M150204, M150204: Slides - Hearing on Combined License for Fermi, Unit 3; Section 189A of the Atomic Energy Act Proceeding

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M150204: Slides - Hearing on Combined License for Fermi, Unit 3; Section 189A of the Atomic Energy Act Proceeding
ML15036A212
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Issue date: 02/04/2015
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DTEO00005 IT E1* 6 DTE Energy Presentation Overview* Background and DTE Strategy* DCWG Approach* ESBWR Design 2

  • In 2006, DTE was considering options to meet Michigan's future electricity needs. Studies at the time indicated that Michigan potentially needed as much as 3800 MW of new baseload capacity by 2020* In the regulatory climate at the time (e.g., NP 2010, Part 52 licensing process), DTE concluded that a new nuclear generating capacity could potentially contribute to satisfying the anticipated demand Despite the 2008 economic downturn, DTE considers the option for a new nuclear unit to be important for a diverse generation portfolio, uncertainty in long term natural gas prices, retirements of aging fossil units, C02 and other environmental regulations

-~ I ------~ ------- -3 A strategy for licensing and constructing a new nuclear plant was developed* Employ the COL approach under Part 52 to fully license the plant before proceeding

  • Utilize the DCWG approach as an S-COLA* Fully embrace standardization with a high governance threshold for deviations from the DCD and R-COLA* Use DTE Project Management Organization to lead the project and build future capabilities
  • Conduct the project independent of the operating plant organization to minimize distractions Existing Fermi site selected for new plant.-Site had space for an additional plant.-Environmental and seismic siting issues would be minimized* Detailed vendor evaluation process led to selection of the GE-Hitachi ESBWR technology.

4 DTE Energy, Fermi 3 Would Be Co-Located With Fermi 2* Located in Monroe County near Newport, MI on western shore of Lake Erie" Approximately 25 miles northeast of Toledo, OH* Approximately 30 miles southwest of Detroit, MI" Approximately 7 miles from US/Canadian International Boundary* Site is part of the Lagoona Beach Unit of the Detroit River International Wildlife Refuge* Partnership with US Fish & Wildlife Service to Manage Approximately 650 acres of the Refuge located at the Fermi site 5

-;-HW'-- DTE Energy Fermi 3 Would Be Co-Located With Fermi 2* Fermi site is 1260 acres-Fermi 1: Liquid Metal Fast Breeder Reactor; shutdown in 1972; currently in SAFESTOR-Fermi 2:1200 MWe GE BWR* Fermi 3 located southwest Fermi 2* Remaining Fermi Unit 1 structures to be removed prior to Fermi 3 construction" Key attributes

-Site is suitable for additional nuclear unit-Readily accessible by major roadways, rail lines, and Lake Erie-Much of necessary infrastructure is already in place 6

  • Regulatory Issue Summary 2006-06-Describes the NRC Design-Centered Review Approach (DCRA)-Encourages standardization of COLA content and RAI responses-Applicants participate in Design Centered Working Group (DCWG)* DTE informed NRC of ESBWR selection in November 2007 and subsequently joined NuStart and ESBWR DCWG in December 2007" The ESBWR DCWG identified a Reference COLA (R-COLA) and several subsequent COLAs (S-COLAs)" Fermi 3 COLA was initially submitted as an ESBWR S-COLA in 2008" Fermi 3 application became the ESBWR R-COLA in 2010* Fermi 3 would be the first ESBWR COL Holder 7 0 10 CFR Part 52, Appendix E, and ESBWR DCD Revision 10 incorporated by reference in COLA-Supplements added where DCD required additional information to address site-specific considerations 9 One departure from DCD-To increase solid waste storage capacity in RadWaste Building* One exemption-From 10 C.F.R. Part 74 requirements for Special Nuclear Material Control and Accountability requirements

