ML20212F685
| ML20212F685 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1997 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9711050067 | |
| Download: ML20212F685 (3) | |
Text
. . _ . _ _ _ - , _ _ . - -_ __ _ _ .
'~
, October- 29,.1997
- MEMORANDUM T0
- _ Carl J. Pa)eriello Director >
' Office of luclear Material Safety.
and Safeguards
.-' FROM: John T..Greeves. Director Division 'of Waste Management [ Original signed by)
< Office of Nuclear Material Safety ' ' '
.1 - and Safeguards _
r , .
SUBJECT:
MANAGEMENT REVIEW 0F NATIONAL ENVIRONMENTAL. POLICY ACT; ,
[e b, U u DECISIONS IN WASTE MANAGEMENT PROGRAMS- ,.
~
- In response to an NMSS Management Control Plan assignment (Item No. 9 in the a Management Control Plan), the Division of Waste Management recently completed ,
a management control review (MCR) of environmental impact statements (EISs)? i ano environmental assessments (EAs) that have been developed in the_ Division ~.
This study.~1n addition to assessing lessons learned in previous reviews._ ,
describes a new~ methodology, useful in making and recording the decisions < '
< regarding the type (i.e.. EA or EIS) of future environmental reviews. The' report prepered for this review concludes.with six recommendations for
. improving the documented environmental review process. A copy of the report 9 is attached, in a related action, at your request, we are also reviewing current office and division guidance with the objective of 3roviding improved environmental reviews. We will prepare revisions to tlese guidance documents as necessary.
- We intend to incorporate the recommendations of the EIS and EA MCR in the new guidance.
Attachment; As stated
Contact:
John Hickey DWM/NMSS (301) 415-7234 l
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- October 29,;1997 _
MEMORANDUM T0: Carl J. Paperiello. Director Office of Nuclear Material Safety.
and, Safeguards John T. Greeves. Director, g/
FROM:
Division of Waste Manageient Office of Nuclear Material Safety and-Safeguards
SUBJECT:
MANAGEMENT REVIEW 0F NATIONAL ENVIRONMENTAL POLICY,ACT G ISIONS IN WASTE MANAGEMENT PROGRAMS In-response to an NMSS Management Control Plan assignment (Item No. 9 in the Management Control Plan), the Division of Waste Management recently completed ,
a management control review (MCR) of environmental impact statements (EISs) and environmental assessments (EAs) that have been developed in the Division.
This study, in addition to assessing lessons learned in previous reviews, describes a new methodology, useful in making and recording the decisions regarding the type (1.e...EA-or EIS) of future environmental reviews. The report prepared for this review concludes with six recommendations for improving the documented environmental review process. A copy of the report is attached.
In a related action, at your request, we are also reviewing current office and division guidance with the objective of 3roviding improved environmental reviews. -We will prepare revisions-to t1ese guidance documents as necessary.
We 1ntend to incorporate the recommendations of the EIS and EA MCR in the new guidance.
Attachment:
As stated
Contact:
John Hickey. DWM/NMSS (301) 415 7234
~.nr ,
October 29, 1997 . !
I MEMORANDUM T0: CarlLJ. Pa)eriello.- Director Office of luclear Material Safety and_ Safeguards FROM: John T. Greeves. Director-Division of Waste Management [0riginal signed by)
Office of- Nuclear Material Safety '
and Safeguards
SUBJECT:
MANAGEMENT REVIEW OF NATIONAL ENVIRONMENTAL' POLICY-ACT i DECISIONS IN WASTE MANAGEMENT PROGRAMS -l In_ response to an NMSS Management' Control Plan assignment (Item No. 9 in the
- Management Control Plan). the Division of Waste Management recently completed a management control review (MCR) of environmental impact statements (EISs)-
and environmental assessments (EAs) that have been developed in the Division.
This study. in addition to assessing lessons learned in previous reviews.
-describes a new methcdology, useful in making and recording the decisions regarding the type (i.e.. EA or EIS) of future environmental reviews. The report prepared for this review concludes with six recommendations for improving the documented environmental review process, A copy of the report is attached.
In a related action, at your request, we are also reviewing current office and division guidance with the objective of aroviding-improved environmental reviews. We will prepare revisions to t1ese guidance documents as necessary.
We intend to incorporate the recommendations of the EIS and EA MCR in the new .
guidance.
