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At least 343 records · Page 19

Addendum 2 to the Closure Report for CAU 577 Area 5 Chromium Containing Waste Disposal Cells, NNSS, Nevada

Corrective Action Unit (CAU) 577, “Area 5 Chromium Containing Waste Disposal Cells,” includes five low-level waste cells at the Nevada National Security Site Area 5 Radioactive Waste Management Site where buried waste received from Nuclear Fuel Services, Inc., was subsequently determined to contain chromium that exceeded the toxicity characteristic leaching procedure regulatory limit, which would require the waste to carry hazardous waste code D007. CAU 577 was created to satisfy the requirements of the Settlement Agreement (SA) executed between the Nevada Division of Environmental Protection (NDEP) and the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office (NNSA/NFO) on April 25, 2019 (NDEP 2019). The SA required that the chromium-containing waste received from NFS would be addressed following the closure process laid out in the Federal Facility Agreement and Consent Order (FFACO). The FFACO process ensures proper closure of the chromium-containing waste and documentation of that closure through FFACO-type documents. The following three Corrective Action Sites (CASs) were closed, and their closure was documented in the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030, dated September 2021 (U.S. Department of Energy [DOE] Environmental Management [EM] Nevada Program 2021a): • CAS 05-21-02, Waste Disposal Cell 12 • CAS 05-21-03, Waste Disposal Cell 15 • CAS 05-21-04, Waste Disposal Cell 17 Closure of the following CAS was previously documented in the Addendum to the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030-ADD, dated September 2022 (DOE EM Nevada Program 2022): • CAS 05-21-05, Waste Disposal Cell 20 This second addendum to the Closure Report documents the closure activities that have occurred for CAS 05-21-06, Waste Disposal Cell 21. This is the last CAS in CAU 577. The final waste shipment was placed in the waste disposal cell on November 21, 2022. Following this, closure activities began on November 28, 2022, and were conducted according to the Corrective Action Decision Document/Corrective Action Plan (CADD/CAP) for CAU 577 (DOE EM Nevada Program 2021b). The following closure activities were performed: • Constructing an engineered evapotranspiration cover • Installing two subsidence monuments and vadose zone monitoring equipment • Seeding the cover with a mixture of native plant species • Installing four concrete monuments on the corners of the cover and placing two use restriction (UR) warning signs on each monument These activities fulfill applicable federal and state regulations for closure of CAS 05-21-06 and minimize potential future exposure pathways to buried waste. Completed closure activities are also consistent with closure of the nine historical Resource Conservation and Recovery Act (RCRA) units included in Section 10.2.2 of the RCRA Permit that governs hazardous waste management activities at the Nevada National Security Site (Permit NEV HW0101) (NDEP 2023). UR documentation for this CAS is included in Appendix B of this report. The post-closure plan is presented in detail in the CADD/CAP for CAU 577 (DOE EM Nevada Program 2021b), and the requirements are summarized in Section 5.2 of this document. In accordance with paragraph 5D of the SA, a request to incorporate the requirements for post-closure monitoring of CAU 577 was included with the permit application for RCRA Permit NEV HW0101 that was submitted in January 2022 (NNSA/NFO 2022). The request included the post-closure requirements for the three CASs that had been closed at the time of submittal of the application as well as requirements that would be implemented upon future approval of closure of the remaining two CASs. All CAU 577 post-closure monitoring requirements have been captured in the April 4, 2023, Revision 7 of the RCRA Permit (NDEP 2023). As the RCRA Permit NEV HW0101 has been revised since the submittal of the original CAU 577 Closure Report (DOE EM Nevada Program 2021a) and Addendum 1 (DOE EM Nevada Program 2022), the post-closure requirements in this Addendum 2 report do not align with the previous documents. Specific changes resulting from the issuance of Revision 7 of the RCRA Permit are discussed in Section 5.2 of this report. The requirements in this report are consistent with the current permit (NDEP 2023) and supersede all requirements listed in the CAU 577 Closure Report and Addendum 1. All CAU 577 post-closure requirements should be conducted in accordance with the version of the RCRA Permit that is current at the time of the activities being performed. The DOE EM Nevada Program is requesting a Notice of Completion from NDEP for closure of CAU 577. Although CAU 577 is not a legacy site, the FFACO process is being followed to ensure proper closure of the chromium-containing waste. Therefore, transfer of CAU 577 from Appendix III of the FFACO to Appendix IV, Closed Corrective Action Units, is requested, as all closure activities have been completed.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

SolarAPP+ Enhancements and Commercialization (Final Technical Report)

