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RCRA Part A Permit Application for Waste Management Activities at the Nevada National Security Site Hazardous Waste Storage Unit (HWSU), Explosive Ordnance Disposal Unit (EODU), Mixed Waste Storage Unit (MWSU), and Mixed Waste Disposal Unit (MWDU)

This document is the first volume in a Resource Conservation Recovery Act (RCRA) Permit Application to the Nevada Division of Environmental Protection for continued operation of certain facilities on the Nevada National Security Site (NNSS), owned by the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office (NNSA/NFO). This RCRA permit application pertains to the Hazardous Waste Storage Unit (HWSU), the Explosive Ordnance Disposal Unit (EODU), the Mixed Waste Storage Unit (MWSU), and the Mixed Waste Disposal Unit (MWDU). This volume lists the relevant permits for each of these facilities and provides maps and drawings of many aspects of them. The companion volumes, which provide descriptive text and discussion and additional graphics, are jointly considered Part B of the permit application. Those volumes are identified by the following document numbers: DOE/NV/25946--2442, DOE/NV/25946--2448, DOE/NV/25946--2425, and DOE/NV/25946--2429.

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E Tunnel Wastewater Disposal System Quarterly Monitoring Report and Annual Summary Report Nevada National Security Site, Nevada, Water Pollution Control Permit NEV 96021: Fourth Quarter and Calendar Year 2018

This annual report includes the results of the ETOS sample collection and analysis of the effluent water from the ETOS. The effluent sample was collected on October 9, 2018. Sampling activities were performed in accordance with the requirements of WPC Permit NEV 96021, Revision 1, which is effective October 1, 2013. Although the stated end date of the WPC permit is September 3 O, 2018, the NDEP, in a letter dated September 21, 2018, provided guidance that indicated the WPC Permit NEV 96021, Revision 1, is in effect until NOEP notifies NNSA/NFO otherwise.

54 ENVIRONMENTAL SCIENCES↗

Solar permitting, inspection, and interconnection cycletimes and requirements

Twenty three small-to-large residential, commercial, and industrial PV installers submitted project-level data for analysis, which included timestamps for major components of the permitting, inspection, and interconnection process as well as contract and installation dates. NREL calculated median timelines for these processes across the authorities having jurisdiction (AHJs) and utilities represented in the data. Also included are relevant permitting requirements for AHJs and interconnection process requirements for utilities. This dataset represents the underlying results shown in the Solar Time-based Residential Analytics and Cycle time Estimator (SolarTRACE) viewer. This dataset has been reviewed but errors may exist, and it may not be comprehensive. Errors in the sources (e.g., AHJ permitting requirements lists from data partners) may be duplicated in the dataset.

14 SOLAR ENERGY↗

Efforts to Streamline Permitting of Geothermal Projects in the United States

Geothermal permitting timelines in the United States can be a deterrent to new investment, with geothermal project development taking as long as seven to ten years. The Energy Policy Act of 2005 (EPAct 2005) in part aimed to streamline aspects of the geothermal permitting process on federally managed public lands. This article summarizes the general regulatory process for developing geothermal projects in the United States and thereafter discusses efforts proposed or undertaken by the U.S. Congress, U.S. Forest Service, U.S. Bureau of Land Management, state governments, and project developers to increase permitting efficiency.

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Supplemental Environmental Baseline Survey for Proposed Land Use Permit Modification for Expansion of the Dynamic Explosive Test Site (DETS) 9940 Main Complex Parking Lot

