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Policy Area

ESH-Environment Safety & Health

Procedure Number

ESH100.1.EP.2

Procedure Title

Implement NEPA, Cultural Resources, and Historic Properties Requirements

Procedure Manager

COOPER, TERRY W.

Status

Active

Subject Matter Expert

  • Joseph M. Bonaguidi (Joe)
  • Barbara L. Larsen—SNL/CA

 

Applicability, Exceptions, and Consequences

This corporate procedure applies to all SNL organizations, all management elements, all SNL sites, all Members of the Workforce, and all SNL activities on private and government properties, as well as international settings.

Exceptions to, or deviations from this procedure must be approved through the Executive Policy Sponsor or Policy Area Manager, if delegated. Click here to view Contacts for Corporate Policy System Policies, Processes, and Procedures. See CG100.1.7, Request an Exception to a Policy, Process, or Procedure, for directions on how to obtain an exception to this procedure.

Granting or permitting exceptions or violations of policy, process, or procedure without authority, regardless of position or title, may be cause for disciplinary action up to and including termination of employment. Violating a policy, process, or procedure may be cause for disciplinary action up to and including termination of employment.

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is located on the Sandia National Laboratories Sandia Restricted Network (SRN).

Procedure Overview

This procedure describes the requirements for preparing National Environmental Policy Act (NEPA) documents.

Procedure Requirements

Training

Activity Responsible Individual Required Action
Ensure Training Compliance Managers

Ensure that Members of the Workforce complete the training identified in ESH100.1.EP.2 prior to performing the indicated work activity or fulfilling the indicated role.

Note: See Sandia corporate procedure HR100.2.1, Identify and Complete Sandia Required Training for all Members of the Workforce.

NEPA Planning Process

Activity Responsible Individual Required Action
Prepare a NEPA Checklist Managers

Ensure that a National Environmental Policy Act (NEPA) checklist determination has been received prior to the initiation of proposed actions.

Note:  A NEPA checklist can only be accessed through this link by choosing NEPA Module Software.

NEPA Review Process

Activity Responsible Individual Required Action
Complete a NEPA Checklist Owner of a Proposed Action (Members of the Workforce)
  • Use the Integrated Safety Management System (ISMS) NEPA Software process described in the subsection titled NEPA Checklist Creation, or an SSO approved equivalent process, to complete a NEPA checklist.
  • Use the NEPA Module for unclassified controlled information (UCI), official use only (OUO) project reviews.
  • Do not enter classified information into the NEPA Module.
  • A NEPA determination must be received prior to initiating work.

NEPA Checklist Creation

Notes:

  • The NEPA Module provides a document restriction capability to process Unclassified Controlled Information (UCI) Official Use Only (OUO) project reviews.
  • NO CLASSIFIED INFORMATION MAY BE ENTERED INTO THE NEPA MODULE.

 

Step Responsible Individual Required Action
1 Members of the Workforce

Log onto the ISMS Software home page and create a new record, as follows:

  • Click the NEPA Software button on the ISMS Software home page (links to the NEPA Module home page).
  • Click the NEPA Module Software button on the Welcome screen (links directly to the NEPA Module, which is used to create a corporate record that qualifies as a DOE-approved process to prepare NEPA checklists).
  • Click the Create button.

Notes:  

    • For SNL/NM, if the project would occur outside a Technical Area, but within the boundaries of Kirtland Air Force Base (KAFB), NM, an Air Force Form 813, "Preliminary Environmental Impact Analysis," may be required in place of or in addition to a DOE NEPA checklist (consult a NEPA SME or qualified NEPA reviewers (QNRs) for assistance).
    • The NEPA Practice Module Software can be used to gain familiarity with the module software, if needed.
2 Members of the Workforce

Complete all seven screens of the NEPA checklist.

Note: Tabs for six of the seven screens will appear after the first screen is completed and the Create button located at the bottom is selected.

