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At least 199 records · Page 11

Annual Summary Report (FY 2025) Performance Assessment for the Integrated Disposal Facility

The purpose of this Annual Summary Report (ASR) for fiscal year (FY) 2025 is to evaluate the continued adequacy of the Integrated Disposal Facility (IDF) Performance Assessment (PA) and Disposal Authorization Statement (DAS). This report consolidates relevant monitoring data, modeling analyses, and regulatory reviews to demonstrate a reasonable expectation that the PA objectives and performance measures will be met, as required under DOE O 435.1, Radioactive Waste Management. The ASR follows the guidance in DOE-STD-5002-2017, Disposal Authorization Statement and Tank Closure Documentation, which provides a framework for maintaining the validity of the DAS through periodic assessment of facility performance and compliance with waste disposal requirements.

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Carbon Storage Technical Viability Approach and National Data Assessment

Carbon Storage Technical Viability Approach is a comprehensive evaluation of potential geologic carbon storage sites that includes classic subsurface resource assessment components such as reservoir suitability in addition to hazard, environmental, social, regulatory, and jurisdiction components that may enhance or hinder successful carbon storage. Data for assessments of technically viable carbon storage span many categories, types; are disparate and numerous. Variables and types of data required to support CS assessments were previously not clearly defined and documented. Contextualizing available data indicates their utility, potential uncertainty, and gaps. This presentation details the Carbon Storage Technical Viability Approach, the associated matrix and database, and initial results from a portion of the national data availability assessment that contextualizes the data available to support carbon storage projects. Presented at the American Association of Petroleum Geologists' Carbon Capture Utilization and Storage (SPE-AAPG-SEG CCUS 2024) conference in Houston, TX, March 11-13, 2024.

Mark-Moser, Mackenzie K.↗

Molten Salt Reactor Fundamental Safety Function PIRT

The phenomenon identification and ranking table (PIRT) process was employed to evaluate the current capability to assess the ability of liquid-salt–fueled molten salt reactors to achieve their fundamental safety functions (FSFs). The PIRT process provides a structured mechanism to elicit and document expert opinions on the most important phenomena and the corresponding level of knowledge with regard to achieving the FSFs. The PIRT panel included reactor developers, accident progression evaluation tool developers, US Department of Energy (DOE) national laboratory technical staff, university researchers, and US Nuclear Regulatory Commission (NRC) staff. The information-gathering process concentrated on phenomena related to accidents in which the fuel salt—including any in the cover gas—has been released from the first barrier layer. This information-gathering process included identifying all potential accidents that could result in the release of a substantial amount of radionuclides that could breach or bypass the first barrier. The PIRT did not identify any previously unrecognized systemic vulnerabilities. However, the elicitation process identified several areas with low levels of knowledge and significant potential impact on accident progression. These areas either require additional research to improve the state of knowledge or additional design conservatism to accommodate the remaining unknowns.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Enhanced Component Performance Study: Emergency Diesel Generators 1998–2022

This report presents an enhanced performance evaluation of the emergency power system (EPS) and high-pressure core spray (HPCS) emergency diesel generators (EDGs) at U.S. commercial nuclear power plants. This report evaluates component performance over time using (1) Institute of Nuclear Power Operations (INPO) Industry Reporting and Information System (IRIS) data from 1998 through 2022 and (2) maintenance unavailability performance data from Mitigating Systems Performance Index (MSPI) Basis Document data from 2002 through 2022. The objective is to show estimates of current failure probabilities and rates related to EDGs, trend these data on an annual basis, determine if the current data are consistent with the probability distributions currently recommended for use in Nuclear Regulatory Commission (NRC) probabilistic risk assessments, show how the reliability data differ for different EDG manufacturers and for EDGs with different ratings; and summarize the subcomponents, causes, detection methods, and recovery associated with each EDG failure mode. The EDG failure modes considered are fail to start (FTS), fail to load and run (FTLR), and fail to run after one hour of operation (FTR>1H). Engineering analyses were performed with respect to time-period and failure mode without regard to the actual number of EDGs at each plant. The factors analyzed include subcomponent, failure cause, detection method, recovery, manufacturer, and EDG rating. The following increasing trends were identified for EDGs for the most recent 10-year period: (1) HPCS EDG FTS failure probability, (2) EPS and HPCS EDG frequency of start demands (demands per reactor year), and (3) EPS and HPCS EDG frequency of FTLR demands. The following decreasing trends were identified for EDGs for the most recent 10-year period: (1) EPS EDG FTS failure probability, (2) EPS EDG FTLR failure probability, (3) EPS EDG unavailability, and (4) EPS and HPCS EDG frequency of FTLR events (failures per reactor year).

