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At least 541 records · Page 30

Wind Energy Industry Eagle Detection and Deterrents: Research Gaps and Solutions Workshop Summary Report

The Bald and Golden Eagle Protection Act (BGEPA) prohibits the 'take' of these birds. The act defines take as to 'pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, destroy, molest or disturb.' The 2009 Eagle Permit Rule (74 FR 46836) authorizes the U.S. Fish and Wildlife Service (USFWS) to issue nonpurposeful (i.e., incidental) take permits, and the USFWS 2013 Eagle Conservation Plan Guidance provides a voluntary framework for issuing programmatic take permits to wind facilities that incorporate scientifically supportable advanced conservation practices (ACPs). Under these rules, the Service can issue permits that authorize individual instances of take of bald and golden eagles when the take is associated with, but not the purpose of, an otherwise lawful activity, and cannot practicably be avoided. To date, the USFWS has not approved any ACPs, citing the lack of evidence for 'scientifically supportable measures.' The Eagle Detection and Deterrents Research Gaps and Solutions Workshop was convened at the National Renewable Energy Laboratory in December 2015 with a goal to comprehensively assess the current state of technologies to detect and deter eagles from wind energy sites and the key gaps concerning reducing eagle fatalities and facilitating permitting under the BGEPA. During the workshop, presentations and discussions focused primarily on existing knowledge (and limitations) about the biology of eagles as well as technologies and emerging or novel ideas, including innovative applications of tools developed for use in other sectors, such as the U.S. Department of Defense and aviation. The main activity of the workshop was the breakout sessions, which focused on the current state of detection and deterrent technologies and novel concepts/applications for detecting and minimizing eagle collisions with wind turbines. Following the breakout sessions, participants were asked about their individual impressions of the relative priority of each of the existing and novel ideas.

17 WIND ENERGY↗

Stormwater Pollution Prevention Plan, TA-03-22 Power and Steam Plant, Revision 4: LANS Archived 2019

This Storm Water Pollution Prevention Plan (SWPPP) was developed in accordance with the provisions of the Clean Water Act (33 U.S.C. §§1251 et seq., as amended), and the Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activity (U.S. EPA, June 2015) issued by the U.S. Environmental Protection Agency (EPA) for the National Pollutant Discharge Elimination System (NPDES) and using the industry specific permit requirements for Sector O-Steam Electric Generating Facilities as a guide. The applicable stormwater discharge permit is EPA General Permit Registration Number NMR053915 (Los Alamos National Security (LANS) (U.S. EPA, June 2015). This SWPPP applies to discharges of stormwater from the operational areas of the TA-03-22 Power and Steam Plant at Los Alamos National Laboratory. Los Alamos National Laboratory (also referred to as LANL or the “Laboratory”) is owned by the Department of Energy (DOE), and is operated by Los Alamos National Security, LLC (LANS). Throughout this document, the term “facility” refers to the TA-03-22 Power and Steam Plant and associated areas. The current permit expires at midnight on June 4, 2020.

54 ENVIRONMENTAL SCIENCES↗

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

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

54 ENVIRONMENTAL SCIENCES↗

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

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

54 ENVIRONMENTAL SCIENCES↗

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

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

54 ENVIRONMENTAL SCIENCES↗

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

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

14 SOLAR ENERGY↗

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

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

Farrell, C. E.↗

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

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

Abshire, J. B.↗

Managing Environmental Effects to Facilitate Marine Renewable Energy Development

The marine renewable energy (MRE) industry is in the early stages of commercial development. In addition to the challenges of deploying and maintaining devices under harsh ocean conditions and transporting electricity to shore, concerns around potential environmental effects continue to slow permitting (consenting) processes. Regulators and stakeholders perceive a wide array of potential environmental interactions as risky and highly uncertain, and request that considerable baseline assessments and post-installation monitoring be carried out in order to permit or license a project. The MRE industry is struggling with the high cost of baseline assessments and post-installation monitoring, as well as extended timelines for obtaining permits, leading to uncertainty and risk for financing projects. As a means to mitigate this uncertainty and risk, regulators in the US have been engaged to ensure that they understand the underlying science that drives these challenges and to explore the feasibility of transferring learning and information from early MRE projects and analogous industry interactions to inform potential environmental effects and permitting for new MRE projects. The ability to use data and information from one project or location to another can aid the industry by reducing the high costs of environmental monitoring and accelerating permitting processes for future projects. This paper presents findings of a regulator survey and other engagements with regulators, provides insight into the process of data transferability, suggests a framework for data transferability and collection consistency, and details efforts to engage the research community in furthering this process.

