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Monthly Sewer Monitoring Report for LLNL Livermore Site, April 2020

Lawrence Livermore National Laboratory (LLNL) collects effluent samples from its sewer outfall at the B196 Sewer Monitoring Station (SMS). Effluent flow-proportional composite samples are collected at the SMS on a daily (midnight-to-midnight), weekly (Thursday through Wednesday), and “monthly” (composited from daily) basis; effluent grab samples are also collected each month at that same location. Certified contract laboratories analyzes these compliance samples, and results (Tables 1–3) are used to establish LLNL compliance with the 2019–2020 Wastewater Discharge Permit (Permit 1250) granted by the City of Livermore Water Resources Division (WRD). Supplemental analyses for biochemical oxygen demand (BOD) and total suspended solids (TSS) are performed onsite and reported (Table 4) for the calculation and assessment of sewer service charges. Quarterly, effluent is sampled for metals (24-hour composite) and cyanide (grab sample) concentrations (mg/L). The results are presented in Table 5. In addition to the sampling noted above, the SMS continuously monitors LLNL sewage effluent in real-time for flow rate, pH, metals, and radioactivity. Standard measurement methods are used to monitor flow and pH to determine permit compliance. Unique nonstandard analytical methods monitor for the presence of metals and radioactivity using x-ray fluorescence (XRF) and gamma spectroscopy, respectively. If an anomalous condition is detected by the monitoring system, an alarm activates LLNL’s Sewer Diversion Facility (SDF) and Livermore Water Reclamation Plant (LWRP) operators are notified that a potential release has occurred.

54 ENVIRONMENTAL SCIENCES↗

LLNL Semiannual Wastewater Point Source Monitoring Report (July 2020)

In accordance with the Code of Federal Regulations, Title 40, Part 403.12(e), Lawrence Livermore National Laboratory (LLNL) submits a semiannual monitoring report regarding federally regulated wastewater generating processes (categorical processes) that discharge wastewater to the sanitary sewer system. Attachments A-2 and A-3 of the 2019-2020 Wastewater Discharge Permit #1250 granted to LLNL by the City of Livermore Water Resources Division (WRD) also mandate submission of this report. The LLNL Livermore Site is required to monitor identified electrical and electronic components processes (40 CFR Part 469) and metal finishing processes (40 CFR Part 433) semiannually and to submit monitoring reports in January and July of each year. Under authority delegated to enforce compliance with these regulations, the WRD reviews this report. This report provides information on the significant metal-finishing operations and electrical and electronic component operations located at the Livermore Site during the period from December 1, 2019 through May 31, 2020 and includes descriptions of the LLNL regulated (categorical) processes that discharge to the sanitary sewer. Attachments A-2 and A-3 of the 2019-2020 Wastewater Discharge Permit #1250 provide the list of categorical processes and the required self-monitoring program for point-source discharges at LLNL. The monitoring data collected for this report documents compliance with all federal and local pretreatment limits. Compliance certification accompanies this report, as required by federal regulations.

54 ENVIRONMENTAL SCIENCES↗

Lawrence Livermore National Laboratory Annual Environmental Report 2019

The purposes of the Lawrence Livermore National Laboratory (LLNL) Environmental Report 2019 are to record LLNL's compliance with environmental standards and requirements, describe LLNL’s environmental protection and remediation programs, and present the results of environmental monitoring at the two LLNL sites—the Livermore Site and Site 300. The report is prepared for the U.S. Department of Energy (DOE) by LLNL’s Environmental Functional Area. Submittal of the report satisfies requirements under DOE Order 231.1B, “Environment, Safety and Health Reporting,” and DOE Order 458.1, “Radiation Protection of the Public and Environment.” The report begins with an executive summary, which provides the purpose of the report and an overview of LLNL’s compliance and monitoring results. The first three chapters provide background information: Chapter 1 is an overview of the location, meteorology, and hydrogeology of the two LLNL sites; Chapter 2 is a summary of LLNL’s compliance with environmental regulations; and Chapter 3 is a description of LLNL’s environmental programs with an emphasis on the Environmental Management System including pollution prevention. The majority of the report covers LLNL’s environmental monitoring programs and monitoring data for 2019: effluent and ambient air monitoring and dose assessment (Chapter 4); waters, including wastewater, storm water runoff, surface water, rain, and groundwater (Chapter 5); and terrestrial, including soil, sediment, vegetation, foodstuff, ambient radiation, and special status wildlife and plants (Chapter 6). The remaining two chapters discuss LLNL’s groundwater remediation program (Chapter 7), and quality assurance for the environmental monitoring programs (Chapter 8). Complete monitoring data, which are summarized in the body of the report, are provided in Appendix A.