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Enhanced Component Performance Study: Emergency Diesel Generators 1998-2024

This report presents an enhanced performance evaluation of the emergency power system (EPS) and high-pressure core spray (HPCS) emergency diesel generators (EDGs) at U.S. commercial nuclear power plants. This report evaluates component performance over time using (1) Institute of Nuclear Power Operations (INPO) Industry Reporting and Information System (IRIS) data from 1998 through 2024 and (2) maintenance unavailability performance data from Mitigating Systems Performance Index (MSPI) Basis Document data from 2002 through 2024. The objective is to show estimates of current failure probabilities and rates related to EDGs, trend these data on an annual basis, determine if the current data are consistent with the probability distributions currently recommended for use in Nuclear Regulatory Commission (NRC) probabilistic risk assessments, show how the reliability data differ for different EDG manufacturers and for EDGs with different ratings; and summarize the subcomponents, causes, detection methods, and recovery associated with each EDG failure mode. The EDG failure modes considered are fail to start (FTS), fail to load and run (FTLR), and fail to run after one hour of operation (FTR>1H). Engineering analyses were performed with respect to time-period and failure mode without regard to the actual number of EDGs at each plant. The factors analyzed include subcomponent, failure cause, detection method, recovery, manufacturer, and EDG rating. The following increasing trends were identified for EDGs for the most recent 10-year period: • EPS and HPCS EDG frequency of start demands (demands per reactor year) • EPS and HPCS EDG frequency of FTLR demands • EPS and HPCS EDG frequency of run>1H hours. The following decreasing trends were identified for EDGs for the most recent 10-year period: • EPS EDG FTR>1H failure rate • EPS EDG unreliability • EPS and HPCS EDG frequency of FTR>1H events (failures per reactor year).

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Test Report for the Regulatory Testing of the Welded Isotek-SFC-W-3 Special Form Capsule

Two prototypes the welded ISOTEK-SFC-W-3 special form capsules (SFCs) of the same design were evaluated to determine if the requirements of Title 49, Code of Federal Regulations (CFR), Part 173.469, Tests for Special Form Class 7 (Radioactive) Materials, were met. The results of the special form tests are documented in this test report. This report describes the special form testing activities performed on the two welded ISOTEK-SFC-W-3 capsules. The test units were designated as TU-1 and TU-2. TU-1 was subjected to leak testing, percussion testing, and impact testing. TU-1 was leak tested using the leak rate test specified in 49 CFR 173.469(a)(4)(i). The impact test on TU-1 was conducted according to the requirements in 49 CFR 173.469 (b)(1). The percussion test that was carried out on TU-1 was conducted in accordance with 49 CFR 173.469 (b)(2). TU-2 was subjected to a leak rate test as specified in 173.469(a)(4)(i) and a heat test as specified in 49 CFR 173.469(b)(4). Each test unit was leak tested before and after these respective tests. The leak rate tests performed were helium back-pressure tests and bubble tests, as specified in American National Standards Institute (ANSI) N14.5-2014. The measured leak rates were converted to standard condition leak rates as specified in American Society for Testing and Measurement (ASTM) E 493. The determined standardized leak rates obtained from the test and the calculations for all the test units met the requirements for special form certification. The testing was performed under the direction of the Oak Ridge National Laboratory (ORNL) Package Testing Program (PTP).

