Environmental Impact Statements

DOE-HDBK-1163-2003

PSM and EPA RMP requirements; and (3) other facilities not subject to these regulations but

containing hazardous/radioactive materials exceeding emergency management thresholds. The

first two cases present the primary opportunity for hazard analysis integration since they involve

applicability of multiple hazard analysis requirements.

DOE G 151.1-1 V2, Hazardous Survey and Hazards Assessments, acknowledges similarities

between the EPHA and safety analyses that are compliant with 10 CFR 830, Subpart B. This

includes the use of common baseline hazards information, equivalency of many accident

initiators and similarity in consequence assessment models. This similarity also extends to some

aspects of PrHA performed for hazardous non-nuclear operations subject to the PSM and/or RMP

requirements. However, there are also additional features of the EPHA, such as consideration of

malevolent acts, or perhaps, some external hazards (e.g., site-wide chlorine release), which go

beyond the scope of DSAs and PrHAs. Further, the EPHA involves the determination of

protective action criteria based on the level of radiological and chemical releases to environs

surrounding a facility.

Hazards analysis data and results from DSAs, or PrHAs in the case of a non-nuclear

hazardous facility may be useful as a primary basis for conducting EPHAs (alternatively, if

EPHAs already exist, they can be used as source data for DSAs). This includes the use of

baseline assumptions for material inventories (location, quantity and form), energy sources

and accident initiators/scenarios needed in the EPHA to determine emergency management

needs and establish emergency planning zones. This will help minimize the efforts needed

to complete an EPHA.

Environmental Impact Statements. The National Environmental Policy Act (NEPA) of 1969

[Section 102(2)(c) in 40 CFR 1502] requires that environmental impacts be evaluated for

proposed activities that could harm the environment. An Environmental Impact Statement (EIS)

is the vehicle for this analysis and is required by NEPA for certain classes of DOE activities as

defined in 10 CFR 1021, National Environmental Policy Act Implementing Procedures (see

Subpart D, Appendix D). Some examples of activities requiring an EIS include siting,

construction, operation and decommissioning of nuclear fuel reprocessing facilities, waste

disposal facilities, and incinerators. [NOTE: NEPA requirements related to "environmental

assessments" do not explicitly require a hazard analysis and are therefore not presented in this

section.]

For each of the alternatives considered in an EIS, an analysis of facility accidents must be

prepared. This should involve a review of available hazard and accident analysis

information from previous safety analysis documents, environmental assessment

documents, or other available risk assessments such as a PrHA. Data that is common to

these analyses and the EIS includes hazard assumptions such as source term estimates, accident

initiators, and release scenarios. However, the EIS is somewhat different in the methods and

targets chosen to evaluate potential consequences. For example, an EIS includes a broad focus on

impacts to the "human environment" that involves consideration of long-term health and socio-

economic impacts to populations (e.g., potential cancer fatality risks to workers and the public)

from events such as groundwater contamination, as well as consideration of impacts to other

natural resources. DSA and PrHA efforts primarily evaluate a range of accidents with the

potential to significantly impact workers, the public and environment over a relatively short

period of time. In spite of these differences, many of the basic assumptions supporting EIS-

related hazard identification, hazard analysis, and accident analysis activities are consistent

with nuclear safety analysis or chemical PrHA activities.