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Your comments to stop a Fermi 3 nuclear power plant will be appreciated by all future generations.
Although the official deadline for comment has been reached, the NRC may still consider them.
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Dear Ms. Barnes,

As discussed in my February 9, 2009, email below, the NRC will not be granting an extension to the Fermi 3 scoping period, for the reasons expressed in the January 30, 2009, letter to Mr. Kevin Kamps.  However, as also stated in that letter, consistent with the NRC’s “Detroit Edison Company Fermi Nuclear Power Plant Unit 3 Combined License Application Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process”, published in the Federal Register on December 10, 2009 (73 FR 75142), the NRC staff may, at its discretion, consider comments submitted after the end of the comment period on February 9, 2009. 

The public's next opportunity to comment is anticipated to be in 2010, when the Draft Environmental Impact Statement (EIS) is made publicly available; and another public meeting will be held at that time.  The public comment period and public meeting for the Draft EIS will be announced by the NRC in a Federal Register notice, and the public meeting will also be announced on the NRC's Fermi 3 web page at  Since you are on our mailing list, you should be receiving a copy of the Federal Register notice.

Regarding your difficulty in accessing the documents, in my January 29, 2009, email to you on that matter (see attached), I stated that if you continue to have such problems to please contact the Public Document Room (PDR) Help Desk at 1-800-397-4209 or by email at


Stephen Lemont

Environmental Project Manager

Office of New Reactors

Environmental Coalition Files Legal Contentions!


Environmental Coalition Files Fourteen Legal Contentions against Fermi 3 Atomic Reactor

Groups Cite Radioactive Waste Risks, Harms to Lake Erie

Monroe, Michigan – An environmental coalition comprised of Beyond Nuclear, Citizens for Alternatives to Chemical Contamination, Citizens Environment Alliance of Southwestern Ontario, Don’t Waste Michigan, and the Sierra Club has filed fourteen legal contentions with the U.S. Nuclear Regulatory Commission (NRC), intervening against Detroit Edison’s proposed new Fermi 3 atomic reactor in Newport, Michigan. The contentions against Detroit Edison’s application for a Combined Construction and Operation License were due March 9. The coalition objected to Fermi 3’s radioactive, toxic, and thermal impacts on Lake Erie’s vulnerable western basin, especially considering the cumulative damage already occurring in the Great Lakes due to the presence of 33 operating atomic reactors, and dozens of additional coal fired power plants. These include Detroit Edison’s Fermi 2 atomic reactor and Monroe (Coal) Power Plant, one of the largest in North America, Consumers Energy’s Whiting Coal Plant, and First Energy’s Davis-Besse atomic reactor and Bay Shore (Coal) Power Plant, all located on Lake Erie’s shallow western basin.

"Efficiency and renewable, such as solar and wind, could readily replace the dirty, dangerous, and expensive Fermi 3 proposal," said Terry Lodge, the Toledo-based legal counsel to the coalition. “And they could do so much more cleanly, safely, and affordably,” he added.

"The track record of the Detroit Edison Company is abysmal. The partial core-melt accident at Fermi 1 in October, 1966 and the 1993-94 Holiday dumping of millions of gallons of radioactively contaminated water into Lake Erie by Fermi 2 speaks to this record," said Michael Keegan of Don’t Waste Michigan. "The proposed Fermi 3 would represent another half-century of safety and security risks for the Great Lakes shoreline. Many concerned local residents don’t want to play yet another round of radioactive Russian roulette," Keegan added. Michael Keegan resides in Monroe and has been following the Fermi reactors for three decades.

"It is incomprehensible that the NRC failed to notify Walpole Island First Nation in the St. Clair River, or other First Nations whose lands or fisheries lie within 50 miles of the proposed reactor, about their right to take part in this proceeding," said Kay Cumbow of Brown City, speaking for Citizens for Alternatives to Chemical Contamination. "Great Lakes waters are protected both by treaties and by the Great Lakes Water Quality Agreement. We share the obligation to protect these waters with other nations. Indigenous Peoples' land and fisheries in Lake Erie would be harmed by Fermi 3's radioactive, toxic, and thermal discharges," she added.