54 ENVIRONMENTAL SCIENCES↗

Annual Site Environmental Report (CY2019)

The primary purpose of this report is to summarize the performance of Ames Laboratory’s environmental programs, present highlights of significant environmental activities, and confirm compliance with environmental regulations and requirements for calendar year 2019. This report is a working requirement of Department of Energy Order 231.1B, Environment, Safety and Health Reporting. It includes descriptions of the Laboratory’s site, mission, the status of its compliance with applicable environmental regulations, its planning and activities to maintain compliance, and a comprehensive review of its environmental protection, surveillance and monitoring activities.

54 ENVIRONMENTAL SCIENCES↗

Requirements and Conceptual Design of Off-gas Systems for the Reprocessing of Metallic Fuels

An assessment has been conducted to determine how key regulations regarding volatile radionuclide emissions to the atmosphere may apply to the off-gas streams associated with electrochemical reprocessing. The scope of this assessment was based upon a generic electrochemical reprocessing scheme with a throughput rate of 200 MTIHM/y applied to metallic fuel discharged from a sodium fast reactor (SFR), but the findings are able to be translated to other advanced nuclear scenarios as merited. Air dispersion modeling was performed using the EPA CAP-88 model and evaluated the uncontrolled decontamination factors (DFs) that would be required to achieve regulatory compliance with the dose-based limits set forth by EPA regulation 40 CFR 190.10(a). These DFs were compared to those required by fuel cycle–based limits set forth by EPA regulation 40 CFR 190.10(b). Two theoretical sites with disparate climatological conditions were selected for air dispersion modeling (Idaho and Tennessee). The radionuclides modeled included 3 H, 85 Kr, 129 I, and selected alpha-emitting transuranic isotopes (referred to here as 239 Pu-TRU <1y ). It was found that the fuel cycle-based limits in 40 CFR 190.10(b) are most restrictive for 85 Kr and 239 Pu-TRU <1y , with DFs of 3 and 6.1E+09, respectively. The dose-based limit as derived from 40 CFR 190.10(a) could require mitigation of tritium in some scenarios, with an estimated DF of about 3 for the reference scenarios. The fuel cycle-based limit for 129 I resulted in a DF of about 240 for the reference scenario. The need for iodine mitigation based on dose to the public depended upon the physical form of iodine as either particulate or vapor-phase species. Emission of iodine from the facility as a vapor necessitated DFs of about 2 but emission as a particulate would require DFs >6,000 to meet thyroid dose-based limits. Effects of physical form on needed iodine mitigation are significant, but the understanding of speciation of iodine both during electrochemical reprocessing and after release to the atmosphere is limited. The electrochemical processing unit operations were evaluated to identify potential release points for the volatile radionuclides and to assess the potential for retention of the radionuclides within the process (thus decreasing the need for mitigation). Mitigation strategies for 3 H, 85 Kr, 129 I, and 239 Pu-TRU <1y were identified. In all cases, there are reasonably achievable pathways to regulatory compliance, although in some cases additional R&D is merited to verify the chemical speciation of these isotopes and to develop and demonstrate potential treatment technologies for this application. Whether or not additional off-gas controls (beyond common operations such as HEPA filtration and oxygen and moisture control) are needed for any of these regulated or volatile radionuclides depends on the (a) type of facility (NRC-regulated or DOE), (b) used fuel process rate, (c) used fuel burnup and composition, (d) speciation and retention of volatile radionuclides in the process and in the cell gas cleanup system, (e) site-specific parameters such as location, meteorology, stack height, and site boundaries, and (f) levels of conservatism and safety factors used in assessing compliance to air emissions regulations. Performance of this assessment revealed several areas where information is lacking or additional research is required in order to better determine if or what kinds of off-gas control might be needed. First, and most significantly, the understanding of the chemical speciation and physical form and partitioning of iodine during electrochemical processing operations is lacking and prevents the ability to accurately assess the potential iodine mitigation requirements. Future research in this area should be multifaceted and include thermodynamic modeling of iodine speciation in different process steps, experiments to quantify the kinetics of vapor-phase and melt-phase transitions, bench-scale experiments to determine the potential chemical and physical form of iodine emissions from the electrorefining process, and verification of iodine behavior with experiments utilizing operational facilities. Similarly, an improved understanding of iodine behavior in the environment after release from the facility stack will be required to refine dose estimations, as particulate and vapor-phase emissions result in significantly different doses to the MEI.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Primer on the Cost of Marine Fuels Compliant with IMO 2020 Rule

