ML14252A138

Comment (11) of Michael J. Keegan on Behalf of Don'T Waste Michigan on Fermi 2 Docket Id NRC-2014-0109 License Renewal Application

ML14252A138
Person / Time
Site:	Fermi
Issue date:	08/29/2014
From:	Keegan M J Don't Waste Michigan
To:	Gallagher C A, Perkins L T Division of Administrative Services
SECY RAS
References
79FR36837 00011, NRC-2014-0109
Download: ML14252A138 (12)

Text

1. 1. V.Gallagher, CarolTo: Gallagher, Carol

Subject:

FW: Fermi 2 License Renewal Application Comments to NRC August 29, 2014 /Correction Attachments:

Final Fermi 2 License Renewal Application Comments to NRC August 29, 2014 -Final.docx From: Perkins, LeslieSent: Wednesday, September 03, 2014 8:22 AMTo: Gallagher, Carol

Subject:

FW: Fermi 2 License Renewal Application Comments to NRC August 29, 2014 / Correction Hi Carol,I am not sure if you receive this already.

If not, please process the attached comment for Fermi 2 licenserenewal; Docket ID NRC-2014-0109 6/3Z/c //-Thanks,LeslieFrom: mkeecianjicomcast.net

[1]

Sent: Friday, August 29, 2014 9:19 PMTo: Perkins, Leslie; LCarol Gallagher Cc: Kevin Kamps; rickcoronado; dcoronado derek; Jessie Collins; Terry Lodge; Diane Curran; mkeeganj

Subject:

Re: Fermi 2 License Renewal Application Comments to NRC August 29, 2014 / Correction

Dear Leslie Perkins and Carol Gallagher,

Regarding the previous message with Comments please do add to the Organizational ListNuclear Information Resource

Service, Takoma Park, MD, Tim Judson.I am entering below and I have now attached the Final Fermi 2 License Renewal Application whichincludes this correction

-Thank YouMichael J. KeeganDon't Waste MichiganSUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03Add= /. CI-je-7Ls)1 Leslie PerkinsEnvironmental Project Manager,Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001; Leslie.Perkins

@ nrc.gov.Carol Gallagher Carol.Gallagher@

nrc.govCindy BladeyOffice of Administration Mail Stop: 3WFN A44MU.S. Nuclear Regulatory Commission Washington, DC 20555-0001.

Regarding:

Fermi 2 Docket ID NRC-2014-0109 License Renewal Application

Dear Leslie Perkins,

Carol Gallagher, Cindy Bladey,We the undersigned submit these Comments into the Fermi 2, 20 year License Renewal Application record pertaining to Environmental Impact Statement and Safety Evaluation Review process Docket IDNRC-2014-0109.

Approval of the Fermi 2 will result in 20 additional years of highly irradiated nuclear fuel perpetuating theWaste Con that one day there will be a solution.

The Emperor still has no clothes.We acknowledge, accept and adopt as our own Comments the Contentions listed below. Please adoptthese Contentions submitted here in part as our Comments by the undersigned.

In addition we submitinto the EIS and SER record the full docketed request for Public Hearings based on Contentions broughtforward in two separate requests.

(1) The Public Hearing request made by Don't Waste Michigan(DWM), Citizens Environment Alliance (CEA) and Beyond Nuclear (BN) docketed at:http://adamswebsearch2.nrc.qov/webSearch2/main.msp?AccessionNumber=ML1 4230B040(2) The Public Hearing request made by Citizen's Resistance at Fermi Two (CRAFT) docketed at:http://adamswebsearch2.nrc.qov/webSearch2/main.jsp?AccessionNumber=ML1 4231 B1 42Please enter into the Fermi 2 (LRA) EIS and SER record the request for Public Hearing based onconcerns raised by DWM/CEA/BN:

(ENVIRONMENTAL)

CONTENTION 1: INADEQUATE SAMAANALYSIS OF MARK I BWR VULNERABILITIES Statement of the Contention and CommentThe Applicant's Fermi 2 Environmental Report fails to accurately and thoroughly conduct Severe AccidentMitigation Alternatives (SAMA) analysis to the long-recognized and unaddressed design vulnerability ofthe General Electric Mark I Boiling Water Reactor pressure suppression containment system and theenvironmental consequences of a to-be-anticipated severe accident post-Fukushima Daiichi.(ENVIRONMENTAL)

