Text

Comment (7) of Vito A. Kaminskas on Behalf of DTE Energy Company on Draft Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants Supplement 56 Regarding Fermi 2 Nuclear Power Plant
	ML15356A368
Person / Time
Site:	Fermi
Issue date:	12/15/2015
From:	Kaminskas V A; DTE Energy
To:	; Rules, Announcements, and Directives Branch
References
	80FR68881 00007, NRC-15-0100, NRC-2014-0109
	Download: ML15356A368 (37)
	v • d • e

~U --> ._ Vito A. Kanlirnskas Site Vice Pr'esident(DTE Eniergy Comlpany 6400 N. Dixie Highway, Newport, M'H 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kanhiInsLasv'cadtceIergy~coI1

' *' --- -- '-/L-L -DTIEEnergy' 10 CFR 54 NRC-2014-0 109 December 15, 2015 NRC-15-0 100 Chief, Rules, Announcements, and Directives Branch (RADB) l / Division of Administrative Services, ADM,,-Mailstop:

OWFN- 12-HO08 U. S. Nuclear Regulatory Commission Washington D C 20555-0001

,.

References:

1) Fermi 2 /NRC Docket No. 5 0-341 NRC License No. NPF-43 2) DTE Electric Company Letter to NRC, "Fermi 2 License Renewal Application," NRC-14-0028, dated April 24, 2014 (ML14121A554)

3) NIJREG-1437 Supplement 56 Volume 1, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 56, Regarding Fermi 2 Nuclear Power Plant, Draft Report for Comment, Chapters i to 8," dated October 31, 2015 (M~l15300A064)

4) NUIREG-1437 Supplement 56 Volume 2, "Generic Environmrental Impact Statement for License Renewal ofNuclear Plants, Supplement 56, Regarding Fermi 2 Nuclear Power Plant, Draft Report for Comment, Appcnd ices," dated October 31, 2015 (ML15300A073)

Subject:

DTE Comments on the Draft Generic Environmental hmpact Statement for License Renewal of Nuclear Power Plants Supplement 56 Regarding Fermi 2 Nuclear Power Plant In Reference 2, DTE Electric Company (DTE) submitted the License Renewal Application (LRA) for Fermi 2. In References 3 and 4, NRC staff published the draft plant-specific supplement to the generic environmental impact statement (GElS)regarding the Fermi 2 LRA. Enclosure 1 to this letter provides the DTE comments on the draft plant-specific supplement to the GElS for Fermi 2.SUNSI Review Complete Template =ADM -013 E-RIDS= ADM-03 USNRC NRC-1 5-01.00 Page 2 No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Lynne Goodman at 734-586-1205.

Sincerely, Michel A. Philippon Director Nuclear Production (Plant Manager)For Vito A. Kaminskas

Enclosures:

1) Comments to Draft Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants Supplement 56 Regarding Fermi 2 Nuclear Power Plant cc: NRC Document Control Desk NRC Project Manager NRC License Renewal Project Manager NRC License Renewal Enviromnental Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administratoi, Region IlI Michigan Public Service Commission, Regulated Energy Division (kindschl@michigan.gov)

Enclosure 1 to NRC-15-0100 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Comments to Draft Generic Environmental Impact Statemenit for License Renewal of Nuclear Plants Supplement 56 Regarding Fermi 2 Nuclear Power Plant Enclosure 1 to NRC- 15-0100 Page 1 DTE has reviewed the Draft Generic Environmental Imnpact Statement for License Renewal of Nuclear Plants Supplement 56 Regarding Fermi 2 Nuclear Power Plant (i.e. the draft SEIS). DTE's comments are provided in the table below. Two types of comments are provided:

those of a technical nature and those of an editorial natUre. The two types are identified in the table by the letter preceding the comment number, with "T'" indicating technical and "E" indicating editorial.

CmetSection Page Line Comment Number In the discussion of the purpose and need for the proposed federal action in the Exective ~ 37Executive Summary and Section 1.2, the draft SETS states that the purpose and need T1 Sumaryis "...to provide an option that allows for power generation...".

This statement Ti S~arydiffers from the DTE ER as it does not include the term "base-load" in front of 1.2 1-1 25 "power generation".

The term "base-load" is used in the NRC's Regulatory Guide (RG) 4.2 and also in GETS (NUREG-1437)

Section 1.3. The SETS should add the term "base-load" for consistency with the DTE ER, RG 4.2, and the GEIS.The draft SETS text says that the Duke Energy Station in Tndiana is in the ROT.T2 2.2.2.2 2-9 25 -26 However, the earlier definition of ROT was for counties in Michigan.

Therefore, the Duke Energy Station may be near the ROT but is not in the ROT.The draft SETS says that nuclear power provides 31% of electricity generation in Michigan.

The reference provided for this information is "ETA 2015". When DTE T3 2.2.2.3 2-10 42 reviewed reference ETA 2015, the value was 28.4%, not 31%. Tt is possible that the value on the website may have changed during the period of review. In that case,_________stating "approximately 30%" would cover both values.The SETS text discusses drinking water wells onsite. Both the Fermi 2 and Fermi 3 T4 2.2.2.3 2-11 24 B~s state that DTE does not withdraw groundwater at the site and drinking water is obtained from a local utility. There are no drinking water wells onsite.

Enclosure 1 to NRC-15-0 100 Page 2 CmetSection Page Line Comment Number The SEIS states that solar will remain a commercially available option for electrical generation capacity supported through the Michigan Renewable Energy Standard.As discussed on SEIS page 2-5, the Michigan Renewable Energy Standard will be T5 2.2.2.4 2-14 22 -23 met by the end of 2015. When the standard is met, it is not certain that the availability of solar will increase in the same manner as it increased prior to meeting the standard.

Therefore, the NRC may want to revise the sentence so that it does not give the impression that the Michigan Renewable Energyr Standard will necessarily cause further growth in renewable beyond 2015.Table 2-2 footnote 3 is only applied to the proposed action, no-action, and new nuclear power items. It is not used for the NGCC, IGCC, and combination T6 22-23 Table 2-2 alternatives.

Since the impacts from chronic effects of electromagnetic fields would be applicable to any plant that produces and transmits electricity, this footnote should also be used for the NGCC, IGCC, and combination alternatives.

The statement "began commercial operation in July 1985" is not correct. A full power operating license was issued in July 1985. However, commercial operation T7 3.1 3-1 10 did not begin until January 23, 1988 per DTE letter to the NRC (letter number NRC-88-0032) dated February 15, 1988. This DTE letter does not appear to be in ADAMS. The sentence could be reworded to discuss the operating license date of July 1985 rather than the commercial power operation date.

Enclosure 1 to NRC-15-0100 Page 3 omnient ume Section Page Line Comment There are inconsistencies between Figures 3-5 and 3-12: 1) In Figuare 3-5, the water bodies are labeled North Canal, South Canal, and Small Pond (in order fr~om top to bottom). However, as shown on Figutre 3-12, the water bodies are labeled North Canal, Small Pond, and South Canal (in order from top to bottom). Figure 3-12 is correct. The water body labeled South Canal on Figure 3-5 is actually part of the North Canal; the South Canal is not actually shown in Figure 3-5. It is recommended that Figure 3-5 be revised to remove the South Canal label and that another line be drawn from the North Canal label to the water body 83.1.3.1 3-8 Figure 3-5 currently labeled as the South Canal. DTE recommends this line alsobe added to 3.5.1.1 3-42 Figure 3-12 Figure 3-12 for clarity.2) In addition, it is also recommended that "(Overflow Canal)" be added to the North Canal label in both Figures 3-5 and 3-12, as the Overflow Canal is used interchangeably with North Canal in the actual text.3) The pointer for NPDES Outfall 001 label is in a different location on Figures 3-5 and 3-12. The pointer location in Figure 3-5 is correct. The pointer location in Figure 3-12 for NPDES Outfall 001 should be moved slightly further south for consistency with Figure 3-5.The SETS text indicates that the Fermi site potable water demand is approximately 20,000 gallons per day and gives the DTE ER as the source document.