With millions of distributed photovoltaic (PV) systems expected to be installed over the next five years, the permitting and inspection processes of authorities having jurisdiction (AHJs) may become overburdened, causing delays and increased costs for installed systems (Cruce et al. 2022). The central goal of this project was to automate and streamline permitting processes for distributed PV systems and complementary technologies, such as battery storage. Deploying automated permitting has been hypothesized to reduce permit review times, resulting in reduced costs and improved customer experience. This has the potential to expand the PV and PV-plus-storage market nationwide. The National Renewable Energy Laboratory (NREL) and its project partners, including UL Solutions, the Interstate Renewable Energy Council (IREC), the International Code Council (ICC), and more, developed the Solar Automated Permit Processing (SolarAPP+™) software platform to reduce permit review times. NREL and its partners also collaborated with the solar industry, the building safety community, and local governments to develop SolarAPP+.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Corrective Action Management Unit Report of Post-Closure Care Activities Calendar Year 2019

The Corrective Action Management Unit (CAMU) at Sandia National Laboratories, New Mexico (SNL/NM) consists of a containment cell and ancillary systems that underwent closure in 2003 in accordance with the Closure Plan in Appendix D of the Class 3 Permit Modification (SNL/NM September 1997). The containment cell was closed with wastes in place. On January 27, 2015, the New Mexico Environment Department (NMED) issued the Hazardous Waste Facility Operating Permit (Permit) for Sandia National Laboratories (NMED January 2015) to the U.S. Department of Energy/National Nuclear Security Administration (DOE/NNSA) and its Management and Operating (M&O) contractor. The current M&O contractor is National Technology & Engineering Solutions of Sandia, LLC (NTESS). The Permit became effective February 26, 2015. The CAMU is undergoing post-closure care in accordance with the Permit, as revised and updated. This CAMU Report of Post-Closure Care Activities documents all activities and results for calendar year (CY) 2019, as required by the Permit.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Corrective Action Management Unit Report of Post-Closure Care Activities. Calendar Year 2020

he Corrective Action Management Unit (CAMU) at Sandia National Laboratories, New Mexico (SNL/NM) consists of a containment cell and ancillary systems that underwent closure in 2003 in accordance with the Closure Plan in Appendix D of the Class 3 Permit Modification (SNL/NM September 1997). The containment cell was closed with wastes in place. On January 27, 2015, the New Mexico Environment Department issued the Hazardous Waste Facility Operating Permit (Permit) for Sandia National Laboratories (NMED January 2015) to the U.S. Department of Energy/National Nuclear Security Administration (DOE/NNSA) and its Management and Operating (M&O) contractor. The current M&O contractor is National Technology & Engineering Solutions of Sandia, LLC (NTESS). The Permit became effective February 26, 2015. The CAMU is undergoing post-closure care in accordance with the Permit, as revised and updated. This CAMU Report of Post-Closure Care Activities documents all activities and results for calendar year (CY) 2020, as required by the Permit.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada (CY2021)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): CAU 90, Area 2 Bitcutter Containment, CAU 91, Area 3 U-3fi Injection Well, CAU 92, Area 6 Decon Pond Facility, CAU 110, Area 3 WMD U-3ax/bl Crater, CAU 111, Area 5 WMD Retired Mixed Waste Pits, and CAU 112, Area 23 Hazardous Waste Trenches. This report covers calendar year 2021. The post-closure requirements for these sites are described in RCRA Permit NEV HW0101 and are summarized in each CAU-specific section of this report. The results of the inspections, a summary of maintenance activities, and an evaluation of monitoring data are presented in this report. This report will address all monitoring requirements noted in the RCRA Permit NEV HW0101, except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site. All required inspections, maintenance, and monitoring were conducted in accordance with the post-closure requirements of the permit. Revision 6 of RCRA Permit NEV HW0101 was issued effective December 10, 2015, and remained in effect until December 10, 2020. At the time of this report submittal, the new RCRA permit application was in review.

54 ENVIRONMENTAL SCIENCES↗

Innovative Advanced Hydrogen Mobile Fueler (Final Technical Report)