The “subject property” is comprised of a parcel of land within the Kirtland Military Reservation, Bernalillo County, New Mexico, as shown on the map in Appendix B of this document. The land requirement for the parking lot addition to the 9940 Main Complex is approximately 2.7 acres. The scope of this Supplemental Environmental Baseline Survey (SEBS) is for the parking lot addition land transfer only. For details on the original 9940 Main Complex see Environmental Baseline Survey, Land Use Permit Request for the 9940 Complex PERM/0-KI-00-0001, August 21, 2003, and for details on the 9940 Complex Expansion see Environmental Baseline Survey, Proposed Land Use Permit Expansion for 9940 DETS Complex, June 24, 2009. The 2.7-acre parcel of land for the new parking lot, which is the subject of this EBS (also referred to as the “subject property”), is adjacent to the southwest boundary of the original 12.3- acre 9940 Main Complex. No testing is known to have taken place on the subject property site. The only activity known to have taken place was the burial of overhead utility lines in 2014. Adjacent to the subject property, the 9940 Main Complex was originally a 12.3-acre site used by the Department of Energy (DOE) under a land use permit from the United States Air Force (USAF). Historical use of the site, dating from 1964, included arming, fusing, and firing of explosives and testing of explosives systems components. In the late 1970s and early 1980s experiments at the 9940 Main Complex shifted toward reactor safety issues. From 1983 to 1988, fuel coolant interaction (FCI) experiments were conducted, as were experiments with conventional high explosives (HE). Today, the land is used for training of the Nuclear Emergency Response community and for research on energetic materials. In 2009, the original complex was expanded to include four additional 20-acre areas: 9940 Training South, 9940 Training East, T-Range 6, and Training West Landing Zone. The proposed use of the subject property is for the purpose of adding a parking lot to serve the increase in customer vehicles that is occurring as the 9940 Main Complex is more heavily utilized, and as the 2009 Expansion areas come online as operational training facilities. The subject property would be used only for parking, not for testing or training activities. The parking lot would have a gravel surface. Current and future work at the 9940 Main Complex involves arming, fuzing, and firing of explosives and the testing of explosive systems components in both terrestrial and aquatic settings. It also involves specialized training activities for a variety of first responder customers, both DOE and non-DOE agencies. The approach was to perform a document search, supplemented by a visual site inspection, to identify potential environmental contamination associated with the property. Factors evaluated included hazardous substances; petroleum products and derivatives; environmental restoration sites; areas of concern; storage tanks; oil/water separators; grease traps; wash racks; waste tanks; pesticides; military munitions/ordnance; medical or bio-hazardous waste; radioactive waste; solid/municipal waste; indoor air quality; groundwater; wastewater treatment, collection, and disposal/discharge; drinking water quality; utilities; asbestos; polychlorinated biphenyls (PCBs); radon; lead-based paint; cultural resources; floodplains; and natural/biological resources. Each of these factors is evaluated separately in Section 5, Findings for Subject Property. The property categorization for this subject property would be considered Category 1- “An area or real property where no storage, release, or disposal of hazardous substances or petroleum products or their derivatives has occurred into the environment or structures or disposed on the subject property (including no migration of these substances from adjacent properties).” There appears to be sufficient information to categorize the subject property and it appears that no further effort needs to be made to obtain additional information. There are no findings of an adverse nature on the subject property itself or from adjacent properties. It is recommended that the proposed transfer of the subject property from the USAF to DOE proceed.

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Soil Sample Plan in Support of the Site 300 Explosives Waste Treatment Facility Ecological Risk Assessment Pursuant to the Hazardous Waste Facility Permit, Part V, Special Condition #14 a-f. August 2020

The Department of Toxic Substances Control issued the Final Hazardous Waste Facility Permit to Lawrence Livermore National Laboratory, Site 300 in 2017. As part of the continual process to ensure waste treatment emissions are not impacting ecological receptors, LLNL analyzed soil samples in the vicinity of the Explosive Waste Treatment Facility (EWTF) Burn Units (i.e., Burn Cage and Burn Pan) and the Detonation Pad. Soil samples were analyzed by EPA Solid Waste 846 Methods for furans, explosives, metals, and semivolatile compounds. In all samples, furans, explosives, and semi-volatile organic compounds were not detected. Metals were detected at concentrations below background levels. This soil sample plan will sample the same four downwind areas of the Burn Units and the same downwind areas of the Detonation, as well as including four new sample locations. The four new locations will be located to the northeast and southwest of the Burn Units and Detonation (as shown in Figure 3). The constituents to be analyzed are in Tables 2 and 3. Perchlorate was not identified as a constituent of concern in the 2007 Soil Sampling Plan. However, for this plan, all soil samples will be analyzed for perchlorate. After completion of the sampling event, a soil sample report will be submitted to DTSC in accordance with requirements specified in the Hazardous Waste Facility Permit, Part V, Special Conditions 16 a-f. This proposed soil sampling plan will be fully implemented no later than one year after receiving DTSC approval, in accordance with the Hazardous Waste Facility Permit, Part V, Special Condition 15.

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E-Tunnel Wastewater Discharge Permit Quarterly Monitoring Report

Monitoring and sampling activities are performed at the E-Tunnel Wastewater Disposal System (ETDS) in accordance with the requirements of Water Pollution Control (WPC) Permit NEV 96021, Revision 1, which is effective October 1, 2013. Although the end date of the WPC permit is September 21, 2018, provided Nevada Division of Environmental Protection (NDEP), in a letter date September 21, 2018, provided guidance that indicated the WPC Permit NEV 96021, Revision 1, is in effect until NDEP notifies the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office otherwise. This QMR includes the results of monthly inspections and monitoring for April, May, and June 2020. Monthly inspections and monitoring were conducted on April 21, May 28, and June 24 2020. Inspections include a visual assessment of the berms, ponding, water levels relative to the overflow pipes, tunneling or burrowing into the berms, seeps at the toe of the berms, deep-rooting botanicals on the berms, and fencing. Monthly monitoring includes measurements of the instantaneous flow rate, hydrogen ion activity (pH), and specific conductance of the ETDS discharge.

