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Review of New or Modified Radioactive Air Emission Sources

This Environmental Protection and Compliance (EPC), Compliance Programs (CP) Quality Procedure (QP) describes the process for review and evaluation of new and modified sources of radioactive air emissions to determine the requirements for pre-construction approval, stack monitoring, stack sampling system upgrade, ambient air monitoring, and the implementation of As Low As Reasonably Achievable (ALARA) principles. These requirements are specified in 40 CFR 61 Subpart H and by DOE Order 458.1, Radiation Protection of the Public and the Environment.

61 RADIATION PROTECTION AND DOSIMETRY↗

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2019

This report documents radionuclide air emissions that result in the 2019 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, 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.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2019 from PNNL Richland Campus sources is 1.4E-5 mrem (1.4E-7 mSv) EDE. The dose from all fugitive sources is 1.3E-6 mrem (1.3E-8 mSv) EDE. The dose from radon emissions is 1.5E-10 mrem (1.5E-12 mSv) EDE. No nonroutine emissions occurred in 2019. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 1.5E-5 mrem (1.5E-7 mSv) EDE, or more than 10,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart H↗

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2020

This report documents radionuclide air emissions that result in the 2020 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, 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.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2020 from PNNL Richland Campus sources is 1.5E-5 mrem (1.5E-7 mSv) EDE. The dose from all fugitive sources is 2.0E-6 mrem (2.0E-8 mSv) EDE. The dose from radon emissions is 9.3E-9 mrem (9.3E-11 mSv) EDE. No nonroutine emissions occurred in 2020. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 1.7E-5 mrem (1.7E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart H↗

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2021

This report documents radionuclide air emissions that result in the 2021 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, 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.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2021 from PNNL Richland Campus sources is 1.7E-5 mrem (1.7E-7 mSv) EDE. The dose from all fugitive sources is 1.2E-6 mrem (1.2E-8 mSv) EDE. The dose from radon emissions is 2.1E-9 mrem (2.1E-11 mSv) EDE. No nonroutine emissions occurred in 2021. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 1.8E-5 mrem (1.8E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart H↗

PNNL-Richland Campus Radionuclide Air Emissions Report for Calendar Year 2022

This report documents radionuclide air emissions that result in the 2022 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, 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.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2022 from PNNL Richland Campus sources is 2.1E-5 mrem (2.1E-7 mSv) EDE. The dose from all fugitive sources is 1.2E-6 mrem (1.2E-8 mSv) EDE. The dose from radon emissions is 9.2E-9 mrem (9.2E-11 mSv) EDE. No nonroutine emissions occurred in 2022. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 2.3E-5 mrem (2.3E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart↗

Updated Assessment of Water-Energy Issues for Nuclear Power

There is significant ongoing need for understanding the water-energy nexus issues in the U.S. commercial nuclear energy industry. The water-energy nexus is a dynamic, ever evolving conundrum involving technological changes, regulatory concerns, economic constraints, environmental issues, and political attributes. This report provides a brief update on the water-energy nexus challenges facing the U.S. commercial industry since the 2010 report titled “Cooling Water Issues and Opportunities at the U.S. Nuclear Power Plants”. Since the 2010 report, nuclear power has experienced significant curtailments due to drought, intake and discharge temperatures, and flooding. These events will be exacerbated by global climate and resource competition. Water and energy regulation changes have accelerated and pose a particular risk to the commercial nuclear fleet compliance. The definition of Water of the United States continues to be litigated as water rights are being evaluated for fair and equitable allocation. The ability to maintain compliance with state and federal water regulations offers a substantial risk to the commercial nuclear industry, and therefore understanding the energy-water nexus is necessary for maintaining success of the current fleet.

