that the internal events internal flooding model includes a similar basic event, 

“Operators fail to shutdown from outside the main control room.” In response to the request to 

provide more information on how the benefit of these SAMAs was determined to include the 

potential for impacting both fire risk and internal event risk, DTE indicated that the ER reported 

benefit of SAMAs 183 and 187 was based only on the reduction in fire risk. If the benefit of the 

improved alternate shutdown panel for both fire and internal flood initiators was considered, 

DTE determined that the maximum benefit would be $205,000 including uncertainty. Because 

the cost of implementation is estimated to be $790,000 for SAMAs 183 and 187, DTE concluded 

that these SAMAs remain not cost beneficial (DTE 2015a).

The NRC staff noted that SAMAs 213 and 214 both involve providing leak detection and 

automatic isolation valves for EECW piping in the DC switchgear room or the Division 2 

switchgear room, respectively. The benefit for each was indicated to be based on the 

assumption that a flood from the piping failure would not result in the failure of any electrical 

equipment in the switchgear room in which the flood occurred. Because these SAMAs were 

identified to mitigate important flooding events in which the flood would or could cause failures 

in adjacent electrical rooms, DTE was asked to confirm that the benefit assessment includes the 

elimination of failures in the adjacent rooms. DTE confirmed that the benefit for SAMAs 213 

and 214 included the elimination of failures of equipment in the flood location room as well as 

due to propagation of the flood outside of the room in which it occurs (DTE 2015a).

In response to an NRC staff RAI concerning how the benefit was determined for those SAMAs 

that specifically mitigate fire risk (i.e., SAMAs 183, 187, and 206−211), DTE indicated it was 

necessary to estimate the reduction in fire CDF by the SAMA from the IPEEE compartment 

scenario analysis because the Fermi 2 IPEEE fire analysis was performed using FIVE and there 

is not an integrated quantitative model. The reduction in fire CDF determined from the IPEEE 

was reduced by the factor of 2 to determine the total fire CDF, as discussed above in 
Appendix F

F-47

Section F.2.2.2. The resulting reduction in CDF was used to determine a reduction factor that is 

uniformly applied to the CDF and release category frequencies. Concerning the differing 

assumptions in the SAMA evaluation regarding the impact on the CCDP due to the SAMA

modifications, DTE indicated that the SAMA was assumed to reduce the severe fires to 

non-severe fires and the associated CCDP, when the IPEEE analysis included both severe and 

non-severe fires. If the IPEEE analysis did not distinguish between severe and non-severe 

fires, an order-of-magnitude reduction was assumed. This was stated to be consistent with that 

found for those scenarios where information on the CCDPs for severe and non-severe fires 

was available.

The NRC staff has reviewed DTE’s bases for calculating the risk reduction for the various plant 

improvements and concludes, with the above clarifications, that the rationale and assumptions 

for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk 

reduction is higher than what would actually be realized). Accordingly, the NRC staff based its 

estimates of averted risk for the various SAMAs on DTE’s risk reduction estimates. 

F.5 Cost Impacts of Candidate Plant Improvements

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 the following cost ranges were used based on the review of previous SAMA

applications and an evaluation of expected implementation costs at Fermi 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

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, not recurring costs (DTE 2015a). Replacement power, 

lifetime maintenance, and procedure costs were not included in the estimates. DTE indicated 

that the only exceptions are the cost estimates for SAMA 145 (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 so 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 recurring costs associated with plant walkdowns of 

piping segments that are significant to the internal flooding risk (DTE 2015a).

The NRC staff reviewed the applicant’s cost estimates presented in Table D.2–1 of the ER 

(DTE 2014). For certain improvements, the NRC staff also compared the cost estimates to 
Appendix F

F-48

estimates developed elsewhere for similar improvements, including estimates developed as part 

of other licensees’ analyses of SAMAs for operating reactors.

Regarding the $200,000 cost for SAMA 176 to develop a procedure to open the door to the 

EDG buildings upon the high temperature alarm, DTE justified the cost estimate by explaining 

that an evaluation on ventilation sufficiency from opening the doors would be needed in addition 

to the costs for procedure changes and training (DTE 2015a).

