ML21138A867
| ML21138A867 | |
| Person / Time | |
|---|---|
| Issue date: | 05/04/2021 |
| From: | Lance Rakovan NRC/NMSS/DREFS/ELRB |
| To: | Duke Energy Corp |
| Rakovan L, NMSS/REFS/ELRB | |
| Shared Package | |
| ML21138A822 | List: |
| References | |
| Download: ML21138A867 (15) | |
Text
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Land Use 3.1; 4.1 Description of the plant site location in relationship to State and local political jurisdictions (e.g., county, town, township, service districts, parish)
Description of the site vicinity within a 6-mile radius regarding political jurisdictions, major land uses and land cover, topographic and physiographic features, transportation networks and facilities, place names, Indian and/or Bureau of Indian Affairs lands held in trust for Indians, and Indian Tribes lands A map of the site vicinity within a 6-mile radius of the plant showing major land uses and land cover (with land use classifications consistent with the USGS categories)
Description of the region within a 50-mile radius of the site regarding political jurisdictions, place names, topographic and physiographic features, and transportation networks and facilities Description of the site boundaries and properties; plant exclusion area; site structures and facilities; major land uses and land cover; the construction zone for refurbishment, if any; sites for any other planned buildings, facilities, and structures (both temporary and permanent);
areas under lease or with public access; and transportation routes entering and adjacent to the site Information on local county comprehensive land use and development plans concerning land use and zoning that are relevant to population and housing growth and control and to changes in land use patterns Information, including area and percentage by land use and land cover category, about the undeveloped portions of land within the plant site boundary and/or property The amount of developable unused open portions of the site, including fields and forest uplands The amount of non developable wetlands and open water bodies (i.e.,
marshes, bogs, swamps, streams, ponds, estuaries, and rivers) within the site.
The amount of developed portions of the plant site, including facilities, structures, parking areas, landscaped areas, leased lands, and visitor and recreation areas The amount of onsite land that has been disturbed at some time during the construction and operation of the plant
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Description of land uses and land cover within the in-scope transmission lines and corridors and any current and planned restrictions or covenants on use Status of compliance with regard to Coastal Zone Management Act consistency certification and copies of relevant correspondence between the applicant and the State Any new and significant information applicable to land use.
Visual Resources 3.1; 4.1 Description of the plants visual setting, including the identities and heights of the tallest visible plant structures, significant lights and vapor plumes, as well as direction and distances from which these structures, lights, and plumes are visible Description of the existing visual impacts of in-scope transmission lines and corridors level of significance, distance, and type of observer Any new and significant information applicable to visual resources.
Meteorology and Air quality 3.2; 4.2 A description of the general climate of the region Summary of onsite meteorological program and meteorological data (mean monthly and annual temperature, monthly and annual precipitation, wind speed and direction) for the most recent 5-year period A description of the regional air quality, including nonattainment or maintenance areas or Federal Class I areas.
Description of issued air permits for onsite air emissions sources and permit conditions A description of air emission sources and estimated annual criteria pollutant emissions for these sources for the most recent five years Compliance history associated with the site's air permit and identification of any notice of violations.
Estimated greenhouse gas emission inventory for the most recent 5-year period. Emissions should include stationary combustion sources, mobile sources (commuters, visitors, delivery vehicle, etc.), and other sources (refrigerant leakage, emissions from switchyard, etc.).
Discussion of expected upgrade/replacement activities equipment/operation that could increase or decrease air emissions over the license renewal period
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes If refurbishment is planned, a discussion of additional workers, estimated onsite and offsite vehicle emissions, construction equipment and emissions from use of equipment to support refurbishment activities.
Field tests conducted concerning ozone and nitrogen oxides emissions generated by site in-scope high voltage transmission lines Any new and significant information identified pertaining to Category 1 Air quality issues.
Noise 3.3; 4.3 Noise complaints (if any) resulting from plant operation.
Discussion of offsite and onsite noise sources Distance of nearby noise sensitive receptors Discussion of current or past noise studies (if any) conducted at or near the plant site.
Description of ambient noise environment Any new and significant information identified pertaining to Category 1 noise issues.
Geologic Environment 3.4; 4.4 Description of soil units within site boundary General description of seismic activity within the region.
Description of geologic stratigraphy and structure.