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Assessment of Survey Results from Advanced Reactor Industry Domain Experts on Nonlinear Soil-Structure Interaction Analysis Software Verification and Validation

The seismic load case has a significant impact on the design and cost of nuclear power plants. Given the need to substantially reduce cost, advanced reactor designers are looking to leverage numerical tools that enable seismic analysis of an integrated vessel/support/structure/soil system. Modern nonlinear analysis tools provide a solution, capturing dynamic coupling between components (including soil-structure interaction (SSI)) concurrent with nonlinear behavior in one or more parts of the system. Although these methods have a rich history of technical development and implementation, software quality assurance (SQA) following nuclear industry standards remains a significant burden for those wishing to adopt such methods for advanced reactor design and licensing. To reduce the SQA burden, this project will develop the guidance for SQA verification and validation (V&V) of coupled nonlinear SSI analysis tools, to include a test matrix of software features and test problems to support commercial grade dedication (CGD). The guidance is intended to be technology-neutral: supporting designers of all advanced reactors. To maximize the value of the project to reactor designers, the project team performed focused surveys of and interviews with advanced reactor designers. Additionally, the project surveyed members of the broader industry involved in reactor design and licensing. The aggregated industry feedback consists of written survey responses, live polling responses, focused interviews, and informal feedback provided after outreach presentations, collectively referred to as “survey results”. Herein, the survey results are reported, reviewed, and assessed to inform follow-on project activities. The survey results confirmed the familiarity of the industry with the coupled nonlinear SSI analysis. They also affirm the project need based upon the expressed intent to (1) incorporate nonlinear features and (2) pursue the coupled nonlinear SSI analysis to reduce seismic demands and construction costs. All reactor designers indicated their intent to incorporate two or more nonlinear features, and all reactor designer respondents opined that the coupled nonlinear SSI analysis would allow for the optimization of the reactor design and construction. However, the programmatic challenges, whether real or perceived, present a significant barrier to reactor designers. The barrier most commonly identified by the reactor designer population was regulatory risk, with 70% citing this as a reason not to pursue the approach. The perceived regulatory risk identified by the reactor designers underscores the importance of regulator engagement and dialogue in this project. Additionally, half of the reactor designers identified cost and lack of guidance as a deterrent. The survey results also provide insights to tailor specific aspects of the guidance document and test matrix. The project plans to prepare both a formal referenceable guidance document and a collaborative, web-based test matrix and problem set. The project will focus on more complete test problem definitions for the prioritized nonlinear features over shallower problem descriptions for a larger set of features. The nonlinearities prioritized as high based upon survey feedback include fluid-structure interaction and seismic isolation and energy dissipation devices. The nonlinearities prioritized as intermediate include nonlinear geomaterials, nonlinear concrete, nonlinear steel, and interface/contact nonlinearity. Deep embedment and the associated nonlinear phenomena are assigned the lowest priority based upon survey feedback.

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Waste Compliance and Tracking System (WCATS) Version 3 Requirements Document

This document describes the end-user requirements for the Waste Compliance and Tracking System (WCATS) project in accordance with the WCATS Software Quality Management Plan, EPC-WMP-WCATSPLAN-001. The WCATS application shall support the generation, characterization, processing, and shipment of LANL radioactive, hazardous, and industrial waste. Regulatory drivers include RCRA hazardous waste, DOT shipping, NNSA nuclear material control and accountability, DOE nuclear safety, TSDF permit, and transuranic waste certification requirements. The system will utilize a task-based architecture that supports the spectrum of treatment, storage, disposal, administrative, and characterization based unit operations necessary to manage waste from cradle to grave. The application design shall readily accommodate new facilities, processes, workflow, signature requirements, and so forth, via end-user established metadata. WCATS will provide support for representing waste storage and disposal facilities, buildings, rooms, and grid layouts (x, y, z) to support waste and radioactive material inventory management. Nuclear material at risk (MAR), DOE hazard rating (e.g., Category II facility) compliance per DOE-STD-1027, and permit inventory requirements will be configurable for any storage or disposal facility, or waste operation, and the system will automatically evaluate and enforce those requirements. In addition, the application will support the characterization and management of the entire range of hazardous and radioactive wastes (TRU, MTRU, LLW, MLLW, hazardous waste, etc.) that might be colocated or processed at a permitted facility. Some capabilities not found in traditional systems include user-defined tank systems for liquid waste, user-defined work paths (i.e., sequence of operations), and an equipment subsystem for tracking the calibration, maintenance, and inspection of tools used to process waste, such as torque wrenches, scales, pH probes, etc. The application incorporates a desktop and mobile user interface as shown in Figure 1. The mobile interface supports field operations, such as waste item characterization, intra-facility transfers, internal and external audits, and shipment preparation and receipt.