Attachment:
As stated
Contact:
John Hickey. DWM/NMSS (301) 415-7234 TIGET5tMU210
- UI$TRIBDTION'
- 'bentralFile LLDP r/f DWM r/f DWM t/f NMSS r/f Jereeves MFederline JHolonich KStablien Public $> g DOCUMENT NAME: S:\DWM\LLDP\LSP\MEMJGCP.MCR OFC- ,lM@4 LLDPN/ L[ f. DW M M NAME Uo'n Nelson HNkey M7 DATE 10/4//97 10h /97 10/)//97 10/2$/97 / /94 0FFICIAL RECORD COPY LSS: YES NO X ACNW: YES x NO ~ ~
IG: .YES ~ NO 7 Delete file after distribution YES NO x
MANAGFsMENT REVIEW OF NATIONAL ENVIRONMENTAL POLICY ACT
_ DECISIONS IN THE WASTE MANAGEMENT PROGR, AIS lYepared by LeRoy S. Person, Sr. Materials Engineer Low 'sevel Waste & Regulatory Issues Section Low-Level Waste & Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety & Safeguards September 26,1997 Attachment h0 (] ('/)
. <g.
. MANAGEMENT-REVIEW OF NATIONAL ENVIRONMENTAL POLICY ACT
-DECISIONS IN THE WASTE MANAGEMENT-PROGRAMS TABLE OF CONTENTS Sect Description Pace I. PURPOSE. . .;. . . . . . . . . . . . . . . . . . . . . . 1 II . - INTRODUCTION . . . . . . . . . .. . . . . . . . . . . . 1 III. DOCUMENTATION OF ENVIRONMENTAL REVIEWS . . . . . . . . . 1
~
IV. NEED FOR A CONSISTENT DECISION FRAMEWORK . . . . . . . . 3 V. STUDY METHODOLOGY , . . . . . . . . . . . . . . . . . . 3-A. General Approach . . . . . . . . . . . . . . . . . 3 B. Review of Decisions Regarding Level of Environmental Review and Method of Preparation . . 4 C. Selection'of Major Factors Influencing the Decision 3ases . . . . . . . . . . . . . . . . . . 4 VI. APPLICATION OF INFLUENCE FACTORS TO SITES IN THE STUDY . 6 VII. CONCLUSIONS OF STUDY .. . , . . . . . . . . . . . . . . G A. General . . . . . . . . . . . . . . . . . . . . . . 7 B. Application of Influence Factors to EAs . . . . . 7 C. Application of Influence Factors to EISs . . . . . 7 VIII. IMPACT OF THE NEW DECOMMISSIONING RULE . . . . . . . . 8 IX. RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . 8 X. DOCUMENTS REVIEWED . . . . . . . . . . . . . . . . . . . 9 A. Environmental Assessments . . . . . . . . . . . . . 9 B. Environmental-Impact Statements . . . . . . . . . . 9 Appendix A. Actions-and Requirements Associated with the Development of an Environmental Impact Statement ,
11 4
-MANAGEMENT-REVIEW OF NATIONAL ENVIRONMENTAL POLIC'l ACT DECISIONS IN THE= WASTE MANAGEMENT PROGRAMS
+
I. . PURPOSE The purpose of this. report is to: (1) review the bases'for-
-Division of Waste Management (DWM) decisions to prepare environmental assessments (EAs) and environmental impact statements (EISs)in support of decommissioning and uranium recovery actions; and (2) identify lessons-learned. based on the review with the objective of enhancing the effectiveness, consistency, and efficiency of DWM environmental decisions.
II. INTRODUCTION The U.S. Nuclear Regulatory Commission has established a process by which the Agency analyzes a licensee's proposed action-to determine-if the action will have a significant impact on the human environment and documents the Agency's findings. This process has the purpose of assuring that the Agency, in its decision making, will comply with the requirements of the National Environmental Policy Act of 1969, as amended (NEPA) .
NRC's. regulations in Subpart A of 10 CFR Part 51, " Environmental
-Protection Regulations for Domestic Licensing and Related Regulatory Functions," have been promulgated to implement section 102(2) of NEPA which, in part, requires that Federal agencies identify whether a proposed action is a major Federal action significantly affecting the quality of the human environment. i' The regulations in Part 51 are implemented in a manner that is consistent with NRC's domestic licensing responsibility under the Atomic Energy Act of 1954, as amended-(AEA), the Energy Reorganization Act of 1974, as amended, and the Uranium Mill Tailings Radiation Control Act of 1978.
