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At least 415 records · Page 23

A Preliminary Radiological Risk Assessment Model for Disposition of Remote-Handled Transuranic Wastes at Los Alamos National Laboratory Area G - 20116

The U.S. Department of Energy (DOE) operates a low-level radioactive waste (LLW) disposal site at Material Disposal Area G, in Los Alamos, New Mexico, USA. Area G has been the primary LLW disposal site for Los Alamos National Laboratory (LANL) since the 1960's. In addition to LLW, Area G is host to a variety of other wastes, the disposition of which must be determined before closure of the site. A probabilistic Radiological Risk Assessment (RRA) for Area G is used in order to support decision making regarding some wastes that are not addressed in the extant Area G Performance Assessment (PA) and Composite Analysis (CA). Between 1979 and 1987, 33 special shafts were augered into the Bandelier Tuff at Area G. This volcanic tuff is present across Pajarito Plateau on the eastern slopes of the Jemez Mountains, and varies widely in its consistency, from weakly indurated non-welded layers to welded layers that uphold the mesa cliffs of the Plateau. These mesas are home to LANL, Area G, and the townsites of Los Alamos and White Rock, with residences about 1400 m from Area G. The 33 Shafts were lined with steel casing, and contain remote-handled (RH) transuranic wastes (TRU) resulting from experiments and analysis performed in special glove boxes at the Chemistry and Metallurgy Research (CMR) facility at LANL. Some of these wastes originated as used nuclear fuel. The purpose of the Area G RRA is to evaluate the potential future risk to humans and the environment from the RH TRU in the 33 Shafts in the context of the risk associated with the surrounding wastes at Area G. The analysis is responsive to expectations outlined in DOE Order 458.1, Radiation Protection of the Public and the Environment, and is informed by the Manual and Guidance accompanying DOE O 435.1, Radioactive Waste Management. Because the waste meets the definition of TRU, the regulatory context necessarily takes into consideration the regulation governing the disposal of TRU from the U.S. Environmental Protection Agency (EPA): 40 CFR 191, Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes. Given the broader regulatory context for the RRA, the analysis is subject to different assumptions from those made in the existing DOE O 435.1 PA and CA, such as allowing for future occupation of the site. The analysis begins with a comprehensive evaluation of features, events, processes, and exposure scenarios (FEPS) for Area G and the wastes it contains. These FEPSs are screened to eliminate from further consideration those of extremely low probability and/or consequence, and a conceptual site model (CSM) is subsequently developed. The scope and structure of the Area G RRA Model is informed by this CSM, and the Area G RRA Model is developed using the GoldSim systems analysis modeling platform. This paper presents the initial version of a defensible, transparent, and reasonably realistic model, which is based on the state of knowledge of the wastes, the site, and the FEPSs that govern contaminant transport from wastes into the environment and subsequent exposures to humans and other biota. Probabilistic model input distributions represent uncertainties inherent in the real and modeled systems. The results of the Area G RRA Model inform decisions regarding the disposition of the RH TRU in the 33 Shafts. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

XERICO as a target for engineering stress-resilient crops: Mechanisms, applications, and future directions

XERICO's capacity to enhance ABA-driven stress responses across diverse crops, its regulatory crosstalk with other hormonal pathways, and its compatibility with advanced genetic engineering tools highlight its central role in sustainable agriculture. Leveraging XERICO in crop improvement programs aligns with the urgent need to mitigate the impacts of climate-induced stress in agriculture, offering a pathway toward resilient and high-yielding crops. Here, by enabling crops to withstand drought and other environmental stresses, XERICO-based biotechnological approaches hold transformative potential for global food security and environmental sustainability.

09 BIOMASS FUELS↗

A Review of Modeling Approaches for Understanding and Monitoring the Environmental Effects of Marine Renewable Energy