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IMITATION SWITCH is required for normal chromatin structure and gene repression in PRC2 target domains

Significance Polycomb Repressive Complex 2 (PRC2) methylates histones to regulate multicellular development, maintenance of stem cell identity, X-chromosome inactivation, and other important processes. Given these essential roles, there is significant interest in identifying components that function with PRC2 to establish and maintain transcriptionally repressive heterochromatin. Here we document an unexpected new role for a well-studied and conserved chromatin remodeling factor, ISWI. We found that the Neurospora ISWI homolog is required for normal facultative heterochromatin structure and gene repression at PRC2 target regions, and we defined requirements for ATP-dependent catalytic activity and accessory regulatory proteins. These findings provide mechanistic insights into the formation and function of facultative heterochromatin in a model eukaryote.

Kamei, Masayuki↗

Advancing Electric System Resilience with Distributed Energy Resources: Key Questions and Resources

This resource has two complementary parts: (1) A list of questions that offers an initial starting point for state public utility commissions (commissions) to frame how they review proposed utility investments and considerations that could offer resilience benefits; (2) A list of relevant resources to improve a regulator's ability to oversee resilience investments and obtain the best possible solutions for customers. The list of resources includes a synopsis of relevant topics covered in each resource. This document is not intended to offer a complete picture of resilience literature, but instead suggests strategies for state regulators to convene conversations and make decisions to achieve better resilience outcomes for customers. It is meant to serve as a starting point for commissions to understand and incorporate resilience into regulatory processes. The list of questions and resources will not be perfectly suited to the particular needs of each commission. As the resilience conversation advances, regulators will need to take advantage of available resources to build their capacity to assess resilience risks, compare investment options, and evaluate performance.

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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.

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Defense Energy Resilience Engagement Framework for Utility Regulators

The purpose of this document is to provide public utility commissions with a framework to facilitate engagement with in-state military stakeholders and support consideration of defense-related utility applications. The framework also includes questions that would benefit the U.S. Department of Defense’s (DoD) stakeholders as they prepare for future engagements and regulatory proceedings with commissions and utilities.

24 POWER TRANSMISSION AND DISTRIBUTION↗

MatLib-1.2: Nuclear Material Properties Library

The U.S. Nuclear Regulatory Commission (NRC) uses the computer code Fuel Analysis under Steady-state and Transients (FAST) to model steady-state and transient fuel behavior to support regulatory decisions. FAST relies on a material properties library (MatLib) that contains the thermal and mechanical properties of the nuclear materials and coolants of interest to support the US commercial nuclear industry. MatLib contains properties for a variety of nuclear fuels, cladding and other structural materials, gases, and coolants. In this document, material property correlations for the materials contained within MatLib are presented and discussed. When available, comparisons are made between the material property correlations and available data. Additionally, uncertainties are quantified on the material proper- ties, which is then used by the NRC to support uncertainty quantification for best-estimate plus uncertainty safety evaluation reviews. This document describes MatLib-1.2, which was updated from MatLib-1.1 to include cleanup of the code for streamlined calls to MatLib from the main FAST source code, and to enable easier readability of the code by developers that maintain and enhance the FAST code. The results of MatLib did not change between MatLib-1.1 and MatLib-1.2; however, the source code changes warranted incrementing the minor numbering of the software version number. The changes may result in faster execution times of FAST-1.2 as compared to FAST-1.1. This document is one of a series of documents on FAST; the other documents detail the models used by FAST as well as its integral assessment to experiments and commercial data.