  • Ensure that appropriate document restrictions are applied.
  • Identify the need-to-know contacts to protect any sensitive information, if the record is restricted to Official Use Only (OUO).
  • Define the scope of the project and the activities that will be conducted.
  • Provide details regarding how the activities of the proposed project could affect the environment. For example, would the proposed action:
    • Produce air emissions?
    • Require discharges to the ground or sanitary sewer?
    • Require the use of hazardous material?
    • Generate hazardous waste?
    • Produce other potential environmental impacts? Note: The list of potential environmental impacts to be discussed would depend on the environmental aspects associated with the proposed action.
  • Get help by doing one of the following:
    • Click on the hyperlinks on the screen.
    • Access ISMS NEPA Module Guidance and FAQs on the NEPA website.
    • Consult a NEPA SME, ES&H coordinator, or qualified NEPA reviewers (QNRs).
3 Members of the Workforce

Submit it by clicking "Save and Submit" under the "Submit" tab, when the NEPA checklist is complete.

Note: For SNL/NM, if the project would occur outside a Technical Area, but within the boundaries of KAFB an Air Force Form 813 (AF Form 813), "Request for Environmental Impact Analysis," may be required in place of, or in addition to, a DOE NEPA checklist. Consult a NEPA SME or QNR for assistance.

NEPA Checklist Review

Step Responsible Individual Required Action
1 Members of the Workforce

Submit the NEPA checklist.

Notes:

  • After the project owner or the qualified NEPA reviewers (QNRs) prepares the NEPA checklist, the NEPA SME or QNR reviews the NEPA checklist.
  • The responsible line manager will receive notification of pending NEPA checklists of proposed projects within their purview via the Corporate Workbox.
2 NEPA SME Review the NEPA checklist.
If … Then …
Complete, Submit to line manager for review and approval.
SME determines that the checklist is incomplete, The SME returns the NEPA review to the Members of the Workforce and the process resets to Step 1.
3 Line Manager Review the NEPA checklist.
If … Then …
Manager approves the NEPA checklist, Software sends an automatic email to the project owner, the organization’s ES&H coordinator, and other interested parties, stating that the review is complete, or the NEPA checklist is forwarded to the DOE/NNSA/SSO NEPA Compliance Officer for a determination (see Review of NEPA Records section and Step 4 in this section).
Manager determines insufficient detail is provided in the NEPA checklist,

Line manager can request more environmental aspect and impact information to enable completion of the review.

Note:  If the line manager requests additional information, the NEPA checklist is returned to the NEPA SME to obtain additional information.

4 SSO NEPA Compliance Officer (NCO) Review the NEPA checklist.
If … Then …
Complete, NCO enters determination into record. Software emails all interested parties. NEPA review is complete.
Insufficient detail provided, NCO returns the review with comments to the SME and process resets to Step 2.

Proceed with the Project

Step Responsible Individual Required Action
1 Members of the Workforce

Review, thoroughly, the DOE/NNSA/SSO NEPA determination for additional project requirements or limitations.

Note: The DOE/NNSA/SSO NEPA Compliance Officer determines NEPA coverage of proposed actions.

2 Members of the Workforce

Proceed with the project only after the following occurs:

  • Notification that the NEPA review is complete and has been received.
  • Identified requirements or limitations have been incorporated into the project.

Use of the NEPA Checklist Identification Number

Activity Responsible Individual Required Action
Cite the
NEPA Checklist Identification Number
Members of the Workforce

Cite the NEPA checklist identification number (NEPA ID number) issued by the ISMS Software NEPA Module (found under the tab title in each NEPA Module screen) when:

  • Preparing proposed-action funding requests, if required.
  • Documenting the NEPA checklist (other methods of documentation may be required for an equivalent NEPA review process).

Note: Compliance with NEPA requirements does not ensure that all ES&H requirements have been identified or addressed. Consult the appropriate division or center ES&H coordinator, environmental compliance coordinator, or division ES&H team member for assistance regarding other regulatory requirements that may affect the project.

