Consideration of biota dose assessment methodology in preparation of environmental impact statements

The U.S. Nuclear Regulatory Commission (NRC) has been working with the U.S. Department of Energy (DOE) and U.S. Environmental Protection Agency on developing methods, models, and guidance within a graded approach for evaluating radiation doses to biota. This effort has been headed by DOE and is predominately a screening tool to demonstrate compliance with dose to biota standards at existing DOE facilities. The graded approach does, however, have the capability of incorporating site specific pathway and biota data to estimate doses to biota. Two questions under consideration by the NRC are: is a biota dose assessment methodology needed in the existing National Environmental Policy Act (NEPA) framework and how should a biota dose assessment methodology be incorporated into the preparation of an Environmental Impact Statement (EIS). The paper discusses the protection of biota in context of the existing framework of NEPA and the Endangered Species Act, and how protection of biota is typically addressed in EISs prepared by the NRC. The paper also discusses whether the proposed biota dose methodology needs to be considered in preparation of NEPA documents, given the protection afforded under these Acts. The paper also identifies circumstances where an NRC NEPA document would use the dose methodology for impact assessment to biota. (author)