DTE did not 9 -provide a value of potable water demand in the ER, so it is not clear where the value"93.1.3.4 3-10 36 -7 of 20,000 gallons per day was obtained.

The value also seems high. Recen~t analysis by DTE indicates that the average Fermi site potable water demand was less than 6,500 gallons per day.

Enclosure 1 to NRC- 15-0 100 Page 4 Cm etSection Page LineComn NumberComn The sentence as written is partially incorrect since universal waste does not include items such as scrap metal, plastic bottles, etc. The sentence could possibly be T1O .1. 3-1 17-20 reworded as "Universal wastes, such as batteries and mercury-containing lamps, and other potential wastes, such as oils, scrap metal, aluminum cans, plastic bottles, cardboard, and paper, are recycled when possible in accordance with DTE's_________

_______procedures (DTE 2014d)." Ti 1 3.16.1 3-1 16DTE recommends deleting the phrase "for RHR" from the end of the sentence since the EDGs provide standby power for more than just RHR.DTh recommends revising the phrase "that provide power" to "'and provides T12 3.1.6.5 3-20 40 power". The 120 kV switchyard services the 4 CTGs and it provides power to Fermi 2 Division 1. The sentence as written in the draft SF1S does not fully reflect the plant design and so should be clarified as indicated (see ER Section 2.2.10).The draft SEIS says that the total length of the lines is 315 feet. However, per ER Section 2.2.10.1, the lines run 325 feet from the turbine building to the intermediate T13 .1.65 3-1 6switchyard, and then run 315 feet from the intermediate switchyard to the 345 kV_________switchyard.

Therefore the total length is 325 + 315 = 640 feet.The draft SEIS states that the 345 kV lines go to a point west of 1-75 and then turn north and run adjacent to 1-275 for 12 mi to Brownstown Substation.

The SIEIS T14 3.1.6.5 3-21 19 -20 reference for this information is the Fermi 3 COLA ER. Per Section 2.2.2.1 and Figure 2.2-3 of the Fermi 3 COLA ER, the 345 kV lines run adjacent to 1-75 not 1-275. The discussion ofi1-275 in the SE15 should be revised to 1-75.The draft SEIS says that Fermi 1 operated from 1957 through 1972. Fermi 1 T 15 3.2.1.1 3-26 4construction started in 1956 (see ER Section 3.7.3.1 ), but only operated from 1963____ ___ _ _ ___ ____ ___ ___ ___to 1972.

Enclosure 1 to NRC-15-0 100 Page 5 CommentComn Nubr Section Page LineCom t The draft SEIS says that the area on Site where the MiDNR owns mineral rights is in the southeastern portion of the site "near the meteorological tower". The source of this information is the Fermi 3 and it is not correct to apply it Fermi 2. The discussion of the meteorological tower was based on the proposed Fermi 3 T16 3.2.1.1 3-28 7 -8 meteorological tower. The Fermi 2 meteorological tower is in a different location.As discussed in the Fermi 2 ER Section 3.1.1, the MDNR does own mineral rights in the far'southeastern portion of the Fermi site and the meteorological tower is not mentioned.

The sentence should be revised to remove the discussion of the________ _________

________meteorological tower.The draft SEIS says that the nearest quarry is about 3 miles north-northwest (NTNW).In ER Table 3.12-1, the nearest quarry is 2.5 miles north-northeast (NNE). Table T17 .4.13377.1 of the Fermi 3 FEIS also has the direction as NNE. The direction should be revised to NNE.In several locations, the SEIS text uses the term "Central Canal" as an alternative 3.5.1.1 3-40 35 name for a small pond which is not connected to nearby water features.

However, TIS this name is not used in the labels on Figures 3-5 and 3-12. DTE also did not use 3.7.1.2 3-76 4 -6 this term in the ER. Therefore, DTE recommends removing the name "Central Canal" from the text for consistency with the SEIS figures as well as the DTE ER.Lines 17 and 33 refer to Figuares 3-2 and 3-3, respectively, when discussing water features.

However, Figures 3-2 and 3-3 are not as detailed as later figures, such as T19 3.51.1 3-4 17 33Figulre 3-12. It may be better to refer to Figulre 3-12 in both cases since Figure 3-12 provides a much more detailed view of the relevant water features.

Enclosure 1 to NRC-15-0 100 Page 6 CmetSection Page Line Comment Number 3.51.3 3-4 41In the Section 3.5.1.3 text, the state regulations for N-PDES permit program are cited as "MVAC R 323.2101-2197".

The same regulations are listed as "MAC R 323.2101-2196" in the Section 3.14 list of references and Section 4.5.3.1.T20 .143-16 30Therefore, there is an inconsistency in number (2197 vs. 2196). According to a 4.5..1 426 9review of the website associated with the references, 2197 appears to be the correct_______ _________number.

For the discussion of Outfalls 009 and 011, the NPDES permit used the term"overflow canal". As discussed previously in the comment on Figures 3-5 and 3-12, T21 3.5.1.3 3-47 -Table 3-8 the overflow canal is an alternate name for the north canal (the term used currently in Table 3-8). However, it may be preferable to use the term overflow canal in________ __________Table 3-8 for consistency with the NPDES permit.Lines 3 and 47 refer to Figures 3-3 and 3-2, respectively, when discussing water T22 .5..3 348 47features.

However, Figures 3-2 and 3-3 are not as detailed as later figures, such as Figure 3-12. It may be better to refer to Figure 3-12 in both cases since Figuxre 3-12 provides a much more detailed view of the relevant water features.3.5.1.3 3-49 6, 15 According to the source document for reference USAGE 2004, the USAGE dredge T23 permit number should be 88-001-040-8, not 98-001040-9.

This incorrect permit_____3.14 3-176 24 number appears in two locations on page 3-49 and one location on page 3-176.The SEIS text says that tritium was detected above the laboratory detection limit in two wells with concentrations of 527 and 1170 pCiIL. This information references"DTE 2014e" which is the Fermi 2 Radiological Environmental Operating Report for 2013. Table 9 of that document (starting on page B-6) shows 5 sample results in T24 3.5.2.3 3-54 41 -45 3 monitor wells over the laboratory detection limit, not 2 monitor wells. The values are 568 pCi/L (well EF2-07-005S), 527 pCi/L (well EF2-07-024S), and 1110, 1170, and 1450 pCi/L (well EF2-07-025S).

The SEIS text should be revised for consistency with the source document.

As discussed in the draft SEIS, all detected_______ ________ ________________concentrations are well below EPA's drinking water standard of 20,000 pCi/L.

Enclosure 1 to NRC-15-0 100 Page 7 CmetSection Page LineComn NumberComn The draft SEIS says the prairie restorattion associated with the transmission corridor T25 3.6.3.1 3-60 47 was started in 2003. However, the project was started in 2005 as indicated in ER__________Section 3.6.6.3.Table 3-11 does not include the eastern fox snake. SETS page 3-68 describes that the eastern fox snake was observed onsite in 2008, although in a different survey than the survey that was the source of the data used for Table 3-11. Since the title T26 .6.32 364 Tble -11 of Table 3-11 indicates it covers the years 2008-2009, it seems appropriate to include the eastern fox snake. Alternatively, the text preceding Table 3-11 or the title of Table 3-11 could be revised to indicate that the table only contains animals observed during the specific survey (and therefore the eastern fox snake would not need to be included).

SEIS Table 3-15 lists two birds for May 22, 2008. The source listed for this table is a DTE RAI response.

In the DTh RAI response (TE-15), there are three birds listed T27 3.6.6 3-73 Table 3-15 for the date May 22, 2008. The chestnut sided warbler in the RAI response (which is listed in a separate row under the same date) should also be included in SEIS Table 3-15 for consistency.