-Requested that programs licensed under 10 CFR Part 52 be treated identically to those licensed under 10 CFR Part 50.8 Key Features of the ESBWR Simplified COLA DTE Energy, Development and Review ESBWR Certified Desian ESBWR Evolutionary Desian Features Final rule in 10 CFR Part 52, Appendix E, published in November 2014* Passive Safety Design -Safety systems require no AC power to actuate or operate for at least 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s* Natural Circulation Core and Containment Cooling Systems* Robust Seismic Design Envelope* No site-specific Seismic Category I safety-related structures

  • Simplicity

-Significantly fewer systems and components than previous designs promotes ease of operation and maintenance

  • Safety -Low Core Damage Frequency (CDF)" Security -Main Control Room and Spent Fuel Pool are located below grade.9 DTE000006
  • In 2012, Fukushima Near Term Task Force Recommendation

2.1 required

evaluation of the Central and Eastern US Seismic Source Characterization (CEUS SSC) model* Fermi 3 site-specific SSI analyses were re-performed using CEUS SSC based inputs* The Fermi 3 site-specific Soil-Structure Interaction (SSI) analyses address:-Partial embedment of Seismic Category I structures

-Evaluation of side backfill for Seismic Category I structures as permitted by DCD* Results demonstrate that the ESBWR design envelopes the Fermi 3 site with substantial margin___________________________________

---~2 The SSI Analyses Considered Fermi 3 Foundation DTE Energy-Interfaces, Excavation, and Geology LOOKING NORIH Reactor Building and Control , =, Building are founded on bedrock-° Fire Water Service Complex is founded on fill-concrete which extends to bedrock-_ K- " Engineered Granular Backfill__f- surrounds all Category I j .Safety-Related Structure& ~ ~ i I DISTANCE IN~ FEET 3 Fermi 3 RB/FB Foundation Input Response Spectra (FIRS)compared to ESBWR Certified Seismic Design Response Spectra (CSDRS) (5 percent damping)10 1 CL 0.1 0.0 10 0.1 CL CO 0.01 0.1 1 10 100 0.1 1 10 100 Frequency (Hz)Frequency (Hz)4 Analyses Demonstrate ESBWR Design Envelopes DTE Energyýthe Fermi 3 Site With Substantial Margin Governing Comparison for Response Spectra 10.0 50.0-DOD Design Spectrum ESBWR RSW -DCD Design Spectrum ESBWR RPV NODE 707Z NODE 801X TOP TOP-Fermi 3 SSI Enveloping EL 24180mm -Fermi 3 SSI Enveloping EL 27640mm Response Spectrum 5% DAMPING Response Spectrum 5% DAMPING 8.0 40.0 6.0 , 30.0 Cl) Cl)o 0<- -wi UA LU L 4.0 -20.0 2.0 10.0 0.0 0.0 0.1 1.0 10.0 100.0 0.1 1.0 10.0 100.0 FREQUENCY-Hz FREQUENCY-Hz Vertical Response Spectra -RB/FB RSW Top Horizontal Response Spectra -RB/FB RPV Top (Figure 3.7.2-209d) (Figure 3.7.2-207e) 5 DTE000007 ESBWR passive design substantially resolves Fukushima Near-Term Task Force (NTTF) Recommendations Aspects of NTTF Recommendations supplemented in COLA and that will be addressed in COL: 2.1 Seismic Evaluation (previously discussed)

4.2 Mitigating

Strategies for Beyond-Design-Basis External Events* Draft License Condition to implement FLEX 7.1 Reliable Spent Fuel Pool Instrumentation

° Draft License Condition for operator training 9.3 Emergency Preparedness

° Draft License Condition for staffing and communication assessments 2

CITETEOOOOO8 Interacted with regional stakeholders prior to COLA-Explained project and licensing process-Contacted local tribes to seek input on cultural resources-Strong state and local support for project for Fermi 3" Followed NRC guidance for Fermi 3 Environmental Report (NUREG-1555, ISGs)-Used available information on Fermi site (historic information from Fermi 1 and 2 construction and operation)