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NA-SS-SN L-5000-2018-0005 858EL Arsenic Release Above Permit Level (Causal Analysis Report)

On November 28, 2018 at approximately 4:17pm the arsenic monitor in the Acid Waste Neutralization (AWN) room located in 858N was registering a concentration above the permit level of 51ppb as stated in ABCWUA Permit 2069G Daily Composite Limit. 100ml samples had been drawn from the waste stream at - 6pm November 28, 2018. The samples were analyzed, results received on November 29, 2018 confirmed an arsenic concentration above the permit level.

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Soil Sample Workplan in Support of the Site 300 Explosives Waste Treatment Facility Ecological Risk Assessment Pursuant to the Hazardous Waste Facility Permit (Part V, Special Condition #14 a-f)

The Department of Toxic Substances Control issued the Final Hazardous Waste Facility Permit to Lawrence Livermore National Laboratory, Site 300 in 2017. As part of the continual process to ensure waste treatment emissions are not impacting ecological receptors, LLNL analyzed soil samples in the vicinity of the Explosive Waste Treatment Facility (EWTF) Burn Units (i.e., Burn Cage and Burn Pan) and the Detonation Pad. Soil samples were analyzed by EPA Solid Waste 846 Methods for furans, explosives, metals, and semi-volatile compounds. In all samples, furans, explosives, and semi-volatile organic compounds were not detected. Metals were detected at concentrations below background levels. This soil sample plan will sample the same four downwind areas of the Burn Units and the same downwind areas of the Detonation, as well as including four new sample locations. The four new locations will be located to the northeast and southwest of the Burn Units and Detonation (as shown in Figure 3). The constituents to be analyzed are in Tables 7 and 8. Perchlorate was not identified as a constituent of concern in the 2007 Soil Sampling Plan. However, for this plan, all soil samples will be analyzed for perchlorate. Nitrate and all CAM17 metals have been added to the sampling plan to comply with DTSC comments received in correspondence dated June 4, 2021. After completion of the sampling event, a soil sample report will be submitted to DTSC in accordance with requirements specified in the Hazardous Waste Facility Permit, Part V, Special Conditions 16 a-f. This proposed soil sampling plan will be fully implemented no later than one year after receiving DTSC approval, in accordance with the Hazardous Waste Facility Permit, Part V, Special Condition 15.

45 MILITARY TECHNOLOGY, WEAPONRY, AND NATIONAL DEF↗

Geophysical Characterization and Monitoring of the 200 Area Treated Effluent Disposal Facility to Support Permit Renewal; TEDF Geophysical Monitoring

The Treated Effluent Disposal Facility (TEDF), located in the 200 East Area of the Hanford Site, is a site where non-hazardous and non-radioactive liquid wastes are disposed into two state-permitted infiltration basins. In 2016, the Washington State Department of Ecology denied a permit renewal request for TEDF due to the inability to adequately assess the impact of TEDF discharge water on the underlying groundwater quality. TEDF overlies the relatively impermeable Ringold Lower Mud (RLM) unit, whose upper contact lies in the vadose zone approximately 30 m below ground surface and approximately 10 m above the water table boundary. The RLM is assumed to isolate TEDF discharge water from the natural groundwater aquifer, which is monitored using wellbores screened below the RLM. Therefore, samples collected from monitoring wells near TEDF are not considered representative of TEDF discharge water. Rather, TEDF discharge water is assumed to mound on top of the RLM to form a perched aquifer. To support permitting of the TEDF, a new monitoring well is required that can be used to sample water from the presumed perched water aquifer above the RLM. Ideally, the screened section of the well would be located at the peak of the perched water mound(s), which presumably occurs at the point of maximum vertical flux from TEDF to the RLM, or equivalently where the dominant infiltration flow paths reach the RLM. This report describes how time-lapse 3D electrical resistivity tomography (ERT) was used in conjunction with nominal TEDF discharge operations to image the dominant flow paths from each pond to the RLM. Results are summarized in Figure ES.1. Figure ES.1A shows a satellite image of the TEDF overlain by an array of surface ERT electrodes. The solid and dashed black circles denote the zones of maximum vertical flux at the RLM within the south and north ponds, respectively, and presumably the regions where perched water peaks during discharge. Figure ES.1B shows time-lapse difference imaging results approximately 15 days after switching discharge from the south pond to the north pond. Blue iso-surfaces beneath the north pond denote regions of increasing bulk electrical conductivity caused by increasing saturation due to infiltrating water. Red iso-surfaces beneath the south pond denote regions that were previously saturated during the south pond discharge and are now de-saturating, causing a decrease in bulk electrical conductivity. In both cases, the zones of maximum change mark the dominant flow paths to the RLM. Figure ES.1C shows time-lapse imaging results approximately 15 days after switching discharge from the north pond to the south pond. In this case, blue iso-surfaces mark the dominant flow paths to the RLM from the south pond. The red iso-surfaces mark the dominant flow paths that existed during discharge to the north pond. The regions of maximum change in bulk conductivity (due to saturation or desaturation) that mark the primary flow paths are equivalent in both cases and denoted by the dashed solid and black circles. If a perched water zone forms on the RLM, it is likely to mound within or near the dashed circle during discharge to the north pond, and in the solid circle during discharge to the south pond. In other words, if perched water mounding occurs, the circles mark the optimum locations suggested by the ERT imaging for monitoring boreholes to be placed, enabling samples to be collected that are representative of TEDF discharge impacts on groundwater quality.