Surface Water Resources 2.2; 3.5; 4.5, 9.0 Typical water balance (water use diagram) diagram for the plant showing volume of makeup water required and depicting flow rates to and from the various water systems, water system interconnections and interdependence, points of consumption, and source and discharge locations General description of the surface water features of the plant site and vicinity and associated water quality and hydrologic parameters, including wetlands, floodplains and flood hazard areas, impoundments, and any surface water bodies that could affect or be affected by plant water withdrawals or discharges Summary of the plants water withdrawal, return flow, and consumptive water use reporting data (e.g., covering latest 5 year period) and any regulatory limits on withdrawals. Include a description of in-plant water uses, intake and system makeup flow rates, and pump design and normal operating rates
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes A projection of water withdrawals including consumptive water use during the license renewal period, including a comparison with projected flows or water storage, as applicable, in the water source as well as with other withdrawals by offsite users from the same water source Status of National Pollutant Discharge Elimination System (NPDES) permit renewal, including copy of current NPDES or equivalent State-issued discharge permit Summary of NPDES-regulated effluent discharge results, covering monitored parameters for each outfall (e.g., covering latest 5 year period)
Summary of any Notices of Violation (NOVs), nonconformance notifications, or related infractions received from regulatory agencies associated with water withdrawals, NPDES permitted discharges, sanitary sewage systems, groundwater or soil contamination, including spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) (e.g., covering latest 5 year period)
Documentation from State Agency of Clean Water Act Section 401 Certification to support license renewal Groundwater Resources 3.5; 4.5 Description of the hydrogeological units that underlie the site, including aquifers and aquitards.
Description of groundwater flow directions and the rate of flow in aquifers.
Identification of aquifers being used or which could be used as source of groundwater.
Description of any inadvertent releases of radionuclides into the groundwater. Project the impact of any inadvertent releases on groundwater and surface water resources over the period of license renewal.
Descriptions of aquifer groundwater chemistries Describe aquifer interconnections and connections to surface water bodies.
Describe groundwater use by aquifer.
Terrestrial Resources 3.6; 4.6 Description of the ecosystem and habitats of the ecoregion and geomorphic or physiographic province
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Characteristic vegetation, physiographic habitats, and animal communities of the site and vicinity including climax vegetation and typical succession in the area of the site Descriptions of in-scope transmission line rights-of-way, including (1) transmission line and ROW length and width; (2) ROW maintenance plans, procedures, or protocols and pesticide or herbicide use therein; (3) locations where ROWs cross wetlands and waterfowl areas as well as other vulnerable or otherwise important terrestrial habitats; and (4) detailed maps of in-scope transmission lines and stream crossings, any significant natural heritage areas, and known locations or historic sightings of migratory bird rookeries, etc.
Occurrence, location, and description of communities and habitats of special interest in the vicinity of the plant, such as wetlands, natural heritage areas, other areas of public or scientific interest, or other areas that may be particularly sensitive or susceptible either directly or indirectly to the effects of continued plant operations during the license renewal term Occurrence of invasive species in the vicinity of the plant and documentation of any management activities undertaken by the plant to control such species Wildlife management plans and best management practices (if applicable), including pesticides and herbicides used routinely to maintain the site Summaries of studies or monitoring programs of terrestrial resources on or in the vicinity of the site in terms of when and where conducted and by whom, the objective (why conducted), the biological entities or attributes chosen for study, methods and results (how conducted) applicable to the license renewal, and what data summaries might be available for NRC review
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Information on State-listed terrestrial species and habitat that could be found on or in the vicinity of the site, including the area within the in-scope transmission line corridors, including the following information: (1) descriptions of historical occurrences, population size and trends, critical habitat, and potential habitat on or in the vicinity of the site; (2) description of any license renewal or refurbishment activities as well as any modifications to plant operation that may affect such species and habitats.
An analysis of the effects of water use conflicts on terrestrial resources for plants with cooling ponds or cooling towers using makeup water from a river.
An analysis of non-cooling system impacts on terrestrial resources, including the effects of landscape maintenance activities, refurbishment activities, any plan or possible construction, stormwater management, noise, or any other operations or maintenance activities that have the potential to disturb terrestrial habitats or biota. Descriptions and summaries of applicable plant procedures and best management practices that bound such impacts should also be included.
Any new and significant information applicable to terrestrial resources.
