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NUREG-1437, Supplement 56, Volume 2, Fermi, Unit 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants.
	ML16259A109
Person / Time
Site:	Fermi
Issue date:	09/30/2016
From:	Keegan E; NRC/NRR/DLR/RERP
To:	;
	Meyd, Donald
References
	NUREG-1437 S56 V02
	Download: ML16259A109 (725)
	v • d • e

NUREG-1437 Supplement 56 Volume 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 56 Regarding Fermi 2 Nuclear Power Plant Final Report Appendices Office of Nuclear Reactor Regulation

NUREG-1437 Supplement 56 Volume 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 56 Regarding Fermi Nuclear Power Plant Final Report Appendices Manuscript Completed: August 2016 Date Published: September 2016 Office of Nuclear Reactor Regulation

COVER SHEET Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation. There are no cooperating agencies involved in the preparation of this document.

Title: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 56, Regarding Fermi 2 Nuclear Power Plant (NUREG-1437). Fermi 2 is located in Frenchtown Township, Michigan.

For additional information or copies of this document contact:

Division of License Renewal U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop O-11F1 11555 Rockville Pike Rockville, Maryland 20852 Phone: 1-800-368-5642, extension 8517 Fax: 301-415-2002 Email: elaine.keegan@nrc.gov ABSTRACT This supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by DTE Electric Company (DTE), to renew the operating license for the Fermi 2 Nuclear Power Plant for an additional 20 years.

This SEIS includes analyses that evaluate the environmental impacts of the proposed action and the alternatives to the proposed action. Alternatives considered include: (1) natural gas combined-cycle (NGCC), (2) coal-integrated gasification combined-cycle (IGCC), (3) new nuclear power generation, (4) a combination of NGCC, wind, and solar generation, and (5) the no-action alternative (i.e., no renewal of the license).

The U.S. Nuclear Regulatory Commission (NRC) staffs recommendation is that the adverse environmental impacts of license renewal for Fermi 2 are not so great that preserving the option of license renewal for energy-planning decisionmakers would be unreasonable. The NRC staff based its recommendation on the following factors:

the analysis and findings in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Volumes 1 and 2;

the Environmental Report submitted by DTE;

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

the NRC staffs independent environmental review; and

consideration of public comments received during the scoping process and received on the draft SEIS.

iii

TABLE OF CONTENTS ABSTRACT .............................................................................................................................. iii TABLE OF CONTENTS ............................................................................................................ v FIGURES ................................................................................................................................. xv TABLES ................................................................................................................................ xvii EXECUTIVE

SUMMARY

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

1.0 INTRODUCTION

......................................................................................................... 1-1 1.1 Proposed Federal Action.................................................................................. 1-1 1.2 Purpose and Need for Proposed Federal Action .............................................. 1-1 1.3 Major Environmental Review Milestones .......................................................... 1-1 1.4 Generic Environmental Impact Statement ........................................................ 1-3 1.5 Supplemental Environmental Impact Statement ............................................... 1-5 1.6 Decisions To Be Supported by the SEIS .......................................................... 1-6 1.7 Cooperating Agencies ...................................................................................... 1-6 1.8 Consultations ................................................................................................... 1-6 1.9 Correspondence .............................................................................................. 1-7 1.10 Status of Compliance ....................................................................................... 1-7 1.11 Related State and Federal Activities ................................................................ 1-7 1.12 References ...................................................................................................... 1-8 2.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION ......................................... 2-1 2.1 Proposed Action .............................................................................................. 2-1 2.1.1 Plant Operations during the License Renewal Term .......................... 2-1 2.1.2 Refurbishment and Other Activities Associated with License Renewal ............................................................................................ 2-2 2.1.3 Termination of Nuclear Power Plant Operations and Decommissioning after the License Renewal Term ........................... 2-2 2.2 Alternatives ...................................................................................................... 2-3 2.2.1 No-Action Alternative ......................................................................... 2-3 2.2.2 Replacement Power Alternatives ....................................................... 2-3 2.2.2.1 NGCC Alternative ............................................................. 2-8 2.2.2.2 IGCC Alternative .............................................................. 2-8 2.2.2.3 New Nuclear Power Alternative ...................................... 2-10 2.2.2.4 Combination Alternative (NGCC, Wind, and Solar) ........ 2-11 2.3 Alternatives Considered but Dismissed .......................................................... 2-14 2.3.1 Energy Conservation and Energy Efficiency .................................... 2-14 2.3.2 Solar ................................................................................................ 2-15 2.3.3 Wind ................................................................................................ 2-15 v

Table of Contents 2.3.3.1 Offshore Wind ................................................................ 2-16 2.3.3.2 Wind Power with Storage ............................................... 2-16 2.3.3.3 Conclusion ..................................................................... 2-16 2.3.4 Biomass .......................................................................................... 2-17 2.3.5 Hydroelectric ................................................................................... 2-17 2.3.6 Wave and Ocean Energy................................................................. 2-18 2.3.7 Fuel Cells ........................................................................................ 2-18 2.3.8 Delayed Retirement ......................................................................... 2-19 2.3.9 Geothermal...................................................................................... 2-19 2.3.10 Municipal Solid Waste ..................................................................... 2-19 2.3.11 Petroleum-Fired Power .................................................................... 2-20 2.3.12 Supercritical Pulverized Coal ........................................................... 2-20 2.3.13 Purchased Power ............................................................................ 2-21 2.4 Comparison of Alternatives ............................................................................ 2-21 2.5 References .................................................................................................... 2-24 3.0 AFFECTED ENVIRONMENT ...................................................................................... 3-1 3.1 Description of Nuclear Power Plant Facility and Operation .............................. 3-1 3.1.1 External Appearance and Setting ...................................................... 3-1 3.1.2 Nuclear Reactor Systems .................................................................. 3-5 3.1.3 Cooling and Auxiliary Water Systems ................................................ 3-5 3.1.3.1 General Service Water and Intake System ....................... 3-6 3.1.3.2 Circulating Water System and Blowdown Discharge ........ 3-9 3.1.3.3 Residual Heat Removal Complex ................................... 3-10 3.1.3.4 Potable Water System.................................................... 3-10 3.1.3.5 Fire Protection Water System......................................... 3-10 3.1.4 Radioactive Waste Management Systems ...................................... 3-11 3.1.4.1 Radioactive Liquid Waste Management ......................... 3-11 3.1.4.2 Radioactive Gaseous Waste Management..................... 3-14 3.1.4.3 Radioactive Solid Waste Management ........................... 3-15 3.1.4.4 Radioactive Waste Storage ............................................ 3-16 3.1.4.5 Radiological Environmental Monitoring Program ............ 3-17 3.1.5 Nonradioactive Waste Management Systems ................................. 3-18 3.1.6 Utility and Transportation Infrastructure ........................................... 3-19 3.1.6.1 Electricity........................................................................ 3-19 3.1.6.2 Fuel ................................................................................ 3-19 3.1.6.3 Water ............................................................................. 3-20 3.1.6.4 Transportation Systems ................................................. 3-20 3.1.6.5 Power Transmission Systems ........................................ 3-20 3.1.7 Nuclear Power Plant Operations and Maintenance.......................... 3-23 3.2 Land Use and Visual Resources .................................................................... 3-23 3.2.1 Land Use ......................................................................................... 3-23 vi

Table of Contents 3.2.1.1 Onsite Land Use ............................................................ 3-23 3.2.1.2 Offsite Land Use ............................................................ 3-28 3.2.1.3 Land Use Planning ......................................................... 3-31 3.2.2 Visual Resources............................................................................. 3-31 3.3 Meteorology, Air Quality, and Noise ............................................................... 3-32 3.3.1 Meteorology and Climatology .......................................................... 3-32 3.3.2 Air Quality ........................................................................................ 3-33 3.3.3 Noise ............................................................................................... 3-35 3.4 Geologic Environment .................................................................................... 3-37 3.4.1 Physiography and Geology.............................................................. 3-37 3.4.2 Soils ................................................................................................ 3-40 3.4.3 Seismic Setting ................................................................................ 3-40 3.5 Water Resources ........................................................................................... 3-40 3.5.1 Surface Water Resources................................................................ 3-40 3.5.1.1 Surface Water Hydrology ............................................... 3-40 3.5.1.2 Surface Water Use ......................................................... 3-44 3.5.1.3 Surface Water Quality and Effluents............................... 3-45 3.5.2 Groundwater Resources .................................................................. 3-49 3.5.2.1 Site Description and Hydrogeology ................................ 3-49 3.5.2.2 Groundwater Use ........................................................... 3-52 3.5.2.3 Groundwater Quality ...................................................... 3-54 3.6 Terrestrial Resources ..................................................................................... 3-55 3.6.1 Fermi 2 Ecoregion ........................................................................... 3-55 3.6.2 Fermi Site Surveys, Studies, and Reports ....................................... 3-55 3.6.3 Fermi Site ........................................................................................ 3-57 3.6.3.1 Vegetation ...................................................................... 3-58 3.6.3.2 Animals .......................................................................... 3-61 3.6.4 Fermi 2 Wildlife Management Plan .................................................. 3-65 3.6.5 Important Species and Habitats ....................................................... 3-65 3.6.5.1 Important Species .......................................................... 3-65 3.6.5.2 Important Habitats .......................................................... 3-68 3.6.6 Bird Collisions and Strikes ............................................................... 3-72 3.7 Aquatic Resources ......................................................................................... 3-74 3.7.1 Aquatic ResourcesSite and Vicinity .............................................. 3-75 3.7.1.1 Circulating Water Reservoir (Cooling Water Pond and Circulation Pond) ..................................................... 3-75 3.7.1.2 Overflow and Discharge Canals ..................................... 3-75 3.7.1.3 Drainage Ditches............................................................ 3-76 3.7.1.4 Quarry Lakes ................................................................. 3-76 3.7.1.5 Wetland Ponds and Marshes Managed as Part of the DRIWR ..................................................................... 3-76 vii

Table of Contents 3.7.1.6 Swan Creek ................................................................... 3-76 3.7.1.7 Stony Creek ................................................................... 3-77 3.7.1.8 Lake Erie ........................................................................ 3-78 3.7.2 Aquatic HabitatsTransmission Lines ............................................ 3-88 3.7.3 Important Aquatic Species and HabitatsSite and Vicinity ............. 3-88 3.7.3.1 Commercially Important Species .................................... 3-89 3.7.3.2 Recreationally Important Species ................................. 3-100 3.7.3.3 State-Listed Aquatic Species........................................ 3-103 3.7.3.4 Non-Native Nuisance Species ...................................... 3-112 3.7.4 Aquatic Species and Habitats in the Transmission Line Corridor ... 3-116 3.7.5 Aquatic Monitoring ......................................................................... 3-116 3.8 Special Status Species and Habitats............................................................ 3-116 3.8.1 Species and Habitats Protected under the Endangered Species Act ................................................................................................. 3-116 3.8.1.1 Action Area .................................................................. 3-116 3.8.1.2 Species and Habitats under the FWSs Jurisdiction ..... 3-117 3.8.1.3 Species and Habitats under the NMFSs Jurisdiction ... 3-126 3.8.2 Species and Habitats Protected under the Magnuson-Stevens Act ................................................................................................. 3-126 3.9 Historic and Cultural Resources ................................................................... 3-127 3.9.1 Cultural Background ...................................................................... 3-127 3.9.2 Historic and Cultural Resources .................................................... 3-129 3.10 Socioeconomics ........................................................................................... 3-131 3.10.1 Power Plant Employment and Expenditures .................................. 3-131 3.10.2 Regional Economic Characteristics ............................................... 3-132 3.10.2.1 Employment and Income.............................................. 3-132 3.10.2.2 Unemployment ............................................................. 3-134 3.10.3 Demographic Characteristics ......................................................... 3-134 3.10.3.1 Transient Population .................................................... 3-137 3.10.3.2 Migrant Farm Workers.................................................. 3-138 3.10.4 Housing and Community Services ................................................. 3-139 3.10.4.1 Housing ........................................................................ 3-139 3.10.4.2 Education ..................................................................... 3-140 3.10.4.3 Public Water Supply ..................................................... 3-140 3.10.5 Tax Revenues ............................................................................... 3-142 3.10.6 Local Transportation ...................................................................... 3-145 3.11 Human Health .............................................................................................. 3-146 3.11.1 Radiological Exposure and Risk .................................................... 3-146 3.11.2 Chemical Hazards ......................................................................... 3-147 3.11.3 Microbiological Hazards................................................................. 3-148 3.11.3.1 Background Information on Microorganisms of Concern ....................................................................... 3-148 viii

Table of Contents 3.11.3.2 Studies of Microorganisms in Cooling Towers .............. 3-149 3.11.3.3 Microbiological Hazards to Plant Workers .................... 3-149 3.11.3.4 Microbiological Hazards to the Public ........................... 3-149 3.11.4 Electromagnetic Fields .................................................................. 3-150 3.11.5 Other Hazards ............................................................................... 3-151 3.12 Environmental Justice .................................................................................. 3-151 3.12.1 Minority Population ........................................................................ 3-152 3.12.2 Low-Income Population ................................................................. 3-155 3.13 Waste Management and Pollution Prevention.............................................. 3-157 3.13.1 Radioactive Waste......................................................................... 3-157 3.13.2 Nonradioactive Waste ................................................................... 3-157 3.14 References .................................................................................................. 3-157 4.0 ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS ....................... 4-1 4.1 Introduction ...................................................................................................... 4-1 4.2 Land Use and Visual Resources ...................................................................... 4-1 4.2.1 Proposed Action ................................................................................ 4-1 4.2.2 No-Action Alternative ......................................................................... 4-2 4.2.2.1 Land Use.......................................................................... 4-2 4.2.2.2 Visual Resources ............................................................. 4-2 4.2.3 Natural Gas Combined-Cycle Alternative .......................................... 4-3 4.2.3.1 Land Use.......................................................................... 4-3 4.2.3.2 Visual Resources ............................................................. 4-3 4.2.4 Integrated Gasification Combined-Cycle Alternative .......................... 4-3 4.2.4.1 Land Use.......................................................................... 4-3 4.2.4.2 Visual Resources ............................................................. 4-4 4.2.5 New Nuclear Alternative .................................................................... 4-4 4.2.5.1 Land Use.......................................................................... 4-4 4.2.5.2 Visual Resources ............................................................. 4-5 4.2.6 Combination Alternative (NGCC, Wind, and Solar) ............................ 4-5 4.2.6.1 Land Use.......................................................................... 4-5 4.2.6.2 Visual Resources ............................................................. 4-5 4.3 Air Quality and Noise ....................................................................................... 4-6 4.3.1 Proposed Action ................................................................................ 4-6 4.3.1.1 Air Quality ........................................................................ 4-6 4.3.1.2 Noise ................................................................................ 4-6 4.3.2 No-Action Alternative ......................................................................... 4-7 4.3.2.1 Air Quality ........................................................................ 4-7 4.3.2.2 Noise ................................................................................ 4-7 4.3.3 NGCC Alternative .............................................................................. 4-7 4.3.3.1 Air Quality ........................................................................ 4-7 4.3.3.2 Noise .............................................................................. 4-10 ix

Table of Contents 4.3.4 IGCC Alternative ............................................................................. 4-11 4.3.4.1 Air Quality ...................................................................... 4-11 4.3.4.2 Noise .............................................................................. 4-13 4.3.5 New Nuclear Alternative .................................................................. 4-14 4.3.5.1 Air Quality ...................................................................... 4-14 4.3.5.2 Noise .............................................................................. 4-16 4.3.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-17 4.3.6.1 Air Quality ...................................................................... 4-17 4.3.6.2 Noise .............................................................................. 4-19 4.4 Geologic Environment .................................................................................... 4-21 4.4.1 Proposed Action .............................................................................. 4-21 4.4.2 No-Action Alternative ....................................................................... 4-21 4.4.3 NGCC Alternative ............................................................................ 4-21 4.4.4 IGCC Alternative ............................................................................. 4-22 4.4.5 New Nuclear Alternative .................................................................. 4-22 4.4.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-22 4.5 Water Resources ........................................................................................... 4-22 4.5.1 Proposed Action .............................................................................. 4-22 4.5.1.1 Surface Water Resources .............................................. 4-22 4.5.1.2 Groundwater Resources ................................................ 4-23 4.5.2 No-Action Alternative ....................................................................... 4-24 4.5.2.1 Surface Water Resources .............................................. 4-24 4.5.2.2 Groundwater Resources ................................................ 4-24 4.5.3 NGCC Alternative ............................................................................ 4-24 4.5.3.1 Surface Water Resources .............................................. 4-24 4.5.3.2 Groundwater Resources ................................................ 4-26 4.5.4 IGCC Alternative ............................................................................. 4-26 4.5.4.1 Surface Water Resources .............................................. 4-26 4.5.4.2 Groundwater Resources ................................................ 4-27 4.5.5 New Nuclear Alternative .................................................................. 4-27 4.5.5.1 Surface Water Resources .............................................. 4-27 4.5.5.2 Groundwater Resources ................................................ 4-28 4.5.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-29 4.5.6.1 Surface Water Resources .............................................. 4-29 4.5.6.2 Groundwater Resources ................................................ 4-30 4.6 Terrestrial Resources ..................................................................................... 4-30 4.6.1 Proposed Action .............................................................................. 4-30 4.6.1.1 Generic Terrestrial Resource Issues .............................. 4-30 4.6.1.2 Effects on Terrestrial Resources (Noncooling System Impacts) ............................................................ 4-31 4.6.2 No-Action Alternative ....................................................................... 4-32 x

Table of Contents 4.6.3 NGCC Alternative ............................................................................ 4-33 4.6.4 IGCC Alternative ............................................................................. 4-34 4.6.5 New Nuclear Alternative .................................................................. 4-34 4.6.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-35 4.7 Aquatic Resources ......................................................................................... 4-36 4.7.1 Proposed Action .............................................................................. 4-36 4.7.1.1 Generic GEIS Issues ...................................................... 4-36 4.7.2 No-Action Alternative ....................................................................... 4-37 4.7.3 NGCC Alternative ............................................................................ 4-37 4.7.4 IGCC Alternative ............................................................................. 4-38 4.7.5 New Nuclear Alternative .................................................................. 4-38 4.7.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-39 4.8 Special Status Species and Habitats.............................................................. 4-39 4.8.1 Proposed Action .............................................................................. 4-39 4.8.1.1 Species and Habitats Protected under the Endangered Species Act of 1973 ................................... 4-40 4.8.1.2 Species and Habitats Protected under the Magnuson-Stevens Act of 2006..................................... 4-49 4.8.2 No-Action Alternative ....................................................................... 4-49 4.8.3 NGCC Alternative ............................................................................ 4-50 4.8.4 IGCC Alternative ............................................................................. 4-50 4.8.5 New Nuclear Alternative .................................................................. 4-51 4.8.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-51 4.9 Historic and Cultural Resources ..................................................................... 4-52 4.9.1 Proposed Action .............................................................................. 4-52 4.9.2 No-Action Alternative ....................................................................... 4-54 4.9.3 NGCC Alternative ............................................................................ 4-54 4.9.4 IGCC Alternative ............................................................................. 4-55 4.9.5 New Nuclear Alternative .................................................................. 4-55 4.9.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-56 4.10 Socioeconomics ............................................................................................. 4-57 4.10.1 Proposed Action .............................................................................. 4-57 4.10.2 No-Action Alternative ....................................................................... 4-58 4.10.2.1 Socioeconomics ............................................................. 4-58 4.10.2.2 Transportation ................................................................ 4-58 4.10.3 NGCC Alternative ............................................................................ 4-58 4.10.3.1 Socioeconomics ............................................................. 4-58 4.10.3.2 Transportation ................................................................ 4-59 4.10.4 IGCC Alternative ............................................................................. 4-60 4.10.4.1 Socioeconomics ............................................................. 4-60 4.10.4.2 Transportation ................................................................ 4-60 xi

Table of Contents 4.10.5 New Nuclear Alternative .................................................................. 4-61 4.10.5.1 Socioeconomics ............................................................. 4-61 4.10.5.2 Transportation ................................................................ 4-62 4.10.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-62 4.10.6.1 Socioeconomics ............................................................. 4-62 4.10.6.2 Transportation ................................................................ 4-63 4.11 Human Health ................................................................................................ 4-63 4.11.1 Proposed Action .............................................................................. 4-63 4.11.1.1 Normal Operating Conditions ......................................... 4-64 4.11.1.2 Environmental Impacts of Postulated Accidents ............. 4-65 4.11.2 No-Action Alternative ....................................................................... 4-75 4.11.3 NGCC Alternative ............................................................................ 4-75 4.11.4 IGCC Alternative ............................................................................. 4-75 4.11.5 New Nuclear Alternative .................................................................. 4-76 4.11.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-76 4.12 Environmental Justice .................................................................................... 4-77 4.12.1 Proposed Action .............................................................................. 4-77 4.12.2 No-Action Alternative ....................................................................... 4-79 4.12.3 NGCC Alternative ............................................................................ 4-80 4.12.4 IGCC Alternative ............................................................................. 4-80 4.12.5 New Nuclear Alternative .................................................................. 4-81 4.12.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-82 4.13 Waste Management and Pollution Prevention................................................ 4-82 4.13.1 Proposed Action .............................................................................. 4-83 4.13.2 No-Action Alternative ....................................................................... 4-83 4.13.3 NGCC Alternative ............................................................................ 4-84 4.13.4 IGCC Alternative ............................................................................. 4-84 4.13.5 New Nuclear Alternative .................................................................. 4-84 4.13.6 Combination Alternative (NGCC, Wind, and Solar) .......................... 4-85 4.14 Evaluation of New and Potentially Significant Information .............................. 4-85 4.15 Impacts Common to All Alternatives............................................................... 4-90 4.15.1 Fuel Cycle ....................................................................................... 4-90 4.15.1.1 Uranium Fuel Cycle ........................................................ 4-90 4.15.1.2 Replacement Power Plant Fuel Cycles .......................... 4-91 4.15.2 Terminating Power Plant Operations and Decommissioning ........... 4-92 4.15.2.1 Existing Nuclear Power Plant ......................................... 4-92 4.15.2.2 Replacement Power Plants ............................................ 4-92 4.15.3 Greenhouse Gas Emissions and Climate Change ........................... 4-93 4.15.3.1 Greenhouse Gas Emissions from the Proposed Project and Alternatives ................................................. 4-93 4.15.3.2 Climate Change Impacts to Resource Areas .................. 4-96 xii

Table of Contents 4.16 Cumulative Impacts of the Proposed Action ................................................. 4-103 4.16.1 Air Quality and Noise ..................................................................... 4-104 4.16.1.1 Air Quality .................................................................... 4-104 4.16.1.2 Noise ............................................................................ 4-106 4.16.2 Geology and Soils ......................................................................... 4-106 4.16.3 Water Resources ........................................................................... 4-107 4.16.3.1 Surface Water Resources ............................................ 4-107 4.16.3.2 Groundwater Resources .............................................. 4-114 4.16.4 Terrestrial Resources .................................................................... 4-115 4.16.4.1 Conclusion ................................................................... 4-118 4.16.5 Aquatic Resources ........................................................................ 4-118 4.16.6 Historic and Cultural Resources .................................................... 4-124 4.16.7 Socioeconomics ............................................................................ 4-125 4.16.7.1 Conclusion ................................................................... 4-126 4.16.8 Human Health ............................................................................... 4-126 4.16.9 Environmental Justice ................................................................... 4-127 4.16.9.1 Conclusion ................................................................... 4-128 4.16.10 Waste Management and Pollution Prevention ............................... 4-129 4.16.11 Global Climate Change ................................................................. 4-129 4.16.12 Summary of Cumulative Impacts ................................................... 4-131 4.17 Resource Commitments Associated with the Proposed Action .................... 4-133 4.17.1 Unavoidable Adverse Environmental Impacts................................ 4-133 4.17.2 Relationship between Short-Term Use of the Environment and Long-Term Productivity ................................................................. 4-134 4.17.3 Irreversible and Irretrievable Commitment of Resources ............... 4-134 4.18 References .................................................................................................. 4-135

5.0 CONCLUSION

............................................................................................................ 5-1 5.1 Environmental Impacts of License Renewal ..................................................... 5-1 5.2 Comparison of Alternatives .............................................................................. 5-1 5.3 Recommendations ........................................................................................... 5-1 6.0 LIST OF PREPARERS ............................................................................................... 6-1 7.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS SEIS ARE SENT .......................................................................................... 7-1 8.0 INDEX ......................................................................................................................... 8-1 APPENDIX A COMMENTS RECEIVED ON THE FERMI 2 ENVIRONMENTAL REVIEW........................................................................................................ A-1 APPENDIX B APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS ......................................................................................... B-1 APPENDIX C CONSULTATION CORRESPONDENCE ..................................................... C-1 xiii

Table of Contents APPENDIX D CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE .................................................................................. D-1 APPENDIX E ACTIONS AND PROJECTS CONSIDERED IN CUMULATIVE ANALYSIS .................................................................................................... E-1 APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR FERMI UNIT 2 NUCLEAR STATION, IN SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW ............................................................................... F-1 xiv

FIGURES Figure 1-1. Environmental Review Process........................................................................ 1-2 Figure 1-2. Environmental Issues Evaluated for License Renewal ..................................... 1-5 Figure 3-1. Fermi 2 50-mi (80-km) Radius Map .................................................................. 3-2 Figure 3-2. Fermi 2 6-mi (10-km) Radius Map .................................................................... 3-3 Figure 3-3. Fermi 2 Site Boundary ..................................................................................... 3-4 Figure 3-4. Closed-Cycle Cooling System with Natural Draft Cooling Tower ...................... 3-6 Figure 3-5. Fermi 2 Cooling Water Supply Facilities and Major Surface Water Features .......................................................................................................... 3-8 Figure 3-6. Fermi 2 In-Scope Transmission Lines ............................................................ 3-22 Figure 3-7. Fermi Site Land Uses .................................................................................... 3-25 Figure 3-8. Detroit River International Wildlife Refuge, Lagoona Beach Unit Boundaries on the Fermi Site ......................................................................... 3-27 Figure 3-9. Land Use and Land Cover within a 6-mi (10-km) Radius of the Fermi Site ................................................................................................................ 3-30 Figure 3-10. Topographic Map and Site Boundary ............................................................. 3-38 Figure 3-11. Fermi Site Geologic Column .......................................................................... 3-39 Figure 3-12. Surface Water Features at the Fermi Site and Vicinity ................................... 3-42 Figure 3-13. Bed Rock Water Levels and Lateral Groundwater Flow Directions ................ 3-51 Figure 3-14. Wells within 2 mi (3 km) of Fermi ................................................................... 3-53 Figure 3-15. Delineated Wetlands on the Fermi Site .......................................................... 3-71 Figure 3-16. Estimated Abundance of Walleye Aged 2 and Older in Lake Erie, 1980-2010 (Lake Erie Walleye Task Group 2010) ......................................... 3-96 Figure 3-17. Estimated Abundance of Yellow Perch Aged 2 and Older in the Western Basin of Lake Erie, 1975-2010 (Lake Erie Yellow Perch Task Group 2010) ............................................................................................................. 3-99 Figure 3-18. 2010 U.S. Census Minority Block Groups within a 50-mi (80-km) Radius of Fermi 2 .................................................................................................... 3-154 Figure 3-19. U.S. Census Low-Income Block Groups within a 50-mi (80-km) Radius of Fermi 2 .................................................................................................... 3-156 xv

TABLES Table ES-1. Summary of NRC Conclusions Relating to Site-Specific Impacts of License Renewal............................................................................................. xxiii Summary of Replacement Power Alternatives and Key Characteristics Considered In Depth ........................................................................................ 2-6 Summary of Environmental Impacts of the Proposed Action and Alternatives .................................................................................................... 2-22 Fermi 2 Nonnuclear Fuel Storage Units ......................................................... 3-19 Fermi Site Land Uses by Area ....................................................................... 3-23 Monroe County Land Use, 2008 .................................................................... 3-29 Monroe County Land Cover, 2010 ................................................................. 3-29 Air Emission Estimates for Permitted Combustion Sources at Fermi 2........... 3-35 Common Noise Sources and Noise Levels .................................................... 3-36 Annual Surface Water Withdrawals and Return Discharges to Lake Erie, Fermi 2 .......................................................................................................... 3-44 NPDES-Permitted Outfalls, Fermi 2 ............................................................... 3-47 Vegetative Cover Types and Dominant Species on the Fermi Site by Area ............................................................................................................... 3-58 Mammals Observed on the Fermi Site, 2008-2009 ....................................... 3-63 Reptiles and Amphibians Observed on the Fermi Site, 2008-2009 ................ 3-64 Rare Species with Known Occurrences within 1.5 mi (2.4 km) of the Fermi Site ...................................................................................................... 3-65 Delineated Wetlands on the Fermi Site by Area ............................................. 3-70 Bird Strike Occurrences, 2005-2014.............................................................. 3-73 Bird Strike Monitoring Data, 2008-2009......................................................... 3-73 Percent Abundance of Fish Species Collected in Lake Erie near the Fermi Site during 2008 and 2009 ................................................................... 3-83 Estimated Numbers of Fish Eggs and Larvae Entrained by the Fermi 2 Cooling Water Intake from July 2008-July 2009 ............................................ 3-85 Estimated Numbers of Fish Impinged by the Fermi 2 Cooling Water Intake from August 2008-July 2009 ............................................................... 3-87 Important Aquatic Species That Have Been Observed in the Vicinity of the Fermi Site ................................................................................................ 3-88 Commercial Fishery Statistics for Michigan from Lake Erie during 2010 ........ 3-90 Commercial Fishery Statistics for Ohio from Lake Erie during 2010 ............... 3-91 Exclusively State-Listed Aquatic Species That Have Been Observed in Monroe County and Their Potential To Occur on the Fermi Site .................. 3-103 Federally Listed Species in Monroe County, Michigan ................................. 3-117 Cultural Resources Located within the Fermi Site ........................................ 3-130 Fermi 2 Employees Residence by County/Province ..................................... 3-132 Employment by Industry in the Fermi 2 ROI (2013 Estimates) ..................... 3-133 Major Employers in Monroe County in 2013................................................. 3-133 xvii

Tables Estimated Income Information for the Fermi 2 ROI (2013 Estimates) ........... 3-134 Population and Percent Growth in Fermi 2 ROI Counties, 1970-2010, 2013 (Estimated), and Projected for 2020-2060 .......................................... 3-135 Demographic Profile of the Population in the Fermi 2 ROI in 2010 ............... 3-135 Demographic Profile of the Population in the Fermi 2 ROI in 2013 ............... 3-136 2013 Estimated Seasonal Housing in Counties Located within 50 mi (80 km) of Fermi 2........................................................................................ 3-137 Migrant Farm Workers and Temporary Farm Labor in Counties Located within 50 mi (80 km) of Fermi 2 (2012) ......................................................... 3-138 Housing in the Fermi 2 ROI (2013 estimate) ................................................ 3-139 Local Public Water Supply Systems ............................................................. 3-140 Fermi 2 Property Tax Distribution 2009-2013 (in Dollars) ............................ 3-142 Property Taxes Paid for Fermi 2 by Millage Type, 2013 Tax Year................ 3-142 2013 Frenchtown Charter Township Millage Totals by District ..................... 3-144 2013 Fermi 2 Property Tax Distribution in Millage ........................................ 3-144 2013 Fermi 2 Property Tax Distribution as a Percentage of Total Property Taxes Collected by Frenchtown Township ..................................... 3-145 Major Commuting Routes in the Vicinity of Fermi 2: 2013 Average Annual Daily Traffic Count ........................................................................... 3-146 Land Use and Visual Resource Issues............................................................. 4-2 Air Quality and Noise ....................................................................................... 4-6 Geology and Soils Issues............................................................................... 4-21 Surface Water Resources Issues ................................................................... 4-22 Groundwater Issues ....................................................................................... 4-23 Terrestrial Resource Issues ........................................................................... 4-30 Aquatic Resource Issues ............................................................................... 4-36 Special Status Species and Habitat Issues .................................................... 4-40 Effect Determinations for Federally Listed Species ........................................ 4-41 Historic and Cultural Resources ..................................................................... 4-52 Socioeconomic NEPA Issues ......................................................................... 4-57 Human Health Issues ..................................................................................... 4-63 Issues Related to Postulated Accidents ......................................................... 4-65 Potentially Cost-Beneficial SAMAs for Fermi Unit 2 ....................................... 4-71 Estimated Cost Ranges of SAMA Implementation Costs at Fermi Unit 2 ....... 4-73 Environmental Justice NEPA Issue ................................................................ 4-77 Waste Management Issues ............................................................................ 4-83 Issues Related to the Uranium Fuel Cycle ..................................................... 4-90 Issues Related to Decommissioning .............................................................. 4-92 Estimated GHG Emissions from Operations at Fermi 2.................................. 4-94 Direct GHG Emissions from Operation of the Proposed Action and Alternatives .................................................................................................... 4-96 xviii

Tables Cumulative Surface Water Withdrawals from the Michigan Portion of the Lake Erie Watershed by Water Use Sector (2013) ....................................... 4-108 Comparison of GHG Emission Inventories ................................................... 4-131 Summary of Cumulative Impacts on Resource Areas .................................. 4-131 List of Preparers .............................................................................................. 6-1 List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent.................................................................................................. 7-1 Table A-1. Individuals Providing Comments during the Scoping Comment Period ............ A-2 Table A-2. Issue Categories .............................................................................................. A-5 Table A-3. Commenters on the Draft Supplemental Environmental Impact Statement .................................................................................................... A-312 Table A-4. Issue Categories .......................................................................................... A-315 Table B-1. Federal and State Requirements ..................................................................... B-2 Table B-2. Licenses and Permits ....................................................................................... B-6 Table C-1. ESA Section 7 Consultation Correspondence ..................................................C-3 Table C-2. NHPA Correspondence....................................................................................C-4 Table D-1. Environmental Review Correspondence ..........................................................D-1 Table E-1. Actions and Projects Considered in Cumulative Analysis ................................. E-1 Table F-1. Fermi 2 CDF for Internal Events....................................................................... F-2 Table F-2. Base Case Mean Population Dose Risk and Offsite Economic Cost Risk for Internal Events ............................................................................................ F-4 Table F-3. Summary of Major PRA Models and Corresponding CDF and LERF Results............................................................................................................. F-5 Table F-4. Fermi 2 Important Contributors to Fire CDF ................................................... F-11 Table F-5. SAMA Cost/Benefit Screening Analysis for Fermi 2 Station ........................... F-30 Table F-6. Adjusted Cost/Benefit Analysis for SAMAs Impacted by Accident Class IIA Consequence Revisions ................................................................. F-54 xix

EXECUTIVE

SUMMARY

BACKGROUND By letter dated April 24, 2014, DTE Electric Company (DTE) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to issue a renewed operating license for Fermi 2 Nuclear Power Plant (Fermi 2) for an additional 20-year period.

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 51.20(b)(2), the renewal of a power reactor operating license requires preparation of an environmental impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that, in connection with the renewal of an operating license, the NRC shall prepare an EIS, which is a supplement to the Commissions NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants.

Upon acceptance of DTEs application, the NRC staff began the environmental review process described in 10 CFR Part 51 by publishing a Notice of Intent to prepare a supplemental environmental impact statement (SEIS) and to conduct scoping. In preparation of this SEIS for Fermi 2, the NRC staff performed the following:

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

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

reviewed DTEs Environmental Report (ER) and compared it to the GEIS;

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

conducted a review of the issues following the guidance set forth in Standard Review Plans for Environmental Reviews for Nuclear Power Plants:

Environmental Standard Review Plan for Operating License Renewal (NUREG-1555 Supplement 1, Revision 1, Final Report);

considered public comments received during the scoping process;

issued the draft SEIS for comment;

conducted a public meeting to receive comments on the draft SEIS on December 2, 2015; and

considered the public comments received during the draft SEIS comment period.

PROPOSED ACTION DTE initiated the proposed Federal action (i.e., issuance of a renewed power reactor operating license) by submitting an application for license renewal of Fermi 2 for which the existing license (NPF-43) expires on March 20, 2025. The NRCs Federal action is to decide whether to renew the license for an additional 20 years. The regulation at 10 CFR 2.109 states that, if a licensee of a nuclear power plant files an application to renew an operating license at least 5 years before the expiration date of that license, the existing license will not be deemed to have expired until the safety and environmental reviews are completed and until the NRC has made a final decision on whether to deny the application or to issue a renewed license for the additional 20 years.

xxi

Executive Summary PURPOSE AND NEED FOR ACTION The purpose and need for the proposed action (issuance of renewed license) is to provide an option that allows for baseload power generation capability beyond the term of the current nuclear power plant operating license to meet future system generating needs. Such needs may be determined by other energy-planning decisionmakers, such as states, operators, and, where authorized, Federal agencies (other than the NRC). This definition of purpose and need reflects the NRCs recognition that, unless there are findings in the safety review required by the Atomic Energy Act of 1954, as amended, or findings in the National Environmental Policy Act of 1969, as amended, environmental analysis that would lead the NRC to reject a license renewal application, the NRC does not have a role in the energy-planning decisions as to whether a particular nuclear power plant should continue to operate.

ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL The SEIS evaluates the potential environmental impacts of the proposed action. The environmental impacts from the proposed action are designated as SMALL, MODERATE, or LARGE. As established in the GEIS, Category 1 issues are those that meet all of the following criteria:

The environmental impacts associated with the issue are determined to apply either to all plants or, for SMALL: Environmental effects are not detectable or are so minor that they will some issues, to plants having a specific type of neither destabilize nor noticeably alter cooling system or other specified plant or site any important attribute of the resource.

characteristics.

MODERATE: Environmental effects are A single significance level (i.e., SMALL, MODERATE, sufficient to alter noticeably, but not to or LARGE) has been assigned to the impacts except destabilize, important attributes of the for collective offsite radiological impacts from the fuel resource.

cycle and from high-level waste and spent fuel LARGE: Environmental effects are disposal. clearly noticeable and are sufficient to destabilize important attributes of the Mitigation of adverse impacts associated with the resource.

issue is considered in the analysis, and it has been determined that additional plant-specific mitigation measures are likely not to be sufficiently beneficial to warrant implementation.

For Category 1 issues, no additional site-specific analysis is required in this SEIS unless new and significant information is identified. Chapter 4 of this SEIS presents the process for identifying new and significant information. Site-specific issues (Category 2) are those that do not meet one or more of the criteria for Category 1 issues; therefore, an additional site-specific review for these nongeneric issues is required, and the results are documented in the SEIS.

Neither DTE nor the NRC identified information that is both new and significant related to Category 1 issues that would call into question the conclusions in the GEIS. This conclusion is supported by the NRC staffs review of the applicants ER and other documentation relevant to the applicants activities, the public scoping process and substantive comments raised, and the findings from the environmental site audit conducted by the NRC staff. Therefore, the NRC staff relied upon the conclusions of the GEIS for all Category 1 issues applicable to Fermi 2.

Table ES-1 summarizes the Category 2 issues relevant to Fermi 2 and the NRC staffs findings related to those issues. If the NRC staff determined that there were no Category 2 issues applicable for a particular resource area, the findings of the GEIS, as documented in Appendix B to Subpart A of 10 CFR Part 51, are incorporated for that resource area.

xxii

Executive Summary Table ES-1. Summary of NRC Conclusions Relating to Site-Specific Impacts of License Renewal Resource Area Relevant Category 2 Issues Impacts Groundwater Resources Radionuclides released to groundwater SMALL Terrestrial Resources Effects on terrestrial resources (noncooling SMALL system impacts)

Special Status Species and Threatened, endangered, and species and No effect(a)

Habitats essential fish habitat Historic and Cultural Historic and cultural resources No adverse effect(b)

Resources Human Health Electric shock hazards SMALL Environmental Justice Minority and low-income populations See note below(c)

Cumulative Impacts Air Quality and Noise SMALL Geology and Soils SMALL Water Resources SMALL to MODERATE Terrestrial Ecology MODERATE to LARGE Aquatic Resources LARGE Historic and Cultural Resources SMALL Socioeconomic SMALL to LARGE Human Health SMALL Environmental Justice See note below(c)

Waste Management SMALL Global Climate Change MODERATE (a) For Federally protected species, the NRC reports the effects from continued operation of Fermi 2 during the license renewal period in terms of its Endangered Species Act of 1973, as amended, findings of no effect, may effect, but not likely to adversely effect, or may affect, and is likely to adversely affect.

(b) The National Historic Preservation Act of 1966, as amended, requires Federal agencies to consider the effects of their undertakings on historic properties.

(c) There would be no disproportionately high and adverse impacts to minority and low-income populations and subsistence consumption from continued operation of Fermi 2 during the license renewal period and from cumulative impacts.

SEVERE ACCIDENT MITIGATION ALTERNATIVES Since severe accident mitigation alternatives (SAMAs) have not been previously considered in an environmental impact statement or environmental assessment for Fermi 2, 10 CFR 51.53(c)(3)(ii)(L) requires DTE to submit, with the ER, a consideration of alternatives to mitigate severe accidents. SAMAs are potential ways to reduce the risk or potential impacts of uncommon, but potentially severe accidents. SAMAs may include changes to plant components, systems, procedures, and training.

The NRC staff reviewed DTEs ER evaluation of potential SAMAs and determined whether the identified potentially cost-beneficial SAMAs are subject to aging management. Because the potential cost-beneficial SAMAs are associated with procedure changes, new hardware to improve a manual action, and a new structure between switchgear rooms, the NRC staff xxiii

Executive Summary determined that these SAMAs do not relate to managing the effects of aging during the period of extended operation. Therefore, the potentially cost-beneficial SAMAs identified need not be implemented as part of the license renewal, pursuant to 10 CFR Part 54.

ALTERNATIVES The NRC staff considered the environmental impacts associated with alternatives to license renewal. These alternatives include other methods of power generation, as well as not renewing the Fermi 2 operating license (the no-action alternative). The NRC staff considered the following feasible and commercially viable replacement power alternatives:

natural gas combined-cycle (NGCC);

coal-integrated gasification combined-cycle (IGCC);

new nuclear power; and

a combination of NGCC, wind, and solar power.

The NRC staff initially considered a number of additional alternatives for analysis as alternatives to the license renewal of Fermi 2. The NRC staff later dismissed these alternatives because of technical, resource availability, or commercial limitations that currently exist and that the NRC staff believes are likely to continue to exist when the current Fermi 2 license expires. The no-action alternative and the effects it would have were also considered by the NRC staff.

Where possible, the NRC staff evaluated potential environmental impacts for these alternatives located at both the Fermi 2 site and some other unspecified alternate location. The NRC staff considered the following alternatives, but dismissed them:

energy conservation and energy efficiency,

solar power,

wind power,

biomass power,

hydroelectric power,

wave and ocean energy,

fuel cells,

delayed retirement,

geothermal power,

municipal solid waste,

petroleum-fired power,

supercritical pulverized coal, and

purchased power.

The NRC staff evaluated each alternative using the same resource areas that were used in evaluating impacts from license renewal.

xxiv

Executive Summary RECOMMENDATION The NRC staffs recommendation is that the adverse environmental impacts of license renewal for Fermi 2 are not so great that preserving the option of license renewal for energy-planning decisionmakers would be unreasonable. The NRC staff based its recommendation on the following:

the analyses and findings in the GEIS;

the ER submitted by DTE;

the NRC staffs consultation with Federal, state, tribal, and local agencies;

the NRC staffs independent environmental review;

the NRC staffs consideration of public comments received during the scoping process, and

the NRC staffs consideration of public comments received during the draft SEIS comment period.

xxv

ABBREVIATIONS AND ACRONYMS ac acre(s)

AC alternating current ACHP Advisory Council on Historic Preservation ADAMS Agencywide Documents Access and Management System AEA Atomic Energy Act of 1954 (as amended)

ALARA as low as is reasonably achievable ANS American Nuclear Society APE averted public exposure APE area of potential effect AQCR Air Quality Control Region ASLB Atomic Safety and Licensing Board (NRC)

ASME American Society of Mechanical Engineers ATWS anticipated transient(s) without scram AWEA American Wind Energy Association BGEPA Bald and Golden Eagle Protection Act of 1940, as amended Black and Veatch Black & Veatch Corporation BLM Bureau of Land Management BLS Bureau of Labor Statistics BOEM Bureau of Ocean Energy Management BWR boiling water reactor

°C degrees Celsius CAA Clean Air Act CAES compressed air energy storage CCS carbon capture and storage CDC Centers for Disease Control and Prevention CDF core damage frequency CEQ Council on Environmental Quality CET containment event tree CFR Code of Federal Regulations cfs cubic foot (feet) per second cm centimeter CNWR Center for Nuclear Waste Regulatory Analysis CO carbon monoxide xxvii

Abbreviations and Acronyms CO2 carbon dioxide CO2/MWh carbon dioxide per megawatt hour COL combined license Compact 2008 Great Lakes-St. Lawrence River Basin Water Resources Compact CSAPR Cross-State Air Pollution Rule CWA Clean Water Act CWR circulating water reservoir CWS circulating water system CZMA Coast Zone Management Act of 1972 dB decibels dBA decibel(s) on the A-weighted scale DBA design-basis accident DECo Detroit Edison Company DBH diameter at breast height DOE U.S. Department of Energy DRIWR Detroit River International Wildlife Refuge DSIRE Database of State Incentives for Renewables and Efficiency DSM demand-side management DTE DTE Electric Company Ducks Unlimited Ducks Unlimited, Inc.

DWCA Detroit Wayne County Airport ECCS emergency core cooling system EDG emergency diesel generator EFH essential fish habitat EIA Energy Information Administration EIS environmental impact statement EMF electromagnetic field EO Executive Order EPA U.S. Environmental Protection Agency EPRI Electric Power Research Institute EPT Ephemeroptera-Plecoptera-Trichoptera index EPZ emergency planning zone ER Environmental Report ERC Energy Recovery Council xxviii

Abbreviations and Acronyms ESA Endangered Species Act of 1973, as amended ESBWR economic simplified boiling water reactor

°F degrees Fahrenheit FDC floor drain collector FDCT floor drain collector tank FEIS final environmental impact statement Fermi 2 Fermi, Unit 2 Fermi 3 Fermi, Unit 3 FES-C final environmental statement-construction FES-O final environmental statement-operation FIVE fire-induced vulnerability evaluation FLIGHT Facility Level Information on Green House Gases Tool FR Federal Register FRN Federal Register Notice ft foot (feet) ft3 cubic foot (feet)

FWS U.S. Fish and Wildlife Service g Ceq/kWh gram(s) of carbon equivalent per kilowatt-hour gal gallon(s)

GEIS generic environmental impact statement GI generic issue GL generic letter GLC Great Lakes Commission gpm gallon(s) per minute GSW general service water ha hectare(s)

HCLPF high confidence in low probability of failure HFO high winds, floods, and other HRA human reliability analysis HRSG heat recovery steam generator IEA International Energy Agency IEEE Institute of Electrical and Electronics Engineers IGCC integrated gasification combined-cycle in. inch(es)

ISFSI independent spent fuel storage installation xxix

Abbreviations and Acronyms IPE individual plant examination IPEEE individual plant examination(s) of external events ISLOCA interfacing-systems loss-of-coolant accident kg kilogram(s) km kilometer(s) 2 km square kilometer(s) kph kilometer(s) per hour kV kilovolt(s) kW kilowatt(s) kWh/m2/d kilowatt hours per square meter per day L liter(s)

LaMP (Lake Erie) Lakewide Management Plan Work Group LDN day-night sound intensity level LEQ equivalent sound intensity level Ln statistical sound level lb pound(s)

LERF large early release frequency LLMW low-level mixed waste LOCA loss-of-coolant accident LOOP loss(es) of offsite power Lpd liter(s) per day L/min liter(s) per minute LRA license renewal application m/s meter(s) per second m3 cubic meter(s) m3/d cubic meter(s) per day 3

m /s cubic meter(s) per second m3/y cubic meters per year MAAP Modular Accident Analysis Program MAC Michigan Administrative Code MACCS2 MELCOR Accident Consequence Code System 2 MCPDC Monroe County Planning Department and Commission MACR maximum averted cost risk MATS Mercury and Air Toxics Standards MCL Michigan Compiled Laws xxx

Abbreviations and Acronyms MCR main control room MDEQ Michigan Department of Environmental Quality MDCH Michigan Department of Community Health MDHS Michigan Department of Human Services MDNR Michigan Department of Natural Resources mgd million gallons per day mgy million gallons per year mGy milligray mi mile(s) mi2 square mile(s)

MIOSHA Michigan Occupational Safety and Health Administration MISO Midcontinent Independent System Operator mm millimeter MNFI Michigan Natural Features Inventory MOA Memorandum of Agreement mph mile(s) per hour mrad millirad mrem millirem MSA Magnuson-Stevens Fishery Conservation and Management Act, as amended through 2006 MSL mean sea level MSUE Michigan State University Extension mSv millisievert MUR measurement uncertainty recapture MW megawatt(s)

MWe megawatt(s) electric MWh megawatt hour(s)

MWt megawatt(s) thermal NAAQS National Ambient Air Quality Standards NASS National Agricultural Statistics Service (U.S. Department of Agriculture)

NAVD88 North American Vertical Datum of 1988 NCDC National Climatic Data Center NCES National Center for Education Statistics NEI Nuclear Energy Institute xxxi

Abbreviations and Acronyms NEPA National Environmental Policy Act of 1969, as amended NESC National Electrical Safety Code NETL National Energy Technology Laboratory NGCC natural gas combined-cycle NHPA National Historic Preservation Act of 1966, as amended NIEHS National Institute of Environmental Health Sciences NMFS National Marine Fisheries Service (National Oceanic and Atmospheric Administration)

NO2 nitrogen dioxide NOx nitrogen oxide(s)

NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NPS National Park Service NRC U.S. Nuclear Regulatory Commission NRCS Natural Resources Conservation Service NREL National Renewable Energy Laboratory NREPA Michigans Natural Resources and Environmental Protection Act 451 of 1994, as amended NRR Nuclear Reactor Regulation, Office of (NRC)

NSR New Source Review O3 ozone ODCM Offsite Dose Calculation Manual ODNR Ohio Department of Natural Resources OECR offsite economic cost risk ORNL Oak Ridge National Laboratory OSHA Occupational Safety and Health Administration OSSF onsite storage facility OW open water pCi/L picocurie(s) per liter Pb lead PDR population dose risk PDS plant damage state PEIS programmatic environmental impact statement PEM palustrine emergent marsh PFO palustrine forested xxxii

Abbreviations and Acronyms PHAC Public Health Agency of Canada P-IBI Planktonic Index of Biotic Integrity PM particulate matter PRA probabilistic risk assessment PRE principal residence exemption PSDAR post-shutdown decommissioning activities report PSS palustrine scrub-shrub PTS post-treatment system PV photovoltaic radwaste radioactive waste RAI request(s) for additional information RCRA Resource Conservation and Recovery Act of 1976, as amended rem roentgen equivalent(s) man REMP Radiological Environmental Monitoring Program RESA (Wayne) Regional Educational Service Agency RHR residual heat removal ROI region(s) of influence ROW right-of-way(s)

RPHP Radiation and Public Health Project RPS reactor protection system RPV reactor pressure vessel RRW risk reduction worth SAMA severe accident mitigation alternative SAR Safety Analysis Report SBO station blackout SCPC supercritical pulverized coal SCR selective catalytic reduction SEIS supplemental environmental impact statement SEMCOG Southeast Michigan Council of Government SER safety evaluation report SESC Soil Erosion and Sediment Control (Michigan)

SHPO State Historic Preservation Office SMA seismic margin assessment SO2 sulfur dioxide SOx sulfur oxide(s) xxxiii

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

SSEL Safe Shutdown Equipment List Sv sievert(s) syngas synthesis gas TAC technical assignment control TEEIC Tribal Energy and Environmental Information Clearinghouse U.S. United States USACE U.S. Army Corps of Engineers U.S.C. United States Code USCB U.S. Census Bureau USDA U.S. Department of Agriculture UFSAR updated final safety analysis report USGCRP U.S. Global Change Research Program USGS U.S. Geological Survey

µm micrometer WAPA Western Area Power Administration WCS waste collector subsystem WHC Wildlife Habitat Council WM wooded marsh xxxiv

COMMENTS RECEIVED ON THE FERMI 2 ENVIRONMENTAL REVIEW

A. Comments Received on the FERMI 2 Environmental Review A.1 Comments Received During the Scoping Period The scoping process for the environmental review of the license renewal application (LRA) for Fermi 2 began on June 30, 2014, with the publication of the U.S. Nuclear Regulatory Commissions (NRCs) Notice of Intent to conduct scoping in Volume 79 of the Federal Register, page 36837 (79 FR 36837). The scoping process included two public meetings held in Monroe, Michigan, on July 24, 2014. Approximately 110 people attended the meetings. After the NRCs prepared statements pertaining to the license renewal process, the meetings were open for public comments. Attendees provided oral statements that were recorded and transcribed by a certified court reporter. A summary and transcripts of the scoping meetings are available using the NRCs Agencywide Documents Access and Management System (ADAMS).

The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. The scoping meetings summary can be found under ADAMS No. ML14233A450. Transcripts for the afternoon and evening meetings can be found under ADAMS Nos. ML14254A465 and ML14254A470, respectively. In addition to comments received during the public meetings, comments were also received electronically and through the mail.

Each commenter was given a unique numeric identifier (001 through 063) so that every comment can be traced back to its author. Table A-1 identifies the individuals who provided comments and an accession number to identify the source document of the comments in ADAMS. Each source document was assigned an alphabetic identifier (A through CC).

Specific comments were categorized and consolidated by topic. Comments with similar specific objectives were combined to capture the common essential issues raised by commenters.

Comments have been grouped into the following general categories:

Specific comments that address environmental issues within the purview of the NRC environmental regulations related to license renewal. These comments address Category 1 (generic) or Category 2 (site-specific) issues identified in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), or issues not addressed in the GEIS. The comments also address alternatives to license renewal and related Federal actions.

General comments in support of, or opposed to, nuclear power or license renewal or comments regarding the renewal process, the NRCs regulations, and the regulatory process.

Comments that address issues that do not fall within, or are specifically excluded from, the purview of the NRCs environmental regulations related to license renewal.

These comments typically address issues, such as the need for power, emergency preparedness, security, current operational safety issues, and safety issues related to operation during the renewal period.

A-1

Appendix A Table A-1. Individuals Providing Comments during the Scoping Comment Period Each commenter is identified, along with an affiliation, and how the comment was submitted.

Commenter Affiliation (if stated) ID Comment Source ADAMS Number Gabriel Agboruche DTE Electric Company 001 Evening ML14254A470 Transcript (CC)

Anonymous None given 002 Comment letter (S) ML14252A172 Mary Ann Baier None given 003 Comment letter (O) ML14252A142 Sandra Bihn Lake Erie Waterkeeper 004 Comment letter (U) ML14252A175 Paul Braunlich Frenchtown Charter 005 Afternoon ML14254A465 Township Resort Transcript (BB)

District Authority Greg Brede None given 006 Afternoon ML14254A465 Transcript (BB)

Barry Buschmann The Mannik & Smith 007 Afternoon Transcript ML14254A465 Group (BB)

Joanne Cantoni None given 008 Comment letter (N) ML14252A141 Corinne Carey Don't Waste Michigan 009 Comment letter (M) ML14252A140 Connie Carroll United Way of Monroe 010 Afternoon Transcript ML14254A465 County (BB)

Robert Clark City of Monroe 011 Afternoon Transcript ML14254A465 (BB)

Jessie Pauline Collins Citizens' Resistance at 012 Afternoon Transcript ML14254A465 Fermi 2 (BB)

Evening Transcript ML14254A470 (CC)

Comment letter (F) ML14234A189 Comment letter (L) ML14252A139 Valerie Crow None given 013 Evening Transcript ML14254A470 (CC)

Eric Dover DTE Electric Company 014 Afternoon Transcript ML14254A465 (BB)

Evening Transcript ML14254A470 (CC)

Nancy Dover None given 015 Afternoon Transcript ML14254A465 (BB)

Rosemary Doyle None given 016 Comment letter (R) ML14252A171 Michelle Dugan Monroe County 017 Comment letter (E) ML14234A188 Chamber of Commerce Bill Dyer Utilities Workers Union 018 Afternoon Transcript ML14254A465 of America, Local 223 (BB)

Fermi Division Mark Farris None given 019 Afternoon Transcript ML14254A465 (BB)

A-2

Appendix A Commenter Affiliation (if stated) ID Comment Source ADAMS Number Evening Transcript ML14254A470 (CC)

Comment letter (Z) ML14252A186 Lynne Goodman DTE Electric Company 020 Evening Transcript ML14254A470 (CC)

Martha Gruelle Wildlife Habitat Council 021 Afternoon Transcript ML14254A465 (BB)

Keith Gunter Alliance to Halt 022 Afternoon Transcript ML14254A465 Fermi 3 (BB)

Taiya Himebauch DTE Electric Company 023 Afternoon Transcript ML14254A465 (BB)

Sean Honell DTE Electric Company 024 Afternoon Transcript ML14254A465 (BB)

Carol Izant Alliance to Halt 025 Afternoon Transcript ML14254A465 Fermi 3 (BB)

Evening Transcript ML14254A470 (CC)

Comment letter (V) ML14252A176 Kevin Kamps Beyond Nuclear 026 Afternoon Transcript ML14254A465 (BB)

Evening Transcript ML14254A470 (CC)

Hedwig Kaufman None given 027 Evening Transcript ML14254A470 (CC)

Michael Keegan Don't Waste Michigan 028 Afternoon Transcript ML14254A465 (BB)

Comment letter (K) ML14252A138 Comment letter (Y) ML14252A180 Manfred Klein None given 029 Evening Transcript ML14254A470 (CC)

Dustin Krasny Office of Congressman 030 Afternoon Transcript ML14254A465 Tim Walberg (BB)

Tim Lake Monroe County 031 Evening Transcript ML14254A470 Business Development (CC)

Corporation Bobby Lambert Monroe County Board 032 Evening Transcript ML14254A470 of Commissioners (CC)

Ron Lankford None given 033 Afternoon Transcript ML14254A465 (BB)

Bill LaVoy Michigan House of 034 Evening Transcript ML14254A470 Representatives (CC)

Vic and Gail Macks None given 035 Comment letter (J) ML14234A339 Archana Manoharan American Nuclear 036 Afternoon Transcript ML14254A465 Society/DTE Electric (BB)

Company A-3

Appendix A Commenter Affiliation (if stated) ID Comment Source ADAMS Number Bonnie Masserant DTE Electric Company 037 Evening ML14254A470 Transcript (CC)

Ed McArdle Sierra ClubMichigan 038 Comment ML14259A341 Chapter letter (AA)

Jim McDevitt Frenchtown Charter 039 Comment letter (D) ML14216A376 Township Rich McDevitt DTE Electric Company 040 Afternoon Transcript ML14254A465 (BB)

Evening Transcript ML14254A470 (CC)

Stephen McNew Monroe County 041 Comment letter (C) ML14219A583 Intermediate School District Floreine Mentel Former Monroe 042 Afternoon Transcript ML14254A465 County Commissioner (BB)

Jeanne Micka Monroe County 043 Afternoon Transcript ML14254A465 Garden Club (BB)

Richard Micka None given 044 Afternoon Transcript ML14254A465 (BB)

Comment letter (G) ML14234A190 Jessica Miskena None given 045 Evening Transcript ML14254A470 (CC)

Sandy Mull Southern Wayne 046 Afternoon Transcript ML14254A465 County Regional (BB)

Chamber of Commerce Tracy Oberleiter Monroe County 047 Afternoon Transcript ML14254A465 Economic (BB)

Development Corporation Phyllis Oster None given 048 Comment letter (Q) ML14252A170 Sandy Pierce Monroe Center for 049 Afternoon Transcript ML14254A465 Healthy Aging (BB)

Joseph Plona DTE Electric Company 050 Afternoon Transcript ML14254A465 (BB)

Emilio Ramos None given 051 Evening Transcript ML14254A470 (CC)

Ken Richards None given 052 Comment letter (T) ML14252A173 Randy Richardville Michigan State 053 Comment letter (B) ML14219A580 Senator Angela Rudolph URS 054 Afternoon Transcript ML14254A465 (BB)

David Schonberger None given 055 Afternoon Transcript ML14254A465 (BB)

Evening Transcript ML14254A470 (CC)

A-4

Appendix A Commenter Affiliation (if stated) ID Comment Source ADAMS Number Comment letter (X) ML14252A178 Robert Simpson None given 056 Comment letter (P) ML14252A143 Comment letter (W) ML14252A177 Phillip Skarbek DTE Electric Company 057 Afternoon Transcript ML14254A465 (BB)

Evening Transcript ML14254A470 (CC)

Jerry Sobczak DTE Shareholders 058 Evening Transcript ML14254A470 United (CC)

Robert Tompkins Detroit Edison Alliance 059 Comment letter (A) ML14205A009 of Retirees Tim Walberg U.S. Congress 060 Comment letter (I) ML14234A192 Emily Wood Women in 061 Afternoon Transcript ML14254A465 Nuclear/DTE Electric (BB)

Company Evening Transcript ML14254A470 (CC)

Grace Yackee Monroe County 062 Afternoon Transcript ML14254A465 Community College (BB)

Dale Zorn Michigan State 063 Evening Transcript ML14254A470 Representative (CC)

Comment letter (H) ML14234A191 Comments that are general or outside the scope of the environmental review for the Fermi 2 license renewal are not addressed in this appendix, but they can be found in the Scoping Summary Report (ADAMS No. ML15252A015). To maintain consistency with the Scoping Summary Report, the unique identifier used in that report for each comment is retained in Appendix A. Comments addressed in Appendix A are provided in their original form at the end of the Scoping Summary Report.

Comments received during the scoping comment period applicable to this environmental review were placed into categories, which are based on topics contained in the Fermi 2 draft supplemental environmental impact statement (DSEIS). These categories and their abbreviation codes are listed in Table A-2 Table A-2. Issue Categories Comments were divided into the categories below.