-Accounted for existing site infrastructure/access (not a greenfield)

-Overall, ER is a comprehensive assessment of the impacts of building Fermi 3* Stakeholder involvement during COLA preparation and review resulted in project improvements

-Made significant revisions to site layout to minimize wetland impacts-Reduced impacts to undeveloped areas of site (e.g., parking garage, barge slip)-Corollary benefit: better site layout for construction activities 2

DTE000009 DTE Energy Presentation Overview" Historic Preservation

  • International Interactions" Continued Storage Rule 2 DTE Took Steps to Preserve Historic DTE Energy Information About Fermi 1" Fermi 1 is eligible for inclusion into the National Register of Historic Places" Use of Fermi 1 site area reduces impacts to undeveloped areas at Fermi site from building Fermi 3* DTE archived historical artifacts and plant records relating to Fermi 1" DTE developed Fermi 1 exhibit at Monroe County Community College;opened August 2013 THE MONROE*, ..____ NeWs Recreating the ATOMIC WAGE n Hisry of Feui nudear paer 4p ant Wdk in new at MCCC'-'Vt-A~ -..a 1 I~- ~'7 3
  • The Fermi site is in close proximity to the US/Canada international border (approximately 7 miles)* Fermi 2 provided "template" for international interactions for Fermi 3" DTE addressed potential transboundary impacts in the Fermi 3 Environmental Report; no unique or unusual impacts were identified" DTE conducts ongoing and frequent outreach with local Canadian officials, similar to Fermi 2 interactions 4
  • Fermi 3 would be the first COL issued since the Continued Storage Rule was published in October 2014" NRC efforts in developing the Continued Storage Rule were commendable
  • Good public outreach* Met rulemaking schedule* No new and significant information in Continued Storage GEIS* No FEIS supplement was necessary 5 NRCO00011 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment Combined License Application Review FERMI 3 Overview February 4, 2015 Overview of Staff Review of Fermi 3 COL Application" Fermi 3 COL Application and Contents" ESBWR Design Certification (DC)" Fermi 3 COL Overview -Safety Review" Fermi 3 COL Overview -Environmental Review" Summary of Staff Findings -COL Application 2

Fermi 3 COL Application" Detroit Edison Company (now DTE Electric Company) submitted the application on September 18, 2008" Incorporates by reference:

-ESBWR Design Certification Document (DCD), Revision 10-10 CFR Part 52, Appendix E, "Design Certification Rule for the ESBWR Design"" Staff safety evaluation for ESBWR NUREG-1966 and NUREG-1966, Supplement 1 3 Fermi 3 COL Application Contents* Fermi 3 plant-specific information

  • Standard content material in accordance with design-centered review approach 4 Fermi 3 COL Overview: Safety Review Design-Centered Review Approach-Subject of Regulatory Issue Summary 2006-06-Endorsed by Commission in Staff Requirements Memorandum (SECY-06-0187)

-Single technical review for each standard issue outside of the DC scope supports decisions on multiple COL applications referencing the same design center 5 Fermi 3 COL Overview: Safety Review* Review performed for reference COL (RCOL)* Applied to subsequent COL (SCOL)6 Fermi 3 COL Overview: Safety Review Application of Design-Centered Review Approach-North Anna Unit 3 was original ESBWR R-COL-August 2009: Safety evaluation report (SER) with open items issued for North Anna-May 2010: Fermi 3 became R-COL 7 Fermi 3 COL Overview: Safety Review-NRC staff verified standard content for North Anna directly applicable to Fermi 3-DTE responded to open items related to standard content in North Anna SER 8 Fermi 3 COL Overview: Safety Review Advisory Committee on Reactor Safeguards (ACRS) Review-Six ESBWR Subcommittee meetings -and one Full Committee meeting held related to Fermi 3 COL application and advanced final safety evaluation

