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Driving Economics and Reducing Risks: The Business Case for Security-by-Design in Nuclear Power

This report provides an analysis of the financial, operational, and strategic advantages of incorporating Security-by-Design (SeBD) early in the lifecycle of nuclear power plant projects. By framing security as a foundational design element rather than a late-stage add-on, owners, vendors, and operators can reduce budget overruns, strengthen regulatory compliance, and increase revenue opportunities. The report details key lifecycle phases, highlighting the strategic imperative for organizations (including project developers, investors, vendors, and regulators) to adopt SeBD. Drawing on industry estimates, real-world case studies, and comparative cost analyses, the findings underscore that even a modest upfront investment in SeBD can yield substantial long-term returns by preventing costly retrofit activities, minimizing regulatory delays, and positioning nuclear vendors for the ability to adapt in the evolving security market. By avoiding excessive retrofit expenses and positioning security as a built-in feature rather than an afterthought, nuclear projects can protect their financial performance, enhance public trust, and secure a competitive edge in an increasingly complex global energy market. The authors advocate for SeBD’s strategic implementation, supported by established quality management methodologies, thereby promoting continuous improvement and defect avoidance. Ultimately, early SeBD integration represents a strategic investment, yielding significant returns by preventing costly retrofits and positioning nuclear projects for enhanced competitiveness and public trust.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

ORNL Package Testing Program Overview

When transporting radioactive or hazardous materials, safety and security are top priorities. Packaging and transportation regulations require reliable evidence that containers have passed rigorous performance tests to ensure that the public and the environment are protected from the hazardous nature of the cargo. Because of its long history in energy and security research, Oak Ridge National Laboratory (ORNL) has needed to ship hazardous packages for the past 65 years. Since the 1940s, ORNL has made significant contributions to transportation regulations and has been at the forefront of regulatory testing development. Today, ORNL is a leader in standards development and testing of designs of radioactive material packages. ORNL plays a critical role in ensuring the safe transportation of radioactive materials across the United States by executing rigorous testing campaigns of packages that contain radioactive materials. Early testing activities focused on supporting the development of transportation regulations established by both the International Atomic Energy Agency (IAEA) and the United States. Currently, all package testing activities are performed under the Package Testing Program (PTP) at the Package Evaluation Facility (PEF) located at the National Transportation Research Center (NTRC), which is about 10 miles from the main ORNL campus. The PTP develops and evaluates testing solutions, ensuring that they are safe efficient, and in compliance with regulatory requirements. The vision for the PTP is to be a world-class leader in the evaluation and testing of radioactive and hazardous material packages. The key elements necessary to fulfill this mission are an experienced and professional staff; state-of-the-art facilities, equipment, and instrumentation; and completion of challenging programs and projects important to package transportation. Collaborations with other internal and external organizations play a significant role in building stronger teams and achieving this vision. By adhering to and advancing regulatory standards, ORNL’s PTP supports development of safe and compliant packaging, safeguarding the transportation process from potential risks associated with radioactive material logistics.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

A Novel Manufacturing Process of Lightweight Automotive Seats (Integration of Additive Manufacturing and Reinforced Polymer Composite)