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RCRA Part B Permit Application Nevada National Security Site (NNSS) for Waste Management Activities at the NNSS Mixed Waste Storage Unit (MWSU)

This volume of the Resource Conservation and Recovery Act (RCRA) permit application to the Nevada Division of Environmental Protection focuses on continued operation of the Mixed Waste Storage Unit at the Nevada National Security Site (NNSS), under the auspices of DOE’s National Nuclear Security Administration Nevada Field Office (NNSA/NFO). Low-level mixed waste (LLMW) accepted at the NNSS contains both radioactive and hazardous material components as defined by various laws and regulations. The Mixed Waste Storage Unit (MWSU) is located at the Area 5 Radioactive Waste Management Complex (RWMC). Existing facilities at the RWMC are used to store LLMW generated at or shipped to the NNSS prior to disposal at the Mixed Waste Disposal Unit (MWDU). The document describes the MWSU, its general design, its operation, the materials it stores, and relevant health and safety regulations with which NNSS complies. The currently permitted MWSU has been operated since December 2010. Each of the four designated storage areas is RCRA-compliant for the storage of hazardous waste. This application represents a renewal request by DOE for the permitted MWSU. For security reasons, some of the contents of the full application are not available for public viewing. This version of the application contains most but not all of the contents as submitted to the regulatory agencies.

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Reuse Permit I-160-02Quality Assurance Project Plan (QAPP) for Required Environmental and Process MonitoringIdaho National Laboratory Materials and Fuels Complex Industrial Waste Ditch and Pond

The purpose of this quality assurance project plan (QAPP) is to describe the technical requirements and quality assurance (QA) activities of the environmental data collection/analyses operations to be performed under Reuse Permit I-160-02, Modification 1 (hereafter ‘permit’). It describes the scope of monitoring, the organization and persons involved, the data quality objectives, the monitoring procedures, and the specific quality control (QC) measures to be employed. All QAPP activities are implemented to determine whether the results of the sampling and monitoring performed are the right type, quantity, and quality to satisfy the requirements of the permit, Section 5.

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Diagnosing added value of convection-permitting regional models using precipitation event identification and tracking

Dynamical downscaling with high-resolution regional climate models may offer the possibility of realistically reproducing precipitation and weather events in climate simulations. As resolutions fall to order kilometers, the use of explicit rather than parametrized convection may offer even greater fidelity. However, these increased resolutions both allow and require increasingly complex diagnostics for evaluating model fidelity. Here we focus on precipitation evaluation and analyze five 2-month-long dynamically downscaled model runs over the continental United States that employ different convective and microphysics parameterizations, including one high-resolution convection-permitting simulation. All model runs use the Weather Research and Forecasting Model driven by National Center for Environmental Prediction reanalysis data. We show that employing a novel rainstorm identification and tracking algorithm that allocates essentially all rainfall to individual precipitation events allows new insights into model biases. Results include that, at least in these runs, model wet bias is driven by excessive areal extent of individual precipitating events, and that the effect is time-dependent, producing excessive diurnal cycle amplitude. This amplified cycle is driven not by new production of events but by excessive daytime enlargement of long-lived precipitation events. Here, we further show that in the domain average, precipitation biases appear best represented as additive offsets. Of all model configurations evaluated, convection-permitting simulations most consistently reduced biases in precipitation event characteristics.