DTE also described the cost estimates for fire-related SAMAs 207 through 211, either being 

developed by DTE for Fermi 2 including costs for equipment, engineering design, construction, 

and materials with incipient detection or clarified to have been based on a Brunswick estimate 

for medium-sized, moderate complexity automatic fire suppression systems without incipient 

detection (DTE 2015a).

With the above clarifications, the NRC staff concludes that the cost estimates provided by DTE 

are sufficient and appropriate for use in the SAMA evaluation.

F.6 Cost-Benefit Comparison

DTE’s cost-benefit analysis and the NRC staff’s review are described in the following sections.

F.6.1 DTE’s Evaluation 

The methodology used by DTE was based primarily on the NRC’s guidance for performing 

cost-benefit analysis, NUREG/BR–0184, Regulatory Analysis Technical Evaluation Handbook

(NRC 1997a). This NRC guidance was adopted in the NEI 05-01 report (NEI 2005). As 

described in Section D.1.5.4 of the ER (DTE 2014), the MMACRSAMA was determined for each 

SAMA according to the following formula, which the NRC staff accepts as mathematically 

equivalent to the formula in the NUREG/BR–0184: 

MMACRSAMA = EEM (WPHA + WEA + WO + WCD + WRP) 

Where

EEM = external event multiplier (unit less)

WPHA = present value of averted offsite exposure cost ($)

WEA = present value of averted offsite economic cost ($)

WO = present value of averted onsite exposure cost ($)

WCD = present value of averted onsite cleanup cost ($)

WRP = present value of averted replacement power cost ($)

DTE’s derivation of each of the associated costs is presented separately in this section. For 

each SAMA, the applicant determined the internal and external benefit from the implementation 

of individual SAMAs using the following formula:

SAMA Benefit =MMACRBaseline – MMACRSAMA 

For each SAMA, the estimated benefit is compared to the cost of implementation. If the cost of 

implementing the SAMA is larger than the benefit associated with the SAMA, the SAMA is not 

considered to be cost beneficial. If the cost of implementing the SAMA is smaller than the 

benefit associated with the SAMA, the SAMA is considered to be potentially cost beneficial.

Sensitivity analyses performed by the applicant can lead to increases in the calculated benefits. 

DTE analyzed one sensitivity case with a lower discount rate of 3 percent in accordance with 
Appendix F

F-49

NUREG/BR–0184 guidance (NRC 1997a), which states that 2 sets of present worth estimates 

should be developed using both the 3 percent and 7 percent discount rates. DTE conducted a 

baseline analysis using the 7 percent discount rate and a sensitivity analysis using the 3 percent 

discount rate (DTE 2014). Additional details on the sensitivity analysis are presented in 

Section F.6.2.

Averted Offsite Exposure Cost (WPHA) 

DTE defined WPHA cost as the monetary value of accident risk avoided from population doses 

after discounting (DTE 2014). The WPHA costs were calculated using the following formula:

WPHA = Averted public dose risk (person-rem per year)

× monetary equivalent of unit dose ($2,000 per person-rem)

× present value conversion factor (NRC 1997a) 

As stated in NUREG/BR–0184 (NRC 1997a), it is important to note that the monetary value of 

the public health risk after discounting does not represent the expected reduction in public 

health risk because of a single accident. Rather, it is the present value of a stream of potential 

losses extending over the remaining lifetime (in this case, the 20-year renewal period) of the 

facility. Thus, it reflects the expected annual loss caused by a single accident, the possibility 

that such an accident could occur at any time over the renewal period, and the effect of 

discounting these potential future losses to present value. For discount rates of 7 percent and 

3 percent, DTE calculated WPHA costs of $105,676 and $147,667, respectively, due to internal 

events in Table D.1–27 of the ER (DTE 2014).

Averted Offsite Economic Cost (WEA)

DTE defined WEA as the monetary value of risk avoided from offsite property damage after 

discounting (DTE 2014). The WEA values were calculated using the following formula:

WEA = Annual offsite property damage risk before discounting in dollars per year

× present value conversion factor (NRC, 1997a) 

For discount rates of 7 percent and 3 percent, DTE calculated WEA costs of $167,403 and 

$233,921, respectively, due to internal events in Table D.1–28 of the ER (DTE 2014).