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MatLib-1.0: Nuclear Material Properties Library

The U.S. Nuclear Regulatory Commission (NRC) uses the computer code Fuel Analysis under Steady-state and Transients (FAST) to model steady-state and transient fuel behavior to support regulatory decisions. FAST relies on a material properties library (MatLib) that contains the thermal and mechanical properties of the nuclear materials and coolants of interest to support the US commercial nuclear industry. MatLib contains properties for a variety of nuclear fuels, cladding and other structural materials, gases, and coolants. In this document, material property correlations for the materials contained within MatLib are presented and discussed. When available, comparisons are made between the material property correlations and available data. Additionally, uncertainties are quantified on the material properties, which is then used by the NRC to support uncertainty quantification for best-estimate plus uncertainty safety evaluation reviews. This document describes MatLib-1.0, which is the first official version of the MatLib library. This document is one of a series of documents on FAST; the other documents detail the models used by FAST as well as its integral assessment to experiments and commercial data.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

MatLib-1.1: Nuclear Material Properties Library: Developed under NQA-1-2017

The U.S. Nuclear Regulatory Commission (NRC) uses the computer code Fuel Analysis under Steady-state and Transients (FAST) to model steady-state and transient fuel behavior to support regulatory decisions. FAST relies on a material properties library (MatLib) that contains the thermal and mechanical properties of the nuclear materials and coolants of interest to support the US commercial nuclear industry. MatLib contains properties for a variety of nuclear fuels, cladding and other structural materials, gases, and coolants. In this document, material property correlations for the materials contained within MatLib are presented and discussed. When available, comparisons are made between the material property correlations and available data. Additionally, uncertainties are quantified on the material properties, which is then used by the NRC to support uncertainty quantification for best-estimate plus uncertainty safety evaluation reviews. This document describes MatLib-1.1, which was updated from MatLib-1.0 to include the addition of Lua functionality and code changes for integration with FAST. The results of MatLib did not change between MatLib-1.0 and MatLib-1.1; however, the source code changes warranted incrementing the minor numbering of the software version number. This document is one of a series of documents on FAST; the other documents detail the models used by FAST as well as its integral assessment to experiments and commercial data.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Dataset for report: Non-Technical Barriers to Geothermal Development in California and Nevada

In California and Nevada, geothermal projects are subject to non-technical barriers, which may create development delays leading to higher project costs and risks and decreased competitiveness with other electricity generation technologies. These non-technical barriers may include federal and state permits, authorizations, environmental reviews, and other regulatory requirements that are applicable throughout different phases of geothermal project development. The 2022 National Renewable Energy Laboratory (NREL) report, "Non-Technical Barriers to Geothermal Development in California and Nevada" presents findings of a study on non-technical barriers that may influence geothermal project development. The set of data resources relied upon for the report includes: 1) interviews conducted with relevant geothermal stakeholders including regulators and project developers, 2) federal and state environmental review documents developed for specific projects, 3) a techno-economic analysis conducted using the NREL Annual Technology Baseline (ATB) framework, and 4) an analysis of the impacts of site-specific land access and permitting considerations on project development readiness conducted using the Geothermal Resource Portfolio Optimization and Reporting Technique (GeoRePORT) Socioeconomic Assessment Tool (SEAT).

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Pivotal trial characteristics and types of endpoints used to support Food and Drug Administration rare disease drug approvals between 2013 and 2022

Background/aims Rare disease drug development faces unique challenges, such as genotypic and phenotypic heterogeneity within small patient populations and a lack of established outcome measures for conditions without previously successful drug development programs. These challenges complicate the process of selecting the appropriate trial endpoints and conducting clinical trials in rare diseases. In this descriptive study, we examined novel drug approvals for non-oncologic rare diseases by the U.S. Food and Drug Administration’s Center for Drug Evaluation and Research over the past decade and characterized key regulatory and trial design elements with a focus on the primary efficacy endpoint utilized as the basis of approval. Methods Using the Food and Drug Administration’s Data Analysis Search Host database, we identified novel new drug applications and biologics license applications with orphan drug designation that were approved between 2013 and 2022 for non-oncologic indications. From Food and Drug Administration review documents and other external databases, we examined characteristics of pivotal trials for the included drugs, such as therapeutic area, trial design, and type of primary efficacy endpoints. Differences in trial design elements associated with primary efficacy endpoint type were assessed such as randomization and blinding. Then, we summarized the primary efficacy endpoint types utilized in pivotal trials by therapeutic area, approval pathway, and whether the disease etiology is well defined. Results One hundred and seven drugs that met our inclusion criteria were approved between 2013 and 2022. Assessment of the 107 drug development programs identified 150 pivotal trials that were subsequently analyzed. The pivotal trials were mostly randomized (80%) and blinded (69.3%). Biomarkers (41.1%) and clinical outcomes (42.1%) were commonly utilized as primary efficacy endpoints. Analysis of the use of clinical trial design elements across trials that utilized biomarkers, clinical outcomes, or composite endpoints did not reveal statistically significant differences. The choice of primary efficacy endpoint varied by the drug’s therapeutic area, approval pathway, and whether the indicated disease etiology was well defined. For example, biomarkers were commonly selected as primary efficacy endpoints in hematology drug approvals (70.6%), whereas clinical outcomes were commonly selected in neurology drug approvals (69.6%). Further, if the disease etiology was well defined, biomarkers were more commonly used as primary efficacy endpoints in pivotal trials (44.7%) than if the disease etiology was not well defined (27.3%). Discussion In the past 10 years, numerous novel drugs have been approved to treat non-oncologic rare diseases in various therapeutic areas. To demonstrate their efficacy for regulatory approval, biomarkers and clinical outcomes were commonly utilized as primary efficacy endpoints. Biomarkers were not only frequently used as surrogate efficacy endpoints in accelerated approvals, but also in traditionally approved rare disease drugs. The choice of primary efficacy endpoints varied by therapeutic area, approval pathway, and understanding of disease etiology.