Marine renewable energy, environmental effects, da↗

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

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

42 ENGINEERING↗

Radioactive Waste Disposal Strategies within the US Army Corps of Engineers FUSRAP - 18328

The U.S. Army Corps of Engineers' (USACE) highest priority is the protection of human health and the environment and public and worker safety during the cleanup, transportation, and disposal of Formerly Utilized Sites Remedial Action Program (FUSRAP) material. In addition to following all appropriate federal and state rules and regulations, the USACE has its own safety program that ensures that we are being protective. One aspect of the USACE FUSRAP is the radioactive waste disposal strategies that we must consider. The USACE will only dispose of FUSRAP material in a facility that is licenses/permitted to accept it. The estimated exposures to facility workers and members of the public from the permitted disposal of FUSRAP wastes is evaluated as part of this process. The USACE uses the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process to study and remediate FUSRAP sites. An evaluation is performed to decide whether it is best to manage the waste on-site or off-site and the requirements for disposal. The action selected must be protective of human health and the environment and must comply with regulations. When making the decision, there are several other factors taken into consideration including cost of the disposal and whether the public and state agencies support the action. Prior to determining disposal options, wastes must first be characterized. This involves an evaluation of both site history and analytical data. Determining the proper disposal requirements and subsequent disposal option involves: Characterizing the waste as stated above. This is important because there are several regulatory agencies which may oversee management of the waste. The US Nuclear Regulatory Commission, the US Environmental Protection Agency (US EPA), the US Department of Transportation, and state hazardous waste and/or radiation protection agencies may all have varying degrees of involvement. Identifying disposal requirements. Certain wastes must be disposed at licensed radioactive waste disposal facilities. Wastes containing US EPA regulated hazardous waste must be disposed at permitted hazardous waste disposal facilities. Certain wastes must be disposed at facilities licensed/permitted for both radioactive and hazardous waste. Some lower activity wastes may be accepted for disposal at other types of landfills. Considering acceptance criteria of the disposal facility. Radionuclides and/or hazardous constituents in the waste, as well as physical and chemical form of the waste, are evaluated to ensure they meet the acceptance criteria of the receiving facility's license and/or permit. If they don't, another disposal location must be used. Considering the accessibility and location of the disposal facility. Some facilities are able to accept shipments only by truck and others can accept material via railcar as well. The distance to a disposal facility impacts the risk of transportation accidents and efficient use of project resources such as the number of trucks required to perform the transportation. These factors are also important in evaluating whether material can be cost effectively shipped to a disposal facility. Evaluating the compliance status of the receiving facility. It is not assumed that just because a facility has a license or permit that it is acceptable for the USACE' waste. Prior to selecting a facility for disposal of FUSRAP waste, a site visit, audit and consultation with the US EPA is required to determine whether there are any known relevant violations at the facility. Facilities that have violations that negatively impact the USACE or US EPA approval of the facility are not used for disposal of FUSRAP waste. Once a facility is selected. The USACE procures contracts, or utilizes existing contracts, to facilitate the transportation and disposal action. Additionally, the USACE continues to consult with US EPA routinely to confirm the compliance status of the facility. Considering state acceptance of wastes to a facility. The USACE seeks to obtain written authorization from the facility state regulator indicating the action is compliant with existing licenses, permits, laws, and regulations. Each of these factors is considered by the USACE in selecting a FUSRAP disposal location. The goal is to provide safe, cost effective disposal which is protective of human health and the environment and which complies with all regulatory requirements. These steps all feed in to the disposal strategy consideration that USACE must go through for our FUSRAP waste streams. There are a number of challenges in the process to include In order to achieve the Congressional mandate of completing cleanup work under FUSRAP in a more cost effective, timely manner, while assuring protection of public health and safety. USACE must determine all disposal options that are available for the types of waste at each FUSRAP site. As a solution, completion of a disposal strategy document can help ensure this goal is met and will foster consistency across the FUSRAP. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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

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

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

MH-1A Sturgis Decommissioning and Dismantlement - 20281

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

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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

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

15 GEOTHERMAL ENERGY↗

Adding Impacts and Mitigation Measures to OpenEI's RAPID Toolkit

The Open Energy Information platform hosts the Regulatory and Permitting Information Desktop (RAPID) Toolkit to provide renewable energy permitting information on federal and state regulatory processes. One of the RAPID Toolkit's functions is to help streamline the geothermal permitting processes outlined in the National Environmental Policy Act (NEPA). This is particularly important in the geothermal energy sector since each development phase requires separate land analysis to acquire exploration, well field drilling, and power plant construction permits. Using the Environmental Assessment documents included in RAPID's NEPA Database, the RAPID team identified 37 resource categories that a geothermal project may impact. Examples include impacts to geology and minerals, nearby endangered species, or water quality standards. To provide federal regulators, project developers, consultants, and the public with typical impacts and mitigation measures for geothermal projects, the RAPID team has provided overview webpages of each of these 37 resource categories with a sidebar query to reference related NEPA documents in the NEPA Database. This project is an expansion of a previous project that analyzed the time to complete NEPA environmental review for various geothermal activities. The NEPA review not only focused on geothermal projects within the Bureau of Land Management and U.S. Forest Service managed lands, but also projects funded by the Department of Energy. Timeline barriers found were: extensive public comments and involvement; content overlap in NEPA documents, and discovery of impacted resources such as endangered species or cultural sites.