Averted Onsite Exposure Cost (WO)

DTE defined WO as the avoided onsite exposure (DTE 2014). Similar to the WPHA calculations, 

the applicant calculated costs for immediate onsite exposure. Long-term onsite exposure costs 

were calculated consistent with guidance in the Regulatory Analysis Handbook (NRC 1997a), 

which included an additional term for accrual of long-term doses.

DTE derived the values for averted occupational exposure from information provided in 

Section 5.7.3 of the Regulatory Analysis Handbook (NRC 1997a). Best estimate values 

provided for immediate occupational dose (3,300 person-rem) and long-term occupational dose 

(20,000 person-rem over a 10-year cleanup period) were used. The present value of these 

doses was calculated using the equations provided in the handbook in conjunction with a 

monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 7 percent, 

and a time period of 20 years to represent the license renewal period. Immediate and long-term 

onsite exposure costs were summed to determine the WO cost. For discount rates of 7 percent 

and 3 percent, DTE calculated WO costs of $572 and $930, respectively, due to internal events 

in Table D.1–31 of the ER (DTE 2014).

Averted Onsite Cleanup Cost (WCD) 
Appendix F

F-50

DTE defined WCD as the avoided cost for cleanup and decontamination of the site (DTE 2014). 

The applicant derived the values for WCD based on information provided in Section 5.7.6 of 

NUREG/BR–0184, the Regulatory Analysis Handbook (NRC 1997a).

Averted cleanup and decontamination costs were calculated using the following formula:

WCD = Annual CDF × present value of cleanup costs per core damage event × present value 

conversion factor.

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 

the Regulatory Analysis Handbook to be $1.5×109 (undiscounted). This value was converted to

present costs over a 10-year cleanup period and integrated over the term of the proposed 

license extension. For discount rates of 7 percent and 3 percent, DTE calculated WCD costs of 

$17,450 and $29,293, respectively, due to internal events in Table D.1–32 of the ER 

(DTE 2014).

Averted Replacement Power Cost (WRP) 

DTE defined WRP as the avoided costs of replacement power (DTE 2014). Long-term 

replacement costs were calculated using the following formula:

 WRP = Annual CDF × present value of replacement power for a single event 

 × factor for remaining service years for which replacement power is required

 × reactor power scaling factor

DTE based its calculations on the net electric output for Fermi 2, specifically 1,170 

megawatt-electric (MWe), and scaled up from reference plant value of 910 MWe specified in 

NUREG/BR–0184 (NRC 1997a). For discount rates of 7 percent and 3 percent, DTE calculated 

WRP costs of $15,247 and $14,278, respectively, due to internal events in Table D.1–34 of the 

ER (DTE 2014).

MMACRBaseline

Using the above equations, DTE estimated the total present dollar value equivalent associated 

with completely eliminating severe accidents caused by internal events, referred to as the 

MACR, to be about $306,348 and $426,090 for respective discount rates of 7 percent and 

3 percent in Table D.1–35 of the ER (DTE 2014). To account for the risk contributions from 

external events and yield the internal and external benefit, DTE selected an EEM value of 11 for 

Fermi 2 (DTE 2014), as discussed further in Section F.6.2. By multiplying MACR and EEM, 

DTE estimated MMACRBaseline to be about $3,369,832 and $4,686,991 for respective discount 

rates of 7 percent and 3 percent in Table D.1–35 of the ER (DTE 2014). As described above in 

the SAMA benefit formula, components of the MMACRBaseline calculation factor into the benefit 

determination for individual SAMAs.