The sentence regarding the use of the overflow canal by Fermi 1 implies that its usage ceased when Fermi 1 was temporarily shut down. It seems to imply that it is no longer used at all. However, the overflow canal is being used for Fermi 2 as indicated later in the discussion.

Therefore, the sentence should be revised to more T28 3.7.1.2 3-75 28 -30 clearly state that its usage by Fermi 1 ceased when Fermi 1 ceased operation.

In addition, the overflow canal may have been used by Fermi 1 after the temporary shutdown but not after the permanent shutdown.

DTE recommends revising the sentence such as "The overflow canal was historically used as a cooling water discharge and overflow canal for operation of Fermi 1 but use for this purpose ceased when Fermi 1 was shut down."

Enclosure I to NRC-15-0 100 Page 8 CmetSection Page LineComn NumberComn The draft SEIS text says that the overflow canal is a permnitted wastewater discharge and specifically mentions Ouffall 009. As shown on Figure 3-12, Ouffall 011 and T29 3.7.1.2 3-75 32 -33 three stormwater ouffalls (002, 003, and 014) are also applicable to the overflow canal. These other ouffalls could be mentioned within the parentheses for consistency with Figure 3-12.SIEIS Table 3-19 lists the northern riffleshell, purple lilliput, round bickorynut, and salamander mussel as "M-' which is defined as listed as threatened by the state T30 3.7.3 3-88 Table 3-19 of Michigan.

In SEIS Table 3-22, these four species are all listed as endangered (i.e. not threatened) in Michigan which is consistent with DTE ER Table 3.6-6.DTE confirmed that the current MNPI lists these four species as endangered rather than threatened.

The discussion of the commercial harvest of lake whitefish (page 3-94) and white 3-94 38 -40 perch (page 3-97) provide values for Michigan in 2007 and Ohio in 2009 and then T31 3.7.3.1 reference Tables 3-20 and 3-21. However, Tables 3-20 and 3-21 provide commercial harvest for the year 2010, not 2007 or 2009. DTE recommends 3-97 2 -32 removing the reference to Tables 3-20 and 3-21 as the values in the text are not found in those tables. Perhaps a different cross-reference was intended.The discussion of the wavyrayed lampmussel includes the reference citation~"Carman and Goforth 2000c". However, this reference listed in Section 3.14 T32 .7.33 3-07 6addresses the channel darter and not the wavyrayed lampmussel.

The reference citation on line 6 should be deleted (other references to Carnan and Goforth 2000c on page 3-107 appear to be correct as they are in the channel darter discussion

___________section).

The SEIS text includes a discussion paragraph on the pugnose shiner. However, the T33 3.7.3.3 3-109 26 -43 pugnose shiner was not listed in Table 3-22. Clarification is needed on why it is being included in the discussion even though it is not listed in Table 3-22.

Enclosure 1 to NRC-15-0100 Page 9 CmetSection Page Line Comment Number For consistency with the discussion in the cited reference (Kuranda et al. 2009), T34 3.9.2 3-129 12 DTE recommends adding the word "sized" after "commercial" when discussing Fermi 1.The SEIS text says there are approximately 870 employees and 20 long-term contract employees, with the source reference being the DTE ER. The DTE ER states that there are 889 full time employees (ER pages 2-50 and 2-56). The ER does not explicitly distinguaish between employees and long-term contract employees.

So although the total number of employees

(@890) is consistent between the SEIS and the ER, it is not clear where the NRC got the information that there are 20 long-term contract employees.

This distinction is also made elsewhere T35 3.10.1 3-13I1 6 -7 in the SEIS such as in Sections 4.10 and 4.12.2 which repeatedly uses the -~870 value rather than -890. The -890 value in the ER does include some employees from far outside the region of interest (e.g. ER Table 2.5-1 lists employees from Georgia and New York), but it is not clear if the NRC used distance as a criteria for determining the ~-870 value used in the evaluations for the number of employees.

Note that if the text here was revised to use the -890 value, then corresponding changes to Sections 4.10 and 4.12.2 (and potentially others) would also be required.

Enclosure 1 to NRC-15-0 100 Page 10 CommentComn Nubr Section Page LineComn The SEIS text says that the remaining 22% of the workforce comes from 16 other counties in M~ichigan and Ohio and 1 Canadian province, with numbers ranging from 1 to 9 employees per county. The source reference for this statement is the DTE ER. However, ER Table 2.5-1 lists 18 counties in Michigan and Ohio (besides T36 3.10.1 3-13 1 9 -11 Monroe and Wayne), 1 Canadian province, as well as 2 counties in Georgia, and 1 in New York. In addition, ER Table 2.5-1 as well as SEIS Table 3-25 shows that there are more than a maximum of 9 employees per county (excluding Monroe and Wayne). Lucas county has 74 employees which is included as part of the 22%. It appears that the SEIS text is not consistent with the SETS table and the DTE ER.SETS Table 3-25 shows a total of 867 employees.

However, the actual sum of the numbers in the rows of the table is 889. The 889 value would be consistent with the value in ER Table 2.5-1, but the 867 value would not be. This comment is related to the above comment regarding the correct value to use for the number of employees.

T37 3.10.1 3-131 Table 3-25 Also, the format of the table lists "Other counties" in such a way that it appears to be other counties of just Ohio. The numbers in this row clearly reflect other counties for both Ohio and Michigan.

The formatting should be altered to make it clear that "Other counties" is not a subset of Ohio.The SETS text indicates that retail trade is the third largest employment sector with 10.5%. However, based on Table 3-26, the "professional, scientific, management, T38 3.10.2.1 3-132 15 -16 administrative, and waste management services" sector appears to be slightly larger than "retail trade" (i.e. 10.9% vs. 10.5%). Therefore, the text is not consistent with the table.

Enclosure 1 to NRC-15-0 100 Page 11 Comment Nubr Section Page Line Comment The Winter PRE entry for Airport Schools in SEIS Table 3-38 has a value of T39 .10. 3-42 Tble -38 18.5446. The source document (the DTE RAI response) had a value of l18.5445.There appears to be an inconsistency in the last digit of the value in SEIS Table__________

3-38.The SElS text says that the 3-year average annual collective dose per reactor is T40 .11. 3-16 14131.18 person-rem.

The source document (NUJREG-0713) uses a rounded value of 133 person-rem on page 4-14 and a more detailed value of 133.185 on page 4-15.The value in the SEIS text appears to be inconsistent with the source document.The sentence that discusses DTE chemical control procedures refers to reference DTE 2014g, which is the DTE RAI response.

The information in the DTE RAI WMVNR-5 response is slightly different than how it is presented in the SEIS. The SEIS sentences seems to imply that personnel are required to check the existing stock system to see if a chemical is already available before requesting .that chemical.

In the DTE RAI WMiNR-5 response, DTE stated that personnel are T4 1 3.11.2 3-146 33 -36 required to check if a similar chemical is already available before requesting a new chemical.

The difference is very slight, but the intent of the DTE wording was to demonstrate that the procedure requirement is to avoid having multiple products that perform the same function in addition to just minimizing overall stock. It may be beneficial to reword the sentence in the SEIS for consistency with the RAI response.However, the overall conclusion in the SEIS section that DTE has processes and procedures to minimize potential for hazardous chemical waste is correct and consistent with the DTE ER and RAI response.

