Does "consider off-site consequences" mean perform an environmental impact assessment?
What does EPA mean by “consider offsite consequences”? Do we have to do an environmental impact assessment (EIA)?
EPA does not expect you to do an EIA. Potential consequences to the public and the environment are already analyzed in the offsite consequence analysis. In the PHA, EPA only expects you to identify any failure scenarios that could lead to public exposures and to examine whether your strategies are adequate to reduce the risk of such exposures.