Understanding the environmental effects of marine energy (ME) devices is fundamental for their sustainable development and efficient regulation. However, measuring effects is difficult given the limited number of operational devices currently deployed. Numerical modeling is a powerful tool for estimating environmental effects and quantifying risks. It is most effective when informed by empirical data and coordinated with the development and implementation of monitoring protocols. We reviewed modeling techniques and information needs for six environmental stressor–receptor interactions related to ME: changes in oceanographic systems, underwater noise, electromagnetic fields (EMFs), changes in habitat, collision risk, and displacement of marine animals. This review considers the effects of tidal, wave, and ocean current energy converters. We summarized the availability and maturity of models for each stressor–receptor interaction and provide examples involving ME devices when available and analogous examples otherwise. Models for oceanographic systems and underwater noise were widely available and sometimes applied to ME, but need validation in real-world settings. Many methods are available for modeling habitat change and displacement of marine animals, but few examples related to ME exist. Models of collision risk and species response to EMFs are still in stages of theory development and need more observational data, particularly about species behavior near devices, to be effective. We conclude by synthesizing model status, commonalities between models, and overlapping monitoring needs that can be exploited to develop a coordinated and efficient set of protocols for predicting and monitoring the environmental effects of ME.

16 TIDAL AND WAVE POWER↗

Naval Reactors Facility Environmental Monitoring Report (CY2020)

This report presents the results of the radiological and non-radiological environmental monitoring programs for 2020 at the Naval Reactors Facility (NRF). Current operations at NRF are in compliance with applicable regulations governing use, emission, and disposal of solid, liquid, and gaseous materials. The results obtained from the environmental monitoring programs verify that releases to the environment from operations at NRF did not have any adverse effect on human health or the environment. Evaluation of the environmental data confirms that the operation of NRF continues to have no adverse effect on the environment or the health and safety of the general public. Furthermore, a conservative assessment of radiation exposure to the general public as a result of NRF operations demonstrated that the maximum potential dose received by any member of the public was well below the most restrictive dose limits prescribed by the US Environmental Protection Agency (EPA), the US Department of Energy (DOE), and the Nuclear Regulatory Commission.

54 ENVIRONMENTAL SCIENCES↗

Naval Reactors Facility Environmental Monitoring Report (CY2019)

This report presents the results of the radiological and non-radiological environmental monitoring programs for 2019 at the Naval Reactors Facility (NRF). Current operations at NRF are in compliance with applicable regulations governing use, emission, and disposal of solid, liquid, and gaseous materials. The results obtained from the environmental monitoring programs verify that releases to the environment from operations at NRF did not have any adverse effect on human health or the environment. Evaluation of the environmental data confirms that the operation of NRF continues to have no adverse effect on the environment or the health and safety of the general public. Furthermore, a conservative assessment of radiation exposure to the general public as a result of NRF operations demonstrated that the maximum potential dose received by any member of the public was well below the most restrictive dose limits prescribed by the US Department of Energy (DOE) and the Nuclear Regulatory Commission.

54 ENVIRONMENTAL SCIENCES↗

Sensor Domain of Histidine Kinase VxrA of Vibrio cholerae : Hairpin-Swapped Dimer and Its Conformational Change

VxrA and VxrB are cognate histidine kinase (HK)-response regulator (RR) pairs of a two-component signaling system (TCS) found in Vibrio cholerae, a bacterial pathogen that causes cholera. The VxrAB TCS positively regulates virulence, the type VI secretion system, biofilm formation, and cell wall homeostasis in V. cholerae, providing protection from environmental stresses and contributing to the transmission and virulence of the pathogen. The VxrA HK has a unique periplasmic sensor domain (SD) and, remarkably, lacks a cytoplasmic linker domain between the second transmembrane helix and the dimerization and histidine phosphotransfer (DHp) domain, indicating that this system may utilize a potentially unique signal sensing and transmission TCS mechanism. Here, we have determined several crystal structures of VxrA-SD and its mutants. These structures reveal a novel structural fold forming an unusual β hairpin-swapped dimer. A conformational change caused by relative rotation of the two monomers in a VxrA-SD dimer could potentially change the association of transmembrane helices and, subsequently, the pairing of cytoplasmic DHp domains. Based on the structural observation, we propose a putative scissor-like closing regulation mechanism for the VxrA HK. IMPORTANCE V. cholerae has a dynamic life cycle, which requires rapid adaptation to changing external conditions. Two-component signal transduction (TCS) systems allow V. cholerae to sense and respond to these environmental changes. The VxrAB TCS positively regulates a number of important V. cholerae phenotypes, including virulence, the type six secretion system, biofilm formation, and cell wall homeostasis. Here, we provide the crystal structures of the VxrA sensor histidine kinase sensing domain and propose a mechanism for signal transduction. The cognate signal for VxrAB remains unknown; however, in this work we couple our structural analysis with functional assessments of key residues to further our understanding of this important TCS.