"As Fermi 2’s storage pool is full to the gills, and vulnerable to accident or attack, Detroit Edison proposes to generate yet more radioactive waste it doesn’t know what to do with," said Kevin Kamps of Beyond Nuclear, a national watchdog group in Takoma Park, Maryland. "With President Obama indicating the end of the Yucca Mountain dumpsite proposal in Nevada, forever deadly radioactive wastes generated by Fermi 2 and 3 would continue to pile up on the Lake Erie shoreline with nowhere to go," he added.

“Taxpayers and ratepayers should not be forced to further subsidize the already heavily subsidized nuclear power and coal industries,” said Ed McArdle of the Sierra Club. "We believe the electricity from Fermi 3 will not even be needed," he added. McArdle resides in Melvindale, Michigan, less than 25 miles from Fermi nuclear power plant.

“We need to implement a 21st century action plan for our energy and environmental needs in the Great Lakes basin. Nuclear and coal are the dirty siblings of a previous century and we can no longer afford to live in an environmentally destructive manner,” stated Derek Coronado of the Citizens Environment Alliance in Windsor, Ontario.

A copy of the 150 page contentions filing is available upon request from Kevin Kamps at Beyond Nuclear, (240) 462-3216 or

Fermi 2 plant closed after vibrations were detected

Published: Saturday, April 18, 2009

"FRENCHTOWN TWP.  DTE Energy shut down its Fermi 2 reactor plant in Monroe County on March 28 after an unexpected vibration in plant equipment was detected."

: "...DTE is moving ahead with a plan to store spent fuel in dry containers that are a combination of steel and concrete, similar to other plants across the country, Austerberry said."

"...Last month, a binational environmental coalition filed 14 legal contentions with federal regulators against DTE’s plan [to build a third reactor, Fermi 3, at the site], citing public health and several environmental concerns...The environmental groups object to the proposed plant’s possible radioactive and toxic impacts on the western basin of Lake Erie’s as damage already is occurring in the Great Lakes due to 33 atomic reactors and dozens of additional coal-fired power plants operating, they said."

For more of this story, click HERE

According to a plant report, the water level in the reactor vessel fell to 162 inches during the March 28 shutdown but a Fermi spokesman says he doesn't think that 'necessarily indicates that there was any loss of water level at all.'

By Eartha Jane Melzer 4/7/09 5:17 PM Online article

An incident involving a nuclear reactor going into “hot shutdown” at DTE Energy’s Fermi II power generation station in Monroe County late last month went largely unnoticed locally and is raising questions about what exactly happened at the plant.

DTE officials have minimized the incident, stressing that it’s dangerous to make assumptions about the safety of the reactor after high vibrations from a bearing in the plant’s main turbine caused operators to manually switch the reactor into shutdown.

According to a report by the plant to the Nuclear Regulatory Commission, the 1,100 megawatt boiling water reactor was operating at 23-percent power on March 28 when at 1:46 a.m. the shutdown began.

The plant was running at the reduced power level as part of a ramping down of operations in advance of a planned shutdown for refueling and maintenance.

“The cause of the high main turbine vibrations is currently under investigation,“ according to the report. “There was no maintenance or testing in progress that would explain the high turbine vibration levels.”

The report went on to state that the lowest reactor water level reached during the incident was 162 inches, and “[a]ll isolations and actuations for reactor vessel water level 3 occurred.”

“As you shut down the reactor quickly the pressure becomes higher and the water level goes down,” said Viktoria Mytling, a Nuclear Regulatory Commission spokeswoman. “The reactor water level does go down a certain amount as a consequence of a SCRAM [sudden shutdown]. What happened at Fermi in terms of the water level going down was expected.”

Mytling said that the normal reactor vessel water level is 197 inches and the minimum level is 150 inches.

Although the NRC reports that lowered reactor vessel water levels are an anticipated result of sudden plant shutdowns, DTE spokesman John Austerberry cautioned Michigan Messenger against reporting about the drop in water levels during the incident.

Asked about the low reactor vessel water level included in the shutdown incident report, Austerberry said: “I think that was just a data point we were providing them. I don’t think it necessarily indicates that there was any loss of water level at all. So I’d be very careful about that.”

“The ’scramming’ of a nuclear reactor is a little like hitting your breaks on the interstate,” said Paul Gunter, a policy analyst with the nuclear watchdog group Beyond Nuclear. “It tests a lot of systems and puts systems and components under a lot of stress. It does put a lot of wear and tear on the system.”

Michael Keegan, a nuclear power critic who lives near the Fermi II plant said that he learned of the incident through a notice on the NRC website.