This report aims to provide information for owners and operators of U.S. ocean-going marine cargo vessels on the cost of different approaches to compliance with the IMO mandate to reduce the sulfur content of marine fuels (outside emission control areas) to no more than 0.5%. The IMO 2020 rule came into effect on January 1, 2020. The report discusses a suite of options for compliance including low-sulfur petroleum-based fuels and alternative fuels. Since fuel prices are a primary factor in determining the cost of the various alternatives, the document also includes a discussion of the main drivers of marine fuel prices. The cost analysis compares the average annual costs (capital and fuel) out to 2050 of each compliance approach under alternative scenarios regarding fuel prices, policy, and technology innovation. The cost calculations focus on representative U.S. fleet vessels for containership and tanker types. Even though the analysis focuses on average cost of approaches to comply with IMO 2020, the comparison of approaches also acknowledges other benefits or risks including fuel price risk and the contribution of the approach to achieving other potential environmental performance objectives or regulations.

02 PETROLEUM↗

Annual Status Report (FY 2020): Performance Assessment for the Environmental Restoration Disposal Facility

DOE O 435.1 and DOE M 435.1-1 require that a determination of continued adequacy of the performance assessment (PA) (CP-60089), composite analysis, and disposal authorization statement (DAS) be made annually, and these guidelines must be used to consider the results of data collection and analysis from research, field studies, and monitoring as well as provide the need to update any radioactive waste management basis documents. Beginning in 1996, the Environmental Restoration Disposal Facility (ERDF) started accepting low-level radioactive, hazardous, and mixed wastes generated during cleanup activities at the Hanford Site. ERDF is composed of a series of cells or disposal areas and can accommodate future design expansions as needed. Currently, there are 10 cells. During this reporting period (fiscal year 2020, which extended from October 1, 2019, through September 30, 2020), approximately 3.39E+04 U.S. tons (3.07E+04 metric tons) of waste was disposed at ERDF. From ERDF inception through September 30, 2020, approximately 18.5 million U.S. tons of waste has been disposed at ERDF, which equates to the consumption of approximately 88% of the disposal volume. As a condition of the DAS, disposal operations within ERDF must be in accordance with the waste acceptance criteria (ERDF-00011) that provide specific radionuclide disposal limits, waste form restrictions, and descriptions of acceptable waste packages in compliance with DOE M 435.1-1 requirements. The ERDF waste acceptance criteria stipulate that waste destined for disposal at ERDF be controlled based on source, physical form, and contaminant concentration and activity levels. There have been no changes to the physical configuration of ERDF or to the waste forms (source, physical form, etc.). No new Unreviewed Disposal Question Screenings or Evaluations have been generated during this reporting period. Therefore, there are no noted impacts to the PA, composite analysis, DAS, or radioactive waste management basis documents resulting from the evaluations and screenings. Sum of fraction analysis shows that the disposed inventory meets both the concentration and inventory threshold requirements. A sum of fractions value is computed for ERDF sensitive radionuclides contributing to the all pathways and air pathway inventory limits. Computed values were 8.85E-02 and 1.78E-01, respectively. The disposed waste inventory remained well under the PA imposed limits. Required monitoring was satisfactorily completed during the fiscal year reporting period (fiscal year 2020). Compliance with performance objectives were met as each of the reported values were well below the established limit. Overall, there are no substantive changes to primary PA assumptions nor changes to the PA analysis conclusion; therefore, compliance with DOE O 435.1 and the DAS is maintained.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Annual Status Report (FY 2020): Performance Assessment for the Disposal of Low Level Waste in the 200 East Area Burial Grounds