59 BASIC BIOLOGICAL SCIENCES↗

NASA Principal Center for Review of Clean Air Act Regulations

The Clean Air Act (CAA) regulations have greatly impacted materials and processes utilized in the manufacture of aerospace hardware. Code JE/ NASA's Environmental Management Division at NASA Headquarters recognized the need for a formal, Agency-wide review process of CAA regulations. Marshall Space Flight Center (MSFC) was selected as the 'Principal Center for Review of Clean Air Act Regulations'. This presentation describes the centralized support provided by MSFC for the management and leadership of NASA's CAA regulation review process.

Clark-Ingram, Marceia↗

From chromatin to crop: epigenetic innovations in bioenergy systems

Energy crops encompass a diverse array of plant species cultivated primarily as a source of biomass for energy generation and biofuel production. As such, they play a pivotal role in the transition to sustainable energy systems. However, their productivity is often limited by environmental stresses, nutrient availability, and the need for optimized yield. While traditional breeding and genetic engineering have driven improvements, challenges such as narrow genetic diversity, long development cycles, trait instability, and unexpected gene interactions remain. Epigenetics offers a largely untapped opportunity to overcome these constraints by regulating gene expression through mechanisms that are dynamic, finely tuned, and responsive to environmental and developmental cues. Epigenetic modifications including DNA methylation, histone post-translational changes, and small non-coding RNAs influence nearly all aspects of plant development and physiology, including traits central to bioenergy crops. While these mechanisms are well characterized in model species such as Arabidopsis thaliana, they remain underexplored in many purpose-grown energy crops. This review summarizes the current state of knowledge of epigenetic regulation in bioenergy species, explores how these mechanisms can be leveraged to enhance crop resilience and productivity, and identifies gaps in our understanding. By characterizing epigenetic mechanisms and harnessing epigenetic variation, we can expand the toolkit for developing resilient, high-yielding bioenergy crops to meet future environmental and energy demands.

09 BIOMASS FUELS↗

Moving from scientific research to consenting guidance for MRE environmental risk

Potential environmental effects from tidal and wave devices are of concern to regulators, advisors, and other stakeholders in many nations. Monitoring results from early deployments and the first commercial arrays, coupled with targeted research studies, are providing a growing base of knowledge of how components of tidal turbines and wave energy converters might interact with marine animals and habitats. Efforts are underway to organize and direct these findings towards facilitating consenting that allays concerns and allows the marine renewable energy (MRE) industry to move forward. The OES-Environmental international initiative has developed scientific evidence bases for several key interactions from MRE devices, organized around stressors (portions of MRE systems that may cause injury or stress to the marine ecosystem), and receptors (the animals, habitats, and ecosystem processes that may be affected). This paper summarizes the evidence bases for four stressors (underwater noise, electromagnetic fields, habitat change, and changes in oceanographic systems) and presents the process of moving from the scientific knowledge into guidance documents to support the regulatory process. The guidance documents will serve as a broad guide that can be used internationally to look at stressor-receptor interactions of interest within a regulatory context. The evidence bases and guidance documents aim to assist MRE developers, regulators, and advisors with project scoping, consenting, and licensing processes.

Copping, Andrea E.↗

EMP - Environmental Radiological Air Monitoring Plan: PNNL Operations in Washington

The Environmental Radiological Air Monitoring Plan (EMP) for Pacific Northwest National Laboratory (PNNL) describes systems/processes/practices related to radiological operations in Richland and Sequim, Washington, that are associated with environmental radiological air monitoring and surveillance activities. The activities described support the lab’s responsibility to maintain safe operations and minimize negative impacts to both onsite and offsite persons and environment. Dose assessments required by regulations and DOE Orders for the public and biota are described. PNNL conducts environmental air surveillance monitoring as part of the PNNL Site Radioactive Air Emissions License (RAEL)-005 for Richland Campus, issued in 2010 with its most recent renewal effective in January 2021. The radioactive air emissions license for the PNNL-Sequim campus (RAEL-014) was issued to the U.S. Department of Energy in 2012 with its most recent renewal effective in January 2023. The EMP is a compilation of the following four documents: - Environmental Radiological Air Monitoring Plan (this main document) (PNNL-20919) - Sampling and Analysis Plan (Attachment 1) (PNNL-20919-1) - Data Management Plan (Attachment 2) (PNNL-20919-2) - Dose Assessment Guidance (Attachment 3) (PNNL-20919-3).