Lightweight automotive seats offer multiple benefits to original equipment manufacturers in terms of cost savings from various aspects, including less material usage, more integrated processes, and compliance with Corporate Average Fuel Economy Standards. Original equipment manufacturers have been focusing on innovative ways to produce light weight automotive seats. The commercially available automotive seats are currently made of multiple metal components combined through welding and fasteners. The use of additive manufacturing and composite structures is particularly useful for light weighting the automotive components. Additive manufacturing (AM) offers multiple advantages over traditional manufacturing processes such as freedom of design thereby enabling complex structural geometries, mass customization and waste minimization, and control over the fiber alignment through deposition in a predetermined pattern. Combining metal inserts with polymer composites through a novel manufacturing process allows design of lightweight and high-performance materials for automotive components. However, fabricating these metal polymer composite structures through traditional manufacturing processes limits their mechanical properties due to limited design freedom, lack of control over fiber orientation in composite parts, and poor interfacial bonding between the constituent materials. It is essential to develop a novel manufacturing process to enable high throughput production of lightweight automotive seats using metal and polymer composites. As such it is important to design the automotive seat suitable for manufacturing via this process and perform mechanical characterization on various subcomponents of the seat to ensure that the design and performance requirements provided by the auto manufacturer are met. The aim of this project is to develop a novel manufacturing technique to produce lightweight automotive seat by combining AM with conventional manufacturing processes. The car seat back panel will be designed via topology optimization and numerical simulations to minimize the overall weight while ensuring it meets all the performance requirements. The optimization of the seat back structure will be based on computational stress analysis to maximize the stiffness and minimize the weight. Materials currently used by Ford Motor Company will be adopted for a few subcomponents while the in-house composite materials will be used for the rest of the seat back. The composite and metallic materials will be tested to determine their mechanical properties as these are necessary for simulations. A novel manufacturing process will be developed to integrate AM metal inserts with discontinuous reinforced composite through large scale additive manufacturing and compression overmolding processes. The developed manufacturing technique will be used to fabricated various subcomponents suitable for the seat back design and mechanically tested to determine their properties. The manufacturing of the lightweight seat back design through this process involves integrated AM metal inserts with the composite structure for recliner connection. The manufacturing of the entire seat back which is lightweight through the novel manufacturing process will be discussed. The performance of the designed seat back will be investigated through numerical simulations and shown to meet all the requirements provided by the auto manufacturer. The final goal of developing a novel manufacturing process for lightweight automotive seats is met through design optimization of seat back, manufacturing of subcomponents, mechanical characterization, and validation through numerical simulations. The routes to achieve the final goal of the project and the depth in which they were investigated changed throughout the project due to personnel changes and the COVID-19 pandemic. The project resulted in the development of a novel manufacturing process to integrate metal inserts with tailored polymer composite preforms through overmolding. Leveraging this proven manufacturing process, a lightweight seat back was designed through topology optimization and numerical simulations. The designed seat back uses AM metal inserts and compression overmolding of tailored polymer composite preforms obtained via large scale additive manufacturing. The metal polymer composite structures fabricated through this process exhibited enhancement in stiffness and improved ductility upon testing. Overall, the project provided an alternative design and manufacturing technique for automotive seat back that enables weight saving while meeting the safety and performance requirements.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

Life-Cycle Cost Analysis Framework for Water Efficiency Measures

Life-Cycle Cost Analysis Framework for Water Efficiency Measures: Guidance Designed for Federal Agencies (hereafter referred to as “this report”) provides a technical framework for federal agencies to conduct a life-cycle cost analysis (LCCA) for water efficiency projects in accordance with 42 U.S.C. § 8253. This report leverages insights from the 2023 report, PNNL-34006, Water and Wastewater Annual Price Escalation Rates for Selected Cities Across the United States: 2023 Edition (Unger et al. 2023). The primary objective of this report is to provide a framework to assist federal agencies with evaluating the full economic impact of water efficiency projects by assessing both initial investments and long-term operational benefits. An LCCA can provide a comprehensive view of all costs associated with a water efficiency project, including initial investment, ongoing operations and maintenance (O&M), and eventual disposal or replacement, ensuring the most cost-effective solution is selected. The LCCA methodology outlined in this report enables users to compare base case scenarios with potential alternatives using a standardized present value approach. It incorporates key cost components such as energy, water and wastewater, installation, O&M, and equipment replacement. Additionally, the framework introduces relevant evaluation metrics, such as the net savings and the savings-to-investment ratio, to ensure that water efficiency measures are economically justified over the lifespan of the project. To support practical application, this report also describes various water efficiency strategies that may be analyzed using an LCCA, including plumbing retrofits, irrigation upgrades, alternative water use, and cooling system improvements. By applying this framework, federal agencies can ensure compliance with regulatory mandates while maximizing the return on investment and contributing to resilient water management practices. The information provided in this report is aligned with the Federal Energy Management Program (FEMP) life-cycle cost (LCC) methodology, as conveyed in National Institute of Standards and Technology (NIST) Handbook 135 (Kneifel and Webb 2022). This report is intended to provide relatively high-level guidance, acting as a complement to, rather than a substitute for, that resource.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