This annual review provides the projected dose estimates of radionuclide inventories disposed in the 200 East Area Low-Level Waste Burial Grounds (LLBGs) since September 26, 1988. These estimates are calculated using the original dose methodology developed in the performance assessment (PA) analysis (WHC-SD-WM-TI-730). The estimates are compared with requirements of DOE O 435.1 Chg 1 and performance objectives defined in companion documents DOE M 435.1-1 Chg 1and DOE-STD-5002-2017). All performance objectives are currently satisfied, and operational waste acceptance criteria (HNF-EP-0063) and waste acceptance practices continue to be sufficient to maintain compliance with performance objectives. Inventory estimates and associated dose estimates from future waste disposal actions are unchanged from previous years’ evaluations that indicate potential impacts well below performance objectives; therefore, future compliance with DOE O 435.1 Chg 1 is expected. A new PA study was initiated in fiscal year (FY) 2019 for evaluation of active disposal sites within the 200 East and 200 West Areas (Trench 94 in 200 East; Trenches 31 and 34 in 200 West) due to extended time elapsing between the current annual status report and the original PA for the active disposal sites. The new PA for the active disposal sites is expected to be completed in FY 2021. Within the active burial grounds in the 200 East Area, low-level waste and mixed low-level waste will continue to be disposed of in the dedicated U.S. Navy reactor compartment trench at the 218-E-12B Burial Ground (Trench 94). During this reporting period (FY 2020, from October 1, 2019, through September 30, 2020), two reactor compartments were disposed in Trench 94. Results from sorption experiments are summarized for this reporting period to quantify the efficacy of concrete waste forms in retaining key radionuclides (e.g., technetium-99 and iodine-129). The test durations ranged from 1 to 3 months. Continued groundwater monitoring of the 200 East Area LLBGs indicates no groundwater contamination due to LLBG waste. Current assumptions about future land use at the Hanford Site are consistent with PA analysis1 assumptions of a post-closure facility that will not be degraded by human activity. The LLBGs are located in an area identified for waste management and containment of residual contamination. This area will remain after final environmental remediation and the proposed shrinkage of Hanford Site boundaries to small sections within the 200 East and 200 West Areas in the Central Plateau (DOE/EIS-0391). The current closure plan for the LLBGs (DOE/RL-2000-707) estimates that the 200 East LLBGs will be closed in the 2050 timeframe. The Disposal Authorization Statement, other technical basis documents, and the radioactive waste management basis are of continued adequacy to meet the performance objectives of DOE O 435.1 Chg 1. Overall, there are no substantive changes to primary PA assumptions nor the PA analysis conclusion; therefore, compliance with DOE O 435.1 Chg 1 and the Disposal Authorization Statement is maintained.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Application of Manufacturing Quality Management Principles to PV System Installations

To help SETO/DOE achieve its goals, the IBTS team proposed a project addressing system reliability by improving installation standards and quality management. The proposed approach was designed to help achieve measurable reductions in installation defect density and improvements in the performance of PV systems by optimizing design and installation of residential and commercial PV systems. This approach addressed the soft costs associated with installations and quality management. The project demonstrated improved system reliability and reduced PV system installation costs. The software developed improved operations, decreased risk, and increased the overall value of PV systems across their lifecycle. The project used several data collection methods, including extensive industry surveys, face-to-face high-level interviews at industry conferences, stakeholder teleconferences, and in-depth interviews conducted by IBTS staff. Results from the research found the industry needs a uniform assessment method for national providers to be more efficient; the software should support both code officials and installers; most industry stakeholders would find value in a centralized software system that allows them to collect, report, and review information on in-process and completed solar installations; and mobile solutions that bridge existing knowledge gaps with inspectors and integrate with existing methodologies (such as permitting software) are of great value. The software solution developed is web-based, allowing for national access, and is built on a Google Firebase platform that can handle significant users and data. It can be used onsite or remotely, allowing for code compliance to continue despite ongoing pandemic related delays or shutdowns for local economies. The information provided by the software tool allows users to uniformly assess a system for compliance and use that aggregated data to identify training topics or create internal process designed to improving issues and reducing occurrence. This solution has multiple benefits in managing quality at time of use and promoting an increase in future safety and quality through education. Perhaps most importantly, this software increases public safety by ensuring compliance of installed systems and allows for local AHJs to remotely engage specialized and qualified solar specific expertise for oversite of the installation in their jurisdictions. Data analysis provides the quality feedback loop identifying the root cause of failure and drives installation practices to improve through training and education, resulting in systems with higher performance, greater reliability, and reduced operations and maintenance costs. With the successful completion of this project, the industry can expect reduced soft costs and increased performance and safety and will ultimately benefit from longer performing systems that cost less to operate.