III. DOCUMENTATION OF ENVIRONMENTAL REVIEWS Licensing actions in the uranium recovery, low-level waste, and decommissioning programs are supported by both safety and environmental _ reviews. The safety reviews are conducted in accordance with applicable Standard Review Plans and are intended to ensure that proposed activities can be conducted safely and in-accordance with NRC requirements under the AEA. The results of safety reviews are typically documented in the form of a safety evaluation report. . Environmental reviews are conducted in accordance-with the applicable provisions.of Part 51 and are documented in one of three ways described in the following paragraphs.
- Categorical Exclusion (CATEX) - This type of action must meet the criterion that=the action has been declared by the Commission, through regulation or rule, to be a category of
P action which neither individually nor cumulatively has a significant effect on the human environment. Such actions have been determined in advance by Commission rule not to require further environmental review (i.e., development of an environmental assessment or an environmental impact statement) and are listed in S51.22.(c).
- Environmental Assessment (EA) - Generally, the staff prepares an EA for actions that do not qualify as a CATEX but, based on the influence factors discussed later in this report, do not appear to require an environmental impact statement (EIS). Assuming that the EA concludes that the proposed action will not result in a significant environmental impact, the EA is accompanied by a formal Finding of No Significant Impact (FONSI). If the EA concludes that a significant environmental impact will result frem the proposed action, an EIS must be developec.
The requirements for an EA and FONSI are contained in S51.30 and S51.32 respectively. An EA describes the proposed action, and gives a brief discussion of: (1) the need for the proposed action; (2) alternatives to the proposed action; (3) the environmental impacts of the proposed action and alternatives; and (4) a list of agencies and persons consulted and identification cf sources used.
- Environmental Impact Statement (EIS) - The most detailed environmental review is the development of an EIS. This process, and the associated regulatory requirements, are summarized in Appendix A to this report. 10 CFR 51.20 specifies the conditions that require an EIS to be developed. These are: (1) the proposed action is a major Federal action significantly affecting the human environment; or (2) the proposed action in olves a matter which the Commission, in the exercise of its discretion, has determined should be covered by an EIS. Because of the broad nature of these two regulatory criteria, considerable uncertainty can exist in determining whether a proposal is a major Federal action. This section of the regulations also specifically requires that an EIS be developed for certain licensing and regulatory actions. Those actions applicable to DWM are:
Issuance of a license to possess and use source material for uranium milling or production of uranium hexafluoride pursuant to 10 CFR Part 40; Issuance or renewal of a license authorizing receipt and disposal of radioactive waste from other persons pursuant to 10 CFR Part 61; and Issuance of a license amendment pursuant to Part 61 authorizing: (1) closure of the facility; (2) transfer 2
of-the. license 1to the' disposal site owner for the purpose of institutional control; or (3) termination of.
, the-license following the institutional control-period.-
None of EIS's reviewed were developed as a result of one of these three requirements.
IV. NEED FOR A CONSISTENT DECISION FRAMEWORK Experience shows that the level of effort required to prepare these documents varies considerably, ranging from a few staff-hours for a CATEX to up to 2-3 (two to three) FTE and
$800,000.00- of technical support for an EIS. In addition, EISs are developed through a formal and public process over several years, including opportunities for adjudicatory review within NRC or through the-courts and public meetings. Litigation and public involvement in NEPA actions can significantly increase esource requirements of the agency and licensees. Consequently, it is important that NRC make decisions on whether EAs or EISs will be prepared in a consistent, defensible, and appropriate manner to ensure prudent use of government and licensee resources.
V. STUDY METHODOLOGY ,
A. -General Anoroach :
Five EAs and four EISs were examined in this study in an effort i I
to determine the level of management review and the most common factors considered by.DNM's staff in its decision to-prepare (or conversely not to prepare) an EIS. These documents are identified in Section X. The decision that a proposed action falls within a CATEX is a relatively straightforward one, as is the documentation for this decision. Therefore, no CATEXs were reviewed in conjunction with this study.
The EAs r.nd EISs reviewed contain the environmental decision records of several types of DNM facilities, including:
decommissioning sites; uranium milling facility final tailings reclamations and treatment pond closures; and in-situ leach operations. Agency actions encompassed by these reviews include:
issuing of a license; amendments to a license; license termination; and review of a licensee's proposed remediation alternative. In addition to reviewing these documents, interviews were-conducted with the licensing project managers and
-the organizational managers of record, where possible, to determine: the level of management review; technical details of the facility; physical conditions at each site; and significant issues.