DTE’s Results

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 

was determined to be not cost beneficial. If the SAMA benefit exceeded the estimated cost, the 

SAMA candidate was considered to be potentially cost beneficial. The DTE’s baseline 

cost-benefit analysis identified one SAMA candidate as potentially cost-beneficial. From the 

sensitivity analysis, DTE identified an additional three SAMA candidates as potentially cost 

beneficial. Results of the cost-benefit evaluation are presented in Table F–5. Considering the 

results from the baseline and sensitivity analyses, the full set of potentially cost-beneficial 

SAMAs for Fermi 2 is:
Appendix F

F-51

• SAMA 112: Revise emergency operating procedures to improve identification of 

interfacing system LOCAs, 

• SAMA 113: Improve operator training on coping with interfacing system LOCAs,

• SAMA 115: Revise procedures to control vessel injection to prevent boron loss or 

dilution following standby liquid control injection, and

• 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. 

DTE indicated that seven SAMAs, the four numbered SAMAs above as well as three additional 

unnumbered SAMAs listed in Section F.6.2 arising from the NRC staff’s review, will be 

incorporated into the evaluation process and evaluated considering other planned changes. 

F.6.2 Review of DTE’s Cost-Benefit Evaluation 

During its review of the cost-benefit analysis performed by DTE, the NRC staff compared the 

applicant’s approach with guidance in NUREG/BR–0184 (NRC 1997a) and discount rate 

guidelines in NEI 05-01 (NEI 2005). NEI guidance states that two sets of estimates should be 

developed for discount rates of 7 percent and 3 percent (NEI 2005). DTE performed 

assessments using both discount rates. DTE provided a baseline set of results using a discount 

rate of 7 percent. For the other types of potential sensitivity analyses suggested (NEI 2005), the 

NRC staff finds that DTE’s information provided in the ER submittal and subsequent RAI 

responses on plant modifications, peer review findings or observations, and evacuation speed 

have been adequately addressed in the baseline analysis, as discussed in this appendix. As 

previously indicated, DTE performed the cost-benefit evaluation using an analysis time period of 

20 years. Because DTE explicitly accounted for uncertainty in its sensitivity analysis by 

applying a multiplication factor of 2.5 and the results of the sensitivity analysis were used to 

identify additional potentially beneficially SAMAs, the NRC staff finds that an additional 

sensitivity analysis for a time frame longer than 20 years is not necessary. Although longer 

timeframes would increase estimated benefits compared to baseline results, it is unlikely that 

influences from a longer timeframe would exceed the factor of 2.5 already considered by DTE. 

Based on its review of the applicant’s cost-benefit evaluation, the NRC staff determined that the 

applicant’s approach is consistent with the guidance and is acceptable.

The applicant considered possible increases in benefits from analysis uncertainties on the 

results of the SAMA assessment. In the ER (DTE 2014), DTE indicated that the 95th percentile 

value of the Fermi 2 CDF was greater than the mean CDF by a factor of 2.36. A multiplication 

factor of 2.5 was conservatively selected by the applicant to account for uncertainty. This 

multiplication factor was applied in addition to the separate external events multiplication factor 

of 11 (DTE 2014), as described in Section F.2.2.2. DTE’s assessment accounted for the 

potential risk-reduction benefits associated with both internal and external events. The NRC 

staff considers the multipliers of 2.5 for uncertainty and 11 for external events at Fermi 2 provide 

adequate margin and are acceptable for the SAMA analysis.

Using DTE’s information on the release category frequencies during the onsite audit 

(NRC 2014c), the NRC staff spot checked the applicant’s calculations of delta CDF

(i.e., percentage reduction in CDF due to accumulated differences in the release categories for 

a specific SAMA candidate compared to the base case), population dose risk, and offsite 

economic cost risk. By applying the formula for SAMA benefit presented in Section F.6.1 and 

comparing the results with those presented in Table D.2–1 of the ER (DTE 2014), the NRC staff 

found the results to be in agreement and within small roundoff errors. Consistency also was 
Appendix F

F-52

found between the base release category frequencies and those reported in Tables D.1–9 and 

D.1–10 of the ER (DTE 2014).

DTE’s 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. As described in Section F.3.2, 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 2015a): 

• Install a flood barrier or curb between the DC switchgear room and Division 2 AC 

switchgear room. 

• Develop a new procedure to close valves to terminate the flood from EECW in an 

AB3 switchgear room. 

• Revise existing alarm response procedures to direct operators to DC switchgear 

room and the Division 2 AC switchgear room following indication of leakage in 

RBCCW/EECW system piping. 