15 GEOTHERMAL ENERGY↗

Air Pollutant Emissions and Regulatory Implications of a Biorefinery Producing Raw Bio-Oil: Preprint

Co-processing bio-oil with petroleum-derived intermediates in existing refineries attracted refineries' interest because it offers a promising opportunity to reduce the carbon intensity of transportation fuels produced and requires relatively low capital investments to retrofit the refineries. A biorefinery producing bio-oil is considered a chemical process plant under the Clean Air Act's permitting program and could be classified as a major or minor source based on the size of the facility and the magnitude of regulated pollutants expected to be emitted. Our analysis examines the air pollutant emissions and potentially applicable federal air quality regulations for a biorefinery utilizing an ex situ catalytic fast pyrolysis process with a design capacity of processing 2,000 dry metric tons of biomass per day to produce 4,200 barrels of raw bio-oil per day. We quantify the preliminary potential-to-emit (PTE) for the biorefinery producing raw bio-oil and examine the ramifications on potential air permit classifications. We also provide an alternative set of PTE estimate by assuming the adoption of selected technically feasible emission control options that could help the biorefinery avoid being subject to major source permitting requirements (e.g., prevention of significant deterioration). Our analysis is expected to provide insights for new bio-oil project developers to identify opportunities to mitigate emissions and develop strategies to overcome potential challenges associated with air permitting.

09 BIOMASS FUELS↗

Annual FEC-PTC Report - CDRL F.70

The U.S. Department of Energy (DOE) Idaho National Laboratory (INL) Site operates facilities with potential emissions of criteria and hazardous air pollutants. This report documents the calendar year 2021 criteria and hazardous air pollutants emissions and has been prepared to comply with permit to construct (PTC) P-2015.0023 for the period of 1-1-2021 up to the effective date of PTC P 2020.0045 (1-29-2021), and PTC P-2020.0045 for the period from 1-29-2021 through 12-31-2021. The Idaho Administrative Procedures Act (IDAPA) 58.01.01.178, Standard Contents of Permits Establishing a Facility Emissions Cap (FEC) requires that all permits establishing a FEC shall include sufficient reporting to assure compliance with the permit establishing the FEC. Total hazardous air pollutant (HAP) emissions for the year were 0.10 tons in aggregate and the maximum individual HAP was toluene at 0.04 tons. Criteria pollutant emissions were 0.75 tons for sulfur dioxide, 24.33 tons for oxides of nitrogen, 6.07 tons of carbon monoxide, 2.53 tons of total particulate matter and 0.99 tons of volatile organic compounds (VOC).

99 GENERAL AND MISCELLANEOUS↗

Emission factors of industrial boilers burning biomass-derived fuels

Boilers are combustion devices that provide process heat and are integral to many industrial facilities. Historically, outside of the pulp and paper industry, most boilers burned fossil fuels, although interest in decarbonization has been leading to an increased use of renewable fuels in boilers. These boilers, including those in the biorefineries, are often large sources of air pollutant emissions, and the characterization of these emissions is critical to obtaining air permits and ensuring protection of the surrounding air quality. Several industrial boilers and new biorefineries allow utilization of biomass-derived fuels (e.g. wastewater sludge, lignin, etc.) produced during their operation as a fuel for the boiler to meet process energy needs. However, there is limited empirical data on emission factors for the burning of unconventional fuels, such as solid-gas mixtures containing biomass residues. To fill this gap, we carry out a comprehensive data survey, collecting information on emission factors for boilers burning either a single or a mixture of solid and gaseous biomass-derived fuels. We review multiple hard-to-obtain and unconventional data sources, such as air permit applications, stack test data, and industry-sponsored data collection efforts, to compile emission factors for biomass-derived fuels. We then compare this data with wood residue emission factors from the U.S. Environmental Protection Agency’s AP-42 emission factor database. Our results indicate that the emission factors for boilers burning unconventional fuels vary widely depending on the fuel composition, boiler type, and fuel characteristics. Overall, we find that median emission factors of selected biomass-derived fuels are typically lower than those of wood residue boilers in AP-42. The information collected herein could be useful to permitting agencies and industries utilizing boilers who may want to reduce the carbon impact of their facilities by combusting biomass-derived wastes for process energy needs, for more accurate emission estimation for permitting.

09 BIOMASS FUELS↗