54 ENVIRONMENTAL SCIENCES↗

An Evaluation of Recent Events Involving Hazardous Energy at INL Facilities

Idaho National Laboratory (INL) Facilities and Site Services (F&SS) has experienced 14 reportable events relating to work performed under lockout / tagout (LOTO) during the period of March 4, 2019 through August 18, 2020. The 14 events are described in Appendix A and were numerous enough and similar enough in nature to be indicative of an adverse trend that warranted further evaluation. A qualified cause analyst was assigned to lead a team in the review of these non-compliances, to determine commonalities, and to provide recommendations to the sponsoring organization. The team focused on both individual and institutional behaviors as well as the LOTO process and procedure. The non-compliances were reported in the Department of Energy (DOE) Occurrence Reporting and Processing System (ORPS) and/or the INL issues tracking system.

99 GENERAL AND MISCELLANEOUS↗

Los Alamos National Laboratory 2022 Annual Site Environmental Report (Rev. 2)

Los Alamos National Laboratory (Laboratory) annual site environmental reports are prepared each year by the Laboratory’s environmental organizations as required by U.S. Department of Energy Order 231.1B, Administrative Change 1, Environment, Safety, and Health Reporting, and Order 458.1, Administrative Change 4, Radiation Protection of the Public and the Environment. The chapters in this report discuss our compliance with environmental laws, regulations, and orders (Chapter 2, Compliance Summary); how we manage the Laboratory’s environmental performance and assure the quality of data from analysis of environmental samples (Chapter 3, Environmental Programs and Analytical Data Quality); how we monitor for air emissions of radioactive materials and for weather conditions (Chapter 4, Air Quality); how we monitor for effects of Laboratory operations on groundwater quality (Chapter 5, Groundwater Protection); how we monitor the levels of chemicals and radionuclides in storm water runoff and sediment (Chapter 6, Watershed Quality); how we monitor for the levels and effects of chemicals and radionuclides in plants, animals, soil, and vegetation (Chapter 7, Ecosystem Health); and finally, what radioactive dose or risk from chemical exposure that members of the public could experience as a result of Laboratory operations (Chapter 8, Public Dose and Risk Assessment).

54 ENVIRONMENTAL SCIENCES↗

R&D Outcomes of Surrogate Environmental Swipe Manufacturing Technique Method Development for Arms Control and Treaty Verification Applications

The analysis of environmental samples is a critical component of nuclear compliance verification and safeguards activities. While the associated particle analyses have benefitted from recent advances in the production of actinide-bearing particulates with uniform and well-characterized particle size, material phase, and isotopic ratios to serve as reference materials for calibration and interlaboratory comparisons, there is an outstanding need for surrogate environmental samples, which resemble field-collected samples, with the aforementioned reference particulates to support future nuclear compliance verification exercises and method development. This effort seeks to leverage the recent advances in tailored reference particle production to generate surrogate environmental swipe samples via parallel production techniques (direct and indirect) which are uniquely suited to the hydrothermal and aerosol-based synthesis routes developed at PNNL and SRNL, respectively. PNNL’s hydrothermal particle production method was used to generate surrogate reference particles for the indirect production of test swipes.

54 ENVIRONMENTAL SCIENCES↗

SAM Software Quality Assurance Plan Implementation and NQA-1 Assessment

The System Analysis Module (SAM) is an advanced and modern system analysis tool being developed at Argonne National Laboratory under the U.S. DOE Office of Nuclear Energy’s Nuclear Energy Advanced Modeling and Simulation (NEAMS) program. As a modern-day software, SAM development included efforts to follow best practices in software development. These best practices include version control using git, independent reviews of development activities, and detailed descriptions of developments and bug fixes using the GitLab issue and merge request system. In Fiscal Year 2023 (FY23), the SAM development team set out to formalize a Software Quality Assurance (SQA) program that allowed industry partners to credit the informal steps being taken by the SAM development team to ensure the quality of the software. As part of formalizing an SQA program, a SQA Plan (SQAP) was developed, implemented, and assessed. The SAM SQAP targets compliance with NQA-1-2008/2009 Addenda. The SQAP builds on the MOOSE SQAP and the Argonne SSQAPP while accounting for the needs of the multi-organization SAM development team. Modifications to the SAM repository structure, including a new testing system, updated test cases, and the development of an internal website, facilitate the implementation of the SAM SQAP. The initial assessment of the SAM SQAP indicated that the SAM SQAP was adequately and effectively implemented and additional work was required to improve the compliance of the SAM SQAP with NQA-1 2008/2009 Addenda. Several improvements to the SQAP have already been drafted to address these assessments and future work is planned to further improve the SAM SQAP in support of end-user needs.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Trace Element Sampling and Partitioning Modeling to Estimate Wastewater Composition and Treatment Performance at Coal Generators