From its review of the original SAMA analysis and additional information, the NRC staff agrees 

with DTE’s disposition of the above lower cost alternatives. 

As discussed above in Section F.2.2.3, the Level 2 analysis assignment of sequences to 

release categories resulted in the underestimation of the consequences for Accident Class IIA 

sequences. As noted by the NRC staff in an RAI (NRC 2015a), the impact of this accident class 

assignment may not have a significant impact on the base case MACR, but it would lead to an 

underestimate of the benefit for any SAMA that mitigated these Class IIA sequences. 

In response to the RAI and a subsequent RAI (NRC 2015b) to include in the benefit evaluation 

the impact of the 3.14×10−9 per year undercounting due to truncation discussed previously in 

Section F.2.2.3, DTE provided an analysis of the impact on the cost-benefit analysis of those 

SAMAs expected to be most impacted by these issues (DTE 2015b and 2015c). Eleven 

SAMAs (21, 24, 50, 54, 67, 78, 123, 145, 152, 177, and 194) were selected based on three 

criteria: 

• The SAMA was not already considered potentially cost-beneficial in the base case 

analysis or in the sensitivity analysis. 

• The SAMA was not specifically oriented towards other types of sequences 

(e.g., LOCA, ATWS, early loss of RPV injection). 

• The SAMA has a non-marginal impact on Class IIA sequences relative to 

non-Class IIA sequences. 

For this RAI response, DTE assumed that the Class IIA frequency originally included in the H/E 

release category (5.32×10−8 per year) and all the unaccounted for 3.14×10−9 per year have 

offsite population dose in person-rem and economic cost consequences equal to those for the 

H/E-BOC release category because MAAP analysis results were not available for these 

sequences. The cutsets for each of the SAMAs (except SAMAs 78 and 123, discussed below) 

were reviewed and the percent reduction in the Class IIA sequence frequency determined. This 

percent reduction was used to determine the additional benefit due to the originally 

mischaracterized 5.32×10−8 per year and the unaccounted for 3.14×10−9 per year. As explained 

in the RAI response (DTE 2015c), this frequency reduction was multiplied by the difference 

between the new, higher, H/E-BOC consequence (person-rem and offsite economic cost) and 

the original H/E release category consequence and converting the resultant averted risk to a 
Appendix F

F-53

monetary benefit. For SAMAs 78 and 123, the analysis used the benefit analysis revised in 

response to an NRC staff RAI discussed above in Section F.4. For both SAMA 78 and 

SAMA 123, it was assumed that the SAMA was 100 percent effective in eliminating the risk from 

the Class IIA sequences (DTE 2015c). 

The NRC staff notes that while the above described procedure to subtract the original H/E 

release category consequence to determine the added benefit associated with the Class IIA 

sequences is correct with regard to the original mischaracterized 5.32×10−8

 per year, it is not 

correct with regard to the unaccounted for 3.14×10−9 per year because this frequency was not 

included in the original benefit calculations. The NRC staff calculated this added benefit as part 

its review and concluded that the added benefit is relatively small and does not impact the final 

selection of cost-beneficial SAMAs. It is further noted that DTE’s analysis does not include the 

added onsite benefit (onsite exposure, onsite cleanup, and replacement power) associated with

mitigating the unaccounted for 3.14×10−9 per year Class IIA sequences. Because the 

sequences are approximately 0.2 percent of the total CDF and the maximum averted onsite cost 

risk is only about 10 percent of the MACR, the NRC staff concludes this added contribution 

is negligible.

A full presentation of results from the analysis performed by DTE is reported in Table 2–2 of the 

RAI response (DTE 2015c). Table F–6 of this appendix summarizes some of DTE’s results and 

presents results from the calculation performed by the NRC staff during the review of the SAMA

analysis. No additional cost-beneficial SAMAs were identified as a result of the NRC staff’s 

calculation. 

Because the NRC staff reviewed the cost benefit evaluations performed by DTE, DTE 

satisfactorily addressed the NRC staff questions regarding the evaluations, and the NRC staff 

found that no additional cost-beneficial SAMAs were missed as a result of a minor correction to 

DTE’s evaluation, the NRC staff concludes that the cost-benefit evaluations, subject to the one 

correction discussed above, are of sufficient quality to support the SAMA evaluation.