Enclosure 1 to NRC-15-0100 Page 12 CmetSection Page LineComn NumberCom t The SEIS text discusses "Mid-Atlantic states". Michigan is an "East North Central" state according to the US census divisions, which are the groupings used in the reference document "CDC 201 1". According to the source document, the statement T42 .11. 3-17 26about the highest number of cases being during summer and early fall is true for both Mid-Atlantic and East North Central. Therefore, it seems more appropriate to refer to East North Central states for the discussion of Fenni 2. Another alternative would be to use the term "Midwest", which is also used in the source document and would be appropriate for Michigan.There appears to be a difference in methodology between the draft SEIS and the DTE ER in the Environmental Justice section. In the DTE ER Section 3.10.2, a population is considered minority or low-income if the population in the block group exceeds 50% or if it is more than 20 percentage points greater than the 3.12.1 3-15 1 34 -40 percentage in the geographic area (50 mile radius). The methodology in the DTE T43 ER was based on the NRC guidance LIC-203 Revision 3. However, in the draft 3.12.2 3-153 15 -21 SEIS Sections 3.12.1 and 3.12.2, a population is considered minority or low-income if the population in the block group exceeds the percentage in the geographic area (50 mile radius). As a result, the draft SEIS describes and shows much larger values for minority and low-income populations than the DTE ER. However, DTE agrees that the draft SEIS results are conservative.

The SEIS text says that the impact of the no-action alternative on air quality would T44 4.3.2.1 4-7 10 be SMALL. However, SEIS Table 2-2 says that the impact would be SMALL to MODERATE.

This appears to be an inconsistency between the text and the table.

Enclosure 1 to NRC-15-0 100 Page 13 Comment Nubr Section Page Line Comment The SETS value for sulfur oxide emissions is given as 4 tons (13 metric tons) per year. One of these values must be incorrect since 1 ton is equal to approximately T45 4.3.3.1 4-8 15 0.9 metric tons. Based on scaled values given on page 4-18, it appears that 13 metric tons is probably the correct value and 4 tons is incorrect.

Using the correct unit conversion, the value would then be approximately 15 tons instead of 4 tons.The SETS text discusses the maximum hourly Leq resulting from operation of T46 .3.52 4.6 45Fermi 3. However, this discussion is in the section on construction not operation, consistent with its use in the source document (Fermi 3 FEIS). So it appears that________ ________"operation" should be "construction" in this line.The energy rating for the NGCC component of the combination alternative on page 4-17 0-31 4-17 (400 MW) and page.4-18 (total gross capacity 400 MW) seems to be T47 4.3.6.1 inconsistent with the rating of 470 MWe or net capacity of 400 MWe given in 4-18 40Section 2.2.2.4 on page 2-12 (lines 7 and 16). DTE recommends that the sentences on pages 4-17 and 4-18 be clarified to indicate the appropriate rating for consistency with Section 2.2.2.4.The current wording of the sentence seems to imply that the emission of nitrogen oxides (90 MT) exceeds the threshold for GHG reporting (25,000 MT) which it does T48 .3.61 419 3- 4not. DTE recommends revising the sentence so that it states that "Annual emissions of nitrogen oxides would exceed the major source threshold and emissions of C02eq would exceed the threshold for mandatory GHG reporting (25,000 MT (27,558 tons) CO2eq per year)."

Enclosure 1 to NRC-i15-0100 Page 14~metSection Page Line Comment umber The SEIS states that the "The majority of site landscape maintenance is performed within the protected area and not within natural areas on the site." The use of the 49 .61. 431 15- 16 phrase "protected area"' in this context is confusing since the term has a specific 4.6..1 431 1 16 meaning with regards to plant security.

Some of the landscape requiring maintenance is outside of the "protected area"'. DTE recommends replacing_______"protected area" with "developed area"'.The discussion in the SEIS regarding the impact of Fermi 2 decommissioning on the DRIWR or other sensitive habitats references the DTE RAI responses.

In those RAI 50 46.24-32 42 44 responses, such as the response to LUVR-3, DTE discusses the decommissioning of 50 46.2 -32 2 -Fermi 1 and the potential construction of Fermi 3, but does not discuss decommissioning of Fermi 2. Since the statement in the SIEIS is not supported by the listed reference, the sentence should be revised or deleted.The statement that the wind and solar portions of the alternative account for 90% of 51 4.7.6 4-39 17 the alternative's power generation is inconsistent with SEIS Table 2-1 which_______indicates that they are about 75% (i.e. 800 MWe of 1200 M-We).The SEIS text refers to reference "DTE 201 5a"' for discussion regarding the red knot. In Section 4.18, the reference "DTE 2015a" description is for DTE'S RAI 4.8.1.1 4-41 35 response on SAMA. Therefore, this does not appear to be the correct reference.

In 52 addition, the ML number provided for reference DTE 2015a in Section 4.18 (page 4.18 4-136 45 4-136) brings up an exhibition document rather than a DTE RAI response.

So there appears to be an inconsistency between the SEIS text, the reference number, and the ML number.

Enclosure 1 to NRC-i15-0100 Page 15 CmetSection Page Line Comment Number Item 4 of the sentence indicates DTE's assurance that no license renewal-related physical changes or ground-disturbing activities would occur. This is slightly different than similar statements in the ER, such as in Section 4.7.1.4.2 which 4.9. 45 30 31 discusses that no license-renewal related construction activities have been identified, T53 any maintenance activities would be limited to currently developed areas of the site, 2 2-2 Tabl 2-2 and that no future ground-disturbing activities are planned in support of license renewal. A possible alternative would be to revise Item 4 to "..no license renewal-related physical changes or ground-disturbing activities would occur outside developed areas." Note that footnote 2 of Table 2-2 uses the same Item 4 wording_________and so would also need to be revised for consistency.

The SEIS text in Section 4.9.3 says that the impact on historic and cultural resources T54 49.3 44 29due to construction and operation of an NGCC plant would be SMALL. However, SEIS Table 2-2 says that the impact would be SMALL to MODERATE.

This appears to be an inconsistency between the text and the table.It is not clear why fewer workers than the 210 estimated to conmnute daily to an T55 .104.2 4-60 17 18 IGCC plant W¢ould be required if multiple units are operated at the same site. More units would mean fewer workers per unit, but would not reduce the total number of workers.The SEIS text mentions construction near an existing nuclear plant or retired coal T56 4.10.5.1 4-60 42 site. It is not clear why this section on the new nuclear alternative would include discussion of a retired coal site.The SEIS text in Section 4.10.6.2 says that the impact on socioeconomics T57 4.10.6.2 4-62 41 (transportation) due to construction and operation of wind and solar would be SMALL to MODERATE.

However, SEIS Table 2-2 says that the impact would be SMALL. This appears to be an inconsistency between the text and table.

Enclosure 1 to NRC-15-0100 Page 16 CmetSection Page Line Comment Number In Table 4-14, the assumption listed Under SAMTA 206 does not appear to be correct.From comparison with the DTE ER, it appears that the assumption listed in the T58 4.11.1.2 4-70 Table 4-14 SETS corresponds with the assumption for SAMA 211 in the ER. The SAMTA 206 assumption should be revised to correspond with the assumption for SAMTA 206 in the ER.Table 4-14 footnote c describes SAMAs not listed in the table that were updated by T59 .11..2 471 Tble -14 DTE as described in Section F.4 of the SEIS. DTE believes that SAMA 154 should also be listed in footnote c as it is included in Section F.4 as having its assessment

_______ _________updated by DTE.Table 4-14 footnote d describes SAMAs not listed in the table with calculated T60 4.11.1.2 4-71 Table 4-14 corrected benefits as listed in Table F-6. DIE believes that SAMA 54 should also________ _________

__________________be listed in footnote d as it is included in Table F-6.4.111.2 -72 2-33 DTE recommends revising the phrase "the design evaluation process and evaluated considering other planned plant modifications" to "the evaluation process and 4.11.1.2 4-73 16 -17, evaluated considering other planned changes".

The reason is that some of the T145 -46 potentially cost-beneficial SAMAs involve procedures andlor training and do not T6 1 include design changes or modifications.