-ACRS letter report provided September 22, 2014 9 Fermi 3 COL Overview: Safety Review Staff response provided November 14, 2014 FSER issued November 18, 2014 10 Fermi 3 COL Overview: Safety Review* Summary of Findings -10 CFR 52.97-Applicable standards and requirements of the Atomic Energy Act and the Commission's regulations have been met-Required notifications to other agencies or bodies have been duly made 11 Fermi 3 COL Overview: Safety Review* Summary of Findings, continued-There is reasonable assurance that the facility will be constructed and will operate in conformity with the license, the provisions of the Act, and the Commission's regulations 12 Fermi 3 COL Overview: Safety Review* Summary of Findings, continued-Applicant is technically and financially qualified to engage in the activities authorized

-Issuance of the licenses will not be inimical to the common defense and security or to the health and safety of the public-Findings required by Subpart A of 10 CFR Part 51 have been made 13 Fermi 3 COL Overview: Environmental Review* Environmental Impact Statement (EIS)completed in accordance with:-National Environmental Policy Act of 1969-10 CFR Part 51* U.S. Army Corps of Engineers, Detroit District was a cooperating agency 14 Fermi 3 COL Overview: Environmental Review* Staff follows a systematic approach to evaluate impacts-Solicit and reconcile scoping comments-Conduct technical review-Issue draft EIS for public/stakeholder comment-Consider and disposition comments in preparing final EIS 15 Fermi 3 COL Overview: Environmental Review Stakeholder involvement is a key aspect of the process* Final EIS published January 18, 2013, as NUREG-2105 16 Fermi 3 COL Overview: Environmental Review* A Record of Decision is required by 10 CFR 51.102* Record of Decision is a concise public record of the decision that:-States the decision-Identifies all alternatives considered

-Discusses preferences among alternatives 17 Fermi 3 COL Overview: Environmental Review States whether the Commission has taken all practicable measures, within its jurisdiction, to minimize environmental harm 18 Fermi 3 COL Overview: Environmental Review Summary of Findings -10 CFR 51.107(a)-The requirements of Section 102(2)(A),(C), and (E) of NEPA and the regulations in 10 CFR Part 51 have been met-After considering the final balance among conflicting factors in the record of the proceeding, the appropriate action is issuance of the COL 19 Fermi 3 COL Overview: Environmental Review After weighing the environmental, economic, technical, and other benefits against environmental and other costs, and considering reasonable alternatives, the COL should be issued The staff's NEPA review has been adequate 20 Fermi Overview of Panel Presentations PaeNme Isue to beDiscse Evalatio Safety Panel 1 Soil-Structure Interaction FSER Chapters 2 and 3 Safety Panel 2 Fermi Actions in Response to Fukushima FSER Chapter 20 Near-Term Task Force Recommendations Summary of process for developing the EIS Environmental EI Einmen Analysis of Alternatives FEIS P Summary of Conclusions and Recommendations Historic Preservation Related to Fermi 1 Environmental

  • International Interactions FEIS Panel 2
  • Implementation of the Continued Storage Rule 21

~U.S.NRC United States Nuclear Regulatory Commission NRC000012 Protecting People and the Environment Combined License Application Review FERMI 3 Safety Panel 1 February 4, 2015 Panelists* Adrian Muniz -Lead Project Manager* Sarah Tabatabai

-Seismologist

-Senior Structural Engineer 2 Seismic Hazard Reevaluation

  • Staff issued requests for additional information (RAI) to new reactor applicants in light of the new Central and Eastern U.S.Seismic Source Characterization (CEUS-SSC) model* Operating plant seismic reevaluations also used current NRC requirements and guidance, including the CEUS-SSC model 3 Response to CEUS-SSC RAI* Original submittal used Electric Power Research Institute models endorsed by NRC at that time* The applicant revised the submittal to incorporate the CEUS-SSC model, updating:-Earthquake catalog-Probabilistic seismic hazard analysis (PSHA)-Site response analysis-Ground motion response spectra (GMRS)4 Staff Confirmation Analysis* Staff's confirmatory PSHA and site response results are similar to the applicant's results 3 2.5 2 1.5 1 0.5FPreq., 10-4-Ann6aýi Exceed,-Low Freq., 10-4 AEF (Applicarot)

