Text

Comment (14) of Art Myatt Opposing the Construction of Fermi 3 and the Relicensing of Fermi 2 for the 2025-2045 Timeframe
	ML16011A008
Person / Time
Site:	Fermi
Issue date:	01/01/2016
From:	Myatt A; Alliance to Halt Fermi 3
To:	James Danna, Gallager C, Keegan E N; Rules, Announcements, and Directives Branch, License Renewal Projects Branch 2
References
	80FR68881 00014, NRC-2014-0109
	Download: ML16011A008 (36)
	v • d • e

Gallagher, Carol/From:Sent:To:Cc:

Subject:

Attachments:

Art Myatt <almyatt@yahoo.com>

Friday, January 01, 2016 2:24 PMKeegan, Elaine; Danna, James; Gallagher, CarolKeith Gunter; Ethyl Rivera[ExternalSender]

Fermi 2 GElS Supplement 56 commentsATHF3_Fermi 2_EIS Comments.pdf Attached please find comments from Alliance to Halt Fermi 3.Arthur MyattATHF3 board memberPower yields nothing without a struggle.

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/ ........

7I-cz~SUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM -03Add= ('k1 U.S. Nuclear Regulatory Commission (NRC)Docket Nos. 50-341; NRC-2014-0109 Fermi Nuclear Power Plant, Unit 2 (Fermi 2)License Renewal Application (LRA) Environmental ReviewApplicant/Licensee:

DTE Electric Company (DTE)Generic Environmental Impact Statement

[GEIS] for License Renewalof Nuclear Plants (NUIREG-1437), Supplement 56, Regarding Fermi 2Nuclear Power Plant, Vol. 1 and 2(Draft Report for Comment)also known as:Draft Supplemental Environmental Impact Statement (Draft SEIS or DSEIS)December 28, 2015Public CommentSubmitted to:http ://www.Re gulations.

govDocket ID NRC-2014-0109 Submitted by:Alliance to Halt Fermi 3 (ATHF3)Board of Directors

Livonia, Michigan U.S.A.http://www.athf3.org

==

Introduction:==

Alliance to Halt Fermi 3 (ATHF3) is a 501(c)(3) organization based inSoutheast Michigan representing numerous individual andorganizational

members, the majority of whom reside within fifty (50)miles of DTE's Fermi 2 nuclear reactor and are subjected to its adverseenvironmental impacts..

In addition to opposing the construction ofFermi 3, the Alliance unconditionally opposes the relicensing of Fermi 2for the 2025 -2045 timeframe and calls on DTE to:1) Withdraw its Fermi 2 License Renewal Application, and2) Shutdown the Fermi 2 reactor as soon as possible.

Concurrently, as stated in our Bylaws, we encourage and advocate forthe development and expanded use of sustainable,

reliable, clean, safeand affordable alternatives to nuclear power, such as renewable energysources and robust energy efficiency and conservation programs.

Preface:In addition to the specific items that follow, we present these commentsto document our opposition to the NRC's blanket overuse andmisapplication of assessments and findings from the GenericEnvironmental Impact Statement (GEIS) and the determination ofcertain environmental impacts to be "generic" to all nuclear powerplants, ". ..or in some cases, to plants having specific characteristics

[shared in common] such as a particular type of cooling system."(Scoping Summary).

Due to the NRC's "copy and paste" approach fordeveloping the Draft SEIS, we contend that numerous plant-specific, site-specific environmental impacts associated with the continued operation of Fermi 2 have been incorrectly designated as "generic" (Category

1) resulting in such issues being dismissed as falling outsidethe scope of the NRC' s Fermi 2 LRA Environmental Review.Equally, the narrowly-defined scope of the NRC's Fermi 2 LRA SafetyReview serves, by design, to eliminate the consideration of numeroussafety, security, and emergency planning/preparedness issues which thevast majority of members of the public would consider as pertinent andvital to the question of license renewal.Therefore, it is in that context that ATHF3 wholly reiterates andresubmits our official Written Public Comment from August 29, 2014which pertained to the NRC's Scoping Process for the Draft SEISrelated to the proposed Fermi 2 federal relicensing action. ATHF3 'spublic submission from 2014 is on file with the NRC and is alsoavailable for viewing at: http://www.ATHIF3

.org/Fermi-2.

Let it be clear we continue to stand by our previous assessment that theproposed federal relicensing action would be "inimical..

.to the healthand safety of the public."

(Atomic Energy Act (ABA), 42 U.S.C. §2133(d)).

Further, ATHF3 contends that the Draft SEIS is deficient suchthat further analysis is called for, pursuant to federal law (NEPA).Through omissions, errors and misleading assumptions, the NRC hasfailed to comply with the "hard look" requirements established forproposed federal actions.

ITEM #1Uranium mining and processing:

(offsite fuel cycle front end impacts during the period of extendedoperation)

The Atomic Energy Act (AEA) precludes the U.S. NRC from licensing any newnuclear power plant or re-licensing any existing nuclear power plant if itwould be "inimical...

to the health and safety of the public."

42 U.S.C. §2133(d).The Draft Supplemental Environmental Impact Statement (DSEIS) citesnumerous reports on evidentiary

reviews, assessments, and the results ofthose actions.

It is glaringly deficient,

however, by the absence of animportant area in which the relicensing of DTE Electric Company's Fermi 2 nuclear reactor does, and would continue to, negatively impactthe health and safety of "the public" in direct contradiction to the above-cited United States Code.While repeatedly relying on the Generic EIS and applying assessments and "generic environmental impacts" from data pertaining to numerousnuclear power plants across the country, the NRC has selectively limitedits documented reviews and assessments to environmental impactswithin the narrow geographical/physical confines of the Fermi 2 plantand its surrounding environs.

Excluding certain off-site issues from theScope of the SEIS and Environmental Review of the Fermi 2 LicenseRenewal Application (LRA) has resulted in totally eliminating fromconsideration several important environmental issues affecting the healthand safety of the public through negative

physical, economic, andenvironmental justice impacts.