AOI 5 Improved Efficiency of Medium- and Heavy-Duty Natural Gas and Propane (LPG) Engines

Spark-ignited heavy-duty (HD) natural gas engines typically experience efficiency losses at part-load operation due to throttling requirements needed to maintain stoichiometric combustion. A substantial portion of medium- and heavy-duty engine operation occurs in this low-load region, resulting in increased brake-specific carbon dioxide emissions and reduced overall efficiency. This project designed, developed and demonstrated cylinder deactivation (CDA) technology on an HD natural gas engine to mitigate these losses. CDA enables selective deactivation of cylinders, reducing pumping losses while maintaining required torque output and meeting vehicle noise, vibration, and harshness (NVH) targets. The project objectives were successfully achieved, demonstrating up to 12% improvement in fuel consumption over the next generation HD NG engine on key low loaded HD cycles and maintained compliance with 0.02 g/hp-hr NO x emissions with comparable or better vibrations to current product. These results confirm that CDA technology can substantially improve the fuel efficiency and environmental performance of heavy-duty natural gas engines, reinforcing their potential as a low-carbon bridge solution in the transition toward zero-emission transportation technologies.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

Workflow for Process Automation of Soil Gas Results from an Automated Soil Gas-Sampling System for Application in Carbon Storage Projects

Conference presentation at Geoconvention, Calgary, Alberta, Canada, May 12–14, 2025. The Energy & Environmental Research Center (EERC) developed an automated workflow for processing soil gas measurements collected from the automated soil gas-sampling systems deployed across the project site. Raw soil gas measurements are collected from each station every 4 hours and automatically uploaded to a cloud database. The workflow begins by writing code to download the data to a workstation automatically, then the data are published to an online dashboard that visualizes the measurements in time-series plots and a process-based decision-making framework. This automated workflow accelerates the time from data acquisition to decision-making. It supports carbon storage project operators by preparing and delivering a live, standardized dataset for quick analysis and source attribution to provide assurance of containment and overall permit compliance.

02 PETROLEUM↗

Wetland Re-Evaluation and Delineation Report for the Los Alamos National Laboratories Wetlands Project, Los Alamos County, New Mexico

In March of 2005, the Department of Energy (DOE), National Nuclear Security Administration (NNSA), Los Alamos Site office (LASO) requested the U.S. Army Corps of Engineers Albuquerque District (USACE) to identify and delineate wetlands at Los Alamos National Laboratory (LANL). The results of this study were intended to support the preparation of the Supplemental Site-Wide Environmental Impact Statement (EIS) and various mitigative measures that would become part of the National Environmental Policy Act (NEPA) compliance process for LANL. The term “wetland” will be used throughout the report to refer to the potential wetlands listed in Table 1. Many of these potential "wetlands” were not determined to be wetlands based on 2025 data.

60 APPLIED LIFE SCIENCES↗

Evaluation of Cease Fire CFP 640 for Use in Gloveboxes (Final Report)

A Los Alamos National Laboratory (LANL) task group was established to discuss and evaluate a candidate fire suppression system (FSS) for gloveboxes (GB) and dropboxes (DB, for brevity, this report will simply refer to gloveboxes). Suitability criteria include compliance, compatibility, and capability. LANL contracted with New Mexico Tech (NMT) to quantitatively evaluate the perfor mance of one of those systems including its ability to extinguish GB fires, limit over-pressurization of the GB, etc. Additionally, the results of these experiments provide data points that could be used when fire hazard evaluations (FHEs) are conducted for determining when to require a fire suppres sion system installation within a GB (as required by NFPA 801, Standard for Facilities Handling Radioactive Materials, DOE Standard 1066-2012 Fire Protection, and AGS-G010-2011 Standard of Practice for Glovebox Fire Protection).

