Integrating natural resource damage assessment and environmental restoration activities at DOE facilities

Environmental restoration activities are currently under way at many U.S. Department of Energy (DOE) sites under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended. DOE is the CERCLA lead response agency for these activities. Section 120 of CERCLA also could subject DOE to liability for natural resource damages resulting from hazardous substance releases at its sites. A Natural Resource Damage Assessment (NRDA) process is used to determine whether natural resources have been injured and to calculate compensatory monetary damages to be used to restore the natural resources. In addition to restoration costs, damages may include costs of conducting the damage assessment and compensation for interim losses of natural resource services that occur before resource restoration is complete. Natural resource damages represent a potentially significant source of additional monetary claims under CERCLA, but are not well known or understood by many DOE staff and contractors involved in environmental restoration activities. This report describes the requirements and procedures of NRDA in order to make DOE managers aware of what the process is designed to do. It also explains how to integrate the NRDA and CERCLA Remedial Investigation/Feasibility Study processes, showing how the technical and cost analysis concepts of NRDA can be borrowed at strategic points in the CERCLA process to improve decisionmaking and more quickly restore natural resource services at the lowest total cost to the public