-+igh Freq., 10-5-AEF (Aplicarit)-Low Freq., 10-5 AEF (Applicant)-Input Peak Ground Aocelerationi(-Input PGA = 0.3 g (NRC)ice requency (AE) ( picat IGA) = 0.1 g (INRC)0.2 E 4m I -I- I Mlul 0 0.1 1 Frequency (Hz)10 100 Note: Figure developed from the applicant's site response results provided in SER Figure 2.5.2-12 and the staff's results shown in SER Figure 2.5.2-13.5 Staff Confirmatory Analysis* Applicant's GMRS and Staff's GMRS are enveloped by the ESBWR certified seismic design response spectrum (CSDRS)0 C.)1.00 0.10-NNC ~$M(ITRI -(20¶f3) GMM---Appiant GMR.... .... .... ... ....-........

.E S B W R C S1B R ,' ..... ... ........ ...0.01 0.1 1 10 100 Frequency (Hz)6 Site-Specific Soil Structure Interaction (SSI) Analyses* The applicant incorporates ESBWR Design Control Document (DCD) Sections 3.7 and 3.8 by reference* The applicant performed site-specific SSI analyses to address-Partial rock embedment effect-ESBWR requirement of minimum shear wave velocity for side backfill 7 Fermi 3 Foundation Embedment Configuration Rock fl-c m ".-0a --mmc M "w* ' 8 Margin in Seismic Input ESBWR CSDRS envelops Fermi Reactor Building (RB) site-specific Foundation Input Response Spectra (FIRS)*~1.00 0 0.10------,- -RB UFtRS (NRC)0.01 0.10 1.00 Frequency (Hz) 10.00 100.00 9 Conclusions" Section 2.5.2 adequately addressed new CEUS-SSC through seismic hazard reevaluation for Fermi 3" Sections 3.7 and 3.8-Site-specific seismic demands for seismic Category I structures are bounded by ESBWR DCD-ESBWR standard plant design is adequate" Fermi 3 COL application meets relevant ESBWR DCD requirements and applicable NRC regulations 10 NRC000013 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment Combined License Application Review FERMI 3 Safety Panel 2 February 4, 2015 Panelists" Adrian Muniz -Lead Project Manager" Angelo Stubbs -Senior Reactor Systems Engineer" Raul Hernandez

-Reactor Systems Engineer" Dan Barss -Emergency Preparedness Team Leader 2 Recommendation 4.2-Framework* SECY-1 2-0025 contains proposed orders and requests for information in response to lessons learned from Fukushima Dai-ichi-Discussed approach for new reactors* Order EA-12-049 specifies requirements for mitigation strategies for beyond-design-basis external events* JLD-ISG-2012-01 provides guidance for meeting Order EA-12-049 3 Recommendation 4.2 -Approach* Initial phase mitigation for the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will use the ESBWR passive safety systems* Final phase mitigation to cover indefinite time beyond the initial 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s-Will use same passive safety systems, supported by offsite resources 4 Recommendation 4.2-Safety Review* Core cooling via the isolation condenser system-Safety-related passive closed-loop cooling system-Natural circulation, no reliance on ac power-Transfers decay heat to atmosphere 5