CONTENTION 2: INADEQUATE CONSIDERATION UNDER NEPA OF DENSEL Y-PACKED SPENT FUEL STORAGE POOLS Statement of the Contention and CommentThe Environmental Report for Fermi 2 does not satisfy the National Environmental Policy Act ("NEPA")

or10 C.F.R. § 51.45( c) because it does not consider a range of mitigation measures to mitigate the risk ofcatastrophic fires in the densely packed, closed-frame spent fuel storage pools at Fermi 2.(ENVIRONMENTAL AND TECHNICAL)

CONTENTION 3: LACK OF SITE-SPECIFIC SAFETY ANDENVIRONMENTAL FINDINGS REGARDING STORAGE AND DISPOSAL OF SPENT FUELStatement of the Contention and CommentThe Environmental Report for Fermi 2 does not satisfy the Atomic Energy Act or NEPA because (1) itdoes not make any site-specific safety and environmental findings regarding the storage and ultimatedisposal of the spent fuel that will be generated during the license renewal term and (2) the NRC has novalid generic findings on which the Environmental Report could rely.(ENVIRONMENTAL)

CONTENTION 4: INSUFFICIENT SEVERE ACCIDENT MITIGATION ANAL YSIS(SAMA) OF POTENTIAL FERMI 2 AND 3 COMMON-MODE FAILURES AND MUTUALLYEXACERBATING CA TASTROPHES Statement of the Contention and CommentFermi 2 and Fermi 3's safety and environmental risks due to common mode failures, and the potential formutually 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 2License Renewal Application (LRA) and Environmental Report (ER). Also, the cumulative impactsassociated with the proposed new Fermi 3 reactor cannot be excluded from DTE's Fermi 2 LRA and ERas "remote" or "speculative,"

for it is DTE's own proposal, and is advanced in the Fermi 3 COLAproceeding.

Such environmental and safety analysis is required on this unique local problem specific toFermi 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 NRC's forthcoming Draft Supplemental Environmental Impact Statement (DSEIS),

as required by NEPA and the AEA.Please enter into the Fermi 2 (LRA) EIS and SER record the request for Public Hearing based onconcerns raised by CRAFT:1) WIND ENERGY IS A VIABLE ALTERNATIVE Statement of the Contention and CommentWind 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 aswind power, to replace the loss of energy production from Fermi 2, and to make the license renewalrequest from 2025 to 2045 unnecessary.

In violation of the requirements of 10 CFR§ 51.53© (3) (iii) andof the GElS § 8.1, the DTE ER (§ 7.1.2.2.1) treats all of the alternatives to license renewal asunreasonable and does not provide a substantial analysis of the potential for significant alternatives, suchas wind power, in the Region of Interest for the requested relicensing period of 2025 to 2045. While theER plainly states, 'Whereas a single wind farm generation unit would not provide consistent powergeneration, multiple wind farms scattered within a reasonable region and interconnected together via thegrid may potentially provide power generation that could approach base-load capacity."

On page 7-8, theER states, "Placing wind farms offshore eliminates some of the obstacles encountered when siting windfarms on shore and limits conflicts with other planning interests."

2) WALPOLE ISLAND FIRST NATIONS' EXCLUSION FROM PROCEEDINGS Statement of the Contention and Comment Purpose of Contention:

To ensure that all Native American tribes and bands and First Nations haveadequate notification by NRC of the proposed Fermi 2 licensing extension and environmental reviewproceedings, as due to them under applicable

treaties, laws, and regulations; and to ensure thatindividual tribal members' interests are represented whether their tribal government intervenes or not ontheir behalf.3) The NRC HAS NOW EXTENDED REACTOR LICENSESStatement of the Contention and CommentIn brief, the U.S. NRC's recently lifted moratorium on licensing and renewal actions as part of the ongoingWaste Confidence rulemaking now allows for the possibility of the NRC Commission granting issuance ofLicense Renewal in the Matter of the Fermi 2 License Renewal Application (hereinafter LRA). ThePetitioner's requests an ASLB recommendation to the. Commission to reinstate the moratorium until alllegal appeals through the federal courts have been exhausted or resolved, pertaining to the expectedappeal of the pending 2014 Waste Confidence Rule by the same Coalition of U.S. States andOrganizations which successfully appealed the previous 2010 version of the Waste Confidence Rule. Ingood faith, the NRC should defer to the multiple intervening parties who together represent millions ofU.S. persons, American citizens and residents.

