Integrating NEPA (National Environmental Policy Act) and CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) requirements during remedial responses at DOE facilities

US Department of Energy (DOE) Order 5400.4, issued October 6, 1989, calls for integrating the requirements of the National Environmental Policy Act (NEPA) with those of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) for DOE remedial actions under CERCLA. CERCLA requires that decisions on site remediation be made through a formal process called a Remedial Investigation/Feasibility Study (RI/FS). According to the DOE order, integration is to be accomplished by conducting the NEPA and CERCLA environmental planning and review procedures concurrently. The primary instrument for integrating the processes is to be the RI/FS process, which will be supplemented as needed to meet the procedural and documentational requirements of NEPA. The final product of the integrated process will be a single, integrated set of documents; namely, an RI report and an FS-EIS that satisfy the requirements of both NEPA and CERCLA. The contents of the report include (1) an overview and comparison of the requirements of the two processes; (2) descriptions of the major tasks included in the integrated RI/FS-EIS process; (3) recommended contents for integrated RI/FS-EIS documents; and (4)a discussion of some potential problems in integrating NEPA and CERCLA that fall outisde the scope of the RI/FS-EIS process, with suggestions for resolving some of these problems. 15 refs.