14 SOLAR ENERGY↗

Risk-Informed Initiating Events and Accident Response

Emerging nuclear technologies and advanced reactor developments have brought proposed changes to the regulatory framework which can be leveraged to improve safety implementation and regulatory oversight processes at existing operating nuclear power plants. Specifically, opportunities exist to make plants’ regulatory compliance processes more efficient. This can be done by decreasing reliance on purely deterministic and prescriptive approaches and expansion of the use of risk informed and performance-based approaches to demonstrate reactor safety while achieving economic gains and efficiencies. In this report, we researched possibilities of economic benefits potentially available from the application of concepts associated with a modernized regulatory framework developed for advanced reactors to the existing light water reactors. We used timing factors to demonstrate the complexity of the existing risk assessments and described how these complexities affect regulatory compliance activities at the plants. We also investigated regulatory framework for both existing and new reactors and provided an overview of potential improvements. Lastly, we evaluated various areas of existing plant operations where modernization of compliance activities can offer substantial benefits.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

2021 Idaho National Laboratory Site Environmental Report

The INL Site’s operations, as well as the ongoing cleanup, necessarily involve a commitment to environmental stewardship and full compliance with environmental protection laws. As part of this commitment, the INL Site Environmental Report is prepared annually to inform the public, regulators, stakeholders, and other interested parties of the INL Site’s environmental performance during the year. This report is published for the DOE-ID in compliance with DOE O 231.1B, “Environment, Safety and Health Reporting.” Its purpose is to: • Present the INL Site, mission, and programs • Report compliance status with applicable federal, state, and local regulations • Describe the INL Site environmental programs and activities • Summarize results of environmental monitoring • Discuss potential radiation doses to the public residing in the vicinity of the INL Site • Report on ecological monitoring and research conducted by contractors and affiliated agencies and by independent researchers through the Idaho National Environmental Research Park • Describe quality assurance methods used to ensure confidence in monitoring data • Provide supplemental technical data and reports that support the INL Site Environmental Report (https://idahoeser.inl.gov/publications.html).

99 GENERAL AND MISCELLANEOUS↗

Performance Assessment for the E-Area Low-Level Radioactive Waste Disposal Facility at the Savannah River Site: Chapter 9

This chapter summarizes the results of PA compliance against all relevant PA POs and measures. The final inventory limits presented in Chapters 7 and 8, as well as the methodology employed, provide assurance that POs will be met throughout the compliance periods. Deterministic and stochastic closure analyses also demonstrate a minimal likelihood of exceeding POs. Potential peaks post compliance are also addressed where future work is proposed to improve the understanding in actual uncertainties.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Lawrence Livermore National Laboratory Environmental Report 2021

The purposes of the Lawrence Livermore National Laboratory Environmental Report 2021 are to record Lawrence Livermore National Laboratory’s (LLNL’s) compliance with environmental standards and requirements, describe LLNL’s environmental protection and remediation programs, and present the results of environmental monitoring at the two LLNL sites—the Livermore Site and Site 300. The report is prepared for the U.S. Department of Energy (DOE) by LLNL’s Environmental Functional Area. Submittal of the report satisfies requirements under DOE Order 231.1B, “Environment, Safety and Health Reporting,” and DOE Order 458.1, “Radiation Protection of the Public and Environment.” The report is distributed electronically and is available at https://saer.llnl.gov/, the website for the LLNL annual environmental report. Previous LLNL annual environmental reports beginning with 1994 are also on the website. Some references in the electronic report text are underlined, which indicates that they are clickable links. Clicking on one of these links will open the related document, data workbook, or website. Sampling location maps throughout this report were created using ArcGIS® software by Esri. The report begins with an executive summary, which provides the purpose of the report and an overview of LLNL’s compliance and monitoring results. The first three chapters provide background information: Chapter 1 is an overview of the location, meteorology, and hydrogeology of the two LLNL sites; Chapter 2 is a summary of LLNL’s compliance with environmental regulations; and Chapter 3 is a description of LLNL’s environmental programs with an emphasis on the Environmental Management System including pollution prevention. The majority of the report covers LLNL’s environmental monitoring programs and monitoring data for 2021: effluent and ambient air monitoring and dose assessment (Chapter 4); waters, including wastewater, storm water runoff, surface water, rain, and groundwater (Chapter 5); and terrestrial, including soil, sediment, vegetation, foodstuff, ambient radiation, and special status wildlife and plants (Chapter 6). The remaining two chapters discuss LLNL’s groundwater remediation program (Chapter 7), and quality assurance for the environmental monitoring programs (Chapter 8). Complete monitoring data, which are summarized in the body of the report, are provided in Appendix A. The report uses Système International units, consistent with the federal Metric Conversion Act of 1975 and Executive Order 12770, “Metric Usage in Federal Government Programs” (1991). For ease of comparison to environmental reports issued prior to 1991, dose values and many radiological measurements are given in both metric and U.S. customary units. A conversion table is provided in the glossary. The report is the responsibility of LLNL’s Environmental Functional Area. Monitoring data were obtained through the combined efforts of the Environmental Functional Area; Environmental Restoration Department; Physical and Life Sciences Environmental Monitoring Radiological Laboratory; and the Radiation Protection Functional Area.