Aquatic Resources 3.6; 4.6 Description of the marine ecoregion of the ocean or gulf waters near plant, if applicable, and aquatic resources therein Description of the watershed(s) of the ecoregion and aquatic resources therein Descriptions of water body from which plant withdraws and discharges cooling water and any other potentially affected water body(ies),
including (1) the source and receiving water bodies in terms of relationship to the watershed, size, shoreline, bathymetry, tidal and net flows including seasonal or occasional variations, bottom types (e.g.,
sand, silt, clay, sandy silt, silty sand, etc.), and both sediment and water quality; (2) location of the main channel, dams, and flood control; and (3) additional uses of the water body other than for cooling.
Significant water bodies that intercept or parallel in-scope transmission lines and detailed maps and descriptions that contain site and in-scope transmission lines and stream crossings, any significant natural heritage areas, etc.
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Summaries of studies or monitoring programs of aquatic resources on or in the vicinity of the site in terms of when and where conducted and by whom, the objective (why conducted), the biological entities or attributes chosen for study, methods and results (how conducted) applicable to the license renewal, and what data summaries might be available for NRC review Information on State-listed aquatic species that could be found on or in the vicinity of the site, including the area within the in-scope transmission line corridors, including the following information: (1) descriptions of historical occurrences, population size and trends, critical habitat, and potential habitat on or in the vicinity of the site; (2) description of any license renewal or refurbishment activities as well as any modifications to plant operation that may affect such species and habitats.
An analysis of the impacts of impingement and entrainment for once-through plants and plants with cooling ponds. The analysis should include summaries and results of any impingement and entrainment studies performed at the plant in connection with Clean Water Act compliance and the status of the plant's compliance with best technology available (BTA) under Section 316(b) of the Clean Water Act.
An analysis of the impacts of thermal effluent for once-through plants and plants with cooling ponds. The analysis should include summaries and results of any thermal studies performed at the plant in connection with Clean Water Act compliance and the status of the plant's compliance with Section 316(a) of the Clean Water Act.
An analysis of the effects of water use conflicts on aquatic resources for plants with cooling ponds or cooling towers using makeup water from a river.
Any new and significant information applicable to aquatic resources.
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Special Status Species and Habitats 3.6; 4.6 Information on Federally listed threatened, endangered, proposed, or candidate species and critical habitat that could be found in the action area as defined under the Endangered Species Act, including the following information: (1) descriptions of historical occurrences, population size and trends, critical habitat, and potential habitat on or in the vicinity of the site; (2) description of any license renewal or refurbishment activities as well as any modifications to plant operation that may affect such species and habitats.
Information on essential fish habitat on or near the site designated under the Magnuson-Stevens Act, including the following information:
(1) descriptions of the location, characteristics, and quality of the habitat; (2) historical occurrences, population size and trends, and status of Federally managed species with essential fish habitat; and (3) description of any license renewal or refurbishment activities as well as any modifications to plant operation that may affect essential fish habitat.
For applicable Federally listed species and critical habitats: species-and habitat-specific analyses of the effects of license renewal and conclusions for each species and habitat according to language prescribed in the Endangered Species Act and its implementing regulations.
For applicable essential fish habitat: species-and habitat-specific analyses of the effects of license renewal and conclusions for each habitat by Federally managed species and life stage according to language prescribed in the Magnuson-Stevens Act and its implementing regulations.
Copies of correspondence between the applicant, U.S. Fish and Wildlife Service, National Marine Fisheries Service, and State agencies related to Federally listed species, critical habitats, and essential fish habitat.
Any new and significant information applicable to special status species and habitats.
Historic and Cultural Resources 3.7; 4.7 A discussion and description of the cultural history of the area from the beginning of human settlement to the 20th century.
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Discussion of land use history of the plant site and immediately surrounding area. If available, historical maps should be included.
A discussion of activities (ground disturbing activities, increases in traffic, audio or visual intrusions) associated with continued operations and refurbishment activities that could affect onsite or offsite historic properties or cultural resources.
Identification and description of historic properties and cultural resources within the area of potential effects. Previous investigations and studies that have occurred within the area of potential effect should be summarized.
Identification and summary of cultural resource surveys conducted within the area of potential effects. A discussion should be included of records review for historic structures and cultural resources that was conducted and/or activities that have taken place on the plant site to determine the presence of historic and cultural resources.
A discussion of procedures in place to protect historic properties and cultural resources and handling of inadvertent discoveries of historic and cultural resources. If the site has a cultural resource management plan, that should be discussed.
A discussion of consultations conducted with the State Historic Preservation Officer and/or Tribes.
