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Monitoring: The missing piece

The U.S. National Environmental Policy Act (NEPA) of 1969 heralded in an era of more robust attention to environmental impacts resulting from larger scale federal projects. The number of other countries that have adopted NEPA's framework is evidence of the appeal of this type of environmental legislation. Mandates to review environmental impacts, identify alternatives, and provide mitigation plans before commencement of the project are at the heart of NEPA. Such project reviews have resulted in the development of a vast number of reports and large volumes of project-specific data that potentially can be used to better understand the components and processes of the natural environment and provide guidance for improved and efficient environmental protection. However, the environmental assessment (EA) or the more robust and intensive environmental impact statement (EIS) that are required for most major projects more frequently than not are developed to satisfy the procedural aspects of the NEPA legislation while they fail to provide the needed guidance for improved decision-making. While NEPA legislation recommends monitoring of project activities, this activity is not mandated, and in those situations where it has been incorporated, the monitoring showed that the EIS was inaccurate in direction and/or magnitude of the impact. Many reviews of NEPA have suggested that monitoring all project phases, from the design through the decommissioning, should be incorporated. Information gathered though a well-developed monitoring program can be managed in databases and benefit not only the specific project but would provide guidance how to better design and implement future activities designed to protect and enhance the natural environment. -- Highlights: • NEPA statutes created profound environmental protection legislative framework. • Contrary to intent, NEPA does not provide for definitive project monitoring. • Robust project monitoring is essential for enhanced environmental management. • Adaptive database framework is needed to accommodate project-monitoring data.

54 ENVIRONMENTAL SCIENCES↗

NEPA training is essential: it shouldn't just be for environmental staff - 15063

In times of increasing workloads and flat budgets, it is important that the U.S. Nuclear Regulatory Commission (NRC) use available resources and techniques efficiently and effectively to achieve success in environmental reviews throughout the agency. By implementing a contract with Duke University, co-sponsored by the Council on Environmental Quality, to present courses near the NRC Headquarters in the Implementation of National Environmental Policy Act (NEPA), the NRC major program offices achieved success in training a large number of staff in NEPA in a timely and cost-effective manner. In addition, this training is positioning NRC staff to complete the Duke University graduate-level professional certificate in NEPA. (authors)

99 GENERAL AND MISCELLANEOUS↗

Data Analysis for NEPA Supplement Analysis of Chemistry and Metallurgy Research Building Replacement Project at LANL - 16017

The Department of Energy/National Nuclear Security Administration (DOE/NNSA) is proposing to provide analytical chemistry (AC) and materials characterization (MC) capabilities at the Los Alamos National Laboratory (LANL) by using a combination of existing space in two existing buildings: The Radiological Laboratory/Utility/Office Building (RLUOB) and the Plutonium Facility, Building 4 (PF-4) in TA-55. This represents a change from decisions made by DOE as informed by previous National Environmental Policy Act (NEPA) analyses. In accordance with Council on Environmental Quality and DOE requirements, NNSA prepared a Supplement Analysis to evaluate the potential environmental impacts of the proposed action. The focus of this analysis is on determining whether the proposal to provide AC and MC laboratory capabilities in existing space in RLUOB and PF-4 rather than building a new nuclear facility is a substantial change that is relevant to environmental concerns or whether new circumstance or information relevant to environmental concerns and bearing on the proposed action or its impacts are significant. The determination of the analysis is that the existing Chemistry and Metallurgy Research Building Replacement Environmental Impact Statement (CMRR EIS) need not be supplemented, nor is a new EIS required, because 'the proposed changes do not represent a substantial change that is relevant to environmental concerns.'[1 p.49] No further NEPA analysis is necessary. This report describes the analysis used to create data needed for the Supplement Analysis. Los Alamos subject matter experts estimated equipment lists, facility modifications, waste quantities, labor needs and radiological doses. Los Alamos NEPA experts assisted in compiling existing data from the LANL Site-Wide EIS and CMRR EIS for public and other impacts. Bounding conditions were used to determine NEPA estimates. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