Hong, Kyungwan [Rare Diseases Team, Office of New ↗

Guidance for Monitoring Passive Groundwater Remedies Over Extended Time Scales

Passive remediation can be appropriate where natural processes and actions such as institutional controls mitigate exposure to contaminated groundwater, achieving remedial action objectives and protectiveness of human health and the environment. Monitored natural attenuation (MNA) is a prevalent passive remediation strategy supported by a regulatory framework and monitoring design guidance. However, long-term passive remedies are usually selected in combination with at least one active remedy, such as source removal, in situ treatment, or pump-and-treat, functioning as a complementary method for achieving remediation objectives and meeting the applicable statutory and regulatory requirements. However, MNA and existing monitoring guidance primarily target situations where the remedial action objectives are met within a few decades. When time scales for passive remediation extend to many decades (50 years or more), a corresponding change in monitoring strategy is needed to adapt to the extended time scale. This document provides guidance for implementing an extended-scale monitoring (ESM) approach appropriate for long-duration passive remediation. Extended-scale is defined in this document with respect to time (i.e., a long duration of remediation) and a large enough physical scale such that downstream receptors will not be impacted within the remediation timeframe. ESM applies to slow-moving groundwater contaminant plumes and emphasizes monitoring primarily for potential exposure pathways. For this approach, the primary monitoring objective is to demonstrate that the plume diminishes before reaching the receptor zone or point of compliance and/or a receptor does not receive concentrations above the compliance limit. While the overall objectives of protecting human health and the environment are the same as for plumes where remediation can occur over a shorter time period, the time scales between decisions are longer and the dynamics of plume evolution are slower. To this end, a scenario-based strategy is described for different plume and source conditions, defining a containment and receptor zones. The containment zone is the area where the risk of exposure to groundwater contamination can be mitigated (e.g., through institutional controls) during the remediation time period. The receptor zone is defined as the area where exposure to groundwater contamination cannot be mitigated and compliance concentration standards must be met. Within the containment zone, slow plume migration may occur, leading to concentrations that exceed compliance standards. However, where distance to the receptor zone is large relative to plume migration and attenuation rate, this approach can be protective of the receptor zone. Selection of a long-duration passive remedy needs to be based on sufficient understanding of contaminant sources, hydrogeology, and contaminant plumes. A strong technical basis, supported by predictive analysis, is recommended to substantiate that contamination is expected to stay within the containment zone during the active remediation and attainment phase of the remedy, and diminish to meet compliance standards within the extended timeframe prior to reaching the receptor zone (e.g., many decades or even centuries). The ESM approach is based on verification of plume behavior and not on detailed plume dynamics. Monitoring is conducted to confirm expected behavior with an emphasis on exposure pathways to verify that plumes remain contained in areas where the protectiveness objectives can be met. ESM should not be adopted if there is significant risk of the plume extending beyond the containment zone. Given the slow movement within the containment zone, less frequent sampling is required relative to approaches used for conventional-scale remediation.

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