Since it appears that the statement in the SEIS was meant to be a general statement applicable to all of the potentially cost-App.F.6. F-5 13 14 beneficial SAMAs, the terms "design" and "plant modifications" are not appropriate in general. The same revision would apply to all 5 ofthe locations noted for this App. F.7 F-56 19 -20 cmet The SEIS text refers to Figuares 3.12-1 and 3.12-2. The location of these figures is not clear as there are no figures by those numbers in the SEIS, ER, or GElS. If the T62 .12. 4-7 24figures are intended to be those in the SEIS, the correct numbers appear to be__________________________Figures 3-18 and 3-19.

Enclosure 1 to NRC-15-0100 Page 17 Cm etSection Page Line Comment Number The SEIS text states that samples are collected annually.

In some cases, samples T63 4.12.1 4-77 33 -34 may be collected more frequently than annually.

Therefore, DTE recommends revising the statement to indicate that samples are collected at least annually.In several locations on page 4-78, the SEIS text states that no radioactivity was detected greater than the minimum detectable activity.

In each case, DTE 3 ~ recommends clarifying that no plant-related radioactivity was detected greater than T63.1. 48- 4,the minimum detectable activity.

In some cases, offsite samples did indicate T64 4.2. 478 10 -11, radioactivity greater than minimum detectable activity due to causes other than 16 -17 Fermi 2, such as naturally occurring radiation or fallout from weapons tests (as described at the top of page 4-78). This clarification would be consistent with the language used by DTE in the reference cited in the SETS (DTE 2014b).Table 4-17 should list "Termination of plant operations and decommissioning" as the only issue, since it is the issue listed in Table B-i of Appendix B to Subpart A of 10 CFR Part 51 related to decommissioning.

The issues currently listed in Table 4-19 are not listed in Table B-i. The sentence bef'ote Table 4-19 reads "Table 4-19 T65 .152.1 4-9 Tale -19 lists the Category 1Tissues in Table B-i of Appendix B to Subpart A of 10 CFR Part 51 that are applicable to Fermi 2 decommissioning following the license renewal term." For the other categories of NEPA issues in the draft SEIS, the issues listed match those in Table B-i.T66 4.15.3.1 4-~93 15 This page indicates that 25,000 MT is equal to 25,558 tons. However, 25,000 MT is_______ ________________

_________actually equal to 27,558 tons as indicated on page 4-19 line 4.

Enclosure 1 to NRC-15-0 100 Page 18 CmetSection Page Line Comment Number The SEIS Table 4-20 entry for 2010 h~as 9163 CO2eq MT/year with the source T67 .I5..1 493 Tble -20 document being the DTE RAI response.

This value appears to be inconsistent with T67 .15..1 493 Tble -20 the DTE RAI response.

When adding the values in the DTE RAI MET-3 response, the correct total appears to be 9193 CO2eq MT/year.The SEIS text gives an emissions estimate of 937 kg of CO2eq per kilowatt-hour with a value in parentheses of 937 g Ceq/kWh. There appears to be a discrepancy between the units of the two values (i.e. one is in kilograms and the other is in T68 4.15.3.1 4-94 14 -15 grams).In addition, the reference given for the values is NETL, 2010. According to Section 4.18, NE'TL 2010 is a study on NGCC rather than IGCC. Since this text is in the IGCC section, the reference may be incorrect.

The SEIS discusses an increase in annual mean temperature of 2.5 to 3.5 0 F (4.5 to T69 4.15.3.2 4-96 42 6.3 °C). Either the units or values are incorrect here because the values do not correspond to each other when converting between F and C.On lines 41 and 42, DTE recommends revising "Over the past 5 years" to "During a T70 4.16.3.1 4-108 40 -43 five-year period from 2009 to 2013" since the past 5 years could be interpreted to mean 2010-2014 due to the date of this SEIS, whereas the data was for the specific 5 year period from 2009 to 2013.The discussion of mayflies leaves the impression that mayflies have been reduced T71 .16. 4-19 32- 49 almost to extirpation since the 1960s. However, some mayfly recovery occurred subsequent to the 1960s and there are currently considerable densities of miayflies in this region. It may be beneficial to note that somewhere in the discussion.

Enclosure 1 to NRC- 15-0100 Page 19 CmetSection Page Line Comment Number The SEIS Table 4-24 entry for "socioeconomics" says "no new or increased impact", which corresponds with the first sentence of Section 4.16.7.1 (the conclusion section for the cumulative effects on socioeconomics).

However, the"socioeconomics" entry for cumulative impacts in Table ES-i says "'SMALL to T72 4.16.12 4-131 Table 4-24 LARGE", which corresponds to the second sentence of Section 4.16.7.1.

The result is that the entries in Tables 4-24 and ES-i appear to be inconsistent with each other.DTE recommends adding some of the informnation from the second sentence of Section 4.16.7.1 to Table 4-24 so that it is more obvious that Tables 4-24 and ES-i are in agreement.

No affiliation is given for "Richard Micka". However, the conmment letter (G)T73 App. A A-4 Table A-i provided by Mr. Micka indicates that he is the Chairman of the DRIWR Alliance._________

_______This affiliation could be included in Table A-i.The SEIS text in Appendix A and Appendix F says that sensitivity values for App. A A-29 42 -43 evacuation fraction have a very small influence on population dose risk (< 0.005 T74 percent).

It appears that this number is calculated based on ER Table D.1-26. If so, App. F.2.2.4 F-19 37 -38 the calculated number should be < 0.5 percent rather than < 0.005 percent. The same change should be made in Appendix A and Appendix F.

Enclosure 1 to NRC- 15-0 100 Page 20 CmetSection iPage LineComn NumberComn The SEIS text says that wildlife surveys do not indicate the presence of beavers on or in the vicinity of the Fermi site. This statement is correct since the wildlife surveys and the DTE ER do not discuss beavers. However, site personnel have recently noticed possible evidence of a beaver (i.e. some small chewed trees and debris collected in water on site) although an actual beaver has not been observed.T75 App. A A43 7 -8 The debris that looked like a potential beaver dam was located in the small pond shown on Figure 3-12 of the SEIS. As discussed in SEIS Section 3.5.1.1, this small pond is not directly connected to any other surface water features.

Therefore, DTE recommends that the discussion be modified to indicate that even if beavers were present on site, the evaluation of the draft SIEIS in Sections 3.6 and 4.6 would still be accurate and impacts would be SMALL.In Table B-i, in the last row on page B-4, revise "These parts of the MCL T76 App. B B-4 Table B-i implement the requirements of the CAA" to "These parts of the MCL implement the-requirements of the CWA".T77 In the first row of Table B-2, the expiration date of NRC license NPF-43 should be 77 App. B B-6 Table B-2 "32/05 There are two correspondence letters that could be added to this table: 1) DTE sent a letter to the NRC on February 18, 2015 that was a revised response to T78 pp. D-3Tabl D-1 an environmental RAI. The ML number for the correspondence is ML15050A682.

2) The NRC sent a letter to DTE on February 24, 2015 that was a change in license renewal schedule and project manager. The ML number for the correspondence is ML15051A348.

The text on line 24 states a reduction in CDF to 1 .5E-06 per year while the T79 App. F.2.2 F-5 24 footnote 1 at the bottom of the page states 1.3E-06 per year. DTE believes that the text on line 24 should state 1.3E-06 per year for consistency with the footnote.

Enclosure 1 to NRC-15-0 100 Page 21 Cm etSection Page Line Comment Number The Table F-3 LERF value for IPE (1992) says "Not Available".

The value is T80 pp. .2.2 F-5 ableF-3 provided in ER Table D.l-17 as 8.OE-07.T81 pp. .2.22 F-3 26The SEIS text indicates that the external events multiplier is 14.6. In the DTE RAT 3.b response (NRC-15-0013), the multiplier was calculated to be 14.7.The SETS text says that there were 5 accident classes and 19 subclasses as listed in T82 App. F.2.2.3 F-14 11 -12 ER Table D.1-8. However, according to the ER Section D.1.2.2.4 and Table D.1-8,-there are 5 classes and 16 subclasses.