The coal combusted at coal-fired power plants (CFPPs) contains several trace elements that impact human heath if released to the environment. Effective combinations of air pollution control devices (APCDs) and water pollution control devices (WPCDs) are critical to reducing these impacts. This work sampled pulverized CFPPs owned and operated by Louisville Gas & Electricity – Kentucky Utilities (LGE-KU) during baseload and cycling conditions. Next, an open-source and easy-to-implement trace element partitioning model was developed using publicly available datasets, literature studies of trace element partitioning, and sampling data to estimate trace element partitioning in APCDs to the gas, liquid, and solid phases exiting CFPPs. These estimates of the liquid phase trace element concentration in FGD wastewater were then used to estimate trace element behavior in WPCDs and evaluate treated wastewater effluent concentrations for compliance with the Effluent Limitation Guidelines (ELG) for the Steam Electric Generating Sector. Finally, cost estimates were developed for established and emerging wastewater treatment trains to identify the most cost-effective approaches for ELG compliance.

01 COAL, LIGNITE, AND PEAT↗

Evaluation of Naturally Occurring Be-7 Activity on LANL Stack Filter Clumps

Los Alamos National Laboratory (LANL) is responsible for providing solutions to challenging issues through multidisciplinary science, engineering, and technology that impact national security. As part of the Radioactive Air Emissions Management (RAEM) Team, it is our responsibility to ensure LANL operates within the requirements of the Code of Federal Regulations 40 CFR 61, Subpart H, National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities (Rad-NESHAP). The standard states, “Emissions of radionuclides to the ambient air from Department of Energy facilities shall not exceed those amounts that would cause any member of the public to receive in any year an effective dose equivalent of 10 mrem/yr” (EPA, 2002) During a routine assessment of LANL’s Rad-NESHAP compliance program, an opportunity for improvement was identified that addresses the evaluation of routine stack samples which potentially have naturally occurring radioactive materials (NORM) on the filter media. In the past and based on professional judgment, detections of NORM such as K-40 and Be-7 typically were rejected from the analytical results. The assessment finding suggested developing a technical criterion to ensure that such rejections were justified, comparing actual measured values with anticipated NORM concentrations for various stacks located at LANL. The significance of accepting or rejecting samples as “true” or “NORM” and its impact on the RAEM’s mission and compliance to the regulations is explained later in the document. Additionally, this document will describe the process and calculations for how such results are to be accepted as actual samples “true positive” or rejected as NORM.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

Invasive Plant Species Management Plan for Los Alamos National Laboratory (Rev.3)