54 ENVIRONMENTAL SCIENCES↗

Benefits of the SolarAPP+ Online Permitting Software

The Solar Automated Permit Processing Plus (SolarAPP+) software is an online platform that provides plan review and instantly issues permits for code-compliant residential photovoltaic (PV) systems.

automated permitting↗

Evaluation of precipitation across the contiguous United States, Alaska, and Puerto Rico in multi-decadal convection-permitting simulations

Abstract This study is an early effort to generate a multi-decadal convection-permitting regional climate dataset that covers nearly the entire North American continent. We assessed a 20 year dynamically downscaled regional climate simulation at a 4 km spatial resolution with explicit convection across the contiguous United States (CONUS), Alaska, and Puerto Rico. Specifically, we evaluated the model’s performance in representing mean, 95th percentile, and extreme precipitation across regions. Our findings indicate that when compared with ERA5 reanalysis, the forcing data, convection-permitting simulation improves representations of seasonal, 95th percentile, and extreme precipitation over a large portion of the CONUS, Alaska, and Puerto Rico, particularly in areas where precipitation is heaviest. The simulation adds value over its forcing data (ERA5) in up to 53% of all grid cells in the CONUS, 68.8% in Alaska, and 84.0% in Puerto Rico. It is important to note that, however, despite improvements, model errors in Puerto Rico remain large. Similar improvements are observed in extreme indices, including consecutive dry days, maximum 5 days precipitation, and extreme precipitation. Analysis of the diurnal cycle of mean hourly precipitation suggests that representations of convective processes—including onset, dissipation, suppression, downstream propagation, and local circulation—improved overall.

54 ENVIRONMENTAL SCIENCES↗

Transportation of Large Wind Components: A Permitting and Regulatory Review

This report summarizes permitting and regulatory issues associated with transporting wind turbine blades, towers, and nacelles as well as large transformers (wind components). These wind components are commonly categorized as oversized and overweight (OSOW) and require specific permit approvals from state and local jurisdictions. The report was developed based on a Quadrennial Energy Review (QER) recommendation on logistical requirements for the transportation of 'oversized or high-consequence energy materials, equipment, and components.'

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Summary Overview of Content Guidance For Early Site Permit Applications

The Early Site Permit (ESP) process offered under Title 10 Code of Federal Regulations (CFR) Part 52, Subpart A, was promulgated by the Nuclear Regulatory Commission (NRC) in 1989 to address industry concerns with the former licensing process under 10 CFR Part 50. Previously, the licensing process required large expenditures of time and money by applicants well before key site specific environmental, safety, and emergency planning issues could be resolved. As envisioned, the ESP process is meant to resolve these issues well in advance of when a decision is made to build a nuclear power facility and before substantial capital is invested in the construction of a new nuclear facility. The ESP application is required to provide design information pertaining to structures, systems, and components along with site-specific parameters (such as meteorology, demographics, and hydrology) and address site safety, environmental protection, and emergency planning. Although an ESP applicant does not need to specify a particular nuclear plant design, as in construction permit applications, it does need to provide sufficient surrogate design information (developed to bound the nuclear plant design(s) that are being considered by the applicant) so that the NRC can make a determination on the acceptability of the site and the environmental impacts, and determine whether designs bounded by the surrogate design information provided by the applicant can be qualified for the proposed site.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Workshop Summary Report on Using AI Tools to Improve the Efficiency and Outcomes of the NEPA Process: AI for Permitting Workshop at the 2025 National Association of Environmental Professionals (NAEP) Annual Conference

On April 29, 2025, the U.S. Department of Energy and Pacific Northwest National Laboratory hosted a workshop at the National Association of Environmental Professionals 2025 Conference and Training Symposium in Charleston, South Carolina, titled, “Effective and Responsible Use of Customized AI Tools to Improve the Efficiency and Outcomes of the NEPA Process.” The objectives of this workshop were to make environmental practitioners aware of the potential for using artificial intelligence in the National Environmental Policy Act process, demonstrate examples of how artificial intelligence can be integrated effectively to improve efficiency and outcomes and solicit questions and feedback from practitioners. This report summarizes the key points from all talks and case studies, as well as audience questions and feedback on the presentation topics and the broader topic of "AI in permitting". The report concludes by highlighting the key barriers and opportunities for the implementation of AI in permitting, as discussed during the workshop.

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