Equivalent NEPA Review Process

Activity Responsible Individual Required Action
Use an Equivalent NEPA Review Process Members of the Workforce

Use or establish an equivalent process (approved by a NEPA SME in consultation with DOE/NNSA/SSO) that documents that the following has occurred:

  • Proposed actions have been reviewed for potential environmental impacts.
  • NEPA SMEs or qualified NEPA reviewers (QNRs) (and, preferably, the appropriate ES&H coordinator) have been consulted to determine whether an existing NEPA analysis applies or a DOE NEPA checklist has been completed.
  • NEPA checklists and records have been established for DOE review.

Environmental Limits Included in SNL Site-Wide Environmental Documents

Note: Through the environmental impact analysis included in SNL site-wide environmental documents, the DOE establishes environmental limits for operations at SNL facilities. These limits are established from data provided by facility operators based on existing plans or on best estimates of activities at the facility (which were usually projected for 5 and 10 years). The DOE has published these limits in site-wide NEPA documents for SNL/NM, SNL/CA, TTR, and KTF. For further information for SNL/NM only, see environmental limits included in the SNL site-wide environmental documents NEPA guidance. Contact a NEPA SME for additional information.

 

Activity Responsible Individual Required Action
Adhere to Environmental Limits for Operations at SNL Facilities Managers

Ensure that Members of the Workforce:

  • Understand the environmental limits for the facility operations where new work is proposed to be done.
  • Determine whether proposed new work activities would cause any bounding environmental limits that are in place to be exceeded.
  • Perform a NEPA review in the ISMS Software NEPA Module, when a proposed action is expected to exceed environmental limits for the facility's operations.

Notes:

  • Projects not covered under an existing NEPA document may require a new NEPA checklist.
  • Exceeding a facility's bounding environmental limits without initiating a NEPA checklist can result in an environmental occurrence. Consult a NEPA SME in the Environmental Programs Department for more information on environmental limits for facility operations, and how they are interpreted in the context of facility operations.  At SNL/CA, consult a NEPA SME in the Environmental Management Department.

Compliance with U.S. Air Force NEPA at SNL/NM

Note: The process described in this section applies to activities subject to U.S. Air Force (USAF) land-use permits outside SNL/NM Technical Area (TA) boundaries, but within Kirtland Air Force Base (KAFB), NM.

 

Step Responsible Individual Required Action

1

Members of the Workforce

After consultation with a NEPA SME, complete the following actions before beginning activities on USAF properties on KAFB:

  • Consult with the Facilities Management and Operations Center to determine whether a new or modified land-use permit will be required to support proposed SNL/NM activities.
  • Prepare the required USAF NEPA documentation for new land-use permits or permit modifications, if the decision is made to secure a new or modified land-use permit. (Permit renewals are initiated by the Facilities Management and Operations Center.)

Note: Facilities real-estate management maintains detailed real-estate maps identifying DOE- and non-DOE-owned property and permit files for the use of non-DOE property.

2

Members of the Workforce

Determine whether the proposed action affects property on KAFB that is not owned by DOE (usually those lands outside the boundaries of SNL/NM TAs).

Notes:

  • For assistance, consult the Facilities Management and Operations Center or a NEPA SME regarding actions described in current permits and for assistance in determining whether a proposed action could affect property not owned or administered by DOE. (See environmental limits included in SNL site-wide environmental documents NEPA guidance in this topic for information that can be used to assist in this determination.)
  • Requests for new land-use permits require approval by the KAFB Siting Board before the NEPA process can be completed (consult SNL/NM Facilities real-estate management for more information).
If … Then …
The proposed action affects only DOE-owned property, The USAF NEPA process does not apply (see the NEPA Checklist Creation section).
The proposed action affects property on KAFB not owned by DOE,

Go to Step 3.