Native species are plants and animals that continually occupy a natural range without direct or indirect introduction and/or care by humans. They are adapted to the environmental conditions and processes of the ecosystem in which they reside. A species introduced into a novel ecosystem can either exploit that ecosystem and thrive or be unable to survive in that ecosystem (Hobbs et al. 2006). Alien or non-native species are species that are intentionally or accidentally introduced into a novel ecosystem and are capable of living and propagating within the physical parameters of that ecosystem. Invasive species is a species that is non-native (or alien) to the ecosystem under consideration and a noxious species are those whose introduction causes or is likely to cause economic or environmental harm. The term invasive species is applicable to plants and animals alike; however, this invasive species management plan currently focuses on invasive vegetation. Invasive plant species are usually capable of rapid colonization of disturbed ground, such as after a change in wildfire regime intensity and frequency (Reilly et al. 2020) or anthropogenic ground disturbance (Burke and Grime 1996; Hobbs and Huenneke 1992). Climate change facilitates the spread and establishment of many alien species and creates new opportunities for them to become invasive (Turbelin and Catford 2021). As climate change impacts increase in the coming decades, we may see in an increase in invasive species establishment. See a list of definitions of terms pertinent to this document in Appendix A: Definitions. Los Alamos National Laboratory (LANL) hosts populations of non-native and invasive species all typical of the northern New Mexico region (Martin 2004; NMDA 2020). By implementing an invasive species management plan, LANL will have readily accessible management strategies for invasive species that are found on-site. The benefits of managing invasive species include a decrease in wildland fire risks, an increase in soil productivity, an increase in (productive or beneficial) wildlife habitat, an increase in water quantity and quality, and the restoration of impacted areas (Burke and Grime 1996; Hobbs and Huenneke 1992; D’Antonio and Hobbie 2005; MacDougall et al. 2013; Reilly et al. 2020). The aforementioned benefits from invasive species management directly enable the LANL mission by ensuring compliance requirements are met and site-wide programs, such as the Vulnerability Assessment and Resilience Plan, are supported for a mutually beneficial outcome. An example for the LANL site specifically, controlling non-native annual plant species, for example, could reduce the costs associated with stabilizing soils during the stormwater pollution prevention compliance process. Roadway and utility right-of-way areas are another place where an integrated vegetation management strategy would promote low growing perennial plants in a way that is mutually beneficial to habitat and the institution through lowered maintenance costs. There is also an economic benefit to managing invasive species. In one nationwide study, invasive plants had an estimated impact cost of $190.45 billion (Fantel-Lepczyk et al. 2022). Investing in preventative measures and surveillance could help to offset future control and management costs of invasive species that have the potential to become established. The State of New Mexico has developed plant species lists and recommendations through the New Mexico Department of Agriculture’s Noxious Weeds Management Act, Article 7D (NM Statute § 76-7D-4 2021); however, effective invasive species management must rely on local knowledge of the site and region. Los Alamos County (LAC) has already compiled a target invasive plant species list and species-specific management objectives (Martin 2004). Therefore, the New Mexico Noxious Weed List and the LAC invasive plant species list, as well as management objectives from those documents, are integrated into LANL’s invasive plant species management plan.

54 ENVIRONMENTAL SCIENCES↗

Advanced Algorithms for Scrutiny of Mandatory State Reports Declarations to the IAEA (Final Project Report)

In compliance with their Comprehensive Safeguards Agreements, based on INFCIRC/153 (corrected) (International Atomic Energy Agency, 1972), States Party to the Treaty on the NonProliferation of Nuclear Weapons (NPT) are obligated to declare to the International Atomic Energy Agency (IAEA) all changes in their nuclear material inventory as well as movement of the material across boundaries of IAEA recognized material balance areas (MBA), inventories and nuclear material balances. This project addresses capabilities to detect irregularities in State reports, thus ensuring their accuracy and completeness, and in the broader context, States’ compliance with safeguards obligations of the NPT. A recent study (Henzl et al., 2022) (lead by this project’s PI) demonstrated how analysis of dynamic correlations in nuclear material movement within the entire fuel cycle of a State (viewed as a single system) can reveal variances consistent with and indicative of “irregular” activities. Expanding on this concept, novel ways to analyze State declarations themselves—again, for the State as a whole entity—will help the IAEA draw accurate safeguards conclusions and trust the validity and authenticity of Stategenerated declaration reports. Introducing new declaration analyses capabilities explored in this project will help to provide credible assurance of both the non-diversion of nuclear material from declared activities and of the absence of undeclared nuclear material and activities in the State in general.