DTE identified three additional potential cost-beneficial SAMAs as a result of the NRC staff 

questions on installing a flood barrier or curb between the DC switchgear room and Division 2 

AC switchgear room, developing a new procedure to close valves to terminate the flood from 

EECW in an AB3 switchgear room, and revising existing alarm response procedures to direct 

operators to the DC switchgear room and the Division 2 AC switchgear room following indication 

of leakage in the RBCCW/EECW system piping. For the other SAMAs that were not cost 

beneficial, the NRC staff concludes that their implementation costs exceed their associated 

benefits; therefore, those SAMAs are not cost beneficial. 
F-54

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

SAMA

No.

SAMA

Description

Class IIA 

Percent 

Reduction

(a)

Class IIA 

Frequency 

Reduction 

(1/yr)(b)

Additional 

Offsite Dose 

Cost Benefit

($)(c)(i)

Additional 

Offsite 

Economic 

Cost Benefit

($)(d)(j)

Adjusted Cost 

Benefit

($)(e)(k)

2.5 Unce

Factor A

to Adj. 

Bene

($)(f

21 Use firewater 

system as a backup 

source for diesel 

cooling

58.34% 3.29×10−8 $107,000

($3,840) 

$8,950

($6,070) 

$373,000

($382,000) 

$931,0

($956,0

24 Training for offsite 

power recovery after 

SBO

0.00%(h) 0(h) $0

($0)

$0

($0)

$6,270

($6,270) 

$15,7

($15,7

50 Change procedures 

to allow cross 

connect of motor 

cooling for RHRSW

pumps

2.88% 1.62×10−9 $5,260

($190)

$441

($300)

$18,900

($19,300) 

$47,1

($48,4

54 Enhance procedural 

guidance for use of 

cross-tied 

component cooling 

or service water 

pumps

0.02% 1.07×10−11 $35

($1)

$3

($2)

$3,280

($3,280) 

$8,1

($8,2

67 Enhance procedure 

to trip unneeded 

RHR or containment 

spray pumps on loss 

of room ventilation

0.00%(h) 0(h) $0

($0)

$0

($0)

$1,190

($1,190) 

$2,9

($2,9

78 Enable flooding of 

drywell head seal

100.00% 5.63×10−8 $183,000

($6,580)

$15,300

($10,400)

$296,000

($313,000)

$739,0

($781,0

123 Install an 

ATWS-sized filtered 

containment vent to 

remove decay heat

100.00% 5.63×10−8 $183,000

($6,580)

$15,300

($10,400) 

$1,300,000

($1,320,000)

$3,250,0

($3,290,0
F-55

SAMA

No.

SAMA

Description

Class IIA 

Percent 

Reduction

(a)

Class IIA 

Frequency 

Reduction 

(1/yr)(b)

Additional 

Offsite Dose 

Cost Benefit

($)(c)(i)

Additional 

Offsite 

Economic 

Cost Benefit

($)(d)(j)

Adjusted Cost 

Benefit

($)(e)(k)

2.5 Unce

Factor A

to Adj. 

Bene

($)(f

145 Increase training 

and operating 

experience feedback 

to improve operator 

response

11.94% 6.73×10−9 $21,800

($786)

$1,830

($1,240) 

$333,000

($335,000) 

$834,0

($839,0

152 Proceduralize all 

potential 4- kV AC 

bus cross-tie actions

6.01% 3.39×10−9 $11,000

($395)

$923

($625)

$37,300

($38,300) 

$93,1

($95,7

177 Provide an alternate 

means of supplying 

the instrument air 

header

15.84% 8.92×10−9 $28,900

($1,040) 

$2,430

($1,650) 

$131,000

($134,000) 

$327,0

($334,0

194 Provide ability to 

maintain 

suppression pool 

temperature lower

4.74% 2.67×10−9 $8,660

($312)

$727

($493)

$38,300

($39,100) 