Code Technical Issue AM Air Quality AL Alternatives to License Renewal AE Aquatic Resources CC Climate Change GW Groundwater Resources HC Historic and Cultural Resources HH Human Health A-5

Appendix A Code Technical Issue PA Postulated Accidents, including Severe Accident Mitigation Alternatives (SAMAs)

RW Waste Management SH Special Status Species and Habitats TE Terrestrial Resources The following pages contain the comments that have been copied directly from the comment source documents and are followed by the NRC staff response. Each comment is identified by the commenters identifier (ID), comment source document (as identified in Table A-1), and comment number and is grouped by the comment issue category (as identified in Table A-2).

Similar comments are grouped together with a single response. Comments are presented in the same order as listed in Table A-2 A.1.1 Air Quality (AM)

Comment 029-CC-6: Number six, in 2010, the tornado that we had damaged the power plant, damaged Fermi 2 to the point where it had to be shut down. Keep that one in mind. We're not--

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

Response: This comment voices concern regarding the impacts associated with tornadoes at Fermi. As noted by the commenter, on June 6, 2010, an EF2 tornado with maximum sustained winds of 130 to 135 miles per hour (209 to 217 kilometers per hour (km/h)) moved through Monroe County. As a result of the tornado, a partial loss of offsite power at Fermi 2 occurred, and the licensee declared an Unusual Event, the lowest of the NRCs four emergency level classifications. The reactor was shut down and stabilized. There were no radiological releases from this event, and power was restored to the site.

The NRC requires licensees to design nuclear power plants to withstand the effects of tornado and high wind-generated missiles so as not to adversely impact the health and safety of the public in accordance with the requirements in General Design Criterion (GDC) 2, Design Bases for Protection against Natural Phenomena, and GDC 4, Environmental and Dynamic Effects Design Bases, of Appendix A, General Design Criteria for Nuclear Power Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. These are called design-basis requirements. Section 4.11.1.2 of the Fermi DSEIS discusses design-basis accidents and adopts the GEIS finding that the environmental impacts from externally initiated events, such as tornadoes, are SMALL.

A.1.2 Alternatives to License Renewal (AL)

Comment 012-F-4: DTE needs to document the viable alternatives to operating Fermi 2 another 31 years, as opposed to building and operating both wind and photovoltaic options.

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

Environmental Report (hereinafter, ER) does not adequately evaluate the full potential for renewable energy sources, such as wind power, to replace the loss of energy production from Fermi 2, and to make the license renewal request from 2025 to 2045 unnecessary. In violation of the requirements of 10 CFR§ 51.53(c) (3) (iii) and of the GElS § 8.1, the DTE ER (§ 7.1.2.2.1) treats all of the alternatives to license renewal as unreasonable and does not provide a substantial analysis of the potential for significant alternatives, such as wind power, in the Region of Interest for the requested relicensing period of 2025 to 2045. While the ER plainly A-6

Appendix A states, Whereas a single wind farm generation unit would not provide consistent power generation, multiple wind farms scattered within a reasonable region and interconnected together via the grid may potentially provide power generation that could approach base-load capacity. On page 7-8, the ER states, Placing wind farms offshore eliminates some of the obstacles encountered when siting wind farms on shore and limits conflicts with other planning interests.

Comment 019-CC-8: It has its flaws and you know, we also have to look at the -- the Germans are using solar and, you know, so thats the direction theyre going. There - theres advances taken off like gangbusters there and fortunately, the sun doesnt have to be shining for solar technology to work. Of course, it works best without clouds, but itll work with cloud cover also.

Comment 019-CC-9: After my comments earlier, I talked to one of the folks here and they told me that Germany has a lot of problems now with particulate matter and, you know, gaseous emissions because of shutting down nuclear plants. Well, thats true, however, we have to keep in mind that Germany made the same mistake that Detroit Edison made by not putting scrubbers in when they could have. The scrubbers out here at the coal burner, you know, thats a step in the right direction and Im sure the Germans will be working on that also.

Comment 012-CC-4: DET -- DTE also needs to document the viable alternatives to operating Fermi 2 another 31 years instead of doing it by a coal-fired plant somewhere else comparing it to -- I want them to actually do the -- the figures on -- in windmills, solar panels, sustainable energy. Do that now, not -- okay.

Comment 025-CC-3: But I -- I'm not insensitive to, you know, the -- the economic impact of a closure of Fermi 2. I -- I understand the economic impact that it would have on this community, but I also know that, you know, as we speak, more and more people around the world and in the United States are figuring out -- the cost of solar panels is coming down, wind, the whole -- the cost of the renewables is coming in cheaper and cheaper and more and more people are going to start to move off of the grid. It is -- we are going to move away from the, you know, a centralized grid and move into more of a distributed grid of energy.

And, you know, more and more people, the -- the -- you know, the low-hanging fruit of energy efficiency, I'm -- my husband and I had a very thorough, you know, attic insulation done a couple years ago and duct ceiling and air ceiling and our energy bills, our heating bills, now are 30 percent less than -- than what they were. And this was even after this cold winter that we had this last year.

And -- and also, as kind of a side perk that I never even considered, it -- it keeps the house so much cooler in the summer so that -- and I don't have A/C, but I haven't hardly -- I mean, I haven't had to run my ceiling fans. I mean, its been -- now granted, weve had a pretty mild summer so far, but nevertheless, you know, and more and more this is what people are going to

-- you know, nuclear power is such a heavily-subsidized industry. If only, you know, we could have the same opportunity to subsidize some of these other ways of generating electricity, I mean, you would see a far different, you know, picture.

And again, I -- I know, you know, the younger generation is coming up. They are definitely connecting the dots on all of this and the Passive House Movement, which is a net zero, you know, way to build a house so that it, you know, it doesn't consume any energy. If anything, it --

it produces electricity and thats - thats going to start to happen more and more.

Response. These comments are concerned with renewable energy replacement power and energy efficiency alternatives to Fermi 2. In evaluating alternatives to license renewal, the NRC staff considered energy technologies or options currently in commercial operation, as well as A-7

Appendix A technologies not currently in commercial operation but likely to be commercially available by the time the current Fermi 2 operating license expires in 2025.

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

Alternatives that could not provide the equivalent of Fermi 2s current generating capacity and, in some cases, those alternatives whose costs or benefits did not justify inclusion in the range of reasonable alternatives, were eliminated from detailed consideration. The NRC staff explained the reasons why each of these alternatives was eliminated from further consideration in Section 2.3 of the Fermi 2 DSEIS. The 17 replacement power alternatives were narrowed to 4 alternatives considered in detail in Sections 2.2.2.1 through 2.2.2.4 of the Fermi 2 DSEIS.

The NRC staff evaluated the environmental impacts of these four alternatives and the no-action alternative in Chapter 4 of the Fermi 2 DSEIS.

A.1.3 Aquatic Resources (AE)

Comment 012-F-2: Another issue is Fermi 2's fish kills. DTE's 2009 study stated Fermi 2's Cooling Water Intake sucked up 3,102 live fish, and 62,566,649 fish eggs and larvae in a year's time. We need another such study to show how many fish the reactor is killing now.

025-V-17: In a nine month study, the Fermi, Unit 2 Cooling Water Intake impinged 3,102 live fish and more than 62.5 million fish eggs and larvae. This significant impact to the ecosystem of Lake Erie's western basin must be addressed in the SEIS.

012-BB-3: In the 19 - 2009 study that they did on the cooling water intake, it showed the cooling water intake sucked up, in an eight-month period, 3,102 live fish, over 63 million fish eggs and fish larva in normal operations. The world depends on the fish. And the water they put out is hot, inviting in invasive species.

012-CC-2: I want to put in the scoping process another issue to -- another study on the Fermi 2 cooling water intake's fish kill. The 2009 study showed that they sucked up 3,102 live fish, 62,566,649 fish eggs and fish larvae in less than a year. Another study needs to be a part of this environmental impact statement to see how many fish - - is there any left - I hope so -- in the ocean -- or lake.

Response: These comments refer to the Aquatic Ecology Characterization Report Detroit Edison Company Fermi 3 Project, Final Report prepared by AECOM Environment in November 2009 (AECOM 2009) and express concerns regarding the effects of entrainment and impingement of Lake Erie fish at Fermi 2s cooling water intake structure. This report was one of the reports reviewed by NRC staff as part of the environmental review. Entrainment and impingement of fish are discussed in Sections 3.7 and 4.7 of this draft supplemental environmental impact statement (DSEIS). As discussed in Section 4.7, entrainment and impingement of aquatic organisms for nuclear power plants with cooling towers is a generic (Category 1) issue with an impact level of SMALL for all sites. During the review of the Fermi 2 LRA, the NRC staff did not identify any new and significant information that would challenge the generic conclusion in the GEIS for this issue.

Regarding the need for new or additional studies of entrainment and impingement at Fermi 2, the requirements of Section 316(b) of the Clean Water Act of 1977, as amended (33 U.S.C. 1251 et seq.), determine the need for studies, such as the studies requested in comments. The requirements of Section 316(b) are addressed as part of the National Pollution Discharge Elimination System (NPDES) permitting process, which is meant for protection and propagation of the waterbodys balanced, indigenous population of shellfish, fish, and wildlife. The State of Michigan, not the NRC, is responsible for administering the NPDES permitting program.

A-8

Appendix A Comment 035-J-1: Thermal loading of the Great Lakes by Nuclear Reactors The Nuclear Regulatory Commission (NRC) has stated in Draft NUREG-2105, volume 1, October 2011, page 2-228: "Public and occupational health can be compromised by activities at the Fermi site that encourage the growth of disease-causing microorganisms (etiological agents). Thermal discharges from Fermi into the circulation water system and Lake Erie have the potential to increase the growth of thermophilic organisms. These microorganisms could give rise to potentially serious human concerns, particularly at high exposure levels."

There are 48 nuclear reactors in the Great Lakes basin. Each one has added to the thermal load on the Lakes in addition to designed and non-designed radioactive releases. The water usage from Lake Erie is 56,024 million gallons per day (Draft NUREG-2105, volume 1, p. 2-24).

Of that, 50,518 million gallons per day are used by power plants. Nuclear power plants release some of that in water vapor and the rest goes back into Lake Erie heated. Without water cooling, reactors would melt their cores and explode as happened to three at Dai-ichi.

Toxic plumes on Lake Erie were a repeat occurrence in August 2014, shutting down water to Toledo and surrounding areas. The only allowable water use was to flush a toilet. We cannot live with safe water being made unavailable from multiple causes and most significantly, in this instance, from Fermi 2 and Davis Bessie, near Toledo, on Lake Erie.

Comment 028-K-16: Petitioner's request a public hearing to examine the impact of daily thermal discharges from Fermi 2 as an accelerator and contributor to harmful algal blooms (HABS). The Fermi 2 releases 45 million gallons of water per day into Lake Erie. This thermal discharge averages 18 degrees (F) above ambient lake temperature 365 days per year.

Petitioner's contend that the Applicant's Environmental Report (ER) fails to consider new and updated environmental and public health data, unavailable at the time of issuance of the original Operating License; further, the Petitioner contends that the Applicant fails to adequately consider Mitigation Alternatives which could significantly reduce the alleged significant environmental and public health impact of Fermi, Unit 2 operations. Therefore, the Petitioner invokes NEPA requirements and contends that further analysis is called for. Illustration:

Petitioner puts forth the following NOAA Satellite Image of Lake Erie from August 10, 2014 to illustrate how severe the algal bloom crisis has become.

http://coastwatch.glerl.noaa.gov/webdata/cwops/htmi/modis/modis.php?region=e&pacqe=1&ite mplate=sub&image=al.14222.1852.LakeErie.143.250m.jpg Comment 012-L-1: Earlier this month, thousands of people in the vicinity of the Fermi 2 nuclear reactor could not drink their water because of poison algae growth. And yet, back in 2011, the NRC stated, "Public and occupational health can be compromised by activities at the Fermi site that encourage the growth of disease-causing micro-organisms (etiological agents).

Thermal discharges from Fermi into the circulation water system and Lake Erie have the potential to increase the growth of thermophilic organisms. These microorganisms could give rise to potentially serious human concerns, particularly at high exposure levels. (Draft NUREG-2105, Vol. 1, 10/2011, page 2-228)

So if the NRC knew if 2011 that DTE's discharges could poison the water, why did they let them? For profit, or were they/you covering the legal liability laws by declaring you make the potential degradation public, but hoping no one noticed. Your agency added in that same document, "Recent studies of the effects of climate change indicate that there could be declines in the overall Lake Erie water levels of 1 to 2 m (Hartig et al 2007). There are no known studies of potential future surface water use in the Lake Erie Basin or the entire Great Lakes Basin.

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

A-9

Appendix A Comment 004-U-1: About 500,000 people who are provided drinking water by the City of Toledo were told not to drink the water because the toxin microcystin exceeded World Health Organization drinking water standards. Fermi 2 is located at the western end of the western basin of Lake Erie. Fermi uses up to 50 mgd for cooling purposes which means that water exiting the plant is warmer than water entering the plant. Harmful algal blooms are triggered when the water gets warmer. Lake Erie's first mass of algae each year is generally in the Monroe DTE coal and nuclear plant mixing zones. Before relicensing, there needs to be an assessment of whether or not the thermal discharge mixing zone algae creation is contributing to a larger bloom of harmful algae- cyanobacteria - and/or if the thermal discharge contributes to an increased amount of microcystin released in the water.

Comment 029-CC-3: Number three, somebody spoke about loving the lake, as I do, even though I'm not a long- term resident of Monroe. We've only been here about 16 years. The fact of the matter is that the - the temperature -- the cooling water that comes out of Fermi is above the water temperature of the lake and it contributes to the algal blooms. If anybody would like to seen one or would've liked to have seen one last year, I could invite them down to my place and you could smell it before you got there.

Response: These comments express concerns regarding the effects of Fermi 2s thermal discharge on harmful algal blooms in Lake Erie. Harmful algal blooms are discussed in Sections 3.7, 4.7, 4.14, and 4.16 of this DSEIS. As discussed in Section 4.7, algal blooms resulting from the operation of cooling systems are addressed as part of the generic (Category 1) issue, Infrequently Reported Thermal Impacts. As noted in Section 4.16.5 of this DSEIS, several research studies indicate that recent algal blooms in western Lake Erie are linked to nutrient loading, nutrient releases by zebra mussels, and selective feeding by zebra mussels, with much more research needed (EPA 2014). Based its review of available information for the Lake Erie algal blooms, the NRC staff determined that this information does not constitute new and significant information that would change the GEISs conclusion of SMALL for this issue.

DTE is required to address the thermal impacts from the operation of Fermi 2including any possible mitigation that may be requiredas part of the NPDES permitting process. The NPDES process is meant for the protection and propagation of the waterbodys balanced, indigenous population of shellfish, fish, and wildlife and for enforcing Michigan State Water Quality Standards to protect the public health and welfare, to enhance and maintain the quality of water, and to protect the States natural resources. The State of Michigan, not the NRC, is responsible for administering the NPDES permitting process.

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

Within the Scope for review, the SEIS for the Fermi, Unit 2 LRA must include an updated and realistic analysis of current and projected public health impacts of authorized, routine, by-design thermal discharges by Fermi, Unit 2 into the surrounding environment. ATHF3 [Alliance to Halt Fermi 3] considers this issue to be in the category of "Significant New Unknown and Unanalyzed Conditions. The SEIS must consider new and updated environmental and public health data, unavailable at the time of issuance of the original Operating License; further, the SEIS must adequately consider Mitigation Alternatives which could significantly reduce the alleged environmental and public health impacts of Fermi, Unit 2's operations. Thus, further analysis is called for, under NEPA.

In support of this contention, ATHF3 submits into the docket the following analysis from the U.S. NRC, pertaining to the Fermi Nuclear Power Plant:

A-10

Appendix A

The U.S. Nuclear Regulatory Commission (NRC) has stated in Draft NUREG-2105, volume 1, October 2011, page 2-228: "Public and occupational health can be compromised by activities at the Fermi site that encourage the growth of disease-causing microorganisms (etiological agents). Thermal discharges from Fermi into the circulation water system and Lake Erie have the potential to increase the growth of thermophilic organisms. These microorganisms could give rise to potentially serious human concerns, particularly at high exposure levels. (emphasis added).

Indeed, the U.S. NRC has been vindicated, as the above analysis has proved to be both correct and prescient. The Governor of the State of Ohio recently declared a "State of Emergency" (summer 2014) in response to a clean drinking water supply crisis in and around the City of Toledo, Ohio. There is no doubt about the significance of this public health crisis. The question is to what extent Fermi, Unit 2 operations contributed to the conditions which led to the crisis in the first place, and what are the prospects for the future. ATHF3 contends that one significant contributing factor is the routine thermal discharges from Fermi, Unit 2 which add cumulative stress impacts to the fragile ecosystem of Lake Erie's shallow western basin and shoreline.

Lake Erie already suffers from numerous environmental stressors, including pollution from agricultural runoff (such as phosphorus), sewage overflows and routine, authorized releases of industrial toxic chemicals (including releases originating from Fermi, Unit 2). In addition, thermal pollution from nearby power plants is a known contributing factor to the conditions which produce toxic algal blooms and consequent hypoxic dead zones. The exact and precise extent to which Fermi, Unit 2 normal operations are directly causative, not just correlative, of significant environmental and public health impacts is "unknown and unanalyzed. Therefore, ATHF3 hereby invokes NEPA requirements and contends that a "hard look" and further analysis is called for, as a precondition for approval of the Applicant/Licensee's Fermi, Unit 2 License Renewal Application (LRA).

Additionally, ATHF3 demands an SEIS analysis of the environmental and public health impacts of the NRC's decision to approve Fermi, Unit 2 License Amendment No. 196, which allows an increase in thermal power from the facility. The largest algae blooms on Lake Erie occur in the shallow, warm water near DTE's nuclear and coal-fired power plants.

Comment 028-Y-4: Algae Bloom Contribution Algae blooms of particular concern in Lake Erie is Microcystis spp., a phytoplanktonic species of blue-green alga that can produce a substance (microcystin) that is toxic to fish and other organisms when concentrations are high enough. Mycrocystis spp. Blooms can affect water quality as well as the health of human and natural resources. General consensus is that algae blooms initiate in the western Lake Erie basin. What is the Thermal Contribution of Fermi 2 to Algae Blooms, we are requesting that there be a multivariate analysis conducted by a qualified independent third party.

Thermal Discharge Impact on Algae Blooms Another assault on Great Lakes water degradation is due to thermal discharges. Public and occupational health can be compromised by activities at the Fermi site that encourage the growth of disease-causing microorganism (etiological agents). Thermal discharges from Fermi 2 into the circulating water system and Lake Erie have the potential to increase the growth off thermophilic microorganisms. These microorganisms could give rise to potentially serious human health concerns, particularly at high exposure levels. This would endanger the whole bio-region, yet there is only tertiary discussion in the ER of thermal contribution from Fermi 2, and how it will be mitigated. Forty-five million gallons per day of discharge averaging 18 degrees F above ambient Lake Erie temperature. This compounds the Algae Blooms A-11

Appendix A Response: These comments express concern regarding the sensitivity of the Lake Erie ecosystem to stressors, the effects of Fermi 2s thermal discharge on harmful algal blooms in Lake Erie, and the effect of the thermal effluent on thermophilic organisms that can affect human health. Section 4.16.5 of this DSEIS addresses the sensitivity of the Lake Erie ecosystem. As discussed in Section 4.16.3, the EPA has initiated the Great Lakes Restoration Initiative, which is a consortium of 11 Federal agencies that were tasked with developing an action plan to address (1) cleaning up toxins and areas of concern, (2) combating invasive species, (3) promoting nearshore health by protecting watersheds from polluted runoff, (4) restoring wetlands and other habitats, and (5) tracking progress and working with strategic partners. More information on the Great Lakes Restoration Initiative can be found at http://greatlakesrestoration.us/.

Sections 3.7, 4.7, 4.14, and 4.16.5 of this DSEIS discuss harmful algal blooms. As discussed in Section 4.7, algal blooms resulting from the operation of cooling systems are addressed as part of the generic (Category 1) issue, Infrequently Reported Thermal Impacts. As noted in Section 4.16.5 of this DSEIS, several research studies indicate that recent algal blooms in western Lake Erie are linked to nutrient loading, nutrient releases by zebra mussels, and selective feeding by zebra mussels, with much more research needed (EPA 2014). Based its review of available information for the Lake Erie algal blooms, the NRC staff determined that this information does not constitute new and significant information that would change the GEISs conclusion of SMALL for this issue.

As discussed in Section 3.11.3 of this DSEIS, heated discharge from cooling system operations can result in the presence of thermophilic microorganisms, such as enteric pathogens, thermophilic fungi, bacteria, and the free living amoeba. The presence of these microorganisms could result in adverse effects to the health of nuclear power plant workers in plants that use cooling towers and to the health of the public where thermal effluents discharge into cooling ponds, lakes, canals, or rivers.

DTE is required to address the thermal impacts from the operation of Fermi 2including any possible mitigation that may be requiredas part of the NPDES permitting process. The NPDES process is meant for the protection and propagation of the waterbodys balanced, indigenous population of shellfish, fish, and wildlife and for enforcing Michigan State Water Quality Standards to protect the public health and welfare, to enhance and maintain the quality of water, and to protect the States natural resources. The State of Michigan, not the NRC, is responsible for administering the NPDES permitting process.

A.1.4 Climate Change (CC)

Comment 038-AA-5: Because of the long time line of proposed operation until 2045 and the prospect of an additional 60 years allowed for decommissioning, much care must be taken to determine the environmental impacts for at least 90 years from now (until 2105 and possibly beyond).

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

5. Overriding all of these concerns is the ongoing crisis of global warming and its effect on Lake levels and more severe weather events that are predicted.

Response: This comment voices concern about climate change implications, specifically the impacts on Lake levels and severe weather events. Section 4.15.3 of this DSEIS discusses projected climate change for the license renewal period of Fermi 2 (2025 to 2045) and climate change impacts to resource areas.

A-12

Appendix A As discussed in Section 4.15.3, water levels for Lake Erie have exhibited a downward trend since the 1860s, and the average lake level of Lake Erie could decrease by 7.8 to 9.8 in. (20 to 25 cm) compared to the current long-term mean by 2050 (Mackey 2012; USGCRP 2014;).

However, future lake level changes are highly uncertain and climate models have a low confidence level associated with estimated water level changes. Future lake levels will depend on evaporative losses, local precipitation changes, wind speeds, and storm frequency.

Further, as discussed in Section 4.15.3, observed global changes in average surface temperature and precipitation have been accompanied by an increase in sea surface temperatures, a decrease in global glacier ice, an increase in sea level, and changes in extreme weather events. Such extreme events include increases in frequency of heat waves, heavy precipitation, and minimum and maximum temperatures.

Comment 019-CC-5: We have to look at some of the reactors, you know, with the global disruption of weather. We're going to see as we have in the past, some nuclear power plants have had to shut down for a lack of cooling water. River levels drop. The water warms up and some nuclear plants have had to be shut down and I think that that's an issue we're going to be seeing a whole lot more of down the road.

Response: This comment voices concern about climate change implications to water resources, specifically the impacts of climate change on operation of nuclear power plants.

Section 4.15.3, Greenhouse Gas Emissions and Climate Change, of this DSEIS discusses projected climate change for the license renewal period of Fermi 2 (2025 to 2045) and climate change impacts to resource areas. However, the impacts of climate change on operations and safety of Fermi 2 are considered outside the scope of the license renewal environmental review, which documents the potential impacts of continued operation on the environment. The NRC evaluates nuclear plant operation conditions and physical infrastructure to ensure continued safe operations through its ongoing inspection and oversight process. Furthermore, plant operations are dictated by NRC-issued operating license technical specifications. Technical specifications and operating procedures exist to ensure that adequate cooling water is available and is maintained to ensure safe operation of the facility. Licensees must operate within the dictated technical specifications, or if they propose changes in operating conditions contrary to operating license specifications, the NRC staff conducts safety reviews of any such license amendment before allowing the specific licensee to continue operation.

A.1.5 Groundwater Resources (GW)

Comment 012-F-5: There exists a need for explanation as to why citizens within the radiation zone are no longer allowed to use their water well, and must have water brought into them if they are unable to hook up to a public water supply.

Comment 012-L-2: Groundwater was also noted to be affected back in 2011, "In wells within a 5-mile radius of the Fermi site, elevated concentrations of arsenic above the EPA (2009a) maximum contaminate level (MCL) were found in groundwater samples (Detroit Edison 2011 a).

p. 2-29 Comment 019-BB-2: And one issue I wanted to bring up momentarily, is that 2,500 gallons of diesel fuel that leaked here recently at the Fermi Plant, was this a large line or just a long-term leak that nobody paid attention to? Where was the NRC? You know, nobody mentioned, no comments from the NRC on this issue. That raises questions.

Comment 012-CC-5: There's also a great number of people within a 25-mile radius of the plant that are no longer allowed to use their water wells. They have to either buy their water or hook up to a public water supply. Why are their wells contaminated?

A-13

Appendix A Response: Section 3.5.2.3 of this DSEIS presents the NRC staffs characterization of existing groundwater quality beneath the Fermi site. As discussed in Section 3.5.2.3, the groundwater outside the Fermi site has not been impacted by Fermi 2 activities. Within the site boundary, no significant concentrations of radionuclides above background have been found in the groundwater. In addition, DTE maintains a radioactive effluent monitoring and a radiological environmental monitoring program (REMP) at Fermi 2 to assess the radiological impact (if any) to its employees, the public, and the environment around the Fermi site. As part of the license renewal environmental review, the NRC staff specifically reviewed DTEs most recent annual radiological environmental operating reports, which are submitted under the REMP, to look for any significant impacts to the environment or any unusual trends in the data. Based on the review of the radiological environmental monitoring data, the NRC staff found that there were no unusual and adverse trends and that there was no measurable impact to the offsite environment from Fermi 2 operations. The NRCs ongoing inspection program periodically evaluates DTEs programs for compliance with the NRCs radiation protection standards. The NRCs inspection program evaluates the data for compliance with radiation protection standards. If the data were to show a noncompliance with requirements, the NRC would take appropriate enforcement action.

However, within the site boundary, a few nonradiological spills of chemicals have occurred, as noted in Section 3.5.1.3 and further described in Section 3.5.2.3. All of these spills were reported by DTE to the Michigan Department of Environmental Quality and have been remediated. During the license renewal environmental review for Fermi 2, the NRC staff specifically considered the issue of such minor chemical spills as part of its review of information for generic surface water issues. The use of chemicals and fuels is common at industrial facilities and spills are always a possibility. Any such spills are regulated by State and other Federal environmental agencies, rather than the NRC. As stated in Section 4.5.1.1 of the DSEIS, the NRC staff did not identify any new and significant information with regard to the Category 1 (generic) surface water issues and found, in part, that the environmental impact of minor chemical spills is SMALL.

Finally, in Monroe County and other counties in Michigan, naturally occurring concentrations in the groundwater of arsenic and some nonhazardous water quality constituents may exceed drinking water standards. In wells within a 5-mi (8-km) radius of the Fermi site, elevated concentrations of arsenic above the EPA maximum contaminant level for drinking water have been found. The Fermi site did not cause the arsenic concentrations in these wells. In the local area and in other areas of Michigan earth materials, such as bedrock, sand, and gravel may contain arsenic-bearing minerals. The arsenic in these naturally occurring materials may enter the groundwater as a dissolved constituent. If the water in a private well is found to be high in arsenic one of the corrective actions that can be taken is to close the well and connect to a public water supply.

A.1.6 Historic and Cultural Resources (HC)

Comment 012-F-3: Next issue needing study is why the Walpole Island First Nation, which exists on unceded lands within the 50-mile evacuation zone, is not allowed to have input into these proceedings.

Comment 028-K-6: WALPOLE ISLAND FIRST NATIONS' EXCLUSION FROM PROCEEDINGS Statement of the Contention and Comment A-14

Appendix A Purpose of Contention: To ensure that all Native American tribes and bands and First Nations have adequate notification by NRC of the proposed Fermi 2 licensing extension and environmental review proceedings, as due to them under applicable treaties, laws, and regulations; and to ensure that individual tribal members' interests are represented whether their tribal government intervenes or not on their behalf.

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

All of the following recognized First Nations (Native American) communities have treaty rights at Fermi, Unit 2. Each of these communities has legal standing in the Matter of the Fermi, Unit 2 LRA relicensing proceeding. ATHF3 contends that the SEIS must adequately address the impacts of continued operations at Fermi, Unit 2 on the health and well-being of the standing population:

Grand Traverse Band of Ottawa and Chippewa

Ottawa Tribe of Oklahoma

Wyandotte Nation

Saginaw Chippewa Indian Tribe of Michigan

Sault Ste. Marie Tribe of Chippewa Indians of Michigan

Ogema Little River Band of Ottawa Indians

Little Traverse Bay Bands of Odawa Indians

Delaware Nation

Hannahville Indian Community

Pokagon Band of Potawatomi Indians

Bay Mills Indian Community

Lac Vieux Desert Tribe

Forest County Potawatomi Community of Wisconsin

Shawnee Tribe

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

Huron Potawatomi, Inc.

Keweenaw Bay Indian Community

Lac Vieux Desert Band of Lake Superior Chippewa Indians Members of the above U.S. federally-recognized communities have treaty rights to hunt, fish and gather in the area of the Fermi, Unit 2 nuclear power plant. ATHF3 is concerned that if the NRC approves the proposed Fermi license extension, the health, safety and quality of life of the native population would be adversely affected. Numerous species of plants, fish, wild game and migratory birds are already being polluted by Fermi, Unit 2's routine discharges which bioaccumulate, thus making unhealthy or inedible the entire local food supply for current and future generations.

In addition, ATHF3 believes that the U.S. NRC should officially recognize the legal standing of the Walpole Island First Nations (WIFN), who reside within a 50-mile-radius of Fermi, Unit 2.

WIFN is an unceded island located between Michigan and Canada, populated by natives who A-15

Appendix A were never captured and who never surrendered; they are sovereign entities. However, the NRC has refused to allow WIFN to legally intervene in Fermi licensing proceedings because the NRC considers them to be Canadians not entitled to NRC-recognition or to U.S. treaty rights.

Comment 012-CC-3: The next issue I want in the record is why Walpole Island First Nation, which exists on unceded lands and is within the 50-mile evacuation zone, is not allowed to have input into the proceedings.

Response: These comments concern the NRCs recognition and notification of Indian tribal nations and the potential impacts from Fermi 2 license renewal on associated native populations.

As discussed in Section 4.9 of the Fermi 2 DSEIS, the NRC initiated consultations with the Advisory Council on Historic Preservation, the Michigan State Historic Preservation Office (SHPO), and 17 Federally recognized Indian tribes. The NRC provided information about the proposed undertaking (license renewal); defined the area of potential effect; and indicated that the NRC would comply with Section 106 of the National Historic Preservation Act of 1966, as amended (54 U.S.C 300101 et seq.), through the requirements of the National Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.), and as outlined in 36 CFR 800.8.

The NRC invited the Michigan SHPO and the tribes to participate in the identification of historic properties and any decisions potentially affecting historic properties and invited them to participate in the NEPA process.

Separate from these consultations, an Indian tribe from Ontario, Canada, the Walpole Island First Nation, sent a letter to the NRC stating that they would like an opportunity to thoroughly review the Fermi 2 license renewal process to ensure that their rights to fish and harvest resources in western Lake Erie and other nearby areas are not adversely impacted.

Accordingly, the NRC invited the tribe to provide input on the Fermi 2 license renewal environmental review process.

The DSEIS addresses potential human health impacts from Fermi 2 license renewal in Section 4.11. Section 4.12.1 presents an analysis of potential impacts specific to subsistence consumption of fish and wildlife by tribal populations.

A.1.7 Human Health (HH)

Comment 035-J-3: Radiation Releases from Nuclear Reactors National Academy of Sciences, Committee on the Biological Effects of Ionizing Radiation (BEIR) has stated that all ionizing radiation including low levels can produce broad spectrum non-malignant illnesses and cancer, morbidity, as well as genetic mutations. The BEIR report defines low level radiation as near zero to 100 millisieverts (mSv).

http://www8.nationalacademies.org/onpinews/newsitem.aspxRecordl D=11340 See also: http://www.radiation.org/about/index.html This is ignored, dismissed, and trivialized by the NRC recurrently over decades of statements.

Fermi 2, like all reactors has stipulated designed radiation releases into the biosphere continuously. Degraded equipment, operator error, and accidents expand the public exposure to ionizing radiation. The public is not provided with actual real time measurements and is misled by NRC/industry statements conflating "allowable" limits with "safe" or "legal" limits.

"Legal limit" is also misleading in that there is no punishment, sanction, or penalty for exceeding it. The cumulative effect of release exposures, varying in dose, experienced over time, are addressed by the NRC as though each release were one time only in impact on human cell tissue and the rest of the biosphere. The reality ignored by the NRC is that years or a lifetime of A-16

Appendix A exposure to releases from nuclear reactors, added to the fallout from nuclear weapons production and testing, nuclear medicine, X-rays, (all man made sources) have been producing illness, morbidity, and genetic mutations. It is convenient for the NRC, the National Nuclear Security Administration (NNSA) and the nuclear industry to address a given ionizing radiation exposure as though it existed in isolation and is not additive to all of the rest of releases and ongoing exposures around the region, the nation, and the world currently and historically and to behave as though once forgotten, ionizing radiation ceases to exist.

There is a cynicism in the NRC, the NNSA, and the nuclear industry not being upfront in stating clearly to the public that the decision was made in the 1940s, and continuing in the present, that there will be manmade ionizing radiation releases into the biosphere, that those releases will be whatever the nuclear regulators/industry decides and that the exposures will increase. Indeed, they have increased. Ionizing radiation and radionuclide particles move about the world, are ingested and breathed in and bioaccumulate up the food chain. They assault human cell tissue and the rest of the biosphere, in accord with their dose and half-lives. A problematic issue, obfuscated, unmeasured, unstudied---to that extent and intentional----doesn't exist in the public mind. A result desired and intended by nuclear advocates beginning with the Manhattan Project.

Response: This comment expresses concerns about the adequacy of radiation limits and the human health effects of exposure to radiation. The NRCs mission is to protect the public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. The NRCs regulatory limits in 10 CFR Part 20 for radiological protection are set to protect workers and the public from the harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. The dose limits are based on the recommendations of standards-setting organizations that reflect extensive scientific study by national and international organizations. The NRC actively participates in, and monitors the work of, these organizations to keep current on the latest trends in radiation protection.

Regarding the comment that the National Academy of Sciences report on radiation health effects (i.e., the Biological Effects of Ionizing Radiation (BEIR) report) concluded that there is no safe dose of radiation, the NRC disagrees with that assertion. The BEIR VII report entitled, Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2, does not assert that there is no safe level of exposure to radiation. Rather, the conclusions of the report are specific to estimating cancer risk. The report does not make any statements about no safe level or threshold. However, the report did note that the BEIR VII Committee said that the higher the dose, the greater the risk; the lower the dose, the lower the likelihood of harm to human health. Although the linear no-threshold model is still considered valid, the BEIR VII Committee concluded that the current scientific evidence is consistent with the hypothesis that there is a linear dose-response relationship between exposure to ionizing radiation and the development of radiation-induced solid cancers in humans. Further, the Committee concluded that it is unlikely that a threshold exists for the induction of cancers but notes that the occurrence of radiation-induced cancers at low doses will be small. The BEIR VII Committee concluded that the current scientific evidence is consistent with the hypothesis that there is a linear no-threshold dose-response relationship between exposure to ionizing radiation and the development of cancer in humans.

The linear, no-threshold dose response relationship describes the relationship between radiation dose and adverse impacts, such as incidents of cancer. Simply stated, in this model, any increase in dose, no matter how small, results in an incremental increase in health risk.

This theory is accepted by the NRC as a conservative model for estimating health risks from radiation exposure, recognizing that the model probably overestimates those risks. Based on this theory, the NRC conservatively establishes limits for radioactive effluents and radiation A-17

Appendix A exposures for workers and members of the public. Although the public dose limit in 10 CFR Part 20 is 100 mrem (1 millisievert (mSv)) for all facilities licensed by the NRC, the NRC has imposed additional dose constraints on nuclear power reactors. Each nuclear power reactor has enforceable license conditions that limit the total annual whole body dose to a member of the public outside the facility to 25 mrem (0.25 mSv). The amount of radioactive material released from nuclear power facilities is well measured, well monitored, and known to be very small. The doses of radiation that are received by members of the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few mrem) that resulting cancers attributed to the radiation have not been observed and would not be expected.

As part of its review of the Fermi 2 LRA, the NRC evaluated the projected environmental impacts from the operation of Fermi 2 during the license renewal term. The NRC staff reviewed Fermi 2s radiological data on effluent releases and the environmental monitoring program. The NRC concluded that the radiological impacts to human health would be SMALL during the license renewal term. The NRC staffs discussion of these issues appears in Sections 3.1.4 and 4.11.1 of this DSEIS.

Comment 035-J-4: Cancer Deaths from Fermi 2 Center for Disease Control statistical analysis shows that there is a significantly higher incidence of cancer deaths for Monroe, MI residents compared with incidences for the U.S. as a whole. This increase in Monroe cancer deaths correlates with the Fermi 2 going to full power.

This is ignored by the NRC and Detroit Edison:

RISING LOCAL CANCER RATE SUGGESTS LINK WITH FERMI REACTOR January 14, 2009 - The cancer death rate in Monroe County has been rising since the late 1980s, when the Fermi 2 nuclear reactor began operating, according to a new analysis.

The rise in cancer has been sharpest among children and adolescents, who are most susceptible to the harmful effects of radiation exposure. The analysis uses official data from the U.S. Centers for Disease Control and Prevention.

"The increasing cancer death rate among Monroe County residents, especially young people, suggests a link with the radioactive chemicals emitted from the Fermi reactor," says Joseph J.

Mangano MPH MBA, Executive Director of the Radiation and Public Health Project research group. "Because Monroe County has a low risk population that is well educated, high income, and has few language barriers, rising cancer rates are unexpected, and all potential causes should be investigated by health officials."

Fermi 2 reactor began "operating" June 21, 1985. However, it ran very little after the initial low-power start-up until a warranty run in January of 1988, marking the commercial start-up of the reactor. In the early 1980s, the Monroe County cancer death rate was 36th highest of 83 Michigan counties, but by the early 2000s, it had moved up to 13th highest. From 1979-1988, the cancer death rate among Monroe County residents under age 25 was 21.2%

below the U.S. rate. But from 1989-2005, when Fermi 2 was fully operational, the local rate was 45.5% above the U.S.

All nuclear reactors produce electricity by splitting uranium atoms, which creates high energy needed to heat water. This process also creates over 100 radioactive chemicals, not found in nature, including Strontium-90, Cesium-137, and Iodine-131.

While most of these chemicals are retained in reactors and stored as waste, a portion is routinely released into the local air and water. They enter human bodies through breathing and the food chain, and raise cancer risk by killing and injuring cells in various parts of the body.

They are especially harmful to children.

A-18

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

The original Fermi 1 reactor, which was the site of a "Partial Core-Melt Accident" in 1966, shut permanently in 1972.

DATA ON CANCER RISK FROM FERMI 2 RADIOACTIVE EMISSIONS

The Fermi 2 reactor is located in Monroe County, and started on June 21, 1985, not becoming fully operational until January 1988.

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

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

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

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

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

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

The Monroe County cancer death rate age 0-24 was 21.1% below the U.S. in 1979-1988 (before/during startup) was 45.5% above the U.S. in 1989-2005 (after startup) (3)

Monroe County has no obvious cancer risk. It has a high income, low poverty, well educated population with few language barriers and access to excellent medical care in nearby Detroit. (4)

Thus, an increase in cancer (especially to children) is unexpected. This change should be investigated, and one potential cause should be radioactive emissions from Fermi.

Sources:

1. Fermi 2 incurred "near miss" accidents on March 28, 2001 (emergency diesel generator was inoperable for over 7 days) and August 14, 2003 (loss of offsite power due to northeast blackout). Source: Greenpeace USA. An American Chernobyl: Nuclear "Near Misses" at U.S. Reactors since 1986. www.greenpeace.org, April 26, 2006.

2. U.S. Centers for Disease Control and Prevention, http://cdc.wonder.gov, underlying cause of death. Death rates are adjusted to 2000 U.S. standard population. Includes ICD-9 codes 140.0-239.9 (1979-1983) and ICD-1 0 codes COO-D48.9 (2000-2005). Whites account for over 95% of Monroe residents.

3. Cancer Death Rates, Monroe County vs. U.S. 1979-1988 and 1989-2005, age 0-24 Monroe County Deaths/100,000 Pop.

Period Cancer Deaths Avg. Pop. Monroe U.S. %vs. US 1979-1988 22 56,234 3.91 4.96 -21.2%

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

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

A-19

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

Increase in rate significant at p < .05.

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

Indicator Monroe U.S.

2006 Population 155,035 299,398,484 2000 % Foreign Born 1.9 11.1 2000 % Language other than English spoken 4.0 17.9 at home, age 5+

2000 % High School graduates, age 25+ 83.1 80.4 2000 % Homeownership 81.0 66.2 2004 Median Household Income $53,838 $44,344 2004 % Below Poverty 8.7 12.7 Source: U.S. Census Bureau, www.census.gov, 2000 population, State and County Quick facts Comment 028-K-15: The Petitioner requests a public hearing to consider the following Contention pertaining to "Significant New Unknown and Unanalyzed Conditions" reflected by the Applicant/Licensee's incomplete and obsolete analysis of public health impacts of authorized, routine, by-design radioactive releases by Fermi, Unit 2 into the surrounding environment. The Petitioner contends that the Applicant's ER fails to consider new and updated public health data, unavailable at the time of issuance of the original Operating License; further, the Petitioner contends that the Applicant fails to adequately consider Mitigation Alternatives which could significantly reduce the alleged significant environmental and public health impact of Fermi, Unit 2 operations. Therefore, the Petitioner invokes NEPA requirements and contends that further analysis is called for. In support of this Contention, the Petitioner submits into the docket the following public health impacts study by the Radiation and Public Health Project (RPHP): Potential Health Risks Posed By Adding A New Reactor At The Fermi Plant:

Radioactive contamination from Fermi 2 and changes in local health status, pages 1-21, January 10, 2012, Joseph J. Mangano, MPH, MBA, Executive Director, Radiation and Public Health Project (RPHP).

http://www.beyondnuclear.orq/storage/Manqano_corrected_Fermi_report_Jan_11_2012.pdf Comment 025-V-12: Public Health Impacts:

Within the Scope for review, the SEIS for the Fermi, Unit 2 LRA must include an updated and realistic analysis of current and projected public health impacts of authorized, routine, by-design radioactive releases by Fermi, Unit 2 into the surrounding environment. ATHF3 considers this issue to be in the category of "Significant New Unknown and Unanalyzed Conditions. The SEIS must consider new and updated public health data, unavailable at the time of issuance of the original Operating License; further, the SEIS must adequately consider Mitigation Alternatives which could significantly reduce the alleged environmental and public health impacts of Fermi, Unit 2's operations. Thus, further analysis is called for, under NEPA.

In support of this contention, ATHF3 submits into the docket the following public health impacts study by the Radiation and Public Health Project (RPHP):

Potential Health Risks Posed By Adding A New Reactor At The Fermi Plant: Radioactive contamination from Fermi 2 and changes in local health status, pages 1-21, January 10, 2012, Joseph J. Mangano, MPH, MBA, Executive Director, Radiation and Public Health Project A-20

Appendix A (RPHP). http://www.beyondnuclear.org/storage/Mangano corrected Fermi report Jan 11 2012.pdf Additionally, making the case for scoping and material relevance, ATHF3 submits revised excerpts from the following press release issued by the Fermi, Unit 3 COLA Intervenors:

February 2, 2012 NEW REPORT SHOWS INCREASE IN CANCERS AND MORTALITIES SINCE FERMI 2 NUCLEAR PLANT START UP Thursday -- Monroe, MI -- A new report submitted to the U.S. Nuclear Regulatory Commission (NRC) shows dramatic increases in cancer and mortalities in Monroe County since the start-up of the Fermi 2 nuclear plant. Using data from the Centers for Disease Control and Prevention (CDC), the report was prepared by Joseph Mangano, MPH, MBA, Executive Director of the Radiation and Public Health Project (RPHP).

One of the most shocking statistics shows that cancer death rates of young people (up to age 24) living in Monroe County exceeded the U.S. national rate by 28% from 1985 to 2008, a large shift from 1979 to 1984, when the county rate was 24% below the national average.

Cancer death rates for 25 to 44 year olds in Monroe County also jumped, from 22% below the U.S. national average to 4% above the national average. In 1985, Fermi 2 loaded fuel and began low power testing; full commercial operation began in January 1988.

There were nineteen (19) health indicators reviewed including infant mortalities, low birth weights and hospitalizations that showed increased incidence in Monroe County, compared to the U.S. national average. Ten (10) of these indicators were statistically significant, and four (4) others approached significance.

"These patterns in Monroe County raise serious questions about whether emissions from Fermi 2 harmed local residents," says Joseph Mangano. "Before any decision is made on the future of [nuclear power in Southeast Michigan,] unusual health patterns such as these must be studied thoroughly by federal and state health officials, and findings reported to the public,"

Mangano concluded.

Nuclear power plants emit numerous radioactive isotopes not only from accidents, but also as part of routine "normal" operations. In 2002, Fermi 2 was 10th highest in the U.S. for airborne emissions of Iodine-131 and 7th highest for Strontium-89. In 2007, Fermi 2 was 13th highest in emissions of Tritium. Fermi 2 experienced a serious accident Christmas Day 1993 that resulted in a discharge of two million gallons of slightly radioactive water into Lake Erie. The drinking water intakes for the City of Monroe and Frenchtown Township are located 1/4 mile downstream from the plant. Radioactive isotopes can bio-accumulate and bio-concentrate in the food chain much like DDT, PCB's and dioxins.

The Mangano Report was prepared for submission to the U.S. Nuclear Regulatory Commission (NRC) during the proposed Fermi 3 nuclear plant Draft Environmental Impact Statement (DEIS) public comment period. Mangano calls for more study before approval of a new Fermi 3 nuclear plant that is proposed adjacent to Fermi 2 and the closed Fermi 1. For these reasons, a growing Coalition of Fermi 3 Intervenors have called for Baseline Health Studies of Monroe County in order that elevated cancers from a proposed Fermi 3 could be measured.

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

A recent French study on childhood leukemia, posted at:

http://www.beyondnuclear.org/home/2012/1 / 12/french-study-finds-childhood-leukemia-doubled-aroundnuclear.html A-21

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

http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2696975/?tool=pubmed Both of these studies report elevated incidence of cancers associated with proximity to nuclear power plants.

Additionally, ATHF3 demands an SEIS analysis of the significant public health impacts of predictable accidental radioactive releases which can be expected to occur periodically due to human error or mechanical failure for the entire duration of Fermi, Unit 2's licensed operations.

As an example, at least one hundred gallons of radioactive floodwaters (contaminated wastewater) reached the Monroe County public sewer system in December 2010 when a wastewater holding tank valve malfunctioned at Fermi, Unit 2.

Comment 055-CC-1: First, for Ms. Perkins, overseeing the NEPA environmental review, I'd like to discuss the impact of authorized routine radioactive releases at Fermi 2. I'd like to submit new and significant information into the official record, a study by Joe Mongano, NPH, of the radiation and public health project who has refuted the clean power argument.

He has documented that from 1979 to 1988, before Fermi 2 began operating, the cancer death rate among Monroe County residents under age 21 was 20 percent below the US average.

However, from 1989 to 2005, after Fermi 2 became fully operational, the cancer death rate for a similar population rose to 45 percent above the US average. From 20 percent below to 45 percent above the US average, so nuclear is not clean and that should be in the public record.

Response: These comments address a report that claims to show increases in cancer and mortalities in Monroe County attributable to the operation of Fermi 2. The NRCs mission is to protect the public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. The NRCs regulatory limits in 10 CFR Part 20 for radiological protection are set to protect workers and the public from the harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. The dose limits are based on the recommendations of standards-setting organizations that reflect extensive scientific study by national and international organizations. The NRC actively participates in, and monitors the work of, these organizations to keep current on the latest trends in radiation protection.

The NRC staff evaluated the information contained in the report entitled, Potential Health Risks Posed by Adding a New Reactor at the Fermi Plant: Radioactive contamination from Fermi 2 and changes in local health status (RPHP report) (Mangano 2012). The RPHP report contains data on demographic characteristics, types of cancers, death rates, and cancer death rates for selected time periods reported for Monroe County, Michigan; the State of Michigan; and the United States. Additionally, the RPHP report contains selected data on radioactive effluent releases from Fermi 2 and other U.S. nuclear power plants.

Based on the NRC staffs review, the report is a compilation of selected data from publically available documents. The data does not provide a technical basis linking the cancer and death rate data to the radiological impacts from the operations of the Fermi 2 plant. The NRC staff found that the RPHP report does not contain information to determine the cause of the cancers.

The NRC staff reviewed the radiation doses to members of the public from radioactive effluent releases from the Fermi 2 plant in Section 3.1.4 of this DSEIS. Based on its review, the NRC staff concluded that the dose to members of the public were within the NRCs dose limits in 10 CFR Part 20.

A-22

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

The REMP monitors the local environment around the Fermi site, starting before the plant operates to establish background radiation levels and continues throughout its operating lifetime. The REMP provides a mechanism for determining the levels of radioactivity in the environment to determine whether there is any buildup of radioactivity from plant operations.

The REMP also measures radioactivity from other nuclear facilities that may be in the area (i.e., other nuclear power plants, hospitals using radioactive material, research facilities, or any other facility licensed to use radioactive material) and from natural background radiation and fallout from atomic weapons testing and nuclear accidents. Thus, the REMP monitors the cumulative impacts from all sources of radioactivity in the vicinity of the Fermi 2 plant. Based on its review of Fermi 2s REMP, the NRC staff concluded that there was no indication of an adverse trend (i.e., increased buildup) in radioactivity levels in the area and that there is no measurable impact to the environment from operations at Fermi 2.

The NRC staff does not agree that the RPHP report contains information that supports that there are significant radiological impacts associated with Fermi 2 operations greater than those determined in the GEIS. This conclusion is based on the NRC staffs review of radiological data from Fermi 2 discussed in Section 3.1.4 of this DSEIS. Therefore, as discussed in Section 4.11.1 of this DSEIS, the radiological impact to human health (i.e., radiation exposures to the public) remains a Category 1 issue with a SMALL impact.

Comment 038-AA-1: Because of the long time line of proposed operation until 2045 and the prospect of an additional 60 years allowed for decommissioning, much care must be taken to determine the environmental impacts for at least 90 years from now (until 2105 and possibly beyond).

As a result multiple scenarios must be considered;

1. Health and ecosystem impacts on the Monroe and Frenchtown Township drinking water from radioactive releases of normal operations, refurbishment and transport of large components.

Response: The NRC staff reviewed the radiation doses to members of the public from radioactive effluent releases from the Fermi 2 plant in Section 3.1.4 of this DSEIS. Based on its review, the NRC staff concluded that the dose to members of the public were within the NRCs dose limits in 10 CFR Part 20.

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

The REMP monitors the local environment around the Fermi site, starting before the plant operates to establish background radiation levels and continues throughout its operating lifetime. The REMP provides a mechanism for determining the levels of radioactivity in the environment to determine whether there is any buildup of radioactivity from plant operations.

The REMP also measures radioactivity from other nuclear facilities that may be in the area (i.e., other nuclear power plants, hospitals using radioactive material, research facilities, or any other facility licensed to use radioactive material) and from natural background radiation and fallout from atomic weapons testing and nuclear accidents. Thus, the REMP monitors the cumulative impacts from all sources of radioactivity in the vicinity of the Fermi 2 plant. Based on its review of Fermi 2s REMP, the NRC staff concluded that there was no indication of an adverse trend (i.e., increased buildup) in radioactivity levels in the area and that there is no measurable impact to the environment from operations at Fermi 2.

A.1.8 Postulated Accidents, including SAMA (PA)

Comment 028-K-1: The Applicants Fermi 2 Environmental Report fails to accurately and thoroughly conduct Severe Accident Mitigation Alternatives (SAMA) analysis to the A-23

Appendix A long-recognized and unaddressed design vulnerability of the General Electric Mark I Boiling Water Reactor pressure suppression containment system and the environmental consequences of a to-be-anticipated severe accident post-Fukushima Daiichi.

Comment 003-O-3: Another contention concerns the General Electric Mark I Boiling Water Reactor, and its containment's, long known, fatal design flaws. Fermi 2 is largest GE Mark I BWR in the world, almost as big as the melted down Fukushima Daiichi Units 1 and 2 reactor cores put together.

Comment 055-CC-3: Today I contend that the applicant's Fermi 2 environmental report is inadequate because it fails to accurately and thoroughly provide a severe accident mitigation alternatives analysis, a SAMA analysis that addresses the well-known and unresolved design vulnerability of the GE Mark One boiling water reactor pressure suppression containment system and severe accident consequences.

Response: In general, the probabilistic risk assessment (PRA) is an analytical tool used to identify accident scenarios, estimate the likelihood of each accident scenario, and estimate the consequences of each accident scenario. Fermi plant-specific PRAs were used to develop the Fermi SAMA analysis. The SAMA analysis was submitted as part of the LRA and was evaluated by the NRC staff. Section 4.11.1.2 and Appendix F of the DSEIS contain the NRC staffs evaluation..

The Fermi Level 2 PRA specifically simulates severe accident progression and containment challenges for a number of sequences that represent significant core damage scenarios and was used in the Fermi SAMA analysis to identify SAMAs. The analysis specifically addressed accident scenarios resulting in containment failures similar to those experienced at the Fukushima Dai-ichi plant and measures to mitigate or prevent those accidents. Specific design vulnerabilities of the General Electric Mark I Boiling Water Reactor pressure suppression containment system are being evaluated in the current term as part of the NRCs Fukushima lessons learned process. The Commission has ordered changes to the GE Mark I and II plants to address containment performance during design based accidents and severe accidents.

Additional information regarding the NRCs actions to enhance the safety of reactors in the United States based on lessons learned from this accident may be found at http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html.

While SAMA is a category 2 issue for Fermi 2, this comment is actually a challenge to the adequacy of the plants current licensing basis. The proper forum to raise safety concerns challenging the adequacy of the plants current licensing basis is through a petition under 10 CFR 2.206 for NRC action on the current license.

Comment 028-K-4: Fermi 2 and Fermi 3's safety and environmental risks due to common mode failures, and the potential for mutually initiating/exacerbating radiological catastrophes, involving the common Transmission Corridor (TC) shared by both units' reactors and pools, have been inadequately addressed in DTE's Fermi 2 License Renewal Application (LRA) and Environmental Report (ER). Also, the cumulative impacts associated with the proposed new Fermi 3 reactor cannot be excluded from DTE's Fermi 2 LRA and ER as "remote" or "speculative," for it is DTE's own proposal, and is advanced in the Fermi 3 COLA proceeding.

Such environmental and safety analysis is required on this unique local problem specific to Fermi 2 and 3. It can, and must, be dealt with in Severe Accident Mitigation Alternatives (SAMA) analyses, and must be treated as Category 2 Issues in the NRC's forthcoming Draft Supplemental Environmental Impact Statement (DSEIS), as required by NEPA and the AEA.

A-24

Appendix A Comment 003-O-4: The final contention is about the interconnected risks between the age-degraded Fermi 2, and the untested, proposed new Fermi 3 atomic reactor, including the vulnerability of both sharing a common off-site electricity transmission corridor.

Response: These comments assert that the common TC which would be shared by both Fermi 2 and 3 has been inadequately addressed in DTEs Fermi 2 LRA and ER. These comments also assert that the cumulative impacts associated with the proposed new Fermi 3 reactor cannot be excluded from DTEs Fermi 2 LRA and ER.

Fermi 2s or Fermi 3s compliance with requirements related to offsite power or availability of diesel generators, which is embedded in the commenters assumption that loss of the TC is a loss of defense-in-depth, is a current licensing basis issue that is being addressed now and is not unique to license renewal. Therefore, these assertions are outside the scope of license renewal.

The comments appear to assert that Fermi 3 must be considered in Fermi 2s site-specific SAMA analysis or else the SAMA analysis for Fermi 2s license renewal proceeding is inadequate. The Commissions rules regarding SAMA analysis are not so prescriptive as to require consideration of any particular method or set of events.

Comment 028-K-12: Contention 8 is regarding Severe Accident Mitigation Alternatives (SAMA) analysis: Pertaining to critical input data, as follows: The Applicant's Fermi, Unit 2 LRA Environmental Report (ER) and SAMA analysis are materially deficient in that the input data concerning evacuation time estimates (ETE) and economic consequences are incorrect, resulting in incorrect conclusions about the costs versus benefits of possible mitigation alternatives, such that further analysis is called for under NEPA.

Basis:

The first issue to address is Meteorology: The Fermi, Unit 3 COLA (Part 5, Appendix 4 "Emergency Plan: Radiological Monitoring and Assessment," Feb. 2014) incorporates the Raddose-V software program to 'provide real-time (as the release is occurring), site specific predictions of atmospheric transport and diffusion . . . determined using a variable trajectory plume simulation model, along with real-time or simulated scenario meteorological data ....

Raddose-V is currently in-use at the Fermi site [that is, Fermi, Unit 2]. (Emphasis added). The Petitioner agrees that the "variable trajectory" plume distribution model is more realistic and appropriate for the Fermi site than a "straight-line Gaussian" model would be, due to the Fermi site's lakeshore and riverside location (see, for example, Dr. Bruce Egan's testimony in support of the New York Attorney General's Intervention against the Indian Point LRA); however, the Petitioner contends that, for the same reason, the Fermi site's location necessitates a wider (larger) Emergency Planning Zone (EPZ) than is currently proposed by the Applicant and endorsed by the NRC. A "variable trajectory" model recognizes the uncertainties of predicting plume behavior, especially near bodies of water, and the Fermi site is also located near many major metropolitan urban communities. In other words, a "variable trajectory" model and a larger EPZ go hand-in-hand. Thus, while the Applicant's SAMA analysis assumes a 10-mile EPZ probabilistic model, the Petitioner contends that a 50-mile EPZ would be a more realistic and appropriate starting point for Fermi, Unit 2's location and would, importantly, yield different results. In fact, the Petitioner asserts that the Applicant's arbitrary and unrealistic EPZ probabilistic modeling served conveniently for underestimating and minimizing projected consequences of a Severe Accident.

Comment 025-V-9: Meteorology: The Fermi, Unit 3 COLA (Part 5, Appendix 4 "Emergency Plan: Radiological Monitoring and Assessment," Feb. 2014) incorporates the Raddose-V software program to "provide real-time (as the release is occurring), site specific predictions of A-25

Appendix A atmospheric transport and diffusion... determined using a variable trajectory, plume simulation model, along with real-time or simulated scenario meteorological data.... Raddose-V is currently in-use at the Fermi site [that is, Fermi, Unit 2]. (Emphasis added). ATHF3 agrees that the "variable trajectory" plume distribution model is more realistic and appropriate for the Fermi site than a "straight-line Gaussian" model would be, due to the Fermi site's lakeshore and riverside location (see, for example, Dr. Bruce Egan's testimony in support of the New York Attorney General's Intervention against the Indian Point LRA); however, ATHF3 contends that, for the same reason, the Fermi site's location necessitates a wider (larger) Emergency Planning Zone (EPZ) than is currently proposed by the Applicant/Licensee (DTE) and endorsed by the NRC. A "variable trajectory" model recognizes the uncertainties of predicting plume behavior, especially near bodies of water, and the Fermi site is also located near many major metropolitan urban communities. In other words, a "variable trajectory" model and a larger EPZ go hand-in-hand.

Thus, while DTE's SAMA analysis assumes a 10-mile EPZ probabilistic model, ATHF3 contends that a 50-mile EPZ would be a more realistic and appropriate starting point for Fermi, Unit 2's location and would, importantly, yield different results. In fact, ATHF3 asserts that DTE's arbitrary and unrealistic EPZ probabilistic modeling served conveniently for underestimating and minimizing projected consequences of a Severe Accident. Therefore, further analysis is called for, under NEPA.

Evacuation Time Estimates (ETE): DTE's evacuation time estimates are unrealistically low because the estimates rely on (1) an arbitrary and scientifically inappropriate probabilistic model for the Fermi site --- a 10-mile EPZ and minimal "shadow evacuation zone" and (2) the incorrect and unwise assumption that not everyone within ten miles of the Fermi site would have to evacuate, rather only those in the peak radiation plume. DTE minimized "shadow evacuation" of those outside the 10-mile EPZ, and DTE's ETE input parameters failed to consider instances of serious road construction delays, severe Michigan snow conditions (beyond 20%

impairment), and other pertinent factors including questionable local preparedness response capabilities required by 10 CFR 50.47(b)(1). Even after the Fukushima Dai-ichi disaster proved that the EPZ should be significantly expanded, DTE's analysis relies on the inappropriate, absurd and discredited 10-mile EPZ --- see Endnotes. Ironically: (a) the NRC's inconsistent guidelines (Dec. 2013) require Emergency Planning within fifty (50) miles of each plant for preventing the ingestion of releases, "such as through bans on contaminated food and water,"

according to the Congressional Research Service (Jan. 2014); and, (b) while the Raddose-V program is capable of calculating deposition at receptors in the 50-mile ingestion pathway, which appears to include, in the U.S., about 8 counties in Michigan and 8 counties in Ohio, DTE's Emergency Plan executes arrangements in support of emergency preparedness with only two county governments -- Monroe Co. and Wayne Co., Michigan. Thus, ATHF3 contends that the Applicant/Licensee's Emergency Plan is inadequate, and, therefore, further analysis is called for, under NEPA.