42 ENGINEERING↗

Optimize the Autonomous Sensor Fish Device for Understanding Interactions of Aquatic Animals with Marine and Hydrokinetic and Hydro Systems (CRADA 476) Final Report

This project at the Pacific Northwest National Laboratory (PNNL) enhances our understanding of how aquatic life interacts with marine renewable energy (MRE) and hydropower systems through the development and testing of advanced sensor technology. The Marine Sensor Fish (MSF) and its smaller variants, the Sensor Fish Mini (SF Mini) and Flexible Sensor Fish (FSF), measure critical environmental stressors, such as shear forces, pressure changes, and strike impacts, that are essential for assessing the risks posed by energy devices, including tidal turbines, hydropower installations, and other MRE infrastructure. Rigorous field testing has shown that these tools are effective in capturing detailed data on turbulence, pressure variations, strike impacts, and other stressors near these devices, providing valuable insights into the conditions faced by aquatic species. Economically, these tools offer renewable energy developers a practical solution for streamlining environmental assessments and ensuring regulatory compliance, ultimately reducing costs associated with evaluating and mitigating ecological impacts. This research also benefits the public by promoting the growth of renewable energy sources that protect aquatic ecosystems, advancing both sustainable energy production and environmental stewardship.

13 HYDRO ENERGY↗

Hanford Site Bird Surveys Report for Calendar Year 2016

Resource stewardship is an integral part of the U.S. Department of Energy, Richland Operations Office (DOE-RL) responsibilities at the Hanford Site. Efficient conservation or management of any species or any population is supported through the availability of reliable information on the population in question. DOERL conducts ecological monitoring on the Hanford Site to collect and track this information. Ecological monitoring data provide baseline information about the plants, animals, and habitat under DOE-RL stewardship at Hanford that is required for decision-making under the National Environmental Policy Act (NEPA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The Hanford Site Comprehensive Land Use Plan (CLUP, DOE/EIS-0222-F), which is the Environmental Impact Statement for Hanford Site activities, helps ensure that DOE-RL, its contractors, and other entities conducting activities on the Hanford Site are in compliance with NEPA.

54 ENVIRONMENTAL SCIENCES↗

PSU ESI Review

A guide to developing an Energy Service Interface (ESI) was created as part of the Grid Modernization Laboratory Consortium 2.5.2 ESI project. The approach applies device-agnostic and service-oriented ESI principles and leverages documents such as the Interoperability Maturity Model and Common Grid Service Definitions to provide a methodology to review, develop, and update standards and profiles to engage distributed energy resources (DER) to provide grid services. This document evaluates the ESI developed by Portland State University’s Power Engineering Group under the Electric Grid of Things project funded by the U.S. Department of Energy. The evaluation explores the compliance of this specific implementation with the GMLC ESI principles to provide an example of an ESI profile and gap analysis.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Characterization Results for the August 2025 Tank Farm 2H Evaporator Overhead Sample