Keegan, who is among the individuals trying to block the construction of an additional reactor at the Fermi complex, said that locals are “salivating” at the prospect of jobs in building the new plant. He said that he finds the lack of local media on the situation disturbing.

“It’s kind of peculiar,” he said. “You see [this incident] is picked up by Reuters and you can read about it in New York but you can’t read about it in your home town.”

The Toledo Blade published an article about the “erratic vibration.”

Keegan said incidents at the plant have led to serious environmental issues.

In 1993, a turbine problem on Christmas Day led to a fire which resulted in the radioactive contamination of more than a million of gallons of water that was subsequently released into Lake Erie.

Jim Riccio, a Greenpeace nuclear policy analyst said he is not surprised that a utility spokesman would try to play down a drop in reactor vessel water levels.

“He wants to make you believe that splitting atoms is something safe, but its not,” Riccio said. “The risk is that if the water levels go too low you uncover the core and you start to melt down, that is what happened at Three Mile Island,” referring to the 1979 partial core meltdown at the nuclear power station near Harrisburg, Pa.

Fermi 3 Wetlands Impact Largest in Michigan History
According to the Michigan Department of Environmental Quality the proposed Fermi 3 would be largest impact on coastal wetlands in Michigan history. On May 5th, 2009 the Atomic Safety Licensing Board (ASLB) held a pre-hearing on the proposed Fermi 3 nuclear power plant in Monroe, MI. The ALSB learned from the Interveners that the Michigan Department of Environmental Quality had stated February 3, 2009 that: "Based on the Wetlands Identification Program report, a significant portion of the proposed Fermi 3 property contains regulated wetlands, with most of the wetlands on the site being Great Lakes coastal wetlands. With historic losses of greater than 95 percent of the coastal wetlands of western Lake Erie, the wetlands on site represent a very important and rare natural resource for the State of Michigan. The Environmental Report (by the utility) describes the wetland impacts as moderate. In fact, it appears that the project as proposed would be one of the largest impacts to coastal wetlands in the history of Michigan's wetland statute." There are seven endangered species on the proposed Fermi 3 site.

Fermi 3 Cooling Tower Must Be Relocated
In an email memo from DTE to the NRC sent May 20, 2009 Interveners learned that there will be COL Application changes to minimize the environmental impacts that include movement of the cooling tower. Because of concerns raised in the ASLB pre-hearing on May 5th, regarding wetlands it now appears that the cooling tower must be relocated, these changes are reported to "Impact the Schedule". (From: Mark Tonacci Sent: Wednesday, May 20, 2009 3:48 PM To: Jerry Hale, Subject: Fermi COLA Changes that Impact the Schedule)

Fermi Schedule Delayed
Because DTE is late with their responses on Request Additional Information from the NRC. The schedule will be pushed back. Request made May 12th, responses that were due June 30th will not be submitted for review until December 30th. The proposed Fermi 3 is already behind schedule, by as much as a year. The Final Safety Evaluation Review will not be completed until March 22, 2012, if no further delays are incurred. DTE has already acknowledged that there will be "site layout modifications" to the COLA later this year.

In addition, review of the Economically Simplified Boiling Water Reactor reference design may delay the proposed Fermi 3 schedule further. Early indication suggest that there are problems with the ESBWR design. (Letter from Mark E. Tonacci, Senior Project Manager ESBWR Projects Branch 1 Division of New Reactor Licensing, Office of New Reactors to Mr Jack M. Davis, DTE June 30th, 2009)

Transmission Corridor Problems for Fermi 3
In a Request for Additional Information (RAI No. 2168 Revision 0) the NRC indicates that the Transmission Corridor for the proposed Fermi 3 is problematic, running 29 miles to a Milan. DTE writes: "There are no single failures that can prevent the Fermi offsite power system from performing its function to provide power to EF3." The NRC staff writes: "Failure mode and effect analysis of the towers indicates that structural failure of one tower could affect power distribution of the neighboring tower. The staff notes that all three transmission lines are routed in a common corridor for 29.4 miles. Provide justification that a failure of one tower could not propagate and cause the failure of the third tower lines in the same offsite power transmission corridor." The letter lists a multitude of concerns regarding the Transmission Corridor including: failure of the third tower lines; galloping conductors; lightening strikes; loss of offsite power; grid stability.

