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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
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.

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