On an annual basis, Savannah River Mission Completion (SRMC) provides 2H and 3H evaporator overhead samples to Savannah River National Lab (SRNL) to be analyzed per Section 5.2 of the Effluent Treatment Project (ETP) Waste Compliance Plan (WCP) and the Waste Acceptance Criteria (WAC). This report presents the average characterization results for the August 2025 2H evaporator overhead sample. The sample was clear and colorless with no visible solids. The results provide measurements for cesium-137 ( 137 Cs), strontium-90 ( 90 Sr), and iodine-129 ( 129 I) with the radionuclide concentration limits specified by the WAC. These analyses were performed in duplicate, and all three measured radionuclide concentrations were within ETP WAC limits. A summary of the analytical results for this 2H evaporator overhead sample includes the following: The measured cesium-137 activity in the 2H evaporator overhead sample averaged 3.02E+02 dpm/mL, which is below the ETP WAC limit of 1.30E+03 dpm/mL. The strontium-90 activity in the 2H evaporator overhead sample averaged 3.33E+00 dpm/mL, which is below the ETP WAC limit of 1.76E+02 dpm/mL. The iodine-129 activity in the 2H evaporator overhead sample averaged 1.20E-01 dpm/mL, which is below the ETP WAC limit of 1.00E+00 dpm/mL. Although the measurements for Cs-137 and Sr-90 are lower compared to previous years, the results remain within a similar range to past measurements and are well below the WAC limits. Iodine-129 indicates detectable results compared to previous years, which can be attributed to recent salt batch processing trending close to the WAC limit for saltstone production. However, these results are still below the ETP WAC limit.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Mitigation for the Demolition of Dormitory Buildings 12-32, 12-34, 12-35, and 12-37 in the Area 12 Camp Historic District, Nevada National Security Site, Nye County, Nevada

The purpose of this letter report is to document the mitigation of adverse effects of a proposed undertaking in compliance with the stipulations in the Programmatic Agreement DE-GM58-22NA25554 Among the U.S. Department of Energy and the Nevada State Historic Preservation Officer and the Advisory Council on Historic Preservation Concerning the Protection of Historic Properties on the Nevada National Security Site, Nye County, Nevada, hereafter referred to as the NNSS PA. The proposed undertaking would demolish Buildings 12-32 (State Historic Preservation Office [SHPO] Resource No. B18291), 12-34 (SHPO Resource No. B18292), 12-35 (SHPO Resource No. B18293), and 12-37 (SHPO Resource No. B18294) in the Area 12 Camp Historic District (SHPO Resource No. D372) on the Nevada National Security Site (NNSS). The Area 12 Camp Historic District has been determined eligible for listing in the National Register of Historic Places (NRHP) under Criteria A and C (Reed 2021; Reno et al. 2021).

54 ENVIRONMENTAL SCIENCES↗

Value of Nuclear Energy to the Reliability of the North American Power System: Results for Western and Eastern Interconnections

This report documents the fulfillment of a milestone for the United States (U.S.) Department of Energy Office of Nuclear Energy Light Water Reactor Sustainability Program: completing a baseline study of regional impact of nuclear power plants and hydrogen production in maintaining grid services and power quality. Models have been comprehensively demonstrated for the Western Interconnection, or Western Electric Coordinating Council area, and in the Eastern Interconnection for scenarios representative of past extreme events (e.g., drought and heat waves). Understanding the impact on the reliability of the bulk electric system of any reduction in generation capacity from nuclear power, for any reason, is the motivation of this work. Factors that might lead to the premature or unplanned closure of nuclear plants, extended outages, or repurposing of nuclear power include: • Aging infrastructure: Many nuclear power plants in the U.S. are nearing the end of their designed operating lives. Upgrading aging infrastructure can be expensive, and some utilities may choose to retire plants rather than invest in costly upgrades. • Low wholesale electricity prices: The deregulation of the electricity market in many states has led to increased competition and driven down wholesale electricity prices, causing nuclear power operators to seek other revenue sources for their heat and power such as clean hydrogen production. • Renewables growth: The rapid growth of renewable energy sources like solar and wind power is posing a challenge to traditional generation sources like nuclear. While many see renewables as a key part of the clean energy transition, their intermittent nature requires additional grid solutions for reliable power supply. • The potential for regulatory decisions to be in conflict: In its 2021 rulemaking, EPA rule (86 FR 880), the Environmental Protection Agency (EPA) set a compliance date for the ban on processing and distribution in commerce of Decabromodiphenyl Ether (DecaBDE). Since DecaBDE is in many components, particularly wiring, of nuclear power plants which are deemed safety-related or important to safety, three plants would not have been able to restart after their 2023 spring outages, and numerous others would have faced issues in the near future. Fortunately, in this case, the EPA provided relief to the nuclear energy industry. The report provides a summary of the significant role nuclear energy plays in the United States’ power generation mix, supplying around 20% of the nation’s electricity generation, spread across 28 U.S. states. Nuclear power is reliable, mostly unaffected by weather and seasonal changes, and provides a consistent source of baseload power. In terms of capacity, nuclear power plants account for as much as 26% of balancing area power generation capacity. Nuclear power also provides a substantial contribution (e.g., 10% of the inertia in the Eastern Interconnection) of the synchronous spinning mass/inertia that buffers the rate at which frequency changes when a load and generation imbalance occurs (e.g., a large plant trips or a load is suddenly shed due to a transmission outage). This contribution is critical for maintaining grid stability during sudden changes in load or generation.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Floating Photovoltaics in Hydropower Reservoirs in the United States