54 ENVIRONMENTAL SCIENCES↗

Performance Assessment for the Disposal of Low-Level Waste in the 200 West Area Burial Grounds (Annual Status Report FY 2022)

This annual review provides the projected dose estimates of radionuclide inventories disposed in the active 200 West Area Low-Level Waste Burial Grounds (LLBGs) since September 26, 1988. These estimates are calculated using the original dose methodology developed in the performance assessment (PA) analysis (WHC-EP-0645). The estimates are compared with the performance objectives defined in U.S. Department of Energy requirements (DOE O 435.1 and its companion documents DOE M 435.1-1 and DOE-STD-5002-2017). All performance objectives are currently satisfied, and operational waste acceptance criteria (HNF-EP-0063) and waste acceptance practices continue to be sufficient to maintain compliance with performance objectives. Inventory estimates and associated dose estimates from future waste disposal actions are unchanged from previous years’ evaluations that indicate potential impacts well below performance objectives; therefore, future compliance with DOE O 435.1 is expected. Within the active burial grounds, low-level and mixed low-level waste currently may be disposed only in two lined trenches in the 218-W-5 Burial Ground (Trenches 31 and 34) until they are either filled or a decision is made to close these trenches. Some mixed low-level waste is also disposed at the Environmental Restoration Disposal Facility in the 200 West Area (which is covered under a separate PA). During this (fiscal year 2022) reporting period (October 1, 2021, through September 30, 2022), waste was disposed to the 200 West Area LLBGs. Continued groundwater monitoring of the 200 West Area LLBGs indicates no groundwater contamination due to LLBG waste. Current assumptions about future land use at the Hanford Site are consistent with PA analysis assumptions of a postclosure facility that will not be degraded by human activity. The LLBGs are in an area identified for waste management and containment of residual contamination (DOE/EIS-0391). The current closure plan for the LLBGs (DOE/RL-2000-70) estimates that the 200 West LLBGs will be closed in the 2050 timeframe. The Disposal Authorization Statement, other technical basis documents, and the radioactive waste management basis are of continued adequacy to meet the performance objectives of DOE O 435.1. Overall, there are no substantive changes to primary PA assumptions and no changes to the PA analysis conclusion; therefore, compliance with DOE O 435.1 and the Disposal Authorization Statement is maintained. A new PA to evaluate the long-term impacts of three disposal trenches that are currently active within the 200 East and 200 West Areas (Trench 94 in the 200 East Area and Trenches 31 and 34 in the 200 West Area) was initiated in fiscal year 2019 and completed in fiscal year 2022. Corrective actions addressing 3 key issues and 31 secondary issues identified during the review process were developed and submitted to the Low-Level Waste Disposal Facility Federal Review Group Co-Chairs for review and approval. This PA provides additional technical basis for the continued adequacy of the existing Operating Disposal Authorization Statement.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Performance Assessment for the Environmental Restoration Disposal Facility (Annual Status Report FY 2022)