While Federal law (NEPA) requires the NRC to apply a "hard look"analysis for evaluating the reasonably foreseeable environmental andpublic health consequences of the proposed relicensing action and toconsider the potential impacts of both mitigating and fundamental alternatives, it is noted that the NRC did not prepare a separatebiological assessment for the proposed Fermi 2 license renewal.1 In itsOctober 20th lefter to the Fish and Wildlife

Service, the NRC states that"..... the SEIS constitutes the NRC's biological assessment

....The Draft SEIS for the Fermi, Unit 2 LRA states that it "considers' theenvironmental impacts across several impact categories, including landuse, visual resources, air quality and noise, geologic environment, waterresources, ecological resources, historic and cultural resources, socio-economics, human health, environmental

justice, and wastemanagement."

In our review of the Draft SEIS, however, no mentioncan be found of a realistic analysis of the significant offsite public healthconsequences of front end activities related to the nuclear fuel cycleduring the proposed license renewal period. In particular, ATHF3contends that the Fermi 2 relicensing would result in widespread impactsin resource-specific regions due to additional Uranium Mining, Milling,Processing and Transportation.

In-scope impacts would fall into thecategories of public health, environmental

justice, land use, socio-economic justice and the often overlooked biological effects.The Human Health, Environmental,

Cultural, and Socio-Economic Effects resulting from the contamination of human populations, surfaceand groundwater and the surrounding environment are not addressed inthis document, albeit disproportionately high environmental impactsfrom this activity are well recognized and documented.

The fact thatthey occur outside the regional area of Fermi 2 (primarily in low-income or minority communities, predominantly on Aboriginal or indigenous lands) should not automatically exclude them from the identification, review, and assessment of environmental

impacts, impacts that primarily affect geographically dislocated or dispersed minority or low-income populations, indigenous populations and their habitats.

Reference:

1. Letter to Messrs. Tom Melius and Scott Hicks, Fish and Wildlife ServiceRegarding the Availability of the Fermi Draft SEIS, October 20, 2015, fromDavid J. Wrona, Chief, Environmental Review and Guidance UpdateBranch, Office of NRC Regulation.

ITEM4#2High-Level Radioactive Waste (HLRW) impacts during the periodof extended operation:

The NRC's conclusions are truly remarkable.

It is reasonable toestimate that during the 20-year license renewal period, Fermi 2 wouldgenerate an amount of spent nuclear fuel (HILRW) from normaloperations equal to about 50% of that which it produced during theoriginal 40-year operating license period. Concurrently, the self-described "structured coordination" between the nuclear industry and thefederal regulator appears to be heading towards a condition ofpotentially indefinite "continued storage" of spent nuclear fuel with notechnical specifications in place, now or for the foreseeable future.As a consequence of several re-racks implemented as part of anextremely misguided policy, the Fermi 2 spent fuel pool currently storesapproximately 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.

Adding to the danger is that Fermi 2's GE Mark I BWR design locatesthe spent fuel pool in an elevated position inside what is now an age-degraded structure.

Fermi 2 has a uniquely large spent fuel poolcapacity relative to other boiling water reactors in the U.S. commercial fleet; hence Fermi 2 has the potential for uniquely severe consequences in the event of a severe accident.

Thus, the impact of spent nuclear fuel generation and storage at Fermi 2is a plant-specific issue which pertains directly to the license renewalperiod. To get some idea of how much IILRW is at issue here, ATHF3did our own calculations which we submit for the record. We note aswell that we had to refer back to a 2002 U.S. Department of Energy(DOE) document and then extrapolate.

Apparently, the NRC does notrequire licensees such as DTE to disclose exactly how much HLRWthey have generated at any given time, so additionally, ATHAF3 calls formore accountability and transparency in the NRC's Final SEIS.The 2002 DOE Yucca Final EJS, Tables A-7 and A-8, revealed that byspring 2010, Fermi 2 would have 523 metric tons of irradiated nuclearfuel stored on site. Fermi 2 generates about 20 metric tons moreirradiated nuclear fuel each year it operates.

Therefore, by spring 2016,Fermi 2 will have 20 metric tons/year X 6 years =120 metric tons, plusthe 523 metric tons that already existed, for a grand total of 643 metrictons by spring 2016.2016 to 2045 is 29 more years. 29 years X 20 metric tons/year

=580metric tons, for a grand total by 2045 of 580 +/- 643 =1,223 metric tons.The above metric ton figure for 2045 can be converted to U.S. tons bymultiplying by 1.1023. 1,223 metric tons X 1.1023 =1,348 U.S. tons.

ITEM# 3Public Health impacts during the period of extended operation:

Fermi 2 violates the most basic human right, the right to life:The U.S. Nuclear Regulatory Commission (NRC) gives some limitedacknowledgment of this human right violation in the Generic EIS forLicense Renewals as follows:"Sodium hypochlorite is added as a biocide to the circulating water tolimit biofouling of condenser tube surfaces."

"The plant's NPDES permit does not impose any thermal effluents limits, such as either a maximum temperature or a change in receiving water temperatures per unit of time."~"All nuclear plants were licensed with the expectation that they wouldrelease radioactive material to both the air and water during normaloperations."

"The radioactive material removed from the effluents is either releasedinto the environment or converted into a solid form for disposal at alicensed radioactive disposal facility."

"Cumulative impacts on the terrestrial Ecology would be Moderate toLarge. The cumulative impacts on the aquatic resources would beLarge."From NUREG-2 105 (Fermi 3 EIS) acknowledging the serious diseasecausing impact of reactor operations on public health:"Public and occupational health can be compromised by activities at theFermi 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...

These microorganisms could give rise to potentially serious humanconcerns, particularly at high exposure levels."

(v 1, p 2.229)The most fundamental violation of the right to life was the decision, made in secret by a few individuals from the U.S., U.K. and Canada,to build atomic fission reactors in order to generate nuclearweapons material and that the entire biosphere would be irradiated and the public would be misled as to the seriousness of it:Based on the National Academy of Sciences, Commiftee on theBiological Effects of Ionizing Radiation (BEIR):At 100 Reins or 1 Sievert (Sv) the risk of cancer is 1 in 10.At 10 Reins or 100 mSv the risk of cancer is 1 in 100.At 1 Rem or 10 mnSv the risk of cancer is 1 in 1,000.Low dose radiation is defined as near zero to 100 mnSv.The BEIR 2007 report predicts cancer and genetic damage below 20mSv per year and subsequent research indicates that there is an increased magnitude at lower doses than previously seen. Japan (after themeltdown of 3 GE Mark 1 reactors) is allowing (and coercing) return toFukushimna evacuated areas and has raised the allowable dose from 1mSv per year to 20 mSv per year. For women and children (girls higherthan boys), the risk of cancer is much higher than for a 25 year oldhealthy white adult male (the standard used since the flawed studies--..-

begun 5 years after and based only on estimates of external radiation---

of Hiroshima and Nagasaki victims).