3
B. Review of Decisions Recardino Level of Environmental Review and Method of Preparation The decision that an action qualifies as a CATEX is normally made by the Section Chief in consultation with the office of the General Counsel. The CATEX finding is concurred in by the Branch Chief. The level of management review concerning the decision to develop an EA is identical. Because of the resource implications involved in developing an EIS, DWM management is consulted in this decision process.
C. Selection of Maio Factors Influencino the Decision Bases The document reviews and staff interviews resulted in the identification of eleven common factors that influenced the decision regarding the type of environmental review conducted for the proposed licensirg actions. The determination if a facuar is significant is reflected in the answer to the questions posed by the influence factors. The factors are defined below and are listed in the first column of Tables 1 and 2. These factors have (1) regulatory influence been divided into two categories:
factors; and (2) site specific influence factors.
- 1. Regulatory Influence Factors (RIFs)
The first six factors of the eleven identified in this study have a citable regulatory basis or are directly related to NRC interim cleanup criteria. These RIFs are major factors that must be considered in the assessment of the impacts of a proposed action because they automatically exert an influence during any assessment of the degree to which the proposed action complies with agency regulations. The six RIFs are defined below.
- Factor 1, Is the Proposed Action Listed in 10 CFR 51.22 as a CATEX? - Proposed actions which do not qualify as a CATEX under 10 CFR 51.22.tc), require either an EA or EIS.
- Factor 2, Is an EIS Requirad by Commission Direction or by 10 CFR 51.20? - This influence would be the result of a Commission decision to exercise its discretion to require an EIS or the action is identified as requiring an EIS as discussed in Section III above.
- Factor 3, Will Meeting Cleanup Criteria Require Large Cost?
- This influence factor accounts for the impact that a lack of available licensee decommissioning funds has on the decision to produce an EA or EIS.
- Factor 4, Are Ground Water Contaminants a Significant Fraction of an Applicable Standard? - This factor recognizes the potential influence on the decision bases from contamination present in a major aquifer.
4
- Factor 5, Does Licensee's Proposed Action Meet Unrestricted i Release Criteria? - This reflects a determination that the residual cleanup criteria cannot. be met and will not allow release of the site for unrestricted use.
- Factor 6,-Does Preliminary Screening Suggest That Long-term Dose Impacts Exceed Dose Standards? - This factor reflects the significance of the dose assessment and the residual contamination, considering a pathways aralysis. Factor 6 differs from Factor 5 in that Factor 5 involves a comparison to establish criteria without the use of a pathways analysis. Factor 6 involves a pathways analysis / dose assessment.
It can be assumed that these RIFs should be considered for all sites although the degree of influence will vary from site to site.
- 2. Site Specific Influence Factors (SSIFs)
The document reviews and the interviews have revealed a set of common factors that are heavily dependent on site specific conditions. The remaining five influence factors in Tables 1 and 2 fall into this category. Each of the SSIFs is discussed below.
- Factor 7, Is There a Special Source Term? - This factor considers the presence and toxicity of significant >
quantities of unusual chemicals or radiological speciee such as transuranic radionuclidea, hazardous organic materials, ,
or mixed waste. This factor also includes consideration of :
such attributes as chemical form (which may have an impact due to enhanced mobility of chemicals and radionuclides).
- Factor 8, Is Cost of Off-Site Disposal Excessive? - This factor considers the influence that availability and cost of off-site disposal will have on the decision bases for the proposed alternative.
- Factor 3, Are Large Quantities of Contaminated Muter al Proposed for Burial On-Site? - This factor reflects the volume of contaminated material if proposed for burial on site.
- Factor 10, Are there Socio-Economic Considerations? - This factor captures the influence of locating a facility in an area that is impoverished or contains a high percentage of minority residents (incluces environmental justice considerations). In addition, other concerns, such as property value impacts, would also fall under this SSIF.
- Factor 11, Is There Heightened Public Interest? - This factor considers the influence of heightened public interest 5
~ . - . . . -..- -- - -- - - - . - - - - - . . . . . . ...~
i from.--local residents, public interest-groups,Eand/or1 thel
- ' news i media ' .