Socioeconomics 3.8; 4..8 Current estimate of the number of permanent, full-time, onsite workers (applicant employees and full-time contractors) and residential distribution by county/parish and community Average number of refueling outage workers, the duration of refueling outages (number of weeks), and their frequency (number of months)
Estimated number of workers required to support any refurbishment activities, if applicable Distribution of property tax payments and other forms of annual agreed-to payments, including payments in lieu of taxes to local jurisdictions (e.g., county, municipality, townships, villages, and school districts) for the past 5 years and the associated total revenues or property tax revenue for each jurisdiction and school district Commuter routes for the workers and traffic conditions on those roads
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Description of public recreational facilities and tourist attractions located in the vicinity of the plant site, including the present and projected percentage of use where available Human Health 3.9; 4.9 A discussion, if applicable, of any abnormal radionuclide releases, including the types of radionuclides released, calculated doses from the release, monitoring plans to track the release, and any corrective measures performed on the release.
A discussion, if applicable, of any license renewal-related refurbishment activities and their impacts on applicable plant systems, changes to effluent releases, and any associated change in public exposure, A discussion of the plant workforce adherence to safety standards and their use of protective equipment as required by Federal and State regulations, as it pertains to occupational safety and health hazards at the plant.
Microbiological Hazards 3.8.1; 4.8.1 Description of the plant cooling system.
Description of the location of the thermal discharges for the plants cooling system (i.e., a cooling pond, lake, canal) and a characterization of the water body receiving discharges from the cooling system, e.g., a large lake or ocean.
The temperature increase expected for the aquatic environment that is subject to the plants thermal discharges.
The results of any analyses that have been made for the presence of deleterious thermophilic microorganisms. These include the enteric pathogens Salmonella sp. and Shigella sp., as well as Pseudomonas aeriginosa and thermophilic fungi. In addition, analyses for the presence of unusually high concentrations of the normally present Legionella sp.
(Legionnaires disease bacteria) and the free-living amoebae of the genera Naegleria and Acanthamoeba.
A list of the outbreaks of waterborne diseases in the vicinity of the plant during the previous 10 years.
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes An evaluation of available data concerning the occurrence and concentrations of any of the deleterious thermophilic microorganisms listed above in the vicinity of the plant and a determination of whether any of them are present under conditions and in locations that might be harmful to members of the public. If such an evaluation exists, it may be obtained from the applicant or from the State Public Health Department in the State in which the plant is located.
A statement from the State Public Health Department indicating their basis for not being concerned about the potential for an impact to the public health from microbiological organisms associated with the cooling system.
Copies of correspondence between the applicant and State relevant to microbiological hazards at the plant.
If the State advises that tests should be conducted for concentration of N. fowleri (or other deleterious thermophilic microorganisms) in the receiving waters and the applicant performs such tests, the application should include a description of the tests that were performed and the results of those tests.
A description of any mitigative measures considered and committed to by the applicant related to microbiological hazards.
Postulated Accidents 4.9 If SAMAs have been previously considered, the applicant should provide the relevant citation in the ER. A license renewal applicant for a plant that has already had a SAMA analysis considered by the NRC as part of an EIS, supplement to an EIS, or EA, does not need to provide another SAMA analysis in the subsequent license renewal ER.
Any new and significant information applicable to SAMA An acceptable approach for performing the SAMA new and significant evaluation is provided in NEI 17-04 which identifies the information needed for the application.
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Provide the significance of new information related to the NRCs conclusion in Table B-1, Issue 66 relevant to the applicant. That is, the conclusion that [t]he probability-weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. This evaluation is not provided in NEI 17-04, thus license renewal applicants are to separately explore new and significant information that relates to this conclusion.