Recommendation 4.2-Safety Review* Containment cooling via the passive containment cooling system-Transfers decay heat via heat exchangers to the atmosphere with no reliance on ac power* Spent fuel cooling uses pool water inventory 6 Recommendation 4.2-Safety Review* Initial phase mitigation (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) provided by existing ESBWR passive safety systems* No transition phase mitigation required as adequate time is available to bring in offsite resources, if needed 7 Recommendation 4.2-Safety Review* Final phase mitigation continues to use passive safety systems with periodic replenishment of water inventories using offsite equipment or other available resources 8 Recommendation 4.2-Conclusions

  • Fermi 3 mitigation strategies provide core cooling, containment, and spent fuel pool cooling capabilities, as discussed in Order EA-12-049* License condition requires completion of the overall integrated plan, as described in Nuclear Energy Institute (NEI) 12-06, and full implementation of the guidance and strategies prior to fuel load 9 Recommendation 7.1 -Framework" SECY-12-0025 discussed approach for new reactors" Order EA-12-051 specifies requirements for reliable spent fuel pool instrumentation" JLD-ISG-2012-03 provides guidance for meeting Order EA-12-051 10 Recommendation 7.1 -Approach* Use level instruments provided in the ESBWR certified design* Expanded the ESBWR level instrument description to include independent power source connectivity and instrument design accuracy 11 Recommendation 7.1 -Safety Review/Conclusions
  • License condition requires a training program on establishing alternate power connections to level instruments 12 Recommendation 9.3-Framework* To conform to the direction in SECY-12-0025, applicants should perform an assessment of-Communications systems and equipment needed during prolonged station blackout condition-Onsite and augmented staffing capability to respond to a multi-unit event 13 Recommendation 9.3-Approach Applicant committed to follow NRC endorsed guidance NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0 14 Recommendation 9.3-Safety Review Staff modified the license condition-Reference schedules required by 10 CFR 52.99(a) and 10 CFR 52.103(a) for completion of Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) and fuel load-Changed license condition timing from two years before initial fuel load to 18 months before last date scheduled for completing ITAAC 15 Recommendation 9.3-Conclusion
  • Revised license condition is acceptable because-Responsive to SECY-12-0025

-Requires use of endorsed guidance in NEI 12-01 16 NRC000014 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment Combined License Application Review FERMI 3 Environmental Panel I February 4, 2015 Panelists" Jennifer Dixon-Herrity, Chief, Environmental Projects Branch* Mallecia Sutton, Lead Environmental Project Manager* Andrew Kugler, Senior Project Manager 2 Environmental Review: Regulations and Guidance" National Environmental Policy Act (NEPA)* NRC framework for implementing NEPA includes:-10 CFR Part 51-Environmental Standard Review Plan (NUREG-1 555)-Supplemental internal guidance 3 Review Process & Schedule Notice o Intent to Published Federal Register notice Conduct Scoping and in December 2008 Prepare EIS 1 0Scoping period from December 2008 to February 2009; scoping meetings held in January 2009 (Monroe)Notice of Availability 0 EPA Published Federal Register of Draft EIS notice on October 28, 2011 1* Comment period on Draft EIS from Public Comments on October 28, 2011 to Draft EIS January 11, 2012 Notice of Availability of

  • Final EIS published ca-, CQ I January 18, 2013 4 Environmental Resource Areas Source U.S. NRC 5 How Impacts are Qualified" SMALL -Environmental effects are not detectable, or 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 sufficient to destabilize important attributes of the resource 6 Summary of Impacts-Small Impacts" Water Resources" Aquatic Ecology* Land Use* Meteorology and Air Quality* Radiological and Non-Radiological Health* Environmental Justice* Fuel Cycle, Transportation, and Decommissioning 7

Summary of Impacts -Small to Moderate Impacts" Terrestrial Ecology" Socioeconomic" Cumulative 8

Alternatives

  • Energy Alternatives

-None of the feasible baseload alternatives considered was environmentally preferable