Japanese returning to evacuated areas will have a risk of cancer of 1 in 500 at the 20 mSv dose, but a 5year old girl will have a risk of cancer of 1 in 100. That risk willmultiply for each year of exposure.

Furthermore, the above statements assess external gamma radiation exposure only and leave out alpha andbeta particles that are breathed in or ingested in air, water and food andbecome a continuing internal emitter source not measured.

Bearing in mind that man-made ionizing radiation can cause almost thewhole spectrum of human illness, that it is cumulative, that it combineswith natural occurring radiation in the environment such as radon, andthat it combines with the huge load of ionizing radiation from uraniummining and milling, nuclear weapons manufacture and testing, as well asthe excessive use of medical X-rays and nuclear medicine procedures.

All of these items in this list have been linked together by the commonthread of government and media misrepresenting the real risk in order topromote nuclear weapons/nuclear energy production as a normal,desirable, acceptable part of modern life. The attitude of governments and the nuclear industry has been: Don't measure doses, and conflate"allowable" with "safe."The NRC addresses the risk of catastrophic failure of containment ofFermi 2 as though it existed in isolation and not one of a total of 391reactors operating in 30 countries.

Fermi 2's license renewal would addto the cumulative risk of catastrophic failure at a greater frequency worldwide and of global fallout.

From the landmark book CHERNOBYL."

Consequences of the Catastrophe for People and the Environment (http ://stopnuclearpoweruk.net/sites/default/flles/Yablokov

%2OChernobyl%20book.pdf):

".... For the past 23 years it has been clearthat there is a danger greater than nuclear weapons concealed withinnuclear power. Emissions from this one reactor exceeded a hundredfold the radioactive contamination of the bombs dropped on Hiroshima and Nagasaki.

No citizen of any country can be assured that he or she can beprotected from radioactive contamination.

One nuclear reactor canpollute half the globe. Chernobyl fallout covered the entire NorthernHemisphere."

Fermi 2 violates the right to life of this generation and all futuregenerations as seen in the effort to abandon radioactive material:

The process of the U.S. NRC's Supplemental Environmental ImpactStatement (SEIS) on the license application (long languishing and longopposed) for a deep nuclear underground dump (Yucca Mountain) recently concluded the required public comment period. This deepunderground dump is for high-level radioactive material (withdrawn nuclear fuel rods) -- lethal in minutes and dangerous for up to a millionyears. We have approximately 72,000 tons and Canada about 50,000tons of that material.

Approximately 600 tons sit outside of containment next to Fermi 2 near Monroe, Michigan.

If a centralized repository and/or interim regional repositories were to be implemented, we wouldhave Fukushima Freeways with this material on highways, barges andrail lines moving across the country.

The push for all of the above ismoney to be made. Utilities want the burden of management of thismaterial off their books. It then becomes the taxpayers' burden. Theutilities then produce more. Worse though is the potential for accidents, public exposure to traveling radiation, terrorist attack, and possiblyrendering areas or regions uninhabitable.

The overall issue regarding the proposed Yucca Mountain NuclearWaste Repository is that the idea is without substance in fact, whenconsidering science and engineering, as there is no data from experience-to validate hypotheses about the behavior of abandoned man-made radionuclides over up to a million years. The oniy twoconmnenced underground dumps have had unresolved failures inGermany and at WIPP near Carlsbad, NM. Both have suspended operations.

What is known is that ionizing radiation cannot be turnedoff, must be shielded and monitored through every generation intoeternity, unless at some future time a better management of theaccumulated and accumulating nuclear material is discovered, validated, and implemented.

Until then, it is the moral obligation of this generation to stop making radioactive material and to educate succeeding generations on the best shielding and monitoring practices.

The currentbest practice (not embraced by the NRC and the nuclear industry) isHardened Onsite Storage (HOSS). Furthermore, it is disingenuous ofnuclear advocates and profiteers who have little financial risk or liability in the production of the nuclear waste legacy (due to federal loanguarantees, the Price-Anderson Act, rate payer bailouts, federalownership of nuclear waste once removed from the utilities' site) toignore the cost burden on this and all future generations of themanagement of the nuclear waste utilities are producing.

Utilities bearlittle financial risk, gain the profit, and the public carries the financial burden that has yet to be calculated or even discussed.

Most important,

however, is the known impact of ever expanding exposure to man-maderadionuclides:

broad spectrum

illness, morbidity, and genetic mutations.

Bottom line, continuing to produce lethal withdrawn reactor fuel rodsknowing they are lethal with no plan for their management throughevery generation into eternity is inexcusable and constitutes an extremebetrayal of the public trust. Such behavior on the part of DTE and NRCwith regard to advancing the Fermi 2 license renewal actiondemonstrates

arrogant, dangerous and reckless disregard for thisgeneration and all future generations of life on Earth.

ITEM# 4NRC's Solar Alternative analysis fails the "hard look" test:The NRC's rejection of solar power as a viable alternative to nuclearpower is both erroneous and based on obsolete standards.

"Solar PV resources in the ROJ [Region of Influence]

and across Michigan rangefrom 4.0 to 4.5 kilowatt hours per square meter per day (kWh/mag/d)

(NREL2013c). Economically viable solar resources are considered to be 6.75 kWh/m2/dand greater (BLM and DOE 2010)." (Draft SEIS, p. 2-13).Let's see just how wrong the NRC's Draft SEIS is. Solar power inGermany consists almost exclusively of photovoltaics (PV) andaccounted for an estimated 6.2 to 6.9 percent of the country's net-electricity generation in 2014. ("Solar Power in Germany" article,Wikipedia).

Out of its total 13,041 MW of electric generating capacity in 2005(1.22% of the U.S. total), DTE Energy produces 6 1.3% from coal,16.4% from natural gas, 11.7% from oil, 9.3% from nuclear, and 0.2%from biomass.

DTE Energy owns power plants in Alabama, California,

Illinois, and Michigan; 95.5% of the company's generating capacitycomes from power plants in Michigan.

("DTE Energy" article,Wikipedia).

The Fermi 2 Nuclear Power Plant is owned and operated by DTE andprovides electricity through the Midcontinent Independent SystemOperator (MISO) to an 11-county service area in southeastern Michigan.