(New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012)Scope and Materiality of Waste Confidence issue To the Fermi LRA Contention:

It is reasonable to estimate that, during the 20-year License Renewal period, Fermi, Unit 2 wouldgenerate an amount of spent fuel from normal operations equal to about fifty percent (50%) of that whichit 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 towardspotentially indefinite "continued storage" of spent fuel with no technical specifications in place, now or forthe foreseeable future.4) ENRICO FERMI UNIT 2 TRANSMISSION CORRIDOR OFFSITE AC POWER SUPPLYStatement of the Contention and CommentFukushima Lessons Learned:

U.S. NRC Order EA-12-051, "Order Modifying Licenses with Regard toReliable Spent Fuel Pool (SFP) Instrumentation,"

March 12, 2012 (ML12054A679),

pertains to Fermi 2.Basis:Petitioners contend that the Applicant has failed to provide the NRC Staff with an acceptable finalconfiguration of the offsite AC power supply, including

sources, routing and termination points(transmission corridor) for each channel/circuit, so the Staff may conclude that the channels/circuits areindependent (physically separate commensurate with the hazard) from a power supply assignment perspective, for the purpose of ensuring reliable and uninterrupted electric power for the Fermi NuclearReactor, Unit 2, within and as part of the inseparable context of the same Applicant's active and pendingFermi, Unit 3 COLA as submitted.

The Petitioner contends that the Applicant's pending arrangement explicitly violates the Acceptance Criteria of the Mitigation Strategies Directorate (NRR) Audit Plan toReview Licensee Submittals in response to the Commission's Issuance of Orders with regard to Beyond-Design-Basis External Events (BDBEE) mitigation response and recovery actions.5) SPENT FUEL POOL INSTRUMENTATION IS DEFICIENT Statement of the Contention and CommentThe Petitioner requests a public hearing to consider the following Contention pertaining to U.S. NRCCommission Order EA-1 2-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool (SFP)Instrumentation,"

March 12, 2012 (ML12054A679):

Basis:

Spent fuel is stored in high-density pools at every reactor in the United States. No spent fuel pool isprotected by containment or is required to have independent redundant cooling; they were meant forshort-term cooling (-5 years) and weren't intended for multi-decade storage of 4-5 times more spent fuelthan their original designs.

Pools are not only vulnerable to accidents

-as witnessed by the Fukushima accident

-but they are prime terrorist targets.

In the NRC's Draft Consequence Study, the NRC admitsthat a pool fire could displace more than 4 million people from their homes. After both 9/11 and theFukushima

accident, the NRC recognized the potential for a catastrophic pool fire. Furthermore theNRC's Office of Nuclear Security and Incident Response uses a predictive tool to aid emergency responders during nuclear accidents which indicates that the radiological release from a pool firefollowing an earthquake would dwarf that of a reactor meltdown.

It also indicates that the consequence ofthe breach of a dry cask is thousands of times less severe. (U.S. Nuclear Regulatory Commission, Officeof NuclearSecurity and Incidence

Response, RASCAL 3.0.05 Workbook, NUREG-1 889, September 2007).6) MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSStatement of the Contention and CommentContention 6 deals with the inadequacies in DTE's response to U.S. NRC Order EA-12-049, "OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond -Design -Basis -External

-Events (BDBEE)"

(ML12054A736).

As of November 25, 2013 DTE Electric had failed toimplement the plan, as revealed in NRC Staff Evaluation (TAC No. MF0770).

DTE had not complied withthe order and had three Open Items. An "Open item" is defined as "an item for which the licensee has notpresented a sufficient basis for NRC to determine that the issue is on a path to resolution.

The intentbehind designating an issue as an open item is to document significant items that need resolution duringthe review process, rather than being verified after the compliance date through the inspection process."

(TAC No. MF0770, page 6) In addition to Open Items, the Fermi 2 plan had thirty-three (33) Confirmatory Items. According to the TAC, a "confirmatory item" is "an item that the NRC considers conceptually acceptable, but for which resolution may be incomplete."

7) AGING MANAGEMENT PLAN DOES NOT ADEQUATELY INSPECT AND MONITOR FOR LEAKSStatement of the Contention and CommentThe Aging Management program proposed in the DTE Electric Company (hereafter, DTE) licenseextension application for the Fermi 2 nuclear reactor is inadequate because (1) it does not provide foradequate inspection of all systems and components that may contain radioactively contaminated waterand (2) there is no adequate monitoring to determine if and when leakage from these areas occurs. Someof these systems include underground pipes and tanks which the current aging management andinspection programs do not effectively inspect and monitor.The Contention is within the Scope of these proceedings This Contention raises concerns of inspection of underground leaks: Pertaining, in part, to buried pipesand tanks that fall within those described in 10 CFR part 54, as follows:

The Aging Management Plan(AMP) program, as proposed by the Applicant, is inadequate with regard to aging management of buriedpipes and tanks that contain radioactively contaminated water, because the AMP program does notprovide for adequate monitoring wells that would detect leakage.