 

3

Members of the Workforce Determine whether USAF NEPA documentation is required. For assistance in determining whether a proposed action requires additional USAF NEPA documentation, consult a NEPA SME.
If … Then …
No additional USAF NEPA documentation is required, The process is complete.
Additional USAF NEPA documentation is required, Go to Step 4.

4

Members of the Workforce Prepare documentation.
If … Then …
An AF Form 813, "Request for Environmental Impact Analysis," or an Air Force environmental assessment (EA), is required, Members of the Workforce follow the NEPA SME lead in preparing necessary documentation.
Note: The NEPA SME submits documentation to DOE which, upon approval, transmits the document to the USAF for a final determination.

5

Members of the Workforce Review USAF NEPA determination and take appropriate action.
If … Then …
The USAF provides a final NEPA determination,
  • Compliance with USAF NEPA requirements is complete.
  • Meet requirements established by the USAF in its NEPA determination for the NEPA determination to remain valid.
The USAF NEPA determination requires more information, Return to Step 4.

Cultural Resources and Historic Properties for All SNL Sites

Note: Members of the Workforce at all SNL locations must use the following procedure before undertaking an action.

 

Step Responsible Individual Required Action
1 Members of the Workforce

In consultation with a NEPA SME or corporate historian, determine whether the proposed action could affect cultural resources or historic properties.

Note: Examples of such actions include, but are not limited to, the following:

  • Construction of new buildings or facilities.
  • Modification of internal or external portions of existing structures, buildings, and test fixtures.
  • Projects that require grading or excavation – particularly if the project is located outside a technical area (TA) fence.
  • Maintenance and cleanup activities that might result in inadvertent collection and destruction of historic artifacts.
If … Then …
The proposed action will not affect cultural resources or historic properties, Consultation with a NEPA SME will verify this determination.
The proposed action may affect cultural resources or historic properties, Go to Step 2.
Note: NEPA SME or Corporate Historian determines adequacy of survey information.
2 Members of the Workforce

Consult with the NEPA SME to obtain survey information.

Note: The NEPA SME provides the survey information to and consults with the appropriate DOE personnel.

3 Members of the Workforce

Obtain notification and documentation of completion of the cultural resources or historic properties review process from a NEPA SME.

Note: Process results could include authorization to proceed or required mitigation. SNL may be required to provide input to or to prepare other NEPA documentation directed by DOE, such as an environmental assessment (EA) or an environmental impact statement (EIS), before proceeding with the action.

4 Members of the Workforce During earth-disturbing activities, if cultural resources or historic properties are found, suspend work in a safe manner and consult a NEPA SME.

Implementing Tools

Guidance

  • NEPA guidance.
  • ISMS NEPA Module Guidance and FAQs.

Websites

  • ISMS Software home page.
  • ISMS NEPA software.
  • ISMS Software NEPA Module.
  • Customer Funded Record Center.
  • Facilities Management and Operations Center.
  • Environmental Programs Department.

Requirement Drivers (Prime Contract Baseline Directives)

DOE O 450.1A

Additional Drivers

  • DOE O 481.1C, Work for Others (non-Department of Energy Funded Work).
  • 10 CFR 851, Worker Safety and Health Program.
  • 10 CFR 1021, Department of Energy NEPA Implementing Procedures.
  • 36 CFR 60, National Register of Historic Places.
  • 36 CFR 800, Protection of Historic Properties.
  • 40 CFR 1500-1508, Council on Environmental Quality, Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act.
  • Memorandum of Understanding Between SNL/NM Environmental Management Department and the DOE Office of Kirtland Site Operations Outlining the Qualified NEPA Reviewer Processes at SNL/NM.

 

Training Requirements

Responsible Individual Required Recommended
Members of the Workforce responsible for NEPA: Owners of the proposed action who are responsible for initiating a NEPA checklist. N/A ENV120
ISMS100

Qualified NEPA reviewers (QNRs): Trained ES&H coordinators, or other trained NEPA reviewers, who support organization NEPA compliance activities at SNL/NM.