Economic Consequences: DTE's cost calculations assume an arbitrary and scientifically inappropriate EPZ probabilistic model for the Fermi site and, as a result, that a radiological release will affect only a relatively small area. Proper inputs specific to the Fermi site indicate a far larger affected area ---- potentially including the densely populated centers of Metro Detroit (MI), Ann Arbor (MI), Monroe (MI), Toledo (OH) and Windsor (ON); such scenarios would result in longer evacuation times and greater costs and consequences. Radiation plume exposure from a prolonged or delayed evacuation and consequent projected health-related costs in the affected population would be greater if an appropriate probabilistic model and correct input parameters were used in DTE's ETE. ATHF3 contends that realistic and reasonably foreseeable scenarios were ignored or underestimated by the Applicant/Licensee's cost-benefit analysis. Importantly, a proper Severe Accident analysis significantly affects whether local communities will receive commensurate safety enhancements. Furthermore, ATHF3 contends A-26

Appendix A that actual long-term recovery, remediation and redevelopment costs in a Severe Accident could be astronomical and that no reliable or credible cost analysis currently exists, given the uncertainties about long-term habitability criteria and cleanup standards. Therefore, ATHF3 contends that the development of a long-term cleanup policy and strategy must be completed as a prerequisite for any further licensing or relicensing actions.

Endnotes:

(1) Elaborating on the inadequacy of the 10-mile Emergency Planning Zone (EPZ) as a probabilistic model or tool for properly estimating reasonably foreseeable costs and consequences of a Severe Accident, ATHF3 submits the following statement from the public record:

http://www.state.gov/p/eap/rls/rm/2011/03/158441.htm Statement by U.S. Ambassador John V. Roos on Japans Earthquake and Tsunamis Remarks (excerpt) - Tokyo, Japan March 16, 2011 The United States Nuclear Regulatory Commission (NRC), the Department of Energy and other technical experts in the U.S. Government have reviewed the scientific and technical information they have collected from assets in country, as well as what the Government of Japan has disseminated, in response to the deteriorating situation at the Fukushima Nuclear Power Plant. Consistent with the NRC guidelines that apply to such a situation in the United States, we are recommending, as a precaution, that American citizens who live within 50 miles (80 kilometers) of the Fukushima Nuclear Power Plant evacuate the area or to take shelter indoors if safe evacuation is not practical.

We want to underscore that there are numerous factors in the aftermath of the earthquake and Tsunami, including weather, wind direction and speed, and the nature of the reactor problem that affect the risk of radioactive contamination within this 50 mile (80 km) radius or the possibility of lower-level radioactive materials reaching greater distances.

(2) ATHF3 contends that the Fermi site must have, at minimum, a readily-expandable 50-mile-radius evacuation plan that can be implemented instantly and effectively in a severe accident that indiscriminately exposes the public to significant radioactive releases. Southeast Michigan needs a comprehensive regional evacuation plan with routes, destinations, immediate notification, long-term housing facilities and financial support for displaced and relocated families and individuals, competent medical care for victims of radiation exposure, full disclosure of real-time radioactive release measurements and plume tracking, and funding for adequate event response capabilities including assistance and preparation for evacuation of vulnerable populations such as indigent and limited-mobility individuals of all ages and for all reasons. The evacuation plan must be coordinated with the entire Great Lakes region, including Michigan, Ohio and Ontario, Canada. The plan must be a realistic, four-season strategy with contingencies for severe weather conditions and impaired visibility/driving conditions; the plan must have flexibility to accommodate and adapt to unexpected road construction delays or other foreseeable scenarios. It should not be assumed that the residents located within the perimeter "shadow evacuation zone" will react any differently from those in the central Emergency Planning Zone (EPZ). The regional emergency communications capabilities must be augmented.

During and following an emergency event, there must be no suppression of public information and no transmission delay. To meet this standard, major infrastructural A-27

Appendix A changes must be implemented immediately. The public does not accept effectively being told to shelter in place and suck it up.

(3) Evacuate Monroe County in two-lane traffic?

The Michigan Department of Transportation is considering whether the City of Monroe, MI (immediately near the Fermi site) can reconfigure S. Monroe Street (M-125) and reduce the traffic flow from five lanes to three. While this would add about 30 parking spots, it could create a serious problem if there were ever an emergency at Fermi. M-125 is an evacuation route for Fermi, as well as an alternate route should there be an accident on 1-75. More than 1,400 people have signed an on-line petition against this reconfiguration.

Comment 025-V-10: ATHF3 has a contrarian point of view on the basic validity of the MACCS and MACCS2 codes as a proper diagnostic tool to assess economic costs and consequences.

ATHF3 refers to expert testimony supporting Pilgrim Watch's Petition to Intervene against the PNPS LRA: David Chanin, who coded the cost model of the MACCS and MACCS2, stated (Chanin Declaration for Pilgrim Watch, June 2007, ML071840568) that, "I have spent many many hours pondering how MACCS2 could be used to calculate economic costs and concluded it was impossible. and [sic] Speaking as the sole individual who was responsible for writing the FORTRAN in question, which was done many years prior to my original work in SAND 96-0957, I think it's foolish to think that any useful cost estimates can be obtained with the cost model built into MACCS2..The economic cost numbers produced by MACCS2 have absolutely no basis. If you want to discuss economic costs, I'd be glad to discuss SAND 96-0957, but the "cost model" of MACCS2 is not worth anyone's time."

For a cost analysis which supports ATHF3's argument, ATHF3 points to Sandia National Laboratory's CRAC-2 Report, "Calculation of Reactor Accident Consequences," (1982). The report stated that a core meltdown at Fermi, Unit 2 would have the following consequences:

8,000 "Peak Early Fatalities," 340,000 "Peak Early Injuries," 13,000 "Peak Deaths from Cancer,"

and $136 billion in property damage costs. Note that these 1982 numbers are unadjusted for demographic and monetary inflation trends and do not account for the current or foreseeable amount of spent fuel stored onsite.

Comment 028-BB-3: Yes, indeed, we all love the tax revenue from Detroit Edison; we appreciate the jobs and the trickle down and so on, but in a heart beat, literally a heart beat, in a super prompt criticality of 1.6 seconds, that reactor can go through the roof, and that means that we will not be just evacuating, we will be permanently relocating, the size of the state of Pennsylvania.

In 1982, the Nuclear Regulatory Commission commissioned a study from Sandia Labs called the "CRAC-II. This was the severe consequences of reactor accidents. At the Fermi 2, a reactor would be 136 billion dollars in property damage -- these are 1980 dollars -- 340,000 --

341,000 injuries; 13,000 deaths from cancer; 8,000 immediate deaths. Yes, we like the tax revenue, we like the jobs, but in a heart beat this reactor could be gone. And there has been no mitigation, Detroit Edison refuses to put in place hardened vent which would allow for the venting of the reactor if it over-pressurized.

Response: The information presented in these comments primarily discusses issues relating to emergency planning and cost calculations. The comments appear to assert that (1) Fermis 10-mi (16-km) plume exposure EPZ is inadequate and (2) Fermis SAMA analysis is inadequate because of its evacuation modeling assumptions. Regarding the first item, emergency preparedness and evacuation planning are part of the current operating license and are outside the scope of the environmental analysis for license renewal. Emergency preparedness A-28

Appendix A programs are required at all nuclear power plants and require specified levels of protection from each licensee regardless of plant design, construction, or license date. Requirements related to emergency planning are in 10 CFR 50.47 and Appendix E to 10 CFR Part 50. These requirements apply to all operating licenses and will continue to apply to facilities with renewed licenses. The NRC has regulations in place to ensure that existing emergency preparedness and evacuation plans are updated throughout the life of all plants. For example, nuclear power plant operators are required to update their ETEs after every U.S. Census or when changes in population would increase the estimate by either 25 percent or 30 minutes, whichever is less.

Additionally, the NRC assesses the capabilities of the nuclear power plant operator to protect the public by requiring the performance of a full-scale exercisethat includes the participation of various Federal, state, local government agencies, and tribesat least once every 2 years.

These exercises are performed in order to maintain the skills of the emergency responders and to identify and correct weaknesses. Within the context of license renewal, the Commission considered the need for a review of emergency planning issues during the 1991 rulemaking proceedings on 10 CFR Part 54, which included public notice and comment. As discussed in the Statements of Consideration for the rulemaking (56 FR 64943, 64966-67; December 13, 1991), the programs for emergency preparedness at nuclear power facilities apply to all nuclear power facility licensees and require the specified levels of protection from each licensee regardless of plant design, construction, or license date. As a result, the Commission determined that [t]here is no need for a licensing review of emergency planning issues in the context of license renewal (56 FR 64966-67). Therefore, issues related to emergency planning are outside the scope of the license renewal review.

Regarding the comments about evacuation modeling in Fermis SAMA probabilistic models, the NRC reviewed the evacuation assumptions and analysis and found them to be reasonable and acceptable for the purposes of the Fermi 2 SAMA analysis. Fermis evacuation modeling assumptions, as modeled in the MACCS2 computer code for offsite consequence analysis, are based on information from the Fermi Nuclear Power Plant Development of Evacuation Times Estimates (DTE 2014). This information includes time delays and travel speeds for a range of possible conditions. Fermis ETE report was prepared based on NRC guidance in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies (NRC 2011), and was reviewed for completeness. For the baseline Level 3 calculation found in Table D.1-24 of Attachment D to the ER (DTE 2014), DTE assumed 95 percent of the population within the EPZ would evacuate. To account for population increases in the future, DTE lowered the assumed evacuation speed from the determined network-wide evacuation speed of 12.8 meters per second (m/s) (28.6 mph) to 10 m/s (22.4 mph). In response to an NRC staff request for addition information on the network-wide evacuation speed and total time for evacuation, DTE affirmed that the evacuation assessment considered site-specific conditions for Fermi 2 and described how spatial dependences of the highway network, as well as population density, were modeled (DTE 2015a). In a sensitivity analysis found in Table D.1-25 of Attachment D to the ER (DTE 2014), DTE reported an increase in the population dose risk by 1 percent due to an assumed factor-of-2 reduction in the average evacuation speed from 10 m/s (22.4 mph) to 5 m/s (11.2 mph). Sensitivity values for the evacuation fraction of 90 percent and 99.5 percent were found to have very small influences on the population dose risk (< 0.005 percent) (DTE 2014).

As described by DTE, evacuation applies to the EPZ with a lower population compared to other areas surrounding the Fermi 2 site. The much larger population outside of the EPZ (about 55 times larger) does not evacuate in the assessment and accounts for a majority of the total population dose. For these reasons, the total population dose is not directly proportional to the fraction of individuals in the EPZ who do not evacuate. Because DTE used site-specific information, applied more conservative (lower) fractions for the evacuating population in the EPZ compared to guidance values (NRC 1997), and considered the effect of population A-29

Appendix A increases on evacuation parameter values, NRC staff concludes that the evacuation assumptions and analysis are reasonable and acceptable for the purposes of the SAMA analysis at Fermi 2.

The commenter also contends that there are no reliable or credible severe accident cost analyses that exist, implying that Fermis SAMA analysis is inadequate because of its analysis of economic consequence analysis. Fermis SAMA analysis uses the MACCS2 computer code for probabilistic offsite consequence analysis of a nuclear accident postulated to occur at some unknown time in the future. The MACCS2 code is the only system that models all the components of a nuclear accident offsite consequence analysis in a fully coupled fashion, including atmospheric transport and deposition, emergency phase and long-term phase protective actions, exposure pathways, dosimetry, health effects, and economic consequences.

In addition, MACCS2 enables the use of site-specific population and economic data and allows sampling of site-specific weather data to account for weather uncertainty at the time of the postulated accident. MACCS2 is an NRC-approved code for use in offsite consequence analysis in a SAMA analysis. In addition, the parameter values used by the applicant in its MACCS2 analysis were reviewed by the NRC staff and are considered reasonable for the purpose of a SAMA analysis.

The CRAC-2 report referred to by the commenters is the Calculation of Reactor Accident Consequences which is a study performed by Sandia Labs in 1982 for the NRC. The report estimated the consequences of the worst case accidents at nuclear power plants in the United States. The NRC has devoted considerable research resources, both in the past and currently, to evaluating accidents and the possible public consequences of severe reactor accidents. The NRCs most recent studies have confirmed that early research into the topic led to extremely conservative consequence analyses that are not useful for attempting to quantify the possible effects of very unlikely severe accidents. They often used unnecessarily conservative estimates or assumptions concerning possible damage to the reactor core, the possible radioactive contamination that could be released, and possible failures of the reactor vessel and containment buildings. These previous studies also failed to realistically model the effect of emergency preparedness. The NRC performed a state-of-the-art assessment of possible severe accidents as part of its ongoing effort to evaluate the consequences of such accidents.

The State-of-the-Art Reactor Consequence Analyses (SOARCA) project incorporates the results of more than 25 years of research to analyze the realistic outcomes of postulated severe reactor accidents, even though it is considered highly unlikely that such accidents could occur. The SOARCA project combined up-to-date information about the pilot plants layout and operations with local population and weather data and emergency preparedness plans. Plant changes that were accounted for included system improvements, training, emergency procedures, and offsite emergency response, as well as mitigation enhancements in response to the terrorist attacks of September 11, 2001. The SOARCA project is documented in NUREG-1935, State-of-the-Art Reactor Consequence Analyses Report (NRC 2012b), and in a public communications brochure, NUREG/BR-0359, Modeling Potential Reactor Accident Consequences (NRC 2012c). These reports can be accessed at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1935/ and http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0359/, respectively. In light of these more recent and more realistic analyses, these comments do not provide any new and significant information; therefore, no changes were made to the DSEIS.

Comment 025-V-4: B) That higher power output levels at Fermi, Unit 2 increase the risk of core melt through because of reactor penetrations placed on the bottom of the reactor in the BWR design.

A-30

Appendix A Comment 022-BB-3: And we've also come to realize that you don't need an earthquake or a tsunami to produce a condition on plant property known as "station blackout," where you have a failure of the primary electrical power and -- and a subsequent -- and a concurrent failure of backup electrical power.

Comment 026-CC-3: The fear being that as plants went up in flames, they would have to be abandoned and all control would be lost. And I put forth that Fermi 2, the old reactor with the breakdown phase risks, Fermi 3, the new reactor with the break-in phase risks, these are the worst of both worlds on the same site. A multiple reactor accident scenario.

Response: These comments are concerned with different types of accidents that could occur at Fermi 2. As discussed in Section 4.11.1.2 of this DSEIS, at the time of initial licensing, an applicant must demonstrate that the plant can withstand normal and abnormal transients and a broad range of postulated accidents without undue hazard to the health and safety of the public.

A number of the postulated accidents are not expected to occur during the life of the plant but are evaluated to establish the design basis for the preventative and mitigative safety systems of the plant.

The NRC staff identified no new and significant information related to postulated accidents during the review of DTEs ER for Fermi 2 (DTE 2014a), the site audit, the scoping process, or evaluation of other available information.

A.1.9 Waste Management (RW)

Comment: 025-V-15: Severe Accident Analysis of Fermi, Unit 2's Spent Fuel Pool:

ATHF3 hereby appeals to the U.S. NRC for reconsideration of a misguided ASLB ruling which is described below and which pertains directly and materially to the Scope of this relicensing action, including the Fermi, Unit 2 LRA Environmental Review and SEIS.

Submitted for

Reference:

--- The Petitions, Contentions and legal filings pertaining to a Petition to Intervene (Contentions 1 - 5) and subsequent adjudication, in the Matter of the Pilgrim Nuclear Power Station (PNPS)

License Renewal Application (2006 - ) -- Docket No. 05000293 (including Pilgrim Watch's Motion to Intervene, Contention 4, May 2006 - ADAMS Accession Number ML061630125).

Petitioners included Pilgrim Watch (http://www.pilgrimwatch.org) and the Commonwealth of Massachusetts Office of Attorney General.

Basis:

The ASLB and the NRC Staff have failed to apply their own rules and regulations pertaining to Severe Accidents involving spent fuel pools, which are vulnerable structures integral to a facility's normal operation. Consistently and incorrectly, the NRC has argued that all spent fuel issues are Category 1 and, therefore, "off the table" for practical purposes, having been generically resolved for all plants and not subject to further analysis in any relicensing proceeding. However, the NRC Rules say otherwise. The NRC applies the wrong section of the Rules and consequently misinterprets the whole regulation. The correct and appropriate interpretation of 10 CFR 51.53 is found in Section 5, not Section 6, in NUREG-1437 (GEIS).

Section 6 of the GEIS specifically deals with "The Uranium Fuel Cycle and Solid Waste Management" under normal operations; Section 5 deals with "Environmental Impacts of Postulated Accidents," including Category 1 generic "Design-Basis Accidents" and Category 2 site-specific "Severe Accidents. Section 5 includes definitions of "severe" and "accident" and does not limit these to reactor core accidents. Section 5 focuses on potential consequences to determine whether or not a potential accident is severe ---- and, thus, under Section 5, spent A-31

Appendix A fuel pool fires are a Category 2 issue, within the Scope of a site-specific Severe Accident Mitigation Alternatives (SAMA) analysis and, therefore, are a fundamental part of an Applicant's Environmental Report (ER) and subject to NEPA SEIS review and remedy. In other words, it is the consequences of an accident, not the source or cause, which determines whether such accident is properly categorized as Severe.

Of course, spent fuel pools typically contain a large inventory of high-level radioactive waste (HLRW) with an inherent and undisputed potential for catastrophic consequences in the context of an accident; ironically, a spent fuel pool event could conceivably cause a reactor core accident, thereby greatly magnifying cumulative consequences. Thus, the idea that a spent fuel pool is somehow outside the realm and scope of a SAMA analysis or SEIS and that even if mitigation alternatives are readily available and cost-effective (which they are) the plant nevertheless need not consider them, is ridiculous and absurd.

As a consequence of several re-racks implemented as part of an extremely misguided, NRC-endorsed policy, the Fermi, Unit 2 spent fuel pool currently stores approximately twice the amount of spent fuel as it was originally designed to hold (4600 vs. 2300 design), resulting in a precariously vulnerable condition which must be actively managed at all times. Indeed, Fermi, Unit 2 has the largest spent fuel pool capacity of any operating boiling water reactor in the country -- hence, the potentially greater magnitude of consequences of severe leaks, fires, or other structural breaches of the pool. Adding to the danger is the fact that the GE Mark 1 BWR design locates the spent fuel pool on the 5th floor, in an elevated, structurally vulnerable position. It is reasonable to estimate that, during the 20-year License Renewal period, Fermi, Unit 2 would generate an amount of spent fuel from normal operations equal to about fifty percent (50%) of that which it produced during the original 40-year Operating License period. At the same time, the current "structured coordination" between the Nuclear Energy Institute (NEI) and the NRC appears to be heading towards potentially indefinite "continued storage" of spent fuel with no technical specifications in place, now or for the foreseeable future.

Given that the Applicant/Licensee is charged with the primary responsibility for safely and securely handling its own high-level radioactive waste (HLRW) generated during the licensed life of the reactor, ATHF3 contends that there is a "gap of accountability" in DTE's plan as it is currently written in the Fermi, Unit 2 LRA and associated documents. The NRC's SEIS must finally address the unaddressed issue of financial accountability to the public taxpayers and utility ratepayers, who deserve a seat at the table on the issue of whether to assume new, additional, and uncertain future long-term liabilities implicit in the LRA.

Under 10 CFR 2.309, a Petitioner is required to show that the issue raised in a Contention is within the Scope of the proceeding. Contentions that seek compliance with NEPA must be based on the Applicant's Environmental Report (ER). (10 CFR 2.309(f)(2)). Under 10 CFR part 51 (c)(3)(ii), the Applicant is required to provide an ER that contains analyses of the environmental impacts of the proposed action associated with license renewal and the impacts of operation during the renewal term for those issues identified as Category 2 issues.

"Severe Accidents" are listed as a Category 2 issue in the applicable section on "Postulated Accidents. Contentions implicating Category 2 issues ordinarily are deemed to be within the Scope of License Renewal proceedings. See Turkey Point, supra at 11-13.

In conclusion, ATHF3 contends that DTE's Fermi, Unit 2 LRA Environmental Report (ER) utterly fails to address Severe Accident Mitigation Alternatives which could substantially reduce the risks and consequences associated with onsite storage of high level radioactive waste (HLRW),

especially, spent fuel pool water loss and fires. Likewise, the NRC's site-specific SEIS must address, within the scope of review, the significant environmental and public health A-32

Appendix A consequences of a Severe Accident involving Fermi, Unit 2's spent fuel pool and include an analysis and discussion of mitigating and fundamental alternatives.

Comment 035-J-6: Withdrawn Nuclear Reactor Fuel Rods Spent fuel is highly flammable as well as radioactive, yet is primarily stored in densely packed pools of water that contain several times more fuel than the nuclear reactor itself. If a fuel pool is damaged or loses its cooling system, fuel rods could be exposed, overheat, and catch fire, releasing massive quantities of radioactive material. NRC refuses to address the incredible risks these facilities pose, pretending the low likelihood of an accident makes the extreme consequences irrelevant. Hardened On-Site Storage systems (HOSS) should be used to store spent fuel more safely and securely at or near nuclear plants. HOSS reduces the immediate dangers spent fuel poses, without creating unnecessary risks.

75% of the total (72,000 metric tons, plus 2,000 tons more per year) of spent fuel is in fuel pools and allowed to remain there for as much as 60 years beyond licensed life of reactor operations.

The Generic Environmental Impact Statement (GEIS) on Waste Confidence, NUREG-2157 underestimates the risk of fuel pool fires and ignores the safer alternative of hardened on site storage at the nuclear plant sites. Dry cast storage at Dai-ichi survived the number 9 earth quake, tsunami, loss of the electrical grid, and loss of back up diesel generators much better than the reactors themselves and their fuel pools.

There is a consensus among the U.S. government and the nuclear industry for more than 60 years that withdrawn spent fuel rods are lethal in minutes unless shielded. To continue to produce them and intend to abandon them into the biosphere (deep underground dump) is profoundly immoral and a burden and a curse on future generations into eternity. It is premeditated murder.

There is no basis in science, engineering, the behavior of the nuclear industry and the Nuclear Regulatory Commission (NRC) for confidence that high level radioactive withdrawn fuel rods (spent fuel) can or will be managed with no risk to the biosphere for as long as the radioactivity last. For the NRC and the nuclear industry to assert probabilistic assessments of what will happen to radioactive material over 240,000 (plutonium) to a billion years for some radionuclides, is a fraud and a con game. There is insufficient data for such probabilistic assessments to have validity. Apart from that, even a small likelihood of the risk of a serious untoward event involving spent fuel could be catastrophic for all life forms, air, water and land.

Nuclear accidents cannot be undone.

NRC's Waste Confidence policy assumes that all nuclear spent fuel is the same. This is far from the truth. The industry is moving toward new fuel types, such as MOX (mixed oxide) and high-burnup fuels, which are more radioactive, dangerous, thermally hot and difficult to store and transport safely.

Fermi 2 has an over crowded fuel pool with 600 tons of spent fuel. It is the largest GE Mark 1 reactor. It is at risk for weather events, loss of coolant, or terrorist attack. Like Dai-ichi reactors and all 23 GE Mark 1 reactors in the U.S., it's cooling pool does not have back up cooling. It has no diesel generators for cooling pool water circulation to rely on in loss of electrical grid emergency. There are 1,331 highly radioactive irradiated spent nuclear fuel assemblies in Fukushima Dai-ichi Unit 4's storage pool. Fermi 2's high-level radioactive waste storage pool contained 2,898 irradiated nuclear fuel assemblies by spring 2010, according to U.S. Department of Energy projections documented in the Yucca Mountain Final Environmental Impact Statement (Feb. 2002, Table A-7, Proposed Action spent nuclear fuel inventory).

Fermi 2 could generate another 443 irradiated nuclear fuel assemblies between spring 2010 and spring 2014, meaning by then, a total of 2,898 + 443 = 3,341 irradiated nuclear fuel A-33

Appendix A assemblies. So, Fermi 2's storage pool would hold 2.5 times as much high-level radioactive withdrawn fuel rods than Fukushima Dai-ichi Unit 4's pool! A cooling pool fire at Fermi 2 would be worse than a meltdown of the Fermi 2 reactor itself in its release of a larger dose of radiation into the environment, resulting in widespread illness, deaths, and genetic mutations. If the radioactivity releases from either location (the reactor, or the irradiated nuclear fuel storage pool) are bad enough, the entire site might have to be evacuated. No intervention would then be possible. Not only could reactor meltdowns proceed out of control, but high-level radioactive spent fuel storage pool fires could result -- emitting orders of magnitude more hazardous radioactivity into the environment than even a reactor meltdown, as the pools are not contained within a radiological containment structure. Fermi 2 is lacking hundreds of structural welds on various floors of the reactor building, never put in place like they were supposed to have been some 40 years ago. This has meant that it could not safely withstand the weight of the crane and cask necessary to move the sufficiently cooled spent fuel to Hardened Onsite Storage (HOSS).

Comment 028-K-2: The Environmental Report for Fermi 2 does not satisfy the National Environmental Policy Act (NEPA) or 10 C.F.R. § 51.45(c) because it does not consider a range of mitigation measures to mitigate the risk of catastrophic fires in the densely packed, closed-frame spent fuel storage pools at Fermi 2.

Comment 028-K-3: The Environmental Report for Fermi 2 does not satisfy the Atomic Energy Act or NEPA because (1) it does not make any site-specific safety and environmental findings regarding the storage and ultimate disposal of the spent fuel that will be generated during the license renewal term and (2) the NRC has no valid generic findings on which the Environmental Report could rely.

Comment 003-O-1: The first is about the risk of catastrophic irradiated nuclear fuel storage pool fires. Fermi 2's storage pool holds around 600 tons of irradiated nuclear fuel, more than all four destroyed units at Fukushima Daiichi put together (419 tons).

Comment 003-O-2: The second radioactive waste contention is about the lack of safety and environmental assurances, since the U.S. Nuclear Regulatory Commission's (NRC) "Nuclear Waste Confidence" policy was declared null and void two years ago by the D.C. Circuit Court of Appeals, and NRC has not yet replaced it.

Comment 038-AA-2: Because of the long time line of proposed operation until 2045 and the prospect of an additional 60 years allowed for decommissioning, much care must be taken to determine the environmental impacts for at least 90 years from now (until 2105 and possibly beyond).

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

(2) Assuming that the recent NRC plan to allow storage of rods in on site pools with stands court challenges, what effect does this present for the 600 tons already stored since the reactor started operation in 1988. 600 tons is beyond the design capacity now, so if DTE is unable to transfer them to outside dry casks, what plan and impacts are there for continued production of this high level waste. It is our understanding that DTE's plan to transfer the high level waste to dry casks is impaired because of defective welds.

Comment 038-AA-3: Because of the long time line of proposed operation until 2045 and the prospect of an additional 60 years allowed for decommissioning, much care must be taken to determine the environmental impacts for at least 90 years from now (until 2105 and possibly beyond).

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

(3) If no final disposal site is developed or the disposal is projected for far into the future and DTE needs to transfer the waste to outside casks, detailed analysis must be performed.

Comment 038-AA-4: Because of the long time line of proposed operation until 2045 and the prospect of an additional 60 years allowed for decommissioning, much care must be taken to determine the environmental impacts for at least 90 years from now (until 2105 and possibly beyond).

As a result multiple scenarios must be considered; []

(4) The impact of storage and transport of low level and intermediate level radioactive waste must also be considered.

Comment 025-BB-2: As it stands right now, there's some 700-plus tons of eradiated spent fuel, a much more dangerous substance than when it first went in. When it comes out, it is a material that is just deadly and the -- the dangers associated with this cannot be, you know, underestimated over -- anyway, you get my point.

So, and my understanding is that the welds that are in place up there, on top of the reactor and the pools that contain this spent fuel, those welds are not -- don't have enough integrity, that allow removal of the spent fuel. Even if -- even if DTE was willing to commit to a dry cask storage on site there, it's my understanding that they can't even get the material safely down, out of the existing pools, so it's just -- you know, so to continue to extend the license, continue to pile up material that has no place to go, is not logical, it's not rational; it's extremely dangerous.

Comment 028-BB-4: Meanwhile, the product out there that they are really producing, that lasts forever, is high-level nuclear waste. If you refine it a bit, you could turn it into a nuclear weapon.

This is the most volatile material in the world and yet this is what they produce and this is what they don't know what to do with to this day. They have been authorized since 2010 to remove that fuel from the fuel pool, they have not been able to do so. Because when they looked at the blueprints, they found that we're missing welds on the fifth floor, 768 missing welds on -- on the fifth floor. The crane would not support the load to break it down 100 feet, five floors; they still don't know what to do with it, but yet they'll make more. They'll make promises: we'll figure it out later. We'll adhere to a human and senseless paradigm, that we are so smart today in this room that: well, we don't know what to do just yet, but we'll figure it out later.

Comment 026-BB-2: So, you know, you draw a line around Fermi 2. Fermi 2 is identically designed, only it's as big as Fukushima Daiichi Units 1 and 2 put together and scaled up. And the issue has been mentioned of the radioactive waste. The radioactive waste risks here are actually much greater than at Fukushima Daiichi and if the official version of things is true at Fukushima Daiichi, we very narrowly avoided a pool fire there. I mean, you may remember St. Patrick's Day of 2011, the desperate attempts to drop water into Unit 4 by helicopter, very reminiscent of scenes from Chernobyl. And the official version is: Oh, that wasn't necessary. It turns out there was water in the pool the whole time.

Obviously, there was a lot of concern that that was not the case, and so much so that once you lose the water, you can't send people in, because they'll get a fatal dose of radioactivity from the uncovered waste within a very short period of time.

So, here at Fermi, as was mentioned earlier by Carol Izant, there is well over 600 tons of high-level radioactive waste perched at the top of Fermi 2. They've had a permit to bring it down for several years, but they can't because of structural deficiencies in the reactor building.

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Appendix A And even when they bring it down, it's planned to be put into whole tech (ph) casks and an industry whistleblower named Oscar Suranyi from Hominoff (ph) Edison, an NRC whistleblower, Dr. Ross Landsman from Region 3, questioned the structural integrity of the whole tech casks sitting still, on-site storage, because of major quality assurance violations in their design and manufacture, let alone moving down the railroads at 60 miles per hour, which is the plan at some point.

So, as was mentioned earlier by Michael Keegan, radioactive waste -- you know, we may enjoy the benefits of the electricity and the money that's flowing in the present -- radioactive waste is a curse on all future generations; they're going to get to deal with this. We're 70 years into this, we have a mountain of radioactive waste 70 year high, and we don't know what to do with the first cupful that was generated by Enrico Fermi on December 2nd, 1942, as a part of the Manhattan Project.

Comment 026-CC-4: And my concluding thoughts will be about nuclear waste. The nuclear waste confidence report that came out today we look forward to reading and we will be ready to go back to court, if need be. Our coalition of environmental groups and states, including the states of New York and Vermont, are very interested in what the NRC has to say at this point about nuclear waste confidence, about expedited transfer of a radiated nuclear fuel from pools to dry casts.

We call for hardened on-site storage. The NRC staff's study of this issue revealed that a - -

even a small pool fire could render 9,400 square miles uninhabitable resulting in 4.1 million nuclear evacuees. We -- we put forth a petition for rule making earlier this year calling for this license extension proceeding, its rules, to be revised in light of this new information and we called for a stay on this proceeding, but were denied just last week by the Nuclear Regulatory Commission.

Comment 013-CC-1: I'm coming also to speak on behalf of myself, but also mother earth because if we ruin the mother, we won't -- we will be homeless and soon gone the way of the dinosaurs, a failed experiment, which leads to my complaint that's been the same ever since Davis-Besse and Fermi 2 were built. What are you going to do with the waste?

We're almost through a license period and we still don't have that answer. We were all told that they'll build a place for it. Of course, we weren't in that mentality of not in my backyard. It wasn't going to stay here, but it sure looks like it's going to stay here, and until we know what we're doing, you know, we're sitting right on Lake Erie. The chance -- if we have an accident, what happens?

I'm sure you're all knowledgeable people with credentials and quite bright, but I have to question even more then: what are you thinking? Is this the legacy you want to leave for your kids and your grandkids, truly?

I guess my final word is if you don't know what you're going to do with it, don't make more.

Thank you.

Comment 019-CC-1: In regards to waste storage in Yucca Mountain, we've got to realize that not only are we dealing with spent fuel rods, but you all have to understand the reactor cores themselves become high level radioactive waste. No -- I don't hear anybody talking about this.

Nobody has an answer for this.

These reactors are not going to end up at Yucca Mountain and, you know, for an example of a decommissioning of a plant, the shipping port reactor, the first commercial reactor in America, a tiny reactor -- I think it was 60, 61 megawatts -- was hauled to the state of Washington for burial.

Now you're not going to do that with a Fermi 2 reactor, 1,140 megawatts, whatever.

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Appendix A My understanding is the building - when decommissioning comes -- rolls around, the reactor building will have to be flooded and the reactor core will have to be cut up with torches underwater and then we still know -- you know, nobody knows what's going to happen.

So Yucca Mountain is not a solution either and actually if -- even if Yucca Mountain were in operation, let's say we're going to haul some fuel rods out to Nevada. I can imagine sitting in a construction zone on I-75 next to a semi carrying a - - a bunch of casts. I guarantee you're going to get a whole lot more than a dental x-ray.

Comment 025-CC-6: You -- you again, it's just -- it's wild, you know, when you think about the fact that there's 600-plus tons sitting up in those pools and not a - not a single ounce of it has been removed and placed into some kind of hardened on-site storage. I mean, there's no talk of that. It's -- you know, and to continue to just continue to produce more and stockpile it on site, this is -- this is not logical; and I thank you.

Comment 029-CC-5: Number five, the Fukushima disaster -- excuse me -- was attributable as much to the failure of their supplemental - supplemental generators as it was to the tidal wave that came over the seawall and which means in our terms, if something were to go wrong with the supplemental -- in the case of an emergency at Fermi, without electricity, the storage pool will begin -- will begin to disintegrate in about four hours and twelve minutes. This is from DTE documentation. All right.

Comment 027-CC-1: I live in a part of Frenchtown where we have septic tanks. Now, what does that have to do with Fermi? Not a whole lot, but flushing your toilet's a pretty important part of your life. Being able to flush it and have things go where they're supposed to go is pretty important and I think we're flushing the toilet of nuclear waste and we don't have a seepage bed for it. We don't have a sewage treatment plant and we don't have a seepage bed.

I don't think we should play political games with nuclear waste as I heard earlier tonight. I don't think we need to blame one party or another. I don't think that's the answer. The government unwisely assumed the job of disposing of nuclear waste from nuclear power plants a long time ago.

The -- I -- I do feel that if the nuclear power plants had to take care of their own nuclear waste, we wouldn't be here. I've also heard talk about reprocessing nuclear waste. That's not a very good answer. Look it up on the internet. You can find out a lot more about it. Bomb grade plutonium is one of the byproducts of the reprocessing of nuclear waste as is a lot of pollution of water and the bomb grade plutonium is piling up and who knows who'll get a hold of it if things go bad.

The -- oh, there -- there was talk about Yucca Mountain. There's more nuclear waste in the United States that can fill Yucca Mountain. So Yucca Mountain, even if it were filled up, wouldn't be the answer to the nuclear waste that are sitting right in the United States as we talk.

Let's see here. Oh, Manny already mentioned that the Michigan State Legislature opposes the disposal site in Ontario while they approve of a place like Fermi 2 and it's a little bit inconsistent as far as I'm concerned. I'm wondering what other industry in our country has the opportunity to have its waste products taken care of by the government? That's us, folks.

Even DTE coal plant here in Monroe is responsible for their fly ash and their emissions and they've built that responsibility into their rate structure. We're paying for it. It's being -- it's being controlled. It's meeting standards that have been set by the EPA, so I say that the cost of disposal of nuclear -- if -- if the costs of the disposal of nuclear waste were part of nuclear power's operating expenses, I doubt if we would be here.

A-37

Appendix A And I hope that the environmental impact statement considers even though it isn't really legally a part of the whole picture, the fact that we do have the problem of nuclear waste. It's going to affect the environment somehow somewhere, even if -- if -- if it isn't in the official statements.

Thank you.

Response: The NRCs regulations require that spent nuclear fuel be stored and maintained in a safe and secure manner while the plant is operating and after the plant operating license expires. The spent fuel remains under the direct control of the licensee and the regulatory oversight of the NRC until its ultimate disposition.

DTE is required to safely handle, process, and store spent fuel in accordance with NRC regulations. Spent fuel is stored onsite in a combination of two types of NRC-approved methods: storage in a spent fuel pool and in dry casks. Both of these methods maintain the spent fuel in a safe configuration. Additionally, to ensure the long-term safety of spent fuel, DTE is required by 10 CFR 50.54(bb) to maintain adequate funding for the safe long-term storage of spent fuel on site.

The issue of an accident involving spent fuel (i.e., spent fuel fire) was specifically addressed by the NRC in two Petitions for Rulemaking (PRM) (PRM 51-10 and PRM 51-12) submitted by the Attorney General of the Commonwealth of Massachusetts and the Attorney General of the State of California, respectively. The Federal Register Notice containing the details of the petitions and the NRCs evaluation are available to the public on the NRCs Web site (www.NRC.gov) under ADAMS No. ML081890124.

The Petitioners requested that the NRC initiate a rulemaking concerning the environmental impacts of the high density storage of spent nuclear fuel in spent fuel pools. The Petitioners asserted that new and significant information shows that the NRC incorrectly characterized the environmental impacts of high-density spent fuel storage as insignificant in its GEIS (NUREG-1437) for the renewal of nuclear power plant licenses. Specifically, the Petitioners asserted that spent fuel stored in high-density spent fuel pools is more vulnerable to a zirconium fire than the NRC concluded in its NEPA analysis.

The Commission denied the petition for rulemaking, concluding as follows:

Based upon its review of the petitions, the NRC has determined that the studies upon which the Petitioners rely do not constitute new and significant information. The NRC has further determined that its findings related to the storage of spent nuclear fuel in pools, as set forth in NUREG-1437 and in Table B-1, of Appendix B to Subpart A of 10 CFR Part 51, remain valid.

Thus, the NRC has met and continues to meet its obligations under NEPA. For the reasons discussed previously, the Commission denies PRM-51-10 and PRM-51-12.

In Section 4.11.1.2 of this DSEIS, the NRC staff concluded that the impact of design-basis accidents and severe accidents at Fermi 2 during the license renewal term would be SMALL.

For the ultimate disposal of spent fuel, the NRC is aware that geologic disposal at Yucca Mountain or elsewhere may not be available in the timeframe that was originally envisioned. As an alternative, the Commission has considered the storage of spent fuel on reactor sites where it is generated. Section 4.11.1.2, Onsite Storage of Spent Nuclear Fuel, in the NRCs 2013 GEIS (NUREG-1437) (NRC 2013b) discusses the impacts from the onsite storage of spent fuel at nuclear power plant sites during the license renewal term. Based on its evaluation, the NRC concluded that the environmental impact for the onsite storage of spent nuclear fuel during the license renewal term was small at all nuclear power plants.

In Section 4.13 of this DSEIS, the NRC staff concluded that impacts from the onsite storage of spent nuclear fuel during the license renewal term would be SMALL.

A-38

Appendix A Regarding the long-term storage of spent nuclear fuel beyond the licensed life for operation of a reactor, on August 26, 2014, the Commission approved the Continued Storage Rule at 10 CFR 51.23 and associated NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NRC 2014b). The Continued Storage Rule adopts the generic impact determinations made in NUREG-2157 and codifies the NRCs generic determinations regarding the environmental impacts of continued storage of spent nuclear fuel beyond a reactors operating license (i.e., those impacts that could occur as a result of the storage of spent nuclear fuel at at-reactor or away-from-reactor sites after a reactors licensed life for operation and until a permanent repository becomes available). Therefore, the NRC staff concludes that the information in NUREG-2157 provides the appropriate NEPA analyses of the potential environmental impacts associated with the continued storage of spent fuel beyond the licensed life for reactor operations at Fermi 2. The environmental impacts assessed in NUREG-2157 regarding continued storage are deemed incorporated by rule into the Fermi 2 license renewal DSEIS pursuant to 10 CFR 51.23(b).

On the issue of requiring DTE to store spent fuel in a hardened onsite storage (HOSS) facility, the NRC is addressing the issue of HOSS through the rulemaking process; therefore, the issue of requiring HOSS is outside the scope of the NRCs environmental review. Current status, as well as all information submitted in support of the ongoing rulemaking, can be found by accessing www.regulations.gov and searching for the docket number NRC-2009-0558.

On the issue of financial accountability, the NRC assumes that the comment is addressing financial accountability following a reactor accident. Financial liability issues resulting from a reactor accident are governed by the Price-Anderson Nuclear Industries Indemnity Act of 1957, as amended (Price-Anderson Act) (42 U.S.C. 2210). The Price-Anderson Act is a Federal law that governs liability-related issues for all nonmilitary nuclear facilities constructed in the United States before 2026. The main purpose of the Price-Anderson Act is to provide prompt and orderly compensation to the public who may incur damages from a nuclear incident, no matter who might be liable. The Price-Anderson Act provides omnibus coveragethe same protection available for a covered licensee or contractor indemnifies any persons who may be legally liable, regardless of their identity or relationship to the licensed activity. Because the Price-Anderson Act channels the obligation to pay compensation for damages to the licensee, any party with a claim only needs to bring its claim to the licensee or contractor.

Comment 019-CC-4: Some of the waste is being removed. They're -- they're -- they're dumping it in Iraq. They're using it as munitions, the depleted uranium munitions. We're spreading this stuff in the Middle East and the birth defect rate is skyrocketing. I think it's criminal. It's criminal.

Response: This comment expresses concern that radiological waste generated from nuclear power plant operations is being used in the manufacture of depleted uranium munitions.

Depleted uranium is produced during the uranium enrichment process and is typically found in spent fuel elements or waste material generated during uranium recovery (referred to as byproduct tailings or residues). Depleted uranium has some commercial applications, including in counterweights and in the manufacturing of ammunitions used to pierce armor plating, such as those found on tanks, in missile nose cones, and as a component of tank armor.

Additionally, depleted uranium can be blended with highly enriched uranium, such as that from weapons, to make reactor fuel.

As described in Section 3.1.4.4, spent fuel generated from the operation of Fermi 2 is stored on site in either the spent fuel pool or on an independent spent fuel storage installation pad.

Radioactive waste from commercial nuclear power plants licensed by the NRC is not used to make weapons, and there are currently no other approved uses of spent fuel that would allow A-39

Appendix A for the extraction of any depleted uranium from the spent fuel. The NRC requires its licensees to maintain strict control over the use, storage, transportation, and disposal of radioactive material and waste. Spent nuclear fuel is stored at the reactor site under strict controls for its safety and security in accordance with NRC regulations.

For additional information on depleted uranium, please refer to the NRCs Web site on the topic:

http://www.nrc.gov/about-nrc/regulatory/rulemaking/potential-rulemaking/uw-streams/bg-info-du.html.

A.1.10 Special Status Species and Habitats (SH)

Comment 025-V-16: Endangered Species at the Fermi site:

Within the Scope for review, the SEIS for the Fermi, Unit 2 LRA must include an updated analysis of current and projected impacts of operations at Fermi, Unit 2 on the threatened and endangered species of fish and wildlife (flora and fauna) which rely on the Fermi site for habitat and ecosystem services. ATHF3 considers this issue to be in the category of "Significant New Unknown and Unanalyzed Conditions. The SEIS must address the current list of state and federally-protected species, updated since the time of issuance of the original Operating License; further, the SEIS must adequately consider Mitigation Alternatives which could significantly reduce the environmental impacts of Fermi, Unit 2's operations. Thus, further analysis is called for, under NEPA.

In support of this contention, ATHF3 submits into the docket the following information:

The Bald Eagle, the Eastern Fox Snake and the Mississauga Rattlesnake live at the Fermi site and must be included in the SEIS and the Applicant's LRA.

Also at the Fermi site are two bird species (Red Knot and Piping Plover) and two bat species (Northern Long-Eared Bat and Indiana Bat).

Other species at the Fermi site include:

Karner Blue Butterfly

Eastern Prairie fringed Orchid

Three species of mussels: Northern Riffleshell, Snuffbox Mussel, and the Rayed Bean.

Response: The comment expresses concern regarding the impacts from operation of Fermi 2 on rare species, such as State and Federally listed species.

The NRC staff analyzed the potential impacts to Federally listed species in Sections 3.8 and 4.8 of this DSEIS, including potential impacts to the red knot (Calidris canutus), piping plover (Charadrius melodus), northern long-eared bat (Myotis septentrionalis), Indiana bat (Myotis sodalist), eastern prairie fringed orchid (Platanthera leucophaea), Karner blue butterfly (Lycaeides melissa samuelis), northern riffleshell (Epioblasma torulosa rangiana), snuffbox mussel (Epioblasma triquetra), and rayed bean (Villosa fabalis). In addition, the NRC staff is consulting with the U.S. Fish and Wildlife Service (FWS) pursuant to Section 7 of the Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 et seq.) (Appendix C to the DSEIS). If the NRC staff determined that continued operations could have an adverse effect on Federally listed species, as part of the ESA Section 7 consultation process, the NRC would issue a biological assessment, and the FWS would issue a Biological Opinion in accordance with the provisions of formal consultation at 50 CFR 402.14. The FWS could include a list of reasonable and prudent measures in a Biological Opinion necessary or appropriate to minimize A-40

Appendix A impacts on Federally listed species. However, as described in Section 4.8 and Appendix C to the DSEIS, the NRC staff determined that continued operation of Fermi 2 is not likely to adversely affect any Federally listed species. Therefore, formal consultation and mitigation measures (in the form of reasonable and prudent measures) would not be appropriate.

In Sections 3.6 and 4.6 of the DSEIS, the NRC staff analyzed the potential impacts to the bald eagle, the eastern fox snake, and other rare and State-listed species. The NRC staff determined that impacts to all terrestrial resources (including rare and State-listed species) would be SMALL for all Category 1 and Category 2 issues. For noncooling system impacts, the NRC staff made this determination because landscape maintenance activities, stormwater management, elevated noise levels, and other ongoing operations and maintenance activities that DTE might undertake during the renewal term would primarily be confined to disturbed areas of the Fermi site. In addition, these activities would not have noticeable effects on terrestrial resources, nor would they destabilize any important attribute of the terrestrial resources on, or in the vicinity of, the Fermi site. Therefore, mitigation measures would not be appropriate.

Regarding the eastern massasauga rattlesnake, in Section 3.6 of the DSEIS, the NRC staff determined that this species is not likely to occur near the Fermi site. This determination was based, in part, on consultation with FWS pursuant to ESA Section 7. During this consultation, the NRC and FWS did not identify the eastern massasauga rattlesnake as a species that has the potential to be affected by the proposed license renewal. In addition, the Michigan State University Extension (MSUE) (2013), on behalf of the Michigan Department of Natural Resources, conducted a review that included examination of records from the Michigan Natural Features Inventory natural heritage database on known occurrences and localities of rare species on and near the Fermi site. The MSUE (2013) identified seven species with known occurrences within 1.5 mi (2.4 km) of the Fermi site. This list did not include the eastern massasauga rattlesnake. Accordingly, the NRC does not specifically address this species in the DSEIS.

Comment 028-Y-2: Bald Eagle - The U.S. Fish and Wildlife inform:

Your list should also include the bald eagle, as they are documented to nest in and near the project area. Although no longer protected under the Endangered Species Act, bald eagles, along with their foraging and winter roosting habitat, remain protected pursuant to the Bald and Golden Eagle Protection Act (BGEPA) and Migratory Bird Treaty Act (MBTA). Disturbance of these birds should be minimized and any resulting take must be permitted by the U.S. Fish and Wildlife Service (Service).

Response: This comment expresses concern regarding the NRC staffs analysis of potential impacts to the bald eagle. In Sections 3.6 and 4.6 of the DSEIS, the NRC staff examined the potential effects to the bald eagle and described the protections afforded to this species and other birds under the Bald and Golden Eagle Protection Act of 1940, as amended (16 U.S.C. 668 et seq.), and Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. 703 et seq.). In Section 4.6, the NRC staff determined that impacts to all terrestrial resources would be SMALL for all Category 1 and Category 2 issues. For noncooling system impacts, the NRC made this determination because landscape maintenance activities, stormwater management, elevated noise levels, and other ongoing operations and maintenance activities that DTE might undertake during the renewal term would primarily be confined to disturbed areas of the Fermi site. In addition, these activities would not have noticeable effects on terrestrial resources, nor would they destabilize any important attribute of the terrestrial resources on, or in the vicinity of, the Fermi site.

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Appendix A A.1.11 Terrestrial Resources (TE)

Comment 012-F-7: And then, there is the continued issue of the Eastern Fox Snake.

Response: The comment expresses concern for the proposed Fermi 2 license renewals impact on the eastern fox snake. The NRC addresses the eastern fox snake in Section 3.6 of this DSEIS. Section 4.6 of this DSEIS describes the impacts of the proposed license renewal on terrestrial resources, which include the eastern fox snake. As discussed in Section 4.6 of this DSEIS, the NRC staff determined that impacts to all terrestrial resources (including rare and State-listed species) would be SMALL for all Category 1 and Category 2 issues. For noncooling system impacts, the NRC staff made this determination because landscape maintenance activities, stormwater management, elevated noise levels, and other ongoing operations and maintenance activities that DTE might undertake during the renewal term would primarily be confined to disturbed areas of the Fermi site. In addition, these activities would not have noticeable effects on terrestrial resources, nor would they destabilize any important attribute of the terrestrial resources on, or in the vicinity of, the Fermi site.

Comment 028-Y-1: Beaver Impact On Wetlands:

No where in the Fermi 2 License Renewal Application Environment Report is mention made of the rise of beaver population in Monroe County and how their growth and presence may affect the wetlands, those to be impacted and the new ones to be built to replace the proposed destroyed ones. (Beaver Population on Rise in Monroe County, Monroe Evening News 12/4/2012) The omission leaves questions about whether other issues did not receive assessment, since beavers were not mentioned.

Detroit River again becoming home to beaver reads the AP story from March 18, 2013. The story as it appears:

"Updated 9:53 am, Monday, March 18, 2013 DETROIT (AP) There's new evidence that the Detroit River once again is becoming home to the beaver, according to officials working improve the health of the river.

A trail camera set up at DTE Energy Co.'s River Rouge Power Plant in 2013 recorded images of a beaver dragging a small tree into the river, the Detroit Free Press reported (http://on.freep.com/146tqQM) Monday. It could be part of a sustained comeback.

"They could be expanding their range," said John Hartig, manager of the Detroit River International Wildlife Refuge.

Following a long absence, a beaver sighting was reported in 2009 at DTE's Conners Creek power plant along the Detroit River. He moved on during that summer, but later was spotted having returned with a family. Beaver sightings also have been reported on Belle Isle.

http://www.seattlepi.comlbusiness/energy/article/Detroit-River-again-becoming-home-to-beaver-4362805.php Read more: http://www.seattlepi.conmbusiness/energy/article/Detroit-River-again-becoming-home-to-beaver-4362805.php#ixzz2NvanEiJ7 Read more: http://www.seattlepi.conibusiness/energy/article/Detroit-River-again-becoming-home-to-beaver-4362805.php#ixzz2NvaTrFZS The Environmental Report is inclomplete [sic]. Beavers have the capability of suddenly and devastatingly altering wetlands, nothing in the Environmental Report has addressed this beaver concern. We request that a ER be done to include beaver wetland modification potential at the Fermi site through year 2045.

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Appendix A Response: The comment expresses concern for the impact of beavers on wetlands in Monroe County. Although the NRC staff recognizes the potential for beavers to alter hydrological regimes and natural habitats, such as wetlands, the available wildlife surveys do not indicate the presence of beavers on, or in the vicinity of, the Fermi site. However, the NRC staff addresses the types and quality of wetland habitats on the Fermi site in Section 3.6 of this DSEIS, and Section 4.6 of this DSEIS considers the impacts of the proposed license renewal on terrestrial resources, including wetlands. As discussed in Section 4.6 of this DSEIS, the NRC staff determined that impacts to all terrestrial resources (including rare and State-listed species) would be SMALL for all Category 1 and Category 2 issues. For noncooling system impacts, the NRC made this determination because landscape maintenance activities, stormwater management, elevated noise levels, and other ongoing operations and maintenance activities that DTE might undertake during the renewal term would primarily be confined to disturbed areas of the Fermi site. In addition, these activities would not have noticeable effects on terrestrial resources, nor would they destabilize any important attribute of the terrestrial resources on, or in the vicinity of, the Fermi site.

Comment 028-Y-3: Bird Kills From Cooling Towers The License Renewal Application has not taken into consideration the number of bird kills resulting from two Cooling Towers at Fermi 2 that will result over extended 20 year license renewal. Please enter into the record the attached 1979 study entitled Cooling Towers as Obstacles in Bird Migration which took a look at bird kills at Davis-Besse which has one Cooling Tower. Recently the Kirkland Warbler was identified as being potentially impacted by Davis-Besse. There is no discussion of this federally endangered species in the Fermi 2 LRA.

Please see that this is addressed.

Response: The comment expresses concern for the potential for birds to collide with the Fermi 2 cooling towers during the proposed license renewal period. The comment also specifically expresses concern for the potential for the Kirtlands warbler, a Federally listed species, to be impacted by the Fermi 2 cooling towers. In the GEIS, the NRC staff determined that bird collisions with plant structures is a generic (Category 1) issue with an impact level of SMALL for all sites. During its review of the Fermi 2 ER, the NRC staff considered whether any new or significant information exists that would conflict with the generic conclusion in the GEIS that impacts would be SMALL. The NRC staff also summarized available bird collision data for the Fermi site in Section 3.6 of this DSEIS. Sections 3.8 and 4.8 of the DSEIS address Federally listed species, including all Federally listed birds that have the potential to occur within the ESA action area, as defined at 50 CFR 402.02. The potential for these species to collide with cooling towers is addressed, as appropriate. Regarding the Kirtlands warbler specifically, during consultation with the FWS pursuant to ESA Section 7, the NRC and FWS did not identify the Kirtlands warbler as a species that has the potential to be affected by the proposed license renewal. Appendix D to this DSEIS describes ESA Section 7 consultation.

A.1.12 References 10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, Agency rules of practice and procedure.

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, Standards for protection against radiation.

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic licensing of production and utilization facilities.

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Appendix A 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental protection regulations for domestic licensing and related regulatory functions.

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for renewal of operating licenses for nuclear power plants.

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, Reactor site criteria.

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part 800, Protection of historic properties.

50 CFR 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, Interagency cooperationEndangered Species Act of 1973, as amended.

79 FR 36837. U.S. Nuclear Regulatory Commission. Notice of intent to prepare an environmental impact statement and conduct scoping process for license renewal application for Fermi 2; DTE Electric Company. Federal Register 79(125):36837-36839. June 30, 2014.

[AECOM] AECOM. 2009. Aquatic Ecology Characterization Report: Detroit Edison Company Fermi 3 Project. November. ADAMS No. ML093380373.

Bald and Golden Eagle Protection Act of 1940, as amended. 16 U.S.C. § 668 et seq.

Clean Water Act of 1977, as amended. 33 U.S.C. § 1251 et seq.

[DTE] DTE Electric Company. 2014. Fermi 2 License Renewal Application. Appendix E:

Applicants Environmental Report, Operating License Renewal Stage, Fermi 2. April 2014.

ADAMS Nos. ML14121A538, ML14121A539, and ML14121A540.

[DTE] DTE Electric Company. 2015a. Letter from V. Kaminskas, Site Vice President, DTE, to NRC Document Control Desk.

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal ApplicationSevere Accident Mitigation Alternatives. January 9, 2015. ADAMS No. ML15037A229.

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

[EPA] U.S. Environmental Protection Agency. 2014. Detroit River-Western Lake Erie Basin Indicator Project. INDICATOR: Algal Blooms in Western Lake Erie. Large Lakes and Rivers Forecasting Branch. Updated December 5, 2014. Available at

<http://www.epa.gov/med/grosseile_site/indicators/algae-blooms.html> (accessed 5 December 2014).

Mackey SD. 2012. Great Lakes Nearshore and Coastal Systems. U.S. National Climate Assessment Midwest Technical Input Report. In: Winkler J, Andresen J, Hatfield J, Bidwell D, Brown D, coordinators. U.S. National Climate Assessment Midwest Technical Input Report.

Great Lakes Integrated Sciences and Assessments (GLISA) Center. Available at

<http://glisa.umich.edu/media/files/NCA/MTIT_Coastal.pdf> (accessed 2 January 2015).

Mangano JJ. 2012. Potential Health Risks Posed by Adding a New Reactor at the Fermi Plant:

Radioactive contamination from Fermi 2 and changes in local health status. Radiation and Public Health Project. January 10, 2012. Available at

<http://static1.1.sqspcdn.com/static/f/356082/16362768/1328128276340/Mangano_corrected_F ermi_report_Jan_11_2012.pdf?token=gBLNCTkz%2B14KsQF62i1RyPquUuo%3D>

Migratory Bird Treaty Act of 1918, as amended. 16 U.S.C. § 703 et seq.

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Appendix A

[MSUE] Michigan State University Extension. 2013. Letter from M. Sanders, Environmental Review Specialist/Zoologist, Michigan Natural Features Inventory (MSUE), to L. Goodman, DTE Energy Company.

Subject:

Enhanced Rare Species Review #1271DTE Electric Fermi 2 Nuclear Station License Renewal, Monroe County, MI T6S, R10E Sections 16, 17, 19, 20, 20, 28 & 29. September 17, 2013. ADAMS No. ML14121A540 (in DTEs Fermi 2 Environmental Report, Appendix C).

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

National Historic Preservation Act of 1966, as amended. 16 U.S.C. § 470 et seq.

[NRC] U.S. Nuclear Regulatory Commission. 1997. Regulatory Analysis Technical Evaluation Handbook. Washington, DC: NRC. NUREG/BR-0184, January 1997. 308 p. ADAMS No. ML050190193.

[NRC] U.S. Nuclear Regulatory Commission. 2011. Criteria for Development of Evacuation Time Estimate Studies. Washington, DC: NRC. NUREG/CR-7002. November 2011.

[NRC] U.S. Nuclear Regulatory Commission. 2012b. State-of-the-Art Reactor Consequence Analyses (SOARCA) Report, Part 1 and Part 2. Washington, DC: NRC. NUREG-1935.

November 2012.

[NRC] U.S. Nuclear Regulatory Commission. 2012c. Modeling Potential Reactor Accident Consequences. Washington, DC: NRC. NUREG/BR-0359. December 2012.

[NRC] U.S. Nuclear Regulatory Commission. 2013a. Environmental Impact Statement for the Combined License (COL) for Enrico Fermi Unit 3, Final Report. Washington, DC: NRC.

NUREG-2105, Volumes 1 and 2. January 2013. ADAMS Nos. ML12307A172 and ML12307A176.

[NRC] U.S. Nuclear Regulatory Commission. 2013b. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Revision 1. Washington, DC: NRC. NUREG-1437, Volumes 1, 2, and 3. June 30, 2013. 1,535 p. ADAMS No. ML13107A023.

[NRC] U.S. Nuclear Regulatory Commission. 2014a. NRC Staffs Answer to Citizens Resistance at Fermi 2 (CRAFT) Petition for Leave to Intervene and Request for Public Hearing.

Washington, DC: NRC. September 12, 2014. ADAMS No. ML14255A495.

[NRC] U.S. Nuclear Regulatory Commission. 2014b. Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel: Final Report, Volume 1. Washington, DC: NRC.

NUREG-2157. September 2014.

Price-Anderson Act Nuclear Industries Indemnity Act of 1957, as amended. 42 U.S.C. § 2210 et seq.

[USGCRP] U.S. Global Change Research Program. 2014. Climate Change Impacts in the United States: The Third National Climate Assessment. Melillo JM, Richmond TC, Yohe GW, editors. May 9, 2014. ADAMS No. ML14129A233.

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Appendix A A.2 Comments Received on the Draft Supplement Environmental Impact Statement On October 26, 2015, the NRC issued the Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 56, Regarding Fermi 2 Nuclear Power Plant, Draft Report for Comment (NUREG-1437) (DSEIS) to Federal, tribal, state, local governmental agencies, and interested members of the public. The U.S. Environmental Protection Agency (EPA) published in the Federal Register a Notice of Availability regarding the DSEIS on November 13, 2015 (80 FR 70206). The public comment period began on November 13, 2015, with the issuance of EPAs notice and ended on December 28, 2015. As part of the process to collect comments on the DSEIS, the staff did the following:

placed a copy of the DSEIS into the NRCs Public Electronic Reading Room, on the license renewal Web site,

placed a copy of the DSEIS on the license renewal website at:

<http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/supplement56/>,

provided a copy of the DSEIS for review at the Ellis Library and Reference Center in Monroe, Michigan,

published a notice of availability of the DSEIS in the Federal Register on November 6, 2015 (80 FR 68881), and

held one public meeting on December 2, 2016, at the Monroe County Community College, La-Z-Boy Center, in Monroe, Michigan.

Approximately 40 people attended the meeting on December 2, 2015, with 24 people providing oral comments. A certified court reporter prepared written transcripts of the meeting. The NRC received 48 written submittals (via Regulations.gov, letters or e-mails with comments and written comments provided at the public meeting). Several people provided both oral and written comments. The total number of commenters is 65.

Each comment is identified by the commenters ID number and comment source document (as identified in Table A-3), and comment number. In addition to the comments received at the December 2015 public meeting, comments were submitted through Regulations.gov, letters, and e-mails. Comments are grouped by issue category (as identified in Table A-4). Similar comments are grouped together with a single response.

Table A-3. Commenters on the Draft Supplemental Environmental Impact Statement Commenters are listed in alphabetical order.

Comment Commenter Affiliation ID Source ADAMS No.

Anonymous 1 None given 1 Regulations.gov ML16011A024 Anonymous 2 None given 2 Regulations.gov ML16011A026 Anonymous 3 None given 3 Regulations.gov ML16011A027 Mary Ann Baier None given 4 Regulations.gov ML16011A025 Pam Barker None given 5 Letter ML16011A028 Martina Barnard None given 6 Regulations.gov ML16011A019 Kathryn Barnes Dont Waste Michigan - 7 Letter ML16011A036 Sherwood Chapter A-312

Appendix A Comment Commenter Affiliation ID Source ADAMS No.