1 VI.---APPLICATION OF INFLUENCE FACTORS TO-SITES IN THE STUDY-Nine! documents were reviewed in this--study and eleven major influence factors were identified asEbeing potentially- '
--significant.in'the= decision-makingLprocess regarding4whether an-EIS should be prepared for a. proposed' licensing action. The
< results-of the review are summarized in Tables 1 and 2. The-first1 row of each table lists the sites associated with the documents reviewed. The first column of each table lists the influence factors. This organization.results in a matrix, the elements of which indicate the influence that each factor had 1.
These influence the-decision-basis for each of the documents.
factors were1not necessarily; considered (or appropriate to be considered) in each proposed licensing-action. However, certain factors have some relevance.to all proposed licensing actions, t
As expected from the diverse nature of the types of proposed actions reviewed, there is obviously a range of impacts-that a particular influence factor might have on an individual licensing case. The scope of this report does not permit an individual
- assessment of each influence factor for each document reviewed. .
VII.' CONCLUSIONS OF STUDY j From this analysis, one can conclude that-most of these factors i i
have the potential to play a role (and indeed may have played a
- role, even if undocumented) in the decision to develop the type of final environmental review (CATEX, EA, or EIS) produced. It *
- would therefore seem to follow that, two proposed licensing actions with similar results from application of the eleven influence-factors would,.more often.then not, result in the decision 1to produce-a similar type of environmental review. In addition, the antearance of ar, affirmative (YES) response te an
' influence factor indicates that a factor s ould h be addressed in whatever environmental review process and/or document chosen for
~
the record. Of course-the environmental impact of one element can"be so overwhelming that it can drive the total decision toward producing an EIS.
Although it may be_ difficult to make quantitative judgements .
- regarding the number of affirmative responses that infer the need to-produce a particular kind of environmental. review document, it appears certain that proposed ~ actions-with large numbers'of
~
-influence factors having. affirmative responses need to consider the. higher level'. document' (i.e.,.EIS).
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This methodology provides a basis for reviewing common factors (or influences) considered-by most reviewers prior to deciding the type of-document that must be prepared for an environmental review. It should also be useful in developing a decision record. However, it can not serve as a tool for exv nning ,
specific environmental documents to determine if the appropriate l I
level of review was conducted, because it is impossible to re-create all the factors that went into that decision. l l
A. General Based on the similarity of the matrices in Table 1 and 2 for EIS and EA documents, the level of environmental review for the documents considered in this study appears, for the most part, to be not only appropriate but consistent in detail, in particular for the EISs.
In general, DWM staff has been consistent in its level of documentation for similar proposed actions.
B. Apolication of Influence Factors to EAs The conclusions below were drawn from an evaluation of the similarities of elements in the matrices for the proposed environmental actions listed in the matrix of Table 1.
A comparison of the matrix elements for all of the five sites reviewed indicate that all of the sites have a small number of affirmative (YES) influence factors which infers that an EIS is probably not warranted. .
C. Acolication of Influence Factors to EISs ,
Review of the four EISs indicate a very high number of affirmative (YES) elements (50 to 75 percent) for all of the documents reviewed. This would strongly suggests that first, a higher level document was warranted and second, production of an EIS requires that each of the influence factors at least be addressed (such is done in an EIS). A specific finding of this review is the presence of an urisual influence factor for the Envirocare case. That factor is the existence of a new source term never before licensed by the Commission. This factor obviously had an influence on the decision to produce an EIS.
This affirmation shows up in SSIF 7 and a case could be made for including this as a separate SSIF in any future analysis.
Although it may seem intuitive, due to the small sample size of this study, the conclusion can not be drawn that RIFs should carry more weight in the decision to produce an EA versus an EIS.
In addition, although this review may indicate a lack of a common definition of a " major Federal Action" regarding the type of proposals reviewed, and which actions should require an EIS, 7
there is at least evidence that EISa, for the most part are developed for the more complex issues requiring environmental review.
VIII. IMPACT OF THE NEW DECOMMISSIONING RULE NRC published its final rule establishing radiological criteria Prior to for license termination on July 21, 1997 (62 FR 29058) .
the promulgation of this rule, decommissioning had been defined as, "to remove (as a facility) safely from service and reduce residual radioactivity to a level that permits release of theand termination of
[ emphasis added) property for unrest;.icted usea proposed remedial action that did
[the) license." Therefore, not meet NRC's criteria for unrestricted release needed This an exemption from the regulations to approve the action. reason is state this study (B&W and Shieldalloy) as a decision basis fc_
development. The new rule redefines " decommissioning" and of The impact the establishes criteria for restricted releases.
new rule on the degree of iafluence of this RIF on future decisions is unclear.
