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Annual Site Environmental Report (2019)

Los Alamos National Laboratory’s (the Laboratory’s) annual site environmental reports are prepared 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 3, Radiation Protection of the Public and the Environment. The following chapters in this report discuss our success in complying with environmental laws, regulations, and orders (Chapter 2, Compliance Summary); how we manage the Laboratory’s environmental performance (Chapter 3, Environmental Programs); how we monitor for air emissions of radioactive materials and climate conditions (Chapter 4, Air Quality); how we monitor for effects of Laboratory operations on groundwater quality (Chapter 5, Groundwater Protection); how we monitor the movement of chemicals and radionuclides by storm water runoff and the levels of chemicals and radionuclides in deposited sediment (Chapter 6, Watershed Quality); how we monitor for the presence, levels, and effects of chemicals and radionuclides in plants, animals, and soil (Chapter 7, Ecosystem Health); and finally, what radionuclide dose or risk from chemical exposure members of the public may experience as a result of Laboratory operations (Chapter 8, Public Dose and Risk Assessment).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Migration of 60 Co, 133 Ba, 137 Cs, and 152 Eu from cementitious wasteforms in field lysimeter experiments

Safe and effective storage of radioactive waste is essential to protect environmental health. Due to the potential for accidental releases and the severity of the associated risks, it is imperative to further understand radionuclide transport should an accident occur. This work analyzed the vadose zone migration of radionuclides from cementitious wasteforms at the Savannah River Site after ten years. The observed radionuclides are prominent constituents of radioactive waste or analogs for other groups or series of radionuclides. Lysimeters were first analyzed in 2016 using a collimated high-purity germanium gamma-ray spectrometer to non-destructively measure the concentration of each radionuclide in the sediment column as a function of depth. Following these measurements, the lysimeters were redeployed in the field for another 4 years. All radionuclides in all lysimeters were observed to transport further during the redeployment period; however, the extent of migration varied with the material used for introduction. Except for 137 Cs, migration through the sediment control system increased with decreasing ionic potential (ionic charge/radius); migration order: 152 Eu< 137 Cs< 60 Co< 133 Ba. Overall, the cementitious wasteforms were observed to decrease radionuclide migration extent relative to the filter paper. In both cementitious wasteforms, the migration extent increased in the order 152 Eu< 133 Ba< 60 Co< 137 Cs. However, less migration was measured when the radionuclides were incorporated into a reducing grout wasteform. The novelty of this paper is the demonstration of a technique capable of creating non-destructive measurements over decade time scales. Ultimately, this work provides insight into the long-term migration of alkali, alkali earth, divalent transition metal, and trivalent actinide element isotopes.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Worswick Hot Springs: A Radioactive Hydrothermal Field Site.

Introduction: We report on a systematic characterization of the environmental conditions at Worswick Hot Springs, a hydrothermal system in Idaho, USA. Because localized “hot spots” of elevated radiation and biofilms are easily accessible, various biological studies of radiation resistance and biosignature formation are possible, making this fieldsite relevant for analog field studies that consider microbiology, geo-chemistry, and ionizing radiation. In addition to Worswick being a natural radiation biology laboratory that may also be relevant for space biology applications, we assert that these unusual environmental conditions may inform us about locations on Mars that are also enriched in radioactive elements and their poten-tial for hosting biosignatures. Methods: We carried out repeated temperature and radiation measurements at the same hot spring locations to observe the system over time (Figure 2). Radiation: A Bicron Micro Analyst micro-r-meter (Bicron NE, Saint-Gobain Industrial Ceramics, Inc.) capable of sensing x-rays and gamma-rays (0-5000 µR/hr), was used to gather radiation data at twenty-four locations around and above the region of the two main stream channels. Water Temperature: A digital hand-held infrared thermometer (Oakton WD-39642-00 Mini-Temp Tester) was used for all measurements. ICP-MS aqueous geochemistry: Water samples were analyzed at the ISU Center for Archaeology, Materials and Applied Spectroscopy (CAMAS). Results: We have discovered localized areas of elevated radiation that are approximately 4 to 5 times greater than background radiation, and we have ob-served that both radioactivity and temperature of the spring waters vary over time. ICP-MS reveal the presence of thorium and uranium, which are correlated with elevated radioactivity. Several point sources of elevated radioactivity have been identified in both Stream A and Stream B.