Barry Buschmann The Mannik & Smith Group 8 Meeting ML16004A049 Transcript Connie Carrol United Way of Monroe 9 Meeting ML16004A049 County Transcript Robert Clark Mayor, City of Monroe 10 Meeting ML16004A049 Transcript Jessie Pauline Collins1 Citizens Resistance at Fermi 11 Letter ML16007A009 Two (CRAFT) Letter ML16011A010 Carolyn Doherty None given 12a Meeting ML16004A049 12b Transcript ML16004A145 E-mail Eric Dover DTE Energy Company 13 Meeting ML16004A049 Transcript Michelle Dugan Monroe County Chamber of 14 Letter ML16011A031 Commerce Paul Fessler DTE Energy Company 15 Meeting ML16004A049 Transcript Sarah Flum None given 16 Regulations.gov ML16011A020 Martha Gruelle Wildlife Habitat Council 17 Letter ML15343A420 Keith Gunter Alliance to Halt Fermi 3 18 Meeting ML16004A049 (ATHF3) Transcript Craig A. Haugen Superintendent of Schools, 19 Letter ML16007A006 Jefferson Schools Scott Hicks U.S. Department of Interior, 20 Letter ML16029A074 Fish and Wildlife Service David Hoffman Monroe County Board of 21 Meeting ML16004A049 Commissioners Transcript Michael Hormel None given 22 Regulations.gov ML16011A023 Carol Izant Alliance to Halt Fermi 3 23 Meeting ML16004A049 Transcript Vito Kaminskas DTE Energy Company 24 Letter ML15356A368 Kevin Kamps2 Beyond Nuclear 25 E-mail ML16011A014 Michael Keegan2 Dont Waste Michigan 26a E-mail ML16011A013 26b E-Mail ML16011A015 Tim Lake Monroe County Business 27 Meeting ML16004A049 Development Corporation Transcript Ron Lankford None given 28a Meeting ML16004A049 28b Transcript ML16011A032 Other Gerald Lee None given 29 Regulations.gov ML16011A021 J. Henry Lievens Monroe County Board of 30 Letter ML16020A337 Commissioners Barbara Loe None given 31 Regulations.gov ML16011A029 A-313

Appendix A Comment Commenter Affiliation ID Source ADAMS No.

Ed McArdle Sierra Club - Michigan 32 Meeting ML16004A049 Chapter Transcript Jim McDevitt Frenchtown Charter 33 Letter ML15356A371 Township Rich McDevitt DTE Energy Company 34 Meeting ML16004A049 Transcript Stephen McNew Monroe County Intermediate 35 Letter ML15329A303 School District Floreine Mentel Former Monroe County 36 Letter ML15343A014 Commissioner Susan Michetti None given 37 Letter ML16011A012 Jeanne Micka Lotus Garden Club 38 Letter ML16011A034 Richard Micka None given 39a Meeting ML16004A049 39b Transcript ML16011A033 Letter Mark Muhich Jackson Sierra Club 40 E-mail ML16011A011 Sandy Mull Southern Wayne County 41 Meeting ML16004A049 Regional Chamber of Transcript Commerce Arthur Myatt Alliance to Halt Fermi 3 42a Letter3 ML16011A008 42b Letter ML16021A437 Lindy Nelson U.S. Department of Interior, 43 Letter ML16011A009 Tracy Oberleiter Monroe County Economic 44 Meeting ML16004A049 Development Corporation Transcript Mark Paff University of Michigan ANS 45 Meeting ML16004A049 Transcript Sandra Pierce Monroe Center for Healthy 46 Letter ML16007A005 Aging Nancy Poprafsky Alliance to Halt Fermi 3 47 Meeting ML16004A049 Transcript Kojo Quartey Monroe County Community 48 Meeting ML16004A049 College Transcript Sue Riopelle None given 49 Regulations.gov ML16011A022 Ethyl Rivera Alliance to Halt Fermi 3 50 Meeting ML16004A049 Transcript Kathleen Russeau Community Foundation of 51 Letter ML16011A035 Monroe County Timothy Schacht None given 52 Regulations.gov ML16011A018 David Schonberger Alliance to Halt Fermi 3 53a Meeting ML16004A049 53b Transcript ML16011A030 Letter3 Larry Smith Frenchtown RDA 54 Meeting ML16004A049 Transcript Jerry Sobczak DTE Shareholders United 55 Letter ML15345A439 A-314

Appendix A Comment Commenter Affiliation ID Source ADAMS No.

Robert Tompkins DEAR 56 Letter ML16021A435 Ralph Tusher None given 57 Regulations.gov ML16011A016 Unknown None given 58 Letter ML16020A336 Roberta Urbani None given 59 Meeting ML16004A049 Transcript Joanne Van Aken International Wildlife Refuge 60 Letter ML15337A079 Alliance Gerald Vande Velde None given 61 Regulations.gov ML16011A017 Robert M Vergiels None given 62 Regulations.gov ML16007A007 Kenneth Westlake U.S. Environmental 63 Letter ML16007A008 Protection Agency, Region 5 Robert Wicke None given 64a Meeting ML16004A049 64b Transcript ML16021A436 Letter Dale Zorn State of Michigan, Senator 65 Letter ML16049A584 from District 17 1 The two letters submitted by Ms. Collins are identical except the first letter contained the wrong document number and the second letter was submitted with the correct document number (i.e., NUREG-1147 instead of NUREG-1437).

2 Mr. Kamps (Beyond Nuclear) and Mr. Keegan (Dont Waste Michigan) also fully endorse and support the comments submitted by CRAFT (Commenter 11) and ATHF3 (Commenters 42a and 53b).

3 In the letters submitted by Mr. Myatt and Mr. Schonberger (Commenters 42a and 53b, respectively) for ATHF3, it was stated that ATHF3 wholly reiterates and resubmits the comments submitted on August 29, 2014, by ATHF3 during the scoping period (ADAMS No. ML14252A176). Responses to the comments in the August 29, 2014, submittal were addressed in the Fermi 2 Scoping Summary Report (ADAMS No. ML15251A015) and in Section A.1 of the Fermi 2 DSEIS, NUREG-1437, Supplement 56, and will not be repeated in this section.

Table A-4. Issue Categories Comments were divided into the following categories:

Appendix A Code Technical Issue Section AQ Air Quality and Climate Change A.2.1 AL Alternative Energy Sources A.2.2 AR Aquatic Resources A.2.3 CU Cumulative Impacts A.2.4 ED Editorial Comments Received A.2.5 GW Groundwater Resources A.2.6 HC Historic and Cultural Resources A.2.7 HH Human Health A.2.8 LR License Renewal Process A.2.9 OP Opposed to License Renewal A.2.10 OS Outside of Scope A.2.11 A-315

Appendix A Appendix A Code Technical Issue Section PA Postulated Accidents and Severe Accident A.2.12 Mitigation Alternatives (SAMA)

SO Socioeconomics A.2.13 SH Special Species and Habitats A.2.14 SP Support for License Renewal A.2.15 SW Surface Water Resources A.2.16 TR Terrestrial Resources A.2.17 WM Waste Management A.2.18 The following pages contain summaries of the comments and the NRC staff responses. The full text of all the comments follow Section A.2.19, References.

A.2.1 Air Quality and Climate Change Comment 18-3: This comment states that nuclear power does not help climate change and that according to a Massachusetts Institute of Technology (MIT) report, an additional 1,500 nuclear power plants would have to be built world-wide to have an appreciable impact on global climate change.

Response: This comment disputes the claim that nuclear power reduces the impact of climate change. Since the title and date of the MIT report mentioned in the comment were not included with the comment, attempts by the NRC staff to locate the report were not successful.

However, according to an MIT summary report published in 2010, nuclear power was a major candidate for reducing greenhouse gas emissions from the electricity sector in the United States. As of 2010, nuclear power plants in the United States provided about 70 percent of the zero-carbon electricity. The MIT summary report can be found at:

http://mitei.mit.edu/publications/reports-studies/future-nuclear-fuel-cycle-summary-report (accessed April 14, 2016).

This comment provides no new information. The SEIS has not been revised as a result of this comment.

A.2.2 Alternative Energy Sources Comments 11-7, 11-12, 12a-4, 28a-2, 42b-1, and 53a-4: These comments express general disagreement with the types of alternative energy sources evaluated in the SEIS.

Response: These comments express dissatisfaction with the energy alternatives evaluated in the SEIS. These comments also state that cleaner energy is needed and that renewables should be developed now. As stated in Chapter 2 of the SEIS, the NRCs decisionmaking authority in license renewal is limited to deciding whether to renew the nuclear power plants operating license for an additional 20 years. However, under NEPA, the NRC staff is required to consider the environmental impacts of the proposed action of license renewal, of the no-action alternative of not renewing the operating license, and of reasonable energy alternatives to renewing the operating license. The alternatives evaluated in the SEIS are energy technologies or options currently in commercial operation, or technologies that are not currently available but could provide replacement power and are likely to be available by the time the current Fermi 2 license expires on March 20, 2025.

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Appendix A These comments provide no new information. The SEIS has not been revised as a result of these comments.

Comments 42a-11, 42a-13, 42a-18, 53b-11, 53b-13, and 53b-18: These comments state that the SEIS failed the hard look in the solar and energy efficiency analyses. These comments also state that the alternatives analysis in the SEIS relies on misleading assumptions and the climate change implications for operating Fermi 2 are considered outside the scope of the license renewal environmental review. These comments also state that the NRC staff failed to further evaluate alternatives that do not rely on a conventionally fueled baseload power source.

Response: In evaluating alternatives to license renewal, the NRC considered energy replacement technologies or options currently in commercial operation, including solar photovoltaic (PV) systems, as well as technologies not currently in commercial operation but that could provide replacement power and are likely to be commercially available by the time the current Fermi 2 operating license expires. Other means of generating electricity, as well as the offsetting demand for electricity using conservation and energy efficiency measures (demand-side management) or purchasing sufficient power to replace the capacity supplied by Fermi 2 were considered. The impacts of renewing the operating license and the continued operation of Fermi 2 were then compared to the environmental impacts of reasonable replacement power alternatives. This allows the NRC to determine whether the environmental impacts of license renewal are so great that preserving the option of license renewal for energy-planning decisionmakers would be unreasonable. Although the NRCs decisionmaking authority is limited to deciding whether to renew a nuclear power plants operating license, NEPA requires the NRC to consider the environmental impacts of potential alternatives to renewing a plants operating license.

Consequently, the evaluation of alternatives in the context of license renewal is limited to an assessment of their environmental impacts relative to those of continued operations of a nuclear power plant during the license renewal term. The NRC does not, however, make energy policy decisions or decide whether to use a nuclear power plant or an energy alternative; this decision is reserved for state, other Federal, and utility decisionmakers and is based on economics, energy reliability goals, and other objectives over which the other entities may have jurisdiction.

The climate change implications for operations at Fermi 2 during the proposed license renewal period are described in Section 4.15.3. To ensure that the alternatives analysis is consistent with state or regional energy policies, the NRC reviewed energy-related statutes, regulations, and policies within the Fermi 2 region. As a result, the NRC considered alternatives that include wind power or solar PV power and a combination of both technologies.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

A.2.3 Aquatic Resources Comments 3-5, 4-5, 5-4, 11-2, 28a-7, 37-2, 58-1, and 63-1: These comments are related to the temperature of the discharge water released back into Lake Erie. These comments also question why the National Pollution Discharge Elimination System (NPDES) permit has no thermal limit for the cooling water discharged into Lake Erie and call on the NRC to impose thermal limits.

Response: These comments suggest that the temperature of the cooling water being discharged into Lake Erie is adversely impacting the lake and that the NRC staff should impose a thermal limit for the discharge water. The comments are correct that the NPDES permit does not impose any temperature limits for the water being discharged back into Lake Erie. As stated A-317

Appendix A in Section 5.5.1.3 of the SEIS, NRC licensees must comply with the Clean Water Act (CWA),

including all associated requirements imposed by the U.S. Environmental Protection Agency (EPA) or the state as part of the NPDES permitting system under Section 402 of the CWA and state water quality certification requirements under Section 401 of the CWA. Nuclear power plants cannot operate without a valid NPDES permit and current Section 401 Water Quality Certification. However, the NPDES permit is outside the scope of the NRCs regulatory authority. EPA is the Federal agency with oversight of the CWA and the NPDES permits.

The CWA allows EPA to delegate authority of the NPDES permits to states. In Michigan, EPA has delegated the authority for issuing NPDES permits to the State of Michigan, Department of Environmental Quality (MDEQ). MDEQ issues NPDES permits on a 5-year cycle. In Michigan, all NPDES permits proposed for issuance will have a 30-day public notice period for the public to review the proposed discharge permit and provide comments to MDEQ. Information on MDEQs NPDES permitting system and laws and regulations can be found at:

http://www.michigan.gov/deq/0,4561,7-135-3313_71618_3682_3713---,00.html.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

Comments 12a-2, 28a-4, 42a-8, and 53b-8: These comments suggest that the Fermi 2 discharges into Lake Erie contribute to the algal blooms that occur in Lake Erie.

Response: These comments suggest that the heated cooling water discharged from Fermi 2 is responsible for the algal blooms that occur in Lake Erie. Algal blooms in Lake Erie are discussed in Section 4.14 of the SEIS. Nonradiological liquid effluents are covered by the plants NPDES permit and are outside the scope of the NRCs regulatory authority. In Michigan, the MDEQ issued the NPDES permit under which Fermi 2 is currently operating. The NPDES permit specifies the discharge standards and monitoring requirements for levels of chemicals and thermal quality of wastewater and stormwater discharges. As noted in the SEIS, the Fermi 2 discharge water is warmer and may contain somewhat higher concentrations of nitrogen and phosphorus compounds than the ambient Lake Erie water, but the affected area would be limited due to the mixing and diffusion of the discharge water with lake water.

The health of the Great Lakes is important to both the United States and Canada. In 1972, the United States and Canada first signed the Great Lakes Water Quality Agreement (GLWQA) and amended it in 1983 and 1987. The GLWQA is a commitment between the United States and Canada to restore and protect the waters of the Great Lakes and provides a framework for identifying priorities and implementing actions that improve water quality. EPA coordinates U.S. activities that fulfill the Agreement.

The GLWQA was updated in 2012 to enhance water quality programs that ensure the chemical, physical, and biological integrity of the Great Lakes. New provisions to the GLWQA address aquatic invasive species, habitat degradation, and the effects of climate change, and they support continued work on existing threats from harmful algae, toxic chemicals, and discharges from vessels.

In June 2015, the Governors of Michigan and Ohio and the Premier of the Province of Ontario signed the Western Basin of Lake Erie Collaborative Agreement in an effort to work together to improve the water quality and environmental conditions in the Western Lake Erie Basin. The goals are to achieve a 40-percent total load reduction in the amount of total and dissolved reactive phosphorus entering Lake Eries western basin by the year 2025. The text of the agreement can be found at: http://www.michigan.gov/documents/snyder/

Western_Basin_of_Lake_Erie_Collaborative_Agreement--Lieutenant_Governor_491709_7.pdf.

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Appendix A On January 14, 2016, MDEQ, Water Resources Division, published Michigans Implementation Plan for the Western Lake Erie Basin Collaborative. The purpose of Michigans implementation plan is to define the actions the State of Michigan needs to take to help meet the Western Basin of Lake Erie Collaborative Agreement. The full text of the report can be found at:

https://www.michigan.gov/documents/deq/wrd-western-lake-erie_503547_7.pdf.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

A.2.4 Cumulative Impacts Comments 11-5, 37-4: These comments suggest that the cumulative impacts of MODERATE and LARGE are solely due to the impacts from Fermi 2.

Response: The NRC staff considered the potential cumulative impacts from the continued operation of Fermi 2 in combination with the impacts from other past, present, and reasonably foreseeable future activities. Chapter 4 of the SEIS discusses the impact levels by resource area from renewing the Fermi 2 operating license and for the energy alternatives. SEIS Table 2-2 contains the summary of the environmental impact levels by resource area for license renewal and for the energy alternatives. The impact level for the Fermi 2 license renewal is SMALL in most resource areas.

SEIS Appendix E describes the activities, other than the license renewal of Fermi 2, which were considered in the NRC staffs analysis of the potential cumulative impacts. Large cumulative impacts can result from individually minor impacts from actions that take place over a long time and when considered with other impacts in the vicinity.

This comment provides no new information. The SEIS has not been revised as a result of this comment.

Comment 63-2: This comment states that it is unclear from the DSEIS whether the cumulative impacts analysis included Fermi 3 and that Fermi 3 was not included in Table E-1, Actions and Projects Considered in Cumulative Analysis.

Response: The Fermi 3 project is included in Table E-1, on page E-4 under Fermi Projects.

Additionally, discussion of Fermi 3 is included throughout SEIS Chapter 3, Affected Environment. Section 4.16 of the SEIS, includes contributions from the cumulative impacts of Fermi 3 during the proposed license renewal period. This comment provides no new information. The SEIS has not been revised as a result of this comment.

A.2.5 Editorial Comments Received Comments on Executive Summary and Chapter 1: 24-1, 24-98, 24-99,24-100, 24-101,24-102, 24-103,24-104, 24-105, and 24-106. These comments identified minor edits or clarifications that were needed in the Executive Summary and Chapter 1 of the SEIS.

Response: The majority of these comments are editorial and provided no new and significant information. The NRC staff reviewed the text mentioned in each comment, agrees with the proposed changes, and revised the Executive Summary and Chapter 1 accordingly. All text changes are marked on the side of the page with change bars.

Comments on Chapter 2: 24-2, 24-3, 24-4, 24-5, 24-6, 24-51, 24-57,24-104, 24-108, and 24-109 Response: These comments are editorial and provided no new and significant information.

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed A-319

Appendix A changes, and revised Chapter 2 accordingly. All text changes are marked on the side of the page with change bars.

Comments on Chapter 3: 24-7, 24-8, 24-10, 24-11, 24-12, 24-13, 24-14, 24-15, 24-16, 24-17, 24-18, 24-19, 24-20, 24-21, 24-22, 24-23, 24-25, 24-28, 24-29, 24-24, 24-41, 24-42,24-110, 24-111,24-112, 24-113,24-114, 24-115,24-116, 24-117,24-118, 24-119,24-120, 24-121,24-122, 24-123,24-124, 24-125,24-126, 24-127,24-128, 24-129,24-130, and 24-131 Response: These comments are editorial and provided no new and significant information.

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed changes, and revised Chapter 3 accordingly. All text changes are marked on the side of the page with change bars.

Comments on Chapter 4: 24-29, 24-35, 24-36, 24-37, 24-38, 24-44, 24-45, 24-46, 24-47, 24-48, 24-50, 24-52, 24-53, 24-54, 24-55, 24-56, 24-58, 24-59, 24-60, 24-61, 24-62, 24-63, 24-64, 24-66, 24-67, 24-68, and 24-69, 24-70,24-132, 24-133,24-134, 24-135,24-136, 24-137,24-138, 24-139,24-140, 24-141,24-142, 24-143,24-144, 24-145,24-146, 24-147,24-148, 24-149,24-150, 24-151,24-152, 24-153,24-154, 24-155,24-156, 24-157,24-158, 24-159,24-160, 24-161,24-162, 24-163,24-164, 24-165,24-166, 24-167,24-168, 24-169,24-170, and 24-171 Response: These comments are editorial and provided no new and significant information.

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed changes, and revised Chapter 4 accordingly. All text changes are marked on the side of the page with change bars.

Comments on Chapter 7, Appendices A, B, C, D, and F: 24-73, 24-74, 24-75 24-75, 24-76, 24-77, 24-78, 24-79, 24-80, 24-81, 24-82, 24-83, 24-84, 24-85, 24-86, 24-87, 24-88, 24-89, 24-90, 24-91, 24-92, 24-93, 24-94, 24-95, 24-96, 24-97, 7-24-171,24-172, 24-173,24-174, 24-175,24-176, 24-177,24-178, 24-179,24-180, 24-181,24-182, 24-183, and 24-184 Response: These comments are editorial and provided no new and significant information.

The NRC staff reviewed the text mentioned in each comment, agrees with the proposed changes, and revised Chapter 7 and Appendices A, B, C, and D, accordingly. All text changes are marked on the side of the page with change bars.

A.2.6 Groundwater Resources Comment 24-4: This comment states that the SEIS incorrectly indicates there are onsite drinking water wells at Fermi 2.

Response: SEIS Section 2.2.2.3 stated that existing drinking water wells would be expected to serve a replacement new nuclear plant alternative. However, drinking water for Fermi 2 is obtained from a local water utility. Section 2.2.2.3 of the SEIS has been revised to reflect that water supply lines would be used to deliver drinking water to the site.

Comment 24-9: This comment disputes the Fermi site potable water demand of 20,000 gallons per day.

Response: The value for the Fermi 2 site-wide potable water demand cited by the NRC staff in the SEIS is derived from Figure 2.2-4 in the Environmental Report (ER), which is a water balance/flow diagram. The figure indicates that the total volume of water supplied by the Frenchtown municipal system is 25,000 gallons per day, with 7,000 gallons per day sent to the demineralizer system. The difference (rounded) between the values was used in the SEIS as a conservative estimate of Fermi 2s potable/sanitary water demand. No changes have been made to the SEIS as a result of this comment.

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Appendix A Comment 24-24: This comment suggests clarifying the number of wells that had detectable levels of tritium.

Response: The text in Section 3.5.2.3, Groundwater Quality, has been updated with respect to tritium concentrations reported in the 2015 Annual Radioactive Effluent Release Report and Radiological Environmental Operating Report.

A.2.7 Historic and Cultural Resources Comments 3-10, 4-10, and 11-10: These comments state that there are numerous Native American and First Nation tribes, including the Walpole Island First Nation, in the vicinity of Fermi 2, but there was no evaluation on the impact to the Native Americans from operating Fermi 2 for an additional 20 years.

Response: In Section 4.9 of the SEIS, the NRC staff documented the consultation with the Advisory Council on Historic Preservation (ACHP), the Michigan State Historic Preservation Officer (SHPO) and 17 Federally recognized Native American Tribes. The Native American Tribes were invited to participate in the scoping process; however, the NRC received no scoping comments from any of the Tribes. The NRC staff met with the Michigan SHPO in September 2014 to discuss the Fermi 2 license renewal. The SHPO did not express any concerns about the proposed Fermi 2 license renewal.

Additionally, the Walpole Island First Nation, an Indian Tribe from Ontario, Canada, sent a letter to the NRC stating that the Tribe would like an opportunity to thoroughly review the Fermi 2 license renewal process to ensure that their rights to fish and harvest resources in western Lake Erie and other nearby areas are not adversely impacted. By letter dated October 31, 2014, the NRC invited the Walpole Island First Nation to provide input on the Fermi 2 SEIS environmental review, as well as the NRCs overall license renewal process. In November 2015, a copy of the Fermi 2 DSEIS was sent to the Walpole Island First Nation requesting comments. However, the Walpole Island First Nation did not provide comments.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

A.2.8 Human Health Comments 3-4, 3-6, 4-4, 4-6, 5-3, 7-2, 11-14, 12a-1, 42a-9, and 53b-9: These comments indicate that nuclear power causes cancer and other illnesses, that the radiation standards are inadequate to protect children, and that radioactive emissions from the plant endanger the people.

Response: The NRCs mission is to protect public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. A discussion of these responsibilities beginning with the Atomic Energy Act of 1954 can be found on the NRC Web site at http://www.nrc.gov/about-nrc/history.html. The NRCs regulatory limits for radiological protection are set to protect workers and the public from the harmful health effects (i.e., cancer and other biological impacts) of radiation. The limits are based on the recommendations of standards-setting organizations. Radiation standards reflect extensive scientific study by national and international organizations. The NRC actively participates in and monitors the work of these organizations to keep current on the latest trends in radiation protection. If the NRC determines that there is a need to revise its radiation protection regulations, it will initiate a rulemaking. Members of the public who believe that the NRC should revise or update its regulations may request that the NRC do so by submitting a petition for rulemaking.

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Appendix A The NRC has based its dose limits and dose calculations on a descriptive model of the human body referred to as standard man. However, the NRC has always recognized that dose limits and calculations based on a standard man must be informed and adjusted in some cases for factors such as age and gender. For example, the NRC has different occupational dose limits for pregnant women workers, once they have declared (i.e., made known) they are pregnant, because the rapidly developing human fetus is more radiosensitive than an adult woman. NRC dose limits are also much lower for members of the public, including children and elderly people, than for adults who receive radiation exposure as part of their occupation. Finally, NRC dose calculation methods include age-specific dose factors for each radionuclide to consider the varied sensitivity to radiation exposure by infant, child, and teen bodies, which are also generally smaller than adult bodies. In addition, the calculation methods have always recognized that the diets (amounts of different kinds of food) of infants, children, and teens are different from those of adults.

Two comments mention the findings of the Biological Effects of Ionizing Radiation (BEIR) VII report. BEIR VII is the seventh in a series of publications from the National Academies concerning radiation health effects, referred to as the BEIR reports. The BEIR VII report entitled Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII - Phase 2 (National Research Council 2006) focuses on the health effects of low levels of low linear energy transfer (LET) ionizing radiation. Low-LET radiation deposits less energy in the cell along the radiation path and is considered less destructive per radiation track than high-LET radiation. Examples of low-LET radiation, the subject of this report, include X-rays and -rays (gamma rays). Health effects of concern include cancer, hereditary diseases, and other effects, such as heart disease.

The NRC accepts the linear, no-threshold (LNT) dose-response model (see additional information at http://www.nrc.gov/about-nrc/radiation/health-effects/rad-exposure-cancer.html.

The BEIR VII Committee concluded that the current scientific evidence is consistent with the hypothesis that there is an LNT dose-response relationship between exposure to ionizing radiation and the development of cancer in humans. Having accepted this model, the NRC believes that it is conservative when applied to workers and members of the public who are exposed to radiation from nuclear facilities. This is based on the fact that numerous epidemiological studies have not shown increased incidences of cancer at low doses. Some of these studies included: (1) the 1990 National Cancer Institute study (NCI 1990) of cancer mortality rates around 52 nuclear power plants, (2) the University of Pittsburgh study that found no link between radiation released during the 1979 accident at the Three-Mile Island nuclear power station and cancer deaths among residents, and (3) the 2001 study performed by the Connecticut Academy of Sciences and Engineering that found no meaningful associations between exposures to radionuclides around the Haddam Neck nuclear power plant in Connecticut and the cancers studied. In addition, a position statement entitled Radiation Risk in Perspective by the Health Physics Society (August 2004) made the following points regarding radiological health effects: (1) radiological health effects (primarily cancer) have been demonstrated in humans through epidemiological studies only at doses exceeding 5-10 rem delivered at high dose rates. Below this dose, estimation of adverse effect remains speculative; and (2) epidemiological studies have not demonstrated adverse health effects in individuals exposed to small doses (less than 10 rem delivered over a period of many years).

The comments also state that low-dose effects of radiation can cause cancer and genetic damage at an increased magnitude than previously seen. The BEIR VII report makes no assertion that there is no safe level of exposure to radiation. Rather, the conclusions of the report are specific to estimating cancer risk. The report notes that the BEIR VII Committee said that the higher the dose, the greater the risk; the lower the dose, the lower the likelihood of harm to human health. Further, the report notes that [t]he Committee maintains that other health effects, such as heart disease and stroke, occur at high radiation doses but that additional data A-322

Appendix A must be gathered before an assessment of any possible dose response can be made of connections between low doses of radiation and non-cancer health effects. Although the LNT model is still considered valid, the BEIR VII Committee concluded that the current scientific evidence is consistent with the hypothesis that there is a linear dose-response relationship between exposure to ionizing radiation and the development of radiation-induced solid cancers in humans. Further, the Committee concluded that it is unlikely that a threshold exists for the induction of cancers but notes that the occurrence of radiation-induced cancers at low doses will be small.

Although radiation may cause cancers at high doses, currently there are no reputable scientifically conclusive data that unequivocally establish the occurrence of cancer following exposure to low doses (i.e., below about 10 rem [0.1 Sv]). However, radiation protection experts conservatively assume that any amount of radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is higher for higher radiation exposures.

Therefore, an LNT dose-response relationship is used to describe the relationship between radiation dose and adverse impacts, such as incidents of cancer. Simply stated, in this model any increase in dose, no matter how small, results in an incremental increase in health risk.

This theory is accepted by the NRC as a conservative model for estimating health risks from radiation exposure, recognizing that the model probably over-estimates those risks. Based on this theory, the NRC conservatively establishes limits for radioactive effluents and radiation exposures for workers and members of the public. Although the public dose limit in 10 CFR Part 20 is 100 mrem (1 mSv) for all facilities licensed by the NRC, the NRC has imposed additional constraints on nuclear power reactors. Each nuclear power reactor has enforceable license conditions that limit the total annual whole body dose to a member of the public outside the facility to 25 mrem (0.25 mSv). The amount of radioactive material released from nuclear power facilities is well measured, well monitored, and known to be very small. The doses of radiation that are received by members of the public as a result of exposure to nuclear power facilities are very low (i.e., less than a few millirem) such that resulting cancers attributed to the radiation have not been observed and would not be expected. As stated in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), the NRC believes the public and occupational impacts during the license renewal term would be SMALL.

Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have been conducted, no studies to date accepted by the scientific community show a correlation between radiation dose from nuclear power facilities and cancer incidence in the general public.

The following is a list of some of the most recent radiation health studies that the NRC recognizes:

In June 2000, investigators from the University of Pittsburgh found no link between radiation released during the 1979 accident at the Three Mile Island power plant and cancer deaths among nearby residents. Their study followed 32,000 people who lived within 5 miles of the plant at the time of the accident.

In 2000, the American Cancer Society concluded that although reports about cancer clusters in some communities have raised public concern, studies show that clusters do not occur more often near nuclear plants than they do by chance elsewhere in the population. Likewise, there is no evidence that links strontium-90 with increases in breast cancer, prostate cancer, or childhood cancer rates. Radiation emissions from nuclear power plants are closely controlled and involve negligible levels of exposure for nearby communities.

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Appendix A

In 2000, the Illinois Public Health Department compared childhood cancer statistics for counties with nuclear power plants to similar counties without nuclear plants and found no statistically significant difference.

In January 2001, the Connecticut Academy of Sciences and Engineering issued a report on a study around the Haddam Neck nuclear power plant in Connecticut and concluded that radiation emissions were so low as to be negligible and found no meaningful associations with the cancers studied.

In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there are striking increases in cancer rates in southeastern Florida counties caused by increased radiation exposures from nuclear power plants. However, using the same data to reconstruct the calculations, on which the claims were based, Florida officials were not able to identify unusually high rates of cancers in these counties compared with the rest of the state of Florida and the nation.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

Comment 24-40: This comment indicates that the 3-year average annual collective dose per reactor may be incorrect.

Response: This comment notes that the 3-year average annual collective dose per reactor for boiling water reactors (BWRs) is incorrectly stated. The NRC staff agrees with this comment and the information in Section 3.11.1 has been updated with information contained in NUREG-0713, Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities 2014: Forty-Seventh Annual Report, (Volume 36), to reflect the correct collective dose numbers.

Comment 24-65: This comment states that SEIS Table 4-17 should be corrected.

Response: This comment notes that SEIS Table 4-19 is incorrect regarding the information contained in Table B-1 of Appendix B to 10 CFR Part 51. The NRC staff agrees with this comment and updated the information in SEIS Table 4-19 to correctly list Termination of plant operations and decommissioning as the only Table B-1 issue related to decommissioning.

Comment 42a-16, 53b-16: These comments disagree with the decommissioning discussion in the SEIS.

Response: These comments express disagreement with how decommissioning impacts are assessed for license renewal. The commenters have concerns with decommissioning being a Category 1 issue. All operating nuclear power plants will terminate operations and be decommissioned at some point after the end of their operating licenses or after a decision is made to cease operations. License renewal could potentially delay this eventuality for an additional 20 years beyond the current license period. The impacts of decommissioning nuclear plants were evaluated in the Generic Environmental Impact Statement for Decommissioning Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, NUREG-0586. The effects of license renewal on the impacts of terminating nuclear power plant operations and decommissioning are considered a single environmental issue. Because the impacts are expected to be SMALL at all plants and for all environmental resources, it is considered a Category 1 issue. No new and significant information regarding decommissioning of Fermi 2 was identified during the review of DTEs ER, the site audit, or the scoping process.

The commenters also raise issues with decommissioning regarding radiological exposures to plant workers and to members of the public as a result of an additional 20 years of operation.

During decommissioning activities, workers are exposed to radioactive materials that are A-324

Appendix A present in the reactor and support facilities, and members of the public may be exposed to radioactive materials that are released to the environment. Many activities during decommissioning are similar to the activities that occur during normal maintenance outages, such as decontamination of piping and surfaces; removal of piping, pumps, and valves; and removal of heat exchangers. Some of the activities, such as removal of the reactor vessel or demolition of facilities, are unique to decommissioning. Public and occupational radiation exposures from decommissioning activities as a result of an additional 20 years of operation are presented in Section 4.12.2 of the GEIS. During an additional 20 years of plant operation, only the quantities of long-lived radionuclides would increase, and, therefore, only the dose caused by the long-lived radionuclides would increase. For plant workers as well as members of the public, an additional 20 years of operation would result in a negligible dose increase of less than 0.1 person-rem. Therefore, the NRC concluded that the impact of an additional 20 years of plant operation on the radiological doses to workers and to members of the public would be SMALL. No new information was provided by this comment. Therefore, no changes to the SEIS were made.

These comments also express concern with security and safeguards during decommissioning of the plant. The license renewal GEIS discusses plant security and safeguards in Section 1.7.4, Safeguards and Security. The NRC requires that nuclear power plants be both safe and secure. Safety refers to operating the plant in a manner that protects the public and the environment. Security refers to protecting the plant (using people, equipment, and fortifications) from intruders who wish to damage or destroy it to harm people and the environment. Security issues such as safeguards planning are not tied to a license renewal action but are considered to be issues that need to be dealt with continuously as a part of a nuclear power plants current (and renewed) operating license. Security issues are periodically reviewed and updated at every operating plant. These reviews continue throughout the period of an operating license, whether it is the original or a renewed license. If issues related to security are discovered at a nuclear plant (such as the issue brought up about unauthorized access), they are addressed immediately, and any necessary changes are reviewed and incorporated under the operating license. As such, decisions and recommendations concerning safeguards and security at nuclear power plants are ongoing and outside the regulatory scope of license renewal and the GEIS. No new information was provided by this comment. Therefore, no changes to the SEIS were made.

Finally, these comments express concern with the effects of climate change on decommissioning. Changes in climate have the potential to affect air and water resources, ecological resources, and human health, and were taken into consideration when developing this SEIS. SEIS Section 4.15.3.2, Climate Change Impacts to Resource Areas, discusses those impacts for an additional 20 years of operation of Fermi 2. As discussed in Chapter 2 of the SEIS, there are no site-specific issues related to decommissioning and the Fermi SEIS only addresses environmental impacts that arise directly from plant shutdown. Climate change impacts on decommissioning activities are outside the scope of license renewal.

No new information was provided by this comment. Therefore, no changes to the SEIS were made.

A.2.9 License Renewal Process Comments 1-2, 11-1, 11-13, 42a-2, and 53b-2: These comments state that the GEIS is flawed and that that the NRC overuses the GEIS and generic impacts. These comments also state that the GEIS dismisses viable energy alternatives and ignores recent advances in renewable energy. One comment disagreed that license renewal is a preferable option.

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Appendix A Response: The GEIS was developed to establish an effective licensing process. It contains the results of a systematic evaluation of the environmental consequences of renewing an operating license and operating a nuclear power facility for an additional 20 years. Those environmental issues that could be resolved generically were analyzed in detail and were resolved in the GEIS. Those issues that were unique because of a site-specific attribute, a particular site setting or unique facility interface with the environment, or variability from site to site, were deferred and would be resolved at the time that an applicant sought license renewal.

In the license renewal process, these issues are addressed by a site-specific SEIS. The GEIS is used to avoid duplication and allow the staff to focus specifically on those issues that are important for a particular plant (i.e., issues that are not generic).

Under NEPA, the NRC is required to consider reasonable energy alternatives, including the no-action alternative (not issuing the renewed operating license). The NRC staff evaluation of alternatives in an SEIS is limited to assessing their environmental impacts rather than recommending energy alternatives. The purpose of NEPA is to ensure that an agency has examined and disclosed the potential environmental impacts of proposed actions before the action is approved. The NRC is responsible for ensuring the safe operation of nuclear power facilities. The NRC does not have a role in the energy-planning decisions of state regulators and utility officials as to whether a particular nuclear power plant should continue to operate or an alternative energy source should be developed instead.

These comments provide no new information and no revisions were made to the SEIS.

Comment 11-8: This comment questions why safety, disposition of spent nuclear fuel, emergency preparedness, security and safeguards, and need for power are outside the scope of the environmental review.

Response: Plant safety, emergency preparedness, security and safeguards, and the need for power are outside the scope of the environmental review for license renewal. The NRCs mission is to protect public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. Plant safety, emergency preparedness, and security and safeguards are part of the current licensing basis and are part of the day-to-day functioning at nuclear power plants.

The NRC provides continuous oversight for the safe operation of nuclear power plants through its ongoing reactor oversight process to verify that they are being operated and maintained in accordance with NRC regulations. This oversight includes having full-time NRC inspectors located at the plant and periodic safety inspections conducted by NRC inspectors based in an NRC Regional Office. The inspections look at a licensees compliance with NRCs regulations, which include the following: plant safety (routine and accident scenarios), radiation protection of plant workers and members of the public, radioactive effluent releases, radiological environmental monitoring, emergency preparedness, radioactive waste storage and transportation, quality assurance, and training. Should the NRC discover an unsafe condition, or that a licensee is not complying with its licensing basis, the NRC has full authority to take whatever action is necessary to protect public health and safety.

Emergency preparedness and physical security plans are required at all nuclear power plants and require specified levels of protection from each licensee regardless of plant design, construction, or license date. Requirements related to emergency planning are in the regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50. Requirements related to physical security are in the regulations at 10 CFR Part 73. These requirements apply to all operating licenses and will continue to apply to facilities with renewed licenses.

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Appendix A Additionally, the NRC assesses the capabilities of the nuclear power plant operator to protect the public by requiring the performance of a full-scale exercisethat includes the participation of various Federal, state, and local government agenciesat least once every 2 years. These exercises are performed in order to maintain the skills of the emergency responders and to identify and correct weaknesses. As such, the NRC, in 10 CFR 50.47, has determined that there is no need for a special review of emergency preparedness issues in the environmental review for license renewal.

The need for power is considered to be outside the scope of license renewal (10 CFR 51.95 (c)(2)). The purpose and need for the proposed action of issuing a renewed license is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, but such needs will be determined by other energy-planning decisionmakers.

These comments provide no new information and no revisions to the SEIS have been made.

Comments 11-11, 42a-15, and 53b-15: These comments question why DTE did not identify refurbishment activities related to license renewal.

Response: Refurbishment activities are either physical activities or changes to the facility or site that are needed to prepare a nuclear power plant to operate following license renewal.

Refurbishment activities can include replacement of large components of the nuclear steam supply system (e.g., steam generator or pressurizer), repair or replacement of pumps, pipes, control rod systems, electronic circuitry, electrical and plumbing systems, or motors. DTE did not identify any refurbishment activities needed for license renewal.

These comments provide no new information and no revisions were made to the SEIS.

Comments 42a-3, 53b-3: These comments stated that the commenters reiterates and resubmits the public comments submitted by the Alliance to Halt Fermi 3 in the scoping comment letter dated August 29, 2014 (ADAMS No. ML14252A176).

Response: Comments submitted during the scoping period were addressed in Appendix A of the SEIS and in the Environmental Impact Statement Scoping Summary Report issued October 2015 (ADAMS No. ML15252A015). No new information was provided in this comment and the SEIS was not revised.

Comments 42a-4, 53b-4: These comments stated that the NRC failed to comply with the hard look requirements because relicensing is inimical to the health and safety of the public.

Response: The NRCs mission is to protect public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. In addition to the environmental review, which is documented in the SEIS, the license renewal process includes a safety review, inspections, and an independent review by the Advisory Committee on Reactor Safety (ACRS). The purpose of the safety review is to determine if the licensee has adequately demonstrated that the effects of aging will not adversely affect any safety-related systems, structures, or components that are relied upon to remain functional during and following design-basis events. The licensee must demonstrate that the effects of aging will be managed so that the intended functions of passive or long-lived structures will be maintained during the license renewal period. The NRC staffs review of the licensees aging management program is documented in the safety evaluation report (SER).

The NRCs inspection program relies upon resident inspectors, who are stationed at each plant, and region-based inspectors, to assess whether day-to-day activities are properly conducted and that equipment is adequately maintained to ensure safe operation. The NRC also established an inspection program for license renewal that examines the information provided A-327

Appendix A by the licensee in the renewal application. The site inspections are assessments of the applicants implementation of and compliance with the regulations in 10 CFR Part 54. The inspection team includes technical, program, and operational experts from the NRC and its consultants. The intent of the inspections is to determine whether the effects of aging will be managed such that the facility can be operated during the period of extended operation without undue risk to the health and safety of the public and to ensure the consistency of the applicants programs to manage aging within the current licensing basis.

The ACRS is an advisory committee mandated by the Atomic Energy Act of 1954, as amended, under the Federal Advisory Committee Act (FACA). The Committee has three primary purposes:

to review and report on safety studies and reactor facility license and license renewal applications,

to advise the Commission on the hazards of proposed and existing reactor facilities and the adequacy of proposed reactor safety standards, and

to initiate reviews of specific generic matters or nuclear facility safety-related items.

The ACRS is independent of the NRC staff and reports directly to the Commission, which appoints its members. The ACRS is composed of recognized technical experts in their fields. It is structured so that experts representing many technical perspectives can provide independent advice, which can be factored into the NRCs decisionmaking process. Most ACRS meetings are open to the public and any member of the public may request an opportunity to make an oral statement during the committee meeting. For license renewal of nuclear power plants, ACRS acts as an independent third-party oversight group that reviews the NRC staffs SER and makes recommendations to the Commission on the safety aspects of license renewal.

These comments provide no new information and no revisions to the SEIS have been made.

Comments 42a-5, 53b-5: These comments state that the SEIS is deficient because it does not include information about uranium mining and processing.

Response: The radiological and nonradiological environmental impacts of the uranium fuel cycle were reviewed and discussed in the 1996 GEIS. The review included a discussion of the values presented in Table S-3 of 10 CFR Part 51, an assessment of the release and impact of Rn222 and of Tc99, and a review of the regulatory standards and experience of fuel cycle facilities. As stated in the 1996 GEIS, the NRC uses the standard that the impacts are of small significance if doses and releases do not exceed permissible levels in the Commissions regulations. Given the available information regarding the compliance of fuel-cycle facilities with applicable regulatory requirements, the NRC has concluded the actual impacts of the fuel cycle are at or below existing regulatory limits. Accordingly, the NRC has concluded that individual radiological impacts of the fuel cycle (other than the disposal of spent fuel and high-level waste) are SMALL. With respect to the nonradiological impacts of the uranium fuel cycle, data concerning land requirements, water requirements, the use of fossil fuel, gaseous effluent, liquid effluent, and tailings solutions and solids, all listed in Table S-3 of 10 CFR Part 51, have been reviewed to determine the significance of the environmental impacts of a power reactor operating an additional 20 years. The nonradiological environmental impacts attributable to the relicensing of an individual power reactor were found to be of small significance. The individual radiological and the nonradiological effects of the uranium fuel cycle are Category 1 issues.

These comments provide no new information and no revisions to the SEIS have been made.

Comment 63-3: This comment recommends clearer distinctions between NRC-assigned categories of SMALL, MODERATE, or LARGE A-328

Appendix A Response: This comment recommends providing a better explanation of thresholds or metrics at which an impact will increase from SMALL to MODERATE and MODERATE to LARGE and to indicate whether mitigation is a factor in assigning a lower impact level. Impacts to resources affected by license renewal and the various alternatives are defined in the GEIS. The GEIS established a standard of significance for each license renewal environmental impact issue based on the Council on Environmental Quality (CEQ) terminology for significantly (see 40 CFR 1508.27). Since the significance and severity of an impact can vary with the setting of the proposed action, both context and intensity, as defined in CEQ regulations in 40 CFR 1508.27, were considered. Context is the geographic, biophysical, and social context in which the effects will occur. In the case of license renewal, the context is the environment surrounding the nuclear power plant and intensity refers to the severity of the impact in whatever context it occurs. Based on this, the NRC established three levels of significance for potential impacts:

SMALLenvironmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. For the purposes of assessing radiological impacts, the Commission has concluded that those impacts that do not exceed permissible levels in the Commissions regulations are considered SMALL.

MODERATEenvironmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource.

LARGEenvironmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

These definitions are reiterated in Section 1.4 of this SEIS, Generic Environmental Impact Statement. Section 1.4 includes definitions for the three key words:

Significance indicates the importance of likely environmental impacts and is determined by considering two variables: context and intensity.

Context is the geographic, biophysical, and social context in which the effects will occur.

Intensity refers to the severity of the impact, in whatever context it occurs.

As explained in Section 1.5 of the GEIS and Section 1.4 of this SEIS, the NRC staff uses the above definitions in its evaluations of the impacts associated with the various alternatives.

Ranges are provided when there are multiple options and multiple unknowns associated with the alternatives. For example, the potential impact on the land use resource as a result of the integrated gasification combined-cycle (IGCC) will vary greatly depending upon the location selected for the new IGCC facility. As explained in Chapter 4, the impacts on Land Use during construction of a new IGCC facility would range from MODERATE to LARGE based on such factors as: the location chosen, the historical use of the location, and the amount of previously undisturbed land impacted by the construction and operation of the new facility. There are too many unknowns to better describe the range and transition from MODERATE to LARGE.

In summary, the NRC staff has defined the thresholds for environmental impacts on resource areas in the GEIS and reiterates these thresholds in Chapter 1 of this SEIS. More specifics regarding the range of impacts associated with many of the alternatives cannot be better defined unless more specifics are available for the each alternative.

The NRC staff did not make changes to the SEIS text as a result of this comment.

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Appendix A A.2.10 Opposed to License Renewal Comments: 1-1, 2-1, 3-11, 5-1, 6-1, 7-1, 11-9, 11-16, 12b-1, 16-1, 18-5, 22-1, 25-1, 26a-1, 26b-1, 28a-6, 29-1, 31-1, 37-1, 37-5, 42a-1, 53b-1, 42a-7, 53b-7, 49-1, 52-1, 53a-3, 57-1, 61-1, 64a-1, and 64b-1: These comments are generally opposed to license renewal for the following reasons: the demand for electricity is down, Fermi 1 and 2 never functioned properly, renewable energy sources are needed instead of nuclear energy, the plant is generating toxic waste, nuclear power is dangerous, the plant has many safety problems, unsuspecting people are using nearby parks and state-managed land is being used by unsuspecting people and the plant is a target for terrorism.

Response: These comments are generally opposed to the license renewal of Fermi 2 for the myriad of reasons stated above. These comments provide no new information. The SEIS has not been revised as a result of these comments.

A.2.11 Outside of Scope Comments 1-3, 3-3, 3-7, 4-3, 4-7, 12a-3, 28a-5, and 40-1: These comments are generally related to emergency planning, evacuation during an accident, and the issuance of potassium iodide pills.

Response: Emergency preparedness is part of the current operating license and is outside the scope of the environmental analysis for license renewal. Emergency preparedness plans are required at all nuclear power plants and require specified levels of protection from each licensee, regardless of plant design, construction, or license date. Requirements related to emergency planning are in the regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50.

These requirements apply to all operating licenses and will continue to apply to facilities with renewed licenses.

The Federal Emergency Management Agency (FEMA) and the NRC are the two Federal agencies responsible for evaluating emergency preparedness at and around nuclear power plants. The NRC is responsible for assessing the adequacy of onsite emergency plans developed by the utility, and FEMA is responsible for assessing the adequacy of offsite emergency planning. The NRC relies on FEMAs findings in determining that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

The NRC has regulations in place to ensure that existing plans are updated throughout the life of all plants. For example, nuclear power plant operators are required to update their evacuation time estimates after every U.S. Census, or when changes in population would increase the estimate by either 25 percent or 30 minutes, whichever is less. Additionally, the NRC assesses the capabilities of the nuclear power plant operator to protect the public by requiring the performance of a full-scale exercisethat includes the participation of various Federal, state, and local government agenciesat least once every 2 years. These exercises are performed to maintain the skills of the emergency responders and to identify and correct weaknesses.

As such, the NRC, in 10 CFR Part 50.47, has determined that there is no need for a special review of emergency preparedness issues in the environmental review for license renewal.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

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Appendix A Comments 1-3, 3-1, 4-1, 18-2, 23-1, and 53a-2: These comments generally state that the plant is unsafe because of the GE BWR Mark I containment and the large number of licensee event reports submitted to the NRC by DTE.

Response: The NRC provides continuous oversight for the safe operation of nuclear power plants through its ongoing reactor oversight process to verify that they are being operated and maintained in accordance with NRC regulations. This oversight includes having full-time NRC inspectors located at the plant and periodic safety inspections conducted by NRC inspectors based in an NRC Regional Office. The inspections look at a licensees compliance with NRCs regulations, which include the following: plant safety (routine and accident scenarios), radiation protection of plant workers and members of the public, radioactive effluent releases, radiological environmental monitoring, emergency preparedness, radioactive waste storage and transportation, quality assurance, and training. Should the NRC discover an unsafe condition, or that a licensee is not complying with its licensing basis, the NRC has full authority to take whatever action is necessary to protect public health and safety.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

Comments 3-9, 4-9, 8-4, 42a-17, and 53b-17: These comments refer to the Fukushima accident.

Response: The NRC has taken significant action to enhance the safety of reactors in the United States based on the lessons learned from the Fukushima accident. Because these lessons learned are applicable to many nuclear power plants in the United States, the NRC has established a process, which is separate from the license renewal process, to identify and implement the lessons it has learned. The NRC Japan Lessons-Learned Web site (http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html) provides the current status of these activities.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

Comments 5-2, 28a-3, 28b-1, 53a-1, and 53a-2: Topics of these comments include building Fermi 3 would add to the radioactive waste stored on site, the Fermi 1 accident, how building codes change over time, and that there is inadequate police support in the county.

Response: Opposition to building Fermi 3, the accident at Fermi 1, and building codes are outside the scope of the environmental review and will not be discussed further.

Comment 28b-1 describes instances where there is an appearance of inadequate police support in Monroe County, which is outside the scope of NRCs regulatory authority. The NRC requires nuclear power plants to have adequate physical security on site to protect the facility.

Physical security at Fermi 2 is part of the current operating license and is outside the scope of the environmental analysis for license renewal. All nuclear power plants are required to have physical security plans and have specified levels of protection, regardless of plant design, construction, or license date. Requirements related to physical security are in the regulations at 10 CFR Part 73.

These comments provide no new information and no revisions to the SEIS have been made.

Comments 1-1, 3-2, 4-2, 42a-12, 42b-2, and 53b-12: These comments state that the SEIS is deficient because it does not include an evaluation of the need for power.

Response: The need for power is considered to be outside the scope of license renewal (10 CFR 51.95 (c)(2)). The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that allows for a power generation capability beyond the term of A-331

Appendix A a current nuclear power plants operating license to meet future system generating needs, as such needs will be determined by other energy-planning decisionmakers. This definition of purpose and need reflects the NRCs recognition that, unless there are findings in the safety review required by the Atomic Energy Act or findings in the NEPA environmental analysis that would lead the NRC to reject a license renewal application, the NRC does not have a role in the energy-planning decisions of state regulators and utility officials as to whether a particular nuclear power plant should continue to operate.

These comments provide no new information and no revisions to the SEIS have been made.

A.2.12 A.2.12 Postulated Accidents and Severe Accident Mitigation Alternatives (SAMAs)

Comment 11-6: This comment questions why operating an aged reactor does not increase the possibility of severe accidents, why any improvements toward safety are not cost effective, and also whether the taxpayer money spent on the Fukushima lessons learned was wasted.

Response: License renewal requirements for power reactors are based on two key principles:

The regulatory process is adequate to ensure that the licensing basis of all currently operating plants maintains an acceptable level of safety, with the possible exceptions of the detrimental aging effects on certain functions of certain structures, systems or components, as well as a few other safety-related issues, during the period of extended operation.

The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term Thus, in the review of a license renewal application, the focus is on the detrimental effects of aging. The safety of the reactor is an ongoing process currently and throughout the period of extended operation. The lessons learned from the Fukushima accident are being considered for the entire nuclear fleet, regardless of whether the applicant is pursuing license renewal.

This comment provides no new information and no revisions to the SEIS have been made.

Comments 42a-19 and 53b-19: These comments state that the NRCs severe accident analysis relies on misleading assumptions, question whether any of the original SAMA candidates were within the scope of license renewal, and suggest that the MACCS2 computer code is flawed.

Response: These comments contend that the SAMA analysis is deficient in that it is fundamentally based on misleading assumptions that serve to underestimate and minimize the projected economic costs and consequences of a severe accident and that the applicants approach was performed using the current guidance for preparing a SAMA analysis provided in Revision A of Nuclear Energy Institute (NEI) 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis (NEI 2005), which was endorsed by the staff for use in a SAMA analysis.

Various input parameters and associated assumptions are described in NEI 05-01 and the ER.

An important step in the analysis is the sensitivity analysis, which evaluates how changes in SAMA analysis assumptions and uncertainties would affect the cost-benefit analysis. This helps to bound the analysis to account for any nonconservative assumptions.

These comments also contend that the original 220 SAMA candidates evaluated are within the scope of license renewal, pursuant to 10 CFR Part 54. The applicant performed the SAMA analysis consistent with the guidance provided in NEI 05-01. The applicant evaluates or screens all of the original 220 SAMA candidates using specific criteria unrelated to aging. Aging A-332

Appendix A is evaluated at the end of the analysis to identify those items that must be implemented specifically for license renewal. If aging were used to screen out SAMAs for additional consideration at the beginning of the process, the SAMA analysis would be a less comprehensive evaluation of mitigation alternatives because most of the SAMAs would be screened out in the beginning of the analysis since most SAMAs are not age-related.

These commenters also contend that using the MACCS2 computer code model for probabilistic offsite consequence analysis of a nuclear accident is inappropriate because the NRC is using a discredited, unreasonable, and illegitimate methodological modeling software tool to assess the economic costs and consequences of a postulated severe accident at Fermi 2. The MACCS2 code was developed at Sandia National Laboratories for the NRC to simulate the impact of severe accidents at nuclear power plants on the surrounding environment. NUREG/CR-7009, MACCS Best Practices as Applied in the State-of-the-Art Reactor Consequence Analyses (SOARCA) Project, provides a description of MACCS modeling capabilities used to represent important aspects of radionuclide atmospheric transport, emergency response, and dose response to radiation exposure. In 2006, an Expert Review Panel recommended enhancements to the MACCS code that were implemented for the SOARCA Project. Some of the enhancements include:

atmospheric transport and dispersion modeling improvements,

increasing angular resolution to 64 compass directions up from 16,

increasing the limit to 200 plume segments instead of the previous limit of 4,

increasing the limit to 20 emergency phase cohorts instead of the original limit of 3, and

enhancing the treatment of evacuation speed and direction to better reflect the spatial and temporal response of individual cohorts.

The MACCS2 code provides a reasonable assessment for SAMA under NEPA standards.

Climate change and its related impacts on the environmental characteristics of the Fermi 2 site are discussed in Sections 4.15.3 and 4.16.11 of this SEIS. For the Level 3 analysis using the MACCS2 code, the applicant used site-specific meteorological data (not speculative) in accordance with the guidance provided in NEI 05-01. This was determined to be a reasonable approach given that the results of previous Level 3 analyses have shown little sensitivity to year-to-year differences in meteorological data.

The NRC is evaluating the inputs used in the MACCS2 code, and is in the process of updating some of the values used in the cost-benefit analysis. However, the staff disagrees with using generic core damage frequencies (CDFs) and benefits. The site-specific, plant-specific probabilistic risk assessment (PRA) takes into account site-specific hazards, the design of the plant, and plant-specific operational practices that affect how a particular plant responds to potential challenges. This site-specific PRA is expected to yield a much more accurate estimate of risk (including CDF) than a generic evaluation. The SAMA analysis for license renewal is a Category 2 issue for plants where SAMAs have not been previously considered in an environmental analysis, which means that it should be evaluated on a site-specific basis. In the Fermi 2 case, DTE calculates the current CDF using plant-specific fault trees, event trees, and reliability information. This approach is consistent with the current guidance for preparing a SAMA analysis provided in Revision A of Nuclear Energy Institute (NEI) 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis (NEI 2005), which was endorsed by the staff for use in performing a SAMA analysis. This document provides the applicant guidance in using the plant-specific PRA model. Based on this site-specific information, the applicant is to A-333

Appendix A estimate the severe accident risk, offsite dose, and economic impacts of a severe accident. The staff believes that the plant-specific estimate, based on the most current information regarding the plant design, appears to be the most accurate measure of risk at Fermi 2.

The NRC staff did note, in a request for information (RAI), that a Phase I SAMA to install a filtered containment vent to remove decay heat was combined with Phase II SAMA 123 for an ATWS-sized filtered containment vent. Because a filtered vent to remove decay heat is considerably smaller than that required for an ATWS event, the evaluation of SAMA 123 does not appear to be valid for the decay heat-sized SAMA. In response, DTE indicated that the SAMA 123 ATWS-sized filtered vent had a rough conceptual cost of $40,000,000, estimated in 2013 from an industry group discussion on a filtered vent. At that time, the cost was assumed by industry to be in the range of $40,000,000 to $50,000,000. DTE also noted in response to an NRC request for additional information that NEI submitted cost estimates for a filtered vent with a small filter and severe accident capable water makeup and for a large filter with severe accident capable water makeup. Neither filter was sized for an ATWS. The cost estimates provided were conceptual in nature. With contingency and subtracting the estimated $3.7M cost of the water makeup, the estimated costs were $31.7M for the small filter and $51.2M for the large filter. These cost estimates were based on incremental costs of filter installation relative to current conceptual designs planned for a hardened containment vent in compliance with NRC Order EA-13-109. Given that these estimates are for a vent that is not specifically sized for an ATWS, the cost is appropriate for the normal decay heat SAMA and is lower than the cost of an ATWS-sized vent. Even considering the cost for the smaller filter of $31.7M, the normal decay heat SAMA is not cost-beneficial (DTE 2015a). As provided in SECY-12-0157, sensitivity studies and analyses using values of event frequency and accident consequence in the upper range of the uncertainty bands result in the calculated benefits potentially justifying the likely costs of improved venting systems. However, as provided in Table F-6 of this SEIS, the benefit of SAMA 123 at Fermi 2 is only $3,290,000. This benefit includes the uncertainty factor applied to the adjusted cost benefit. Therefore, even if the estimated $15 million implementation cost suggested by the 2014 NAS report was used, SAMA 123 would still not be cost-beneficial because the cost of implementation exceeds the benefit.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

A.2.13 Socioeconomics Comment 24-43: There appears to be a difference in methodology between the DSEIS and the DTE ER in the Environmental Justice (EJ) section.

Response: In identifying minority and low-income populations, the NRC staff follows the Commissions Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040), which states, Under current NRC staff guidance, a minority or low-income community is identified by comparing the percentage of the minority or low-income population in the impacted area to the percentage of the minority or low-income population in the County (or Parish) and the State. If the percentage in the impacted area significantly exceeds that of the State or the County percentage for either the minority or low-income population then EJ will be considered in greater detail.

Significantly is defined by staff guidance to be 20 percentage points. Alternatively, if either the minority or low-income population percentage in the impacted area exceeds 50 percent, EJ matters are considered in greater detail.

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Appendix A Identifying populations with 20 percentage points greater than the percentage in the geographic area is simply used to determine whether EJ matters should be considered in greater detail rather than to identify them.

NRC guidance in LIC-203, Revision 3, also states, Minority and low-income populations are identified when (1) the minority and/or low-income population of an impacted area exceeds 50 percent or (2) the minority and/or low-income population percentage of the impacted area is meaningfully greater than the minority and/or low-income population percentage in the general population or other appropriate unit of geographic analysis (e.g., 50-mile radius geographic area or county). All block groups with minority and/or low-income percentages higher than the geographic area should be identified on 50-mile radius maps. (See LIC-203, pages D-5 and D-6). This approach is consistent with Commission policy.

No changes were made to the SEIS as a result of this comment.

Comments 28a-1: This comment indicates that the number of counties identified in the SEIS Section 2.2 may be incorrect.

Response: Section 2.2 of the SEIS indicates that Fermi 2 is owned and operated by DTE and provides electricity through the Midcontinent Independent System Operator to an 11-county service area. This comment states that the correct number of counties should be 13, based on information obtained from the Internet about DTE. DTE does provide electricity to the 13 southeastern counties of Michigan; however, the electricity is from all of DTEs generating capacity, which includes coal, natural gas, fuel oil, and Fermi 2. However, Fermi 2 only provides electricity to 11 counties in the service area.

This comment provides no new information. No changes were made to the SEIS.

Comments 42a-14 and 53b-14: These comments state that the environmental justice impacts on Monroe County residents were not evaluated in the SEIS.

Response: All human health and environmental risks are considered during nuclear plant-specific license renewal environmental reviews. In addition, all minority and low-income people are considered in the NRCs assessment of environmental justice impacts, in accordance with Executive Order 12898 and the Commissions Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040).

As discussed in Section 4.12.1, the NRC addresses environmental justice matters for license renewal by (1) identifying the location of U.S. minority and low-income populations that may be affected by the continued operation of the nuclear power plant during the license renewal term, (2) determining whether there would be any potential human health or environmental effects to these populations and special pathway receptors, and (3) determining if any of the effects may be disproportionately high and adverse. Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant and exceeds the risk or exposure rate for the general population or for another appropriate comparison group. Disproportionately high environmental effects refer to impacts or risks of impacts on the natural or physical environment in a minority or low-income community that are significant and appreciably exceed the environmental impact on the larger community. Such effects may include biological, cultural, economic, or social impacts.