Quality Assurance Program Lacking at Fermi 3
In a memorandum from the NRC to the DTE the public learns that the Fermi 3 Application Quality Assurance (QA) Program is virtually non existent. That the Combined Operating License Application submitted in September of 2008 is totally lacking a Quality Assurance program. NRC states: "These concerns will be assessed during an inspection, but in any case, are of sufficient concern at this time that they might question the quality of the overall application." (June 23, 2009, Memorandum to : Jeffrey Cruz from: John A. Nakoski, )

The NRC writes: "The purpose of this memorandum is to document a concern with the Fermi 3 COL application. No response to this memorandum is required. As the result of my staff’s review of the Fermi 3 Combined License Application, Part 2: Final Safety Analysis Report (FSAR), Section 17.5, "Quality Assurance Program Description - Design Certification, Early Site Permits, and New License Applicants," it is not evident that the FSAR provides for a QA program that governs the design activities performed in support of the FSAR."

Fermi 3 Radiological Doses for the Public Established
n an NRC Request for Additional Information (RAI No. 2884 Revision 0), the public learns that the proposed Fermi 3 is establishing and scheduling radiological dose criteria for members of the public due to gaseous effluent releases. GASPAR II computer code will generate dose estimates to members of the public associated with the operation of Fermi 3. In addition, criteria for members of the public due to exposure to radiological liquid effluent is being established for the public. LADTAP II computer code analyses will be generating dose estimates to members of the public associated with the operation of Fermi 3 with calculations for liquid effluent discharges for different intake locations including commercial fish and invertebrate catch locations, drinking water intake locations.


Fermi website copyright Fermi webmaster
Fermi 3 Not Ready for Prime Time - Systemic Quality Assurance Failures
Fermi 3 Opponents Reveal Serious NRC Concerns about DTE Mismanagement

Monroe, MI-Opponents of the proposed new Fermi 3 atomic reactor ripped into legal arguments by Detroit Edison and the Nuclear Regulatory Commission (NRC) staff that recent charges by the NRC of inadequate quality assurance (QA) cannot be put to a public hearing.

Citing multiple internal NRC staff emails, the environmental coalition revealed that several key NRC staff people have questioned whether Detroit Edison can truthfully guarantee that quality systems, structures and components would be built into the proposed Fermi 3 General Electric-Hitachi boiling water reactor. The intervenors have called upon NRC's Atomic Safety and Licensing Board for a suspension of the construction and operating license application proceeding until such guarantees can be made.

The coalition submitted a 33-page declaration from Arnold Gundersen, a career nuclear engineer, who quoted internal NRC staff emails and analyzed the staff criticisms in light of federal requirements. One NRC quality assurance overseer stated, "At this time [June 4, 2009], the application is not providing an applicant's QA program for these activities as required by [Part] 52.79(a)(25) [of the NRC's regulations]." That same staffer said on June 8, 2009 that "This issue puts into question the quality of the overall application."

"This inadequacy of Detroit Edison's Quality Assurance Program cannot be repaired simply by a quick fix. This gaping hole in legally mandated QA must be addressed by the NRC and rectified by Detroit Edison. The only way to resolve this breach is to start over with a fully implemented QA Program and go back and look at every analysis since 2007.  The people of Michigan should not have to shoulder the cost of repeating these studies," said Gundersen, Chief Engineer for Fairewinds Associates, Inc.

"A quality assurance program has to start at the very beginning of the design for a huge project like Fermi 3," said Terry Lodge, attorney for the public intervenors. "The utility has to guarantee that they won't buy junk parts or electrical components from manufacturers who care about making a quick buck and don't care if the plant can perform properly in an emergency. This isn't just a 'paperwork' issue, it's about protecting the public's health and safety."

"Given that quality assurance is the very foundation upon which the entire Fermi 3 project is based, DTE might as well build this new atomic reactor on quicksand in terms of its environmental and radiological safety and its financial viability.  This project places all parties in peril," added Keith Gunter of Beyond Nuclear who lives in Livonia, Michigan.

The environmental coalition opposing Fermi 3 includes Beyond Nuclear, Citizens for Alternatives to Chemical Contamination, Citizens Environmental Alliance of Southwestern Ontario, Don't Waste Michigan, and the Sierra Club Michigan Chapter. Its latest filing on December 8 is in response to arguments by both NRC staff and Detroit Edison's legal counsel, submitted December 1, for the QA contention to be rejected. The environmental coalition first raised its QA contention on November 6, 2009.