This report presents a comprehensive analysis of the feasibility of floating photovoltaics (FPV) in federally regulated reservoirs within the continental United States (CONUS) and to present a methodology for capturing the true costs of deployment, potential environmental impacts, and regulatory pathways for open-loop hydropower reservoirs. It is intended for stakeholders who may not be solar industry experts but who are interested in exploring the potential for FPV in their reservoirs. While there are promising opportunities, particularly in enhancing dissolved oxygen (DO) levels and potentially improving compliance with existing hydropower licenses, the current capital costs of FPV are not yet competitive with traditional land-based solar installations at the utility-scale when comparing the LCOE results. A competitive financial outlook is achievable when applying a 30% Investment Tax Credit (ITC) and considering a 5% reduction from the baseline capital expenditures (CapEx) at the Tuckertown Reservoir in North Carolina case study. The study is structured around three key pillars of research: technical potential, environmental impacts and regulatory considerations, and technoeconomic analysis. This report provides a nationwide assessment of the opportunities for FPV in terms of capacity, measured in direct current megawatts (MWDC), in reservoirs managed by the U.S. Bureau of Reclamation (USBR), the U.S. Army Corps of Engineers (USACE), and the Federal Energy Regulatory Commission (FERC). Additionally, the report introduces a heuristic model for estimating the CapEx of utility-scale FPV projects (1–100 MW), offering a baseline cost estimate for stakeholders. Finally, the report applies these models to a case study of a hydropower reservoir in North Carolina to present site-specific results.

13 - HYDRO ENERGY↗

Regulatory and Technical Challenges and Barriers to Adoption of Distributed Wind Energy in Agricultural Settings

Distributed wind (DW) energy development can benefit agricultural landowners through the possibility of improved resilience of electrical service from onsite generation and associated economic benefits. DW development currently faces technical and regulatory challenges related to interconnection of projects with distribution or transmission equipment on the main electrical grid. A review was conducted of barriers to adoption for agricultural DW projects and potential roles of various stakeholders in addressing them. One major barrier is that the unique characteristics of wind energy generation such as its variability and intermittency, may require upgrades for the whole power line, which can lead to prohibitive cost burdens on individual interconnection customers. Another barrier is compliance with federal, state, or utility-level regulations that require technology-agnostic, industry-standard equipment that is often not technically realistic for DW projects. DW developers, grid infrastructure owner-operators, regulators, and standards publishers can work together to address these challenges and facilitate DW development.