Except for Fermi 1 decommissioning, DTE currently has no other reasonably foreseeable future planned activities at Fermi 2 beyond continued reactor operations and maintenance. When A-335

Appendix A combined with other past, present, and reasonably foreseeable future activities, the contributory effects of continuing reactor operations and maintenance activities would not likely cause any disproportionately high and adverse human health and environmental effects on minority and low-income populations residing near Fermi 2 beyond what is currently being experienced.

Also, the environmental impacts of postulated accidents, including severe accidents, are discussed in Chapter 4, Section 4.11.1.2. The Commission has generically determined that impacts associated with such accidents are SMALL, because nuclear plants are designed to successfully withstand design-basis accidents and the probability-weighted consequences (risk) of severe accidents are also SMALL.

The NRCs mission is to protect people and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. All nuclear plants were licensed with the expectation that they would release some radioactive material to both the air and water during normal operation. NRC regulations require that radioactive gaseous and liquid releases from nuclear power plants meet the radiation dose-based limits specified in 10 CFR Part 20, the as low as is reasonably achievable (ALARA) dose criteria in Appendix I to 10 CFR Part 50, and EPAs regulations in 40 CFR Part 190. Regulatory limits are placed on the radiation dose that members of the public might receive from radioactive material released by nuclear plants. The NRC regulations are dose based, such that the dose resulting from the radioactive effluent is the value used by the NRC to determine compliance with regulatory limits.

The NRC evaluated human health effects of ongoing reactor operations at Fermi 2 in Chapters 3 and 4 of the SEIS. The NRC staff also reviewed radiological environmental monitoring program (REMP) reports, which show that concentrations of radioactive contaminants related to nuclear power plants in the vicinity of Fermi 2 are very low (at or near the threshold of the survey instruments detection capability) and seldom above background levels. Based on the review of this data, no disproportionately high and adverse human health impacts would be expected in minority and low-income populations.

Additionally, in a report published in 2001, the American Cancer Society concluded that although reports about cancer case clusters in communities surrounding nuclear power plants have raised public concern, studies show that clusters do not occur more often near nuclear plants than they do by chance elsewhere in the population. The National Council on Radiation Protection and Measurements has observed no statistically significant data that support an increased incidence of biological effects due to exposures at levels typical of worldwide fallout.

The American Cancer Society recognizes that public concern about environmental cancer risks often focuses on risks for which no carcinogenicity has been proven or on situations where known exposures to carcinogens are at such low levels that risks are negligible. The report states that ionizing radiation emissions from nuclear facilities are closely controlled and involve negligible levels of exposure for communities near such plants.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

A.2.14 Special Status Species and Habitats Comments 3-8, 4-8: These comments indicate that while the Fermi site has numerous endangered species on site, there was no analysis of the special status species in the SEIS.

Response: The NRC staffs discussion of threatened and endangered species is in Sections 3.8 and 4.8 of the SEIS. The Federally listed species in Monroe County, Michigan, are in SEIS Table 3-23. Section 4.8 of the SEIS discusses the potential impacts on the special status species listed in Table 3-23. SEIS Table 4-9 lists the NRC staffs effects determinations A-336

Appendix A for the Federally listed species from license renewal of Fermi 2 and for the energy alternatives evaluated. A copy of the SEIS was sent to the U.S. Department of Interior, Fish and Wildlife Service (FWS), by letter dated October 28, 2015 (ADAMS No. ML15288A167), requesting that the FWS review the NRC staffs assessment of special status species. On December 7, 2015, the FWS sent a letter (ADAMS No. ML16029A074) stating that it concurs with the NRC staffs determination.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

Comments 20-1 and 43-1: These are the comments provided by the U.S Department of Interior and the FWS regarding the NRC staffs evaluation of special status species.

Response: These comments are in response to the NRC staffs request for the FWS to review and concur with the effects determination for special status species discussed in the SEIS. On December 7, 2015, the FWS sent a letter (ADAMS No. ML16029A074) stating that it concurs with the NRC staffs determination. On December 28, 2015, the U.S. Department of the Interior submitted a letter (ADAMS No. ML16011A009) stating that the Department had no further comments on the SEIS. No changes were made to the SEIS as a result of these comments.

In September 2015, the FWS proposed adding the eastern massasauga rattlesnake as a threatened species. Sections 3.8 and 4.8 of the SEIS were revised to add a discussion of this rattlesnake. As noted in Section 4.8.1, the NRC determined that license renewal of Fermi 2 would have no effect on the eastern massasauga rattlesnake because it is not likely to be found within the area of the plant.

A.2.15 Support for License Renewal Comments 9-1, 10-1, 14-1, 19-1, 30-1, 33-1, 34-1, 35-1, 44-1, 46-1, 48-1, 55-1, and 62-1:

These comments are supportive of the Fermi 2 license renewal for the economic contribution DTE makes to the region.

Response: These comments are in support of Fermi 2s license renewal, generally due to the economic support the plant provides to the area. These comments provide no new information, and will not be addressed further. The SEIS has not been revised as a result of these comments.

Comments 17-1, 39a-1, and 39b-1: These comments are supportive of the Fermi 2 license renewal because of DTEs support for environmental projects in Monroe Harbor and with the Detroit River International Wildlife Refuge.

Response: These comments are in support of Fermi 2s license renewal due to the support the plant provided to the surrounding wildlife area. These comments provide no new information and will not be addressed further. The SEIS has not been revised as a result of these comments.

Comments 8-1, 13-1, 15-1, 21-1, 27-1, 36-1, 38-1, 44-1, 51-1, 56-1, 59-1, 60-1, and 65-1:

These comments are supportive of Fermi 2 license renewal for both economic and environmental reasons.

Response: These comments are in support of Fermi 2s license renewal for both economic and environmental reasons. These comments provide no new information and will not be addressed further. The SEIS has not been revised as a result of these comments.

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Appendix A A.2.16 Surface Water Resources Comments 11-3, 11-4, and 37-3: These comments express disapproval of taking large amounts of water from Lake Erie as cooling water for Fermi 2 and then discharging the water back into the lake at a higher temperature. These comments also state that discharging the heated water into Lake Erie violates the Great Lake Water Quality Act and other legal protections pertaining to water issues of the Great Lakes.

Response: These comments express disapproval of taking large amounts of water from Lake Erie as cooling water for Fermi 2 and then discharging the water back into the lake at a higher temperature. Sections 3.1.3, 3.5.1, and 3.7.1 discusses various aspects of the NPDES permit for Fermi 2. While nuclear power plants cannot operate without a valid NPDES permit, the NPDES permit is outside the scope of the NRCs regulatory authority. The NPDES permit for Fermi 2 is issued and overseen by the MDEQ.

In June 2015, the Governors of Michigan and Ohio and the Premier of the Province of Ontario signed the Western Basin of Lake Erie Collaborative Agreement in an effort to work together to improve the water quality and environmental conditions in the Western Lake Erie Basin. The goals are to achieve a 40-percent total load reduction in the amount of total and dissolved reactive phosphorus entering Lake Eries western basin by the year 2025. The text of the agreement can be found at: http://www.michigan.gov/documents/snyder/

Western_Basin_of_Lake_Erie_Collaborative_Agreement--Lieutenant_Governor_491709_7.pdf.

On January 14, 2016, MDEQ, Water Resources Division, published Michigans Implementation Plan for the Western Lake Erie Basin Collaborative. The purpose of the plan is to define the actions the State of Michigan needs to take to help meet the Western Basin of Lake Erie Collaborative Agreement. The full text of the report can be found at https://www.michigan.gov/documents/deq/wrd-western-lake-erie_503547_7.pdf.

These comments provide no new information. The SEIS has not been revised as a result of these comments.

A.2.17 Terrestrial Resources Comment 24-26: This comment states that Table 3-11 does not include the eastern fox snake and also may provide contradictory information relating to the eastern fox snake being observed on the plant property.

Response: This comment notes that text in Section 3.6.5.1 and in Table 3-11 of the SEIS appears to present contradictory information regarding the observation of the eastern fox snake on the Fermi site in 2008 and 2009. Upon reviewing the SEIS, the NRC staff did not find contradictory information. Table 3-11 specifically applies to a wildlife survey conducted by Black & Veatch. The eastern fox snake was not recorded as occurring on the site during this survey. However, as indicated in Section 3.6.5.1 of the SEIS, the species was observed within site wetlands west of Doxy Road in May and June 2008, during the Ducks Unlimited wetland delineation effort. For clarity, the NRC has revised Table 3-11 in Section 3.6.3 to include the eastern fox snake with a footnote indicating that the species was not formally observed during the Black & Veatch wildlife survey.

Comment: 24-27: This comments states that the number of bird strikes listed in SEIS Table 3-15 is incorrect.

Response: This comment notes that the NRC omitted a bird strike record for May 22, 2008, in SEIS Table 3-15. This table has been revised to include the omitted record.

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Appendix A Comment: 24-49: This comment states that the use of the phrase protected area in SEIS Section 4.6.1.1 should be revised because this section is describing impacts to terrestrial resources and the phrase protected area has a distinct meaning with regard to plant security.

Response: This comment suggests that the phrase developed area be used in place of the phrase protected area when describing site landscape maintenance activities. The phrase protected area is defined in 10 CFR Part 73, Physical Protection of Plants and Materials, with regard to plant security. Using the phrase developed area will avoid confusion with the specific meaning of the term protected area. The NRC agrees with the commenters suggested language and revised the text in Section 4.6.1.1.

Comment 24-50: This comment indicates that DTEs cooperative agreement with the FWS for management of part of the Fermi site within the Detroit River International Wildlife Refuge was attributed to the wrong source.

Response: The NRC staff agrees with this comment. The NRC staff has corrected this error and revised the text in Section 4.6.1.1 accordingly.

Comment 24-71: The comment suggests that a discussion of the recovery of mayfly populations in more recent years be added.

Response: The NRC staff agrees with this comment. A sentence that notes the recovery of mayfly populations and possible causes of the recovery was added to SEIS Section 4.16.5.

A.2.18 Waste Management Comment 11-15: This comment questions who regulates the solid radioactive waste systems portable solidification and dewatering system that was supplied and operated by a vendor.

Response: Regardless of whether the licensee or a vendor is operating equipment on site, the licensee must ensure the equipment is being used in accordance with plant procedures. The NRC has regulatory authority over any equipment that is associated with the plants radioactive waste. Two NRC Resident Inspectors are assigned to each plant on a full-time basis and oversee the day-to-day plant operations.

No new information was provided by these comments. Therefore, no changes to the SEIS were made.

Comments 18-1, 42a-6, 42a-10, 53b-6, and 53b-10: These comments express disapproval that radioactive waste is being generated and stored at Fermi 2. These comments also state that the current best practice for storing spent nuclear fuel (SNF) is hardened onsite storage.

Response: SEIS Section 3.1.4.4, Radioactive Waste Storage, discusses that SNF is stored at Fermi 2 in the spent fuel pool and in dry casks. The spent fuel pool is constructed of steel-reinforced concrete walls, has a stainless steel liner, and is filled with water. The spent fuel pool is located inside the plants protected area. The spent fuel pool and the dry storage casks are evaluated and inspected as part of the day-to-day operations of Fermi 2. The NRC regularly inspects Fermi 2s spent fuel storage program to ensure the safety of the SNF stored in the spent fuel pool. The NRCs safety requirements for the storage of SNF during licensed operations, including requirements related to the spacing of spent fuel rods in the pool, ensure that the expected increase in the volume of SNF during the license renewal term can be safely stored on site.

The regulations for storing SNF are contained in 10 CFR Part 72. SNF must be stored in casks that have been reviewed and have a current Certificate of Compliance. Fermi 2 stores SNF in NRC-approved dry cask canisters made of leak-tight welded and bolted steel at an onsite A-339

Appendix A independent spent fuel storage installation (ISFSI). The ISFSI is discussed in Section 3.1.4.4, Radioactive Waste Storage, where it is noted that there is capacity for 64 dry casks, with the ability to expand the ISFSI to accommodate 32 additional dry casks, if needed. Therefore, Fermi 2 has adequate onsite storage for SNF. The NRC staffs evaluation of impacts from the onsite storage of SNF, offsite radiological impacts of SNF, high-level waste disposal, and the uranium fuel cycle are addressed in Section 4.13.1 of this SEIS. There are no NRC regulations requiring licensees to use hardened onsite storage to store SNF.

No new information was provided by these comments. Therefore, no changes to the SEIS were made.

A.2.19 References 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, Standards for protection against radiation.

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental protection regulations for domestic licensing and related regulatory functions.

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for renewal of operating licenses for nuclear power plants.

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, Packaging and transportation of radioactive material.

10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, Licensing requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related Greater than Class C waste.

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, Physical protection of plants and materials.

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

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

[DTE] DTE Electric Company. 2014b. Applicants Environmental ReportOperating License Renewal Stage, Fermi 2. Newport, MI: DTE Electric Company. April 2014. ADAMS Nos. ML14121A538, ML14121A539, and ML14121A540.

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Final Report. Washington, DC: U.S. Nuclear Regulatory Commission. NUREG-1437, Volumes 1 and 2. May 31, 1996. ADAMS Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, in Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC:

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

ADAMS No. ML040690720.

[NRC] U.S. Nuclear Regulatory Commission. 2002. Generic Environmental Impact Statement Decommissioning of Nuclear Plants. Washington, DC: U.S. Nuclear Regulatory Commission.

NUREG-0586, Supplement 1. November 2002. ADAMS No. ML023500395.

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[NRC] U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Revision 1. Washington, DC: U.S. Nuclear Regulatory Commission. NUREG-1437, Volumes 1, 2, and 3. June 19, 2013. 1,535 p. ADAMS No. ML13107A023.

[NRC] U.S. Nuclear Regulatory Commission. 2014a. MACCS Best Practices as Applied in the State-of-the-Art Reactor Consequence Analyses (SOARCA) Project. Washington, DC: U.S.

Nuclear Regulatory Commission. NUREG/CR-7009. August, 2014. 197 p. ADAMS No. ML14234A148.

[NRC] U.S. Nuclear Regulatory Commission. 2014b. Letter from W. Dean, Director, Office of Nuclear Reactor Regulation, to D. Miskokomon, Chief, Walpole Island First Nation.

Subject:

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

ADAMS No. ML14279A562.

[NRC] U.S. Nuclear Regulatory Commission. 2015. Environmental Impact Statement Scoping Summary Report, Fermi 2, Frenchtown Township, MI. Rockville, MD: U.S. Nuclear Regulatory Commission. October 2015. ADAMS No. ML15252A015.

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APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS

B. Applicable laws, Regulations, and Other Requirements There are a number of Federal laws and regulations that affect environmental protection, health, safety, compliance, and/or consultation at every nuclear power plant licensed by the U.S. Nuclear Regulatory Commission (NRC). Certain Federal environmental requirements have been delegated to state authorities for enforcement and implementation. Furthermore, states have also enacted laws to protect public health and safety and the environment. It is the NRCs policy to make sure nuclear power plants are operated in a manner that provides adequate protection of public health and safety and protection of the environment through compliance with applicable Federal and state laws, regulations, and other requirements.

The requirements that may be applicable to the operation of NRC-licensed nuclear power plants encompass a broad range of Federal laws and regulations, addressing environmental, historic and cultural, health and safety, transportation, and other concerns. Generally, these laws and regulations are relevant to how the work involved in performing a proposed action would be conducted to protect workers, the public, and environmental resources. Some of these laws and regulations require permits or consultation with other Federal agencies or state, tribal, or local governments.

The Atomic Energy Act of 1954, as amended (AEA) (42 U.S.C. 2011 et seq.) authorizes the NRC to enter into agreement with any state to assume regulatory authority for certain activities (see 42 U.S.C. 2021). Michigan has not yet entered into an agreement with the NRC to assume regulatory responsibility over certain byproduct, source, and quantities of special nuclear materials not sufficient to form a critical mass. Although not an Agreement State, the Michigan Department of Environmental Quality (MDEQ) does maintain a network of environmental monitoring stations around each nuclear power plant site in the State. In addition, the MDEQ maintains a Radiological Emergency Preparedness Program to provide response capabilities to radiological accidents or emergencies at any of Michigans commercial nuclear power plants (MDEQ undated).

In addition to carrying out some Federal programs, state legislatures develop their own laws.

State statutes supplement, as well as implement, Federal laws for protection of air, water quality, and groundwater. State legislation may address solid waste management programs, locally rare or endangered species, and historic and cultural resources.

The Clean Water Act (33 U.S.C. 1251 et seq., herein referred to as CWA) allows for primary enforcement and administration through state agencies, given that the state program is at least as stringent as the Federal program. The state program must conform to the CWA and to the delegation of authority for the Federal National Pollutant Discharge Elimination System (NPDES) program from the U.S. Environmental Protection Agency (EPA) to the state. The primary mechanism to control water pollution is the requirement for direct dischargers to obtain an NPDES permit, or, as is the case for Michigan, the authority has been delegated from EPA, a State Pollutant Discharge Elimination System permit, under the CWA.

One important difference between Federal regulations and certain state regulations is the definition of waters regulated by the state. Certain state regulations may include underground waters, whereas the CWA only regulates surface waters. The MDEQ Water Resources Division provides regulatory oversight for all public water supplies, issues permits to regulate the discharge of industrial and municipal wastewatersincluding discharges to groundwater and monitors State water resources for water quality (MDEQ undated).

B-1

Appendix B B.1 Federal and State Requirements Fermi 2 is subject to Federal and State requirements. Table B-1 lists the principal Federal and State regulations and laws that are used or mentioned in this supplemental environmental impact statement for Fermi 2.

Table B-1. Federal and State Requirements Law/regulation Requirements Current operating license and license renewal Atomic Energy Act, The Atomic Energy Act (AEA) of 1954, as amended, and the Energy 42 U.S.C. 2011 et seq. Reorganization Act of 1974 (42 U.S.C. 5801 et seq.) give the NRC the licensing and regulatory authority for nuclear energy uses within the commercial sector. These regulations give the NRC responsibility for licensing and regulating commercial uses of atomic energy and allow the NRC to establish dose and concentration limits for protection of workers and the public for activities under NRC jurisdiction. The NRC implements its responsibilities under the AEA through regulations set forth in Title 10, Energy, of the Code of Federal Regulations (CFR).

National Environmental The National Environmental Policy Act (NEPA), as amended, requires Policy Act of 1969, Federal agencies to integrate environmental values into their 42 U.S.C. 4321 et seq. decisionmaking process by considering the environmental impacts of proposed Federal actions and reasonable alternatives to those actions.

NEPA establishes policy, sets goals (in Section 101), and provides means (in Section 102) for carrying out the policy. Section 102(2) contains action-forcing provisions to ensure that Federal agencies follow the letter and spirit of the Act. For major Federal actions significantly affecting the quality of the human environment, Section 102(2)(C) of NEPA requires Federal agencies to prepare a detailed statement that includes the environmental impacts of the proposed action and other specified information.

10 CFR Part 51 Regulations in 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions, contain environmental protection regulations applicable to the NRCs domestic licensing and related regulatory functions.

10 CFR Part 54 Regulations in 10 CFR Part 54, Requirements for renewal of operating licenses for nuclear power plants, are NRC regulations that govern the issuance of renewed operating licenses and renewed combined licenses for nuclear power plants licensed pursuant to Sections 103 or 104b of the AEA, as amended, and Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242). The regulations focus on managing adverse effects of aging. The rule is intended to ensure that important systems, structures, and components will maintain their intended functions during the period of extended operation.

B-2

Appendix B Law/regulation Requirements 10 CFR Part 50 Regulations in 10 CFR Part 50, Domestic licensing of production and utilization facilities, are NRC regulations issued under the AEA, as amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242), to provide for the licensing of production and utilization facilities. This part also gives notice to all persons who knowingly supplyto any licensee, applicant, contractor, or subcontractorcomponents, equipment, materials, or other goods or services that relate to a licensees or applicants activities subject to this part that they may be individually subject to NRC enforcement action for violation of 10 CFR 50.5.

Air quality protection Clean Air Act, The Clean Air Act (CAA) is intended to protect and enhance the quality of 42 U.S.C. 7401 et seq. the Nations air resources so as to promote the public health and welfare and the productive capacity of its population. The CAA establishes regulations to ensure maintenance of air quality standards and authorizes individual states to manage permits. Section 118 of the CAA requires each Federal agency, with jurisdiction over properties or facilities engaged in any activity that might result in the discharge of air pollutants, to comply with all Federal, state, interstate, and local requirements with regard to the control and abatement of air pollution. Section 109 of the CAA directs the U.S. Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS) for criteria pollutants. The EPA has identified and set NAAQS for the following criteria pollutants: particulate matter, sulfur dioxide, carbon monoxide, ozone, nitrogen dioxide, and lead.

Section 111 of the CAA requires establishment of national performance standards for new or modified stationary sources of atmospheric pollutants. Section 160 of the CAA requires that specific emission increases must be evaluated before permit approval to prevent significant deterioration of air quality. Section 112 requires specific standards for release of hazardous air pollutants (including radionuclides). These standards are implemented through plans developed by each state and approved by EPA. The CAA requires sources to meet standards and obtain permits to satisfy those standards. Nuclear power plants may be required to comply with the CAA Title V, Sections 501-507, for sources subject to new source performance standards or sources subject to National Emission Standards for Hazardous Air Pollutants. Emissions of air pollutants are regulated by EPA in 40 CFR Parts 50 to 99.

Michigan Compiled Laws, This part of the Michigan Compiled Laws (MCLs) implements the Chapter 324, Natural requirements of the CAA.

Resources and Environmental Protection, Part 55, Air Pollution Control B-3

Appendix B Law/regulation Requirements Water resources protection Clean Water Act, The Clean Water Act (CWA) was enacted to restore and maintain the 33 U.S.C. 1251 et seq., and chemical, physical, and biological integrity of the Nations water. The Act the NPDES requires all branches of the Federal Government, with jurisdiction over (40 CFR Part 122) properties or facilities engaged in any activity that might result in a discharge or runoff of pollutants to surface waters, to comply with Federal, state, interstate, and local requirements. As authorized by the CWA, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. The NPDES program requires all facilities that discharge pollutants from any point source into waters of the United States obtain an NPDES permit. A nuclear power plant may also participate in the NPDES General Permit for Industrial Stormwater due to stormwater runoff from industrial or commercial facilities to waters of the United States. EPA is authorized under the CWA to directly implement the NPDES program; however, EPA has authorized many states to implement all or parts of the national program. Section 401 of the CWA requires states to certify that the permitted discharge would comply with all limitations necessary to meet established state water quality standards, treatment standards, or schedule of compliance.

The U.S. Army Corps of Engineers (USACE) is the lead agency for enforcement of CWA wetland requirements (33 CFR Part 320). Under Section 401 of the CWA, EPA or a delegated state agency has the authority to review and approve, condition, or deny all permits or licenses that might result in a discharge to waters of the state, including wetlands.

Coastal Zone Management Congress enacted the Coastal Zone Management Act (CZMA) in 1972 to Act of 1972, as amended address the increasing pressures of over-development upon the Nations (16 U.S.C. 1451 et seq.) coastal resources. The National Oceanic and Atmospheric Administration administers the Act. The CZMA encourages states to preserve, protect, develop, and, where possible, restore or enhance valuable natural coastal resources such as wetlands, floodplains, estuaries, beaches, dunes, barrier islands, and coral reefs, as well as the fish and wildlife using those habitats. Participation by states is voluntary. To encourage states to participate, the CZMA makes Federal financial assistance available to any coastal state or territory, including those on the Great Lakes, which are willing to develop and implement a comprehensive coastal management program.

Wild and Scenic Rivers Act, The Wild and Scenic River Act created the National Wild and Scenic 16 U.S.C. 1271 et seq. Rivers System, which was established to protect the environmental values of free flowing streams from degradation by impacting activities, including water resources projects.

MCL, Chapter 324, Natural These parts of the MCL implement the requirements of the CWA.

Resources and Environmental Protection, Part 31, Water Resources Protection, and Part 41, Sewerage Systems B-4

Appendix B Law/regulation Requirements MCL, Chapter 324, Natural This part of the MCL sets forth the standards for the construction and Resources and maintenancewhich includes dredgingof artificial waterways along the Environmental Protection, Great Lakes.

Part 325, Great Lakes Submerged Lands Waste management and pollution prevention Resource Conservation and The Resource Conservation and Recovery Act (RCRA) requires EPA to Recovery Act, define and identify hazardous waste; establish standards for its 42 U.S.C. 6901 et seq. transportation, treatment, storage, and disposal; and require permits for persons engaged in hazardous waste activities. Section 3006 (42 U.S.C. 6926) allows states to establish and administer these permit programs with EPA approval. The EPA regulations implementing the RCRA are found in 40 CFR Parts 260 through 283. Regulations imposed on a generator or on a treatment, storage, and/or disposal facility vary according to the type and quantity of material or waste generated, treated, stored, and/or disposed. The method of treatment, storage, and/or disposal also impacts the extent and complexity of the requirements.

Pollution Prevention Act, The Pollution Prevention Act establishes a national policy for waste 42 U.S.C. 13101 et seq. management and pollution control that focuses first on source reduction, then on environmental issues, safe recycling, treatment, and disposal.

10 CFR Part 20 Regulations in 10 CFR Part 20, Standards for protection against radiation, establish standards for protection against ionizing radiation resulting from activities conducted under licenses issued by the NRC.

These regulations are issued under the AEA of 1954, as amended, and the Energy Reorganization Act of 1974, as amended. The purpose of these regulations is to control the receipt, possession, use, transfer, and disposal of licensed material by any licensee in such a manner that the total dose to an individual (including doses resulting from licensed and unlicensed radioactive material and from radiation sources other than background radiation) does not exceed the standards for protection against radiation prescribed in the regulations in this part.

MCL, Chapter 324, Natural This part of the MCL sets forth the standards for the generation, Resources and disposition, storage, treatment, and transportation of hazardous waste.

Environmental Protection, Part 111, Hazardous Waste Management MCL, Chapter 324, Natural This part of the MCL sets forth the standards for underground storage Resources and tanks.

Environmental Protection, Part 211, Underground Storage Tank Regulations Act 429 of 1980, the South This Act sets forth the standards for the transportation of radioactive waste Carolina Radioactive Waste into or within South Carolina.

Transportation and Disposal Act Tennessee Department of This rule establishes the requirements for the licensing of shippers of Environment and radioactive material into or within Tennessee.

Conservation Rule 1200-2-10-32 B-5

Appendix B Law/regulation Requirements Utah Administrative Code, This rule establishes the requirements for the issuance of permits to R313, Environmental generators for accessing a land disposal facility located within Utah and Quality, Radiation Control, requirements for shippers.

Rule R313-26, Generator Site Access Permit Requirements for Accessing Utah Radioactive Waste Disposal Facilities Protected species Endangered Species Act, The Endangered Species Act (ESA) was enacted to prevent the further 16 U.S.C. 1531 et seq. decline of endangered and threatened species and to restore those species and their critical habitats. Section 7 of the Act requires Federal agencies to consult with the U.S. Fish and Wildlife Service or the National Marine Fisheries Service (NMFS) on Federal actions that may affect listed species or designated critical habitats.

Magnuson-Stevens Fishery The Magnuson-Stevens Fishery Conservation and Management Act, as Conservation and amended, governs marine fisheries management in U.S. Federal waters.

Management Act, The Act created eight regional fishery management councils and includes 16 U.S.C. 1801-1884 measures to rebuild overfished fisheries, protect essential fish habitat, and reduce bycatch. Under Section 305 of the Act, Federal agencies are required to consult with NMFS for any Federal actions that may adversely affect essential fish habitat.

Historic preservation and cultural resources National Historic The National Historic Preservation Act was enacted to create a national Preservation Act, historic preservation program, including the National Register of Historic 16 U.S.C. 470 et seq.

Places and the Advisory Council on Historic Preservation. Section 106 of the Act requires Federal agencies to take into account the effects of their undertakings on historic properties. The Advisory Council on Historic Preservation regulations implementing Section 106 of the Act are found in 36 CFR Part 800. The regulations call for public involvement in the Section 106 consultation process, including Indian tribes and other interested members of the public, as applicable.

B.2 Operating Permits and Other Requirements Table B-2 lists the permits and licenses issued by Federal, State, and local authorities for activities at Fermi 2.

Table B-2. Licenses and Permits Permit Number Dates Responsible Agency Operating License NPF-43 Issued: 07/15/1985 NRC Expires: 03/20/2025 NPDES Permit MI0037028 Issued: 06/03/2010 MDEQ Water Resources Expires: 10/01/2014(a) Division Industrial/Non-Domestic User 1020 Issued: 08/28/2015 City of Monroe Discharge Permit Expires: 8/31/2018 B-6

Appendix B Permit Number Dates Responsible Agency Federal Clean Air Act MI-ROP-B4321-2013 Issued: 11/01/2013 MDEQ Air Quality Renewable Operating Permit Expires: 11/01/2018 Division Hazardous Waste Generator MID087056685 Not Applicable MDEQ Identification Great Lakes Submerged 11-58-0055-P Issued: 04/25/2012 MDEQ Lands Permit Expires: 04/25/2017 Underground Storage Tank 00010793 Renewed annually MDEQ Registration Certificate Great Lakes Submerged 13-58-0013-P Issued: 06/25/2013 MDEQ Lands Permit (After-the-Fact) Expires: 06/25/2018 Federal Water Pollution LRE-1988-10408-L15 Issued: 09/10/2015 USACE Control Act Section 404 Expires: 09/10/2025 Individual Permit Federal Water Pollution LRE-1988-10408-N13 Issued: 03/20/2013 USACE Control Act Section 404 Expires: 08/22/2023 Letter of Permission Hazardous Materials 060115550071XZ Issued: 06/01/2015 U.S. Department of Certificate of Registration Expires: 06/30/2018 Transportation, Pipeline and Hazardous Materials Safety Administration Permit to transport 0233-21-13 Renewed annually South Carolina radioactive waste Department of Health and Environmental Control License to deliver radioactive T-MI004-L13 Renewed annually Tennessee Department material of Environment and Conservation Permit to deliver radioactive 0203001330 Renewed annually Utah Department of material Environmental Quality (a) Administratively extended pending review of DTE Electric Companys application for reissuance.

Source: DTE 2014 B.3 References 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, Standards for protection against radiation.

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic licensing of production and utilization facilities.

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental protection regulations for domestic licensing and related regulatory functions.

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for renewal of operating licenses for nuclear power plants.

40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122, EPA administered permit programs: the National Pollutant Discharge Elimination System.

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

Clean Air Act of 1963, as amended. 42 U.S.C. § 7401 et seq.

Clean Water Act of 1977, as amended. 33 U.S.C. § 1251 et seq.

Coastal Zone Management Act of 1972, as amended. 16 U.S.C. § 1451 et seq.

[DTE] DTE Electric Company. 2014. Applicants Environmental ReportOperating License Renewal Stage, Fermi 2. Newport, MI: DTE. April 2014. ADAMS Nos. ML14121A538, ML14121A539, and ML14121A540.

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

Energy Reorganization Act of 1974. 42 U.S.C. § 5801 et seq.

Fish and Wildlife Coordination Act of 1934, as amended. 16 U.S.C. § 661 et seq.

[MDEQ] Michigan Department of Environmental Quality, Office of Waste Management and Radiological Protection. Undated. Available at <http://www.michigan.gov/deq/0,1607,7-135-3312_4120---,00.html> (accessed 12 January 2015).

[MDEQ] Michigan Department of Environmental Quality, Water Resources Division. Undated.

Available at <http://www.michigan.gov/deq/0,1607,7-135-3313---,00.html> (accessed 12 January 2015).

Marine Mammal Protection Act of 1972, as amended. 16 U.S.C. § 1361 et seq.

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

16 U.S.C. § 1801 et seq.

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

National Historic Preservation Act of 1966, as amended. 16 U.S.C. § 470 et seq.

Pollution Prevention Act of 1990. 42 U.S.C. § 13101 et seq.

Resource Conservation and Recovery Act of 1976, as amended. 42 U.S.C. § 6901 et seq.

Wild and Scenic Rivers Act, as amended. 16 U.S.C. § 1271 et seq.

B-8

CONSULTATION CORRESPONDENCE

C. Consultation Correspondence C.1 Section 7 Consultation C.1.1 Federal Agency Obligations under ESA Section 7 As a Federal agency, the U.S. Nuclear Regulatory Commission (NRC) must comply with the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.; herein referred to as ESA), as part of any action authorized, funded, or carried out by the agency, such as the proposed agency action that this supplemental environmental impact statement (SEIS) evaluates: whether to issue a renewed license for the continued operation of Fermi 2 for an additional 20 years beyond the current license terms. Under section 7 of the ESA, the NRC must consult with the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) (referred to jointly as the Services and individually as Service), as appropriate, to ensure that the proposed agency action is not likely to jeopardize the continued existence of any endangered or threatened species or result in the destruction or adverse modification of designated critical habitat.

The ESA and the regulations that implement ESA section 7 (Title 50 of the Code of Federal Regulations (50 CFR) Part 402, Interagency cooperationEndangered Species Act of 1973, as amended) describe the consultation process that Federal agencies must follow in support of agency actions. As part of this process, the Federal agency shall either request that the Services provide a list of any listed or proposed species or designated or proposed critical habitats that may be present in the action area or request that the Services concur with a list of species and critical habitats that the Federal agency has created (50 CFR 402.12(c)). If it is determined that any such species or critical habitats may be present, the Federal agency is to prepare a biological assessment to evaluate the potential effects of the action and determine whether the species or critical habitat are likely to be adversely affected by the action (16 U.S.C. 1536(c); 50 CFR 402.12(a)). Furthermore, biological assessments are required for any agency action that is a major construction activity (50 CFR 402.12(b)), which the ESA regulations define to include major Federal actions significantly affecting the quality of the human environment under the National Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.; herein referred to as NEPA) (50 CFR 402.02).

Federal agencies may fulfill their obligations to consult with the Services under ESA section 7 and to prepare a biological assessment in conjunction with the interagency cooperation procedures required by other statutes, including NEPA (50 CFR 402.06(a)). In such cases, the Federal agency should include the results of the ESA section 7 consultation in the NEPA document (50 CFR 402.06(b)). Accordingly, Section C.3 explains why this SEIS fulfills NRCs obligation to prepare a biological assessment under ESA section 7, and Section C.4 describes the chronology and results of the ESA section 7 consultation.

C.2 Biological Assessment The NRC considers this SEIS to fulfill its obligation to prepare a biological assessment under ESA section 7. Accordingly, the NRC did not prepare a separate biological assessment for the proposed Fermi 2 license renewal.

Although the contents of a biological assessment are at the discretion of the Federal agency (50 CFR 402.12(f)), the ESA regulations suggest information that agencies may consider for inclusion. The NRC has considered this information in the following sections.

C-1

Appendix C Section 3.8 describes the action area and the Federally listed and proposed species and designated and proposed critical habitat that have the potential to be present in the action area.

This section includes information pursuant to 50 CFR 402.12(f)(1), (2), and (3).

Section 4.8 provides an assessment of the potential effects of the proposed Fermi 2 license renewal on the species and critical habitat present and the NRCs effect determinations, which are consistent with those identified in Section 3.5 of the Endangered Species Consultation Handbook (FWS and NMFS 1998). The NRC also addresses cumulative effects and alternatives to the proposed action. This section includes information pursuant to 50 CFR 402.12(f)(4) and (5).

C.3 Chronology of ESA Section 7 Consultation Upon receipt of DTE Electric Companys (DTE) license renewal application (LRA), the NRC staff considered whether any Federally listed or proposed species or designated or proposed critical habitats may be present in the action area (as defined at 50 CFR 402.02) for the proposed Fermi 2 license renewal. No species under the NMFSs jurisdiction occur within the action area.

Therefore, the NRC staff did not consult with the NMFS. With respect to species under the FWSs jurisdiction, the NRC staff compiled a list of ESA-protected species and critical habitats within the vicinity of the facility and requested the FWSs concurrence with this list in accordance with the ESA section 7 regulations at 50 CFR 402.12(c) in a letter dated July 1, 2014. The FWS concurred with the NRC staffs list in its letter dated July 30, 2014. The NRC staff used this list as a starting point for its analysis of effects to Federally listed species and critical habitat, which appears in Sections 3.8 and 4.8 of this SEIS. Since publishing the draft supplemental environmental impact statement (DSEIS), NRC staff updated the species list to reflect the proposed listing of the eastern massasauga (Sistrurus catenatus) as a threatened species.

Because the SEIS constitutes the biological assessment, the NRC staff submitted a copy of the DSEIS, upon its issuance, to the FWS for review in accordance with 50 CFR 402.12(j). In comments on the DSEIS, FWS (2015) stated that they concur with the NRCs determination that the proposed action would have no effect on the Karner blue butterfly (Lycaeides melissa samuelis), northern riffleshell (Epioblasma torulosa rangiana), snuffbox mussel (Epioblasma triquetra), and rayed bean mussel (Villosa fabalis). FWS (2015) also notes that its concurrence on the NRCs no effect determination is not required.. In addition, FWS (2015) concurred with the NRCs determination that the proposed action may affect, but is not likely to adversely affect five listed species, the red knot (Calidris canutus), piping plover (Charadrius melodus),

Indiana bat (Myotis sodalis), eastern prairie fringed orchid (Platanthera leucophaea), and northern long-eared bat (Myotis septentrionalis), which may occur within the action area.

Since the publication of the DSEIS, the NRC staff has not identified any new information that would change its no effect determinations regarding Federally listed or proposed species or critical habitats. Thus, the NRC has fulfilled its obligations under section 7 of the ESA with respect to its review of the Fermi license renewal application. Table C-1 lists the letters, e-mails, and other correspondence related to the NRCs ESA review. Because this SEIS constitutes the NRCs biological assessment, the NRC staff will submit a copy of this SEIS, upon its issuance, to the FWS for review in accordance with 50 CFR 402.12(j).

C-2

Appendix C Table C-1. ESA Section 7 Consultation Correspondence Sender and Date Recipient Description ADAMS No. (a)

July 1, 2014 D. Wrona (NRC) Request for concurrence with list of ML14164A037 to T. Melius (FWS) Federally listed species and habitats for the proposed Fermi license renewal July 30, 2014 T. Dandridge (FWS) Concurrence with the NRCs list of ML14219A743 to M. Moser (NRC) Federally listed species and habitats October 28, 2015 D. Wrona (NRC) to S. Availability of the DSEIS for the ML15288A167 Hicks (FWS) proposed Fermi license renewal and the NRCs ESA determinations December 7, 2015 S. Hicks (FWS) to D. Concurrence with NRCs effect ML16029A074 Wrona (NRC) determination for Federally listed species These documents can be accessed through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://adams.nrc.gov/wba/.

C.4 Essential Fish Habitat Consultation The NRC must comply with the Magnuson-Stevens Fishery Conservation and Management Act, as amended (16 U.S.C. 1801-1884, herein referred to as Magnuson-Stevens Act) for any actions authorized, funded, or undertaken, or proposed to be authorized, funded, or undertaken that may adversely affect essential fish habitat (EFH).

In Sections 3.8 and 4.8 of this SEIS, the NRC staff concludes that NMFS has not designated EFH under the Magnuson-Stevens Act in Lake Erie and that the proposed Fermi 2 license renewal would have no effect on EFH. Thus, the Magnuson-Stevens Act does not require the NRC to consult with NMFS for the proposed Fermi 2 license renewal.

C.5 Section 106 Consultation The National Historic Preservation Act of 1966, as amended (NHPA), requires Federal agencies to consider the effects of their undertakings on historic properties and consult with applicable state and Federal agencies, tribal groups, and individuals and organizations with a demonstrated interest in the undertaking before taking action. Historic properties are defined as resources that are eligible for listing on the National Register of Historic Places. The historic preservation review process (Section 106 of the NHPA) is outlined in regulations issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800. In accordance with 36 CFR 800.8(c), the NRC has elected to use the NEPA process to comply with its obligations under Section 106 of the NHPA.

Table C-2 lists the chronology of consultation and consultation documents related to the NRC Section 106 review of the Fermi 2 license renewal. The NRC staff is required to consult with the noted agencies and organizations in accordance with the statutes listed above.

C-3

Appendix C Table C-2. NHPA Correspondence Sender and Date Recipient Description ADAMS No. (a)

July 8, 2014 D. Wrona (NRC) to Request for scoping comments/ ML14157A383 B. Conway, notification of Section 106 review Michigan Historical Center July 8, 2014 D. Wrona (NRC) to Request for scoping comments/ ML14155A207 R. Nelson (ACHP) notification of Section 106 review July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 D. Shalifoe Sr., concerning the Fermi 2 LRA review President, (notification of Section 106 review)

Keweenaw Bay Indian Community July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 L. Carrick, Sr., concerning the Fermi 2 LRA review Chairman, (notification of Section 106 review)

Bay Mills Indian Community July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 A. Pedwaydon, concerning the Fermi 2 LRA review Council Chair, (notification of Section 106 review)

Grand Traverse Band of Ottawa and Chippewa Indians July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 J. Williams Jr., concerning the Fermi 2 LRA review Tribal Chairman, (notification of Section 106 review)

Lac Vieux Desert Band of Lake Superior Chippewa Indians July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 F. Kiogima, Tribal concerning the Fermi 2 LRA review Chairman, (notification of Section 106 review)

Little Traverse Bay Bands of Odawa Indians July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 J. Warren, concerning the Fermi 2 LRA review Chairman, (notification of Section 106 review)

Pokagon Band of Potawatomi Indians July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 A. Payment, Tribal concerning the Fermi 2 LRA review Chairperson, (notification of Section 106 review)

Sault Ste. Marie Tribe of Chippewa Indians of Michigan C-4

Appendix C Sender and Date Recipient Description ADAMS No. (a)

July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 K. Meshigaud, Tribal concerning the Fermi 2 LRA review Chairperson, (notification of Section 106 review)

Hannahville Indian Community July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 H. Mandoka, concerning the Fermi 2 LRA review Chairman, (notification of Section 106 review)

Nottawaseppi Huron Band of the Potawatomi July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 S. Pago, Chief, concerning the Fermi 2 LRA review Saginaw Chippewa (notification of Section 106 review)

Indian Tribe of Michigan July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 D. Sprague, Tribal concerning the Fermi 2 LRA review Chairman, Match- (notification of Section 106 review) e-be-nash-she-wish Band of Pottawatomi Indians of Michigan July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 L. Romanelli, concerning the Fermi 2 LRA review Ogema, (notification of Section 106 review)

Little River Band of Ottawa Indians July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 H. Frank, Chairman, concerning the Fermi 2 LRA review Forest County (notification of Section 106 review)

Potawatomi July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 R. Sparkman, Chief, concerning the Fermi 2 LRA review Shawnee Tribe (notification of Section 106 review)

July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 C. Watkins, Acting concerning the Fermi 2 LRA review President, Delaware (notification of Section 106 review)

Nation July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 B. Friend, Chief, concerning the Fermi 2 LRA review Wyandotte Nation (notification of Section 106 review)

July 8, 2014 D. Wrona (NRC) to Request for scoping comments ML14157A354 E. Cook, Chief, concerning the Fermi 2 LRA review Ottawa Tribe of (notification of Section 106 review)

Oklahoma C-5

Appendix C Sender and Date Recipient Description ADAMS No. (a)

November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15294A101 R. Nelson, Office of Federal Agency Programs, Advisory Council on Historic Preservation November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15294A196 B. Conway, Michigan Historical Center November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 W. Swartx, President, Keweenaw Bay Indian Community November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 L. Carrick, Chairman, Bay Mills Indian Community November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 A. Pedwaydon, Council Chair, Grand Traverse Band of Ottawa and Chippewa Indians November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 J. Williams, Jr.,

Tribal Chairman, Lac Vieux Desert Band of Lake Superior November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 R. Gasco-Bentley, Tribal Chairperson, Little Traverse Bay Bands of Odawa Indians November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 J. Warren, Chairman, Pokagon Band of Potawatomi Indians November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 A. Payment, Tribal Chairperson, Sault Ste. Marie Tribe of Chippewa Indians of Michigan C-6

Appendix C Sender and Date Recipient Description ADAMS No. (a)

November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 K. Meshigaud, Tribal Chairperson, Hannahville Indian Community November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 D. Green, THPO/Chief Planning Officer, Nottawaseppi Huron Band of Potawatomi November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 S. Pego, Chief, Saginaw Chippewa Indian Tribe of Michigan November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 D. Sprague, Tribal Chairman, Matche-be-nash-she-which Band of Potawatomit Indians of Michigan November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 L. Romanelli, Ogema, Little River Band of Ottawa Indians November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 H. Frank, Chairman, Forest County Potawatomi November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 R. Sparkman, Chief, Shawnee Tribe November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 K. Holton, President, Delaware Nation November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 B. Friend, Chief, Wyandotte Nation November 3, 2015 D. Wrona (NRC) to Notice of availability of Fermi 2 DSEIS ML15293A442 E. Cook, Chief, Ottawa Tribe of Oklahoma These documents can be accessed through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://adams.nrc.gov/wba/.

C-7

Appendix C C.6 References 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part 800, Protection of historic properties.

50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, Interagency cooperationEndangered Species Act of 1973, as amended.

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

[FWS] U.S. Fish and Wildlife Service. 2013. Consultations: Frequently Asked Questions.

Available at <http://www.fws.gov/endangered/what-we-do/faq.html#8> (accessed 20 June 2014).

[FWS] U.S. Fish and Wildlife Service. 2015. Letter from S. Hicks, FWS, to D. Wrona, NRC,

Subject:

Re: Submittal of Draft Supplemental Environmental Impact Statement for License Renewal of Fermi 2 and request for concurrence under section 7 of the Endangered Species Act. December 7, 2015. ADAMS No. ML16029A074.

[FWS and NMFS] U.S. Fish and Wildlife Service and National Marine Fisheries Service. 1998.

Endangered Species Consultation Handbook: Procedures for Conducting Consultation and Conference Activities under Section 7 of the Endangered Species Act. March 1998. 315 p.

Available at <http://www.fws.gov/endangered/esa-library/pdf/esa_section7_handbook.pdf>

(accessed 8 July 2013).

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

16 U.S.C. § 1801-1884.

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

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

C-8

CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

D. Chronology of Environmental Review Correspondence This appendix, along with Appendix C, contains a chronological listing of correspondence between the U.S. Nuclear Regulatory Commission (NRC) and external parties as part of its environmental review for Fermi 2. Appendix C contains the chronological listing of consultation correspondence associated with the Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.),

the Magnuson-Stevens Fishery Conservation and Management Act, as amended (16 U.S.C. 1801-1884), and the National Historic Preservation Act, as amended (54 U.S.C. 300101 et seq.). Appendix D contains all other correspondence.

All documents, with the exception of those containing proprietary information, are available electronically in the NRCs Library, which is found on the Internet at the following Web address:

http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRCs Agencywide Documents Access and Management System (ADAMS), which provides text and image files of the NRCs public documents. The ADAMS number for each document is included in the following list. If you need assistance in accessing or searching in ADAMS, contact the Public Document Room Staff at 1-800-397-4209.

D.1 Environmental Review Correspondence Table D-1 lists the environmental review correspondence in date order beginning with the request by DTE Electric Company (DTE or the applicant) to renew the operating license for Fermi 2.

Table D-1. Environmental Review Correspondence Date Correspondence Description ADAMS No.

Apr 24, 2014 DTE Electric Company (DTE) LRA for Fermi 2 ML14121A554 May 5, 2014 U.S. Nuclear Regulatory Commission (NRC) Federal Register ML14098A284 Notice (FRN) of Receipt and Availability of the LRA for Fermi 2 May 5, 2014 NRC Letter to DTE, Notice of Receipt and Availability ML14097A168 Jun 11, 2014 NRC Letter to DTE, Determination of Acceptability and ML14150A416 Sufficiency for Docketing, Proposed Review Schedule, and Opportunity for a Hearing Regarding the Application from DTE for Renewal of the Operating License for Fermi 2 Jun 11, 2014 NRC FRN of Acceptability and Opportunity Request Hearing ML14150A340 Jun 20, 2014 NRC Letter to DTE, Notice of Intent To Prepare an ML14160B055 Environmental Impact Statement and Conduct Scoping Process for License Renewal for Fermi 2 Jun 20, 2014 NRC FRN of Notice of Intent To Prepare an Environmental ML14161A016 Impact Statement and Conduct Scoping Process for License Renewal for Fermi 2 Jul 3, 2014 NRC Letter to Michigan Department of Natural Resources ML14171A427 (MDNR), Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping Process for License Renewal of Fermi 2 Jul 8, 2014 NRC Letter to Advisory Council on Historic Preservation, ML14155A207 Fermi 2 LRA Review D-1

Appendix D Date Correspondence Description ADAMS No.

Jul 8, 2014 NRC Letter to Michigan State Historic Preservation Officer ML14157A383 (SHPO), Fermi 2 LRA Review Jul 21, 2014 Scoping Comment of Jim McDevitt on Behalf of Frenchtown ML14216A376 Charter Township Jul 21, 2014 Scoping Comment of Dr. Stephen J. McNew on Behalf of ML14219A583 Monroe County Intermediate School District Jul 22, 2014 Scoping Comment of Randy Richardville ML14219A580 Jul 23, 2014 Fermi 2 License Renewal Process and Environmental Scoping ML14204A058 Public Meeting Slides Jul 24, 2014 Scoping Comment of Michelle Dugan on Behalf of Monroe ML14234A188 County Chamber of Commerce Jul 24, 2014 Transcript from the Fermi 2 Scoping MeetingAfternoon ML14254A465 Session Jul 24, 2014 Transcript from the Fermi 2 Scoping MeetingEvening Session ML14254A470 Jul 24, 2014 Scoping Comment of Jessie Pauline Collins ML14234A189 Jul 24, 2014 Scoping Comment of Dick Micka ML14234A190 Jul 24, 2014 Scoping Comment of State Representative Dale W. Zorn on ML14234A191 Behalf of Michigan State 56th District Jul 24, 2014 Scoping Comment of Robert Tompkins on Behalf of DEAR ML14205A009 Alliance Aug 19, 2014 Scoping Comment of Vic and Gail Macks ML14234A339 Aug 19, 2014 Scoping Comment of U.S. Representative Tim Walberg on ML14234A192 Behalf of State of Michigan, 7th District Aug 26, 2014 Scoping Comment of Corinne Carey on Behalf of Dont Waste ML14252A140 Michigan Aug 26, 2014 Scoping Comment of Joanne Cantoni ML14252A141 Aug 27, 2014 Scoping Comment of Rosemary Doyle ML14252A171 Aug 27, 2014 Scoping Comment of Robert Simpson ML14252A143 Aug 27,2014 Scoping Comment of Mary Ann Baier ML14252A142 Aug 27, 2014 Scoping Comment of Phyllis Oster ML14252A170 Aug 28, 2014 Scoping Comment of Unknown Individual ML14252A172 Aug 28, 2014 Scoping Comment of Ed McArdle on Behalf of Sierra Club, ML14259A341 Michigan Chapter Aug 28, 2014 Scoping Comment of Ken Richards ML14252A173 Aug 28, 2014 Scoping Comment of Sandra Bihn ML14252A175 Aug 29, 2014 Scoping Comment of Jessie Pauline Collins ML14252A139 Aug 29, 2014 Scoping Comment of Carol Izant ML14252A176 Aug 29, 2014 Scoping Comment of David Schonberger ML14252A178 Aug 29, 2014 Scoping Comment of Michael J. Keegan ML14252A138 Aug 29, 2014 Scoping Comment of Michael Keegan on Behalf of Dont Waste ML14252A180 Michigan Aug 29, 2014 Scoping Comment of Robert Simpson ML14252A177 Aug 29, 2014 Scoping Comment of Mark Farris ML14252A186 D-2

Appendix D Date Correspondence Description ADAMS No.

Sep 3, 2014 NRC Letter to DTE, License Renewal Environmental Site Audit ML14224A353 Regarding Fermi 2 Sep 18, 2014 NRC Summary of Public Meeting To Discuss the License ML14233A450 Renewal and Environmental Scoping Processes for Fermi 2 Sep 22, 2014 Letter from Dan Miskokomon, Chief, Walpole Island First Nation, ML14265A490 to NRC, Fermi 2 Nuclear Reactor License NPF-43 Extension Application Oct 3, 2014 NRC Letter to DTE, License Renewal Environmental Site Audit ML14252A831 Regarding Fermi 2 Severe Accident Mitigation Alternatives (SAMAs)

Oct 15, 2014 NRC Letter to DTE, Summary of the Site Audit Related to the ML14274A304 Review of the LRA for Fermi 2 Oct 28, 2014 NRC Letter to DTE, Project Manager Change for the License ML14294A792 Renewal of Fermi 2 Oct 31, 2014 Letter from NRC to Dan Miskokomon, Chief, Walpole Island ML14295A239 First Nation, on the Fermi 2 Nuclear Reactor License NPF-43 Extension Application Nov 10, 2014 NRC Letter to DTE, Requests for Additional Information (RAIs) ML14275A004 for the Environmental Review of the Fermi 2 LRA Nov 17, 2014 Summary of the SAMAs Environmental Site Audit for Fermi 2 ML14294A812 Nov 18, 2014 NRC Letter to DTE, RAIs for the Review of the Fermi 2 SAMAs ML14308A358 Review of the Fermi 2 LRA Nov 20, 2014 Summary of Telephone Conference Call Held on ML14308A530 October 14, 2014, Between NRC and DTE Concerning RAIs Pertaining to the Fermi 2 LRA Environmental Review Nov 20, 2014 Summary of Telephone Conference Call Held on ML14308A598 October 20, 2014, Between NRC and DTE Concerning RAIs Pertaining to the Fermi 2 LRA Environmental Review Dec 9, 2014 DTE Letter to NRC, Response to License Renewal ML14344B000 Environmental Review RAIs Dec 15, 2014 Summary of Telephone Conference Call Held on ML14330A263 November 17, 2014, Between NRC and DTE Concerning RAIs Pertaining to the Fermi 2 LRA Environmental Review Jan 9, 2015 DTE Letter to NRC, Response to NRC RAI for the Review of the ML15009A358 Fermi 2 LRASAMAs Jan 12, 2015 Summary of Telephone Conference Call Held on ML15005A538 December 18, 2014, Between NRC and DTE Concerning Responses to RAIs Pertaining to the Fermi 2 LRA Environmental Review Feb 3, 2015 NRC Letter to DTE, RAIs for the Environmental Review of the ML15026A307 Fermi 2 LRASAMAs Feb 18, 2015 DTE Letter to NRC, Revision to Response to License Renewal ML15050A682 Environmental RAI SSSH-1 Feb 25, 2015 NRC Letter to DTE, Schedule and Project Manager Change ML15051A348 Mar 5, 2015 DTE Letter to NRC, Response to NRC RAI for the Review of the ML15064A099 Fermi 2 LRASAMAs D-3

Appendix D Date Correspondence Description ADAMS No.

Apr 9, 2015 NRC Letter to DTE, RAI for the Environmental Review of the ML15092A945 Fermi 2 LRASAMAs May 8, 2015 DTE Letter to NRC, Response to NRC RAI for the ML15141A163 Environmental Review of the Fermi 2 LRASAMAs Set 3 May 18, 2015 Summary of March 27, 2015 Telephone Conference Call Held ML15132A427 Between the U.S. NRC and DTW Electric Company Concerning Requests for Additional Information Pertaining to the SAMA Review of the Fermi 2 License Renewal Application Jun 29, 2015 NRC Letter to DTE, Change in the Environmental Review ML15160A297 Schedule Oct 29, 2015 NRC Letter to DTE, Notice of availability of Fermi 2 draft SEIS ML15289A433 (DSEIS)

Oct 29, 2015 NRC Letter to U. S. EPA, Region 5, Notice of availability of ML15292A378 Fermi 2 DSEIS Nov 6, 2015 Letter from S. McNew, Monroe County Intermediate School ML15329A303 District, Comments on DSEIS Nov 16, 2015 Letter from R. Tompkins, DEAR, Comments on DSEIS ML16021A435 Nov 18, 2015 Letter from M. Dugan, Monroe County Chamber of Commerce, ML16011A031 Comments on DSEIS Nov 24, 2015 Letter from J. Lievens, Monroe County Board of Directors, ML16020A337 Comments on DSEIS Nov 24, 2015 Letter from R. Vergiels, Comments on DSEIS ML16007A007 Nov 30, 2015 Letter from J. Sobczak, DTE Shareholders United, Comments ML15345A439 on DSEIS Nov 30, 2015 Letter from F. Mentel, Comments on DSEIS ML15343A014 Nov 30, 2015 Letter from C. Haugen, Jefferson Schools ML16007A006 Nov 30, 2015 Letter from J. McDevitt, Frenchtown Charter Township ML15356A371 Dec 2, 2015 Letter from S. Pierce, Monroe Center for Health Aging, ML16007A005 Comments on DSEIS Dec 2, 2015 Regulations.gov submittal from M Gruelle, Comments on DSEIS ML15343A420 Dec 2, 2015 Letter from K. Russeau, Community Foundation of Monroe ML16011A035 County, Comments on DSEIS Dec 3, 2015 Letter from R. Micka, Comments on DSEIS ML16011A033 Dec 15, 2015 Letter from V. Kaminskas, DTE, Comments on DSEIS ML15356A368 Dec 17, 2015 E-mail from C. Doherty, Comments on DSEIS ML16004A145 Dec 20, 2015 Regulations.gov submittal from S. Flum, Comments on DSEIS ML16011A020 Dec 20, 2015 Regulations.gov submittal from M. Baier, Comments on DSEIS ML16011A025 Dec 20, 2015 Regulations.gov submittal from G. Lee, Comments on DSEIS ML16011A021 Dec 20, 2015 Regulations.gov submittal from an anonymous individual, ML16011A024 Comments on DSESI Dec 20, 2015 Regulations.gov submittal from T. Schacht, Comments on ML16011A018 DSEIS Dec 20, 2015 Regulations.gov submittal from an anonymous individual, ML16011A026 Comments on DSEIS D-4

Appendix D Date Correspondence Description ADAMS No.

Dec 20, 2015 Regulations.gov submittal from M. Hormel, Comments on ML16011A023 DSEIS Dec 20, 2015 Regulations.gov submittal from S. Riopelle, Comments on ML16011A022 DSEIS Dec 20, 2015 Regulations.gov submittal from R. Tuscher, Comments on ML06011A016 DSEIS Dec 20, 2015 Regulations.gov submittal from G. Vande Velde, Comments on ML16011A017 DSEIS Dec 20, 2015 Regulations.gov submittal from M. Barnard, Comments on ML16011A019 DSEIS Dec 21, 2015 Letter from K. Westlake, U.S. EPA, Region 5, Comments on ML16007A008 DSEIS Dec 27, 2015 Regulations.gov submittal from P. Barker, Comments on DSEIS ML16011A028 Dec 28, 2015 Regulations.gov submittal from B. Loe, Comments on DSEIS ML16011A029 Dec 28, 2015 Regulations.gov submittal from D. Schonberger, Alliance to Halt ML16011A030 Fermi 3, Comments on DSEIS Dec 30, 2015 E-mail from J. Collins, Citizens Resistance at Fermi 2 (CRAFT), ML16007A009 Comments on DSEIS Jan 1, 2016 E-mail from A. Myatt, Alliance to Halt Fermi 3, Comments on ML16011A008 DSEIS Jan 4, 2016 E-mail from M. Muhich, Sierra Club Nuclear Free Michigan, ML16011A011 Comments on DSEIS Jan 4, 2016 Letter from L. Nelson, U.S. Department of Interior (transmitted ML16011A009 via e-mail from V. Darby), Comments on DSEIS Jan 4, 2016 E-mail from S. Michetti, Comments on DSEIS ML16011A012 Jan 4, 2016 E-mail from K. Barnes, Comments on DSEIS ML16011A036 Jan 4, 2016 E-mail from J. Collins, CRAFT, Comments on DSEIS ML16011A010 Jan 5, 2016 E-mail from M. Keegan, Dont Waste Michigan, Comments on ML16011A015 DSEIS Jan 5, 2016 E-mail from K. Kamps, Beyond Nuclear, Comments on DSEIS ML16011A014 Jan 6, 2016 Letter from J. Micka, Comments on DSEIS Ml16011A034 Jan 6, 2016 Letter from R. Lankford, Comments on DSEIS ML16011A032 Jan 6, 2016 Regulations.gov submittal from an anonymous individual, ML16011A027 Comments on DSEIS Jan 6, 2016 E-mail from M. Keegan, Dont Waste Michigan, Comments on ML16011A013 DSEIS Jan 13, 2016 Letter from D. Zorn, District 17 Senator, State of Michigan, ML16049A584 Comments on DSEIS Jan 21, 2016 Letter from R. Wicke, Comments on DSEIS ML16021A436 Jul 7, 2016 Letter from NRC to DTE, SAMA RAIs for the Review of the ML16188A192 Fermi 2 s LRA Jul 19, 2016 Letter from DTE to NRC, Response to SAMA RAIs ML16188A192 D-5

ACTIONS AND PROJECTS CONSIDERED IN CUMULATIVE ANALYSIS

E. Actions and Projects Considered in Cumulative Analysis Table E-1 identifies actions and projects considered in the U.S. Nuclear Regulatory Commission (NRC) staffs analysis of cumulative impacts related to the environmental analysis of the continued operation of Fermi 2. Potential cumulative impacts associated with these actions and projects are addressed in Section 4.16 of this supplemental environmental impact statement. Not all actions or projects listed in this appendix are considered in each resource area because of the uniqueness of the resource and its geographic area of consideration.