The US Department of Energy (DOE) funded a project to design, develop, deploy and analyze the economic viability of an innovative Advanced Hydrogen Mobile Fueler (AHMF). As part of the design activity the project team defined specifications based upon vehicle requirements and compliance with specific fueling performance criteria. The AHMF was originally designed to fuel 10-20 fuel cell vehicles (FCV) per day, consistent with the requirements of the H70 fueling category. The AHMF is able to operate without remote power connections, is modular for easy transport and deployment, and can provide expanded daily capacity and multi-day operations using delivered gaseous hydrogen. Toward the end of the project, due to request from the hydrogen industry and some necessary modifications of the AHMF, the system is now modified to fuel heavy duty vehicles. The project was conducted over two primary phases, each including several key tasks, subtasks, and project milestones. Phase 1 involved the design, development, and construction of the AHMF, moving from a conceptual design through to completion of assembly and testing. In addition to reviewing several different approaches, the team chose to take a conventional station design and modify it for mobile fueling. There were several innovative components included in the design. The high pressure storage was the first to achieve a US Department of Energy (DOE) Special Permit (SP 20391) to transport high pressure hydrogen (95 MPa) in a composite cylinder. The second novel system was a liquid nitrogen (LIN) cooling system with a compact heat exchanger. Without this change, the cooling system would not be able to fit into the AHMF. Phase 2 demonstrated the AHMF by fueling fuel cell buses at a fleet in Pomona, CA. The site was chosen because a temporary fueling solution was required while a fixed station was being installed. The existing permits for the fixed station and non-public access also was a determining factor. Over two months, the buses were fueled 320 times with over 5000 kg of hydrogen from tube trailers. Existing shore power was used, and the average electrical efficiency was 0.13 kWh/kg. The average liquid nitrogen (LIN) consumption was 90.68 scf/kg. The fueling and consumption data was provided to the National Renewable Energy Laboratory (NREL) for analysis. An economic analysis was performed and will be provided in a separate report. The project was successful, but not without challenges and lessons learned. The DOT special permit led the way for the use of high pressure, composite cylinders and is being by multiple other systems and applications. The pandemic along with time for the DOT special permit approval delayed the project for years. The team also believes that hydrogen mobile fueling has a use for the industry, especially during this upcoming phase of expansion. However, it does have its limitations due to high cost to build and operate, and the same permitting challenges as a fixed station. A fully capable system at the speeds and pressures of the AHMF may not be necessary for most applications and would help reduce the cost and increase storage capacity. The on-board generator can be easily replaced with shore power or the wide range of power generation solutions in the marketplace. One of the major results of the project was the development of new code language in National Fire Protection Agency (NFPA) 2 and the International Fire Code (IFC) for on-demand mobile fueling. This will provide guidance for Authorities Having Jurisdiction (AHJ) and user on how to permit temporary fueling sites across the nation.

08 HYDROGEN↗

Biofuel Air Emissions Analysis

U.S. has goals to produce 3 billion gallons of sustainable aviation fuel (SAF) annually by 2030, increasing to 35 billion gallons by 2050 to decarbonize the aviation sector. Meeting these production targets will require large number of biorefineries to be set up. However, ability to comply with federal air quality standards is prerequisite to being issued a construction permit. Negotiating the permitting process for a new biorefinery can be quite onerous and cost the investors significant time and money. Although there can be numerous reasons for delayed biorefinery construction, air permitting is fraught with pitfalls because the permitting process relies on precedence, which the future SAF biorefineries lack. NREL's Biofuel Air Emissions Analysis project is unique and innovative in terms of the tools, approaches, and analyses provided. NREL is the only national laboratory that is actively working at the intersection of Federal air quality regulations, emissions and air quality analysis across the supply chain, and process design. This project is focused on providing much needed data and analyses that address biorefinery air permitting. This project develops models and quantitative analyses and measures progress towards meeting air quality regulatory requirements. These models and methods are applied to analyze air permitting related to wastewater sludge to biofuel conversion pathways using hydrothermal liquefaction (HTL), impacts of HTL pathway on local and regional air quality including an assessment of health and equity impacts. In addition to filling research gaps, this project also disseminates the findings to the relevant stakeholders at BETO, other national labs, and regulatory agencies.

air quality↗

Non-Technical Barriers to Geothermal Development in California and Nevada

Geothermal project development in the United States may be subject to numerous permits, authorizations, and other regulatory requirements at the federal, state, and local level, which are necessary to address potential environmental and resource impacts at geothermal project sites. This report presents the findings of our study, including an analysis of federal, state, and local geothermal regulatory and permitting processes, case studies analyzing site-specific attributes that may impact project development at four selected geothermal project sites, an analysis of cost and timeline implications for geothermal project development, and the results of a qualitative study focused on inter-agency coordination and collaboration efforts between federal, state, and/or local agencies for geothermal projects located in California and Nevada. Our analysis found that development timelines may be impacted by multiple federal and state environmental review processes and duplicative permitting requirements as well as coordination efforts between numerous federal, state, and local agencies involved in issuing authorizations and permits necessary for project development. In addition, projects in California and Nevada may face site-specific environmental challenges due to the presence of sensitive resources (e.g., biological species and species habitat, cultural resources) that may result in project construction delays. Our study results also indicate that protracted geothermal development timelines caused by delays in acquiring necessary permits and environmental reviews may result in loss of generated electricity revenue and additional financing costs, which may increase economic uncertainty associated with project development. Through our qualitative analysis, we found that utilization of best practices, including tiering to existing environmental review documents and developing memoranda of understanding, which clearly delineate agency roles and responsibilities may reduce overall project timelines, costs, and uncertainties associated with geothermal project development in California and Nevada.