40 CFR 61 Subpart H↗

Vadose and Saturated Zone Flow and Transport Calculations for the Active Trenches of the Low-Level Burial Grounds, Hanford Site, Washington

The purpose of the fate and transport modeling described in this environmental calculation file (ECF) is to evaluate the impacts to groundwater associated with waste disposal operations at Mixed Waste Low-Level Burial Ground (LLBG) Trenches 31 and 34 to satisfy requirements in DOE O 435.1, Radioactive Waste Management. The model integrates the flow and transport in the vadose zone beneath the active trenches with the saturated zone downgradient of the trenches to predict the radionuclide concentration at the point of assessment (POA). DOE M 435.1-1, Radioactive Waste Management Manual, defines the POA as the point of highest projected dose or concentration beyond a 100 m (328 ft) buffer zone surrounding the disposed waste. The modeling is conducted in accordance with the DOE G 435.1, Implementation Guide for Use with DOE M 435.1-1, performance assessment (PA) guidelines. The modeling involves evaluation of the groundwater concentrations and radionuclide arrival times during the 1,000-year compliance and 10,000-year sensitivity-uncertainty periods per DOE O 435.1 and DOE M 435.1. This analysis does not consider radionuclide release during facility operations, only the post-closure impacts of the radionuclides to the environment. The evaluation of potential radiological dose to groundwater receptors caused by releases from a closed facility containing radioactive waste typically includes the following: (1) Release of radionuclides from that facility (2) Transport of those radionuclides through the environment, and (3) Exposure to humans to environmental concentration levels of those radionuclides The fate and transport three-dimensional (3D) model analysis involves the post-closure impacts to the environment of the technetium-99, iodone-129, and uranium (all isotopes in the waste). The residual inventory estimates include several radionuclides, but technetium-99 is typically responsible for almost all of the beta-gamma dose equivalent associated with groundwater (water resources) protection per 40 CFR 141, “National Primary Drinking Water Regulations” (e.g., see the results in WCH-520, Performance Assessment of Environmental Restoration Disposal Facility, Hanford Site, Washington; hereinafter referred to as the ERDF PA), and iodone-129 can also be a significant dose contributor for some waste (e.g., RPP-RPT-59958, Performance Assessment for the Integrated Disposal Facility, Hanford Site, Washington; hereinafter referred to as the IDF PA). Uranium does not typically factor significantly into the impacts to groundwater, even during the 10,000-year sensitivity-uncertainty period, but always remains of interest as a contaminant. This ECF does not address vadose and saturated zone modeling for Trench 94 of the 200 East Area LLBG. Current information confirms the validity of the low corrosion rate of the naval reactor plant carbon steel (HY-80), and the even lower corrosion rate of the nickel-iron-chromium alloy reactor vessel (Inconel Alloy 600) presented in DOE/EIS-0259, Final Environmental Impact Statement on the Disposal of Decommissioned, Defueled Cruiser, Ohio Class, and Los Angeles Class Naval Reactor Plants. Based on these low corrosion rates, the time to breach the reactor vessel to allow release of radionuclides from the activated metal of the reactor vessel internal structure is at least 10,000 years. This time to breach precludes the need to evaluate the vadose and saturated zone transport of contaminants released from the reactor compartment disposal packages in the 200 East Area LLBGs PA (CP-63826, Waste Release Model Package Report for the Active Trenches of the Low-Level Burial Grounds, Hanford Site, Washington).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Cost Impacts of Risk-Based Methods for Defining AoR and PISC Duration of a CO 2 Storage Project Using NRAP Tools and FE/NETL CO 2 Saline Storage Cost Model