Table E-1. Actions and Projects Considered in Cumulative Analysis Approximate Location Project Name Summary of Project (Relative to Fermi) Status Nuclear projects Davis-Besse Nuclear Nuclear power plant Ottawa County, OH Operational Power Station Unit 1 One 908-MWe Babcock & 27 mi (43 km) southeast of (FENOC 2014)

Wilcox pressurized water Fermi site on Lake Erie reactor Davis-Besse independent Dry spent fuel storage On Davis-Besse site Operational spent fuel storage (NRC 2014) installation Coal-fired energy projects Monroe Power Plant 3,280-MW coal-fired plant 6 mi (10 km) southwest of Operational; completed Fermi site on Lake Erie major emissions-control refurbishment in 2014 (CDB 2014a, 2014b)

Trenton Channel Power 520-MW coal-fired plant 12 mi (19 km) Operational; DTE Plant north-northeast of Fermi retired two of the three site on the Detroit River units in 2016 and reduced the plant capacity from 730 MW to 520 MW (CDB 2014b; News-Herald 2016)

J.R. Whiting Power Plant 328-MW coal-fired plant 14 mi (23 km) Retired in 2016 south-southwest of Fermi (Consumers site on Lake Erie Energy 2014; EIA 2014; Monroe News 2016)

Bayshore Power Plant 136-MW coal-fired plant 20 mi (32 km) Operational south-southwest of Fermi (FirstEnergy 2014) site on Lake Erie at Maumee Bay River Rouge Power Plant 540-MW coal-fired plant 26 mi (42 km) Operational north-northeast of Fermi (DTE 2014) site on the Detroit River E-1

Appendix E Approximate Location Project Name Summary of Project (Relative to Fermi) Status Natural Gas-fired energy projects Oregon Clean 869-MW natural gas 21 mi (34 km) Under construction; Energy Center combined cycle plant south-southwest of Fermi scheduled to become site operational in 2017 (OPSB 2014; CME 2016)

Mining Projects Rockwood Quarry Crushed and broken 2.5 mi (4 km) Closed (EPA 2014a) limestone quarry north-northeast of Fermi site Stoneco Newport Crushed and broken 2.5 mi (4 km) Operational limestone quarry north-northeast of Fermi (EPA 2014b) site Sylvania Minerals Crushed and broken 6 mi (10 km) Operational limestone and crushed north-northwest of Fermi (EPA 2014c) silica quarry site Stoneco Denniston Crushed and broken 9 mi (14 km) southwest of Operational limestone quarry Fermi site (EPA 2014d)

Stoneco Maybee Crushed and broken 13 mi (21 km) Operational limestone quarry west-northwest of Fermi (EPA 2014e) site Sibley Quarry Crushed and broken 14 mi (23 km) Operational limestone quarry north-northeast of Fermi (EPA 2014f) site Landfills Rockwood Landfill Industrial landfill; 2.5 mi (4 km) Closed (MDEQ 2014a, construction and debris north-northeast of Fermi 2016) landfill site Carleton Farms Municipal solid waste 12 mi (19 km) northwest of Operational landfill Fermi site (MDEQ 2015)

Riverview Land Preserve Municipal solid waste 13 mi (21 km) Operational landfill north-northeast of Fermi (MDEQ 2014b) site Sibley Quarry Industrial landfill 14 mi (23 km) Operational north-northeast of Fermi (MDEQ 2014c) site Water supply and treatment facilities Berlin Township Wastewater treatment 1.1 mi (2 km) northwest of Operational Wastewater Treatment plant that discharges to Fermi site (EPA 2015a)

Plant Swan Creek near its confluence with Lake Erie Frenchtown Township Water treatment plant that 2 mi (3 km) southwest of Operational Water Plant withdraws water from Fermi site (Frenchtown Lake Erie Township 2014)

E-2

Appendix E Approximate Location Project Name Summary of Project (Relative to Fermi) Status Monroe Metropolitan Wastewater treatment 6 mi (10 km) southwest of Operational Wastewater Treatment plant that discharges to the Fermi site on Lake (EPA 2015b)

Facility Lake Erie-Plum Erie Creek-Levee Channel Monroe Water Filtration Water treatment plant that 7 mi (11 km) southwest of Operational Plant withdraws water from Fermi site (EPA 2015c)

Lake Erie Carleton Wastewater Wastewater treatment 9 mi (14 km) northwest of Operational; permit Treatment Plant plant that discharges to Fermi site expired in 2014 Swan Creek (EPA 2015d, 2016)

Luna Pier Wastewater Wastewater treatment 14 mi (23 km) Operational Treatment Plant plant that discharges to south-southwest of Fermi (EPA 2015e)

La Pointe Drain site Various minor NPDES Various businesses with Within 10 mi (16 km) Operational wastewater discharges smaller wastewater discharges Manufacturing facilities Spartan Steel Coating Hot-dipped galvanized 5 mi (8 km) west of Fermi Operational LLC steel coil processing site (EPA 2014g) facility JCIM Plastics injection molding 5 mi (8 km) Operational facility west-southwest of Fermi (EPA 2014h) site Spiratex Company Thermoplastic extrusion 5 mi (8 km) Operational manufacturing facility west-southwest of Fermi (EPA 2014i) site Ventower Industries Wind turbine tower 6 mi (10 km) southwest of Operational manufacturing facility Fermi site (EPA 2014j)

Guardian Industries Glass plant manufacturing 10 mi (16 km) Operational facility that discharges into north-northwest of Fermi (EPA 2014k)

Swan Creek site Oil refineries Plants that refine crude oil Various locations Operational for other applications throughout region Transportation Projects Cleveland-Toledo-Detroit Addition to regional Rail line would pass Proposed; schedule Passenger Rail Line transportation hub with rail through Monroe County undetermined lines connecting on its way to Detroit (TMACOG 2011; Cleveland, Buffalo, DTE 2014)

Toronto, Pittsburgh, Cincinnati, and Detroit Interstate 75 Reconstructing 6 mi Between Dixie Highway Construction Improvements (10 km) of I-75 through and I-275 commenced in 2015 Monroe County with completion scheduled for late 2016 (MDOT 2016)

E-3

Appendix E Approximate Location Project Name Summary of Project (Relative to Fermi) Status Parks and recreation sites Sterling State Park Approximately 1,300 ac Approximately 5 mi (8 km) Operational; managed (530 ha) park on Lake Erie southwest by Michigan coast with campgrounds, Department of Natural trails, boat launches, and Resources swimming area (MDNR 2014a)

Maumee Bay State Park 1,336 ac (541 ha) park on Approximately 20 mi Operational; managed Lake Erie coast with (32 km) south-southwest by Ohio State Parks campgrounds, trails, boat (ODNR 2014) launches, and swimming area Detroit River International Approximately 6,000 ac Comprised of multiple Operational; managed Wildlife Refuge (2,400 ha) of islands, refuge units extending by U. S. Fish and coastal wetlands, north and south of Fermi Wildlife Service. The marshes, shoals, and site. The Lagoona Beach Lagoona Beach Unit is waterfront lands along Unit is adjacent to Fermi. managed cooperatively 48 mi (77 km) of Detroit by the refuge in River and Western Lake partnership with DTE Erie shorelines. Only Energy (FWS 2014) international wildlife refuge in North America.

River Raisin National National Battlefield Approximately 7 mi Operational; managed Battlefield Park commemorating the River (11 km) southwest by U.S. National Park Raisin Battles during the Service (NPS 2014)

War of 1812 Point Mouillee State 4,000 ac (1,600 ha) Approximately 4.5 mi Operational; managed Game Area freshwater marsh (7 km) northeast by Michigan restoration project open to Department of Natural wildlife viewing and public Resources hunting (MDNR 2014b)

Recreational Areas Various parks, boat Within 10 mi (16 km) Operational launches, campgrounds, swimming areas Fermi projects Fermi Nuclear Power Decommissioning of On the Fermi site SAFSTOR (NRC 2014)

Plant Unit 1 shutdown nuclear power plant Fermi Nuclear Power Proposed construction and On the Fermi site Combined License Plant Unit 3 operation of 1,535-MWe issued May 1, 2015 nuclear power plant (NRC 2015)

Independent spent fuel Dry spent fuel storage On the Fermi site Operational; storage installation for commenced spent fuel Fermi 2 storage in 2014 (DTE 2014; DTE Energy 2016)

E-4

Appendix E Approximate Location Project Name Summary of Project (Relative to Fermi) Status Other projects Future Urbanization Construction of housing Throughout region Construction may occur units and associated in the future as commercial buildings; described in State and roads, bridges, and rail; local land-use planning and water and wastewater documents treatment and distribution facilities and associated pipelines as described in local land-use planning documents E.2 References

[Carleton] Village of Carleton. 2016. Sanitary Sewer Service Ordinance. Available at

<http://www.carletonmi.us/> (accessed 25 April 2016).

[CDB] Crains Detroit Business. 2014a. DTEs Monroe power plant marks milestone in reducing pollution. November 7, 2014. Available at

<http://www.crainsdetroit.com/article/20141107/NEWS01/141109897/dtes-monroe-power-plant-marks-milestone-in-reducing-pollution> (accessed 25 April 2016).

[CDB] Crains Detroit Business. 2014b. A $15B upgrade for utilities: New EPA rules stoke consumers, DTE move to wind and gas. August 3, 2014. Available at

<http://www.crainsdetroit.com/article/20140803/NEWS/308039968/a-15b-upgrade-for-utilities-new-epa-rules-stoke-consumers-dte-move> (accessed 25 April 2016).

[CME] CME Energy. 2016. Oregon Clean Energy Center. Available at <http://www.cme-energy.com/content/oregon-clean-energy-center> (accessed 25 April 2016).

[DTE] DTE Electric Company. 2014. Applicants Environmental ReportOperating License Renewal Stage, Fermi 2. Newport, MI: DTE. April 2014. ADAMS Nos. ML14121A538, ML14121A539, and ML14121A540.

DTE Energy. 2016. Nuclear Generation - Dry Cask Storage Project. Available at

<http://www.dteenergy.com/nuclear/dryCaskStorageProject.html> (accessed 25 April 2016).

[EPA] U.S. Environmental Protection Agency. 2014a. Envirofacts Search Results: Rockwood Quarry. Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 1500110&p_plant_id=.> (accessed 22 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014b. Envirofacts Search Results: Stoneco Newport. Available at

<http://oaspub.epa.gov/enviro/multisys2_v2.get_list?facility_uin=110001843220> (accessed 22 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014c. Envirofacts Search Results: Great Lakes Aggregates, LLC-Sylvania Minerals. Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 1500146&p_plant_id=> (accessed 22 December 2014).

E-5

Appendix E

[EPA] U.S. Environmental Protection Agency. 2014d. Envirofacts Search Results: Stoneco Denniston. Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 1500147&p_plant_id=.> (accessed 22 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014e. Envirofacts Search Results: Stoneco Maybee. Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 1500029&p_plant_id=> (accessed 22 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014f. Envirofacts Search Results: Sibley Limestone Quarry. Available at

<http://iaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 6305352> (accessed 22 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014g. Envirofacts Search Results: Spartan Steel Coating. Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 1500155&p_plant_id=> (accessed 19 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014h. Envirofacts Search Results: JCIM.

Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 1505489&p_plant_id=> (accessed 19 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014i. Envirofacts Search Results: The Spiratex Company. Available at

<http://oaspub.epa.gov/enviro/multisys2_v2.get_list?facility_uin=110003687617> (accessed 19 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014j. Envirofacts Search Results: Ventower Industries. Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 15P0073&p_plant_id=> (accessed 19 December 2014).

[EPA] U.S. Environmental Protection Agency. 2014k. Envirofacts Search Results: Guardian Industries. Available at

<http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=261 1500015&p_plant_id=> (accessed 19 December 2014).

[EPA] U.S. Environmental Protection Agency. 2015a. Envirofacts Search Results: Berlin Township Wastewater Treatment Plant. Available at

<http://oaspub.epa.gov/enviro/ICIS_DETAIL_REPORTS_NPDESID.icis_tst?npdesid=MI002082 6&npvalue=1&npvalue=13&npvalue=14&npvalue=3&npvalue=4&npvalue=5&npvalue=6&rvalue

=13&npvalue=2&npvalue=7&npvalue=8&npvalue=11&npvalue=12> (accessed 29 April 2015).

[EPA] U.S. Environmental Protection Agency. 2015b. Envirofacts Search Results: Monroe Metropolitan Wastewater Treatment Plant. Available at

<http://iaspub.epa.gov/enviro/ICIS_DETAIL_REPORTS_NPDESID.icis_tst?npdesid=MI0028401

&npvalue=1&npvalue=13&npvalue=14&npvalue=3&npvalue=4&npvalue=5&npvalue=6&rvalue=

13&npvalue=2&npvalue=7&npvalue=8&npvalue=11&npvalue=12> (accessed 29 April 2015).

[EPA] U.S. Environmental Protection Agency. 2015c. Envirofacts Search Results: City of Monroe Water Filtration Plant. Available at

<http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_sys_id_in=MIR0000459 22&pgm_sys_acrnm_in=RCRAINFO> (accessed 29 April 2015).

E-6

Appendix E

[EPA] U.S. Environmental Protection Agency. 2015d. Envirofacts Search Results: Carleton Wastewater Treatment Plant. Available at

<http://iaspub.epa.gov/enviro/ICIS_DETAIL_REPORTS_NPDESID.icis_tst?npdesid=MI0022543

&npvalue=1&npvalue=13&npvalue=14&npvalue=3&npvalue=4&npvalue=5&npvalue=6&rvalue=

13&npvalue=2&npvalue=7&npvalue=8&npvalue=11&npvalue=12> (accessed 27 April 2015).

[EPA] U.S. Environmental Protection Agency. 2015e. Envirofacts Search Results: Luna Pier Wastewater Treatment Plant. Available at

<http://iaspub.epa.gov/enviro/ICIS_DETAIL_REPORTS_NPDESID.icis_tst?npdesid=MI0058821

&npvalue=1&npvalue=13&npvalue=14&npvalue=3&npvalue=4&npvalue=5&npvalue=6&rvalue=

13&npvalue=2&npvalue=7&npvalue=8&npvalue=11&npvalue=12> (accessed 29 April 2015).

[EPA] U.S. Environmental Protection Agency. 2016. Enforcement and Compliance History Online, Detailed Facility Report - Carleton WWTP. Available at <https://echo.epa.gov/detailed-facility-report?fid=MI0022543&sys=ICP> (accessed 26 April 2016).

[FirstEnergy] FirstEnergy Corporation. 2014. Operating Power Plants. Available at

<http://investors.firstenergycorp.com/OperatingPowerPlants.aspx?iid=4056944&print=1>

(accessed 19 December 2014).

[FENOC] FirstEnergy Nuclear Operating Company. 2014. Review of Draft Plant-Specific Supplement 52 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Davis-Besse Nuclear Power Station, Unit 1. April 21. ADAMS No. ML14113A214.

Frenchtown Township. 2014. Annual Water Quality Report. Available at

<http://www.frenchtowntownship.org/water.php> (accessed 30 April 2015).

[FWS] U.S. Fish and Wildlife Service. 2014. Detroit River International Wildlife Refuge, Michigan. Available at <http://www.fws.gov/refuge/detroit_river/refuge_units.html> (accessed 22 December 2014).

[MDEQ] Michigan Department of Environmental Quality. 2014a. Solid Waste Management Disposal Areas-Rockwood Landfill. Available at

<http://www.deq.state.mi.us/wdspi/SolidWaste/OperatingLicenses.aspx?w=438977> (accessed 19 December 2014).

[MDEQ] Michigan Department of Environmental Quality. 2014b. Solid Waste Management Disposal AreasThe Riverview Land Preserve. Available at

<http://www.michigan.gov/documents/deq/DEQ-WHMD-RIVERVIEW_OpLicense_259300_7.pdf> (accessed 19 December 2014).

[MDEQ] Michigan Department of Environmental Quality. 2014c. Solid Waste Management Disposal AreasSibley Quarry Landfill. Available at

<http://www.deq.state.mi.us/wdspi/SolidWaste/DisposalAreas.aspx?w=392616> (accessed 19 December 2014).

[MDEQ] Michigan Department of Environmental Quality. 2015. Solid Waste Management Disposal AreasCarleton Farms Landfill. Available at

<http://www.michigan.gov/documents/deq/DEQ-WHMD-CARLETON_FARMS_OpLicense_241128_7.pdf> (accessed 10 July 2015).

[MDEQ] Michigan Department of Environmental Quality. 2016. Solid Waste Management Disposal Areas - Rockwood Landfill. Available at

<http://www.deq.state.mi.us/wdspi/SolidWaste/OperatingLicenses.aspx?w=438977> (accessed 25 April 2016).

E-7

Appendix E

[MDNR] Michigan Department of Natural Resources. 2014a. Sterling State Park. Available at

<http://www.michigandnr.com/parksandtrails/details.aspx?id=497&type=SPRK> (accessed 22 December 2014).

[MDNR] Michigan Department of Natural Resources. 2014b. Point Mouillee State Game Area.

Available at

<http://www.michigandnr.com/publications/pdfs/wildlife/viewingguide/slp/107Mouillee

/index.htm> (accessed 22 December 2014).

[MDOT] Michigan Department of Transportation. 2016. I-75 Reconstruction, Monroe Co.

Available at <http://www.michigan.gov/mdot/0,4616,7-151-9621_11008-316074--,00.html>

(accessed 25 April 2016).

[Monroe News] The Monroe News. 2016. Closing Whiting. April 10, 2016. Available at

<http://www.monroenews.com/article/20160410/NEWS/160419954> (accessed 25 April 2016).

[News-Herald] The News-Herald. 2016. Two units of DTE Energys Trenton Channel Power Plant to close in April. February 24, 2016. Available at

<http://thenewsherald.com/articles/2016/02/24/news/doc56ce090b88080596858326.txt>

(accessed 25 April 2016).

[NPS] U.S. National Park Service. 2014. River Raisin National Battlefield Park, Michigan.

Available at <http://www.nps.gov/rira/learn/historyculture/index.htm> (accessed 19 December 2014).

[NRC] U.S. Nuclear Regulatory Commission. 2014. Information Digest, 2014-2015.

NUREG-1350, Volume 26. August 2014. 216 p.

[NRC] U.S. Nuclear Regulatory Commission. 2015. Letter from F. Akstulewicz, Director, Division of New Reactor Licensing, Office of New Reactors, to P. Smith, Director, Nuclear Development - Licensing & Engineering, DTE Electric Company.

Subject:

Issuance of Combined License for Enrico Fermi Unit 3. May 1, 2015. ADAMS No. ML14323B045.

[ODNR] Ohio Department of Natural Resources. 2014. Maumee Bay State Park. Available at

<http://parks.ohiodnr.gov/maumeebay> (accessed 22 December 2014).

[OPSB] Ohio Power Siting Board. 2014. Case No.12-2959-EL-BGN: Oregon Clean Energy Center, Lucas CountyStatus. Available at

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[TMACOG] Toledo Metropolitan Area Council of Governments. 2011. Passenger Rail Service:

Northwest Ohio and Southeast Michigan Future High Speed Passenger Rail Corridors Map.

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Rail2.pdf> (accessed 22 December 2014).

E-8

U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR FERMI UNIT 2 NUCLEAR STATION, IN SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW

F. U.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident Mitigation Alternatives for Fermi UNIT 2 NUCLEAR STATION, in Support of License Renewal Application Review F.1 Introduction DTE Electric Company (DTE) submitted an assessment of severe accident mitigation alternatives (SAMAs) for the Fermi Unit 2 Nuclear Station (Fermi 2), as part of its Environmental Report (ER) (DTE 2014). This assessment was based on the most recent Fermi 2 probabilistic risk assessment (PRA) available at that time, a plant-specific accident progression and source term analysis performed using the Modular Accident Analysis Program (MAAP) version 4.0.7 computer code, a plant-specific offsite consequence analysis performed using the MELCOR Accident Consequence Code System (MACCS2) version 3.7.0 computer code, and insights from the Fermi 2 individual plant examination (IPE) (DECo 1992) and individual plant examination of external events (IPEEE) (DECo 1996). In identifying and evaluating potential SAMAs, DTE considered SAMAs that addressed the major contributors to core damage frequency (CDF) and release frequency at Fermi 2, as well as SAMA candidates for other operating plants that have submitted license renewal applications. DTE initially identified 220 potential SAMAs. This list was reduced to 79 unique SAMA candidates by eliminating SAMAs that are not applicable to Fermi 2 because of design differences, that have already been implemented at Fermi 2, that were combined with another SAMA candidate during the assessment, that have excessive implementation costs, that have a very low benefit to Fermi 2, or that are undergoing implementation at Fermi 2. DTE assessed the costs and benefits associated with each of the 79 potential SAMAs and concluded in the ER that one SAMA candidate was potentially cost beneficial. Sensitivity analyses performed by DTE indicated that three additional SAMA candidates had the potential to be cost-beneficial.

Based on a review of DTEs SAMA assessment and the onsite SAMA audit held on October 6-8, 2014 (NRC 2014c), the U.S. Nuclear Regulatory Commission (NRC) staff issued requests for additional information (RAI) to DTE by letters dated November 14, 2014 (NRC 2014a), February 3, 2015 (NRC 2015a), and April 9, 2015 (NRC 2015b). Key questions concerned the modeling of loss of offsite power (LOOP) and station blackout (SBO) sequences, the comparison of the results of the Fermi 2 PRA with those for other similar plants, results of the peer review on the PRA, truncation cutoff used for the Level 2 release category and Level 1 CDF analyses, additional details on the Level 2 and 3 PRA models including the basis for representative sequences for each release category, thermal power levels following a power uprate, justification of population estimates, the identification and screening of candidate SAMAs, the evaluation of the risk reduction of certain SAMAs, and the basis for the SAMA cost estimates. Subsequent followup NRC staff RAIs (NRC 2015a, 2015b) concerned: common cause failure of combustion turbine generators (CTGs) due to severe weather, the treatment and impact of unaccounted for release category frequency, the impact on SAMA cost benefit analysis of a nonconservative treatment of some accident sequences, a reanalysis of the benefit of certain SAMAs, and the development of the population within 50 miles (mi) (80 kilometers (km)) of Fermi 2. DTE submitted additional information by letters dated January 9, 2015; March 5, 2015; and May 8, 2015 (DTE 2015a, 2015b, 2015c). DTEs responses to questions by the NRC staff resulted in three new potentially cost-beneficial SAMAs. The NRC staffs concerns were addressed by DTEs responses and calculations performed by the NRC staff during its review.

An assessment of SAMAs for Fermi 2 is presented below.

F-1

Appendix F F.2 Estimate of Risk for Fermi 2 DTEs estimates of offsite risk at Fermi 2 are summarized in Section F.2.1. The summary is followed by the NRC staffs review of DTEs risk estimates in Section F.2.2.

F.2.1 DTEs Risk Estimates DTE combined two distinct analyses to form the basis for the risk estimates used in the SAMA analysis: (1) Level 1 and Level 2 PRA models for Fermi 2 and (2) a supplemental analysis of offsite consequences and economic impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The Level 1 model is a significant upgrade and revision of the IPE Level 1 model while the Level 2 model is an update of the IPE Level 2 model. The SAMA analysis is based on the most recent Level 1 and Level 2 PRA models available for Fermi 2 at the time of the ER, referred to as the Fermi 2 Version 9 (FermiV9) PRA model. The scope of this Fermi 2 PRA includes internal floods but does not include a separate PRA for external events at Fermi 2.

The Fermi 2 CDF from internal events is approximately 1.5x106 per year (DTE 2014). DTE did not explicitly include the contribution from external events within the Fermi 2 SAMA risk estimates; however, it did account for the potential risk reduction benefits associated with external events by multiplying the estimated benefits for internal events by 11. This is discussed further in Section F.2.2.2.

The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table, events initiated by a total LOOP, a turbine trip with bypass, and a medium loss-of-coolant accident (LOCA) below the top of the active fuel are the dominant contributors to the CDF. DTE identified that SBO contributes 8.4x108 per year, or 5.6 percent of the total internal events CDF while anticipated transients without scram (ATWS) contribute 2.0x107 per year, or approximately 13 percent, of the total CDF (DTE 2014).

Table F-1. Fermi 2 CDF for Internal Events CDF(a) Percent CDF Initiating Event (per year) Contribution Total LOOP 2.1x107 14 Turbine Trip with Bypass 2.0x107 13 Medium LOCA below the Top of Active Fuel 1.6x107 10 Nominal Rupture in Fire Protection System Line in Auxiliary Building 1.1x107 7 Propagating to Relay Room Medium LOCA in Low-Pressure Coolant Injection (LPCI) Line 1.1x107 7 Medium LOCA in Feedwater (FW) Line 6.0x108 4 Loss of Condenser Vacuum 5.3x108 4 Major Rupture in Circulating Water Pipe or Expansion Joints in 5.2x108 3 Turbine Building.

Interfacing System LOCA in Residual Heat Removal (RHR) 5.1x108 3 Shutdown Cooling Line (X-12)

Manual Shutdown 4.4x108 3 Partial LOOP for Division 2 3.8x108 3 Loss of Bus #301 3.7x108 2 F-2

Appendix F CDF(a) Percent CDF Initiating Event (per year) Contribution Nominal Rupture in Reactor Building Closed Cooling Water 3.3x108 2 (RBCCW)/ Emergency Equipment Cooling Water (EECW)

Division 2 Line in Direct Current (DC) Switchgear Room Other Initiating Events(b) 3.5x107 24 (c) 6 Total (Internal Events) 1.5x10 100 (a) CDF based on Fussell-Vesely importance (DTE 2015a) and total CDF.

(b) Other initiating event each contributing less than 2 percent to total CDF.

(c)Column totals may be different because of rounding.

Source: DTE 2015a The Fermi 2 Level 2 PRA model that forms the basis for the SAMA was ...developed as part of the FermiV9 internal events PRA model (DTE 2014) and incorporates the significant improvement in severe accident response coupled with plant modifications and improved understanding of severe accident core melt progression since the original IPE model (DTE 2015a).

The Level 2 model utilizes containment event trees (CETs) to assess the accident progression following a core damage event and contains both phenomenological and containment system status events. The Level 1 core damage sequences are binned into plant damage states (PDSs) or accident classes, which provide the interface between the Level 1 and Level 2 CET analysis. Each PDS bin is then entered into the CET. The CET is linked directly to the Level 1 event trees, and CET nodes are evaluated using supporting fault trees.

The result of the Level 2 PRA is a set of 13 release categories, with their respective frequency and release characteristics. The results of this analysis for Fermi 2 are provided in Tables D.1-10, D.1-14, and D.1-15 of the ER (DTE 2014). The categories were defined based on the timing of release (three release time ranges) and the magnitude of release (four release magnitude ranges). One additional release category was included for an intact containment.

Releases with intact containment were evaluated using the maximum design basis leakage of 0.5 percent of the containment air weight per day.

For use in the SAMA analysis, the release category for high magnitude and early timing was divided into two bins (one for containment isolation and one without). Due to the small release category contributions from 3 categories, the number of release category bins was reduced to 11 cases. The frequency of each release category was obtained by summing the frequency of the individual accident progression CET endpoints binned into the release category. Source terms were developed for each of the 13 release categories using the results of MAAP Version 4.0.7 computer code calculations (DTE 2014).

DTE computed offsite consequences for potential releases of radiological material using the MACCS2 version 3.7.0 code and analyzed exposure and economic impacts from DTEs determination of offsite and onsite risks. Inputs for these analyses include plant-specific and site-specific input values for core radionuclide inventory, source term and release characteristics, site meteorological data, projected population distribution and growth within a 50-mi (80-km) radius, emergency response evacuation modeling, and economic data. The estimation of onsite impacts (in terms of cleanup and decontamination costs and occupational dose) is based on guidance in NUREG/BR-0184 (NRC 1997a). In its calculation for replacement power costs, DTE accounted for the increased electric power output of Fermi 2 F-3

Appendix F compared to the generic reactor power output presented in NUREG/BR-0184 (NRC 1997a) and adopted by the Nuclear Energy Institutes (NEI) guidance document (NEI 2005).

In the ER, DTE estimated the dose risk to be 0.0491 person-sievert (Sv) per year (4.91 person-rem per year) to the population within 50 mi (80 km) of the Fermi 2 site. The offsite economic cost risk was calculated to be $15,600 per year. The breakdown of the population dose risk by containment release mode is summarized in Table F-2. The two categories for high magnitude, early releases accounted for approximately 78 and 68 percent of the population dose risk and offsite economic cost risk, respectively. The high magnitude, intermediate release category accounted for 14 and 24 percent of the population dose risk and offsite economic cost risk, respectively.

Table F-2. Base Case Mean Population Dose Risk and Offsite Economic Cost Risk for Internal Events Release Mode Population Dose Riska Offsite Economic Cost Risk Frequency IDb (per year) person-rem/yr % Contribution $/yr % Contribution H/E-BOCc 5.9x108 1.3x100 26 1.8x103 12 H/E 3.1x107 2.5x100 52 8.8x103 56 H/I 7.2x108 6.9x101 14 3.8x103 24 H/L 2.5x1010 2.2x103 <0.1 4.1x100 <0.1 M/E 6.2x108 1.5x101 3 5.2x102 3 M/Id 3.7x108 1.0x101 2 2.3x102 2 L/E 4.4x108 9.9x103 0.2 9.9x101 <0.1 L/Id 5.5x108 1.2x101 2 4.5x102 3 LL/E 5.0x1010 6.6x106 <0.1 1.9x104 <0.1 LL/Id 7.8x108 1.0x102 0.2 3.1x101 <0.1 CI 7.8x107 5.1x105 <0.1 1.5x106 <0.1 Total 1.5x106 4.9x100 100 1.6x104 100 a Unit Conversion Factor: 1 Sv = 100 rem b Release Mode Nomenclature (Magnitude/Timing) c Contributions to Large Early Release Frequency from break outside containment (BOC) and interfacing system LOCA initiators d The release categories for Late (L) timing were subsumed into the Intermediate (I) release categories for Medium (M), Low (L), and Low-Low (LL) releases.

Magnitude:

High (H) - Greater than 10 percent release fraction for cesium iodide (CsI)

Medium (M) - 1 to 10 percent release fraction for CsI Low (L) - 0.1 to 1 percent release fraction for CsI Low-Low (LL) - Less than 0.1 percent release fraction for CsI Containment intact (CI) - Much less than 0.1 percent release fraction for CsI Timing:

Early (E) - Less than 4 hours0.167 days 0.0238 weeks 0.00548 months Intermediate (I) - 4 to 24 hours1 days 0.143 weeks 0.0329 months Late (L) - Greater than 24 hours1 days 0.143 weeks 0.0329 months Source: DTE 2014 F-4

Appendix F F.2.2 Review of DTEs Risk Estimates DTEs determination of offsite risk at the Fermi 2 site is based on the following three major elements of the analysis:

(1) Level 1 risk model that supersedes the 1992 IPE submittals (DECo 1992) and the fire, seismic, and other external event analyses of the 1996 IPEEE submittal (DECo 1996);

(1) Revised Level 2 risk model and MAAP source term analysis; (2) MACCS2 analyses performed by DTE to translate fission product source terms and release frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed by the NRC staff to determine the acceptability of DTEs risk estimates for the Fermi 2 SAMA analysis, as summarized below.

F.2.2.1 Internal Events CDF Model The NRC staffs review of the Fermi 2 IPE is described in its 1994 NRC memorandum (NRC 1994). Based on its review of the Fermi 2 nuclear power plant IPE submittal and associated documentation, the NRC staff concluded that the licensee met the intent of Generic Letter 88-20 (NRC 1988). As indicated in the NRC staff review, while the licensee concluded that no vulnerabilities exist at Fermi 2, the licensee identified many insights that were later used to identify enhancements for Fermi 2. These are discussed in Section F.3.2.

There have been numerous revisions to the Fermi 2 PRA since the original 1992 IPE submittal.

A listing of the complete revision history of the Fermi 2 PRA since the original IPE submittal was provided in the ER (DTE 2014) and in response to an NRC staff request for additional information (RAI) (DTE 2015a) and is summarized in Table F-3. A comparison of the internal events CDF between the 1992 IPE and the current PRA model indicates there has been a reduction in total CDF from 5.7x106 per year to 1.3x106 per year.1 Table F-3. Summary of Major PRA Models and Corresponding CDF and LERF Results PRA CDF(a) LERF(a)

Model Summary of Significant Changes from Prior Model (per year) (per year)

IPE (1992) IPE Submittal 5.7x106 8.0x107 PSA97C Numerous changes to reflect plant modification and model 7.1x106 1.2x106 (1997) enhancements FermiV2 CDF Model Converted from RISKMAN 5.0x106 Not Available (2002) to CAFTA FermiV3 Normal PRA model maintenance including Fermi-specific data 3.3x106 2.5x107 (2002) used to update initiating event frequencies, component failure frequencies, and common cause event data Test and maintenance based upon data obtained from plant operating experience CAFTA Level 2 Model developed FermiV4 Test and maintenance unavailability based upon the 5.8x106 9.3x107 (2003) Maintenance Rule performance criteria 1 The 1.3x106 per year total CDF excludes the internal flood CDF as it is not included in the IPE value.

F-5

Appendix F PRA CDF(a) LERF(a)

Model Summary of Significant Changes from Prior Model (per year) (per year)

FermiV6(b) Normal PRA model maintenance 6.1x106 4.8x107 (2004) Included revised HRA using HRA Calculator Incorporated several recommendations from the 1997 peer review FermiV7 Included HRA dependent action basic events 1.4x105 5.5x107 (2006) Added Black Start DG with 11-2,11-3, and 11-4 CTGs Updated LOOP initiating event frequencies Incorporated additional recommendations from the 1997 peer review FermiV8 Periodic update 2.3x106 3.1x107 (2010) Expanded the mutually exclusive event file to exclude many nonrepresentative maintenance configurations Updated the maintenance unavailability terms Changed RPS mechanical and electrical failure to scram values to align with current accepted industry benchmark values FermiV9 Complete model upgrade including: initiating events, success 1.3x106 3.9x107 DRAFT criteria, data, system notebooks, HRA, internal flood, MAAP 4.0.7 analyses, and Level 2/LERF Test and maintenance unavailability based upon data obtained from plant operating experience FermiV9 Changes to respond to peer review findings including: 1.5x106 3.7x107 (2013) elimination of credit for terminating certain flood events, corrected HPCI/RCIC fail to start type code failure rate, and added dependent human failure event to operate high pressure injection systems Corrected other significant modeling issues including:

elimination of some ATWS and LERF non-minimal cutsets and lowered human error probability based on added time available from MAAP analysis (a) Models FermiV4, FermiV6, FermiV7, and FermiV8 included pre-IPE internal flood initiating event modeling. The FermiV9 model includes a new internal flood analysis.

(b) The FermiV5 model was not issued.

Key: CDF = core damage frequency; CTG = combustion turbine generator; DG = diesel generator; HPCI = high pressure coolant injection; HRA = human reliability analysis; IPE = individual plant examination; LERF = large early release frequency; LOCA = loss-of-coolant accident; LOOP = loss of offsite power; NRC = U.S. Nuclear Regulatory Commission; PRA = probabilistic risk assessment; RCIC = reactor core isolation cooling; RPS = reactor protection system Sources: DTE 2014 and DTE 2015a The CDF value from the 1992 IPE (5.7x106 per year) is well below the average of the CDF values reported in the IPEs for boiling water reactors (BWR) 3/4 plant units. NUREG-1560 gives the average for the group of BWR 3/4 units to be 2x105 per year with the reported values ranging from 9x108 per year to 8x105 per year (NRC 1997b). It is recognized that other plants have updated the values for CDF subsequent to the IPE submittals to reflect modeling and hardware changes.

F-6

Appendix F The current internal events CDF result for Fermi 2 (1.5x106 per year) is considerably less than that for other plants of similar vintage and characteristics. In response to an NRC staff RAI to explain the reasons for this disparity, DTE identified the following Fermi 2 features that are responsible for this low CDF (DTE 2015a):

Fermi 2 has a standby feedwater system that is not found at other BWRs. It consists of two motor driven pumps, although only one is needed for most scenarios. One pump is powered by Division 2 and the other pump is powered by Division 1, which has combustion turbine generators (CTGs) backup. This system is credited early in general transient and LOOP scenarios and is a backup to high-pressure coolant injection (HPCI) and reactor core isolation coolant (RCIC).

Fermi 2 has a residual heat removal (RHR) complex, which contains two divisions of the ultimate heat sink. This facility contains the emergency diesel generators (EDGs), RHR service water (RHRSW) pumps, diesel generator service water pumps, and EESW pumps. This building is protected from design basis tornados.

The ultimate heat sink has adequate inventory for 7 days without makeup.

Fermi 2 has two independent switchyards. Division 1 offsite power is provided by a 120 kV switchyard fed from three offsite lines. Division 2 offsite power is provided by a 345 kV switchyard fed from two offsite lines. These switchyards are electrically and spatially separated. There is the ability to cross-tie from one division to the other using a maintenance tie breaker.

Fermi 2 has four EDGs (two EDGs support Division 1 and two EDGs support Division 2). One EDG can provide adequate power to shut down the plant in general transients and LOOP. Fermi 2 also has four CTGs. The CTGs provide power to the Division 1 switchyard, which in turn can provide power to the standby feedwater system. CTG 11-1 has blackstart capability from the control room for SBOs, and units 11-2, 11-3, and 11-4 can be manually aligned for blackstart using a standby diesel generator.

Fermi 2 has several closed cooling water systems used to cool plant systems. The benefit is that these closed cooling water systems have a finite amount of water that leads to a reduced internal flooding impact.

The NRC staff considered the peer review performed for the Fermi 2 PRA, and the potential impact of the review findings on the SAMA evaluation. In the ER (DTE 2014), DTE described the August 2012 Boiling Water Reactor Owners Group (BWROG) peer review of the Fermi 2 PRA. In response to an NRC staff RAI, DTE clarified that the peer review was performed on a draft of the FermiV9 PRA (DTE 2015a). The peer review was stated to be performed consistent with Regulatory Guide 1.200, Rev. 2 (NRC 2009) and utilized the American Society of Mechanical Engineers (ASME) PRA standards (ASME and ANS 2009). DTE stated that the peer review resulted in 28 findings and provided a tabulation of the status and resolution of each finding.

All but four of the findings were considered closed by DTE. The NRC staff reviewed the stated resolution of the closed findings. On the basis of this review and DTEs response (DTE 2015a) to an NRC staff RAI requesting clarification, the NRC staff agrees that those findings could be considered closed for the purposes of the SAMA analysis.

The four findings not considered closed were described by DTE as having been addressed.

These findings were related to the methodology employed by DTE in performing the human reliability analysis (HRA) dependency analysis and its appropriateness. Although the methodology employed was not considered an industry standard method by the peer review F-7

Appendix F team, DTE stated that a review of the quantitative results by an Expert Panel (composed of personnel from two nonaffiliated PRA consulting firms and members of the DTE PRA staff) prior to the Peer Review concluded that the quantification results (including HRA) dependency groupings) were representative of the as-built, as-operated plant and were reasonable with respect to similar plants. Based upon this quantification analysis, findings related to the HRA dependency analysis are deemed by DTE to not significantly affect risk-informed applications including the SAMA analysis. On the basis of the conclusions of the expert panel review and DTE clarification (DTE 2015a) that the same PRA model (FermiV9 draft) was the subject of both the peer review and the expert panel review and only one change to correct an error found by the peer review was made in the HRA dependency analysis between the FermiV9 draft and the versions used for the license renewal (FermiV9), the NRC staff concludes that the Fermi 2 HRA dependency analysis is adequate for the SAMA application.

The NRC staff has determined that DTEs disposition of the peer review findings is consistent with the NEI guidance (NEI 2005). The NRC staff also finds the final resolution of the findings provides reasonable assurance of minimal impacts on the results of the SAMA analysis.

In an RAI, the NRC staff requested that DTE briefly discuss the modeling of the LOOP and SBO scenarios, including how the CTGs are incorporated in the model and if common cause loss of alternating current (AC) due to weather is considered. As discussed above, at Fermi 2 there are two separate switchyards (120 kV and 345 kV), each of which supplies offsite power to a single division of engineered safety feature (ESF) and balance of plant power. The LOOP initiators are referred to as divisional Loss of Offsite Power (LOOP) or partial LOOP events. These partial LOOP events are processed via the general transient event tree. Consequential losses of offsite power are modeled as total LOOPs and are processed via the LOOP event tree. The failure of the emergency AC power systems following a LOOP would result in what is commonly referred to as SBO or the complete loss of all AC power to the unit. At Fermi 2, this result requires the failure of the AC power from both switchyards, failure of the emergency diesels available to the unit, and failure of the interconnection with the onsite gas turbines. The SBO event tree considers the ability for direct current (DC)-powered high pressure systems (HPCI and/or RCIC) to provide high pressure reactor pressure vessel (RPV) makeup, manual depressurization per the emergency operating procedures, the ability to recover offsite power (at various time points in the sequence), and the ability to successfully mitigate core damage in the long term following successful recovery of offsite power.

The LOOP models include weather-centered total and partial LOOP events along with a common cause failure of all four CTGs. The model specifically includes the following:

(1) common cause failure of all four CTGs in the event of a weather-centered total LOOP, and (2) common cause failure of all four CTGs in the event of a weather-centered loss of the 120 kV (Division 1) switchyard.

The NRC staff noted in an RAI, that the common cause failure of all four CTGs in the event of a weather-centered loss of the 345 kV switchyard is not included in the model. DTE indicated that there were several reasons for not including weather-centered loss in the model. First, the CTGs are electrically connected to the 120 kV switchyard. Second, the common cause failure of a weather-centered loss of 345 kV switchyard and all four CTGs without affecting the 120 kV switchyard is not deemed a credible scenario due to the large spatial separation between the 120 kV and 345 kV switchyards. If there were a weather phenomenon large enough to affect both the 345 kV switchyard and the CTGs, it would also affect the 120 kV switchyard (DTE 2015b).

DTE stated that the FermiV9 model reflects the Fermi 2 as-built, as-operated configuration as of June 30, 2011. One subsequent plant modification included in the model is the addition of a F-8

Appendix F third breaker row to the existing ring bus configuration in the 345-kV switchyard. In addition, one planned modification, the measurement uncertainty recapture (MUR) power uprate, is included in the SAMA analysis. The small change in the current licensed power, an increase of 1.64 percent, does not have any impact on the PRA model, but the increase in power is included in the Level 3 analysis for the calculation of maximum averted cost risk (MACR). In response to an NRC staff RAI, DTE confirmed that a review of all modifications since the freeze date have been evaluated. Other than the items discussed above, DTE indicated that pending Fukushima modifications will not have an adverse impact on the SAMA analysis, and that in addition, no operating practice/procedure changes have been identified that would have an adverse impact on the SAMA assessment (DTE 2015a).

On the basis of the NRC staffs evaluation of internal events previously described in this subsection, the NRC staff concludes that the internal events Level 1 PRA model is of sufficient quality to support the SAMA evaluation.

F.2.2.2 External Events As previously indicated, the Fermi 2 PRA used for the SAMA analysis does not include external events. In the absence of such an analysis, DTE used the Fermi 2 IPEEE to identify the highest risk accident sequences and the potential means of reducing the risk posed by those sequences and to estimate the benefit of potential SAMAs, as discussed below and in Section F.3.2.

The Fermi 2 IPEEE was submitted in March 1996 (DECo 1996) in response to Supplement 4 of Generic Letter (GL) 88-20 (NRC 1991). The submittal included a seismic margin assessment (SMA), a fire assessment using the Electric Power Research Institute (EPRI) fire-induced vulnerability evaluation (FIVE) guidance (EPRI 1992), and a screening analysis for other external events, such as high winds, floods, and other external events (HFO). Detroit Edison did not provide a definition of a vulnerability and did not identify any vulnerabilities in the seismic, fire, or HFO areas. The licensee did, however propose various plant improvements in the seismic and fire areas. In its safety evaluation report (SER) (NRC 2000a), the NRC staff concluded that the applicants IPEEE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities for external events and, therefore, that the Fermi 2 IPEEE has met the intent of Supplement 4 to GL 88-20.

The Fermi 2 IPEEE seismic analysis was a focused-scope SMA following NRC guidance (Chen et al. 1991; NRC 1991). The SMA approach is deterministic in nature and does not result in probabilistic risk information. The SMA was performed using a Safe Shutdown Equipment List (SSEL) with plant walkdowns in accordance with the guidelines and procedures documented in EPRI Report NP-6041-SL (EPRI 1991). Two success paths, each capable of mitigating the effects of a seismically induced small break LOCA, were identified based on a review of the guidance and plant documentation. The components on the SSEL were then evaluated for seismic capacity using a review level earthquake (RLE) of 0.3 g.

EPRI Report NP-6041-SL provides a set of screening guidelines to be used by the seismic review team (SRT) to screen structures and equipment, against the RLE, during plant walkdowns. The screening also relies on the judgment and the experience of the SRT. More detailed evaluations may be required to establish the seismic capability of items (outliers) that do not meet the screening criteria or are judged by the SRT to warrant further review.

Particular emphasis was placed on equipment anchorage and identification of potential spatial interaction problems. A bounding anchorage evaluation was prepared to evaluate the capability of SSEL component anchorages to resist the RLE loads. High confidence in low probability of F-9

Appendix F failure (HCLPF) calculations were performed for several critical items including masonry block and shield walls, and reactor internals.

As a result of the seismic screening evaluation and walkdown of the structures and components, several field conditions and concerns resulting in the need for plant maintenance were identified. Most of these items consisted of loose, missing, or damaged hardware and were handled by initiating plant maintenance work requests. Several conditions required design modifications. The majority of the outliers involved seismic interaction concerns that were resolved through some corrective actions. Others were resolved either by Conservative Deterministic Failure Margin (CDFM) capacity analysis to show the capacity well beyond review-level earthquake demand or by maintenance or modifications. These outliers were considered further in the Phase I SAMA identification, discussed in Section F.3 below.

As indicated by the licensee, detailed HCLPF calculations were not performed for all outliers.

The approach was to utilize existing design basis documentation to extrapolate a minimum HCLPF of 0.3g PGA, based on the EPRI SMA Methodology found in Report NP-6041-SL. This was primarily accomplished by reviewing the conservative bias of the original design methods versus the guidelines in EPRI Report NP-6041-SL for determining CDFM and/or by taking advantage of existing design margins between capacity and demand.

With respect to the completion of the plant modifications and corrective maintenance activities, the licensee reached the following conclusion (DECo 1996): all outliers identified during the seismic evaluation and walkdowns are shown to have adequate capability to withstand the prescribed RLE without degradation of the components or pertinent systems. The license further noted: [a]s a result, this study has demonstrated, by using the above-described methodology, that the plant seismic HCLPF at Fermi 2 is equal to or greater than 0.3 g.

Improvements to Fermi 2 resulting from the IPEEE were (DECo 1996, DTE 2014):

fastening adjacent panels containing relays to prevent impacts during a seismic event;

replacement of low ruggedness relays;

additional seismic restraints for the large nonsafety-related air dryer tank;

rectification of a weakness in the seismic load path for two large control center heating, ventilating, and air conditioning instrument panels;

additional training incorporated into the continuing maintenance training program to increase the awareness level and emphasize the importance of mounting hardware installation and restoration during and after maintenance activities; and

operations training to include a LOOP and permanent loss of CTG 11 Unit 1 (CTG 11-1) scenario and in dealing with spurious alarms resulting from low seismic ruggedness relay chatter.

DTE actions in response to the 50.54(f) letter (NRC 2012a) requesting information related to the Fukushima Daiichi Near Term Task Force (NTTF) recommendations, confirmed that all of the above items have been addressed and are considered resolved (DTE 2012a). It is further noted that the DTE response to Recommendation 2.3 identified 27 potentially adverse seismic conditions, but none were determined to have an immediate impact to the safe operation of the plant and are being addressed through the NRCs agencywide program for responding to the Fukushima Daiichi accident. This program includes additional seismic evaluations as outlined in the NRCs 50.54(f) letter dated March 12, 2012 (NRC 2012a).

F-10

Appendix F Because the SMA approach used in the IPEEE does not involve the determination of seismic CDF, a seismic CDF from the Generic Issue (GI) 199 risk assessment (NRC 2010) for the Fermi 2 site was used. The weakest link seismic CDF value of 4.2x106 per year from GI-199 was used for determining the external events multiplier. The NRC staff notes that EPRI has provided initial estimates of updated seismic CDFs from new seismic hazard curves developed following the Fukushima Daiichi accident (EPRI 2014). In response to an NRC staff RAI to consider the impact of this updated seismic CDF on the Fermi 2 SAMA analysis, DTE indicated that, using the same methodology as GI-199, the new seismic hazard curves would result in a seismic CDF for Fermi 2 of 2.3x106 per year (DTE 2015a). This is discussed in more detail below.

The Fermi 2 IPEEE included an internal fire analysis employing EPRIs FIVE methodology (EPRI 1992). FIVE is fundamentally a prescriptive fire PRA-based screening approach, which uses progressively more detailed phases of screening. The Fermi 2 analysis utilized the major steps of a FIVE assessment including fire area/compartment identification, safe shutdown equipment location, qualitative screening using spatial failure analysis, a Fire Compartment Interaction Analysis (FCIA), quantitative screening, including determining the safe shutdown failure probability for unscreened fire initiators using the PRA models, a fire propagation analysis, and a confirmatory walkdown (NRC 2000a).

The CDF of the areas that did not screen out in the final screening phase totaled 1.7x105 per year in the original IPEEE submittal (DECo 1996). As a result of a response to an NRC RAI on the IPEEE, the total CDF increased to approximately 2.2x105 per year (DECo 1999).

Table F-4 provides a summary of the final phase of screening results from the Fermi 2 IPEEE fire analysis. As the NRC staff noted in the Fermi 2 IPEEE SER (NRC 2000a), the CDF from the remaining (those with a CDF of less than 1x106 per year) compartments subjected to the detailed analysis is 1.5x105 per year. This yields a total fire CDF of 3.7x105 per year, the impact of which is discussed below.

Table F-4. Fermi 2 Important Contributors(a) to Fire CDF Fire Area Fire Zone Description CDF (per year) 09AB Control Room 7.4x106 04ABN Division 1 Switchgear 4.5x106 03AB Relay Room 2.8x106 12AB Division 2 Switchgear 2.5x106 11ABE Division 1 Portion Miscellaneous Room 1.9x106 02RBNE Northeast Quadrant Reactor Building 1.5x106 RB06 Reactor Building 2nd Floor 1.0x106 Total 2.2x105 Key: CDF = core damage frequency (a) Fire areas are those included in the final phase of screening with a CDF of at least 1.0x106 per year.

The Fermi 2 IPEEE fire assessment does not provide a definition of the term fire vulnerability, but concludes that the risk from fires is acceptable and thus presents no vulnerability. The single fire insight from the IPEEE fire analysis resulted from the evaluation of the second floor Reactor Building (RB06). The dominating contributors for this area are cabinets used for F-11

Appendix F dedicated shutdown and whose loss would isolate the affected equipment from the main control room (MCR), thereby causing loss of the equipment function. Even though the potential for this loss was considered to be adequately addressed by the current operator training, additional fire brigade drills in the vicinity of these cabinets were planned to increase the awareness of the brigade members to the need to quickly isolate and extinguish such cabinet fires. DTE states that this training activity was tracked with a training work request and was subsequently incorporated into the training program (DTE 2014).

The Fermi 2 IPEEE analysis of high winds and tornadoes, external floods, and transportation and other nearby facility accidents followed the screening and evaluation approaches specified in Supplement 4 to GL 88-20 (NRC 1991). For these events, the IPEEE concluded that Fermi 2, while designed prior to the issuance of the 1975 Standard Review Plan (NRC 1975), conforms to the 1975 criteria. Therefore, the contribution to CDF from these events meets the IPEEE screening criterion of 1x106 per year in NUREG-1407 (Chen et al. 1991). No vulnerabilities or enhancements were identified.

As discussed in the ER and in the NRC staffs SER of the IPEEE (NRC 2000a), an issue related to the potential for a common cause failure of diesel generator cooling function due to ice formation was identified during the same time frame that the IPEEE was performed. This was addressed subsequent to the IPEEE submittal. In order to prevent ice formation in service water pumps causing common mode failure of diesel generators, the following actions were taken (DTE 2014): (1) implemented procedures to check on this condition, (2) installed permanent temperature monitoring equipment, (3) installed fiberglass curtain to reduce wind chill effects on portion of pump columns below the RHR complex slab and above the reservoir water surface, and (4) modified terminations of RHR cold weather (bypass of mechanical draft cooling tower) lines to below reservoir water level to eliminate water forces on the curtain.

The NRC staff notes that DTEs response to the NRCs 50.54(f) letter (NRC 2012a) requesting information related to the Fukushima Daiichi NTTF recommendations includes a flooding hazards reevaluation and a flooding walkdown. The flooding hazards reevaluation (DTE 2013) concluded ...the results from the updated flood evaluations analyses for Fermi 2 are less than the design bases flood protection. Therefore, an interim evaluation is not required and there are no additional actions taken or planned. The flooding walkdown identified three conditions adverse to quality as follows: degraded boot seal, small gap between sealing surfaces in the outer railroad airlock door, and absence of seals for four electrical conduits inside the railroad airlock. Work orders were generated to resolve these issues. The walkdown also collected and documented information concerning the available physical margins (APM) for flooding. No conditions related to small APM with large consequences (indicative of a potential cliff-edge effect) were identified (DTE 2012b). The NRC staffs SER on the walkdown (NRC 2014b) stated, The staff concludes that the licensee, through the implementation of the walkdown guidance activities and, in accordance with plant processes and procedures, verified the plant configuration with the current flooding licensing basis; addressed degraded, nonconforming, or unanalyzed flooding conditions; and verified the adequacy of monitoring and maintenance programs for protective features.

As discussed in the ER, since there are no up-to-date quantitative external event models for Fermi 2, it is necessary to develop a multiplier that can be applied to the internal events PRA results to account for the risk contribution from external events in the SAMA evaluation. For the seismic contribution to risk, DTE used the previously described GI-199 seismic CDF value of 4.2x106 per year. For the fire contribution to risk, DTE used a fire CDF of 1.08x105 per year.

This value is one half of the total CDF of the unscreened fire area CDFs from the FIVE analysis given in Table F-4. DTE noted that the FIVE analysis is expected to give conservative results.

In addition, the IPEEE fire analysis utilized the IPE internal events model with a CDF of 5.7x106 F-12

Appendix F per year, approximately four times the current internal events CDF of 1.5x106 per year. DTE indicated that it could be reasonably assumed that an update of the FIVE analysis with the current internal events model would result in a fire CDF equal to one-fourth of the original fire CDF. DTE conservatively utilized a factor of two reduction to arrive at the fire CDF of 1.08x105 per year.

Based on the aforementioned results, DTE indicated in the ER that the total external events CDF is approximately 1.5x105 per year (based on a seismic CDF of 4.2x106 per year, a fire CDF of 1.08x105 per year). DTE did not include CDFs for high winds, external flooding, or transportation and other nearby accidents on the basis that these events were addressed by demonstrating compliance with the 1975 Standard Review Plan (SRP) and that compliance with the SRP and no adverse finds from walkdowns, justifies the conclusion that the hazards contribution to CDF is less than 106 per year. Therefore, these events are not significant contributors to external event risk. Because quantitative analysis of these events is not practical, the external event multiplier was developed based on seismic and fire risk (DTE 2014). The total CDF (internal and external events) is then approximately 1.65x105 per year or 11 times the internal events CDF. This multiplier was used by DTE in the SAMA analysis in the ER to account for the impact of external events on the benefits determined from the internal events PRA.

As noted in an NRC staff RAI, the NRC staffs evaluation report on the IPEEE indicated the CDF of 1.5x105 per year from the remaining areas screened (with CDFs less than 1x106 per year) was subjected to the same detailed analysis as the unscreened areas. Because this 1.5x105 per year CDF was not included in the 2.15x105 per year CDF from the unscreened fire areas, DTE was asked to provide justification for not including it in the total fire CDF used in the SAMA analysis and/or assess the impact on the SAMA cost-benefit evaluation, particularly with respect to determining the external events multiplier. In response, DTE performed two sensitivity analyses. The first analysis, similar to that described above, used the updated seismic CDF (2.26x106 per year) and the total fire CDF including the contribution from the screened areas reduced by a factor of 2 (3.65x105 per year). This resulted in an external events multiplier of 14.7. In the second sensitivity analysis, the total fire CDF including the contribution from the screened areas was reduced by the ratio of the current internal events CDF less the internal flood contribution (1.27x106 per year) to the IPEs internal events contribution (5.7x106 per year). This ratio (0.223) then yielded a fire CDF, based on the total IPEEE fire CDF, of 8.1x106 per year. Internal floods were excluded from the current CDF since they were not included in the IPE and internal flood contributions to CDF would not impact the fire CDF. This second sensitivity yields an external events multiplier of 7.9. DTE concluded that since the average of these two values for the external events multiplier of 11.3 is approximately the same as the value of 11 used in the ER, the continued use of this value is acceptable (DTE 2015a).

The NRC staff agrees with the applicants overall conclusion concerning the multiplier used to represent the impact of external events and finds that the applicants use of a multiplier of 11 will reasonably account for external events in the SAMA evaluation.

F.2.2.3 Level 2 Fission Product Release Analysis The NRC staff reviewed the general process used by DTE to translate the results of the Level 1 PRA into containment releases and the results of the Level 2 analysis, as described in the ER (DTE 2014) and responses to NRC staff RAIs (DTE 2015a). DTE indicated that the Fermi 2 Level 2 PRA model used for the SAMA analysis is a full Level 2 model developed as part of the FermiV9 internal events PRA model (DTE 2014), which included the conversion of the F-13

Appendix F RISKMAN-based Computer-Aided Fault Tree Analysis (CAFTA) Level 2 to an upgraded CAFTA Level 2 model based on first principles.

PDSs provide the interface between the Level 1 and Level 2 analyses. The Level 1 PRA identifies accident sequences that contribute to the CDF and represent the spectrum of possible challenges to containment. The Level 1 sequences that result in core damage are grouped into PDS bins. Each bin collects all of those sequences for which the progression of core damage, the release of fission products from the fuel, the status of the containment and its safeguards systems, and the potential for mitigating the potential radiological source terms are similar. The PDS bins for Fermi 2 are characterized by:

integrity of the primary system,

primary system pressure,

decay heat removal,

integrity of the containment, and

relative timing of core damage.

Based on these parameters, five accident classes were created and subsequently further divided into 16 subclasses as listed in ER Table D.1-8. The PDS designators listed in Table D.1-8 represent the core damage end-state categories from the Level 1 analysis that are grouped together as entry conditions for the Level 2 analysis. The Level 2 accident progression for each of the PDS is evaluated using a CET to determine the appropriate release category for each Level 2 sequence. In response to an NRC staff RAI relative to the definition of accident classes, DTE indicated that for Class IV (ATWS), two of the subclasses (IVT and IVV) were not used since the modeling conservatively precludes these subclasses and that the other two subclasses (IVA and IVL) were combined because the Level 2 modeling of these subclasses was very similar (DTE 2015a).

The Fermi 2 Level 2 model consists of a set of three CETs, which contain both phenomenological and containment system protection status functional nodes, and assess the accident progression following a core damage event. In response to an NRC staff RAI, DTE indicated that the Level 1 and Level 2 models are linked to ensure that dependencies on Level 1 failures and successes are appropriately accounted for (DTE 2015a).

Table D.1-4 of the ER lists the 18 functional nodes and the associated success criteria used in the Fermi 2 Level 2 CET model. The nodes are quantified using subordinate trees and logic rules that are based on deterministic analysis of physical process for a spectrum of severe accident progressions, and a probabilistic analysis component in which the likelihood of the various outcomes are assessed. In response to an NRC staff RAI to provide more information concerning the treatment of containment isolation failures and credit taken for containment sprays, DTE indicated that all containment isolation failure sequences, in conjunction with core damage, were assumed to result in a high early (H/E) release. Relative to containment sprays, DTE indicated that drywell spray is credited as directed by the Severe Accident Guidelines in the Level 2 and associated MAAP analysis and noted that the primary functions of drywell spray in the Level 2 model are to put water on the containment floor, quench ex-vessel debris following vessel breach, and to scrub fission products from the containment atmosphere.

(DTE 2015a)

Each CET end state represents a radionuclide release to the environment and is assigned to a release category. As previously described, the release categories were defined based on the timing and magnitude of release. In response to an NRC staff RAI, DTE discussed the basis for assigning each end state to a release category. Level 2 sequence end states were assigned to F-14

Appendix F a release category based on key attributes of the Level 2 sequence (e.g., accident class, mitigating strategies employed, location of release point out of containment) that ultimately impact the timing and magnitude of a release. Based on the body of Fermi 2 specific deterministic calculations and assignment rules, an understanding of accident phenomenology was inferred to allow the available MAAP 4.0.7 calculations to be used to support the determination of radionuclide release end states for all Level 2 sequences with non-negligible frequency (DTE 2015a). DTE also clarified that leakage from the drywell was modeled instead of the torus air volume because drywell leakage yielded a higher release fraction for cesium iodide (CsI) (DTE 2015a). The NRC staff finds this treatment acceptable, because it is consistent with the technical specification for the plant and inclusion of the release category for intact containment provides additional confidence that estimated releases and consequences have not been underestimated.

In an RAI (NRC 2014a), the NRC staff noted that the SAMA submittal describes a situation in which a lower release category frequency was used in the SAMA analysis compared to the value in the Fermi 2 PRA documentation. DTE indicated the cause to be an issue with under counting of Class II contribution in the PRA. In response to this RAI, DTE explained the cause of this undercounting and its potential impact on the SAMA analysis. The undercounting was caused by use of 1x1012 per year as the truncation cutoff value for the Level 2 analysis. The undercounting (equal to 3.14x109 per year) was described to remove a number of Level 2 sequences when the same truncation cutoff value (1x1012 per year) was used for the Level 2 release category and Level 1 CDF analyses. The undercounting was eliminated when a lower truncation cutoff is used for the Level 2 analysis (DTE 2015a). The impact of this undercounting on the overall consequence was assessed in the ER as minimal based on the assumption that the consequences were the same as the moderate/early (M/E) release category.

A followup RAI by the NRC staff (NRC 2015a), questioned the evaluation assumption that the 3.14x109 per year undercounting had a consequence equivalent to the M/E release category.