15 GEOTHERMAL ENERGY↗

Storm Water Pollution Prevention Plan Middle DP Road Recovery Effort, June 26, 2020

The United States Environmental Protection Agency (EPA) has issued a final 2017 Construction General Permit (CGP) that covers discharges of stormwater from construction sites. The 2017 National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges from Construction Activity (Appendix D) includes the following requirements:(1) conduct a critical habitat and threatened/endangered species study; (2) develop and implement a Storm Water Pollution Prevention Plan (SWPPP) in accordance with good engineering practices; (3) submit a Notice of Intent (NOI); (4) install and maintain erosion and stormwater controls; (5) perform and document storm water inspections during construction and site stabilization; (6) amend the SWPPP as necessary; and (7) submit a Notice of Termination (NOT) following project completion and final stabilization of disturbed areas. Authorization to discharge storm water is required under this Permit for both large and small construction projects disturbing more than one (1) acre or part of a larger common plan of development that collectively disturbs more than one (1) acre. All parties that meet the definition of Operator must be permitted. Each permittee is not required to develop and implement a separate SWPP Plan. It is required that there be at least one SWPP Plan for a site that incorporates the required elements for all Operators. The 2017 CGP number for New Mexico (Region 6) is NMR100000. This Plan, which has been developed for Triad National Security, LLC (Triad), describes the nature and sequencing of construction activities, potential sources of pollution, and identifies the Best Management Practices (BMPs) to minimize the potential for erosion and storm water pollution. The Plan was developed in accordance with the provisions of the Clean Water Act (33 U.S.C. § §1251 et seq., as amended by the Water Quality Act of 1987, P.L. 100-4), and the regulations established by the U.S. Environmental Protection Agency (EPA) for National Pollutant Discharge Elimination System (NPDES) General Permits for Storm Water Discharges From Construction Activities.

54 ENVIRONMENTAL SCIENCES↗

Storm Water Pollution Prevention Plan Middle DP Road Recovery Effort, June 26, 2020 (Copy for Informational Puproses Only)

The United States Environmental Protection Agency (EPA) has issued a final 2017 Construction General Permit (CGP) that covers discharges of stormwater from construction sites. The 2017 National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges from Construction Activity (Appendix D) includes the following requirements: (1) conduct a critical habitat and threatened/endangered species study; (2) develop and implement a Storm Water Pollution Prevention Plan (SWPPP) in accordance with good engineering practices; (3) submit a Notice of Intent (NOI); (4) install and maintain erosion and stormwater controls; (5) perform and document storm water inspections during construction and site stabilization; (6) amend the SWPPP as necessary; and (7) submit a Notice of Termination (NOT) following project completion and final stabilization of disturbed areas. Authorization to discharge storm water is required under this Permit for both large and small construction projects disturbing more than one (1) acre or part of a larger common plan of development that collectively disturbs more than one (1) acre. All parties that meet the definition of Operator must be permitted. Each permittee is not required to develop and implement a separate SWPP Plan. It is required that there be at least one SWPP Plan for a site that incorporates the required elements for all Operators. The 2017 CGP number for New Mexico (Region 6) is NMR100000. This Plan, which has been developed for Triad National Security, LLC (Triad), describes the nature and sequencing of construction activities, potential sources of pollution, and identifies the Best Management Practices (BMPs) to minimize the potential for erosion and storm water pollution. The Plan was developed in accordance with the provisions of the Clean Water Act (33 U.S.C. § §1251 et seq., as amended by the Water Quality Act of 1987, P.L. 100-4), and the regulations established by the U.S. Environmental Protection Agency (EPA) for National Pollutant Discharge Elimination System (NPDES) General Permits for Storm Water Discharges From Construction Activities.

54 ENVIRONMENTAL SCIENCES↗

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada: For Calendar Year 2020 (Rev. 2)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): 1) CAU 90, Area 2 Bitcutter Containment; 2) CAU 91, Area 3 U-3fi Injection Well; 3) CAU 92, Area 6 Decon Pond Facility; 4) CAU 110, Area 3 WMD U-3ax/bl Crater; 5) CAU 111, Area 5 WMD Retired Mixed Waste Pits; 6) CAU 112, Area 23 Hazardous Waste Trenches The locations of the sites are shown in Figure ES-1. This report covers calendar year 2020. The post-closure requirements for these sites are described in RCRA Permit NEV HW0101 and are summarized in each CAU-specific section of this report. The results of the inspections, a summary of maintenance activities, and an evaluation of monitoring data are presented in this report. Site inspections are conducted annually at CAUs 90, 91, and 112; semiannually at CAUs 92 and 110; and quarterly at CAU 111. Additional inspections are conducted at CAUs 92 and 111 if precipitation occurs in excess of 1.0 inch in a 24-hour period. Inspections include an evaluation of the condition of the units, including covers, fences, signs, gates, and locks. At CAUs 110 and 111, soil moisture monitoring and subsidence surveys are conducted in addition to the visual inspections. At CAU 110, the site fence, gate, lock, and use restriction signs are evaluated. At CAU 111, an ecological survey, direct radiation monitoring, air monitoring, radon flux monitoring, and groundwater monitoring are also conducted. This report will address all monitoring item notes above except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site. All required inspections, maintenance, and monitoring were conducted in accordance with the post-closure requirements of the permit. Revision 6 of RCRA Permit NEV HW0101 was issued effective December 10, 2015, and remained in effect until December 10, 2020. At the time of this report submittal, the new RCRA permit application was in review.