DOE O 435.1 and DOE M 435.1-1 require that a determination of continued adequacy of the performance assessment (PA) (CP-60089), composite analysis (CA), and disposal authorization statement (DAS) be made on an annual basis, and that the determination must consider the results of data collection and analysis from research, field studies, and monitoring as well as the need to update any Radioactive Waste Management Basis (RWMB) documents. Beginning in 1996, the Environmental Restoration Disposal Facility (ERDF) started accepting low-level radioactive, hazardous, and mixed wastes that were generated during cleanup activities at the Hanford Site. ERDF is composed of a series of cells or disposal areas and can accommodate future design expansions as needed. Currently, there are eight cells and two supercells in ERDF. Each supercell is the equivalent of two cells. During this reporting period (fiscal year 2022, extending from October 1, 2021, through September 30, 2022), approximately 8.52E+04 metric tons (9.39E+04 U.S. tons) of waste was disposed at ERDF. From ERDF inception through September 30, 2022, approximately 17.0 million metric tons (18.7 million U.S. tons) of waste has been disposed at ERDF, which equates to consumption of approximately 89.1% of the currently constructed disposal volume. According to the design of ERDF, the facility has the ability to be expanded as needed. As a condition of the DAS, disposal operations within ERDF must be in accordance with the waste acceptance criteria (ERDF-00011) that provide specific radionuclide disposal limits, waste form restrictions, and descriptions of acceptable waste packages in compliance with the requirements of DOE M 435-1.1. The ERDF waste acceptance criteria stipulate that waste destined for disposal at ERDF be controlled based on source, physical form, and contaminant concentration and activity levels. There have been no changes to the physical configuration of ERDF or to the waste forms (source, physical form, etc.). No new unreviewed disposal question screenings or evaluations have been generated in this reporting period. Therefore, there are no noted impacts to the PA, CA, DAS, or RWMB resulting from the evaluations and screenings. Sum-of-fractions analysis shows that the disposed inventory meets both the concentration and inventory threshold requirements. A sum-of-fractions value is computed for ERDF sensitive radionuclides contributing to the groundwater pathways and the air pathway inventory limits. Computed values were 5.50E-04 and 3.30E-03, respectively. The disposed waste inventory remained well under the PA imposed limits, as shown in Table 4 and Table 5 in the main text of this report. Required monitoring was satisfactorily completed during the fiscal year reporting period. Compliance with performance objectives were met as each of the reported values were well below the established limit. Overall, there are no substantive changes to primary PA assumptions or changes to the PA analysis conclusion; therefore, compliance with DOE O 435.1 and the DAS is maintained.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Performance Assessment for the Environmental Restoration Disposal Facility (Annual Status Report FY 2021)

DOE O 435.1 and DOE M 435.1-1 require that a determination of continued adequacy of the performance assessment (PA) (CP-60089), composite analysis (CA), and disposal authorization statement (DAS) be made on an annual basis, and that the determination must consider the results of data collection and analysis from research, field studies, and monitoring as well as the need to update any Radioactive Waste Management Basis (RWMB) documents. Beginning in 1996, the Environmental Disposal Facility (ERDF) started accepting low-level radioactive, hazardous, and mixed wastes that were generated during cleanup activities at the Hanford Site. ERDF is composed of a series of cells or disposal areas and can accommodate future design expansions as needed. Currently, there are eight cells and two supercells in ERDF. Each supercell is the equivalent of two cells. During this reporting period (fiscal year 2021, extending from October 1, 2020, through September 30, 2021), approximately 9.14E+04 metric tons (1.01E+05 U.S. tons) of waste was disposed at ERDF. From ERDF inception through September 30, 2021, approximately 16.9 million metric tons (18.9 U.S. tons) of waste has been disposed of at ERDF, which equates to consumption of approximately 88.7% of the currently constructed disposal volume. According to the design of ERDF, the facility has the ability to be expanded as needed. As a condition of the DAS, disposal operation within ERDF must be in accordance with the waste acceptance criteria (ERDF-00011) that provide specific radionuclide disposal limits, waste form restrictions, and descriptions of acceptable waste packages in compliance with the requirements of DOE M 435-1.1. The ERDF waste acceptance criteria stipulate that waste destined for disposal at ERDF be controlled based on source, physical form, and contaminant concentration and activity levels. There have been no changes to the physical configuration of ERDF or to the waste forms (source, physical form, etc.). No new unreviewed disposal question screenings or evaluations have been generated in this reporting period. Therefore, there are no noted impacts to the PA, CA, DAS, or RWMB resulting from the evaluations and screenings. Sum-of-fractions analysis shows that the disposed inventory meets both the concentration and inventory threshold requirements. A sum-of-fractions value is computed for ERDF sensitive radionuclides contributing to the all pathways and the air pathway inventory limits. Computed values were 7.63E-03 and 1.49E-03, respectively. The disposed waste inventory remained well under the PA imposed limits, as shown in Table 4 and Table 5 in the main text of this report. Required monitoring was satisfactorily completed during the fiscal year reporting period. Compliance with performance objectives were met as each of the reported values were well below the established limit. Overall, there are no substantive changes to primary PA assumptions or changes to the PA analysis conclusion; therefore, compliance with DOE O 435.1 and the DAS is maintained.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