  • Alternative Sites -The four alternative sites were not environmentally preferable to the Fermi site* Alternative System Designs -No alternative cooling systems were environmentally preferable to the proposed plant design 9 Alternative Sites* Proposed Site A Altematve Site ,, State Boundary....County/Municipality Interstate Higlhway RiverlStream Water Body Urban Area Recreational Area 10 Process for Addressing New Information
  • Staff developed internal guidance to determine if a supplement to the EIS should be prepared as required by 10 CFR 51.92* The applicant was contacted to determine whether there was new information
  • Staff monitored changes to the application
  • No substantial changes or significant new information were identified that would call for a supplement 11 Endangered Species Act Consultation Consultation with U.S. Fish and Wildlife Service may impact timing of final licensing decision* Rufa Red Knot Bird listed as Threatened on December 11, 2014* Northern Long Eared Bat planned to be listed on April 2, 2015 12 Conclusions
  • Environmental impacts for most resource areas would be SMALL* None of the reasonable alternative energy sources, sites, or system designs was environmentally preferable
  • New information did not affect these conclusions
  • Newly listed species could impact timing of the final licensing decision 13 Recommendation The staff's assessments documented in the FEIS support a recommendation to the Commission to issue the license 14 NRC000015 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment Combined License Application Review Fermi 3 Environmental Panel 2 February 4, 2015 Fermi 1 Historic Preservation" Fermi 3 will be located adjacent to Fermi I and will require demolition of Fermi 1" Fermi 1:-Will be fully decommissioned prior to start of construction of Fermi 3-Was identified as eligible for listing in the National Register of Historic Places and as a Nuclear Historic Landmark-Demolition identified as an adverse effect 2 Mitigation for Demolition of Fermi I-Documentation package on Fermi 1 submitted to State Archives-Permanent public exhibit on history of Fermi I developed 3 International Interactions" Fermi site located seven miles from Canada" Staff contacted:

-International Joint Commission

-Great Lakes Fisheries Commission

-Fish and Wildlife Service Detroit River International Wildlife Refuge 4 Other International Outreach* Notice of public meetings in Canadian newspaper "Windsor Star"* Inclusion of Canadian emergency management personnel in emergency planning zone meetings 5 Comments from International Interactions" Scoping comments received from four international groups" Comments on draft EIS received from two international organizations" Request for opportunity to comment on FEIS received through U.S. Embassy in Canada 6 Continued Storage Background" Fermi 3 FEIS published January 2013" Continued Storage Rule at 10 CFR 51.23 and supporting NUREG-2157 published in September 2014" Staff therefore considered whether a supplement was needed 7 Requirements for Supplement

  • 10 CFR 51.92(a) addresses conditions requiring a supplement to an FEIS including:

-New and significant circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts-Commission has described the standard for a supplement as whether the new information is "presenting a seriously different picture" of impacts 8 Staff Evaluation for Continued Storage" Staff concluded in Fermi 3 FEIS, Section 6.1.6, that impacts of waste from the fuel cycle are SMALL" Following issuance of the rule, Staff prepared analysis (November 2014) to assess significance for Fermi 3 9 Continued Storage Environmental Impacts" NUREG-2157 concluded:

-Impacts of at-reactor storage in short-term timeframe would be SMALL-Disposal in short-term timeframe is most likely-Most impacts would be SMALL-Some impacts could be SMALL to MODERATE or SMALL to LARGE" Ranges are driven by uncertainties 10 Additional Considerations for Continued Storage" NEPA asks for reasonably foreseeable impacts, not worst case" Impacts of existing independent spent fuel storage installations (ISFSIs) are minor* Similar conclusion supports general license provisions for ISFSIs (10 CFR Part 72, Subpart K)11 Continued Storage Conclusions" Based on preceding, impacts of continued storage will likely be SMALL* Staff concludes the most likely outcomes are that:-Storage will remain on site until disposal-Disposal will be by end of short-term timeframe" Staff concludes that this is not a seriously different picture from the Fermi 3 FEIS" No supplement to the FEIS is required 12

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