54 ENVIRONMENTAL SCIENCES↗

Laws in Order: An Inventory of State Renewable Energy Siting Policies

This report identifies which government entity or entities in each state or territory have the jurisdictional authority to make siting and permitting decisions about large scale wind and solar projects. The report also covers established timelines for siting and permitting processes, requirements for public involvement in those processes, and the availability of permitting guides and model ordinances designed to assist local jurisdictions. It details state renewable energy siting policies and permitting authorities across the United States, profiling all 50 states plus Puerto Rico. The report release also includes an interactive map that allows users to easily explore each state’s authorities and policy features. The map, hosted by DOE, includes high-level information on each state’s siting and permitting processes and link directly to the profiles in the report.

14 SOLAR ENERGY↗

Large Advanced Space Systems (LASS) computer-aided design program additions

The LSS preliminary and conceptual design requires extensive iteractive analysis because of the effects of structural, thermal, and control intercoupling. A computer aided design program that will permit integrating and interfacing of required large space system (LSS) analyses is discussed. The primary objective of this program is the implementation of modeling techniques and analysis algorithms that permit interactive design and tradeoff studies of LSS concepts. Eight software modules were added to the program. The existing rigid body controls module was modified to include solar pressure effects. The new model generator modules and appendage synthesizer module are integrated (interfaced) to permit interactive definition and generation of LSS concepts. The mass properties module permits interactive specification of discrete masses and their locations. The other modules permit interactive analysis of orbital transfer requirements, antenna primary beam n, and attitude control requirements.

Farrell, C. E.↗

Laser Sounder for Global Measurement of CO2 Concentrations in the Troposphere from Space: Progress

We describe progress toward developing a laser-based technique for the remote measurement of the tropospheric CO2 concentrations from orbit. Our goal is to demonstrate a lidar technique and instrument technology that will permit measurements of the CO2 column abundance in the lower troposphere from aircraft at the few ppm level, with a capability of scaling to permit global CO2 measurements from orbit. Accurate measurements of the tropospheric CO2 mixing ratio from space are challenging due to the many potential error sources. These include possible interference from other trace gas species, the effects of temperature, clouds, aerosols & turbulence in the path, changes in surface reflectivity, and variability in dry air density caused by changes in atmospheric pressure, water vapor and topographic height. Some potential instrumental errors include frequency drifts in the transmitter, small transmission and sensitivity drifts in the instrument. High signal-to-noise ratios and measurement stability are needed for mixing ratio estimates at the few ppm level. We have been developing a laser sounder approach as a candidate for a future space mission. It utilizes multiple different laser transmitters to permit simultaneous measurement of CO2 and O2 extinction, and aerosol backscatter in the same measurement path. It directs the narrow co-aligned laser beams from the instrument's fiber lasers toward nadir, and measures the energy of the strong laser echoes reflected from the Earth's land and water surfaces. During the measurement its narrow linewidth lasers are rapidly tuned on- and off- selected CO2 line near 1572 nm and an O2 absorption line near 770 nm. The receiver measures the energies of the laser echoes from the surface and any clouds and aerosols in the path with photon counting detectors. Ratioing the on- to off-line echo pulse energies for each gas permits the column extinction and column densities of CO2 and O2 to be estimated simultaneously via the differential absorption lidar technique. For the on-line wavelengths, the side of the selected absorption lines are used, which due to pressure broadening, weights the measurements to the lower troposphere, where CO2 variations caused by surface sources and sinks are largest. Simultaneous measurements of O2 column abundance are made using an identical approach using an O2 line. The laser backscatter profiles from clouds and aerosols are measured with other lidar channels, which permits identifying measurements influenced by clouds and/or aerosol scattering in the path. For space use, our lidar would continuously measure at nadir in near polar circular orbit. Using dawn and dusk measurements made over the same region will make it possible to sample the diurnal variations in CO2 mixing ratios. A 1-m diameter telescope is used for the receiver for all wavelengths. When averaging over 50 seconds, our calculations show a SNR of approximately 1500 is achievable for each gas at each on- and off-line measurement. Measurements from such a mission can be used to generate monthly global maps of the lower tropospheric CO2 column abundance. Our calculations show global coverage with an accuracy of a few ppm with a spatial resolution of approximately 50,000 sq. km are achievable each month. We have demonstrated some key elements of the laser, detector and receiver approaches in the laboratory and with measurements over a 206 m horizontal path. These include stable measurements of CO2 line shapes in an absorption cell using a fiber laser amplifier seeded by a tunable diode laser, measurement of small amplitude changes at low optical signal levels with the PMT receiver, and comparison of the horizontal path measurements of CO2 against those from an in-situ instrument.