The draft SEIS states that DTE indicated in an RAI response that all containment isolation failure sequences were assumed to result in a high early (HJE) release.T83 pp. .2.23 F1 32 33* However, the DTE response to RAT 2.c (NRC-15-00

13) on containment isolation T83 pp. .2..3 F14 2 -3 " failure sequences stated that "Failure of containment isolation in conjunction with core damage is assumed to result in a Hi-gh-Early (LERF) release." The SETS should add the phrase "in conjunction with core damage".The draft SEIS describes that DTE indicated the run times for two of the release T84 pp.F.22.3

-16 30 31 categories was 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months (or approximately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months after accident initiation).

T84 pp.F.22.3

-16 30 31 However, the DTE RAT 2.h response (NRC-15-0013) indicates the time was 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months from accident initiation or approximately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months following core damage.The draft SETS states that DTE reported an increase of 0.01 percent of the core inventory.

However, the DTE RAI 2.h response (NRC-15-00

13) indicates an T85 App. P.2.2.3 F-16 35 -37 increase in 0.01 (not 0.01 percent) of the core inventory or about 3 to 4 percent of the 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months release fractions for CsI and CsOH from the 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months values used in the SAMA analysis were obtained by using a run time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Enclosure 1 to NRC- 15-0 100 Page 22 Cm etSection Page LineComn NumberComn DTE recommends revising "...Fermni 3, whose operation has not yet begun but is T86 App. F.2.2.4 F-20, 49, planned during the license renewal period for Fermi 2..." to "...Fermi 3, which has F-2 1 1 been licensed for the site, and whose operation may occur during the license renewal period for Fermi 2...".T87 pp.F.3 2 F5 6Revise the phrase "including external events uncertainty" to "including external events and uncertainty" similar to how it is on line 10 on this same page.T88 Ap. F4 F-8 36Delete the reference to "DTE 2015Sc" since that RAI response did not address the SAMA being discussed.

The sentence in the draft SEIS states that DTE indicated that drywell head leakage T89 App. P.4 F-29 19 -21 is the dominant containment failure mode. For consistency with the DTE RAI 6.h________ __________response, DTE recommends revising "the dominant" to "a dominant".

In Table F-5, the Population Dose and OECR colurmns for SAMA 203 both have T90 App. F.4 F-41 Table F-5 <0.1. However, comparison to the same entries in Table D.2-1 in the DTE ER show that the values should both be <1.In Table F-5, for SAMAs 206 and 207, the description of the SAMA was left out of the assumption section. The assumption section starts with how the analysis of the T9 1 App. 1P.4 F-42 Table F-S change was performed.

For the other SAMAs, the description of the change in Section D.2.3 of the ER was included before the description of how the change was_______ _________analyzed.

Enclosure 1 to NRC-15-0 100 Page 23 CommentComn Nubr Section Page LineComn This paragraph does not accurately describe DTE' s method of determining avoided costs (i.e. benefit) for each SAMA. While PDR% and OECR% are presented for information in Table D.2-1 of the DTE ER, their values are the result of the SAMVA analysis and are not directly used in the calculation of SAMA benefits (note that OCR% is not presented in the ER). DTE actually recalculated the MMACR for each SAMA using the MMACR formula on line 23 of page F-47. The PRA was modified to represent implementation of each SAMA and then quantified to determine the new core damage frequency (CDF) and each release category T92 App. P.6.1 F-47 31 -37 frequency.

These results were then used to calculate WPH~A, WEA, Wo, WcD, and Wpy for each SAMA. The parameters are then summed and multiplied by EEM to obtain the SAMA's MMACR. A specific SAMA's benefit is then determined by subtracting the SAMA MMACR from the Baseline MIMACR (SAM\A Benefit =

-MMCtRSMvi).

The percentage reductions for PDR and OECR presented in Table D.2-1 of the ER are calculated based on the results of the SAMA analysis which was determined for each SAMA as described above, using the formula on line 23 of page F-47 of the draft SEIS. Note that the method described in the paragraph would provide equivalent results as the method DTE used.The draft SEIS refers to DTE performing a 3 percent discount rate sensitivity case T93 App. P.6.1 F-48 5per NUREGIBR-0058.

The DTE ER, Section D.1.5.4 refers to NUREG/BR-0I84 as being the source of the formulas and refers to it for the 3% sensitivity case.The SEIS states that the 3.14 x 10-9 per year unaccounted for release fraction is --2%T94 App. F.6.2 F-52 17 -20 of the total CDF. DTE believes the values should be '-0.2% (i.e. 3.14 x 10-9 divided Enclosure 1 to NRC-15-0100 Page 24 Cm etSection Page Line Comment Number For SAMA 24, column 3, the footnote "8" is used. However, there is no footnote 8 to the table. Based on context, it appears the correct footnote should be "h".T95 pp. .6.2 F-53 Tabl F-6 For SAIVA 67, columns 3 and 4, the footnote "12" is used. However, there is no footnote 12 to the table. Based on context, it appears the correct footnote should be Footnote e is incorrect.

The values displayed without parentheses represent the summation of the Adjusted Benefit Portion from Offsite and Base Case Benefit Portion from Onsite in Table 2-2 of an RAI response (DTE 2015c). The original T96 App. F.6.2 F-54 Table F-6 DTE ER base case total benefit in Table 3-3 was NOT added since the portion due to offsite is already included in the Adjusted Benefit Portion from Offsite and the base case portion from onsite is already being added. Also, Table 2-2 of DTE 2015c already included the previous RAI response's impact on SAMVA 78.T97 pp.F.62 F-5 TbleF-6 Footnote L refers to column 11 in parentheses.

There is no column 11 in the table.________ _________

__________________Based on context, it appears that it should be column 7.

Enclosure 1 to NRC-15-0 100 Page 25 Cm etSection Page Line Comment Number El Exeutivey xxiv 15 The phrase "Fermi 2 licenses expire" should be "Fermi 2 license ex'pires".

Abbrev. a'nd E2 Acronyms xxviii 6 The acrony'm for "Cross-State Air Pollution Rule" should be CSAPR.E3 Abbrevondm xxix 35 The acronym for "independent spent fuel storage installation" should be ISFSI.Abbrev. and E4 Acronyms xxxiii 6 The definition of the acronym PSDAR should include "report" at the end.Abbrev. and E5 Acronyms xxxiii 15 -16 The acronym and definition for RHIR should begin on a new line.Abbrev. and ..The definition of the acronym SESC is missing a closing parenthesis after E6Acronyms xxi 31Michigan.

E7Abbrev.

and xxi 3The acronym for U.S. Global Change Research Program should be USGCRP.Acronyms Also, the period is missing after the "S" in "U.S." E8 1.31-2 15The draft SEIS says that the NRC staff will host "public meetings".

Since only one___________public meeting is scheduled, it should say "a public meeting".A reference is provided in the text as "NIRC 20 14f". There is no reference "NRC 1.11 1-8 13 2014f' included in the list of references in Section 1.12. There is a reference "NRC E9 2014f' in Section 4.18 that could potentially be the correct reference based on the 1.12 1-9 N/A topic being discussed in the text. However, it would be helpful to include reference"¢NRC 2014f' in the list of references in Section 1.12.

Enclosure 1 to NRC-15-0 100 Page 26 Cm etSection Page LineCom t NumberComn 2.2.23 2-1 15A reference is provided in the text as '"NRC 2013a". In Section 2.5, reference NRC EI0 2013a is the GElS (NUREG-1437).