This service area constitutes the Region of Influence (ROI) for theNRC's analysis of replacement power alternatives.

(Draft SEIS at 2-5).

"Solar insolation" is a measure of solar radiation energy received on agiven surface area in a given time, or in other words, how much sunlightis shining down on us. For comparison, Germany has significantly lesssunlight to work with than does Michigan but still manages to use solarPV panels to generate much of its electricity.

As a matter of fact,Germany's solar resources are closer to 3.0 kWh/m2/d than to 4.0 -4.5kWh/m2/d. Therefore, if the equivalent of Germany's 2014 solar PVpanels were installed within DTE's service area in Michigan, theinstalled solar capacity would have generated between 8.2% to 10.3% ofMichigan's electrical power. As shown above, that is roughly the samepercentage of power now provided by Fermi 2. In other words, the solaralternative has already proved in the real world to be viable both as autility-scale source of power and as a potentially cost-effective replacement for Michigan's nuclear plants.(See "solar insolation world map," Internet search;http ://solargis.info/doc/_pics/freemaps/1000px/dni/So larGIS- Solar-map-DNI-World-map-en.png).

On the issue of grid reliability, the NRC points out that solar panelsprovide intermittent power and do not provide baseload power the way anuclear reactor does. This is true. However, solar panel output is veryclosely matched with peak power demand. When solar panels providepredictable peak power, the need for baseload power is greatly reduced.Again, Germany is an excellent example of how solar panels can beintegrated with the electrical grid, thus entirely eliminating the need fornuclear power.ATHF3 contends that the NRC has chosen to ignore the well-known examples of countries such as Germany which successfully use renewable solar solutions to displace conventional power sources on amodern electrical grid despite such countries having significantly lesssunlight to work with than is available in Michigan.

It would be eveneasier for Michigan to make solar work.The NRC has also chosen to ignore other well-known economic factsand trends which favor solar power over nuclear power looking ahead tothe 2025 -2045 timeframe.

Using an outdated figure from 2010 for theintensity of sunlight required for PV panels to be "economically viable"is just absurd. The price of solar panels has dropped precipitously in thelast five years, while the efficiency of the average commercial panel hasincreased.

As a result, the fact is that solar panels today areapproximately at grid parity with steam-generated electricity, and thereis broad agreement that the price of solar panels will continue toimprove for customers in the coming years.In short, solar power IS a viable alternative to nuclear power. The NRCis completely wrong to dismiss it.ITEM #5NRC omits a "hard look" at the future demand for electricity:

In the Environmental Impact Statement (Fermi 3 EIS, 2013) for theproposed Fermi 3 nuclear power plant, there is an entire section (Section8) entitled "Need for Power." It discusses power planning in Michigan, power demand and power supply, giving references with specificprojected figures out to 2025. Surely, specific figures for projected electrical demand are just as relevant for relicensing Fermi 2 as forlicensing Fermi 3, but there is no such section in the Fermi 2 Draft SEIS.

According to data published by the U.S. Energy Information Administration (EJA), the amount of electricity generated in Michiganover the ten year period from 2005 to 2014 actually declined by roughly1% per year, more exactly, an average annual decline of 0.985%. Thereare other ways of looking at the data which would show an even steeperdecline, such as over the last seven or eight years coinciding with theglobal financial crisis and severe recession.

Detailed figures are shownat an ATHIF3 website:https ://athf3

.wordpress

.com/20 15/12/1 6/michigans-electricity-industry.

If this declining trend were to continue through 2025, the difference between electricity generated in 2014 (the last year for which the EIAhas data) and 2025 would be 21 million megawatt-hours.

To make thisunambiguously clear -the amount of electricity generated in 2025would be 21 million megawatt-hours less than was generated in 2014.As it happens, 19-21 million megawatt-hours is the combined annualgenerating capacity of both Fermi 2 and the proposed Fermi 3, usingcapacity factors of 80% to 90%. The straightforward conclusion if thecurrent trend continues is that, by 2025, neither Fermi 2 nor Fermi 3~would be needed to generate electricity.

ATHF3 understands that the NRC heavily relies on other agencies tocalculate future demand for electricity in the region. For transparency, the NRC should therefore specify which agencies and studies it relieson. Then, members of the public can evaluate whether those projections and forecasts are in line with reality.

If it turns out that the demand formore electrical generating capacity does not exist in the actual future,then it would make much more sense to close the Fermi 2 plant when its original 40-year operating license expires than to continue operating theunnecessary power plant for an additional twenty years until 2045.ITEM #6NRC's Energy Efficiency Alternative analysis fails the "hard look"test:"Michigan has only begun to scratch thle suiface of energy savings.

Our energyefficiency industry can secure savings at a 2% standard per year very easily, withexisting technology."

(Michigan Energy Efficient Contractor's Coalition, Comments to the questionabout the feasibility of energy efficiency in Michigan

-MI Energy Report 2012)According to the MI Energy Report 2012, the Michigan Public ServiceCommission (MPSC) reports that the overall cost of conserved energythrough BO (Energy Optimization) programs was $20/megawatt hour.The MPSC reports that every dollar spent on BO returns $3.55 -$4.88 insavings.

It is noteworthy that the utilities have exceeded the EG targetseach year since 2009 with the passage of new state legislation (PA 295).(http ://www.michigan.

gov/energv).

In November 2013, at the behest of the MPSC and DTE EnergyCompany, GDS Associates, Inc. (an engineering

& consulting firm)released the Michigan Electric

& Natural Gas Energy Efficiency Potential Study. It concluded that a very large cost-effective energyefficiency potential remains untapped.

According to the study, there is a10-year achievable potential of 1.5% per year in electrical savings (thecurrent standard is 1.0% per year). The study notes that the maximumeconomically cost-effective potential was more than double this amount.Of course, what is technically achievable is even greater but givenrealistic achievability, there is sufficient cause to push for higher EOstandards that will begin to pave the way to greater long-term sustainability.

The 10-year projection looked at the period of January2014 -December 2023.In a February 2015 letter to Michigan's Governor Rick Snyder, acoalition of four energy efficiency organizations (MI Energy Innovation Business

Council, MI Solid State Lighting Association, US GreenBuilding Council -MII Chapter, and American Council for an EnergyEfficient Economy) concluded that increasing the EQ goal to 1.5% peryear would yield a $22 billion impact on Michigan's economy over thenext ten years. This is $14 billion more than the business-as-usual projections under the current 1% goal. Increasing the goal would alsoresult in an additional 100,000 job years and $5 billion in additional employment compensation.