Abshire, J. B.↗

Subtask 1.3 – Integrated Carbon Capture and Storage for North Dakota Ethanol Production

The Energy & Environmental Research Center (EERC), in partnership with Red Trail Energy, LLC (RTE), a North Dakota ethanol producer; the North Dakota Industrial Commission (NDIC) Renewable Energy Program (REP); and the U.S. Department of Energy (DOE), conducted a feasibility and implementation study for a commercial carbon capture and storage (CCS) effort. This subtask provided technical support and developed recommended practices of how small-scale industrial CO2 emitters (<1,000,000 tonnes of CO2 emitted annually) may economically deploy CCS. The 64-million-gallon dry mill RTE ethanol facility, emitting an average 180,000 tonnes of CO2 annually, was the subject of the case study. The positive outcome of this research, which shows technical and economic potential for ethanol–CCS in North Dakota, has resulted in RTE acquiring an approved Permit to Drill on December 2, 2019, for a stratigraphic test well in early 2020, a necessary step toward a North Dakota CO2 Storage Facility Permit (SFP) for the RTE CCS effort. Outcomes include 1) validating the Broom Creek Formation as a regional target for CCS, 2) determining the full carbon life cycle of an industrial fuel production facility with CCS, 3) developing a field implementation plan (FIP) for small-scale CCS, and 4) determining the validity and pathway for using CCS to meet low-carbon fuel (LCF) standards. The technical team included the EERC, RTE, Trimeric Corporation, Schlumberger Carbon Services, and Computer Modelling Group (CMG). Findings from activities conducted November 2016 – May 2020 are summarized as follows. Several key steps have been accomplished toward validating the Broom Creek Formation as a CO2 injection and storage target at the RTE CCS site, including verification of the presence and structure of sandstone layers that may comprise the potential CO2 storage reservoir and the several thousand feet of overlying confining zone. Work included site characterization using existing data, interpretation of seismic data within the study area, and geologic modeling simulation of CO2 injection. Interpreted results estimate 3000 feet of confining zone between the Broom Creek Formation (storage target) and the lowermost underground source of drinking water (e.g., the Fox Hills Formation). The thickness of the Broom Creek injection target varies 230–420 ft within the survey area. Results were used to inform the location of a stratigraphic test well and associated characterization test program. No impediments were identified within the targeted CO2 storage complex that would prevent the project from moving forward. A stratigraphic test well is the next step to validate these results and to acquire remaining data necessary to develop a North Dakota CO2 SFP application. The EERC generated full carbon life cycle estimates for CCS integration with the RTE ethanol facility. Results indicated that an average 40% reduction in CO2 emissions is possible through CCS implementation. Approximately half of the carbon in the overall life cycle for a dry mill ethanol plant is generated through the fermentation process and emitted to the atmosphere; this is the CO2 stream targeted for CCS. The remaining carbon is attributed to corn feedstock farming (diesel, fertilizer), energy for fuel processing (natural gas, electricity), and transportation (diesel) of the fuel product. Life cycle carbon estimates are also affected by the anticipated energy consumption of a potential capture facility, which depend on the type of CO2 product generated. For example, a 30%–40% net CO2 emission reduction is estimated if a liquefied CO2 facility were incorporated compared to a 40%–50% net CO2 reduction if a supercritical “injection-grade” CO2 product is generated; i.e., more energy is required to further refine the CO2 stream, affecting the full carbon life cycle estimates. A CCS FIP was developed and initiated at the RTE CCS site, resulting in the development of several guidance documents: a CO2 Capture Process Design Package, a North Dakota CO2 geologic Storage Permits Template, and a Public Outreach Package for CCS in North Dakota. General FIP components include CO2 capture system, pipeline and well designs; monitoring, verification, and accounting (MVA) plans; geologic characterization and testing programs; and permitting and outreach plans. Vendor bids were also acquired for the CO2 liquefaction facility. Near-surface characterization (groundwater and soil gas sampling) and geologic characterization (seismic survey) were initiated to inform development of a UIC Class VI-compliant MVA plan compliant with a North Dakota CO2 SFP. Designs (well and geologic testing) were completed for a stratigraphic test well compliant with a North Dakota CO2 SFP. In addition, the outreach plan was executed, including community open houses, meetings with city/county/state officials, and development of public materials. Although other entities continued to mature incentive programs in 2019–2020, California and the Internal Revenue Service (IRS) currently provide the most advanced economic opportunities for CCS integrated with fuel production. The California Low-Carbon Fuel Standard (LCFS) adopted a CCS Protocol in January 2019, allowing submittal of a design-based pathway (DBP) application for an approved temporary (not certified) carbon intensity value for a fully engineered facility. An ethanol–CCS DBP application to the California LCFS Program (officially approved February 28, 2020) was developed to show that the RTE CCS effort meets LCFS requirements. The approved DBP provides confidence to advance the project and supports potential investments. Other entities continue to mature incentive programs. The IRS issued guidance in February 2020 that addresses the definition of beginning of construction and revenue procedure on partnerships for the Enhancement of Carbon Dioxide Sequestration Credit (a.k.a. Section 45Q) CCS tax credit program; the IRS anticipates issuing further guidance on issues such as secure geologic storage, utilization qualifications, and recapture of claimed credits. Maturing incentive programs coupled with workable permitting regulations provide confidence to advance CCS projects in North Dakota and support financial investment to proceed with designing, constructing, and implementing CCS projects at small-scale fuel production facilities. The largest hurdles for CCS implementation at small-scale industrial systems are often business/economic-related (i.e., not technical). Market uncertainty already exists for agriculture-based alternative fuels such as corn ethanol, for which production has increased by ~33%, and prices have correspondingly lowered since 2015. Passing the Section 45Q tax credit program improves economic feasibility for CCS but may require external investors for a small business to achieve maximum benefits. Public–private partnerships with NDIC and DOE have resulted in foundational technical and regulatory knowledge, growing stakeholder confidence, and a pathway to implementation that enables similar industrial CCS projects in the region to advance. This subtask was funded through the EERC–DOE Joint Program on Research and Development for Fossil Energy-Related Resources Cooperative Agreement No. DE-FE0024233. Nonfederal funding was provided by NDIC and RTE. The authors would also like to thank CMG, ESRI, IHS, Neuralog, and Schlumberger for allowing the use of their software packages in support of this work.