2022 LANL Radionuclide Air Emissions Report (Rev. 2)

This report describes the emissions of airborne radionuclides from operations at Los Alamos National Laboratory (LANL) for calendar year 2022 and the resulting off-site dose from these emissions. This document fulfills the requirements established by the National Emissions Standards for Hazardous Air Pollutants in 40 CFR 61, Subpart H – Emissions of Radionuclides other than Radon from Department of Energy Facilities, commonly referred to as the Radionuclide NESHAP or Rad-NESHAP. Compliance with this regulation and preparation of this document is the responsibility of LANL’s Rad NESHAP compliance program, which is part of the Environmental Protection and Compliance (EPC) Division. The information in this report is required under the Clean Air Act and is being submitted to the U.S. Environmental Protection Agency (EPA) Headquarters and EPA Region 6. The highest effective dose equivalent (EDE) to an off-site member of the public was calculated using procedures specified by the EPA and described in this report. LANL’s EDE was 0.45 for 2022. The annual limit is 10 millirem per year, established by the EPA in 40 CFR 61 Subpart H. All measured air emissions are modeled to a single location, known as the Maximally Exposed Individual (MEI). During calendar year 2022, LANL continuously monitored radionuclide emissions at 27 “major” release points, or stacks. The Laboratory estimates emissions from an additional 34 “minor” release points using radionuclide usage source terms in lieu of stack monitoring. Also, LANL uses an EPA approved network of air samplers around the Laboratory perimeter to monitor ambient airborne levels of radionuclides. To provide data for dispersion modeling and dose assessment, LANL maintains and operates several meteorological monitoring towers. From these various systems, a comprehensive evaluation is conducted to calculate the MEI dose for the Laboratory. The MEI can be any member of the public at any off-site location where there is a residence, school, business, or office. In 2022, this MEI location was a business at 95 Entrada Drive, located in the eastern end of Los Alamos town site. The primary contributors to the off-site dose at this location are the ambient air data at that location combined with radioactive gas emissions from the LANSCE facility and the collected potential emissions from unmonitored (minor) sources. Overall, the MEI dose in 2022 is similar to that which has been observed in recent years, and it remains well below the EPA’s 10 millirem per year limit. Doses reported to the EPA for the past 10 years are shown in Table E1.

54 ENVIRONMENTAL SCIENCES↗

PNNL Sequim Campus Radionuclide Air Emissions Report for Calendar Year 2020

The U.S. Department of Energy Office of Science (DOE-SC) Pacific Northwest Site Office has oversight and stewardship duties associated with the Pacific Northwest National Laboratory Sequim Campus. Some research projects have the potential to emit low levels of radioactive materials. This report is prepared to document compliance with the Code of Federal Regulation, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, "Radiation Protection–Air Emissions." Compliance is indicated by comparing the estimated effective dose equivalent (EDE) to the maximally exposed individual (MEI) member of the public with the 10 millirem per year (mrem/yr) U.S. Environmental Protection Agency (EPA) standard. The PNNL Sequim Campus has only fugitive emissions sources. Despite the fact that the regulations are intended for application to point source emissions, fugitive emissions are included with regard to complying with the EPA standard. The EDE to the Campus MEI due to routine operations in 2020 was 3.5E-05 mrem (3.5E-07 mSv). No non-routine emissions occurred in 2020. The Sequim Campus is in compliance with the federal and state 10 mrem/yr standard.

40 CFR 61 Subpart H↗