According to Martin Kushler, Ph.D. with the ACEEB (American Council for an Energy-Efficient Economy),

the rationale for energyefficiency as a utility system resource is simply this:1) Utility systems need to have adequate supply resources to meetcustomer demand.2) To keep the system in balance, you can add supply resources, reduce customer demand, or a combination of the two.3) In virtually all cases today, it is much cheaper to reduce customerdemand than to acquire new supply resources (we save electricity for about 1/3 the cost of producing it through a new power plant).4) Over a dozen states (including Michigan) are saving enoughenergy with their utility programs to displace existing powerplants.In a special message from Michigan's Governor Rick Snyder (March2015), he urges a call to action: "We should meet at least 15% more of Michigan's energy needs in the next decade by eliminating energywaste."An ambitious plan that includes clean, renewable energy sources plusthe achievable elimination of energy waste through energy efficiency programs could result in 40% of our electricity coming from renewables and efficiency improvements by 2025. The energy efficiency component of this pie chart is 21%. (Martin Kushler, ACEEE report).Notably, Members of the U.S. House of Representatives have introduced and are co-sponsoring a new initiative which is even more ambitious, citing the well-known research of Dr. Mark Jacobson at StanfordUniversity.

Such research is applicable to the country as a whole as wellas to Michigan specifically, as the analysis includes a unique roadmapfor each state to achieve a 100% efficient, renewable-based energysystem. The Stanford research conclusions are bolstered by independent work conducted by the Rocky Mountain Institute (RMI) and the Institute for Energy and Environmental Research (IEER), among others.(http://www.congress.gov/bill/ll14th-congress/house-resolution/5 40/cosponsors)

Meanwhile, the NRC "considered but dismissed" the role that energyefficiency and conservation pro grams (demand-side management) couldplay as a reliable, standalone alternative to the proposed Fermi 2 licenserenewal.

The NRC has irresponsibly issued a generic conclusion that"while the [energy efficiency and conservation]

potential in the UnitedStates is substantial,"

such programs are "unlikely" to be "implemented expressly to replace or offset a large baseload generation station."

(Fermi 2 DSEIS at 2-14, 2-15 citing GEIS).So, even while acknowledging the MPSC's 2013 determination thatenergy efficiency programs potentially could reduce demand in theDTE service area by approximately 800 MW [(2/3 of Fermi 2's output)]

by 2023," the NRC nevertheless explicitly eliminated the energyefficiency and conservation alternative from "detailed study" in theFermi 2 Draft SEIS. (Fermi 2 DSEIS at 2-14, 2-15). Why does thefuture demand for electricity lie outside the scope of whether or not torelicense Fermi 2 for another 20 years?Clearly, as indicated, ATHF3 has a genuine dispute with the NRC'sgeneric determinations pertaining to the feasibility of replacing Fermi 2with commercially-available energy efficiency technologies andrenewable energy sources.

We believe it is short-sighted to dismiss thepotential for achieving the kinds of savings through energy efficiency that have been demonstrated by recent studies.

The future of energy inMichigan is at a crossroads.

We expect the NRC to take another look atthis obvious oversight and evaluate in depth the potential of eliminating energy waste through energy efficiency before granting a 20-yearoperating license extension to DTE for the Fermi 2 nuclear reactor.ITEM# 7Environmental Justice impacts on Monroe County residents:

Pertaining to Executive Order 12898 and the Environmental Justicerequirements under NIEPA and 10 CFR Part 51, ATHF3 contends thatthe Fermi 2 License Renewal would cause significant and cumulative adverse impacts to residents of Monroe County, Michigan and that suchimpacts would be disproportionately high as a function of a resident's relative proximity to the point source of emissions, effluents and routinereleases from normal operations.

Furthermore, during the proposedperiod of extended operation, Monroe County residents living nearby theFermi 2 facility would face a disproportionately higher risk of exposure to radioactive contaminants in the event of an unplanned off-site releasecaused by a severe accident.

ATHF3 contends it is no accident that industrial facilities and powerplants such as Fermi 2 are targeted for construction and license renewalin minority and/or lower-income communities such as Monroe County,thus subjecting marginalized populations to disproportional impactsfrom cumulatively higher doses of toxic and radioactive pollutants:

Thepredictable consequences show up in community public health metrics.Indeed, it is already the case that a longitudinal public health studyindicates the residents of Monroe County suffer from morbidity andmortality at higher rates than the u.S. average, and such disturbing historical data points and trends are correlated with the specific timeperiod during which the Fermi 2 nuclear plant has been in operation.

(Mangano, Docket Nos. 50-34 1; NRC-2014-0 109). The NRC has goneout of its way to dismiss and discredit the peer-reviewed research ofpublic health professionals in the U.S. and Europe; the NRC's realagenda is transparent, even while the NRC itself is not. ATHF3contends that further analysis is called for pursuant to federal law priorto issuance by the NRC of a license extension for the continued operation of Fermi 2 beyond 2025. (NEPA).ITEM# 8Refurbishments:

recent onsite events require a "hard look":ATHF3 contends that a pattern of unplanned adverse events whichoccurred in 2015 calls into question the determination by DTE and theNRC that there is no need to undertake any major refurbishment orreplacement activities associated with license renewal in accordance with 10 CFR Part 54.21 and within the scope of 10 CFR Part 51. Aspart of the license renewal application

process, DTE performed an onsiteevaluation of major passive structures,

systems, and components (SSCs)such as BWR recirculation piping. As a result of its evaluation, "DTEdid not identify the need" to repair or replace any major SSCs in order toprovide adequate protection and reasonable assurance of safety to"support the continued operation of Fermi 2" beyond 2025. Likewise, the NRC therefore has "not discussed" refurbishment-activities associated with license renewal in the Draft SEIS. (Fermi 2 DSEIS at 2-2).ATHF3 contends that new and significant information from LicenseEvent Reports (LERs) of adverse incidents in 2015 renders DTE'sassessment premature and inaccurate, and consequently, we contend thatthe NRC' s omission of discussion and further analysis in the Draft SEISrepresents a material deficiency pursuant to 10 CFR Part 51.The Draft SEIS is also deficient in that it fails to recognize the emerging, plant-specific signs and symptoms of a dangerous tipping point whichmay be developing at the age-degraded Fermi 2 nuclear plant. Indeed,this year was marked by a pattern of dangerously poor performance atFermi 2. Rather than generating electricity in 2015, DTE is nowcompeting for the embarrassing title of generating the most LERs in theentire U.S. commercial fleet, indicating a serious deterioration ofreliability.