Note: QNRs are trained and located only at SNL/NM.

ENV120 ISMS100 N/A
NEPA Subject Matter Experts (SMEs): Experts in NEPA regulations and requirements who are qualified to make a citation to existing NEPA documentation or forward a proposed action to the DOE/NNSA/SSO for a NEPA determination.

ENV120 

ISMS100 

N/A

 

Note:  In addition to the required training listed above, Members of the Workforce who are responsible for preparing NEPA documents must meet the following criteria:

 

Responsible Individual Required Qualifications

Members of the Workforce who are responsible for NEPA compliance (i.e., owners of the proposed action and those who are responsible for initiating a NEPA checklist).

Note: Where the proposed work involves both construction and operations, Members of the Workforce of both the construction and operations programs shall share responsibility for NEPA compliance.

  • Be cognizant of the scope and technical details of the proposed action (as provided in the project description) and be able to assist the NEPA specialists in identifying environmental aspects and potential impacts associated with the proposed action.

QNRs

Note: QNRs are trained and located only at SNL/NM.

  • Be familiar with key NEPA reference documents, such as site-wide environmental impact statements.
  • Be trained in the use of the Integrated Safety Management System (ISMS) NEPA Module) and current in other required training.
  • Be designated by the responsible SNL NEPA SME with concurrence of the respective division ES&H Coordinator to review and apply NEPA citations against existing NEPA reference documents.
  • Acquire DOE/NNSA/SSO NEPA compliance officer concurrence to review NEPA checklists under the supervision of NEPA SMEs.
NEPA SMEs
  • Have a thorough understanding of NEPA requirements and DOE implementing regulations.
  • Be trained in the use of the ISMS NEPA Module and current in other required training.
  • Be familiar with the content of key NEPA documents associated with SNL operations.
  • Acquire DOE/NNSA/SSO concurrence to review and approve NEPA citations against existing NEPA reference documents.

Related Processes and Procedures

Processes

  • ESH100.2, Analyze and Control Hazards.
  • ESH100.3, Perform Work.
  • IM100.2, Manage and Protect Information.

Procedures

  • ESH100.2.ENV.12, Obtain and Comply with Air Permits.
  • ESH100.2.IH.4, Evaluate and Control Chemical Hazards.
  • ESH100.2.IH.14, Implement Safety Requirements for Biological Agents and Biosafety.
  • ESH100.3.2, Manage Accountability and Operational Modes for Facilities.

Change Summary

Date Summary
12/15/2010

Administrative

Modified

  • Updated links to NEPA SME in Requirements & Instructions that were not updated in the changes of 12/03/2010.
  • Changed name of  "Environmental Programs and Assurance Department" to "Environmental Programs Department" in Requirements and Instructions.

 

12/03/2010

Administrative

Modified

Changed hyperlinks throughout the procedure in Requirements& Instructions, Training Requirements, Forms, Links & Tools, and Additional Drivers. Many of the links were contact-related. 

12/02/2010

Administrative

Modified

  • Updated SAPLE links to subject matter experts for system consistency.
  • Updated dictionary links to term identification numbers for system consistency.
  • Removed extra blank line in Applicability field.
06/14/2010

Administrative

Modified

Changes made on 05/18/2010 were relocated to the beginning of the change summary section.

05/18/2010

Administrative

Modified

  • Under "Related Corporate Processes and Procedures," removed the reference to ESH100.2.IH.5 as it is now reserved, and corrected the title of ESH100.2.IH.4 to "Evaluate and Control Chemical Hazards."
  • Under "Additional Drivers," updated and corrected links.
04/29/2010

Administrative

Modified

  • Fixed links to two glossary terms: "action," and "environmental assessment."
04/14/2010

Administrative

Modified

  • Fixed links to two glossary terms: "action," and "environmental assessment."