In response, DTE concluded based on further evaluation that the unaccounted frequency would more appropriately split between the M/E and H/E release categories. DTEs sensitivity study assumed that the entire undercounting was attributed to the H/E category and resulted in a

$16,200 increase in the MACR for both internal and external events (DTE 2015b), which represents an increase of less than a 0.5 percent in the base case MACR given in Section F.6.1. The impact of this undercounting on the SAMA cost-benefit analysis is discussed in Section F.6.2. DTE developed the accident progression and associated release characteristics for each release category, by using the results of MAAP Version 4.0.7 computer code calculations. A MAAP case was identified as a representative case for each of the Fermi 2 Level 2 PRA release categories. In response to an NRC staff RAI, DTE provided a description of the representative cases for each release category and additional information on the selection of these representative cases. DTE noted that MAAP scenarios are chosen based on a frequency-weighted approach (i.e., the MAAP scenario representing the most dominant sequence(s) or bounding the most dominant sequence is typically chosen) and that this approach provides a better representation of the release category then choosing the scenario with the very most conservative conditions, such as the highest CsI release fraction (DTE 2015a).

During the SAMA audit (NRC 2014c), it was noted that documentation of the selection of representative sequences included a situation in which an MAAP scenario or sequence with a CsI release fraction of 0.72 was subsumed into the H/E release category modeled in the ER using MAAP case with a CsI release fraction of 0.24. In response to NRC staff RAIs to discuss the potential for underestimating the benefit of any SAMA that mitigates non-dominant but higher release fraction scenarios, DTE provided additional discussion of the development of the F-15

Appendix F representative scenarios for the three most important release categories (H/E-BOC, H/E, and H/I), which collectively account for 92 percent of the total offsite population dose risk and cost risk (DTE 2015a).

DTE indicated that because the H/E-BOC release category has one representative MAAP scenario, it is therefore adequately represented by that case. For the specific example cited above, DTE indicated that the frequency of the sequence with the 0.72 CsI release fraction is less than 1 percent of the H/E release category frequency; therefore, using this sequence to represent the entire release category would not be appropriate.

In the initial RAI response (DTE 2015a), DTE showed two Accident Class IIA sequences (sequences involving a loss of containment heat removal with the RPV initially intact and core damage induced post-containment failure) included in the H/E release category with CsI and/or cesium hydroxide (CsOH) release fractions greater than those for the representative sequence chosen for this release category. If it is conservatively assumed that the Class IIA sequences have the same consequences as the high/early break outside containment (H/E-BOC) release category, the revised Class IIA contribution is 2.69 times the calculated person-rem/yr and 1.08 times the OECR contributions when they are included in the H/E base case release category. This approach increases the total dose risk by 15 percent (to 5.64 person-rem/yr) but increases the cost risk by only 0.6 percent (to $15,700/yr) over the base case values of 4.91 person-rem/yr and $15,600/yr, respectively. Refer to Table F-2 of this appendix for the base case results presented in the ER. Based on the conservatism of this analysis and considering the offsite exposure cost is only approximately 34 percent of the baseline MACR, this dose risk increase would be much less significant to the total MACR, and DTE concluded that the representative sequence used in the original ER analysis adequately represents the H/E release category even with the inclusion of Class IIA sequences in this release category (DTE 2015a). While the NRC staff agrees with the conclusion that the reassignment of the Class IIA sequences to a different, higher consequence, release category would not have a significant impact on the total base case benefit (the MACR), it would lead to an underestimate of the benefit for any SAMA that mitigates the Class IIA sequences. This topic is discussed further in Section F.6.2. DTE indicated the H/I release category is conservatively represented by a scenario that bounds all the dominant H/I sequence CsI and CsOH release fractions (DTE 2015a).

In response to an NRC staff RAI to provide the duration of the MAAP analysis for each release category and to provide an assessment of the adequacy of the time to characterize the release fractions, DTE indicated that the run times and therefore the release fraction for two (H/E-BOC and H/E) of the three (H/E-BOC, H/E, and H/I) important release categories was 40 hours1.667 days 0.238 weeks 0.0548 months (or approximately 36 hours1.5 days 0.214 weeks 0.0493 months following core damage), which is less than the time frame of 48 hours2 days 0.286 weeks 0.0658 months used in the SOARCA (State-of-the-Art Reactor Consequence Analyses) project (NRC 2012b). SOARCA assumed that adequate mitigating measures could be brought onsite, connected, and functioning within 48 hours2 days 0.286 weeks 0.0658 months . The run time for the third important release category (H/I) was 191 hours7.958 days 1.137 weeks 0.262 months . DTE reported an increase of 0.01 of the core inventory or about 3 to 4 percent of the 40-hour release fractions for CsI and CsOH (key contributors to offsite dose and cost risk) from the 40-hour values used in the SAMA analysis. DTE concluded that this increase is not significant and the use of the release fraction values based on the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months run times is adequate (DTE 2015a). On the basis of the small impact on release fractions, the NRC staff agrees that results calculated with run times of 40 hours1.667 days 0.238 weeks 0.0548 months are acceptable for the SAMA analysis.

In response to an NRC staff RAI, DTE stated that the input for the Fermi 2 MAAP 4.0.7 analysis utilizes both element masses and nuclide activities as recommended by the MAAP 4.0.7 code and is consistent with the guidance in MAAP-FLAASH #68 (DTE 2015a).

F-16

Appendix F As discussed above, the draft FermiV9 PRA model was evaluated in the 2012 BWROG peer review. All findings, including those pertaining to the Level 2 large early release frequency (LERF) model, were considered by the NRC staff to be satisfactorily resolved for the SAMA application.

On the basis of the NRC staffs review of DTEs Level 2 model, the peer review performed on the draft FermiV9 PRA model, and DTEs responses to NRC staff RAIs, the NRC staff concludes that, subject to the further discussion of cost-benefit analysis in Section F.6.2, the Level 2 PRA is of sufficient quality to support the SAMA evaluation.

F.2.2.4 Level 3 Offsite Consequence Analysis The NRC staff reviewed DTEs process to propagate the containment performance (Level 2) portion of the PRA to an assessment of offsite consequences (Level 3 PRA). Using the MACCS2 version 3.7.0 code, DTE determined the offsite consequences from potential releases of radioactive material (DTE 2014). In the Level 3 analysis, DTE combined release fractions and release categories, discussed in Section F.2.2.3, with the calculated core inventory to yield a source term of radionuclide releases to the outside environment. In response to an NRC staff RAI, DTE provided additional information on the source of the Fermi 2 radionuclide inventory that was calculated with the SCALE version 4.4 SAS2H software (DTE 2015a). The NRC staff finds the MACCS2 and SCALE codes to be acceptable for the SAMA evaluation because the codes are widely used for radiological dose calculations resulting from airborne releases of radioactive material and radionuclide source term determinations, respectively.

In response to an NRC staff RAI, DTE provided the rationale for the selection of radionuclides included in the core inventory. Specifically, DTE clarified that radioactive cobalt is not included in the core inventory for Fermi 2 (DTE 2015a) and indicated that core inventory relates to the alternative radiological source term developed in accordance with Regulatory Guide 1.183 (NRC 2000b). In response to a license amendment request, the NRC staff previously evaluated the radionuclide inventory (NRC 2004a) and stated:

The licensee projected the core inventory of fission products using the ORIGEN-S computer code. The ORIGEN-S computer code is acceptable to the NRC staff for estimating the core inventory. The licensee assumed a core licensed power level of 3,430 megawatts thermal (MWt) and applied an uncertainty correction of 102 percent to arrive at the analysis input of 3499 MWt.

The NRC staff notes that the input power level of 3,499 MWt exceeds the approved uprated power of 3,486 MWt (DTE 2015a). Because larger power levels are conservative with respect to the source term and radiological consequences, the NRC finds the greater power level and radionuclide inventory acceptable for use in the SAMA analysis. DTE confirmed that no uprates are planned following the license amendment approval in 2014 for an MUR uprate to 3,486 MWt and that assessed impacts from increases in the power level did not result in additional SAMAs becoming cost beneficial (DTE 2015a). In response to an NRC staff RAI on thermal power levels, DTE reported the radionuclide core inventory in Table D.1-23 of the ER (DTE 2014) was based on a thermal power of 3,430 MWt, which was the licensed power level when the SAMA analysis was performed, and also indicated that a license amendment was approved in 2014 for a power uprate to 3,486 MWt (DTE 2015a). DTE performed a sensitivity analysis to assess the impacts of this power uprate on the radionuclide inventory, Level 3 offsite consequences, and averted cost risk attributable to each SAMA. DTE concluded that the increased power level to 3,486 MWt did not result in additional SAMAs becoming cost beneficial (DTE 2015a). The NRC staff finds DTEs sensitivity results to be reasonable and acceptable because no changes to the list of cost-beneficial SAMAs would be expected from the small 1.6 percent increase in thermal F-17

Appendix F power considering that the original SAMA analysis results in the ER showed that SAMAs deemed as not cost beneficial using the most conservative 95th percentile values for averted cost risk were more than 2 percent below estimated costs for SAMA implementation. DTE stated there are currently no plans for further power uprates at Fermi 2 (DTE 2015a). DTE also confirmed that future fuel management practices or fuel design changes are not expected to influence the core inventory because DTE plans to continue using the same reactor fuel and fuel cycle duration (DTE 2015a). The NRC staff finds that the SAMA analysis is consistent with DTEs plans on fuel management and concludes that the current radionuclide inventory calculations (DTE 2014, 2015a) are adequate for the estimation of offsite consequences.

DTE presented the major input parameter values and assumptions of the offsite consequence analyses in Attachment D of the ER (DTE 2014). DTE considered site-specific meteorological data for calendar years 2003, 2005, and 2007. Meteorological data from 2007 were selected for input to the MACCS2 code because they resulted in the highest population dose risk and offsite economic cost risk (DTE 2014). Meteorological data included wind speed, wind direction, atmospheric stability class, precipitation, and atmospheric mixing heights acquired from the Fermi 2 meteorological monitoring system and the U.S. Environmental Protection Agency. In response to an NRC staff RAI, DTE described the weather bin sampling for modeling precipitation events that results in a rainfall intensity distribution for the 16 compass directions and confirmed that boundary weather parameters include precipitation (DTE 2015a). The NRC staff finds the modeling of precipitation to be acceptable because it is linked to site-specific annual meteorological data and implemented using widely accepted software. Because DTEs assumption of precipitation in cells beyond the 80-km (50-mi) radial boundary would neither underestimate population doses nor economic costs, the NRC staff finds the assumed precipitation in boundary cells to be acceptable. Because selection of the 2007 meteorological data set resulted in the highest population dose risk and offsite economic cost risk, the NRC staff accepts its use in the SAMA evaluation.

DTE estimated missing meteorological data by data substitution. For 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of missing data, interpolation was performed with valid data immediately before and after the data gap. For data gaps greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , data were replaced with data from days with similar meteorological conditions immediately before and after the data gap. In response to a question on the amount of missing data, DTE indicated that the percentages of missing data replaced by substitution were 3.59, 0.35, and 1.88 percent in the respective years 2003, 2005, and 2007. Because these percentages of missing data are reasonable and the methods used to substitute missing data are common remedies, the NRC staff finds these approaches to be acceptable for use in the SAMA analysis. As previously described, the sources of data and models for atmospheric dispersion used by the applicant are appropriate for calculating consequences from potential airborne releases of radioactive material. The NRC staff notes that results of previous SAMA analyses have shown little sensitivity to year-to-year differences in meteorological data and concludes that the selection of the 2007 meteorological data for use in the SAMA analysis is appropriate.

The NRC staff requested additional information on the modeling assumption for watershed drainage, given the Fermi 2 site is located near a large body of water. DTE described that modeling drainage by rivers was conservative compared to drainage by large bodies of water because radionuclide contaminants would have a greater retention in the area due to less removal by drainage (DTE 2015a). The NRC staff accepts this parameter selection because it is conservative and will overestimate radionuclide concentrations as well as offsite population doses.

In response to an NRC staff RAI, DTE assessed the sensitivity of Level 3 results to the 10-MW plume heat output applied to each release category (except intact containment). Specifically, F-18

Appendix F DTE indicated that the modified MACR (MMACR) would increase by 0.76 percent with no plume heat output and decrease by 1.32 percent with a plume heat output of 20 MW. Because these plume heat outputs bracket sample values in SAMA guidance (NEI 2005), and DTE showed a minimal sensitivity of averted cost risk to plume heat, the NRC staff finds that DTEs modeling of plume heat is acceptable because alternative plume heat values would not change the identification of cost beneficial SAMAs.

Because the conservative modeling assumptions were included in the assessment and input data were either obtained for the Fermi 2 site or found to be consistent with guidance values, the NRC staff concludes that data and modeling assumptions for the Level 3 analysis are appropriate for the SAMA evaluation.

DTE projected the population distribution and expected growth within a radius of 50 mi (80 km) of the Fermi site out to the year 2045 and used the areal weighting from the SECPOP2000 Version 3.13.1 code to populate the spatial elements of the computer model (DTE 2014). In response to RAIs by NRC staff (DTE 2015c), DTE clarified the accounting of the Canadian population with additional details on the distribution of U.S. permanent population, Canadian permanent, and transient populations estimated for the year 2045. These data clearly show Canadian populations to the east and northeast of the Fermi 2 site. DTE also considered transient population contributions based on tourism data for Michigan, Ohio, and Ontario, Canada. DTE reported that the total population within 50 mi (80 km) of the Fermi 2 site was projected to be 6,055,850 for the year 2045. The value of land in Canada within 50 mi (80 km) of the Fermi 2 site was also considered in the analysis (DTE 2015c). Since the original ER submittal and additional information provided by DTE satisfactorily addressed the questions raised by NRC staff and showed that population inputs would not underestimate potential consequences, NRC staff finds the methods and assumptions for estimating population reasonable and acceptable for purposes of the SAMA evaluation.

For the 16-km (10-mi) emergency planning zone at Fermi 2, DTE considered information from the Fermi Nuclear Power Plant Development of Evacuation Times Estimates report in its determination of evacuation times, time delays, and travel speeds (DTE 2014). For the baseline Level 3 calculation in Table D.1-24 of the ER (DTE 2014), DTE assumed 95 percent of the population within the emergency planning zone would evacuate. To account for population increases in the future, DTE lowered the assumed evacuation speed from the determined network-wide evacuation speed of 12.8 meters per second (28.6 miles per hour) to 10 meters per second (22.4 miles per hour). In response to an NRC staff RAI on the network-wide evacuation speed and total time for evacuation, DTE affirmed that the evacuation assessment considered site-specific conditions for Fermi 2 and described how spatial dependences of the highway network as well as population density were modeled (DTE 2015a). In a sensitivity analysis shown in Table D.1-25 of the ER (DTE 2014), DTE reported an increase in the population dose risk by 1 percent due to an assumed factor-of-2 reduction in the average evacuation speed from 10 meters per second to 5 meters per second. Sensitivity values for the evacuation fraction of 90 percent and 99.5 percent were shown in Table D.1-26 of the ER to have very small influences on the population dose risk (less than 0.005 percent) (DTE 2014).

As described by DTE, evacuation applies to the emergency planning zone with a lower population compared to other areas surrounding the Fermi 2 site. The much larger population outside of the emergency planning zone (about 55 times larger) does not evacuate in the assessment and accounts for a majority of the total population dose. For these reasons, the total population dose is not directly proportional to the fraction of individuals in the emergency planning zone who do not evacuate. Because DTE used site-specific information, applied more pessimistic (lower) fractions for the evacuating population in the emergency planning zone compared to guidance values (NRC 1997a), and considered the effect of population increases F-19

Appendix F on evacuation parameter values, the NRC staff concludes that the evacuation assumptions and analysis are reasonable and acceptable for the purposes of the SAMA analysis at Fermi 2.

DTE calculated land values using an economic multiplier with economic data from 2002. The economic multiplier was based on the slope of the consumer price index between 2000 and 2012. DTE extrapolated this slope to the year 2013 to obtain an economic multiplier of 1.2964 (DTE 2014). The NRC staff reviewed DTEs assessment of economic data, including the assumptions associated with land values and the destruction of crops exposed to radioactive material from modeled radionuclide releases. This crop destruction applies to the year of the event. In subsequent years, the acceptability of food production is evaluated with projected individual dose criteria to determine if loss of use of farmland is included in offsite costs (DTE 2015a). Because farmland interdiction applies to all crop categories, the cost for destruction of all crops will be included as long as the dose criterion is exceeded. Additionally, there is an implicit assumption that food doses will not increase over time. For the large areas of land modeled in the assessment, the NRC staff agrees that increases in crop doses would not be expected from a short-term release. The annual crop evaluation extends up to 8 years beyond the event. If the annual individual doses from ingestion of crops exceed the dose criterion throughout this time frame, the farmland is treated as condemned (DTE 2015a). If the dose criterion is not exceeded in one of the years evaluated, crop consumption is allowed in that year and in subsequent years, and population doses due to crop consumption are included in the assessment (DTE 2015a).

DTE estimated present dollar values based on the internal events PRA at Fermi 2 and applied a multiplication factor of 11 to account for external events, as described in Section F.2.2.2. As shown in Table D.1-35 of the ER, offsite economic and offsite exposure costs provided the greatest contributions to the total dollar value at approximately 55 and 35 percent, respectively (DTE 2014). Onsite cleanup and replacement power costs collectively contributed 11 or 10 percent to the total dollar value for real discount rates of 7 percent (baseline) or 3 percent (sensitivity), respectively. Onsite exposure costs contributed less than 1 percent. Section F.6 provides more detailed information on the cost-benefit calculation and its evaluation.

Applicable guidance in NUREG/BR-0184 (NRC 1997a) or the NEI 05-01 report (NEI 2005) does not require that the SAMA analysis include replacement power costs from an undamaged, operational unit being shut down for a prolonged period of time following a severe accident at another unit on the same site. Nevertheless, the NRC staff performed a scoping calculation to assess if the added costs from a prolonged shutdown of Fermi 3, which received a combined operating license in 2015 and could possibly be built and operate during the license renewal period for Fermi 2, would change the determination of cost-beneficial SAMAs for Fermi 2. In response to an NRC staff RAI, DTE indicated that 1,585 MWe would be a conservative value for the maximum net electrical power of Fermi 3 (DTE 2015c). The NRC staff assumed that the 10-year outage time for Fermi 3 would occur at the worst time from a replacement power cost perspective (i.e., timing of the 10-year outage results in the largest replacement power cost) and found that the additional replacement power costs from an extended outage at Fermi 3 following a severe accident at Fermi 2 would not change the selection of cost-beneficial SAMAs for Fermi 2.

Based on its review of DTEs submissions, the NRC staff concludes that DTEs methodology to estimate offsite consequences for Fermi 2 provides an acceptable basis to assess the risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the core damage frequencies, population doses, and offsite economic costs reported by DTE.

F-20

Appendix F F.3 Potential Plant Improvements The process for identifying potential plant improvements, an evaluation of that process, and the improvements evaluated in detail by DTE are discussed in this section.

F.3.1 Process for Identifying Potential Plant Improvements DTE identified potential plant improvements (SAMAs) by reviewing industry documents and considering other plant-specific enhancements not identified in the published industry documents. Industry documents reviewed included the following:

NEI 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document (NEI 2005);

Industry BWR SAMA analysis documentation discussing potential plant improvements:

FitzPatrick Nuclear Power Plant SAMA Analysis, Columbia Generating Station SAMA Analysis, Cooper Nuclear Station SAMA Analysis, Oyster Creek Nuclear Generating Station SAMA Analysis, Monticello Nuclear Generating Plant SAMA Analysis, Brunswick Steam Electric Plant SAMA Analysis, Pilgrim Nuclear Power Station SAMA Analysis, Susquehanna Steam Electric Station SAMA Analysis, Vermont Yankee Nuclear Station SAMA Analysis, Duane Arnold Energy Center SAMA Analysis, and Grand Gulf Nuclear Station SAMA Analysis;

The Fermi 2 IPE, Fermi 2 IPEEE reports, and their updates;

NUREG-1742, Perspectives Gained from the Individual Plant Examination of External Events (IPEEE) Program (NRC 2002); and

The Fermi 2 updated PRA model lists of risk significant contributors in Tables D.1-2 and D.1-5 of the ER (DTE 2014).

Based on this review DTE identified an initial set of 220 candidate SAMAs, referred to as Phase I SAMAs. In Phase I of the evaluation, DTE performed a qualitative screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the following criteria:

Not Applicable: If a proposed SAMA does not apply to the Fermi 2 design, it is not retained.

Already Implemented: If the SAMA or equivalent was previously implemented, it is not retained.

F-21

Appendix F

Combined with Another SAMA: If a SAMA is similar in nature and can be combined with another SAMA to develop a more comprehensive or plant-specific SAMA, only the combined SAMA is further evaluated.

Excessive Implementation Cost: If the estimated cost of implementation is greater than the MMACRSAMA, the SAMA cannot be cost beneficial and is screened from further analysis.

Very Low Benefit: If the SAMA is related to a non-risk significant system, which is known to have negligible impact on the risk profile, it is not retained.

Implementation in Progress: If plant improvements that address the intent of the SAMA are already in progress, it is not retained.

During this process, 141 SAMA candidates were screened out based on the criteria listed above. Table D.2-1 of the ER (DTE 2014) provides a description of each of the 79 Phase II SAMA candidates.

In Phase II, a detailed evaluation was performed for each of the 79 remaining SAMA candidates, as discussed in Sections F.4 and F.6 below. To account for the potential impact of external events, the estimated benefits based on internal events were multiplied by a factor of 11, as discussed in Section F.2.2.2.

F.3.2 Review of DTEs Process DTEs efforts to identify potential SAMAs focused primarily on areas associated with internal initiating events. The NRC staff reviewed the listing of Phase I candidate SAMAs as part of the October 2014 audit meeting at the Fermi site (NRC 2014c). The primary source of candidate SAMAs (146 of a total of 220) was the list of BWR SAMA candidates contained in NEI 05-01 (NEI 2005). The review of other SAMA analysis documentation led to identifying 48 additional candidate SAMAs. Review of the risk contribution to CDF and LERF from a risk reduction worth (RRW) perspective at Fermi 2 led to identifying 14 additional SAMAs, while review of the IPEEE lead to 12 additional SAMA candidates.

As discussed above, DTE initially identified 146 Phase I candidate SAMAs from the NEI 05-01 list of SAMA candidates. While the number of SAMA candidates resulting from the Fermi 2 PRA RRW review (14) appears rather low, the majority of the risk significant basic events in the RRW were assessed to be mitigated by the previously identified SAMA candidate.

In the ER, DTE provided a tabular listing of the Level 1 PRA basic events sorted according to their RRW (DTE 2014). These results were reviewed by DTE to identify those potential risk contributors that made a significant contribution to CDF. The RRW rankings were reviewed down to 1.005. Events below this point would influence the CDF by less than 0.5 percent and are judged to be highly unlikely contributors for the identification of cost-beneficial enhancements. These basic events, which include component failures, operator actions, and initiating events, were reviewed to determine if additional SAMA actions may need to be considered.

The NRC staff notes that a RRW of 1.005 corresponds to a MACR (including external events) of approximately $17,000 if it is assumed that a SAMA is 100 percent effective in eliminating the events contribution to CDF and that the total cost-risk is proportional to CDF. Even if uncertainty is included, as is discussed later, the value becomes approximately $42,000.

Because this potential benefit is less than the minimum cost for a simple procedure change of

$50,000, the NRC staff concludes that DTEs minimum RRW review threshold of 1.005 is acceptable for identifying potential cost-beneficial SAMAs.

F-22

Appendix F DTE also provided tabular listings of the Level 2 PRA basic events for the combined LERF categories in the ER. DTE used an RRW cutoff of 1.005 when reviewing these basic events for additional SAMA candidates. As indicated in Table F-2, the LERF release categories dominate the population dose and offsite economic cost risks.

In the NRC staffs review of these importance lists and the SAMAs identified by DTE, a number of concerns with DTEs assessments were documented in RAIs. The following list summarizes these concerns and DTEs responses (DTE 2015a).

SAMA 001 regarding the addition of DC power supplies is not a Phase II SAMA, as it was screened out on the basis of being already implemented per DTE addressing NRC Order 12-049 requirements with a FLEX (diverse and flexible coping capability) portable, DC generator. DTE clarified that FLEX includes a portable AC generator and that it would be used to supply the installed battery chargers and the combination would have the capacity to supply all necessary DC loads.

Relative to considering a SAMA to automate the starting of the mechanical draft cooling tower fan, DTE performed a cost-benefit assessment that indicated the maximum benefit would be $682,000, including external events and uncertainty.

Considering a cost of $2.4 million, such a SAMA would not be cost beneficial (DTE 2015b, 2015c).

In DTEs ER Table D.1-2, Correlation of Level 1 Risk Significant Terms to SAMAs, several internal flooding events relating to the failure of condenser circulating water inlet and outlet expansion joints were cited to be addressed through the External Surfaces Monitoring Program for external degradation and the Internal Surfaces Miscellaneous Piping and Ducting Components Programs for internal degradation (SAMA 129). These aging management programs are primarily visual inspections of the internal and external surfaces. DTE clarified that these license renewal programs will be fully implemented prior to the period of extended operation and that neither monitoring program is credited in the Fermi 2 PRA model. DTE also clarified that there is an existing preventive maintenance program to visually examine the condenser circulating water inlet and outlet expansion joints performed every other outage. Furthermore, DTE described the design features currently installed to detect, minimize, or mitigate the consequences of flooding due to an expansion joint failure, such as the sump alarms to detect flooding, pump switches to prevent overpressurization, and the prevention of water-hammer strategies. Thus, consideration of additional SAMAs is not warranted.

SAMA 031 cited to mitigate HPCI or RCIC failures during subsequent cycles, is said in one place in the ER to evaluate upgrading HPCI throttling capability to reduce the number of start/stops required. In another place, SAMA 031 is said to revise procedures to allow intermittent operations of HPCI and RCIC. DTE clarified that current operating procedures allow for cycling of the HPCI/RCIC (on at reactor water Level 2 and off at Level 8) before operators take manual control of the pumps to throttle flow and maintain RPV water at a constant level, thus preventing additional cycling. A SAMA to address these HPCI or RCIC basic events would involve revision to procedures and training to allow operators to take manual control of HPCI/RCIC earlier in the event to prevent cycling on and off of the pumps. The maximum benefit of eliminating these failures was determined to be $39,300, including uncertainty, which is less than the minimum cost for a procedure change; therefore, this SAMA is not cost beneficial.

F-23

Appendix F

SAMA 009 to reduce the DC dependence between high pressure injection and automatic depressurization system (ADS) is cited to mitigate failure of the turbine-driven HPCI pump to start. This SAMA would not mitigate the cited failure since the common cause failure of DC would not be included in this event. DTE agreed that SAMA 009 would not mitigate the cited failure and indicated that the maximum benefit, including uncertainty, of making a 40-percent reduction in the HPCI pump failure to start would be $12,500, which is less than the cost of potential SAMAs.

SAMA 101 to improve leak detection procedures, is cited for a number of internal flooding events. This SAMA was not included as a Phase II SAMA because the currently in-progress implementation of a risk informed in-service inspection program based on ASME Code Case N-716 (N-716) explicitly addresses internal flooding initiators for inclusion in the program for in-service inspection. N-716 includes risk-informed in-service criteria to provide a method of ensuring that any plant-specific piping locations that are important to safety are identified. Therefore, even though ASME Section XI does not include or require any non-destructive examination requirements for Safety Class 3 and non-nuclear safety class piping, N-716 would add such piping if it were determined to be high-safety significant based on the results of an internal flooding PRA. However, DTE indicated that based on the Fermi 2 PRA results, it is not likely that the important internal flooding initiators will meet the criteria for inclusion in the N-716 program, therefore a new SAMA was evaluated. This SAMA would be the implementation of an inspection program for the piping associated with the risk-significant internal flooding initiators. This change would be implemented by adding visual inspection of these pipes to the regular shift rounds procedure. The SAMA was evaluated by assuming the inspections would result in a 25-percent reduction in the initiating event frequency for these initiators.

The maximum benefit was determined to be $104,000, including external events and uncertainty. The cost of preparing the procedures and the labor to perform the inspections was estimated to be $209,000. Therefore, DTE concluded that this SAMA was not cost beneficial (DTE 2015b, 2015c).

Regarding the potential for a flood barrier to prevent flood propagation to adjacent flood areas through openings and/or failed flood doors, DTE performed some additional cost-benefit analyses as follows (DTE 2015a, 2015b, 2015c):

Installing a flood/watertight door between the auxiliary building and relay room would lead to a maximum benefit of $111,000, including external events and uncertainty. Subsequently, DTE concluded that such a SAMA would not be cost beneficial.

Making the turbine building to auxiliary building isolation door failure-proof (presently assumed to have a failure probability of 1x104) or adding barrier capability that would lead to a maximum benefit of $56,800, including external events and uncertainty. Subsequently, DTE concluded that such a SAMA would not be cost beneficial.

Adding a flood barrier or curb between the DC switchgear room and the Division 2 AC switchgear room would lead to a maximum benefit of $225,000, including external events and uncertainty. DTE noted that this benefit is from a revised base case that took some credit for operator isolation of the initiating pipe breaks compared to the normal base case in which no credit was conservatively taken for this action. Subsequently, DTE concluded that a SAMA to install such F-24

Appendix F a flood barrier or curb between DC switchgear room and the Division 2 AC switchgear room would be potentially cost beneficial.

The current Fermi 2 design and PRA is such that if the reactor building heating ventilation and air conditioning (HVAC) to standby gas treatment system isolation valve fails to close when the containment is vented to prevent overpressure, the HVAC duct may fail. There is then a pathway for steam and other releases to the third floor of the reactor building, which results in the potential for damage to important mitigation equipment. In the ER, DTE stated that the response to NRC Order EA-12-050 (NRC 2012c) is to include measures that would increase the likelihood of successful containment venting to prevent containment overpressure.

In response to an NRC staff RAI to clarify the impact of this order on the above situation, DTE noted that the NRC has rescinded Order EA-12-050 and replaced it with Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (NRC 2013), which establishes numerous functional requirements for a hardened containment venting system (HCVS). Development of a HCVS system, by modification of the existing system or installation of a new system, will result in a robust and reliable venting system and will also mitigate the valve and duct failure event. Specifically, compliance with the requirements to minimize unintended cross flow of vented fluids within a unit and to minimize the potential for hydrogen gas migration and ingress into the reactor building will prevent or significantly reduce the likelihood of this event because the flow path from the vent to the reactor building HVAC system will be reduced.

In response to an NRC staff RAI on how SAMAs from the 11 previous industry SAMA analyses were selected for incorporation into the Fermi 2 Phase I SAMA identification, DTE indicated that the review of industry SAMA analyses was focused on identifying SAMA candidates proved to be potentially cost beneficial for other plants. These SAMA candidates were then screened based on their applicability to the Fermi 2 plant design, if they had already been implemented, or if they were covered by a SAMA candidate already retained for a cost-benefit analysis. DTE noted that no potentially cost-beneficial SAMA candidates for other sites were screened from the Fermi 2 analysis based on excessive implementation costs (DTE 2015a).

As noted above, while no vulnerabilities were found in the IPE, several opportunities for enhancements were identified. The NRC staff SER on the IPE notes that the hard-piped containment venting was installed but indicates that several potential plant improvements were identified for further consideration. The NRC staff noted in an RAI that the status of these enhancements is not addressed in the ER and are not included in the Phase I list of candidate SAMAs. DTE responded by providing a summary description of the implementation of each of the IPE-identified enhancements and confirmed that they all have been implemented (DTE 2015a).

Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, together with those identified in response to NRC staff RAIs, addresses the major contributors to the internal events CDF.

As discussed in Section F.2.2.2, although the IPEEE did not identify any fundamental vulnerabilities or weaknesses related to external events, a number of outliers were identified from the IPEEE seismic assessment (DECo 1996). The IPEEE items in the Phase I list of candidate SAMAs include the six seismic outliers identified in Section F.2.2.2. As discussed above, DTEs actions in response to the 50.54(f) letter (NRC 2012a) that requested information F-25

Appendix F related to the Fukushima Daiichi NTTF recommendations, confirmed that all of these items have been addressed and are considered resolved (DTE 2012a).

DTEs review of the IPEEE fire analysis led to the development of six candidate SAMAs addressing the risk from the important fire CDF contributors listed in Table F-4. These candidate SAMAs were included in the Phase I (and Phase II) SAMA analysis.

As stated earlier, DTEs IPEEE analysis of other external hazards (high winds, tornadoes, external floods, and other external events) did not identify any opportunities for improvements for these events.

As discussed above, the NRC staff notes that the Fermi 2 external flooding design and capability was assessed in the engineering walkdowns and evaluations required for the response to the Fukushima Near-Term Task Forces Recommendation 2.3 (DTE 2012b; NRC 2012a). The NRC staff's SER on the walkdown (NRC 2014b) stated, The staff concludes that the licensee, through the implementation of the walkdown guidance activities and, in accordance with plant processes and procedures, verified the plant configuration with the current flooding licensing basis; addressed degraded, nonconforming, or unanalyzed flooding conditions; and verified the adequacy of monitoring and maintenance programs for protective features.

As discussed above, DTE eliminated numerous Phase I SAMA candidates from further consideration using a number of criteria. As part of the onsite audit (NRC 2014c), the NRC staff reviewed the documentation of this screening and asked DTE to provide additional information concerning the basis for eliminating certain Phase I SAMAs from further consideration. The additional information provided resolved all of the NRC staffs concerns, and no additional Phase II SAMAs were identified based on this review of the Phase I screening.

The NRC staff did note in an RAI that a Phase I SAMA to install a filtered containment vent to remove decay heat was combined with Phase II SAMA 123 for an ATWS sized filtered containment vent. Because a filtered vent to remove decay heat is considerably smaller than that required for an ATWS event, the evaluation of SAMA 123 does not appear to be valid for the decay heat sized SAMA. In response, DTE indicated that the cost of the SAMA 123 ATWS-sized filtered vent was a rough conceptual cost of $40 million, estimated in 2013 from an industry group discussion on a filtered vent. At that time, the cost was assumed to be in the range of $40 million to $50 million. DTE also noted in response to an NRC request that NEI submitted cost estimates for a filtered vent with a small filter and severe accident capable water makeup and for a large filter with severe accident capable water makeup. Neither filter was sized for an ATWS. The cost estimates provided were conceptual in nature. With contingency and subtracting the estimated $3.7 million cost of the water makeup, the estimated costs were

$31.7 million for the small filter and $51.2 million for the large filter. These cost estimates were based on incremental costs of filter installation relative to current conceptual designs planned for hardened containment vent in compliance with NRC Order EA-13-109. Given these estimates are for a vent that is not specifically sized for an ATWS, the cost is appropriate for the normal decay heat SAMA and is lower than what it would cost for an ATWS-sized vent. Even considering the cost for the smaller filter of $31.7 million, the normal decay heat SAMA is not cost beneficial (DTE 2015a).

The NRC staff questioned DTE about potentially lower cost alternatives to some of the SAMAs evaluated (NRC 2014a), including:

A SAMA to improve training specifically for basic event Operators fail to shutdown from outside the main control room instead of SAMA 145 regarding increased training and operating experience feedback to improve operator response, which is F-26

Appendix F much broader in scope. In response to the RAI, DTE noted, that with a risk reduction worth of 1.13, the risk significance of this basic event is well known and that this event is specific to flooding events that require abandonment of the main control room (MCR). An analysis was performed to determine the benefit from increased training specifically for this event assuming a 50-percent decrease in the failure probability to shut down from outside the MCR. The analysis resulted in a maximum assessed benefit of $71,200, including external events and uncertainty. Since a simple procedure change is not anticipated to result in significant improvement for this operator action, procedure changes with training would be required. Therefore, implementation of this SAMA would not be cost beneficial (DTE 2015a, 2015b, 2015c).

SAMAs including only leak detection as alternatives to SAMAs 213 and 214 (both of which involve providing leak detection and automatic isolation valves for emergency equipment cooling water (EECW) piping) might provide sufficient time for manual actions to isolate the flood source, thereby limiting the failures due to flooding, particularly in adjacent rooms. In response to the RAI, DTE provided a discussion of the flood scenarios in the DC switchgear room and the Division 2 switchgear room and the time associated with flood propagation into the adjacent rooms. DTE concluded that providing only leak detection might be cost beneficial. However, upon further investigation of the existing alarms on the systems associated with the flooding, the timing available to take action and the proximity of these rooms to the MCR, DTE concluded that revising existing alarm response procedures (ARPs) to direct operators to these rooms following indication of leakage in reactor building component cooling water (RBCCW)/EECW system piping could be a potentially cost-beneficial SAMA and will be retained for further evaluation (DTE 2015a).

The NRC staff notes that the set of SAMAs submitted is not all-inclusive, because additional, possibly even less expensive, alternatives can always be postulated. However, the NRC staff concludes that the benefits of any additional modifications are unlikely to exceed the benefits of the modifications evaluated and that the alternative improvements would not likely cost less than the least expensive alternatives evaluated, when the subsidiary costs associated with maintenance, procedures, and training are considered.

The NRC staff concludes that DTE used a systematic and comprehensive process for identifying potential plant improvements for Fermi 2, and that the set of potential plant improvements identified by DTE is reasonably comprehensive and, therefore, acceptable. This search included reviewing insights from the plant-specific risk studies and reviewing plant improvements considered in previous SAMA analyses. While explicit treatment of external events in the SAMA identification process was limited, the NRC staff determined that the prior implementation of plant modifications, the absence of external event vulnerabilities, and DTEs compliance with the approved alternative approach for addressing external events provide a reasonable justification to primarily examine the internal events risk results for the purpose of identifying SAMAs.

F.4 Risk Reduction Potential of Plant Improvements DTE evaluated the risk-reduction potential of the 79 SAMAs retained for the Phase II evaluation in the ER (DTE 2014). The SAMA evaluations were generally performed by DTE in a realistic or slightly conservative fashion that overestimates the benefit of the SAMA. In most cases, the failure likelihood with the added equipment is taken to be optimistically low, thereby overestimating the benefit of the SAMA. In other cases, it was assumed that the SAMA F-27

Appendix F eliminated all of the risk associated with the proposed enhancement. The NRC staff notes that this bounding approach overestimates the benefit and is conservative.

Except for SAMAs associated with internal fires, DTE used model requantification to determine the potential benefits for most of the SAMAs. Reductions to the CDF, population dose, and offsite economic cost were estimated using the Fermi 2 PRA model. Changes made to the model to quantify the impact of each SAMA are described in Section D.2.3 of the ER.

Table F-5 summarizes the assumptions used to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF, population dose, and offsite economic cost, and the estimated total benefit (present value) of the averted risk. The determination of the benefits for the various SAMAs is further discussed in Section F.6.

The NRC staff reviewed the assumptions used in evaluating the benefit or risk reduction estimate of each of the SAMAs as described in the ER Section D.2.3. The resolution of RAIs that resulted from this review follow.

For SAMA 023 regarding developing procedures to repair or replace failed 4-kV breakers, the benefit was estimated by eliminating failure of the operator to cross tie non-emergency buses, failure to recover AC power from plant and switchyard-centered events, as well as failure during operation of non-emergency 4.16-kV buses. In response to an NRC staff RAI concerning other 4-kV breaker failures that can be mitigated by this SAMA, DTE responded that this SAMA originated from a vulnerability identified in the IPE at another plant. Because this vulnerability does not exist at Fermi 2, DTE concluded that this SAMA should have been screened out in Phase I (DTE 2015a). In a further response, DTE evaluated the benefit of a 20-percent reduction in the failure probabilities for all breakers greater than 600 volts. The averted cost including external events and uncertainty was found to be $35,600; therefore, DTE concluded that this SAMA is not cost beneficial (DTE 2015b).

The title of SAMA 031, revise procedures to allow intermittent operations of HPCI and RCIC, is not consistent with the stated intent and basis of the evaluation of the SAMA to eliminate the intermittent operation of HPCI/ RCIC by allowing flow to be throttled, thus preventing intermittent starts and stops. In response to an NRC staff RAI to clarify the SAMA description and intent indicated that SAMA 031 apparently originated from a situation at two other BWRs where it was desirable to operate HPCI or RCIC in such a manner as to slow the rate of depressurization of the RPV, thereby maintaining the vessel at a higher pressure and extending the duration at which RPV pressure can support successful operation of HPCI/RCIC. DTE indicated that this situation does not exist at Fermi 2 and consequently SAMA 031 as defined in NEI 05-01 is not applicable to Fermi 2 (DTE 2015a). As discussed above in Section F.3.2, a new SAMA involving a procedure change aimed at reducing the number of HPCI/RCIC on/off cycles was not cost beneficial upon further evaluation.

For SAMA 074 to improve pneumatic components of safety relief valves (SRVs) and main steam isolation valves (MSIVs), the benefit was determined by eliminating the air dependency of these valves. In response to an NRC staff RAI on how this benefit models the improvement of the reliability of SRVs and MSIVs, DTE provided the results of an alternate evaluation that assumed the independent and common cause hardware (as well as AC and DC power to the valves) was improved by 15 percent. The result was a maximum benefit of $2,400, and DTE concluded that this SAMA was not cost beneficial (DTE 2015a). In addition, in response to an NRC staff RAI, DTE discussed the design and modeling features of Fermi 2 that led to this low benefit. The major factor was a high level of redundancy, particularly with respect to the SRVs.

This factor combined with a low frequency of serious demands results in a relatively low importance of valve failures (DTE 2015b).

F-28

Appendix F In an NRC staff RAI, DTE was asked to provide further information and justification for the modeling of the benefit of SAMA 078 to enable flooding of the drywell head seal including the expected containment failure location(s), why only Class II and IV large rupture sequences were considered and why the benefit is so small considering that Class IV (ATWS sequences) would be expected to make up a significant part of release category H/E, which is the major contributor to risk. DTE indicated that drywell head leakage, mitigated by this SAMA, is a dominant containment failure mode only for accident scenarios involving high and intermediate containment temperatures. Most of the Class II and Class IV sequences involve containment failure prior to core damage and therefore do not involve high or intermediate containment temperatures. DTE provided an alternative bounding evaluation of the benefit of this SAMA by assuming that the drywell never fails in the Level 2 analysis. This resulted in a maximum benefit of $244,000 including uncertainty. Compared to an estimated cost of $1 million (from the Vermont Yankee LRA), DTE concluded this SAMA is not cost beneficial (DTE 2015a).

In response to an NRC staff RAI concerning SAMA 154, to modify procedures to allow switching of the combustion turbines to buses while running, DTE stated that such procedures already exist and this SAMA should have been screened during Phase I (DTE 2015a).

The NRC staff in an RAI noted that while SAMAs 165 and 166 both address mitigating the failure of emergency core cooling system low pressure permissive with an order-of-magnitude improvement in the operator action to bypass the low pressure permissive resulted in a 3 percent reduction in CDF, the human error probability for this operator action does not appear in the Level 1 importance list. DTE responded that this human error basic event was mistakenly omitted from the Table D.1-2 importance list because it had a value of 1.0 and was assumed to be a flag event rather than representing an actual failure event.

DTE indicated that a search for other events omitted from the importance analyses tables for the same reason was performed. One additional Level 1 basic event was identified representing failure to terminate the flood from EECW in an AB3 switchgear room. A new SAMA evaluation was performed for this event to evaluate the potential improvement from crediting a new procedure for manually closing the valves that isolates the flood. The probability of the event was changed from 1.0 to 0.1 resulting in a maximum benefit of $302,000 including external events and uncertainty. Based on this result, DTE concluded that this SAMA would be potentially cost beneficial even when assuming a cost in the high range for procedures (e.g., $200,000) (DTE 2015a, 2015b, 2015c).

F-29

Table F-5. SAMA Cost/Benefit Screening Analysis for Fermi 2 Station(a)

% Risk Reduction Total Benefit ($)(b)

Larger Appendix F Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity 009 - Reduce direct current dependence between 1 <1 <1 6K 14K 100K high-pressure injection systems and ADS Assumption: HPCI uses Division 2 direct current power while automatic depressurization system (ADS) valves are powered by Division 1; therefore, the intent of this SAMA is met with the current design. However, to assess the benefit from eliminating the direct current dependence of ADS, failure of the Division 1 130V direct current batteries was eliminated.

012 - Improve 4.16-kV bus cross-tie ability 5 2 2 79K 200K 656K Assumption: Improving the ability to cross-tie the 4.16-kV busses would increase the availability of onsite alternating current power. To assess the potential benefit, the existing cross-ties between the Division 1 and Division 2 engineered safety feature (ESF) buses are assumed to never fail.

014 - Install an additional, buried off-site power source 5 8 13 345K 863K >1M F-30 Assumption: Installing an additional, buried offsite power source, or burying offsite power lines would decrease the probability of LOOP due to weather-related events. To assess the potential benefit, a bounding analysis was performed by eliminating all weather-related LOOP and partial LOOP events.

016 - Install tornado protection on gas turbine 3 5 9 245K 612K 2.1M generator Assumption: Installing tornado protection on the gas turbine generator would eliminate or reduce weather-related failures of the CTG. A bounding analysis was performed by eliminating all weather-induced failures of the CTG.

018 - Improve uninterruptible power supplies <0.1 <1 <1 8K 21K 100K Assumption: Improving the reliability of uninterruptible power supplies would reduce the frequency of loss of power to essential plant instruments. A bounding analysis was performed by eliminating the failure of the modular power units, which provide the uninterruptible power supply to essential plant instruments.

021 - Use fire water system as a backup source for 4 6 9 257K(d) 642K(d) 2M diesel cooling Assumption: This analysis was used to evaluate the change in plant risk from improving the reliability of diesel cooling by adding a backup source of cooling. The analysis was performed by assuming that the diesel driven fire pump would be manually aligned to provide backup diesel cooling. The manual action was given a failure probability of 0.1. The benefit of adding an entirely new source of diesel cooling would be comparable to that of using the fire water system, but the cost of implementation would be much higher.

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity 023 - Develop procedures to repair or replace failed

<0.1 <1 <1 8K 20K 50K 4-kV breakers(c)

Assumption: Developing procedures to repair or replace failed 4 kV breakers would increase the probability of recovery from failure of breakers that transfer 4.16 kV non-emergency buses from unit station transformers. An analysis was performed by eliminating failure of the operator to cross-tie non-emergency buses, failure to recover alternating current power from plant and switchyard centered events, as well as, failure during operation of non-emergency 4.16 kV buses.

024 - In training, emphasize steps in recovery of offsite

<1 <0.1 <1 6K(d) 16K(d) 50K power after an SBO Assumption: Increased training with emphasis on recovery could reduce the human error in steps to recover offsite power after an SBO.

Because enhanced training is not likely to improve the ability to recover offsite power from grid and severe weather-related events, this evaluation assumed that only the probability to recover offsite power after plant centered and switchyard centered events would be impacted.

The analysis assumed a 25-percent improvement in recovery of offsite power for Level 1 events (i.e., 30-minute, 4- and 12-hour recovery). The common failure to respond to SBO was also eliminated.

F-31 026 - Bury offsite power lines 5 8 13 345K 863K >1M Assumption: Installing an additional, buried offsite power source, or burying offsite power lines would decrease the probability of LOOP due to weather-related events. To assess the potential benefit, a bounding analysis was performed by eliminating all weather-related LOOP and partial LOOP events.

028 - Provide an additional high pressure injection 28 6 6 288K 719K 1M pump with independent diesel Assumption: Installing an additional high pressure injection pump with an independent diesel would reduce the frequency of core melt from small LOCA and SBO sequences. To assess the change in plant risk from installing an additional high pressure injection pump, the analysis was performed by eliminating failures of the existing standby feedwater pumps to provide sufficient flow, which includes power dependencies. The analysis also conservatively eliminated standby feedwater failures induced from failure of balance-of-plant batteries.

029 - Raise HPCI/RCIC backpressure trip set points 2 <0.1 <0.1 10K 25K 50K Assumption: Raising the HPCI and RCIC backpressure trip set points would increase the system availability when the suppression pool temperature is high. To assess the change in plant risk, the HPCI and RCIC turbine trip and automatic turbine isolation due to high or instable exhaust pressure were eliminated.

031 - Revise procedure to allow intermittent operations 3 <1 <1 16K 39K 50K of HPCI and RCIC(c)

Appendix F

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose Appendix F External) with Sensitivity Assumption: This analysis was used to evaluate the change in plant risk from increasing the throttling ability of HPCI and RCIC pumps to limit the number of system stops/restarts. The analysis was performed by eliminating the failure of both HPCI and RCIC during subsequent cycles.

034 - Modify automatic depressurization system

<0.1 <0.1 <0.1 <1K <1K 100K components to improve reliability Assumption: Modifying automatic depressurization system components to improve their reliability would reduce the frequency of high pressure core damage sequences. To assess the change in plant risk for this SAMA, analysis was performed by eliminating the failure to open on demand of all safety relief valves (SRVs), both ADS and non-ADS SRVs.

041 - Provide capability for alternate injection via

<1 <1 <1 6K 15K 50K reactor water cleanup Assumption: This analysis was used to evaluate the change in plant risk from improving injection capability through either the diesel-driven fire pump or reactor water cleanup. The analysis was performed by assuming that the diesel fire pump never failed (for injection and all other modeled functions), as well as assuming that the flowpath for RPV injection via the diesel fire pump never failed.

F-32 046 - Improve ECCS suction strainers 2 2 2 73K 183K >2M Assumption: This analysis was used to evaluate the change in plant risk from improving the reliability of the ECCS suction strainers. A bounding analysis was performed by eliminating all plugging of the ECCS suction strainers.

050 - Change procedures to allow cross connection of

<1 <1 <1 13K(d) 33K(d) 50K motor cooling for RHRSW pumps Assumption: This analysis was used to evaluate the change in plant risk from revising procedures to increase the availability of RHRSW water by allowing cross connection of motor cooling for the RHRSW pumps. A bounding analysis was performed by eliminating all failures of both Division 1 and Division 2 RHRSW pumps.

051 - Add redundant direct current control power for

<0.1 <0.1 <0.1 1K 3K 100K service water pumps Assumption: Adding redundant direct current control power for service water pumps would increase the availability of service water. To analyze the change in plant risk, it was assumed that long-term power to the RHRSW pumps where battery chargers are required never fails.

053 - Provide self-cooled ECCS seals 3 6 10 264K 661K 675K Assumption: Providing self-cooled ECCS seals would eliminate the dependency of ECCS on the component cooling system. Because the core spray pumps are the only ECCS pumps that require pump cooling for the probabilistic risk assessment mission time, a bounding analysis was performed by eliminating the failure of core spray pump cooling.

054 - Enhance procedural guidance for use of

<1 <0.1 <0.1 3K(d) 8K(d) 50K cross-tied component cooling or service water pumps

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity Assumption: Enhancing procedural guidance for use of cross-tied component cooling or service water pumps would reduce the frequency of the loss of these systems. An analysis was performed by allowing cross-connection of Division 1 and 2 emergency equipment cooling/service water.

Additionally, the analysis also eliminated all hardware failure initiating events of the general service water.

055 - Implement modifications to allow manual alignment of the fire water system to RHR heat <1 <0.1 <0.1 2K 5K 100K exchangers Assumption: Implementing modifications to allow manual alignment of the fire water system to RHR heat exchangers would improve the ability to cool the RHR heat exchangers. To evaluate the change in plant risk, the fire water system was modeled as an additional train for both Division 1 and Division 2 RHR complex.

067 - Enhance procedure to trip unneeded RHR or

<1 <0.1 <0.1 1K(d) 3K(d) 50K core spray pumps on loss of room ventilation F-33 Assumption: This analysis was used to evaluate the change in plant risk from extending the availability of the RHR or core spray pumps due to reduction in room heat load. To evaluate the change in plant risk, probability of failure of the crew to limit the number of operating RHR pumps was decreased by an order of magnitude to simulate enhanced procedures.

068 - Stage backup fans in switchgear rooms <0.1 <0.1 <0.1 <1K <1K 50K Assumption: Room cooling is not required for alternating current power switchgear rooms. However, Division 2 ESF direct current battery charger room does require cooling or ventilation. An operator action currently exists to open a door per procedure in case room cooling is lost.

The analysis performed decreased the failure probability of this operator action by two orders of magnitude.

071 - Modify procedure to provide ability to align diesel

<0.1 <0.1 <0.1 <1K 2K 50K power to more air compressors Assumption: Providing the ability to align diesel power to more air compressors would increase the availability of instrument air after a LOOP event. To evaluate the change in plant risk from providing diesel power to the air compressors, all power dependencies of the air compressors were removed.

072 - Replace service and instrument air compressors with more reliable compressors that have 2 3 3 100K 249K 433K self-contained air cooling by shaft driven fans Appendix F

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose Appendix F External) with Sensitivity Assumption: Replacing the service and instrument air compressors could eliminate the instrument air system dependence on component cooling water. Providing an additional portable compressor to be aligned to the supply header would reduce the risk associated with loss of instrument air. A bounding analysis was performed by eliminating the failure of air supply from both divisions of the noninterruptible air supply, as well as failure of the station air compressors.

074 - Improve SRV and MSIV pneumatic

<0.1 <0.1 <0.1 <1K 2K 100K components(c)

Assumption: This analysis was used to evaluate the change in plant risk from modifications to improve the reliability of SRVs and MSIVs. A bounding analysis was performed by eliminating the air dependency of MSIV components and the Division 1 SRVs (which includes all ADS valves).

077 - Cross-tie open cycle cooling system to enhance

<0.1 <0.1 <1 3K 7K 100K drywell spray system Assumption: This analysis was used to evaluate the change in plant risk from modifications to cross-tie the RHRSW system to increase the F-34 availability of containment heat removal. A bounding analysis was performed by eliminating the failure of both drywell spray loops.

078 - Enable flooding of the drywell head seal(c) <0.1 <1 <1 9K(d) 22K(d) 100K Assumption: Enabling flooding of the drywell head seal would reduce the probability of leakage through the seal. To evaluate the change in plant risk, it was assumed that flooding the drywell head seal would eliminate all Class II or Class IV accident sequences with large drywell failures.

083 - Enhance procedure to maintain ECCS suction

<0.1 <0.1 <0.1 <1K <1K 50K on condensate storage tank as long as possible Assumption: Maintaining ECCS suction on the condensate storage tank as long as possible would reduce the chance of pump failure due to high suppression pool temperature. A bounding analysis was performed by assuming that the condensate storage tank was always available for long-term makeup for HPCI and RCIC.

091 - Improve vacuum breaker reliability by installing

<1 2 2 53K 133K 500K redundant valves in each line Assumption: Installing redundant valves in each line would improve vacuum breaker reliability and decrease the consequences of a vacuum breaker failure to reseat. To evaluate the change in plant risk, a bounding analysis was performed by eliminating random vacuum breaker failures, tailpipe vacuum breakers sticking open, as well as common cause failure of vacuum breakers.

093 - Provide post-accident containment inerting

<0.1 3 3 96K 240K 1.6M capability

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity Assumption: Providing post-accident containment inerting capability, or installing a passive hydrogen control system would reduce the likelihood of hydrogen and carbon monoxide gas combustion. To evaluate the change in plant risk, a bounding analysis was performed by eliminating all hydrogen deflagrations that results in containment or drywell failure.

100- Institute simulator training for severe accident 9 8 10 310K 774K 8M scenarios Assumption: This analysis was used to evaluate the change in plant risk from increasing training to improve the success probability for important operator actions. The change in plant risk was evaluated by decreasing the likelihood of failure for important human actions by 10 percent. The operator actions with a risk reduction worth of greater than 1.005 were improved by 10 percent.

103 - Install a passive hydrogen control system <0.1 3 3 96K 240K 760K Assumption: Providing post-accident containment inerting capability, or installing a passive hydrogen control system would reduce the likelihood of hydrogen and carbon monoxide gas combustion. To evaluate the change in plant risk, a bounding analysis was performed by eliminating all hydrogen deflagrations that results in containment or drywell failure.

F-35 107 - Increase leak testing of valves in ISLOCA paths <1 6 3 119K 297K 2.3M Assumption: This analysis was used to evaluate the change in plant risk from reducing the frequency of ISLOCA events, and improving operators ability to cope with ISLOCAs. To assess this potential benefit, the frequency of all ISLOCA-initiating events was decreased by 25 percent.

108 - Improve MSIV design <1 <1 <1 12K 29K 100K Assumption: Improving the MSIV design would decrease the likelihood of containment bypass scenarios. To assess this potential benefit, failure of the inboard and outboard MSIV to close (including common cause) was eliminated. Additionally, hardware failures associated with the MSIV failing to remain open, MSIV pneumatics support failures, and random MSIV closures were all eliminated from the model.

112 - Revise emergency operating procedures to

<1 6 3 119K 297K 200K improve ISLOCA identification Assumption: This analysis was used to evaluate the change in plant risk from reducing the frequency of ISLOCA events, and improving operators ability to cope with ISLOCAs. To assess this potential benefit, the frequency of all ISLOCA-initiating events was decreased by 25 percent.

113 - Improve operator training on ISLOCA coping <1 6 3 119K 297K 200K Assumption: This analysis was used to evaluate the change in plant risk from reducing the frequency of ISLOCA events, and improving operators ability to cope with ISLOCAs. To assess this potential benefit, the frequency of all ISLOCA-initiating events was decreased by 25 percent. Appendix F

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose Appendix F External) with Sensitivity 115 - Revise procedures to control vessel injection to prevent boron loss or dilution following standby 2 4 4 122K 304K 200K liquid control injection Assumption: This analysis was used to evaluate the change in plant risk from controlling vessel injection to ensure adequate boron concentration is maintained in the core following an ATWS. To determine the benefit from revising procedures to improve control of vessel injection, the failure probability of the human actions control level early during an ATWS sequence and to control level late during an ATWS sequence were each improved by 10 percent.

117 - Increase boron concentration in the standby 1 1 1 43K 108K 400K liquid control system Assumption: This analysis was used to evaluate the change in plant risk from increasing the boron concentration in the standby liquid control system, which would reduce the time required to achieve shutdown concentration. To assess the benefit, the failure probability of the human actions to initiate the standby liquid system, both early and late, were each improved by 25 percent.

F-36 121 - Increase SRV reseat reliability <1 1 1 35K 89K 100K Assumption: Increasing the reseat reliability of SRVs will reduce the risk of boron dilution due to SRV failure to reseat after standby liquid control injection. A bounding analysis was performed by eliminating all stuck open relief valve and inadvertent open relief valve events.

123 - Install an ATWS-sized filtered containment vent

<1 35 38 1.1M(d) 2.8M(d) 40M to remove decay heat Assumption: To evaluate the change in plant risk from installing an ATWS-sized filtered containment vent, an analysis was performed decreasing the concentration of all radionuclides, excluding noble gases, by 50 percent. Because no modifications were made to the Level 1 or Level 2 probabilistic risk assessment model, there was no change in CDF or release category frequency. The averted cost risk was calculated by comparing the base MMACRBaseline to the MMACRSAMA using a 50 percent reduction in radionuclide concentrations.

141 - Install digital large break LOCA protection 1 2 2 68K 169K >2M system Assumption: This analysis was used to evaluate the change in plant risk from installing digital large break LOCA (leak-before-break) protection system. The analysis was performed by eliminating all large LOCA-initiating events.

145 - Increase training and operating experience 9 8 10 310K(d) 774K(d) 1M feedback to improve operator response Assumption: This analysis was used to evaluate the change in plant risk from increasing training to improve the success probability for important operator actions. The change in plant risk was evaluated by decreasing the likelihood of failure for important human actions by 10 percent. The operator actions with a risk reduction worth of greater than 1.005 were improved by 10 percent.

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity 149 - Provide a portable EDG fuel oil transfer pump:

This SAMA provides additional means of supplying the

<0.1 <0.1 <0.1 <1K <1K 50K EDG day tank in the event a common cause failure prevents operation of the existing pumps Assumption: This analysis was used to evaluate the change in plant risk from eliminating the dependency of EDGs on diesel fuel oil. A bounding analysis was performed by eliminating all failures of the fuel oil support system for each EDG.

151 - Provide a diverse swing diesel generator air start 1 <1 <1 21K 51K 100K compressor Assumption: This analysis was used to evaluate the change in plant risk from installing a diverse swing diesel generator air start compressor. A bounding analysis was performed by eliminating all fails to start events, including common cause, from each diesel generator.

152 - Proceduralize all potential 4-kV AC bus cross-tie 1 1 1 25K(d) 63K(d) 100K actions F-37 Assumption: Proceduralizing all potential 4 kV AC bus cross-tie actions would improve the availability of the 4 kV power system. An analysis was performed by assuming a 50 percent improvement for operator actions to align 4 kV AC cross-ties.

154 - Modify procedures to allow switching of the

<1 <1 <1 7K 17K 50K combustion turbines to buses while running Assumption: This analysis was used to evaluate the change in plant risk from increasing the availability of onsite AC power by allowing switching of the combustion turbines to buses while running. A bounding analysis was performed by eliminating all failures during operation of the CTGs, including the startup diesel generator. Additionally, failures of the CTGs transformers during operation were also eliminated.

155 - Protect transformers from failure 4 4 5 146K 366K 780K Assumption: This analysis was used to evaluate the change in plant risk from reducing the LOOP frequency by protecting transformers from failure. The analysis was performed by decreasing initiating event frequencies for the LOOP by two orders of magnitude.

165 - Modify procedures to defeat the low reactor pressure interlock circuitry that inhibits opening the LPCI or core spray injection valves following sensor or 3 <1 1 26K 64K 100K logic failures that prevent all low pressure injection valves from opening Assumption: This analysis was used to evaluate the change in plant risk from eliminating the probability of ECCS low pressure permissive failing. An analysis was performed by improving the operator action to bypass the low pressure permissive by an order of magnitude. Appendix F

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose Appendix F External) with Sensitivity 166 - Install a bypass switch to allow operators to bypass the low reactor pressure interlock circuitry that inhibits opening the LPCI or core spray injection valves 3 <1 1 26K 64K 100K following sensor or logic failures that prevent all low pressure injection valves from opening Assumption: This analysis was used to evaluate the change in plant risk from eliminating the probability of ECCS low pressure permissive failing. An analysis was performed by improving the operator action to bypass the low pressure permissive by an order of magnitude.