17 WIND ENERGY↗

Autonomous Hydrogen Fueling Station

This project “Autonomous Hydrogen Fueling Station” covered the autonomous refueling with both gaseous hydrogen and liquid hydrogen. The part on gaseous hydrogen focused on the development of an autonomous robotic fueling arm that would couple to a fuel cell engine for hydrogen refueling without guidance from the forklift operator and budget period. Research was also covered for the robotic fueling with a commercial vehicle. The second phase of the project created the baseline for an autonomous liquid hydrogen transfer system that would minimize boil off losses by operating at thermodynamically efficient state points. For the development of the robotic fueling arm, testing was conducted to establish a baseline measurement of the accuracy and repeatability of a human operator positioning a lift truck in front of a dispenser. The goal was to establish the range of motion required for an autonomous fueling mechanism to mate a hydrogen nozzle with a receptacle on a fuel cell system installed in a forklift. The final design comprised a selective compliance articulated robot arm (SCARA)-type mechanism with two arms for horizontal motion and a ball screw for vertical movement and color and LIDAR cameras were used for marker identification and proximity awareness to guide the robotic arm to its target receptacle. Initial tests resulted in 199 out of 200 successful attempts at autonomous coupling of the dispensing coupler and a fuel cell engine, without hydrogen. The dispenser prototype was modified to include tubing for both hydrogen fuel and air purge lines, but subsequent tests were confounded by the shoulder motor over current errors which limited the robot from getting to the fully inserted position to achieve a positive latch. Robotic hydrogen refueling was successfully demonstrated over 1.5 hours of testing, Plug completed 29 successful latches with an average number of 4 sequential latches before failure. However, a robot capable of placing the nozzle with more force is required for higher reliability. For budget period two, a small scale (10 kg / transfer) automated control system was designed that would operate valves to control pressure and flow of liquid nitrogen between a source and receiving tank with an aim to minimize boil off losses by operating at the most thermodynamically efficient state points. Control system logic flow and a P&ID were developed prior to system safety characterization via HAZOP. A control narrative and system state points were defined. Delays in approval for a change of project objective and procurement issues precluded the construction and test of the final prototype system.

08 HYDROGEN↗

Knowledge-Based Hazardous Waste Determinations for Solar Photovoltaic (PV) Modules: A Foundational Study

This report explores using "generator knowledge" to determine whether a solar photovoltaic (PV) module must be managed as hazardous waste prior to recycling or landfilling. Generator knowledge is a legal term and existing regulatory pathway for making a hazardous waste determination that has been used by other industries but is a relatively unknown option to the PV industry. In the United States, a hazardous waste determination often acts as a pre-requisite to recycle or landfill a PV module. The results of the hazardous waste determination dictate whether the PV module must be managed as hazardous waste or nonhazardous solid waste. Managing a PV module as hazardous waste requires compliance with stringent U.S. federal and state hazardous waste law. In addition to increased management costs, which can be ten times higher, legal liability for PV modules regulated as hazardous waste is also heightened with both civil and criminal penalties for noncompliance which includes making an inaccurate or faulty hazardous waste determination. The most common reason a PV module would be regulated as hazardous is if it contains a regulated metal in an amount that equals or exceeds the toxicity characteristic limits. To determine whether a PV module exhibits a hazardous characteristic, the regulated person/entity must "apply knowledge...in light of the materials and processes used." In the absence of adequate knowledge to determine whether the PV module is hazardous, it must be tested using Test Method 1311 Toxicity Characteristic Leaching Procedure (TCLP) or an equivalent EPA-approved method. Although TCLP is the predominant method used to today to make a hazardous waste determination for PV modules, evidence from this study concludes it is not practical to TCLP test every PV module even in a single utility-scale installation, and a scalable solution is needed. This study finds that knowledge-based hazardous waste determinations may allow a regulated person/entity to make a hazardous waste determination for more than one PV module at one time - making this regulatory pathway a potential scalable solution. Through legal analysis and interviews with 44 experts, the authors explore what it means to make an accurate knowledge-based hazardous determination for PV modules considering sources and forms of information as well as potential limitations. The work aims to provide a foundation for building consensus on whether knowledge-based hazardous determinations are a viable, scalable industry approach for solar.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