In September 2015, for example, the Fermi 2 nuclear plant went intoEmergency Operating Procedure mode with another scram, causingsignificant, unplanned offsite releases which occurred during hotshutdown as Fermi's operators maintained equilibrium pressure in thereactor vessel by cycling the Safety Relief Valve mechanism.

ATHF3 contends that the Draft SEIS is deficient because the NRC failsto document and analyze the environmental and public health impacts ofthe reasonably-foreseeable, ever-increasing frequency of similar adverseevents which are likely to occur at the aging reactor site during theperiod of extended operation.

We contend that the adverse events, of2015 are a harbinger of things to come, a "new normal."

If we arecorrect, the likelihood is that Fermi 2 would experience more downtimeand increased maintenance costs during the proposed license renewalperiod. All the while, the potential severity of environmental impacts inthe event of a catastrophic accident would increase significantly asFermi 2 generates more and more high-level radioactive waste (HLRW)to be stored onsite indefinitely.

Thus, further analysis is called for.ITEM #9License Renewal impact on Fermi 2 decommissioning:

The NRC has generically concluded that nuclear plant license renewal"would have a negligible (SMALL) effect" on the environmental impacts of decommissioning no matter what point in time the inevitable termination of operation occurs. That is, the NRC has concluded thattwenty additional years of operation of a nuclear power plant wouldhave no significant effect on the impacts of decommissioning the facilityat the end of its operating life. Pertaining to the Fermi 2 nuclear plant,the NRC has concluded that there are "no site-specific issues related todecommissioning."

(Fermi 2 DSEJS at 2-2)ATHF3 contends that the NRC's conclusions are ludicrous.

Twentyyears of additional production of spent nuclear fuel to be stored onsiteindefinitely under the current protocol would undoubtedly add to thetask of remediating and decontaminating the facility.

Further, it is notpossible that the passive systems, structures, and components (SSCs) at the Fermi 2 nuclear plant would escape significant age-related degradation during the twenty year period of extended operation.

Therefore, it is reasonable to conclude that the process of dismantling and decommissioning the contaminated equipment would entail agreater amount of risk to plant workers and would subject the public to agreater risk of impacts from the removal and transport of the radioactive materials, including those materials created uniquely as a result ofextended operations.

ATHF3 also contends that there are site-specific issues related todecommissioning the Fermi 2 nuclear plant and that the Draft SEIS isdeficient in that such issues are omitted from the NRC's discussion.

Theissue comes down to three famous words: "location,

location, location."

The Draft SEIS fails the "hard look" test because the NRC did notinclude a plant-specific

analysis, updated specifically for the 20-yearlicense renewal period, of reasonably-foreseeable risks associated withFermi 2's proximity to a vulnerable international border accessible byland, air, water and cyberspace.

Indeed, it is a matter of public recordthat DTE spent much of last year under NRC probation for violating federal site-security safeguards and protocols which were in place toprevent unauthorized individuals from gaining access to sensitive areasof the facility.

(Docket No. 50-341).Another site-specific issue related to decommissioning the Fermi 2nuclear plant and applicable to the license renewal action is the impactof climate change on the proposed decades-long deferral of commencing the decommissioning process.

In other words, as climate change causesthe Great Lakes region to experience more frequent severe weatherevents, declining lake levels and other phenomena which are pertinent tooperations at the Fermi 2 site, the notion is the longer decommissioning is postponed into the future, the more risky and the eventual process will be. Given that this issue is omitted from consideration inthe Draft SEIS, ATHF3 contends that further analysis is called for underfederal law. (NEPA).ITEM #10Fukushima Lessons not Learned:Specific to the Fermi 2 nuclear power plant and to the proposed licenserenewal period, the Draft SEIS is deficient in that the NRC omits adiscussion of the site-specific impacts of DTE's failure to fullyimplement and comply with all of the recommendations issued by theFukushima Lessons Learned Task Force which was convened as a resultof an NRC Commission Order following the March 2011 nucleardisaster in Japan.The vast majority of spent nuclear fuel at the Fermi 2 site is not in drystorage.

Further, it is well-known that the Nuclear Energy Institute (NEI), which functions as DTE's lobbying arm in Washington, D.C.,lobbied successfully for the NRC Commission to reject widespread callsfor requiring the expedited transfer of spent nuclear fuel from wet to drystorage, that is, from spent fuel poois to dry casks. Hot spent nuclearfuel must initially be stored in a cooling pool for at least five years inorder to stabilize it enough to allow for transfer to dry casks. There isample evidence to show that transferring spent fuel from wet to diystorage as soon as is technically feasible is the more environmentally preferable alternative to unnecessary, continued storage in a spent fuelpool. Although dry cask storage has its own substantial list of safety andenvironmental risks, the Fukushima disaster dramatically illustrated whyit is preferable to transfer spent nuclear fuel out of wet storage poois assoon as is technically

feasible, particularly in the case of GE Mark IBWRs such as Fermi 2. ATHF3 reiterates our contention that the NRC has failed to properly apply its own rules pertaining to consideration ofsevere accidents involving spent fuel poois, and ATH{F3 again calls forreturning the Fermi 2 spent fuel pool to its original low-density, open-frame storage design and for placing the bulk of the spent fuel in onsitehardened dry casks (HOSS), expeditiously.

(Docket Nos. 50-34 1; NRC-20 14-0 109).Additionally, ATHF3 now contends that an NRC ruling issued inNovember 2015 will have the effect of increasing the risk of adverseenvironmental impacts at the Fermi 2 nuclear power plant during theproposed license renewal period. Specifically, the NRC's recent rulingpertains to a petition filed pursuant to 10 CFR 2.206, the "Lochbaum petition" which sought NRC enforcement action on the CurrentLicensing Basis (CLB) of GE Mark I BWRs such as the Fermi 2 nuclearpower plant. In the wake of the Fukushima

disaster, the Lochbaumpetition asserted by incorporation that DTE Electric Company has neverestablished under 10 CFR Part 50 that the Fermi 2 spent fuel poolcooling system meets all of the General Design Criteria (GDCs)applicable to secondary containment.