167 - Improve training on alternate injection via the fire water system, increasing the availability of alternate <1 <1 <1 6K 15K 50K injection Assumption: This analysis was used to evaluate the change in plant risk from improving injection capability through either the diesel-driven fire F-38 pump or reactor water cleanup. The analysis was performed by assuming that the diesel fire pump never failed (for injection and all other modeled functions), as well as assuming that the flowpath for RPV injection via the diesel fire pump never failed.

169 - Revise procedures to allow the ability to cross-connect the circulating water pumps and the service water going to the turbine equipment cooling 1 1 1 22K 56K 100K system heat exchangers, allowing continued use of the power conversion system after service water is lost Assumption: This analysis was used to evaluate the change in plant risk from continued use of the power conversion system after service water is lost. The analysis was performed by eliminating failures of the turbine building closed cooling water, which includes failure of service water, the turbine building closed cooling water heat exchangers, and LOOP.

175 - Operator procedure revisions to provide additional space cooling to the EDG room via the use 3 1 2 61K 154K 200K of portable equipment Assumption: This analysis was used to evaluate the change in plant risk from revising procedures to provide additional cooling/ventilation to the EDG rooms via opening doors or through the use of portable equipment. The analysis was performed by adding an operator action to provide temporary ventilation to the EDGs.

176 - Develop a procedure to open the door to the 3 1 2 61K 154K 200K EDG buildings upon the high temperature alarm

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity Assumption: This analysis was used to evaluate the change in plant risk from revising procedures to provide additional cooling/ventilation to the EDG rooms via opening doors or through the use of portable equipment. The analysis was performed by adding an operator action to provide temporary ventilation to the EDGs.

177 - Provide an alternate means of supplying the instrument air header: This SAMA involves procurement of an additional portable compressor to 2 3 3 99K(d) 249K(d) 489K be aligned to the supply header to reduce the risk associated with loss of instrument air Assumption: Replacing the service and instrument air compressors could eliminate the instrument air system dependence on component cooling water. Providing an additional portable compressor to be aligned to the supply header would reduce the risk associated with loss of instrument air. A bounding analysis was performed by eliminating the failure of air supply from both divisions of the noninterruptible air supply, as well as failure of the station air compressors.

183 - Improve alternate shutdown panel(c) 1 1 1 30K 76K 790K F-39 Assumption: Installing additional transfer and isolation switches would reduce the number of spurious actuations during a fire. Upgrading the alternate shutdown panel would increase the ability to shut down the plant from outside the MCR. This SAMA was evaluated by assuming that the additional train will reduce the conditional core damage probability of operation from the alternate shutdown panel by a factor of 10.

187 - Upgrade the alternate shutdown panel to include 1 1 1 30K 76K 790K additional system controls for opposite division(c)

Assumption: Installing additional transfer and isolation switches would reduce the number of spurious actuations during a fire. Upgrading the alternate shutdown panel would increase the ability to shut down the plant from outside the MCR. This SAMA was evaluated by assuming that the additional train will reduce the conditional core damage probability of operation from the alternate shutdown panel by a factor of 10.

188 - Increase fire pump house building integrity to withstand higher winds so that the fire system would <1 <1 <1 7K 18K 100K be capable of withstanding a severe weather event Assumption: This analysis was used to evaluate the change in plant risk from increasing the ability of the building containing the electric and diesel driven fire pump to withstand higher winds. A bounding analysis was performed by eliminating all failures of both the electric and diesel driven fire pumps to perform their functions (condensate storage tank makeup and RPV injection).

190 - Implement insights from trip and shutdown risk modeling into plant activities, decreasing the 4 5 6 189K 471K 500K probability of trips/shutdown Appendix F

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose Appendix F External) with Sensitivity Assumption: This analysis was used to evaluate the change in plant risk from decreasing the probability of trip/shutdown risk. The analysis was performed by decreasing manual shutdown, loss of condenser vacuum and turbine trip with bypass initiating event frequencies by 20 percent.

194 - Provide ability to maintain suppression pool 1 1 1 29K(d) 72K(d) 100K temperature lower (especially during summer months)

Assumption: This analysis was used to evaluate the change in plant risk from improving the ability to maintain the suppression pool temperature lower. To estimate the change in plant risk, the events representing insufficient flow from RHR heat exchangers, inadequate flow from check valve to RHR complex, heat exchanger unavailable due to maintenance, and misalignment of RHRSW Division 1 were eliminated. Lowering the initial temperature of the suppression pool may give operators enough extra time to restore RHRSW before the limits are reached, especially if the system is down for maintenance or is misaligned.

195 - Improve reliability of control rod drive mechanical 1 2 2 77K 193K >1M components Assumption: This analysis was used to evaluate the change in plant risk from reducing ATWS frequency by improving the reliability of control rod F-40 drive mechanical components. The analysis was performed by decreasing the failure probability of the control rod drive hydraulic components by 10 percent.

196 - Provide redundant HPCI auxiliary oil pump or 1 <0.1 <0.1 5K 12K 100K backup motive force for HPCI valves Assumption: This analysis was used to evaluate the change in plant risk from reducing the failure risk of the auxiliary oil pump used to provide the hydraulic force to operate the HPCI turbine valves. The analysis was performed by excluding the failure to start of the HPCI auxiliary oil pump.

197 - Upgrade flood barrier between direct current switchgear room and Division 2 alternating current 1 3 3 90K 224K 419K switchgear room Assumption: This analysis was used to evaluate the change in plant risk from physical upgrades to the doors between the direct current switchgear room and the Division 2 alternating current switchgear room to prevent flooding in one room from propagating to the other room. The analysis was performed by assuming that flooding in one room could not propagate to the other.

198 - Provide automatic method of refilling the 3 2 2 72K 179K 200K condensate storage tank Assumption: This analysis was used to evaluate the change in plant risk from physical upgrades to provide an automatic method of refilling the condensate storage tank. The analysis was performed by excluding the condensate storage tank failures caused by an initial low level or an operator failure to refill the condensate storage tank.

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity 199 - Increase surveillance of small break LOCA 1 <1 <1 15K 39K 50K initiators Assumption: This analysis was used to evaluate the change in plant risk from additional monitoring of piping and components that could cause a small break LOCA if failed. The analysis was performed by assuming that increased surveillance would result in a 25 percent decrease in initiating events for small break LOCAs.

200 - Improve capability of general service water 2 2 2 65K 163K 1M pumps to operate during summer months Assumption: This analysis was used to evaluate the change in plant risk from increasing successful operation of general service water pumps during summer months. A bounding analysis was performed by assuming that the general service water pumps never failed during summer months.

201 - Install redundant high water level trip for RCIC 2 <0.1 <0.1 11K 27K 100K Assumption: This analysis was used to evaluate the change in plant risk from adding a redundant Level 8 trip device for RCIC. The analysis F-41 was performed by eliminating the failure of the RCIC Level 8 Trip.

202 - Replace or upgrade reactor building closed 1 1 1 37K 92K 100K cooling water pressure control valve Assumption: This analysis was used to evaluate the change in plant risk from improving the reliability of the reactor building closed cooling water system by replacing or upgrading the reactor building closed cooling water pressure control valve. The analysis was performed by decreasing the initiating event frequency by two orders of magnitude for the loss of reactor building closed cooling water.

203 - Improve EDG maintenance procedures to 1 <1 <1 16K 41K 50K decrease unavailability time Assumption: This analysis was used to evaluate the change in plant risk from improving EDG maintenance procedures to decrease the time in which they are unavailable due to maintenance. The analysis was performed by assuming that improved procedures would decrease the unavailability due to maintenance for all EDGs by 50 percent, including times when multiple EDGs are unavailable.

204 - Improve test and maintenance procedures on standby feedwater pumps to decrease their <1 <1 <1 8K 21K 50K unavailability time Assumption: This analysis was used to evaluate the change in plant risk from improving standby feedwater pump test and maintenance procedures to decrease the time in which standby feedwater is unavailable due to maintenance. The analysis was performed by assuming that improved procedures would decrease the unavailability due to test and maintenance for the standby feedwater pump by 50 percent.

Appendix F

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose Appendix F External) with Sensitivity 205 - Improve test and maintenance procedures on 2 <0.1 <1 9K 23K 50K HPCI pump/turbine to decrease unavailability time Assumption: This analysis was used to evaluate the change in plant risk from improving HPCI pump/turbine test and maintenance procedures to decrease the time in which HPCI is unavailable due to maintenance. The analysis was performed by assuming that improved procedures would decrease the unavailability due to test and maintenance for HPCI by 50 percent.

206 - Improve the ability of operators to manually close a damper to isolate the third floor of the 13 13 13 438K 1.1M 100K reactor building from hardened vent path Assumption: During the IPEEE, it was determined that the human action to manually close a damper to isolate the third floor of the reactor building from the hardened vent path when the non-interruptible air supply had failed was not feasible. Even though the failure is not associated with fire, it accounts for 1.55x10-6 per year of the Control Room and 6.09x10-7 per year of the northeast quadrant of the Reactor Building fire CDF in the modified Fermi fire assessment results. A backup air bottle supply and local control for this damper would allow this action to be performed.

F-42 207 - Add incipient fire detection and suppression to 8 8 8 270K 674K 1.1M selected cabinets in the Division 1 switchgear room Assumption: Four components in the Division 1 Switchgear Room (04ABN) account for approximately 66% of the fire CDF in the room. These components are the 480V 72C Bus/Transformer, 480V 72B Bus/Transformer, 4160V 64C Bus and the 4160V 64B Bus. The addition of incipient fire detection and automatic actuation systems for these components will reduce the CDF of these fires significantly. To determine the impact of this modification, the assumption is made that the detection/auto suppression system has a failure probability of 0.05. It is also assumed that the CCDP for a fire with successful suppression is equal to the CCDP associated with a non-severe fire. Non-severe fires will not propagate to other equipment in the room, while severe fires will result in failure of all equipment in the room. Therefore, the severe fire scenarios for these components are revised from one scenario to two scenarios: one with successful suppression and one with failed suppression. With this modification, the fire CDF is reduced by 1.36x106 per year. This reduction in fire CDF was applied proportionately to each release category.

208 - Add incipient fire detection and suppression to 5 5 5 169K 422K 790K selected cabinets in the Relay room

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity Assumption: Three panels in the Relay room (03AB) account for approximately 70 percent of the fire CDF in the room. These components are P620, P613, and P622. The addition of incipient fire detection and automatic actuation systems for these components will reduce the CDF of these fires significantly. To determine the impact of this modification, the assumption is made that the detection/auto suppression system has a failure probability of 0.05. It is also assumed that the conditional core damage probability for a fire with successful suppression is reduced by an order of magnitude compared to the original conditional core damage probability. Therefore, the original fire scenarios for these components are revised from one scenario to two scenarios; one with successful suppression and one with failed suppression. With this modification, the fire CDF is reduced by 8.3x107 per year. This reduction in fire CDF was applied proportionately to each release category.

209 - Add incipient fire detection and suppression to 5 5 5 179K 447K 1.1M selected cabinets in the Division 2 switchgear room Assumption: Five components in the Division 2 switchgear room (12AB) account for approximately 76 percent of the fire CDF in the room.

These components are the 480V 72F Bus/Transformer, 480V 72E Bus/Transformer, 4160V 65F Bus, 4160V 65E Bus, and the 4160V 65G Bus.

The addition of incipient fire detection and auto actuation systems for these components will reduce the CDF of these fires significantly. To determine the impact of this modification, the assumption is made that the detection/auto suppression system has a failure probability of 0.05. It F-43 is also assumed that the conditional core damage probability for a fire with successful suppression is equal to the conditional core damage probability associated with a non-severe fire. Non-severe fires will not propagate to other equipment in the room, while severe fires will result in failure of all equipment in the room. Therefore, the severe fire scenarios for these components are revised from one scenario to two scenarios; one with successful suppression and one with failed suppression. With this modification, the fire CDF is reduced by 8.74x107 per year. This reduction in fire CDF was applied proportionately to each release category.

210 - Add incipient fire detection and suppression to selected cabinets in the Division 1 portion of the 3 3 3 98K 245K 375K Miscellaneous room Assumption: Three cabinets in the Division 1 portion of the Miscellaneous room (11ABE) account for approximately 60 percent of the fire CDF in the room. These cabinets are MCC 2PA-1, MCC 2PB-1, and Cabinet 2PA-2. The addition of incipient fire detection and automatic actuation systems for these cabinets will reduce the CDF of these fires significantly. To determine the impact of this modification, the assumption is made that the detection/auto suppression system has a failure probability of 0.05. It is also assumed that the conditional core damage probability for a fire with successful suppression is reduced by an order of magnitude compared to the original conditional core damage probability. Therefore, the original fire scenarios for these components are revised from one scenario to two scenarios: one with successful suppression and one with failed suppression. With this modification, the fire CDF is reduced by 4.85x107 per year. This reduction in fire CDF was applied proportionately to each release category.

211 - Add incipient fire detection and suppression to selected cabinets on the second floor of the Reactor 1 1 1 44K 110K 375K Appendix F Building (RB06)

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose Appendix F External) with Sensitivity Assumption: Three cabinets on the second floor of the Reactor Building (RB06) account for approximately 50 percent of the fire CDF in the room. These cabinets are R1600S003J, H2100P627, and R1600S003D. The addition of incipient fire detection and auto actuation systems for these cabinets will reduce the CDF of these fires significantly. To determine the impact of this modification, the assumption is made that the detection/auto suppression system has a failure probability of 0.05. It is also assumed that the conditional core damage probability for a fire with successful suppression is reduced by an order of magnitude compared to the original conditional core damage probability. Therefore, the original fire scenarios for these components are revised from one scenario to two scenarios; one with successful suppression and one with failed suppression. With this modification, the fire CDF is reduced by 2.09x107 per year. This reduction in fire CDF was applied proportionately to each release category.

212 - Diversify standby liquid control explosive valve 2 6 7 76K 189K 370K operation Assumption: This analysis was used to evaluate the change in plant risk from diversifying standby liquid control explosive valve operation to decrease the probability of common cause failures. A bounding analysis was performed by eliminating all common cause failures of standby liquid control squib valves.

F-44 213 - Provide leak detection and automatic isolation valves on EECW piping in the direct current 2 3 3 99K 247K 377K switchgear room Assumption: This analysis was used to evaluate the change in plant risk from providing the capability to detect and isolate floods from EECW piping in the direct current switchgear room. The analysis was performed by assuming that a flood from this piping would not result in the failure of any electrical equipment in the direct current switchgear room.

214 - Provide leak detection and automatic isolation valves on EECW piping in the Division 2 switchgear 1 1 1 44K 111K 377K room Assumption: This analysis was used to evaluate the change in plant risk from providing the capability to detect and isolate floods from EECW piping in the Division 2 switchgear room (Area A3G10). The analysis was performed by assuming that a flood from this piping would not result in the failure of any electrical equipment in the Division 2 switchgear room.

(a) SAMAs in bold are potentially cost-beneficial. Refer to Section F.6.2 for three additional SAMAs determined by DTE to be potentially cost beneficial as a result of questions raised by the NRC staff during the SAMA evaluation review.

(b) DTE identified potentially cost-beneficial SAMAs by comparing the largest total benefit with sensitivity to the estimated implementation cost.

(c) In response to requests by the NRC staff for additional information, DTE updated the assessment related to SAMAs 023, 031, 074, 078, 183, and 187 as described in Section F.4.

(d) The NRC staff calculated corrected benefits in Table F-6 for SAMAs 021, 024, 050, 067, 078, 123, 145, 152, 177, and 194.

% Risk Reduction Total Benefit ($)(b)

Larger Baseline Result: Cost Individual SAMA and Assumption Population CDF OECR (Internal + Baseline ($)(b)

Dose External) with Sensitivity Key: ADS = automatic depressurization system; ATWS = anticipated transients without scram; CCDP = conditional core damage probability; CDF = core damage frequency; CTG = combustion turbine generator; EECW = emergency equipment cooling water; ECCS = emergency core cooling system; EDG = emergency diesel generator; gpm = gallons per minute; HPCI = high pressure coolant injection; ISLOCA = interfacing-systems loss-of-coolant accident; LPCI = low-pressure coolant injection; LOCA = loss-of-coolant accident; MCR = main control room; MSIV = main steam isolation valve; NRC = U.S. Nuclear Regulatory Commission; OECR = offsite economic cost risk; RCIC = reactor core isolation cooling; RHR = residual heat removal; SAMA = severe accident mitigation alternative; SBFW = standby feedwater; SRV = safety relief valve Source: DTE 2014 F-45 Appendix F

Appendix F The review of the LERF events identified four additional events that should be considered. DTE indicated that the first event, Failure of Combustible Gas Venting, will be addressed by implementation of NRC Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions. Since DTE intends to comply with the Order, there is no need to address this event with a specific SAMA. The second event, Hydrogen Deflagration Occurs Globally, is addressed by SAMAs 93 (Provide post-accident containment inerting capability) and 103 (Install a passive hydrogen control system). A bounding analysis was performed for these SAMAs by eliminating all hydrogen deflagrations that result in containment or drywell failures. None of these SAMAs was found to be cost beneficial. Mitigating the third event, Control Rods Melt Prior to Fuel Rods, was evaluated by considering a SAMA to replace the current control rods with rods that have metal cladding with a higher melting point than the fuel. This SAMA was evaluated by revising the probability of this event from 1.0 to 5x102 and requantifying the model. The result was a maximum benefit of $33,000 including external events and uncertainty. DTE concluded that the cost of replacing control rods and disposing of the existing rods is estimated to greatly exceed the benefit of this SAMA, so this SAMA is not cost beneficial. A new SAMA evaluation was performed for the fourth event, Operator Fails to Isolate Path Given Isolation Signal Fails, assuming the probability of the event was revised from 1.0 to 0.1. This resulted in a maximum benefit of $30,000 including external events and uncertainty. DTE concluded that this SAMA is not cost beneficial even when considering low cost changes such as new procedures (DTE 2015a, 2015c).

The NRC staff noted in an RAI that SAMAs 183 and 187 both involve improvements to the alternate shutdown panel that would reduce the conditional core damage probability (CCDP) of operation from the alternate shutdown panel following control room evacuation due to fire events and that the internal events internal flooding model includes a similar basic event, Operators fail to shutdown from outside the main control room. In response to the request to provide more information on how the benefit of these SAMAs was determined to include the potential for impacting both fire risk and internal event risk, DTE indicated that the ER reported benefit of SAMAs 183 and 187 was based only on the reduction in fire risk. If the benefit of the improved alternate shutdown panel for both fire and internal flood initiators was considered, DTE determined that the maximum benefit would be $205,000 including uncertainty. Because the cost of implementation is estimated to be $790,000 for SAMAs 183 and 187, DTE concluded that these SAMAs remain not cost beneficial (DTE 2015a).

The NRC staff noted that SAMAs 213 and 214 both involve providing leak detection and automatic isolation valves for EECW piping in the DC switchgear room or the Division 2 switchgear room, respectively. The benefit for each was indicated to be based on the assumption that a flood from the piping failure would not result in the failure of any electrical equipment in the switchgear room in which the flood occurred. Because these SAMAs were identified to mitigate important flooding events in which the flood would or could cause failures in adjacent electrical rooms, DTE was asked to confirm that the benefit assessment includes the elimination of failures in the adjacent rooms. DTE confirmed that the benefit for SAMAs 213 and 214 included the elimination of failures of equipment in the flood location room as well as due to propagation of the flood outside of the room in which it occurs (DTE 2015a).

In response to an NRC staff RAI concerning how the benefit was determined for those SAMAs that specifically mitigate fire risk (i.e., SAMAs 183, 187, and 206211), DTE indicated it was necessary to estimate the reduction in fire CDF by the SAMA from the IPEEE compartment scenario analysis because the Fermi 2 IPEEE fire analysis was performed using FIVE and there is not an integrated quantitative model. The reduction in fire CDF determined from the IPEEE was reduced by the factor of 2 to determine the total fire CDF, as discussed above in F-46

Appendix F Section F.2.2.2. The resulting reduction in CDF was used to determine a reduction factor that is uniformly applied to the CDF and release category frequencies. Concerning the differing assumptions in the SAMA evaluation regarding the impact on the CCDP due to the SAMA modifications, DTE indicated that the SAMA was assumed to reduce the severe fires to non-severe fires and the associated CCDP, when the IPEEE analysis included both severe and non-severe fires. If the IPEEE analysis did not distinguish between severe and non-severe fires, an order-of-magnitude reduction was assumed. This was stated to be consistent with that found for those scenarios where information on the CCDPs for severe and non-severe fires was available.

The NRC staff has reviewed DTEs bases for calculating the risk reduction for the various plant improvements and concludes, with the above clarifications, that the rationale and assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, the NRC staff based its estimates of averted risk for the various SAMAs on DTEs risk reduction estimates.

F.5 Cost Impacts of Candidate Plant Improvements DTE estimated the costs of implementing the 79 Phase II SAMAs through the use of other licensees estimates for similar improvements and the development of site-specific cost estimates where appropriate.

DTE indicated the following cost ranges were used based on the review of previous SAMA applications and an evaluation of expected implementation costs at Fermi 2.

Type of Change Estimated Cost Range Procedural only $50K Procedural change with engineering or training required $50K to $200K Procedural change with engineering and testing or training required $200K to $300K Hardware modification $100K to >$1,000K DTE stated that the Fermi 2 site-specific cost estimates were based on the engineering judgment of project engineers experienced in performing design changes at the facility and were compared, where possible, to estimates developed and used at plants of similar design and vintage.

In response to an NRC staff RAI to provide further information as to what was included in the Fermi 2 cost estimates, DTE indicated that cost estimates were developed based on initial hardware and installation costs only, not recurring costs (DTE 2015a). Replacement power, lifetime maintenance, and procedure costs were not included in the estimates. DTE indicated that the only exceptions are the cost estimates for SAMA 145 (Increase training and operating experience feedback to improve operator response) and a new SAMA evaluated in response to an RAI to implement an inspection program for the piping associated with the risk significant internal flooding initiators. SAMA 145 is training related so costs estimated by DTE included additional operator training for the life of the plant. Because the new SAMA pertains to a proposed inspection program, DTE included recurring costs associated with plant walkdowns of piping segments that are significant to the internal flooding risk (DTE 2015a).

The NRC staff reviewed the applicants cost estimates presented in Table D.2-1 of the ER (DTE 2014). For certain improvements, the NRC staff also compared the cost estimates to F-47

Appendix F estimates developed elsewhere for similar improvements, including estimates developed as part of other licensees analyses of SAMAs for operating reactors.

Regarding the $200,000 cost for SAMA 176 to develop a procedure to open the door to the EDG buildings upon the high temperature alarm, DTE justified the cost estimate by explaining that an evaluation on ventilation sufficiency from opening the doors would be needed in addition to the costs for procedure changes and training (DTE 2015a).

DTE also described the cost estimates for fire-related SAMAs 207 through 211, either being developed by DTE for Fermi 2 including costs for equipment, engineering design, construction, and materials with incipient detection or clarified to have been based on a Brunswick estimate for medium-sized, moderate complexity automatic fire suppression systems without incipient detection (DTE 2015a).

With the above clarifications, the NRC staff concludes that the cost estimates provided by DTE are sufficient and appropriate for use in the SAMA evaluation.

F.6 Cost-Benefit Comparison DTEs cost-benefit analysis and the NRC staffs review are described in the following sections.

F.6.1 DTEs Evaluation The methodology used by DTE was based primarily on the NRCs guidance for performing cost-benefit analysis, NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook (NRC 1997a). This NRC guidance was adopted in the NEI 05-01 report (NEI 2005). As described in Section D.1.5.4 of the ER (DTE 2014), the MMACRSAMA was determined for each SAMA according to the following formula, which the NRC staff accepts as mathematically equivalent to the formula in the NUREG/BR-0184:

MMACRSAMA = EEM (W PHA + W EA + W O + W CD + WRP)

Where EEM = external event multiplier (unit less)

WPHA = present value of averted offsite exposure cost ($)

WEA = present value of averted offsite economic cost ($)

WO = present value of averted onsite exposure cost ($)

WCD = present value of averted onsite cleanup cost ($)

WRP = present value of averted replacement power cost ($)

DTEs derivation of each of the associated costs is presented separately in this section. For each SAMA, the applicant determined the internal and external benefit from the implementation of individual SAMAs using the following formula:

SAMA Benefit =MMACRBaseline - MMACRSAMA For each SAMA, the estimated benefit is compared to the cost of implementation. If the cost of implementing the SAMA is larger than the benefit associated with the SAMA, the SAMA is not considered to be cost beneficial. If the cost of implementing the SAMA is smaller than the benefit associated with the SAMA, the SAMA is considered to be potentially cost beneficial.

Sensitivity analyses performed by the applicant can lead to increases in the calculated benefits.

DTE analyzed one sensitivity case with a lower discount rate of 3 percent in accordance with F-48

Appendix F NUREG/BR-0184 guidance (NRC 1997a), which states that 2 sets of present worth estimates should be developed using both the 3 percent and 7 percent discount rates. DTE conducted a baseline analysis using the 7 percent discount rate and a sensitivity analysis using the 3 percent discount rate (DTE 2014). Additional details on the sensitivity analysis are presented in Section F.6.2.

Averted Offsite Exposure Cost (W PHA)

DTE defined WPHA cost as the monetary value of accident risk avoided from population doses after discounting (DTE 2014). The W PHA costs were calculated using the following formula:

WPHA = Averted public dose risk (person-rem per year) x monetary equivalent of unit dose ($2,000 per person-rem) x present value conversion factor (NRC 1997a)

As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of the public health risk after discounting does not represent the expected reduction in public health risk because of a single accident. Rather, it is the present value of a stream of potential losses extending over the remaining lifetime (in this case, the 20-year renewal period) of the facility. Thus, it reflects the expected annual loss caused by a single accident, the possibility that such an accident could occur at any time over the renewal period, and the effect of discounting these potential future losses to present value. For discount rates of 7 percent and 3 percent, DTE calculated W PHA costs of $105,676 and $147,667, respectively, due to internal events in Table D.1-27 of the ER (DTE 2014).

Averted Offsite Economic Cost (W EA)

DTE defined WEA as the monetary value of risk avoided from offsite property damage after discounting (DTE 2014). The W EA values were calculated using the following formula:

WEA = Annual offsite property damage risk before discounting in dollars per year x present value conversion factor (NRC, 1997a)

For discount rates of 7 percent and 3 percent, DTE calculated W EA costs of $167,403 and

$233,921, respectively, due to internal events in Table D.1-28 of the ER (DTE 2014).

Averted Onsite Exposure Cost (W O)

DTE defined W O as the avoided onsite exposure (DTE 2014). Similar to the W PHA calculations, the applicant calculated costs for immediate onsite exposure. Long-term onsite exposure costs were calculated consistent with guidance in the Regulatory Analysis Handbook (NRC 1997a),

which included an additional term for accrual of long-term doses.

DTE derived the values for averted occupational exposure from information provided in Section 5.7.3 of the Regulatory Analysis Handbook (NRC 1997a). Best estimate values provided for immediate occupational dose (3,300 person-rem) and long-term occupational dose (20,000 person-rem over a 10-year cleanup period) were used. The present value of these doses was calculated using the equations provided in the handbook in conjunction with a monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 7 percent, and a time period of 20 years to represent the license renewal period. Immediate and long-term onsite exposure costs were summed to determine the W O cost. For discount rates of 7 percent and 3 percent, DTE calculated W O costs of $572 and $930, respectively, due to internal events in Table D.1-31 of the ER (DTE 2014).

Averted Onsite Cleanup Cost (W CD)

F-49

Appendix F DTE defined W CD as the avoided cost for cleanup and decontamination of the site (DTE 2014).

The applicant derived the values for W CD based on information provided in Section 5.7.6 of NUREG/BR-0184, the Regulatory Analysis Handbook (NRC 1997a).

Averted cleanup and decontamination costs were calculated using the following formula:

WCD = Annual CDF x present value of cleanup costs per core damage event x present value conversion factor.

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in the Regulatory Analysis Handbook to be $1.5x109 (undiscounted). This value was converted to present costs over a 10-year cleanup period and integrated over the term of the proposed license extension. For discount rates of 7 percent and 3 percent, DTE calculated W CD costs of

$17,450 and $29,293, respectively, due to internal events in Table D.1-32 of the ER (DTE 2014).

Averted Replacement Power Cost (W RP)

DTE defined W RP as the avoided costs of replacement power (DTE 2014). Long-term replacement costs were calculated using the following formula:

WRP = Annual CDF x present value of replacement power for a single event x factor for remaining service years for which replacement power is required x reactor power scaling factor DTE based its calculations on the net electric output for Fermi 2, specifically 1,170 megawatt-electric (MWe), and scaled up from reference plant value of 910 MWe specified in NUREG/BR-0184 (NRC 1997a). For discount rates of 7 percent and 3 percent, DTE calculated WRP costs of $15,247 and $14,278, respectively, due to internal events in Table D.1-34 of the ER (DTE 2014).

MMACRBaseline Using the above equations, DTE estimated the total present dollar value equivalent associated with completely eliminating severe accidents caused by internal events, referred to as the MACR, to be about $306,348 and $426,090 for respective discount rates of 7 percent and 3 percent in Table D.1-35 of the ER (DTE 2014). To account for the risk contributions from external events and yield the internal and external benefit, DTE selected an EEM value of 11 for Fermi 2 (DTE 2014), as discussed further in Section F.6.2. By multiplying MACR and EEM, DTE estimated MMACRBaseline to be about $3,369,832 and $4,686,991 for respective discount rates of 7 percent and 3 percent in Table D.1-35 of the ER (DTE 2014). As described above in the SAMA benefit formula, components of the MMACRBaseline calculation factor into the benefit determination for individual SAMAs.

DTEs Results If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA was determined to be not cost beneficial. If the SAMA benefit exceeded the estimated cost, the SAMA candidate was considered to be potentially cost beneficial. The DTEs baseline cost-benefit analysis identified one SAMA candidate as potentially cost-beneficial. From the sensitivity analysis, DTE identified an additional three SAMA candidates as potentially cost beneficial. Results of the cost-benefit evaluation are presented in Table F-5. Considering the results from the baseline and sensitivity analyses, the full set of potentially cost-beneficial SAMAs for Fermi 2 is:

F-50

Appendix F

SAMA 112: Revise emergency operating procedures to improve identification of interfacing system LOCAs,

SAMA 113: Improve operator training on coping with interfacing system LOCAs,

SAMA 115: Revise procedures to control vessel injection to prevent boron loss or dilution following standby liquid control injection, and

SAMA 206: Improve the ability of operators to manually close a damper to isolate the third floor of the reactor building from the hardened vent path.

DTE indicated that seven SAMAs, the four numbered SAMAs above as well as three additional unnumbered SAMAs listed in Section F.6.2 arising from the NRC staffs review, will be incorporated into the evaluation process and evaluated considering other planned changes.

F.6.2 Review of DTEs Cost-Benefit Evaluation During its review of the cost-benefit analysis performed by DTE, the NRC staff compared the applicants approach with guidance in NUREG/BR-0184 (NRC 1997a) and discount rate guidelines in NEI 05-01 (NEI 2005). NEI guidance states that two sets of estimates should be developed for discount rates of 7 percent and 3 percent (NEI 2005). DTE performed assessments using both discount rates. DTE provided a baseline set of results using a discount rate of 7 percent. For the other types of potential sensitivity analyses suggested (NEI 2005), the NRC staff finds that DTEs information provided in the ER submittal and subsequent RAI responses on plant modifications, peer review findings or observations, and evacuation speed have been adequately addressed in the baseline analysis, as discussed in this appendix. As previously indicated, DTE performed the cost-benefit evaluation using an analysis time period of 20 years. Because DTE explicitly accounted for uncertainty in its sensitivity analysis by applying a multiplication factor of 2.5 and the results of the sensitivity analysis were used to identify additional potentially beneficially SAMAs, the NRC staff finds that an additional sensitivity analysis for a time frame longer than 20 years is not necessary. Although longer timeframes would increase estimated benefits compared to baseline results, it is unlikely that influences from a longer timeframe would exceed the factor of 2.5 already considered by DTE.

Based on its review of the applicants cost-benefit evaluation, the NRC staff determined that the applicants approach is consistent with the guidance and is acceptable.

The applicant considered possible increases in benefits from analysis uncertainties on the results of the SAMA assessment. In the ER (DTE 2014), DTE indicated that the 95th percentile value of the Fermi 2 CDF was greater than the mean CDF by a factor of 2.36. A multiplication factor of 2.5 was conservatively selected by the applicant to account for uncertainty. This multiplication factor was applied in addition to the separate external events multiplication factor of 11 (DTE 2014), as described in Section F.2.2.2. DTEs assessment accounted for the potential risk-reduction benefits associated with both internal and external events. The NRC staff considers the multipliers of 2.5 for uncertainty and 11 for external events at Fermi 2 provide adequate margin and are acceptable for the SAMA analysis.

Using DTEs information on the release category frequencies during the onsite audit (NRC 2014c), the NRC staff spot checked the applicants calculations of delta CDF (i.e., percentage reduction in CDF due to accumulated differences in the release categories for a specific SAMA candidate compared to the base case), population dose risk, and offsite economic cost risk. By applying the formula for SAMA benefit presented in Section F.6.1 and comparing the results with those presented in Table D.2-1 of the ER (DTE 2014), the NRC staff found the results to be in agreement and within small roundoff errors. Consistency also was F-51

Appendix F found between the base release category frequencies and those reported in Tables D.1-9 and D.1-10 of the ER (DTE 2014).

DTEs baseline cost-benefit analysis identified one SAMA candidate as potentially cost beneficial. From a sensitivity analysis, DTE identified an additional three SAMA candidates as potentially cost beneficial. As described in Section F.3.2, the NRC staff asked the applicant to evaluate potentially lower-cost alternatives to the SAMA candidates. In response to questions raised by the NRC staff, DTE concluded that the following new SAMAs would be potentially cost beneficial (DTE 2015a):

Install a flood barrier or curb between the DC switchgear room and Division 2 AC switchgear room.

Develop a new procedure to close valves to terminate the flood from EECW in an AB3 switchgear room.

Revise existing alarm response procedures to direct operators to DC switchgear room and the Division 2 AC switchgear room following indication of leakage in RBCCW/EECW system piping.

From its review of the original SAMA analysis and additional information, the NRC staff agrees with DTEs disposition of the above lower cost alternatives.

As discussed above in Section F.2.2.3, the Level 2 analysis assignment of sequences to release categories resulted in the underestimation of the consequences for Accident Class IIA sequences. As noted by the NRC staff in an RAI (NRC 2015a), the impact of this accident class assignment may not have a significant impact on the base case MACR, but it would lead to an underestimate of the benefit for any SAMA that mitigated these Class IIA sequences.

In response to the RAI and a subsequent RAI (NRC 2015b) to include in the benefit evaluation the impact of the 3.14x109 per year undercounting due to truncation discussed previously in Section F.2.2.3, DTE provided an analysis of the impact on the cost-benefit analysis of those SAMAs expected to be most impacted by these issues (DTE 2015b and 2015c). Eleven SAMAs (21, 24, 50, 54, 67, 78, 123, 145, 152, 177, and 194) were selected based on three criteria:

The SAMA was not already considered potentially cost-beneficial in the base case analysis or in the sensitivity analysis.

The SAMA was not specifically oriented towards other types of sequences (e.g., LOCA, ATWS, early loss of RPV injection).

The SAMA has a non-marginal impact on Class IIA sequences relative to non-Class IIA sequences.

For this RAI response, DTE assumed that the Class IIA frequency originally included in the H/E release category (5.32x108 per year) and all the unaccounted for 3.14x109 per year have offsite population dose in person-rem and economic cost consequences equal to those for the H/E-BOC release category because MAAP analysis results were not available for these sequences. The cutsets for each of the SAMAs (except SAMAs 78 and 123, discussed below) were reviewed and the percent reduction in the Class IIA sequence frequency determined. This percent reduction was used to determine the additional benefit due to the originally mischaracterized 5.32x108 per year and the unaccounted for 3.14x109 per year. As explained in the RAI response (DTE 2015c), this frequency reduction was multiplied by the difference between the new, higher, H/E-BOC consequence (person-rem and offsite economic cost) and the original H/E release category consequence and converting the resultant averted risk to a F-52

Appendix F monetary benefit. For SAMAs 78 and 123, the analysis used the benefit analysis revised in response to an NRC staff RAI discussed above in Section F.4. For both SAMA 78 and SAMA 123, it was assumed that the SAMA was 100 percent effective in eliminating the risk from the Class IIA sequences (DTE 2015c).

The NRC staff notes that while the above described procedure to subtract the original H/E release category consequence to determine the added benefit associated with the Class IIA sequences is correct with regard to the original mischaracterized 5.32x108 per year, it is not correct with regard to the unaccounted for 3.14x109 per year because this frequency was not included in the original benefit calculations. The NRC staff calculated this added benefit as part its review and concluded that the added benefit is relatively small and does not impact the final selection of cost-beneficial SAMAs. It is further noted that DTEs analysis does not include the added onsite benefit (onsite exposure, onsite cleanup, and replacement power) associated with mitigating the unaccounted for 3.14x109 per year Class IIA sequences. Because the sequences are approximately 0.2 percent of the total CDF and the maximum averted onsite cost risk is only about 10 percent of the MACR, the NRC staff concludes this added contribution is negligible.

A full presentation of results from the analysis performed by DTE is reported in Table 2-2 of the RAI response (DTE 2015c). Table F-6 of this appendix summarizes some of DTEs results and presents results from the calculation performed by the NRC staff during the review of the SAMA analysis. No additional cost-beneficial SAMAs were identified as a result of the NRC staffs calculation.

Because the NRC staff reviewed the cost benefit evaluations performed by DTE, DTE satisfactorily addressed the NRC staff questions regarding the evaluations, and the NRC staff found that no additional cost-beneficial SAMAs were missed as a result of a minor correction to DTEs evaluation, the NRC staff concludes that the cost-benefit evaluations, subject to the one correction discussed above, are of sufficient quality to support the SAMA evaluation.

DTE identified three additional potential cost-beneficial SAMAs as a result of the NRC staff questions on installing a flood barrier or curb between the DC switchgear room and Division 2 AC switchgear room, developing a new procedure to close valves to terminate the flood from EECW in an AB3 switchgear room, and revising existing alarm response procedures to direct operators to the DC switchgear room and the Division 2 AC switchgear room following indication of leakage in the RBCCW/EECW system piping. For the other SAMAs that were not cost beneficial, the NRC staff concludes that their implementation costs exceed their associated benefits; therefore, those SAMAs are not cost beneficial.

F-53

Table F-6. Adjusted Cost/Benefit Analysis for SAMAs Impacted by Accident Class IIA Consequence Revisions Additional 2.5 Uncertainty Class IIA Class IIA Additional Offsite Factor Applied Appendix F Percent Frequency Offsite Dose Economic Adjusted Cost to Adj. Cost Implementa-SAMA SAMA Reduction Reduction Cost Benefit Cost Benefit Benefit Benefit tion Cost (a)

No. Description (1/yr)(b) ($)(c)(i) ($)(d)(j) ($)(e)(k) ($)(f)(l) ($)(g) 21 Use firewater 58.34% 3.29x108 $107,000 $8,950 $373,000 $931,000 $2,000,000 system as a backup ($3,840) ($6,070) ($382,000) ($956,000) source for diesel cooling 24 Training for offsite 0.00%(h) 0(h) $0 $0 $6,270 $15,700 $50,000 power recovery after ($0) ($0) ($6,270) ($15,700)

SBO 50 Change procedures 2.88% 1.62x109 $5,260 $441 $18,900 $47,100 $50,000 to allow cross ($190) ($300) ($19,300) ($48,400) connect of motor cooling for RHRSW pumps F-54 54 Enhance procedural 0.02% 1.07x1011 $35 $3 $3,280 $8,190 $50,000 guidance for use of ($1) ($2) ($3,280) ($8,200) cross-tied component cooling or service water pumps 67 Enhance procedure 0.00%(h) 0(h) $0 $0 $1,190 $2,960 $50,000 to trip unneeded ($0) ($0) ($1,190) ($2,960)

RHR or containment spray pumps on loss of room ventilation 78 Enable flooding of 100.00% 5.63x108 $183,000 $15,300 $296,000 $739,000 $1,000,000 drywell head seal ($6,580) ($10,400) ($313,000) ($781,000) 123 Install an 100.00% 5.63x108 $183,000 $15,300 $1,300,000 $3,250,000 $40,000,000 ATWS-sized filtered ($6,580) ($10,400) ($1,320,000) ($3,290,000) containment vent to remove decay heat

Additional 2.5 Uncertainty Class IIA Class IIA Additional Offsite Factor Applied Percent Frequency Offsite Dose Economic Adjusted Cost to Adj. Cost Implementa-SAMA SAMA Reduction Reduction Cost Benefit Cost Benefit Benefit Benefit tion Cost (a)

No. Description (1/yr)(b) ($)(c)(i) ($)(d)(j) ($)(e)(k) ($)(f)(l) ($)(g) 145 Increase training 11.94% 6.73x109 $21,800 $1,830 $333,000 $834,000 $1,000,000 and operating ($786) ($1,240) ($335,000) ($839,000) experience feedback to improve operator response 152 Proceduralize all 6.01% 3.39x109 $11,000 $923 $37,300 $93,100 $100,000 potential 4- kV AC ($395) ($625) ($38,300) ($95,700) bus cross-tie actions 177 Provide an alternate 15.84% 8.92x109 $28,900 $2,430 $131,000 $327,000 $489,300 means of supplying ($1,040) ($1,650) ($134,000) ($334,000) the instrument air header 194 Provide ability to 4.74% 2.67x109 $8,660 $727 $38,300 $95,700 $100,000 F-55 maintain ($312) ($493) ($39,100) ($97,700) suppression pool temperature lower Notes pertaining to values listed in the first (upper) row for each SAMA, as taken from Table 2-2 of DTEs RAI response (DTE 2015c):

a Class IIA percent reduction was calculated based on detailed cutset summation, except for SAMAs 78 and 123 in which 100% H/E Class IIA reduction is assumed.

b Values were calculated from multiplying the Class IIA Percent Reduction by the H/E Class IIA release frequency of 5.63x108 per year, which includes the 3.14x109 per year additional frequency.

c Values displayed without parentheses were derived from taking the difference between the H/E Class IIA release category population dose (2.18x107 rem, using the H/E-BOC MACCS2 results) and the Other (or original) H/E release category population dose (8.10x106 rem) to calculate the additional benefit (1.37x107 rem) to the population dose reduction. The dose cost factor of $2,000 per person-rem and the Class IIA frequency reduction listed in Column 4 were applied in the calculation. The calculation also included multiplication by the external hazards factor (11) and the 7-percent discount rate factor (10.76).

d Values displayed without parentheses were derived from taking the difference between the H/E Class IIA release category offsite economic cost ($3.03x1010) and the Other (or original) H/E release category offsite economic cost ($2.80x1010) to calculate the additional benefit ($2.30x109) to the offsite economic costs assuming the Class IIA frequency reduction listed in Column 4. The calculation included multiplication by the external hazards factor (11) and the 7-percent discount rate factor (10.76).

Appendix F

Additional 2.5 Uncertainty Class IIA Class IIA Additional Offsite Factor Applied Percent Frequency Offsite Dose Economic Adjusted Cost to Adj. Cost Implementa-SAMA SAMA Reduction Reduction Cost Benefit Cost Benefit Benefit Benefit tion Cost (a)

Appendix F No. Description (1/yr)(b) ($)(c)(i) ($)(d)(j) ($)(e)(k) ($)(f)(l) ($)(g) e 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 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. Table 2-2 of DTE 2015c already included the previous RAI response's impact on SAMA 78.

f Adjusted Cost Benefit (Column 5 without parentheses) multiplied by the uncertainty factor of 2.5.

g Obtained from SAMA ER Table D.2-1, except for SAMA 78 with an updated implementation cost from DTEs RAI response (DTE 2015a).

h Class IIA percent reduction is <0.01 percent, and Class IIA frequency reduction is <5.6x1012 per year. Because the reduction is so small, the impact was considered zero for the evaluation.

Notes pertaining to values in parentheses listed in the second (lower) row for each SAMA, as calculated by the NRC staff to account for the added offsite dose cost benefit, added offsite economic cost benefit, and revised total benefit for each SAMA.

i Values in parentheses were calculated by the NRC staff by using the Other (or original) H/E release category population dose (8.10x106 rem) to calculate the additional benefit to the population dose reduction and applying a dose cost factor of $2,000 per person-rem and the Column 3 percentage reduction of the unaccounted for 3.14x109 per year Class IIA frequency. The calculation included multiplication by the external hazards factor (11) and the 7-percent discount rate factor (10.76).

F-56 j Values in parentheses were calculated by the NRC staff by using the Other (or original) H/E release category offsite economic cost ($2.80x1010) to calculate the additional benefit to the offsite economic costs and the Column 3 percentage reduction of the unaccounted for 3.14x109 per year Class IIA frequency.

The calculation included multiplication by the external hazards factor (11) and the 7-percent discount rate factor (10.76).

k Values in parentheses were calculated by the NRC staff by adding the additional offsite dose and economic cost benefit due to the unaccounted for 3.14x109 per year evaluated at the original H/E release category consequences to the above value for the SAMA from DTEs RAI response (DTE 2015c).

l Adjusted Cost Benefit calculated by the NRC staff (Column 7 in parentheses) multiplied by the uncertainty factor of 2.5.

Appendix F F.7 Conclusions DTE considered 220 candidate SAMAs based on risk-significant contributors at Fermi 2 from updated probabilistic safety assessment models, SAMA-related industry documentation, plant-specific enhancements not in published industry documentations, and its review of SAMA candidates from potential improvements primarily at eight other plants. Phase I screening reduced the list to 79 unique SAMA candidates by eliminating SAMAs that were not applicable to Fermi 2, had already been implemented at Fermi 2, were combined into a more comprehensive or plant-specific SAMA, had excessive implementation cost, had a very low benefit, or related to in-progress implementation of plant improvements that addressed the intent of the SAMA. For the remaining SAMA candidates, DTE performed a cost-benefit analysis with results shown in Table F-5. The baseline cost-benefit analysis identified one SAMA candidate as potentially cost beneficial. From a sensitivity analysis, DTE identified an additional three SAMA candidates as potentially cost beneficial. In response to questions raised by the NRC staff, DTE concluded that three new SAMAs would be potentially cost beneficial.

Because the potentially cost-beneficial SAMAs do not relate to aging management during the period of extended operation, their implementation is not required as part of license renewal pursuant to Title 10 of the Code of Federal Regulations Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Nevertheless, DTE indicated that these seven SAMAs will be incorporated into the evaluation process and evaluated considering other planned changes.

The NRC staff reviewed DTEs SAMA analysis and concludes that, subject to the discussion in this appendix, the methods used and the implementation of the methods were sound. The NRC staffs concerns were addressed by DTEs responses and the NRC staffs review. Furthermore, a calculation performed by the NRC staff with DTEs information did not change the identification of cost-beneficial SAMAs. On the basis of the applicants treatment of SAMA benefits and costs, the NRC staff finds that the SAMA evaluations performed by DTE are reasonable and sufficient for the license renewal submittal. The NRC staff agrees with DTEs conclusion that seven SAMA candidates are potentially cost beneficial for Fermi 2 and notes that DTEs assessment was based on generally conservative treatment of costs, benefits, and uncertainties. Furthermore, this conclusion of a relatively small number of potentially cost-beneficial SAMAs is consistent with a low level of residual risk indicated in the Fermi 2 PRA. Based on the NRC staffs review of DTEs SAMA evaluations, including DTEs response to NRC staff RAIs, the NRC staff concludes that DTE has adequately identified areas in which risk can be further reduced in a cost-beneficial manner through the implementation of the identified potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees that further evaluation by DTE of the seven candidate SAMAs identified by DTE as being potentially cost beneficial is warranted.

Additionally, the NRC staff evaluated if the identified potentially cost-beneficial SAMAs are subject to aging management. The evaluation considered any structures, systems, and components associated with these SAMAs that perform intended functions without moving parts or without a change in configuration or properties and would not be subject to replacement based on a qualified life or specified time period. Because the potential cost-beneficial SAMAs are associated with procedure changes, new hardware to improve a manual action, and a new structure between switchgear rooms, the NRC staff determined that these SAMAs do not relate to adequately managing the effects of aging during the period of extended operation.

Therefore, they need not be implemented as part of license renewal in accordance with 10 CFR Part 54.

F-57

Appendix F F.8 References 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for renewal of operating licenses for nuclear power plants.

[ASME and ANS] American Society of Mechanical Engineers and American Nuclear Society.

2009. Addenda to ASME/ANS RA-S-2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications. New York City, New York: ASME. ASME/ANS RA-Sa-2009. February 2, 2009. 352 p. Available at

<http://www.ewp.rpi.edu/hartford/~povron/EP/Other/ASME-ANS%20RA-Sa-2009.pdf>

(accessed 21 October 2014).

Chen JT, Chokshi NC, Kenneally RM, Kelly GB, Beckner WD, McCracken C, Murphy AJ, Reiter L, Jeng DC. 1991. Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. Washington, DC:

U.S. Nuclear Regulatory Commission. NUREG-1407. June 1991. 98 p. ADAMS No. ML063550238.

[DECo] Detroit Edison Company. 1992. Submittal of the Detroit Edison Individual Plant Examination for External Events (IPEEE) Report - Response to Generic Letter 88-20, Supplement 4. August 1992. Available via the NRC Public Document Room by e-mail to pdr@resource@nrc.gov.

[DECo] Detroit Edison Company. 1996. Fermi 2 Individual Plant Examination (External Events). March 1996. Available via the NRC Public Document Room by e-mail to pdr@resource@nrc.gov.

[DECo] Detroit Edison Company. 1999. Letter from D.R. Gibson, DECo, to the NRC Document Control Desk.

Subject:

Detroit Edison Response to NRC Request for Additional Information (RAI) on Fermi 2 IPEEE Report. Detroit Edison Letter NRC-99-0051. July 22, 1999. Available via the NRC Public Document Room by e-mail to pdr@resource@nrc.gov.

[DTE] DTE Electric Company, LLC. 2012a. Fermi 2 NPP Seismic Walkdown Report, 10 CFR 50.54(f) Section 2.3 Seismic Response. Report TMPE-12-0294, Revision 0.

November 20, 2012. ADAMS No. ML12229A475.

[DTE] DTE Electric Company, LLC. 2012b. Letter from T.J. Conner, DTE, to the NRC Document Control Desk.

Subject:

Detroit Edisons Response to March 12, 2012, Information Request Regarding Flood Protection Walkdowns. DTE letter NRC-12-0076.

November 26, 2012. ADAMS No. ML12331A202.

[DTE] DTE Electric Company, LLC. 2013. Letter from T.J. Conner, DTE, to the NRC Document Control Desk.

Subject:

DTE Electric Submittal of Flooding Hazard Reevaluation Report in Response to March 12, 2012, Information Request Regarding Flood Protection Evaluations.

DTE letter NRC-13-0013. March 8, 2013. ADAMS No. ML13070A199.

[DTE] DTE Electric Company. 2014. Fermi 2 License Renewal Application. Appendix E:

Applicants Environmental Report, Operating License Renewal Stage, Fermi 2. April 2014.

ADAMS Nos. ML14121A538, ML14121A539, and ML14121A540.

[DTE] DTE Electric Company. 2015a. Letter from V. Kaminskas, Site Vice President, DTE, to NRC Document Control Desk.

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal ApplicationSevere Accident Mitigation Alternatives. January 9, 2015. ADAMS No. ML15009A358.

F-58

Appendix F

[DTE] DTE Electric Company. 2015b. Letter from V. Kaminskas, Site Vice President, DTE, to the NRC Document Control Desk.

Subject:

Response to NRC Request for Additional Information for the Environmental Review of the Fermi 2 License Renewal ApplicationSevere Accident Mitigation Alternatives Set 2. March 5, 2015. ADAMS No. ML15064A099.

[DTE] DTE Electric Company. 2015c. Letter from V. Kaminskas, Site Vice President, DTE, to the NRC Document Control Desk.

Subject:

Response to NRC Request for Additional Information for the Environmental Review of the Fermi 2 License Renewal ApplicationSevere Accident Mitigation Alternatives Set 3. Letter May 8, 2015. ADAMS No. ML15141A163.

[EPRI] Electric Power Research Institute. 1991. A Methodology for Assessment of Nuclear Power Plant Seismic Margin. EPRI NP-6041-SL, Revision 1. August 1991. Available at

<http://www.epri.com/abstracts/Pages/ProductAbstract.aspx?ProductId=NP-6041-SLR1>.

[EPRI] Electric Power Research Institute. 1992. Fire-Induced Vulnerability Evaluation (FIVE).

EPRI-TR-100370, Final Report, April 1992, and Revision 1. September 29, 1993. Available at

<http://teams.epri.com/PRA/Big%20List%20of%20PRA%20Documents/EPRI%20TR-100370%20(abstract).htm>.

[EPRI] Electric Power Research Institute. 2014. Letter from S. Lewis, EPRI, to A.R. Petrangelo, NEI.

Subject:

Fleet Seismic Core Damage Frequency Estimates for Central and Eastern U.S. Nuclear Power Plants Using New Site-Specific Seismic Hazard Estimates.

March 11, 2014. ADAMS No. ML14083A586.

[NEI] Nuclear Energy Institute. 2005. Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document. Revision A. Washington, DC: NEI. NEI 05-01. November 2005.

79 p. ADAMS No. ML060530203.

[NRC] U.S. Nuclear Regulatory Commission. 1975. Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants. Revision 0. Washington, DC: NRC.

NUREG-0800. November 1975. Available by request at

<http://www.nrc.gov/reading-rm/pdr.html> (accessed 21 October 2014).

[NRC] U.S. Nuclear Regulatory Commission. 1988. Individual Plant Examination for Severe Accident Vulnerabilities10 CFR 50.54(f). Washington, DC: NRC. Generic Letter No. 88-20.

November 23, 1988. Available at

<http://www.nrc.gov/reading-rm/doc-collections/gen-comm/gen-letters/1988/gl88020.html>

(accessed 21 October 2014).

[NRC] U.S. Nuclear Regulatory Commission. 1990. Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants, Final Summary Report. Washington, DC: NRC.

NUREG-1150. December 1990. ADAMS No. ML100780066.

[NRC] U.S. Nuclear Regulatory Commission. 1991. Individual Plant Examination of External Events for Severe Accident Vulnerabilities. Washington, DC: NRC. Generic Letter No. 88-20, Supplement 4. June 28, 1991. Available via the NRC Public Document Room by e-mail to pdr@resource@nrc.gov.

[NRC] U.S. Nuclear Regulatory Commission. 1994. Memorandum from J. Murphy, NRC, to S.A. Varga, NRC.

Subject:

Review of Fermi 2 Individual Plant Examination (IPE) Submittal Internal Events. Undated.

[NRC] U.S. Nuclear Regulatory Commission. 1997a. Regulatory Analysis Technical Evaluation Handbook. Washington, DC: NRC. NUREG/BR-0184. January 1997. 308 p.

ADAMS No. ML050190193.

F-59

Appendix F

[NRC] U.S. Nuclear Regulatory Commission. 1997b. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance Parts 2-5, Final Report.

NUREG-1560, Volume 2. Washington, DC: NRC. December 31, 1997.

ADAMS No. ML0635550228.

[NRC] U.S. Nuclear Regulatory Commission. 2000a. Letter from A.J. Kugler, NRC, to W.T. OConner, DECo.

Subject:

Fermi 2Completion of Licensing Action for Generic Letter (GL) 88-20, Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. (TAC No. M83621). July 5, 2000. Available via the NRC Public Document Room by e-mail to pdr@resource@nrc.gov.

[NRC] U.S. Nuclear Regulatory Commission. 2000b. Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. Washington, DC: NRC.

Regulatory Guide 1.183. July 2000. ADAMS No. ML003716792.

[NRC] U.S. Nuclear Regulatory Commission. 2002. Perspectives Gained from the Individual Plant Examination of External Events (IPEEE) Program. Washington, DC: NRC.

NUREG-1742. April 2002. ADAMS No. ML021270070.

[NRC] U.S. Nuclear Regulatory Commission. 2004a. Letter from D.P. Beaulieu to W.T. OConner, Jr., DetroitEd.

Subject:

Fermi 2Issuance of Amendment, Re: Selective Implementation of Alternative Radiological Source Term Methodology. (TAC No. MB7794).

September 28, 2004. Available via the NRC Public Document Room by e-mail to pdr@resource@nrc.gov.

[NRC] U.S. Nuclear Regulatory Commission. 2004b. Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission. Revision 4. Washington, DC: NRC. NUREG/BR-0058.

September 2004. 56 p. Available at <http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0058/> (accessed 21 October 2014).

[NRC] U.S. Nuclear Regulatory Commission. 2009. An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities.

Revision 2. Regulatory Guide 1.200. March 1, 2009. 191 p. ADAMS No. ML090410014.

[NRC] U.S. Nuclear Regulatory Commission. 2010. Letter from T. McGinty, Director, NRC, to all holders of an operating license.

Subject:

NRC Information Notice 2010-18: Generic Issue 199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants. September 2, 2010. ADAMS No. ML101970221.

[NRC] U.S. Nuclear Regulatory Commission. 2012a. Letter from E. Leeds, Director, NRC, to All Power Reactor Licensees.

Subject:

Request for information pursuant to Title 10 of the Code of Federal Regulations 50.54(f) regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of insights from the Fukushima Dai-ichi accident.

March 12, 2012. ADAMS No. ML12053A340.

[NRC] U.S. Nuclear Regulatory Commission. 2012b. State-of-the Art Reactor Consequence Analyses (SOARCA) Report. Washington, DC: NRC. NUREG-1935. November 2012.

ADAMS No. ML12332A057.

[NRC] U.S. Nuclear Regulatory Commission. 2012c. Letter from E. Leeds, Director, NRC, to All Operating Boiling-Water Reactor Licensees with Mark I and Mark II Containments.

EA-12-050.

Subject:

Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents. March 12, 2012. ADAMS No. ML12054A694.

F-60

Appendix F

[NRC] U.S. Nuclear Regulatory Commission. 2013. Letter from E. Leeds, Director, NRC, to all operating boiling-water reactor licensees with Mark I and Mark II containments. EA-13-090.

Subject:

Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions. June 6, 2013.

ADAMS No. ML13143A321.

[NRC] U.S. Nuclear Regulatory Commission. 2014a. Letter from M. Wentzel, Project Manager, NRC, to V. Kaminskas, Site Vice President, DTE.

Subject:

Requests for Additional Information for the Review of the Fermi 2 License Renewal ApplicationSevere Accident Mitigation Alternatives. November 18, 2014. ADAMS No. ML14308A358.

[NRC] U.S. Nuclear Regulatory Commission. 2014b. Letter from T.J. Wengert, Senior Project Manager, NRC, to J.H. Plona, Senior Vice President and Chief Nuclear Officer, DTE.

Subject:

Fermi Nuclear Plant, Unit 2Staff Assessment of the Flooding Walkdown Report Supporting Implementation of the Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-ichi Accident. (TAC No. MF0228). June 18, 2014. ADAMS No. ML14143A235.

[NRC] U.S. Nuclear Regulatory Commission. 2014c. Letter from M. Wentzel, Project Manager, NRC, to V. Kaminskas, Site Vice President, DTE.

Subject:

Summary of the Severe Accidents Mitigation Alternatives Environmental Site Audit Related to the Review of the License Renewal Application for Fermi 2. (TAC No. MF4064). November 17, 2014. ADAMS No. ML14294A812.

[NRC] U.S. Nuclear Regulatory Commission. 2015a. Letter from M. Wentzel, Project Manager, NRC, to V. Kaminskas, Site Vice President, DTE.

Subject:

Requests for Additional Information for the Environmental Review of the Fermi 2 License Renewal ApplicationSevere Accident Mitigation Alternatives. February 3, 2015. ADAMS No. ML15026A307.

[NRC] U.S. Nuclear Regulatory Commission. 2015b. Letter from B. Wittick, NRC, to V. Kaminskas, Site Vice President, DTE.

Subject:

Request for Additional Information for the Environmental Review of the Fermi 2 License Renewal ApplicationSevere Accident Mitigation Alternatives. April 9, 2015. ADAMS No. ML15092A945.

F-61

NUREG-1437 Generic Environmental Impact Statement for License Renewal of Nuclear Plants September 2016 Supplement 56 Regarding Fermi 2 Nuclear Power Plant Volume 2

v t e Letter Sequence Acceptance Review
TAC:MF4222, (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance, Acceptance Supplement Administration Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance Questions 29 October 2014 26 November 2014 11 March 2015 13 March 2015 19 March 2015 11 March 2015 13 March 2015 19 March 2015 27 April 2015 26 March 2015 26 March 2015 26 March 2015 27 April 2015 2 April 2015 13 May 2015 22 April 2015 20 May 2015 13 May 2015 1 May 2015 15 May 2015 13 May 2015 13 May 2015 26 May 2015 15 May 2015 11 June 2015 18 May 2015 11 June 2015 21 May 2015 9 June 2015 20 May 2015 11 June 2015 6 July 2015 6 July 2015 6 July 2015 1 September 2015 14 January 2016 10 May 2016 Answers 24 October 2014 18 November 2014 1 December 2014 30 December 2014 5 January 2015 20 January 2015 15 January 2015 5 February 2015 12 February 2015 30 January 2015 9 January 2015 5 March 2015 30 January 2015 5 March 2015 19 February 2015 8 May 2015 19 May 2015 6 July 2015 20 August 2015 24 September 2015 10 March 2016 19 July 2016 Results Approval, Approval, Approval, Approval, Approval, Approval Other: ML14195A221, ML14237A194, ML15030A229, ML15076A468, ML15092A224, ML15092A243, ML15098A175, ML15341A261, ML16005A399, ML16011A009, ML16011A011, ML16011A012, ML16011A013, ML16011A014, ML16011A032, ML16011A036, ML16187A173, ML16270A567, ML16330A117, NRC-16-0014, Comments on the Nrc'S Safety Evaluation Report with Open Items Related to the License Renewal, NRC-16-0061, DTE Response to NRC Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools.
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