42 ENGINEERING↗

A Systematic Evidence Based Performance Approach to Regulation of Nuclear Sites in England and Wales - 20058

The Environment Agency for England has developed a systematic evidence-based approach to pursue our strategic environmental objectives for the regulation of nuclear sites. We use an annual evidence review process to ensure effective and efficient targeting of limited resources to achieve those objectives. Over the last 8 years, we have been developing and refining this approach to ensure risk-based and value driven regulation. The approach comprises nuclear site and nuclear sector review processes known as Site Environment Review (SER) and Nuclear Environment Review (NER). This approach complements our regulation of nuclear site permit holders under the Environmental Permitting Regulations (EPR). We deliver our regulation of nuclear sites in England and Wales alongside the Office for Nuclear Regulation. The SER process involves the lead regulator for each nuclear site assessing the permit holder's environmental performance across 14 themes, set within the context of the site's main activities and associated waste disposals. Our themes include environmental leadership, resources and climate change, radioactive waste management, facility management and decommissioning, groundwater, and environmental radiological protection. We use evidence from site inspections and working within our subject matter groups to grade current and predicted future environmental performance. We are particularly interested in sustainability and the application of Best Available Techniques (BAT) to prevent the creation, and minimise the disposal, of radioactive wastes. We use risk analysis (strengths, weaknesses, threats and opportunities) to examine performance against our strategic environmental objectives, which are set out, in our 5-year Nuclear Delivery Plan (NDP). The output supports the targeting of our resources at each nuclear site. We consult the relevant permit holders on the SER priorities and use their feedback to refine our plans. We expect all permit holders to take account of our priorities when considering their own programmes of work, objectives and plans. The NER process brings together what we learn and achieve through regulation across the sector. It provides input to planning priorities, supported by qualitative and semi-quantitative evidence. It covers the 28 nuclear sites in England and Wales and spans the same 14 environmental themes. During the process we collate, compile and summarise evidence from the SERs and other sources such as inspection reports and evidence from our other nuclear work programmes. The output is the NER annual report. This provides a snapshot of the status of the nuclear sector and gives insights to enable us to regulate more efficiently and effectively. It also takes account of cross-cutting issues and risks such as changes in international standards, domestic policy, regulatory framework, domestic standards and guidance, learning from experience such as incidents, events and good practice, and innovation, research and development. It provides graphics that illustrate the grading of environmental performance for the nuclear sector across the fourteen environmental themes. This analysis allows benchmarking of nuclear site's environmental performance and the visualisation provides a convenient comparison of performance across themes, sites, and over time. We use this intelligence to inform our investment in training and development of our staff, and our cross-cutting engagement on strategic issues with government, the Nuclear Decommissioning Authority (NDA) and other corporate organisations. Adopting this approach can provide benefits with organisational reputation, stakeholder participation and ensuring value from the public investment. This paper describes the history of the SER/NER process, a selection of outputs from the process and ideas for improvement. The paper will be of interest to other regulators and organisations across the world that are interested in supporting continuous improvement. (authors)

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MH-1A Sturgis Decommissioning and Dismantlement - 20281