The purpose of this analysis is to assess the fiscal impact of using risk-based methods to define the area of review (AoR) and post-injection site care (PISC) duration for a geologic carbon dioxide (CO 2 ) storage project. The Office of Fossil Energy (FE)/National Energy Technology Laboratory (NETL) CO 2 Saline Storage Cost Model (“cost model”) was utilized to evaluate CO 2 storage economics in this study. The cost model is a widely used tool for evaluating CO 2 storage costs in geologic settings. It estimates costs for storage operations conducted under compliance to the United States Environmental Protection Agency (EPA) Underground Injection Control (UIC) Class VI regulations. This analysis evaluates and compares the costs of storage (on a first-year break-even dollar per tonne [2018$] basis) at the proposed FutureGen 2.0 site as a case study storage location by implementing different approaches to determine AoR and PISC given the prevailing geologic conditions and injection volume and duration considerations. The approaches include the use of 1) risk-based methods to define AoR and PISC duration, 2) an EPA-approved AoR and PISC documented in the FutureGen 2.0 UIC Class VI permit applications, and 3) cost model default settings that utilize uncertainty multipliers to estimate CO 2 plume and pressure front extent as part of AoR determination, as well as a 50-year PISC default. From all three sources, the AoR and PISC specified in the Class VI permit applications for FutureGen 2.0 were the largest and longest relative to the other two sources.

54 ENVIRONMENTAL SCIENCES↗

Multivariate environmental and trait-based controls of transpiration in the Central Amazon Rainforest

Tropical forest tree mortality is increasing due to more severe droughts, yet our understanding of how tree traits and life strategies are linked to drought stress has been limited by measurement scarcity. The BIONTE (BIOmass and NuTrient Experiment) near Manaus, Brazil hosts one of the world’s largest sap flow installations, with sensors in 90 canopy trees across a wood density gradient monitored since June 2022. The 2023 El Niño drought provided a unique opportunity to evaluate how water availability impacts tree transpiration. An interpretable machine learning framework was used to study the complex interactions between transpiration and multiple environmental variables such as soil water availability and vapor pressure deficit (VPD), and how these interactions vary with wood density and individual trees. We found varying responses of transpiration from different trees during the El Niño drought. Transpiration generally increased with temperature, with stronger effects in wetter areas and in trees with low to medium wood density. However, this response was modulated by stomatal sensitivity to VPD, which constrained transpiration under high atmospheric demand, particularly in intermediate-moisture area. The inflection in transpiration rate at high temperatures (>32°C) underscores the role of stomatal and hydraulic regulation in limiting water loss and protecting trees from excessive evaporative demand. Analysis of soil water contribution to transpiration revealed unimodal patterns in wetter area, with peak contributions near 0.45 cm 3 cm -3 of surface soil water and declining or flat responses beyond that threshold, suggesting a shift from water- to energy-limited transpiration. In contrast, drier areas exhibited limited transpiration sensitivity to soil water conditions and minimal trait-based variation in VPD responses, indicating supply-limited conditions. Despite higher wood density trees being generally more resilient, this study shows diverse tree drought resilience, prompting further investigation into the specific traits and dynamics between environmental variables in regulating transpiration and other physiological processes in trees.

Drought↗

Populus PtrbHLH011 Is a Transcriptional Co‐Regulator Involved in the Activation of Cell Wall Biosynthesis by Iron Deprivation

The lack of a mechanistic understanding of the environmental plasticity of secondary cell wall (SCW) biosynthesis restricts large-scale biomass and bioenergy production on marginal lands. Using Populus (poplar), a key bioenergy crop, we discovered that iron deprivation, a prevalent abiotic stress on marginal lands, stimulates SCW biosynthesis in stems. We identified the transcription factor PtrbHLH011 as a critical regulator underlying this response. Through integrated analyses involving phenotypic characterisation of PtrbHLH011 knockout and overexpression plants, functional genomics and molecular investigations, we established that PtrbHLH011 functions as a central regulator of SCW biosynthesis, iron homeostasis and flavonoid biosynthesis by directly repressing essential genes in these pathways. Iron deprivation downregulates PtrbHLH011 expression, subsequently activating these biosynthetic pathways. Notably, cytosine base editing-based knockout of PtrbHLH011 significantly enhanced plant growth, yielding up to a 110% increase in stem diameter and a 300% increase in leaf iron content. These findings present a novel regulatory mechanism linking environmental iron availability to SCW biosynthesis and illustrate a practical strategy to improve biomass yield on iron-deficient marginal lands. Furthermore, our mechanistic insights into PtrbHLH011 target recognition and regulation provide a valuable foundation for precise manipulation of gene regulatory networks, facilitating the development of high-performance bioenergy crops adapted to marginal environments.