Analog↗

Comparison of measurement techniques and sorption of radium-226 in low and high salinity aqueous samples

Human activities have the potential to redistribute radium (Ra) in the marine environment in a manner that may necessitate monitoring or management of subsequent human or environmental exposures. There is therefore a need to identify accurate and accessible techniques for Ra measurement in high salinity samples and to describe the distribution of Ra in estuarine and marine environments, but most efforts in these areas have focused on low salinity matrices. In addition, rapid and reliable measurements are crucial for time-sensitive samples such as short-lived isotopes or emergency situations. The objective of this study is to describe the limits of detection, cost, and relative ease for measurement of Ra in both low and high salinity aqueous samples via three analytical methods: liquid scintillation counting (LSC), high purity germanium (HPGe) gamma spectrometry, and inductively coupled plasma mass spectrometry (ICP-MS). To contextualize these measurements for real-world scenarios, the partitioning of 226 Ra to substrates relevant to the marine environment was also characterized. Although HPGe detection with solid phase extraction had the lowest limit of detection for low salinity samples (0.27 Bq L −1 ), poor 226 Ra recovery for high salinity samples and high materials costs make this method prohibitive for many users. Limits of detection for high salinity samples were lower for LSC (1.28 Bq L −1 ) than for ICP-MS without dilution (11.4 Bq L −1 ), but significant and unexpected degradation of the high salinity LSC standards was observed after six months. Furthermore, our preferred measurement method for high salinity Ra samples is ICP-MS with sample dilution as necessary to reduce matrix effects.

07 ISOTOPE AND RADIATION SOURCES↗

Irradiation Impact on Uranium Recovery Under Direct Extraction Conditions

Reducing the quantity of high-level radioactive waste is essential for minimizing environmental impact and improving efficiency of using natural resources for nuclear power. The current standard, Plutonium Uranium Solvent EXtraction (PUREX), uses tributyl phosphate (TBP) ligands to extract complexes of uranium and plutonium from a nitric acid (HNO3) phase. Although this method is effective, large volumes of HNO3 and the non-incinerable phosphate ligands increase the amount of hazardous waste produced. Alternative extractants and flowsheets have been proposed that allow for more selective extraction of radioactive metals, reduced nitric acid use, and easier incineration by only containing carbon, hydrogen, oxygen, and nitrogen (CHON). One candidate, N,N-di(2-ethylhexyl)-isobutyramide (DEHiBA) exhibits promising properties for direct extraction. A HNO3 pre-equilibrated DEHiBA phase selectively extracts U(VI), leaving plutonium, transuranics, and fission products behind as precipitate and reducing the volume of radioactive HNO3 produced.

38 - RADIATION CHEMISTRY, RADIOCHEMISTRY, AND NUCL↗

Radioactive Waste Management Basis (Rev.6)

This Radioactive Waste Management Basis (RWMB) documents radioactive waste management practices adopted at Lawrence Livermore National Laboratory (LLNL) pursuant to Department of Energy Order (DOE O) 435.1, Radioactive Waste Management. The purpose of this RWMB is to ensure that LLNL manages radioactive waste in a safe and environmentally-compliant manner, protective of worker and public safety.

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

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

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Summary of Analytical Services for the Hanford Site Radionuclide NESHAP Program

This document is a summary of the point source analytical requirements used to demonstrate compliance for the Department of Energy (DOE) Hanford Site operations with 40 Code of Federal Regulations (CFR) Part 61, “National Emission Standards for Hazardous Air Pollutants,” (NESHAP) Subpart H, “National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities,” and the Washington Administrative Code (WAC) 246-247, “Radiation Protection – Air Emissions.” This reference collects information from multiple source documents and is not intended to create, supersede, replace or over-ride any existing contractual, DOE, federal or state statutes, regulations, compliance agreements, orders, permits, licenses or other requirements. The requirement source document governs where any difference may exist. The Hanford Mission Integration Solutions (HMIS) Environmental organization has been contracted by DOE to manage and report data collected from the sampling and monitoring of radioactive air emissions point sources, colloquially called stacks. The Environmental organization coordinates the analyses and reporting of samples collected at various facilities across the Hanford Site. These facilities operate approximately 52 stacks that require sampling, monitoring or estimating radioactive air emissions. The stacks are operated by Bechtel National, Inc. (BNI), Central Plateau Cleanup Company (CPCCo), Hanford Tank Waste Operations & Closure (H2C), Hanford Laboratory Management and Integration (HLMI), and Pacific Northwest National Laboratory (PNNL). Stack samples from CPCCo, HLMI and H2C facilities are collected by the operating contractor staff, delivered to HMIS, and then shipped to an offsite contracted laboratory for analyses. The field and laboratory sample data uploaded into the Sample Management and Analytical Results Tracking (SMART) database are used to calculate sample volumes and concentrations. Sample concentrations are evaluated for compliance with federal and state regulations, permits, and license requirements. The SMART database also calculates total curies released for sampled point sources and stacks. Point source effluent concentrations and releases are published annually in publicly available reports. The BNI and PNNL operate several DOE-Hanford Field Office (HFO) stacks subject to the requirements of 40 CFR 61, Subpart H and WAC 246-247. The concentrations, curies released and dose modeling evaluation for these stacks are included in the DOE-HFO annual radionuclide NESHAP report. The sample collection, analyses and emissions estimates for these stacks are outside the scope of HMIS contracted responsibilities and not addressed further in this document.