The U.S. Army Corps of Engineers (USACE) with its prime contractor, Aptim Federal Services, LLC (APTIM), recycled 5,260 metric tons (11.6 million pounds) of material from Sturgis Barge (Sturgis) during the Decommissioning and Dismantlement of the MH-1A nuclear power reactor. The overall objective of the project was to reduce residual radioactivity associated with MH-1A to levels that permitted release of Sturgis for dismantlement and termination of the Army Reactor Office permit. By effectively applying waste hierarchy's three Rs - reduce, reuse and recycle - the Sturgis project not only minimized the amount of waste that required disposal at landfills, but also reduced the potential for long-term environmental liability emanating from these landfills. The project team completed the physical decommissioning efforts in June 2018 in Galveston, TX. In September 2018, radiological surveys were completed to demonstrate the vessel could be released for shipbreaking. Sturgis was towed from Galveston, TX to Brownsville, TX in late September 2018. Shipbreaking, dismantlement and recycling efforts began in early October 2018 and were completed on 15 March 2019. As part of the decommissioning effort in Galveston, the team shipped 69 shipments (860 metric tons) of low-level radioactive waste and radioactive components to the Waste Control Specialist (WCS) facility in Andrews TX for disposal. Certain radioactive components had to be transferred to the Department of Energy prior to placing the materials into the Federal Waste Facility located within WCS. However, most of the radioactive waste was characterized, profiled, approved and managed under the WCS permitted radioactive waste exemption process authorized and implemented by the Texas Commission on Environmental Quality (TCEQ) and the Radioactive Materials Division. This allows LLRW and LLMW to be shipped as regulated waste and then upon receipt at WCS through satisfying the relevant waste acceptance criteria the waste is exempted and placed into the WCS RCRA permitted cell. An additional 35 shipments (544 metric ton) of contaminated hazardous waste water were transported to U.S. Ecology in Robstown, TX for treatment/disposal. An additional 36 shipments (500 metric tons) of non-hazardous wastewater was sent to Republic Waste Services' facility in Fresno, TX. The disposal of these materials required close coordination with State of Texas regulators. During decommissioning, the project team recycled approximately 270 metric tons (600,000 pounds) of lead and steel. As part of the dismantlement in Brownsville, TX the team recycled approximately 5,000 metric tons (11 million pounds) of ferrous and non-ferrous material, limiting our disposal requirements to about 180 metric tons (400,000 pounds) of material (<4% from entire shipbreaking activity). Although the primary hazard being mitigated by this project was radiological, recycling was always a priority for the project. The team strived to achieve sustainability goals as we implemented this one of a kind project. Scrap metal recycling has a large positive impact on the environment and can also favorably impact project disposal costs. Steel is among the most recycled material in the world. Nearly 40% of the world's steel production is made from scrap. Recycling steel also requires 75% less energy than producing it from raw materials. By using recycled steel rather than virgin materials, 2.33 kg of carbon emissions are eliminated per kg of steel [1]. The project recycled more than 4,500 metric tons (10 million pounds) of steel, which eliminated about 10,400 metric tons (23 million pounds) of CO{sub 2}. By implementing a recycling initiative for the Sturgis project, the team was able to realize cost avoidance for disposal of scrap, cost savings from the metals recycled, plus the project provided benefits to the environment through our recycling efforts. Once the dismantlement was complete, the team prepared a detailed decommissioning closure report, which allowed for the termination of the Army Reactor Decommissioning Permit. While it not only reduced any potential long-term environmental liability, this project to decommission and dismantle a floating nuclear power plant is truly unprecedented - it is a prime example of the USACE mission which is: 'Engineering solutions for the Nation's toughest challenges'. This unique, one of a kind, historical power plant was never designed to be taken apart, and the available information about its construction was lacking in many details. The hazards that required mitigation dictated a painstaking and deliberate process in order to avoid any release to the environment and the community, and to protect the health and safety of the workers involved while keeping the waste hierarchy's three R's - reduce, reuse and recycle at the forefront. (authors)

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Non-Technical Barriers to Geothermal Development in California and Nevada [Slides]

This presentation presents the findings of our study, including an analysis of federal, state, and local geothermal regulatory and permitting processes, case studies analyzing site-specific attributes that may impact project development at four selected geothermal project sites, an analysis of cost and timeline implications for geothermal project development, and the results of a qualitative study focused on inter-agency coordination and collaboration efforts between federal, state, and/or local agencies for geothermal projects located in California and Nevada. Our analysis found that development timelines may be impacted by multiple federal and state environmental review processes and duplicative permitting requirements as well as coordination efforts between numerous federal, state, and local agencies involved in issuing authorizations and permits necessary for project development. In addition, projects in California and Nevada may face site-specific environmental challenges due to the presence of sensitive resources (e.g., biological species and species habitat, cultural resources) that may result in project construction delays. Our study results also indicate that protracted geothermal development timelines caused by delays in acquiring necessary permits and environmental reviews may result in loss of generated electricity revenue and additional financing costs, which may increase economic uncertainty associated with project development. Through our qualitative analysis, we found that utilization of best practices, including tiering to existing environmental review documents and developing memoranda of understanding, which clearly delineate agency roles and responsibilities may reduce overall project timelines, costs, and uncertainties associated with geothermal project development in California and Nevada.

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