Documents associated with this intervention are posted at Beyond Nuclear's website,
Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abandon both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic. The Beyond Nuclear team works with diverse partners and allies to provide the public, government officials, and the media with the critical information necessary to move humanity toward a world beyond nuclear.

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Fermi 3 Opponents Reveal Serious NRC Concerns about DTE Mismanagement on Quality Assurance  

Beyond Nuclear and its environmental coalition allies defended its quality assurance contention  against the Fermi 3 new reactor proposal targeted at Monroe, Michigan on Dec. 8th. Beyond Nuclear's contention was based upon a U.S. Nuclear Regulatory Commission (NRC) "Notice of Violation"   issued on Oct. 5th. Expert witness Arnold Gundersen's declaration cited U.S. Nuclear Regulatory Commission safety staff internal emails raising serious concerns about the lack of quality assurance in the Fermi 3 combined Construction and Operating License Application (COLA). Beyond Nuclear's media release on its latest filing quoted Gundersen, coalition attorney Terry Lodge, as well as Beyond Nuclear Launch Partner Keith Gunter of Livonia, Michigan. Not only does Fermi 3's COLA lack QA, but NRC's Office of Inspector General has questioned the QA competence of NRC's own staff itself. Despite its challenges at enforcing its own QA regulations, NRC staff have raised serious concerns about the QA of the General Electric-Hitachi design itself for the "Economic Simplified Boiling Water Reactor" proposed at Fermi 3. Beyond Nuclear's original QA contention against Fermi 3's COLA, and Detroit Edison's and NRC staff's responses, are posted at Beyond Nuclear's Nuclear Reactor page.

June 6, 2010:Fermi sustained damage from a tornado. The tornado had an eight mile radius in Ohio, where it leveled some buildings and killed people. At Fermi, in Monroe, Michigan, tornadic winds ripped away siding from the auxiliary building and damaged the turbine building roof, leaving a hole in it. Both buildings sit near the building housing the reactor. The winds also damaged some of the cooling fins that ring the base of the plant’s twin, landmark cooling towers. The reactor went into emergency shut down and is being repaired.
(posted June 12, 2010)
Article published at on Dec 3, 2010
Contaminated water leaks from Fermi

DTE Energy confirmed Thursday that an undetermined amount of radioactive water flooded some areas of its Fermi 2 nuclear power plant on Wednesday afternoon, contaminated some workers’ clothing, and entered the plant’s sewer system.
The problem occurred when a drain valve stuck open on a system that filters water condensed from radioactive steam, causing a holding tank to overflow. The overflow then filled a ventilation line and spilled into portions of the plant’s turbine building and radwaste building.
Some of the water also entered the plant sewage system through a bathroom floor drain.
DTE officials and those with the federal Nuclear Regulatory Commission still today were not sure of the total amount of water involved in the overflow, however.
Some plant areas remained damp and were cleaned and decontaminated Thursday and the utility had sealed and pumped out the sewer pipe and series of holding tanks along the pipe where the water might have traveled. A monitoring station at the end of the sewer pipe was checked to determine if any of the contaminated water made it that far or to the Monroe wastewater collection system beyond. A small amount, they determined, did reach the wastewater plant, but the amount of radioactivity in the water was not detectable by standard instruments.
The utility said no radiation dose was received by any workers.
Viktoria Mitlyng, an NRC spokeswoman, said neither the safety of the plant, the workers nor the public was compromised.
“We don’t see that as an issue,” she said. “Even though you have contamination, it’s far below regulatory limits.”
She said for any of the workers to get a dose, they would have to drink the water, not merely get it on their clothing. The water contained “extremely low levels of radioactivity,” said Guy Cerullo, a DTE spokesman at the plant.
Mr. Cerullo said a number of workers had to surrender their boots and pants, but received no measurable body dose of radiation. A source at the plant said at least six personnel were affected.
The plant had been idle for more than a month for maintenance and to load new nuclear fuel into the reactor. The reactor was restarted at 1:45 this morning.
A formal report was not made to the NRC because the reactor was not operating, the incident did not involve a high level of contamination and did not affect the plant’s safety-related equipment, Ms. Mitlyng said.

Nuclear Power: Hope or Hoax?
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