45 MILITARY TECHNOLOGY, WEAPONRY, AND NATIONAL DEF↗

Hanford Waste Treatment Plant LAB Facility Stack Effluent Monitoring: Sampling Probe Location Qualification Evaluation

The Waste Treatment Plant laboratory (LAB) facility stack monitor locations were qualified using scale model stacks to mitigate the risk of identifying that sampling locations do not meet the qualification criteria on the full-scale stack. As required by the American National Standards Institute/Health Physics Society (ANSI/HPS) N13.1-1999 standard, the scale model and its sampling location were geometrically similar to the actual stack, and the Reynolds numbers for both the actual and model stacks were >10,000. An additional criterion is that the product of the hydraulic diameter and mean velocity (DV) of the full-scale stack must be between 1/6 DV and 6 DV of the scale model stack tests. Verification tests of the LAB stacks were performed at normal operating conditions. The minimum 1/6 DV value, along with the maximum 6 DV value from the scale model testing, determines the range of conditions for which the full-scale stack may be operated and remain in compliance with the stack verification criterion. A practical range for the full-scale stack qualification uses the average DV through 6 DV from the scale model tests to compute the corresponding flow rates. Table S1 lists the operating flow rates along with the average and maximum qualified stack flow rates for each of the LAB facility stacks. For each stack, the operating flow is below the maximum qualified stack flow, which means that the scale model test results are acceptable for stack qualification. The remaining criteria for the stack verification to be considered valid involve the flow angle and velocity uniformity results. First, the flow angle at the full-scale stack must be ≤20°. Second, the velocity uniformity at the full-scale stack must be ≤20% coefficient of variance (COV). Finally, the velocity uniformity results for the actual and scale model stack tests must agree within 5% COV. These criteria were met through the full-scale stack tests at the LAB facility. Flow angle results were primarily less than 10°, except for the LB-C2 Fan A results, which were an average of 13.7°; all flow angle results were within the ≤20° criterion. The velocity uniformity results for each test condition averaged between 1.5 and 4.1% COV, which were all within the range of the target percent coefficient of variation values from the scale model tests. Based on these stack verification test results, the three LAB filtered exhaust stack sampling locations meet the qualification criteria provided in the ANSI/HPS N13.1-1999 standard for all fan operating configurations. This includes single-fan as well as dual-fan operations for LB-C2, each of the dual-fan operating conditions for LB-S1, and each single-fan operating condition for LB-S2. Further changes to the system configuration or operating conditions that are outside the bounds described in this report may require additional tests or analyses to determine compliance with the standard.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Full Scale HEPA Filter Encapsulation in Ultra-High-Performance Grout - Proof of Concept