Environmental Justice 3.10; 4.10 Description of the general demographic composition of minority and low-income populations and communities (by race and ethnicity) residing in the immediate vicinity of the plant that could be affected by ongoing and future plant operations and license renewal activities. The geographic scale should be commensurate with the potential impact area and include a sample of the surrounding population to facilitate the evaluation of the communities, neighborhoods, and areas that may be disproportionately affected. This discussion should cover all areas with actual, or potential, reasonably foreseeable physical, social, cultural, and health impacts Information about migrant workers as well as full-time residents and provide geographic information about the location of these populations and communities. Migrant workers are distinguished from full-time residents as follows: migrant workers are those who move from one location to another in response to various employment opportunities such as employment associated with seasonal farming, construction, and manufacturing. Most migrant workers are foreign-born individuals living in the United States as either citizens or noncitizens and may reside in unconventional housing arrangements Identify potential impacts and any concerns these populations and communities may have about the continued operation of the nuclear plant. Also discuss the potential for disproportionately high and adverse human health and environmental impacts on these populations and communities
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes Description of any observed subsistence consumption behavior patternsspecifically fish and wildlife consumptionby minority and low-income populations in the vicinity of the plant (see Section 4-4 of Executive Order 12898). This subsistence consumption behavior could consist of hunting, fishing, and trapping of game animals and any other general food-gathering activities (e.g., collecting nuts, berries, and other plant material) conducted by minority and low-income individuals in the vicinity of the plant Provide any information about current or past wildlife sampling and testing for radioactivity of game animals such as deer, squirrel, turkey, pheasant, duck, and other game birds and animals that may have been conducted in the vicinity of plant Describe any mitigation measures that could be implemented if it is determined that plant operations and other associated license renewal activities could affect minority and/or low-income populations Waste Management 3.11; 4.11 A description of the radioactive liquid, gaseous, and solid waste management and effluent control systems, as well as their effluent release points and resultant doses.
A discussion of non-radioactive waste management systems, their effluent release points, and the state/federal regulations governing them.
A discussion of low level radioactive waste storage capacity/disposal for the plant over the license renewal term A brief discussion of spent fuel storage plans for the license renewal term (ISFISI details, expansion plans, etc.)
A discussion of non-radioactive waste generation, including EPA designation, types of wastes generated, and storage/disposal plans for the license renewal term.
A discussion of mixed waste generation/storage/disposal, if applicable.
Cumulative Impacts 4.12 A description of the regions of influence that encompass the areas of effect and the distances at which impacts associated with license renewal may occur. Geographic boundaries vary by resource area and the distances over which an impact may occur.
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes A discussion of the timeframe incorporating the sum of the additive new and increased effects of continued reactor operations in combination with past, present, and reasonably foreseeable future actions. The timeframe for future actions is 20 years from the time the renewed license renewal is granted. Past actions are those that have occurred since the nuclear plant began operations, and present actions include all current actions. Future actions are those that are reasonably foreseeable; ongoing and funded for future implementation, or have a high probability of being implemented.
A discussion of the factors that potentially affect each past, present, or reasonably foreseeable future action or activity: new and increased effects of continued reactor operations beyond those described in Chapter 3 and other actions (including global climate change) that could contribute to the overall cumulative impact. The analysis should only discuss potentially affected resources.
Uranium Fuel Cycle 4.13 As applicable, a discussion of new and potentially significant information that could result in environmental impacts that differ from those estimated by the NRC for the model light-water reactor, including an evaluation of those impacts. For example, the use of high burnup fuel (greater than 62,000 MWd/MTU) and the commensurate analysis to determine if the Table S-4 values are still bounding for the transportation impacts.
Termination of Nuclear Power Plant Operations and Decommissioning 4.14 Impacts associated with the termination of plant operations and decommissioning are evaluated in the GEIS and are considered to be generic (the same or similar at all plants), or Category 1. A discussion of any new and significant information, if applicable; otherwise, termination of plant operations and decommissioning impacts do not need further assessment.
Alternatives to License Renewal 2.6 and Chapter 7 A discussion of the process used to identify and select a range of reasonable alternatives to the proposed action A description of all replacement power alternatives considered in detail, including their associated generating capacity, location, cooling system requirements, land requirements, and construction and operating workforces
Resource Area Regulatory Guide 4.2 S1 Rev. 1 Section Acceptance Review Question Is the following information found in the Environmental Report?
Is the ER discussion sufficient for acceptance for this area/topic?
Does the ER address items required by 10 CFR 51?
Remarks/Notes An explanation as to why certain alternatives were eliminated from detailed study A discussion of the alternatives considered to reduce or avoid adverse impacts A description of the environmental impacts of each replacement power alternative identified for detailed study in sufficient detail and in similar format to proposed action so as to compare the effects of the replacement power alternatives with the effects of continued plant operations.
A description of the environmental impacts of any alternatives identified for reducing adverse effects that were considered for detailed study in sufficient detail and in similar format to proposed action so as to compare the effects of the mitigative alternatives with the effects of continued plant operations.
An analysis of the no action alternative