The topic being discussed in the text is the 2.5 229 5Fermi 3 COL FEIS (NUREG-21 05). Therefore, it appears that the correct reference__________should be to "NRC 2013c".Eli 23.1-1 A reference is provided in the text to "DTE 2014". The reference should be "DTE 2.5 225 312014b" for consistency with how the reference is listed in Section 2.5.E12 22-23 Tabl 2-2 For the Hun-an Health entry under Fermi 2 License Renewal (Proposed Action) in_________

_______Table 2-2, the word "SMALL" is spelled incorrectly.

Figure 3-3 has a label for the "'Spoils Disposal Pond". Neither the DTE ER nor the E13 3.1.1 3-4 Figulre 3-3 SEIS use this term. The term "Dredge Basin" is used instead. For consistency, the term "°Dredge Basin" is recommended.

The wording of the sentence starting with "Decanting pumps..." gives the impression that the shoreline discharge structure is the NPDES permit. The structure itself is not the permit, but rather is the primary discharge point authorized El14 3.1.3.2 3-9 34 -38 by the permit. DTE suggests a possible rewording of the sentence to say t..shoreline discharge structure, which under Fermi 2's primary National Pollutant Discharge Elimination System (NPDES) permit (No. MI0037028) (MDNR 2010)allows the plant...".

3.1.3.2 3-9 37 Multiple locations of text discussion of the NPDES permit M10037028 gives reference "MDNR 2010" as the source. There is no "MD.NR 2010" listed in the 3.5.1.3 3-146 43 references in Section 3.14. The reference should be "MDNR 2012" for each of thle El5 three instances listed (pages 3-9, 3-146, 3-147).3.5.1.3 3-147 Table 3-8 In addition, the permit number listed in reference MDNR 2012 in Section 3.14 3.14 3-170 9-12 should be "MI...".rather than "MI ...".

Enclosure 1 to NRC-15-01 00 Page 27 Cm etSection

]Page Line Comment Number E16 .1.43 3-5 19The text defines LLW as the acronym for low-level radioactive waste. This_______ _________acronym should be included in the list of acronyms.E17 31.5 318 9The word "of' should be deleted from the phrase "following list summarizes of the_______ _________types".

The discussion of Washtenaw County refers to the "1997 and 200 standard".

Per E18 3.3.2 3-34 8 the other usage in this section and the list of references, the "200 standard" should________ __________be "2006 standard".

El9 3.3.3 3-37 1 The reference to "HUJD 2014" is missing a closing parenthesis at the end.E20 3.5.1.1 3-44 4 The phrase "dredge spoil" should be "dredge spoils".E21 3.5.1.2 3-44 23 There appears to be a parenthesis missing on this line. The 72.2 million cubic meters per year has an opening parenthesis, but not a closing one.E22 3.5.2.1 3-51 Figure 3-13 The Figuxre 3-13 legend entry for the star says "Fermi 3". It should be "Fermi 2".E23 36.5. 3-6 4 -The reference "DeCO 2000" appears twice in the list; the second instance can be deleted.The draft SEIS text refers to "Section 4.15.4". However, the SEIS does not have a E24 36.5.2 3-69Section 4.15.4. It appears the correct reference should be to "Section 4.16.4".E25 37 3-4 21DTE recommends replacing "cooling lake" with "cooling water" or "blowdown".

___________The CWR is not typically referred to as a lake.E26 3.7.1.8 3-78 42 DTE recommends adding "program" after "NrpDES" for completeness.

The scientific name of the goldfish (given as carrasius auratus) appears to be spelled E27 3.7.3.1 3-93 42 incorrectly.

The correct name appears to be "carassius auratus" as shown on page________ _________________3-89 in Table 3-19.

Enclosure 1 to NRC-15-0100 Page 28 Cm etSection Page LineComn NumberComn The SEIS text says that of the 15 aquatic species, 8 are fish and 8 are mollusks.These numbers do not add up. Since there are only 7 mollusk species listed in Table E28 .7..3 -103 13 15 3-22 and discussed on subsequent pages, the text should be revised to state that of the 15 aquatic species, 8 are fish and 7 are mollusks.E29 3-1 1On page 3-113, the reference citation "AECOM 2009a" should be changed to 3.143-15 44"AECOM 2009" for consistency with how this reference is listed in Section 3.14.The SEIS text on page 3-129 indicates "NIPS 2015c" is the source reference for the discussion of the River Raisin Battlefield Site and "'.NPS 2015d" is the source 3.9.2 3-129 9 -10 reference for the discussion of National Historic Landmarks in Monroe County.E30 However, the references in Section 3.14 are in the opposite order (i.e. NIPS 2015c is 3.14 3-173 21 -25 the reference for the National Historic Landmarks and NIPS 2015d is the reference for the River Raisin Battlefield Site). The text should be corrected to match the order in the references section.The reference provided for the Michigan median household income is "USCB E31 3.10.2 3-133 5 2013a". There is no reference "USCB 2013a" in the list of references in Section 3.14. It appears that the correct reference should be "UJSCB 201I4a'.There is a closing parenthesis

")" missing after "(32 kin)". The parenthesis is E32 3.10.3 3-134 2 needed in order to close the parenthesis that started with "(greater than..." on the_________same line.E33 3.12.2 3-153 3 The plant name "FERMI 2" should not be in all capita/1 letters for consistency with the rest of the SEIS.E34 314 3-59 27The ADAMS ML number listed for reference Carman 2001f (ML1 12640087)________ _________

__________________appears to be incorrect.

The correct number appears to be MLI112640089.

Enclosure 1 to NRC-15-0100 Page 29 CommentComn Nubr Section Page LineComn The SEIS text wording appears to be missing a word (or words) compared to similar E35 4.1 4-1 11 statements in the SEIS. This line says ". ..are great that...".

Elsewhere such as in the abstract (page iii) or Section 5.3 (page 5-1) it says "...are not so great that.." E3 6 4.2..1 42 16The reference citation on page 4-2 should be changed from "2002" to "2002b" for______4.18 4-144 29 consistency with how it is designated in the Section 4.18 list of references.

4.3.3.1 4-7 26 The references to "Section 2.3.1" on pages 4-7 and 4-10 should be changed to E3 7 "Section 2.2.2.1" since the section currently referenced is about alternatives 4.3.3.2 4-10 8 dismissed rather than viable alternatives.

E38 4.3.3.1 4-8 Footnote 14 CO2eq should be CO2eq (i.e. subscript) for consistency with the rest of the text: E39 .3.41 4-2 28The phrase "about 269 mi of the Fermi site" should be "about 269 mifrom the Fermi sire".E40 4.3.5.1 4-15 24 The phrase "the estimates account of' should be "the estimates account for".E41 4.3.5.1 4-16 14 There appears to be an extraneous parenthesis after 25,000 MT.E42 4.3.5.2 4-17 2 The phrase "of a new a nuclear" seems to contain an extra word. Perhaps the__________second "a" should be deleted.The reference to "Section 2.3.4" should be changed to "Section 2.2.2.4" since the E43 4.3.6.2 4-19 26 section currently referenced is about alternatives dismissed rather than viable alternatives.

E44 4.3.6.2 4-19 34 The phrase "the noise environmental will" appears to be grammnatically incorrect.

Perhaps the word "environmental" should be "'environment".

The reference to "Section 4.3.3.1" should be changed to "Section 4.3.3.2" since E45 4.3.6.2 4-20 13 Section 4.3.3.1 is the air quality section while Section 4.3.3.2 is on noise and noise is the topic being discussed here.

Enclosure 1 to N~RC-15-0100 Page 30 CmetSection Page Line Comment Number E46 4.5.1.2 4-24 4 The phrase "As described Section" should be "As described in Section".E47 4.5.3.1 4-25 47 There appears to be an extraneous parenthesis after SETS.The phrase "about 33 percent less than those under the NGCC alternative" should be changed to "about 33 percent of those under the NGCC alternative".

An NGCC E48 4.5.6.1 4-29 1plant 1/3 the size will use 1/3 the amount of water, not 1/3 less water. The values for water use in the rest of the paragraph support that the use is 33% of the NGCC alternative.