The Hanford Tank Waste Treatment and Immobilization Plant (WTP) currently being constructed to treat radioactive waste, includes vitrification facilities for both the high-level waste (HLW) and low activity waste (LAW) fractions. Operation of the WTP will produce contaminated high-efficiency particulate air filters (HEPA), as part of the solid secondary waste (SSW) stream. The HEPA filters receive off-gas from the vessel vent header and primary off-gas treatment system in LAW Facility and remove particulate contaminants including 99 Tc and 129 I salts. The current disposal method for HEPA filters is encapsulation in metal containers using cementitious material (CM) and disposal in the Integrated Disposal Facility (IDF). Results from the 2017 IDF Performance Assessment (PA) WRPS (2018) demonstrated that while compliance is maintained for the 1000 year compliance period mandated by DOE O 435.1 and its accompanying manual, release of constituents from the HEPA filters result in exceedance of the performance objective imposed as the groundwater regulatory limit at later times. For example, at about 1500 years post-closure, solid secondary waste (SSW), including HEPA filters is predicted to become a dominant contributor to 99 Tc release and over the 10,000-year sensitivity analysis period, SSW is the dominant contributor of 129 I release to the groundwater. The estimated release could potentially be reduced if the HEPA filters are not compacted and waste containers could be distributed throughout a large space, thereby diluting the contaminant release. Additionally, a better cementitious material could be used to encapsulate the HEPA filters. One alternative method for disposal of contaminated HEPA filters is encapsulation of the filters in ultra high-performance grout (UHPG). UHPG is a variation of ultra-high-performance concrete (UHPC) is commonly used in the prestressed concrete industry for large structural members. Recent studies of UHPG show it has excellent properties for containing radionuclides such as 99 Tc and 129 I Nichols and Kaplan (2021). This report presents the results of the first attempt to encapsulate a clean, full-size HEPA filter in UHPG and evaluate the effectiveness of the immobilization process and final waste form. A full-scale proof-of-concept simulated waste form was prepared by encapsulating a HEPA filter in a 110-gallon stainless steel (SS) drum using UHPG. A change from Type I/II PC to Type 1L PLC was made after American Rock Products informed the team that they would no longer be using Type I/II by the end of 2024 and the northwest was phasing out Type I/II PC overall. Type I/II PC used in previous studies of UHPG for encapsulation (Nichols and Kaplan 2021). After the UHPG was cured both the scaled mockup and the full-scale simulated waste forms were sectioned for visual examination. UHPG completely encapsulated the filters and bonded to the external surfaces of materials comprising the filters. No cracks were observed in the sectioned waste forms.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway: Safety Criteria Evaluation

There has been recent progress in the development of risk-informed performance-based (RIPB) design and licensing approaches, which leverage the insights gained from detailed risk assessments and utilize performance-based metrics to permit flexibility and innovation. The RIPB approaches have included the probabilistic treatment of external hazards, including low frequency events that are beyond the design basis. A preceding study conducted in FY21 noted that there are certain challenges to the probabilistic treatment of low frequency external events, which are primarily the result of uncertainty in the hazard curve and the associated plant response to rare, severe events. The current work expands on the previous study by examining the regulatory safety criteria contained within draft 10 CFR Part 53 and associated draft RIPB seismic design guidance. The evaluation identified potential challenges in demonstrating satisfaction of the safety criteria for low frequency external events, with specific difficulties associated with demonstrating compliance with cumulative safety criteria metrics, such as the quantitative health objectives (QHOs). Non-LWRs are expected to utilize the direct calculation of offsite consequence, rather than use surrogates, for comparison to the QHOs, which can be particularly challenging as the previously identified uncertainties are compounded by uncertainties in the response of the neighboring population. The current work details this evaluation and key findings. The central recommendation from this effort is that it is necessary to develop an approach for demonstrating compliance with the safety criteria in draft Part 53 that addresses the key challenges while providing flexibility to applicants.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Commercial Building Prototypes Based on ANSI/ASHRAE/IES Standard 90.1-2019 Appendix G PRM: Technical Support Document

The two paths for documenting compliance with ANSI/ASHRAE/IES Standard 90.1 are the prescriptive path and the performance path. Beyond code programs and rating systems (for example, USGBC-LEED ) are primarily known to use a third path – the Appendix G Performance Rating Method. An update in the 2016 edition of Standard 90.1 approved the Appendix G Performance Rating System for code compliance, extending its application and allowing for greater consistency of modeling rules for code and beyond code building energy modeling. The Appendix G PRM provides rules for the development of whole building energy models of baseline and proposed models for calculating the “performance cost index target” value using the simulated energy results of the baseline and proposed models and the building performance factors published in Table 4.2.1.1 of the Standard. This report documents (1) the methodology used for development of the baseline and proposed energy models of the Pacific Northwest National Laboratory and U.S. Department of Energy commercial building prototypes using the Appendix G Performance Rating Method; and (2) the building performance factors that were calculated using those models.

97 MATHEMATICS AND COMPUTING↗