$95,7

($97,7

Notes pertaining to values listed in the first (upper) row for each SAMA, as taken from Table 2–2 of DTE’s RAI response (DTE 2015c):

a Class IIA percent reduction was calculated based on detailed cutset summation, except for SAMAs 78 and 123 in which 100% H/E C

assumed.

b Values were calculated from multiplying the Class IIA Percent Reduction by the H/E Class IIA release frequency of 5.63×10−8 per ye

3.14×10−9 per year additional frequency.

c Values displayed without parentheses were derived from taking the difference between the H/E Class IIA release category population 

using the H/E-BOC MACCS2 results) and the “Other” (or original) H/E release category population dose (8.10×106 rem) to calculate t

(1.37×107 rem) to the population dose reduction. The dose cost factor of $2,000 per person-rem and the Class IIA frequency reducti

were applied in the calculation. The calculation also included multiplication by the external hazards factor (11) and the 7-percent disc

d Values displayed without parentheses were derived from taking the difference between the H/E Class IIA release category offsite eco

and the “Other” (or original) H/E release category offsite economic cost ($2.80×1010) to calculate the additional benefit ($2.30×109) t

costs assuming the Class IIA frequency reduction listed in Column 4. The calculation included multiplication by the external hazards 

7-percent discount rate factor (10.76).
F-56

SAMA

No.

SAMA

Description

Class IIA 

Percent 

Reduction

(a)

Class IIA 

Frequency 

Reduction 

(1/yr)(b)

Additional 

Offsite Dose 

Cost Benefit

($)(c)(i)

Additional 

Offsite 

Economic 

Cost Benefit

($)(d)(j)

Adjusted Cost 

Benefit

($)(e)(k)

2.5 Unce

Factor A

to Adj. 

Bene

($)(f

e The values displayed without parentheses represent the summation of the Adjusted Benefit Portion from Offsite and Base Case Bene

Table 2-2 of an RAI response (DTE 2015c). The original DTE ER base case total benefit in Table 3–3 was NOT added since the port

already included in the Adjusted Benefit Portion from Offsite and the base case portion from onsite is already being added. Table 2-2 

included the previous RAI response's impact on SAMA 78.

f Adjusted Cost Benefit (Column 5 without parentheses) multiplied by the uncertainty factor of 2.5.

g Obtained from SAMA ER Table D.2–1, except for SAMA 78 with an updated implementation cost from DTE’s RAI response (DTE 201

h Class IIA percent reduction is <0.01 percent, and Class IIA frequency reduction is <5.6×10−12 per year. Because the reduction is so 

considered zero for the evaluation.

Notes pertaining to values in parentheses listed in the second (lower) row for each SAMA, as calculated by the NRC staff to account for 

cost benefit, added offsite economic cost benefit, and revised total benefit for each SAMA.

i Values in parentheses were calculated by the NRC staff by using the “Other” (or original) H/E release category population dose (8.10

additional benefit to the population dose reduction and applying a dose cost factor of $2,000 per person-rem and the Column 3 perce

unaccounted for 3.14×10−9 per year Class IIA frequency. The calculation included multiplication by the external hazards factor (11) a

discount rate factor (10.76).

j Values in parentheses were calculated by the NRC staff by using the “Other” (or original) H/E release category offsite economic cost 

the additional benefit to the offsite economic costs and the Column 3 percentage reduction of the unaccounted for 3.14×10−9 per yea

The calculation included multiplication by the external hazards factor (11) and the 7-percent discount rate factor (10.76).

k Values in parentheses were calculated by the NRC staff by adding the additional offsite dose and economic cost benefit due to the un

per year evaluated at the original H/E release category consequences to the above value for the SAMA from DTE’s RAI response (DT

l Adjusted Cost Benefit calculated by the NRC staff (Column 7 in parentheses) multiplied by the uncertainty factor of 2.5.
Appendix F

F-57

F.7 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 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, had already been implemented at Fermi 2, were combined into a more 

comprehensive or plant-specific SAMA, had excessive implementation cost, had a very low 

benefit, or 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. 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 Title 10 of the Code of Federal Regulations 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 

this appendix, the methods used and the 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. On the basis of the applicant’s treatment of SAMA 

benefits and costs, the 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 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 NRC staff RAIs, the NRC staff concludes that DTE has adequately identified areas in which 

risk can be further reduced in a cost-beneficial manner 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 candidate SAMAs 

identified by DTE as being potentially cost beneficial is warranted.