The SETS text cross-reference for the climate change discussion is to Section E49 4.6.4 4-34 24 4.13.3.2.

There is no SETS Section 4.13.3.2.

The climate change discussion is actually found in Section 4.15.3.2.ESO .6.64-35 N/ASEIS page 4-35 was out of order in the PDF in ADAMS. It was placed between pages 4-39 and 4-40. It should be moved to between pages 4-34 and 4-36.E51 4.7.3 4-37 38 The conclusion mentions "IGCC" plant. It should be '"NGCC" plant in this section.The SETS text references Table 4-8, which is the table for Special Status Species E52 4.7.5 4-39 1and Habitat Issues. Since this discussion is regarding aquatic resources, the reference should be to Table 4-7, which is the table for Aquatic Resource Issues.SETS Table 4-9 lists two bird species under the heading "mammal".

This is E53 4.8.1.1 4-40 Table 4-9 different from SEIS Table 3-23 where birds and mammals are listed under separate__________headings.

E54 .8.11 44 20The scientific name for the Indiana bat given here (Sodalis myotis) is not consistent

_________________________

_________with the usage in Table 4-9 (Myotis sodalis).

Enclosure 1 to NRC-15-0 100 Page 31 CmetSection Page Line Comment Number 4.9.2 4-53 35 E55 4.12.2 4-78 45 Multiple places in the SEIS text refer to the Fermi 2 "operating licenses" plural. it should be singular in each case.4.13.2 4-82 30 E56 4.11.1.2 4-69 12 A comma is needed after "only".The SEIS Table 4-17 entry for nonradioactive waste storage refers to GEIS Section E57 4.13.1 4-82 Table 4-17 4.11.1.4.

This section number appears to be incorrect.

The correct GEIS section number appears to be 4.11.1.5.E58 4.14 4-86 6 The phrase "the most the most" should be "the most".E59 4.14 4-86 21 The phrase "washing up of beaches" should be "washing up on beaches".EGO 415.22 4-1 31The SEIS refers to Section 14 of the GEIS. It does not appear that this is the correct section number. The correct section number appears to be 4.12.2.2.The SEIS text refers to Table 4-21, which is a summary table. However, the E61 4.15.3.1 4-94 29 sentence is discussing how emissions will be similar to Fermi 2. Therefore, it_________appears that a reference to Table 4-20 may be intended.The SEIS gives the emissions as 1.3 million tons of CO2eq per year with E62 4.15.3.1 4-94 40 1.2 MT/year in parentheses.

The units in parentheses appear to be incorrect.

For consistency with other values in this section, the units should be million MT/year.E63 4.532 49 2The reference citation "Mackey et al. 2012" should be "Mackey 2012" for 4.18 4-141 37 consistency with how it is shown in the Section 4.18 list of references.

]Enclosure 1 to NRC-15-0 100 Page 32 Cm etSection Page Line Comment Number The sentence discussing increased water temperatures in Lake Erie is worded in a E64 4.15.3.2 4-1 01 38 -40 confusing manner. DTE recommends revising "the potential for adverse effects these organisms that can be a threat to human health" to "the potential adverse effects that these organisms can present to human health".E65 4.16 4-102 34 The phrase "current license terms" should be "current license term".E66 .16..1 404 4The SEIS text says "As discussed in section," but does not give a section number. It is not clear which section is being referenced.

E67 416.31 4-10 12The phrase "population growth and accompany land use changes" appears to be incorrect.

The word "accompany" should be "accompanying".

E68 .16. 4-16 3-33 The reference to "Table-I in Appendix B" should be "Table E-1 in Appendix E" as shown on line 6 of the page.29, 31 The reference citations to "EPA 2014e" on lines 29 and 31 and to "EPA 2014f' on E69 4.16.11 4-128 lines 38 and 39 should be changed to "EPA 2014g" and "EPA 2014h", respectively, 38, 39 as these references better correlate with the information being discussed.

In the Table 4-23 row for Monroe County, Michigan (201 1), "footnote (d)" should be "footnote (c)".E70 4.16.11 4-129 Table 4-23 In addition, in the row for Fermi 2 emissions, "footnote (4)" should be "footnote_____ _____(d)".

4-137 0 '13 The entire references of "EPA 2012a", "Sharp 2007", and "Solomon 2007" are E71 4.18 4-4 4-1, shown as hyperlinks.

Only the portion of the reference that is the website address 416 14 -18, should be shown in the hyperlink format.E72 4.18 4-144 10 The words "of Satellite" are repeated in the title of the reference.

Enclosure 1 to NRC- 15-0 100 Page 33 Cm etSection Page Line Comment Number E73 418 4-45 26The ADAMS MvL number listed for reference

"~NRC 2014f" (ML14279A562) appears to be incorrect.

The correct number appears to be MvL14295A239.

E74 7-2Tabl 7.1 The address for Dr. Stephen McNew should be "Raisinville Road" instead of_______ _________"Roisinville Road".E75 App. A A-i 18 There is a period after "Table A-i" that appears to be extraneous.

The word "Comment" is not included before 025-V-17, 012-BB-3, and 012-CC-2.E76 App. A A-8 16, 19, 23 Elsewhere in Appendix A the word "Comment" is included prior to the comment number. The word "Comment" should be added for consistency.

E77 App. A A124The phrase "Based its review..." should be "Based on its review..." on pages A-10______________

A-1 17and A-12.The SEIS text cites reference "DTE 2014a". In Section A.12 there is no reference E78 App. A A-31 17 DTE 2014a. There is a reference DTE 2014. The reference should be corrected for_________consistency with the list of references in Section A.12.The SEIS text says that Appendix D describes the ESA Section 7 consultation.

E79 App. A A-43 42 However, the ESA Section 7 consultation is in Appendix C rather than Appendix D.It should be corrected to say Appendix C.E80 Ap. A 44 28The ADAMS ML number for reference "DTE 2015a" (MVL15037A229) appears to be incorrect.

The correct ML number appears to be ML15009A358.

There are two entries in Table D-1 for the date May 5, 2014. The ML numbers in E81 pp. D-1Tabl D1 ADAMS do not match the numbers in Table D-l; the ML numbers for the two entries appear to be reversed.

The ML numbers should be switched between the two May 5, 2014 entries.E82 App. F F-3 Table F-i Change footnote designation

"©" to "(c)".E83 App. F.2.2.4 F-17 37 The phrase "license amendment was improved" should be "license amendment was approved".

Enclosure 1 to NRC-15-O0100 Page 34 CmetSection Page Line Comment Number The full title of the DECo 1996 letterwas "Submittal of the Detroit Edison E84 App. F.8 F-57 18 -20 Individual Plant Examination for External Events (IPEEE) Report -Response to Generic Letter 88-20, Supplement 4".The ADAMS ML number listed for reference DTE 2015a (ML1 5037A229) appears E85 App. F.8 F-57 42 to be incorrect.

The correct number appears to be MV1L15009A358 (see SETS page D-3).E86 App. F.8 F-58 20 In the title of NET 05-0 1, "Alternative" should be "Alternatives".

E87 App. F.8 F-60 9 The letter was dated November 18, 2014 (see SETS page D-3).

~U --> ._ Vito A. Kanlirnskas Site Vice Pr'esident(DTE Eniergy Comlpany 6400 N. Dixie Highway, Newport, M'H 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kanhiInsLasv'cadtceIergy~coI1

' *' --- -- '-/L-L -DTIEEnergy' 10 CFR 54 NRC-2014-0 109 December 15, 2015 NRC-15-0 100 Chief, Rules, Announcements, and Directives Branch (RADB) l / Division of Administrative Services, ADM,,-Mailstop:

OWFN- 12-HO08 U. S. Nuclear Regulatory Commission Washington D C 20555-0001

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