Furthermore, the Petitioner contendsthat the Aging Management Plan does not adequately inspect and monitor for leaks in all buried systemsand components within scope or in the partially buried sections of systems and components within scope,to include not only buried components that may contain radioactive liquids but also the buried pipes andtanks for the fuel oil system, the station blackout diesel generator system, the fire protection system andthe water inflow piping that do not contain radioactive material but are within scope.

8) SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA) ARE MATERIALLY DEFICIENT Statement of the Contention and CommentContention 8 is regarding Severe Accident Mitigation Alternatives (SAMA) analysis:

Pertaining to criticalinput data, as follows:

The Applicant's Fermi, Unit 2 LRA Environmental Report (ER) and SAMA analysisare materially deficient in that the input data concerning evacuation time estimates (ETE) and economicconsequences are incorrect, resulting in incorrect conclusions about the costs versus benefits of possiblemitigation 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 anddiffusion

...determined using a variable trajectory plume simulation model, along with real-time orsimulated 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 ismore realistic and appropriate for the Fermi site than a "straight-line Gaussian" model would be, due tothe Fermi site's lakeshore and riverside location (see, for example, Dr. Bruce Egan's testimony in supportof 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 ofwater, and the Fermi site is also located near many major metropolitan urban communities.

In otherwords, a "variable trajectory" model and a larger EPZ go hand-in-hand.

Thus, while the Applicant's SAMAanalysis assumes a 10-mile EPZ probabilistic model, the Petitioner contends that a 50-mile EPZ would bea more realistic and appropriate starting point for Fermi, Unit 2's location and would, importantly, yielddifferent results.

In fact, the Petitioner asserts that the Applicant's arbitrary and unrealistic EPZprobabilistic modeling served conveniently for underestimating and minimizing projected consequences ofa Severe Accident.

9) QUALITY ASSURANCE IS FAULTYStatement of the Contention and CommentThe Petitioner requests a public hearing to consider the following Contention pertaining to a fundamental and egregious failure of Safety-Related Quality Assurance which occurred during a 20-year-period from1986 to 2006 at the Fermi Nuclear Power Plant, Unit 2 and which remains unresolved to this day in theeye of the public, thus warranting a fresh, "hard look" as part of any credible NEPA Review or SafetyReview process associated with the Fermi, Unit 2 LRA; and, therefore, the Petitioner respectfully arguesthat this Item is well within the Scope of Consideration for the LRA Review and is Material to theproceeding.

10) SAFETY ASSURANCE VIOLATION.

Statement of the Contention and CommentThe Petitioner requests a public hearing to consider the following Contention pertaining to ensuringcompliance with reasonable safety and security standards, precautionary principles, and administrative controls and procedures at the Fermi Nuclear Power Plant, Unit 2, in order to prevent a potentially significant unauthorized release over the entire licensed life for operations of the reactor.Safety/Security and Quality Assurance Violation:

The Petitioner's forward-looking, long-term confidence in the Applicant/Licensee has been severelycompromised by a recent incident at the Fermi Nuclear Power Plant, Unit 2, which resulted in the U.S.NRC putting DTE Electric Co. on probation for significantly violating the NRC's security requirements at aGreater than Green level, thus initiating an escalated enforcement action. The regulatory compliance violation happened during a February 2014 inspection that could have resulted in unauthorized andunmonitored access to a protected area, according to an NRC report. As a result of the investigation andfinding, Fermi, Unit 2 will move down in the plant ranking system from the licensee response column tothe regulatory response column for the rest of this year (2014). The irony is that the probationary period isongoing concurrently, even as DTE pushes forward with the Fermi, Unit 2 LRA as well as the Fermi, Unit3 COLA.11) DTE'S ENVIRONMENTAL REPORT IGNORES PUBLIC HEALTH DATAStatement of the Contention and CommentThe 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 andobsolete 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 considernew 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 furtheranalysis 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/storaQe/Manqano corrected Fermi report Jan 11 2012.pdf12) THERMAL DISCHARGE INCREASE ALGAE BLOOMSStatement of the Contention and CommentPetitioner's request a public hearing to examine the impact of daily thermal discharges from Fermi 2 asan accelerator and contributor to harmful algal blooms (HABS). The Fermi 2 releases 45 million gallons ofwater per day into Lake Erie. This thermal discharge averages 18 degrees (F) above ambient laketemperature 365 days per year.Petitioner's contend that the Applicant's Environmental Report (ER) fails to consider new and updatedenvironmental 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 healthimpact of Fermi, Unit 2 operations.