54 ENVIRONMENTAL SCIENCES↗

Environmental Air Monitoring at LANL: 2023 External Program Assessment [Slides]

Radioactive Air Emissions Management evaluates radiological impacts of LANL operations on members of the public, identifies and quantifies releases, and assesses impacts. It is not directly affiliated with cleanup operations or programmatic work and has independent oversight. The focus areas in Environmental Compliance Programs are stack emissions measurements, ambient air measurements, minor source operations evaluations, data management and quality assurance, collaboration with Meteorology program, and collaboration with Dose Assessment program (EPC-ES).

54 ENVIRONMENTAL SCIENCES↗

Determining Unabated Airborne Radionuclide Emissions Monitoring Requirements Using Inventory-Based Methods

Compliance with the airborne radionuclide emission monitoring requirements in the National Emission Standards for Hazardous Air Pollutants (NESHAP; Title 40 of the U.S. Code of Federal Regulations Part 61, Subpart H) and State requirements in Washington Administrative Code 246–247: Radiation Protection – Air Emissions and 173-480: Ambient Air Quality Standards and Emission Limits for Radionuclides were evaluated for Pacific Northwest National Laboratory (PNNL) operations. Additional guidance may be found in the U.S. Department of Energy Handbook, Environmental Radiological Effluent Monitoring and Environmental Surveillance. To meet regulatory requirements, reviews of planned or proposed projects and activities provide the basis for implementing necessary monitoring adjustments or for implementing changes to projects and activities in a timely manner. Potential unabated off-site doses were evaluated for emission locations managed by PNNL and licensed to the Department of Energy. These locations were at facilities in Richland, Washington (i.e., the Hanford Site and PNNL–Richland campus) and in Sequim, Washington, (PNNL–Sequim campus). This report describes the inventory-based methods and provides the results for the NESHAP assessment performed in January 2024 for calendar year ending 2023.

40 CFR 61 Subpart H↗

Benchmark Exercise Report for Experimental Study of Bubble Scrubbing in Sodium Pool

Mechanistic source term (MST) analyses are likely to be an important part of advanced reactor licensing applications. For the purpose, an MST analysis code applicable to newly introduced advanced reactors, called SRT (Simplified Radionuclide Transport) code, has been developed by Argonne National Laboratory. SRT can track overall behaviors of radionuclides especially in metal fuel-based sodium fast reactors (SFRs) and microreactors. Throughout the simulation, migration inside fuel pins before failure, interaction with coolant (for SFR), removal/leakage in cover gas and containment (or confinement), and environmental dose impacts are considered alongside radioactive decay for short-lived nuclides. Among the postulated process, pool scrubbing phenomenon, especially under sodium pool condition, has been identified as high importance with limited supportive data. The phenomenon plays a crucial role in assessing the degree of radiological impacts as radioactive aerosols or vapors are efficiently and effectively removed during the process. To provide validation basis for SRT in assessing pool scrubbing performance inside sodium pools, the University of Wisconsin-Madison performed tests including extensive parametric effects. Separate effect tests were conducted to directly evaluate the SRT models and to estimate degree of contribution by each contributing factor. Specifically, bubble size, aerosol size, aerosol density, aerosol concentration, pool depth, system temperature, and bubble swarm effects were considered. According to the parametric effects, decontamination performance enhances with decreasing bubble size, large density, and deeper pool height. Aerosol concentration provides no effect for the whole range of interest, and pool temperature variation shows minor effects under the considered temperature condition. When multiple bubbles are injected generating a bubble swarm condition, DF performance further enhances by bubble interactions and turbulence characteristics. The measurement shows the exceptional importance of aerosol size range considered, with the lowest decontamination, where most radionuclides are expected to escape.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

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

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

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Nuclear Thermal Propulsion Ground Test History

