Getting The Most Out of NEPA Creative Uses of Previously Approved - - PowerPoint PPT Presentation

▶

Apr 04, 2024 6 likes •100 views

Getting The Most Out of NEPA Creative Uses of Previously Approved NEPA Analyses March 18, 2014 www.inl.gov Creativity is not the finding of a thing, but the making something out of it after it is found. ~James Russell Lowell NEPA At INL

SLIDE 1

www.inl.gov

Getting The Most Out of NEPA

Creative Uses of Previously Approved NEPA Analyses

“Creativity is not the finding of a thing, but the making something out of it after it is found.” ~James Russell Lowell March 18, 2014

SLIDE 2

NEPA At INL

DOE-ID NEPA Compliance officer interprets NEPA decisions as a

federal action that cannot be delegated. Approves all new activities at the CX level.

BEA has negotiated a two-tier environmental checklist process for

many ‘routine’ activities. – 1st Tier- a broad generic environmental checklist covering a categorically excluded action, such as R&D (B3.6). These documents receive a thorough technical review and are approved by DOE. – 2nd Tier- a specific environmental checklist that is bounded by a 1st tier EC. Approved by the contractor environmental organization. Receive periodic oversight by the DOE NEPA Compliance Officer.

SLIDE 3

Background

As a research lab, most INL activities are considered

R&D

Relied heavily on CX B3.6 and a sometimes creative

use of “conventional Laboratory operations” and the

verarching checklist process
Revision of 10 CFR 1021 limited CX B3.6 to projects

“generally” taking less than two years

DOE-ID requested greater involvement in

environmental checklists and oversight of actions involving post irradiation examination and fuel (specifically stating these actions are not eligible for the 2nd tier process, and in some cases, not B3.6).

SLIDE 4

Background Cont.

Around the same time, DOE removed certain

environmental documents from the web

Reviewed those on web and requested those that had

the potential to impact INL

In hindsight, the review was very beneficial because it

provided an overview of the NEPA covering INL activities that proved valuable later (INL does not have a site-wide programmatic EIS;SNF EIS addresses core EM missions)

SLIDE 5

Why ask “Why?”

Late 2011, received checklist for installing a glovebox; reference and

justification included CX B3.6

Project pointed to numerous checklists that referenced B3.6 and

argued the action was “routine” and, creatively, “conventional laboratory operations”

“Purpose and Need” needed clarification; big picture look raised a red

flag for a CX

Started annoyingly asking “why”--Needed to continue processing

surplus uranium

June 1996 FEIS for the Disposition of Surplus Highly Enriched

Uranium (DOE/EIS-0240) and ROD (August 1996); 2007 SA Analysis to the EIS for Disposition of Surplus Highly Enriched Uranium (DOE/EIS-0240-SA1) and the August 2011 Amended ROD (EIS-0240); September 1994 Environmental Assessment for the Proposed Interim Storage of Enriched Uranium Above the Maximum Historical Storage Level at the Y-12 Plant Oak Ridge, Tennessee (DOE/EA-0929).

SLIDE 6

Getting “Creative”

Transfer of ZPPR Materials to NNSS

– Material originally analyzed in an EA to be sent to LANL – LANL process transferred to NNSS in separate analysis – Used both NEPA documents to cover transportation from INL to NNSS without a supplement analysis

Terrapower and foreign research reactors

– Fuel R&D and PIE analyzed in the PEIS for Expanded Civilian Nuclear Energy R&D – Irradiation in and transportation to and from foreign reactor was questionable – Was well within the quantities analyzed in the FRR EIS

High Performance Research Reactor Fuel Development

– GTRI Reactor Conversion Program – Used infrastructure that was available at the time the Civilian Nuclear Energy R&D PEIS was completed and actions fit within those analyzed

SLIDE 7

NEPA Documents To Consider

EA and FONSI for Proposed Interim

Storage of Enriched Uranium (DOE/EA-0929)

– 22 DOE sites; evaluated transportation, processing, and interim storage

EA and FONSI for Consolidation of

Certain Materials and Machines for Nuclear Criticality Experiments and Training (DOE/EA-1104)

– LANL, INL, Hanford, ORNL, SNL

WIPP Disposal Phase Final SEIS

(DOE/EIS-0026-S-2)

– WIPP, INL, ORNL, LANL, RFETP, Hanford, SRS—TRU Waste, long-term disposition including characterization and transportation

NRC Generic EIS
Transportation of commercial SNF
Final Waste Management PEIS

(DOE/EIS-0200-F)

– Every major DOE facility; emphasis on where to locate TSDs not comprehensive NEPA for specific sites (site-specific or project specific NEPA could be required)

Programmatic SNF Management and

INEEL Environmental Restoration and Waste Management FEIS (Vol. 1) (DOE/EIS-0203-F), ROD and Amended ROD

– Programmatic impacts of SNF transportation, storage, and characterization for the DOE Complex

Non-proliferation Foreign Research

Reactor SNF FEIS (DOE/EIS-0218- F) ROD and Amended RODS

– SRS, INL, and 10 seaports

SLIDE 8

NEPA Documents to Consider Cont.

Storage and Disposition of Weapon-

usable Fissile Materials FPEIS (DOE/EIS-0229) ROD, Amended ROD

– Pantex, SRS, ORNL, RFETP, INL, LANL, Hanford

Surplus Plutonium Disposition FEIS

(DOE/EIS-0283)

– SRS, INL, Hanford, Pantex, LLNL, LANL, ORNL, Commercial Reactors – Disposition up to 50 metric tons of surplus Pu

PEIS for Accomplishing Expanded

Civilian Nuclear Energy Research and Development and Isotope Production Missions in the U.S. including the FFTR

– ORNL, Hanford, INL, Commercial – Existing infrastructure for isotope production (medical, research, industrial), Pu-238 for NASA, Nuclear R&D for civilian applications

Various site-specific NEPA

documents

SLIDE 9