Therefore, the Petitioner invokes NEPA requirements and contendsthat further analysis is called for. Illustration:

Petitioner puts forth the following NOAA Satellite Image ofLake 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

&template=sub&image=al

.1 4222.1852.LakeErie.

1 43.250m .jpg13) INADEQUATE RADIATION PROTECTION STANDARDS.

Statement of the Contention and CommentThe following Contention pertains to inadequate environmental radiation protection standards for nuclearpower operations at the Fermi Nuclear Power Plant, Unit 2. The Petitioner seeks an ASLBrecommendation to the NRC Commission to issue an Order to independently assess the adequacy ofcurrent and proposed U.S. EPA guidelines.

Thank youRespectfully Submitted:

Organizational Endorsement Alliance to Halt Fermi 3Detroit, MICarol IzantBeyond NuclearTakoma Park, MDKevin KampsThe Carrie Dickerson Foundation Tulsa, OKMarilyn McCulloch, Secretary Citizens to End Nuclear Dumping in Tennessee

Memphis, TNKathleen Ferris, Co-Founder Citizens Environment Alliance Southwestern OntarioWindsor, Ontario.

CanadaRick Coronado, Derek CoronadoCitizens for Alternatives to Chemical Contamination Lake Station, MIVictor McManemy, ChairCitizen's Resistance at Fermi TwoRedford, MIJessie P. CollinsConcerned Citizens for Nuclear SafetySanta Fe, NMJoni Arends, Executive DirectorCoalition for a Nuclear Free Great LakesMonroe, MIMichael J. Keegan, ChairCrabshell Alliance of Greater Baltimore Baltimore, MDDagmar Fabian, Secretary Don't Waste ArizonaPhoenix, AZStephen BrittleDon't Waste Michigan Grand Rapids, MICorinne CareyDon't Waste MichiganHolland, MIAlice HirtDon't Waste MichiganKalamazoo, MIKevin KampsDon't Waste MichiganMonroe, MIMichael J. KeeganDon't Waste MichiganSherwood, MIKathy BarnesEnergia MiaSan Antonio, TXCynthia WeehlerEnvironmentalists Inc.Aiken, SCRuth ThomasFriends of the EarthWashington, D.C.Ben Schreiber, Program DirectorFriends of the EarthWashington, D.C.Katherine FuchsGE Stockholder's Alliance for Sustainable, Nuclear-Free FutureSandy Spring, MDPatricia T. Birnie, ChairGreat Northern SolarPort Wing, WIChristopher LaForgeThe Guacamole FundHermosa, CATom Campbell Home for Peace JusticeSaginaw, MIJoan McCoyMusicians for Safe EnergyMountain View, CATom CampbellNorth American Water OfficeLake Elmo, MNGeorge CrockerNuclear Energy Information ServiceEvanston, ILDavid Kraft, Executive DirectorNuclear Information Resource ServiceTakoma Park, MDTim Judson, Executive DirectorNukewatch Luck, Wisconsin John LaForge, Co-director Physicians for Social Responsibility Chesapeake ChapterGwen DuBoisProposition One CampaignTryon, NCEllen ThomasThe Rachel Carson Council, Inc.Bethesda, MDRobert K. Musil, Ph.D., M.P.H.San Luis Obispo Mothers For PeaceSan Luis Obispo, CALinda SeeleySinnissippi Alliance for the Environment Rockford ILStanley CampbellStand Up / Save Lives Campaign Burr Ridge, ILMaureen K. Headington, President Toledo Coalition for Safe EnergyToledo, OHTerry J. LodgeWaste Action ProjectSeattle, WAGreg Wingard, Executive DirectorIndividual Endorsement Gerson Lesser, M.D.New York, NYJanette D. Sherman, M.D.Baltimore, MarylandSusan MichelliMt. Horeb, WIDavid Schoenberger Ann Arbor, MIZack RuiterToronto, ONT CanadaJames ShermanWaterford, MITom FergusonMarquette, MISteve FergusonMarquette, MISarah MooreBelleville, MICarol KurzEvanston, ILZiggy KleinowBinbrook ONT, Canada Rosalie RiegleLansing, MIKay CumbowBrown City, MIKeith GunterLivonia, MIPlease Contact Michael J. Keegan, Don't Waste Michigan mkeeganj@comcast.net should youhave any questions.

Thank you.