Nuclear Thermal Propulsion (NTP) was started in ~1955 under the Atomic Energy Commission as project Rover and was assigned to Los Alamos National Laboratory. The Nevada Test Site was selected in 1956 and facility construction began in 1957. The KIWI-A was tested on July 1, 1959 for 5 minutes at 70MW. KIWI-A1 was tested on July 8, 1960 for 6 minutes at 85MW. KIWI-A3 was tested on October 10, 1960 for 5 minutes at 100MW. The National Aeronautics and Space Administration (NASA) was formed in 1958. On August 31, 1960 the AEC and NASA established the Space Nuclear Propulsion Office and named Harold Finger as Director. Immediately following the formation of SNPO, contracts were awarded for the Reactor In Flight Test (RIFT), master plan for the Nuclear Rocket Engine Development Station (NRDS), and the Nuclear Engine for Rocket Vehicle Application (NERVA). From December 7, 1961 to November 30, 1962, the KIWI-B1A, KIWI-B1B, and KIWI-B4A were tested at test cell A. The last two engines were only tested for several seconds before noticeable failure of the fuel elements. Harold Finger called a stop to any further hot fire testing until the problem was well understood. The KIWI-B4A cold flow test showed the problem to be related to fluid dynamics of hydrogen interstitial flow causing fuel element vibrations. President Kennedy visited the NTS one week after the KIWI-B4A failure and got to see the engine starting to be disassembled in the maintenance facility. The KIWI-B4D and KIWI-B4E were modified to not have the vibration problems and were tested in test cell C. The NERVA NRX program started testing in early 1964 with NRX-A1 cold flow test series (unfueled graphite core), NRX-A2 and NRX-A3 power test series up to 1122 MW for 13 minutes. In March 1966, the NRX-EST (Engine System Test) was the first breadboard using flight functional relationship and total operating time of 116 minutes. The NRX-EST demonstrated the feasibility of a hot bleed cycle. The NRX-A5 had multiple start-ups in May-June 1966 with 30.75 minutes accumulative operating time at or above 1GW. The NRX-A6 was tested in December 1969 and ran for 62 minutes at 1100 MW. Each engine had post-test examination and found various structure anomalies which were identified for correction and the fuel element corrosion rate was reduced. The Phoebus series of research reactors began testing at test cell C, in June 1965 with Phoebus 1A. Phoebus 1A operated for 10.5 minutes at 1100 MW before unexpected loss of propellant and leading to an engine breakdown. Phoebus 1B ran for 30 minutes in February of 1967. Phoebus 2A was the highest steady state reactor built at 5GW. Phoebus 2A ran for 12 minutes at 4100 MW demonstrating sufficient power is available. The Peewee test bed reactor was tested November- December 1968 in test cell C for 40 minutes at 500MW with overall performance close to pre-run predictions. The XE' engine was the only engine tested with close to a flight configuration and fired downward into a diffuser at the Engine Test Stand (ETS) in 1969. The XE' was 1100 MW and had ~28 start-ups. The nuclear furnace NF-1 was operated at 44 MW with multiple test runs at 90 minutes in the summer of 1972. The NF-1 was the last NTP reactor tested. The Rover/NERVA program was cancelled in 1973. However, before cancellation, a lot of other engineering work was conducted by Aerojet on a 75, 000 lbf prototype flight engine and by Los Alamos on a ~16,000 lbf "Small Engine" nuclear rocket design. The ground test history of NTP at the NRDS also offers many lessons learned on how best to setup, operate, emergency shutdown, and post-test examine NTP engines. The reactor and engine maintenance and disassembly facilities were used for assembly and inspection of radioactive engines after testing. Most reactor/ engines were run at test cell A or test cell C with open air exhaust. The Rover/NERVA program became aware of a new environmental regulation that would restrict the amount of radioactive particulates allowed to be release in open air and successfully demonstrated a scrubber concept with the NF-1. The ETS stand was the only one with a high altitude test chamber used for XE'. The ETS and other test cells showed the effects the engine's radiation had on the facility materials and instrumentation as well as side effects the ground test facility has back on the engine operation. The breakdown of Phoebus 1A at test cell C showed how the site was cleaned up and back to operation for five more engines before the program was cancelled.

Gerrish, Harold P.↗

Using the CAP88 Plume Model & Dose Assessment Code for the FTWC Project

The Environmental Protection & Compliance Division (EPC) uses the Clean Air Act Assessment Package – 1988 (CAP88) plume model and dose assessment code to evaluate measured emissions or projected emissions of airborne radionuclides from Los Alamos National Laboratory (LANL) facilities. This software package will use facility data (e.g., stack height and exit velocity), emissions parameters (chemical form and quantity), and environmental data (wind speed and direction) to predict downwind concentrations of radioactive material and subsequent dose to a member of the public at that location. The United States Environmental Protection Agency (EPA) has approved CAP88 for use in demonstrating compliance with the Radionuclide NESHAP2, that portion of the Clean Air Act addressing emissions of airborne radioactive material from Department of Energy facilities. EPC Division has two procedures which discuss the use of CAP88.

61 RADIATION PROTECTION AND DOSIMETRY↗

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

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

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