Even with the Fukushima accidentin the background, DTE has allegedly failed to provide reasonable assurance that the integrity of secondary containment at the Fermi 2nuclear reactor complex will be maintained under all reasonably-foreseeable conditions to adequately protect the public. After four yearsof internal bureaucratic

process, the NRC unfortunately chose to rejectthe Lochbaum

petition, thus allowing certain reactor licensees such asDTE to continue to operate indefinitely with sub-optimal safety margins.ATHF3 argues that the Fermi 2 Draft SEIS is deficient pursuant to 10CFR Part 51 because the NRC wholly omits any discussion andconsideration of this issue and fails to assess the relative environmental risk profiles of the following three independent alternatives which apply site-specifically to the Fermi 2 nuclear power plant during the proposedperiod of extended operation:

') the environmental impact of applying some of the GDCs all of thetime;2) the environmental impact of applying all Of the GDCs some of thetime; and,3) the environmental impact of applying all of the GDCs all of thetime.Bottom line, the NRC has not fooled ATHF3. The Draft SEIS isinadequate, and further analysis is called for under the provisions ofNEPA.(http://adamswebsearch2.nrc.gov/webSearch2/view?

Access ionNumber=ML 151 32A62 5).ITEM # 11NRC's Alternatives analysis relies on misleading assumptions:

The climate change implications for operations at Fermi 2 during theproposed license renewal period are considered outside the scope of thelicense renewal environmental review. In other words, the NRC'senvironmental review documents the potential impacts of continued operation on the environment, not vice versa. The NRC concluded thatthe "environmental impacts from all other alternatives would be largerthan the proposed license renewal,

... [and] the environmentally preferred alternative is the granting of a renewed license for Fermi 2."(Draft SEIS at 2-2 1). In that context, ATHF3 contends that the Fermi 2Draft SEIS is deficient in that the NRC relies on misleading assumptions and omissions in its comparison of alternatives to the proposedrelicensing action.Fundamentally, ATHF3 argues that the NRC failed to consider acombination power replacement alternative which does not rely on aconventionally-fueled baseload generation station as part of thecombination alternative.

Moreover, the NRC failed to further evaluatein depth alternatives which do not rely on a conventionally-fueled baseload generation station.

For example, the NRC neglected toconsider the feasibility or to evaluate in depth a combination alternative consisting entirely of an integrated mix of renewables, clean storagesolutions, and energy efficiency and conservation.

Numeroushypothetical combination alternatives exist which could provide virtualbaseload power without relying on a conventional baseload generation station as part of the mix.One such combination alternative has indeed been subjected to high-level scrutiny and has been validated in principle for technical andcommercial viability.

ATHF3 enters into the record a summary of thisresearch:

2015 Summary of "The Solutions Project" for MichiganUsing only existing known technology, Michigan can transition to 100%wind, water and solar energy for all purposes (electricity, transportation, heating/cooling and industry) by 2050. That's the message from Dr.Mark Jacobson of Stanford University.

The obstacles are purelypolitical.

By this plan. Michigan's projected 2050 energy mix would be:* 40% Onshore wind turbines* 31% Offshore wind turbines* 18.8% Solar panel plants (utility-scale solar farms)

3.5% Residential rooftop solar panels* 3.2% Commercial and government rooftop solar panels* 2% Concentrated solar power plants (utility-scale thermal fromsunlight)

1% Wave devices* 0.5% Conventional hydroelectric The number ofj obs created where a person is employed for 40consecutive years would be 178,200; 108,700 in construction and 69,500in operation.

Using renewable energy sources (wind, water and solar) and improving energy efficiency would reduce the need for energy. Instead of 100units of energy used today, oniy 36 units would be needed in 2050.Part of this savings comes from the greater efficiency of electric motorsover gasoline and diesel motors. Part of it comes from better-insulated buildings and direct use of solar heat. Using less energy obviously savesmoney.Other savings come from death and illness avoided because the pollution associated with burning fossil fuels would be avoided.

The savings dueto illness would amount to 4% of the state's "Gross Domestic Product,"

in economic terminology.

1,740 deaths from air pollution would beavoided.

The plan pays for itself in as little as 11 years from airpollution and climate cost savings.

The new energy generators wouldhave a direct footprint of 0.3 7% of Michigan's land, plus another 4.97%,mostly for adequate spacing between wind towers. The spaces betweencan still be used for farming.*Future energy costs in the period 2020-203 0 are projected to be:* Average fossil fuel/nuclear energy costs =20.1 cents perKilowatt-hour.

Health and climate costs of fossil fuels add 5.7 cents per Kilowatt-hour.* Wind, water and solar average electricity

=6.2 cents per Kilowatt-hour.The annual energy, health and climate savings per person in 2050$8000.The annual savings on energy alone per person in 2050 =$5000.All the above information comes fromhttp://thes olution sproj ect. org/info graphicATHF3 contends that the potential environmental impacts of Fermi 2'scontinued operation during the proposed license renewal period are lostin the discussion when the NRC fails to recognize that nuclear powerhas the largest carbon footprint and climate change impact of any non-carbon-based-fuel energy source. One reason it is important to considera combination power replacement alternative which does not rely on aconventionally-fueled baseload generation station as part of thecombination alternative is that, in the case of DTE, the baseload stationwould likely use hydrofracked methane gas as a fuel source, withdramatic climate change implications.

ATHF3 argues that the Jacobsonalternative referenced above would have a smaller long-term climatechange impact on the environment than would either the proposed Fermi.2 nuclear power plant license renewal or any of the power replacement alternatives which were evaluated in depth, including the NR'shypothetical combination alternative.

Therefore, ATHF3 disagrees with the NRC's conclusions and calls forfurther analysis in accordance with the NRC's own regulations.

TheNRC is "obligated to consider reasonable alternatives" to the proposed*

relicensing action. Further, the analysis of alternatives in the SEIS must"tak[e] into account changes in technology and science since thepreparation of the GEIS." However, despite the above, the NRCproceeds to refer directly back to the conclusions of the GEIS, thuseffectively ignoring the latest factual information on replacement poweralternatives.

(Draft SEIS at 2-3).ITEM #12NRC's Severe Accident analysis relies on misleading assumptions:

Within the scope of the Environmental Review for the proposed Fermi 2relicensing action, DTE and the NRC must consider Severe AccidentMitigation Alternatives (SAMAs) in order to identify potentially cost-beneficial plant improvements subject to license renewal requirements.