IX. RECOMMENDATIONS should be
- 1. Each of the RIFs listed in Tables 1 and 2 addressed by project managers and organizational managers prior to a determination about what environmental decisionshou document 2.
SSIFs should be listed as part of the environmental review of proposed licensing actions;
- 3. An appropriate standard matrix should be developed for consideration by project managers and for discussion with organizational managers when proposed licensing actions are 3 reviewed to determine what environmental process will be used; and (3), a
- 4. Barring consideration of the recommendation in item record should be developed and discussed prior to determining the document to be produced;
- 5. DWM management should concur in a decision to initiate development of an EIS.
- 6. As a result of the new decommissioning rule, criteria should be established for developing an EIS under conditions of restricted release.
8 l
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= .
'X. DOCUMENTS: REVIEWED A. Environmental Assessments
,1 . " Environmental Assessmcat Related to The Proposed Removal of Thorium Contaminated Slag Storage Piles at The Dow Chemical Company 5 Sites in Midland and Bay City, Michigan"
- 2. " Draft Environmental Assessment offthe Proposed Decommissioning Plan for The Babcock and Wiicox Nuclear Environmental Services Inc., Facility in Parks Township, Pennsylvania"
- 3. " Environmental Assessment of License Application for Onsite Disposal - Mixed Waste Pond Closure Project at the BP Chemicals Plant Lima, Ohio"
- 4. " Supplemental Environmental Assessment Concerning Flow Rate Increase for Crow Butte Resources, Insitu Leach Facility"
- 5. " ARCO Disposal of Polychlorinated Biphenyl Contaminated Waste" B. Environmental Imnact-Statements
- 1. " Draft Environmental Impact Statement, Decommissioning of the Shieldalloy Metallurgical-Corporation, Cambridge, Ohio, Facility" <
t
- 2. " Draft Environmental Impact Statement Related to Reclamation of the Uranium Mill Tailings at the Atlas Site, Moab, Utah"
- 3. " Final Environmental Impact Statement to Construct and Operate the Crowngmint Uranium Solution Mining Project"
- 4. " Final Environmental Impact Statement to Construct and Operate a Facility to Recc.ve, Store, and Dispose of 11e.(2) i Byproduct Material Near Clive, Utah" U
9 s
Table 1 SUMM72Y OF I'7LUENCE FACTORS ENVIRONMENJf4 ASSESSMENTS I
INFLUENCE DOW B&W, PARKS BP ' CROW Bt)rm ARCO FACTOR: CHEMICAL TOWNSHIP CHEMICALS RESOURCES Regulatory Influence Factors
- 1. Is the Proposed Actice No No No No No Listed in 51.22 as a CATEX?
- 2. Is an EIS Required by No No No No No Commission Direction or by >
51.20?
- 3. Hill Meeting Cleanup No No No No No Criteria Require Large Cost?
- 4. Are Ground Water No No No No No Contaminants A Significant Fraction Of Standard? ;
- 5. Does Proposed Action No Yes No No No Exceed Unrestricted Release Criteria?
- 6. Does Preliminary No No Yes No No Screening That'Suggest Long-term Dose Impacts Exceed Standard?
Site Specific Influence Factors
- 7. Is There a Special No Yes Yes No Yes Source Term?
- 8. Is-Cost of Off Site No No No No No Disposal Excessive?
10
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O o o o N N N o s o N e N Y
s e o o Y N N o s o N e 1 1
N Y s
e Y o o N N f
o ? d s s e e n n il o e tae i t iit ot h tri ia g neS cr i at oe e?
uan Sd Ht s
QMO i es ee edr rn rr geo eo ee rtF hC ht aa T T n Lnd c I ie ? ei s ems l r m I c rao a A o i Acpi n l no r .
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Table 2 .
SUMMARY
OF INFLUENCE FACTORS ENVIRONMENTAL IMPACT STATEMENTS ,
i INFLUENCE ATLAS CRLWNPOINT ENVIROCARE SHIELDALLOY FACTOR Regulatory Influence Factors
- 1. Is'the Proposed Action Listed in No No No No 51.22 as a CATEX?
l
- 2. Is an EIS Required by Commission No No No No Direction or by 51.20?