Additionally, the NRC staff evaluated if 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 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. 
Appendix F

F-58

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Appendix F

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Appendix F

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[NRC] U.S. Nuclear Regulatory Commission. 2012a. Letter from E. Leeds, Director, NRC, to 

All Power Reactor Licensees. Subject: Request for information pursuant to Title 10 of the Code 

of Federal Regulations 50.54(f) regarding Recommendations 2.1, 2.3, and 9.3, of the 

Near-Term Task Force review of insights from the Fukushima Dai-ichi accident. 

March 12, 2012. ADAMS No. ML12053A340. 

[NRC] U.S. Nuclear Regulatory Commission. 2012b. State-of-the Art Reactor Consequence 

Analyses (SOARCA) Report. Washington, DC: NRC. NUREG–1935. November 2012. 

ADAMS No. ML12332A057.

[NRC] U.S. Nuclear Regulatory Commission. 2012c. Letter from E. Leeds, Director, NRC, to

All Operating Boiling-Water Reactor Licensees with Mark I and Mark II Containments. 

EA-12-050. Subject: Issuance of Order to Modify Licenses with Regard to Reliable Hardened 

Containment Vents. March 12, 2012. ADAMS No. ML12054A694.
Appendix F

F-61

[NRC] U.S. Nuclear Regulatory Commission. 2013. Letter from E. Leeds, Director, NRC, to all 

operating boiling-water reactor licensees with Mark I and Mark II containments. EA-13-090. 

Subject: Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment 

Vents Capable of Operation under Severe Accident Conditions. June 6, 2013. 

ADAMS No. ML13143A321. 

[NRC] U.S. Nuclear Regulatory Commission. 2014a. Letter from M. Wentzel, Project Manager,

NRC, to V. Kaminskas, Site Vice President, DTE. Subject: Requests for Additional Information 

for the Review of the Fermi 2 License Renewal Application—Severe Accident Mitigation 

Alternatives. November 18, 2014. ADAMS No. ML14308A358.

[NRC] U.S. Nuclear Regulatory Commission. 2014b. Letter from T.J. Wengert, Senior Project 

Manager, NRC, to J.H. Plona, Senior Vice President and Chief Nuclear Officer, DTE. 

Subject: Fermi Nuclear Plant, Unit 2—Staff Assessment of the Flooding Walkdown Report 

Supporting Implementation of the Near-Term Task Force Recommendation 2.3 Related to the 

Fukushima Dai-ichi Accident. (TAC No. MF0228). June 18, 2014. ADAMS No. ML14143A235.

[NRC] U.S. Nuclear Regulatory Commission. 2014c. Letter from M. Wentzel, Project Manager, 

NRC, to V. Kaminskas, Site Vice President, DTE. Subject: Summary of the Severe Accidents 

Mitigation Alternatives Environmental Site Audit Related to the Review of the License Renewal 

Application for Fermi 2. (TAC No. MF4064). November 17, 2014. ADAMS No. ML14294A812.

[NRC] U.S. Nuclear Regulatory Commission. 2015a. Letter from M. Wentzel, Project Manager,

NRC, to V. Kaminskas, Site Vice President, DTE. Subject: Requests for Additional Information 

for the Environmental Review of the Fermi 2 License Renewal Application—Severe Accident 

Mitigation Alternatives. February 3, 2015. ADAMS No. ML15026A307.

[NRC] U.S. Nuclear Regulatory Commission. 2015b. Letter from B. Wittick, NRC, to 

V. Kaminskas, Site Vice President, DTE. Subject: Request for Additional Information for the 

Environmental Review of the Fermi 2 License Renewal Application—Severe Accident Mitigation 

Alternatives. April 9, 2015. ADAMS No. ML15092A945.



 

 

NUREG-1437

Supplement 56 

Volume 2

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Regarding Fermi 2 Nuclear Power Plant