59 BASIC BIOLOGICAL SCIENCES↗

Plastoquinone redox status influences carboxysome integrity via a RpaA ‐ and reactive oxygen species‐dependent regulatory network

SUMMARY Carboxysomes are bacterial microcompartments that encapsulate Rubisco and are a core component of the cyanobacterial carbon concentration mechanism (CCM). While carboxysome number, size, and spatial organization vary in different environmental conditions (CO 2 , light availability, redox state, temperature, and light quality), the molecular mechanisms underlying this potentially adaptive process remain elusive. Herein, we observe that mutants of the circadian rhythm/metabolism factor, Regulator of Phycobilisome Association A (RpaA), exhibit a striking breakdown of carboxysomes under certain environmental conditions. We find that conditions leading to overreduction of the plastoquinone (PQ) pool (mixotrophic growth, high irradiance, or chemical inhibition of electron transfer from PQ to the cytochromeb 6 fcomplex) are accompanied by an elevated generation of reactive oxygen species (ROS) and correlate with the loss of carboxysome integrity. Carboxysome breakdown is reversed by environmental conditions or chemical inhibitors that prevent PQ overreduction and accompanying ROS generation. Taken together, our data support a novel link between the redox status of the PQ pool and carboxysome integrity. Our results have implications for the fundamental understanding of cyanobacterial energy‐balancing pathways and may indicate new research directions for understanding how the carboxysome is remodeled in response to changing environments.

Plant Sciences↗

Risk Retirement—Decreasing Uncertainty and Informing Consenting Processes for Marine Renewable Energy Development

Marine renewable energy (MRE) is under development in many coastal nations, adding to the portfolio of low carbon energy sources that power national electricity grids as well as off-grid uses in isolated areas and at sea. Progress in establishing the MRE industry, largely wave and tidal energy, has been slowed in part due to uncertainty about environmental risks of these devices, including harm to marine animals and habitats, and the associated concerns of regulators and stakeholders. A process for risk retirement was developed to organize and apply knowledge in a strategic manner that considered whether specific environmental effects are likely to cause harm. The risk retirement process was tested against two key MRE stressors: effects of underwater noise from operational MRE devices on marine animals, and effects of electromagnetic fields from MRE electrical export cables on marine animals. The effects of installation of MRE devices were not accounted for in this analysis. Applying the risk retirement process could decrease the need for costly investigations of each potential effect at every new MRE project site and help move the industry beyond current barriers.

16 TIDAL AND WAVE POWER↗

Site 300 (Facility ID N-472) Toxic Emissions Inventory Plan

The Air Toxics "Hot Spots" Information and Assessment Act (AB 2588 or the “Act”) was enacted in September 1987. Under the Act, stationary sources are required to report the types and quantities of certain toxic substances their facilities routinely release into the air. AB 2588 is designed to provide information to state and local agencies and to the general public on the extent of airborne emissions from stationary sources and the potential public health impacts of those emissions. The San Joaquin Valley Air Pollution Control District (the District) is mandated by the State to implement AB 2588. On March 6, 2015, The State Office of Environmental Health Hazard Assessment (OEHHA) adopted changes to the Air Toxics Hot Spots Program Guidance Manual for the Preparation of Health Risk Assessments. These revisions were designed to incorporate three technical support documents and to provide enhanced protection of children as required under state law (SB 25, Escutia, 1999). Due to these recent changes, and the corresponding potential increases in calculated health risk, the District notified LAWRENCE LIVERMORE NATL SECURITY, LLC that we must be re-evaluated under AB 2588. Pursuant to the Air Toxics "Hot Spots" Information and Assessment Act of 1987, we have prepared a comprehensive, site-specific Toxics Emissions Inventory Plan. The plan specifies in detail how LAWRENCE LIVERMORE NATL SECURITY, LLC will inventory our facility's emissions of all toxic substances on the list of substances subject to the Act. The plan provides a comprehensive and detailed description of the methods that will be used to quantify air releases or potential air releases of listed substances from all points of release. The plan also includes quantification methods which result in accurate and comprehensive characterization of releases and comply with all applicable requirements of the “Hot Spots” regulation.

54 ENVIRONMENTAL SCIENCES↗