Phase 1 screening by DTE reduced the original list of 220 SAMAcandidates to 79 candidates applicable to the Fermi 2 plant though notnecessarily required to be implemented as part of license renewal.

Onfurther review, DTE and the NRC determined that seven (7) SAMVAcandidates were potentially cost-beneficial.

However, none of theseseven candidates are required to be implemented as part of licenserenewal because they do not relate to managing the effects of agingduring the period of extended operation in accordance with 10 CFR Part54. (Draft SEIS at F-5 6).The NRC Staff reviewed DTE's SAMA analysis, which was based onDTE's data information, and concludes that "the methods used and theimplementation of the methods were sound" and "reasonable."

TheNRC Staff further notes that "DTE's assessment was based on generally conservative treatment of costs, benefits, and uncertainties."

(Draft SEISat F-56).

ATHF3 contends that the SAMA analysis referenced above is deficient in that it is fundamentally based on misleading assumptions which serveto underestimate and minimize the projected economic costs andconsequences of a severe accident as well as, in at least one instance, tooverestimate and overinflate the projected economic cost ofimplementation and installation of a particular SAMA. Furthermore, theDraft SEIS is deficient in that the NRC fails to discuss whether any ofthe original 220 SAMA candidates were in fact within the scope oflicense renewal pursuant to 10 CFR Part 54, so that had such SAMAcandidates been deemed to be cost-beneficial such SAMAs would haveindeed been required for license renewal.ATHF3 reiterates our detailed objection to using the MACCS2 computercode model for probabilistic offsite consequence analysis of a nuclearaccident postulated to occur at some unknown time in the future. Again,we point out the fact that the actual code writer himself has publiclydisavowed his own work. As a result, the NRC is using a discredited, unreasonable, and illegitimate methodological modeling software tool toassess the economic costs and consequences of a postulated severeaccident at Fermi 2. (Docket Nos. 50-341; NRC-2014-0109).

ATHF3 also objects to the particular assumptions and input parameter values pertaining to site-specific meteorological data in the offsiteconsequence analysis.

"Meteorological data from 2007 were selectedfor input to the MACCS2 code. .... Meteorological data included windspeed, wind direction, atmospheric stability class, precipitation, andatmospheric mixing heights."

The NRC Staff accepts the use of the2007 data set in DTE's SAMA analysis, noting that "results of previousSAMA analyses have shown little sensitivity to year-to-year differences in meteorological data." (Draft SEIS at F- 18). ATHF3 contends that theNRC Staff has made a giant and dangerous leap of logic in assuming that historical patterns will continue in a predictable manner given theemerging impact of climate change on meteorological conditions indifferent locations.

Thus, the Draft SEIS is incomplete, and furtheranalysis is called for.ATHF3 also takes issue with the NRC's use of obsolete severe accidentcost estimates which fail to consider "new and significant information" released to the public in a July 2014 report by the National Academies ofSciences (NAS). The NAS study challenges current NRC assumptions and identifies serious incongruities between the hypothetical presumedcost of a postulated severe nuclear accident and the actual empirical cost, still open-ended, of the real 2011 Fukushima Dai-ichi nuclearaccident in Japan. One of the basic reasons the NAS study is directlyapplicable to Fermi 2 and to the Fermi 2 license renewal qualification isthat both the Fermi 2 reactor and the Fukushima Dai-ichi reactorsreference the GE Mark I BWR atomic reactor design. The NAS studyreleased in July 2014 estimated that the "total cost of the Fukushima Daiichi accident could..,

exceed...

$200 billion ... ." Eighteenmonths later, it is now reasonable to conclude that the final cost will farexceed previous estimates.

In any event, the point is that the NAS's2014 cost estimate for the Fukushima accident is "about 33 timeshigher" than the NRC's hypothetical presumed cost of a postulated severe nuclear accident.

Thus, the NAS study concludes "severeaccidents..,

can have large costs and other consequences that are notconsidered in USNRC...

analyses."

So, therefore, ATHF3 concludes that the NRC's SAMA analysis applied to Fermi 2 deviates far from themost up-to-date, best available science and hence is unreasonable, incorrect, and fails to meet NEPA's "hard look" requirements.

In addition, ATHF3 contends that the NAS report reveals a conspicuous discrepancy regarding the actual prospective cost of one of DTE's most well-known SAMA candidates, specifically SAMA 123, involving thepossible installation of an ATWS-sized filtered containment vent toremove decay heat with less environmental impact than would occur ifventing without high-capacity filtration.

(Draft SEIS at F-36). Filtration conceivably would reduce the concentration of radionuclides releasedinto the environment by about 50%, thus making this particular mitigation alternative quite appealing for defense-in-depth.

Indeed, theNAS report emphasizes that "managing both pressure and thermal loadsis critically important" for "[p]reventing containment failure" and"requires the capability to safely vent hydrogen in a timely fashion witha minimum release of fission products to the environment."

(emphasis added). Nevertheless, in direct contradiction, DTE and the NRCdetermined that SAMA 123 is not cost-beneficial based on an analysis ofthe supposed cost of the installed plant modification versus the assumedprobability-weighted averted cost risk (that is, benefit) of having theplant modification in place in the event of a severe accident scenario atthe Fermi 2 nuclear power plant. ATHF3 asserts that DTE's quotedprojected cost of implementing SAMA 123 (filtered containment vent)at the Fermi 2 plant would be $40 million; but, the 2014 NAS reportreferencing SECY- 12-0157 suggests this particular "backfit" wouldactually only cost an "estimated

$15 million" to install.

ATHF3contends that this substantial discrepancy must be reconciled with athorough explanation in the NRC's Final SEIS.Finally, ATHF3 contends that if DTE did indeed report Fermi 2-specific "core damage frequencies" which assume one accident every 50,000years on average, consistent with SECY- 12-0157 pertaining to a GEMark I BWR, then there is no basis whatsoever in reality to accept theconclusions of DTE and the NRC Staff regarding their risk assessment of projected offsite consequences stemming from a severe accident atthe Fermi 2 nuclear power plant. In any event, it speaks volumes that during thirty years of operation at Fermi 2 until now, DTE has neverconducted nor been required to conduct an investigation to evaluatepotential plant modification alternatives to mitigate the costs andconsequences of a severe accident.