- 3. Will Meeting Cleanup Criteria Yes No No Yes Require Large Cost?
- 4. Are Ground' Water Contaminants A Yes Yes No No Significant Fraction of Standard?
l S. Does Proposed Action Exceed No None Yes Yes Unrestricted Release Criteria? Proposed
- 6. Does Preliminary Screening Yes N/A Yes Yes Suggest That Long-term Dose Impacts Exceed Standard?
Site Specific Influence Factors
- 7. Is'There a Special Source Term No No Yes Yes i
- 8. Is, Cost Of Off Site Disposal Yes No Yes Yes Excessive?
- 9. Are Large Quantities of Yes N/A Yes Yes Contaminated Material Proposed For On Site Burial?
12
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s s e e Y' Y ,
o' o N N s s e e Y Y 3 w 1 -
s v -
o e N Y -
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i c l i b m u o P n
o d c e E n
- e o t i h c g o i S? e s H en ro e r
ei ht e Ta h?
r Tt ee s rd se Ai Ir s e
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, APPENDIX A
-ACTIONS AND REQUIREMENTS ASSOCIATED WITH THE ,
DEVELOPMENT OF AN-ENVIRONMENTAL-IMPACT STATEMENT
~Not' ice of Intent
--Following the determination'that an environmental-impact statement (EIS) will be prepared. A notice of intent (NOI)' to prepare an EIS must be published in the Federal Reaister. The requirements for_an NO1 are contained in 10 CFR 51.27.
Scocing' Process /Recort The scoping process, cormacted in .accordance with 10 CFR 51.28 and 51.29, is an opportunity for public participation in identifying the concerns and issues that should be included-in '
the EIS. The scoping process may include a public scoping
-meeting. At the_conclusionEof the. scoping process, a report is prepared which summarizes the determinations and conclusions reached, including the significant issues identified. A copy of the report is sent to each' participant in the scoping process.
, Environmental Imoact Stateuent The EIS is prepared in two versions, a draft and a' final, with an intervening public comment period. The EIS is normally the result of the staff's review of an environmental report submitted by the. licensee. The staff independently evaluates, and is responsible for the' reliability of, all information in the EIS.
NRC's general requirements for the 'draf t EIS' (DEIS) are contained in 10 CFR 51.70. The format of the DEIS is specified in Appendix a of this Part.
The DEIS is prepared-in accordance with-the scope decided upon in the scoping process and addresses the following topics:
- Cor. sideration of major poir.cs of view concerning the environmental impacts of the-proposed action _and the alternatives and includes an analysis of significant problems and objections raised by interested and affected groups / individuals.-
- -A list of all Federal-permits, l'icenses, approvals, and other entitlements which must be obtained in connection with the proposed action and a description of the status of ;
compliance with these requirements.
- An analysis which considers and. balances the environmentrl effects of the proposed action and the alternatives-available for reducing or avoiding adverse environmental eftects, as well as environmental, economic, technical, and-other. benefits of the proposed' action, a A preliminary recommendation concerning the proposed action.
. .' l In lieu of a recommendation, the staff may indicate that two ,
or more alternatives remain under consideration.
4 The DEIS is distributed in accordance with 951.74 and a notice of 4 availability is published in the W .tl Reafster. A minimum public comment period of 45 days follows.
After receipt and consideraticn of comments; the staff prepares a NRC s general final EIS (FEIS) in the same format as the DEIS.
requirements for the FEIS are contained in 10 CFR 51.90 and 51.91. The FEIS includss:
i
- All substantive comments received on the DEIS.
- Responses to any comments received on the DEIS. Responses may include modification of alternatives, development and evaluation of additional alternatives, revised analyses, factual corrections, and explanation of why comments do not warrant further response.
- A discussion of any relevant opposing view not adequately discussed in the DEIS.
- A statement of how the alternatives considered in it and the decisions based on it will or will not achieve NEPA requirements.
- A final recommendation on the action to be taken.
The FEIS is distributed in accordance with S51.93 and a notice of availability 4s published in the Federal Reaister.
Record of Decishm NRC's regulations (10 CFR 51.102) require f5at any action for which an FEIS has been prepared shall be accompanied by or include a public record of decision (ROD). NRC's general requirements for the ROC are located in 10 CFR 51.103.
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