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Energy Management Information Systems Technical Resources Report

Guide supports federal facility staff in understanding, designing, procuring, and implementing Energy Management Information Systems (EMIS) as a valuable component of their portfolio-level energy and water planning and management strategies. As a broad and rapidly evolving family of tools that monitor, analyze, and control building energy use and system performance, EMIS tools present significant opportunities for federal sector energy savings and improved operational performance. EMIS are at the forefront of transforming energy management best practices by providing building owners and operators with well-organized building performance and energy consumption data, enabling a host of analytic capabilities. These capabilities include portfolio-wide energy benchmarking, data visualization, and key performance indicator tracking; automated fault detection and diagnostics (AFDD); artificial intelligence for predictive analytics and control; automated measurement and verification of energy conservation measures; and supervisory control enabling automated system optimization and demand management.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

ARM Aerial Instrument Workshop Report

The mission of the U.S. Department of Energy’s (DOE) Biological and Environmental Research (BER) program is to “support transformative science and scientific user facilities to achieve a predictive understanding of complex biological, earth, and environmental systems for energy and infrastructure security, independence, and prosperity.” (https://science.osti.gov/ber) Aligned with the BER central mission, the Earth and Environmental Systems Sciences Division (EESSD) plays a vital role in supporting the fundamental research to understand and predict Earth’s climate and environmental systems, and is also in a unique position to inform the development of sustainable solutions to the nation’s energy and environmental challenges. Specifically, EESSD manages two scientific user facilities: the Atmospheric Radiation Measurement (ARM) user facility and the Environmental Molecular Sciences Laboratory (EMSL). These facilities provide the broader scientific community with scientific expertise, technical capabilities, and unique data sets to facilitate science in areas of importance to DOE. As a multi-platform scientific user facility, ARM aims to fulfill the needs predominantly within the EESSD Atmospheric System Research (ASR) and the Earth and Environmental System Modeling (EESM) mission areas, and provide the critical measurements required to improve understanding of aerosol and cloud life cycles and their interactions, and their coupling with the Earth’s surface. Over the years, ARM has carried out piloted and unmanned aircraft campaigns under different organizational and operational paradigms (Schmid et al. 2014, 2016). Building on its success, the ARM Aerial Facility (AAF) continues to complement the ground-based observations with airborne in situ cloud, aerosol, and trace gas observations as well as measurements of atmospheric state and atmospheric radiation. During the past three years, ARM has managed field campaigns using unmanned aerial systems (UAS) and tethered balloon systems (TBS) at Oliktok Point in Alaska to improve understanding of atmospheric processes in the Arctic. In 2019, following a careful evaluation of scientific community needs, ARM acquired a Bombardier Challenger 850 regional jet to replace the vintage Grumman Gulfstream-159 turboprop aircraft previously used by AAF. With this new “laboratory in the sky”, AAF is evaluating its current and future aerial observation capabilities to continue satisfying the needs of the research community.

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Nuclear Deactivation and Downgrade of Enriched Uranium Facilities at the Y-12 National Security Complex

Buildings 9206 and 9212 at the Y-12 National Security Complex are both Hazard Category 2 nuclear facilities from the Manhattan Project era that supported various missions over the decades, including the processing of enriched uranium. The production mission for Building 9206 ended in the 1990s, while Building 9212 is still an active production facility. The disposition process for contaminated excess facilities is generally described in the U.S. Department of Energy (DOE) Guide DOE O 430.1A, Life Cycle Asset Management, which provides guidance on facility surveillance and maintenance, deactivation, decommissioning, and transition in supplemental guides DOE G 430.1-2 through 430.1-5. Historically, production facilities similar to Buildings 9206 and 9212 have not always been cleaned out and deactivated prior to being excessed, which significantly complicates the decommissioning phase. Many legacy facilities were shut down before the formal DOE guidance was established. This paper presents the practical application and implementation of the DOE guidance for the nuclear deactivation of Buildings 9206 and 9212, and summarizes the lessons learned for application across the DOE enterprise.

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Nuclear Deactivation and Downgrade of Enriched Uranium Facilities at the Y-12 National Security Complex

Buildings 9206 and 9212 at the Y-12 National Security Complex are both Hazard Category 2 nuclear facilities from the Manhattan Project era that supported various missions over the decades, including the processing of enriched uranium. The production mission for Building 9206 ended in the 1990s, while Building 9212 is still an active production facility. The disposition process for contaminated excess facilities is generally described in the U.S. Department of Energy (DOE) Guide DOE O 430.1A, Life Cycle Asset Management, which provides guidance on facility surveillance and maintenance, deactivation, decommissioning, and transition in supplemental guides DOE G 430.1-2 through 430.1-5. Historically, production facilities similar to Buildings 9206 and 9212 have not always been cleaned out and deactivated prior to being excessed, which significantly complicates the decommissioning phase. Many legacy facilities were shut down before the formal DOE guidance was established. This paper presents the practical application and implementation of the DOE guidance for the nuclear deactivation of Buildings 9206 and 9212, and summarizes the lessons learned for application across the DOE enterprise.

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Artificial Intelligence in Nuclear Safeguards; Evaluating Safeguards and Security Risks and Benefits for Advanced and Small Modular Reactor Deployments

Rapidly growing interest in advanced and small modular reactor (A/SMR) technologies presents challenges as well as opportunities for implementing international safeguards and security. A/SMR deployments are expected to be more numerous, more geographically dispersed, and more varied in their designs, placing new demands on the data systems and analytical tools used to support oversight (Alberti et al., 2023; Canadian Nuclear Safety Commission et al., 2024). Because of this variability, the importance and reliance on data systems for A/SMR deployments is expected to be higher than for previous reactor generations. Artificial Intelligence and Machine Learning (AI/ML) offer potential capabilities to address the high variability inherent in A/SMR technology. The beneficiaries of AI-assisted tools include facility operators, government regulators, IAEA inspectors, and A/SMR vendors. This report analyzes how AI/ML-assisted technologies can strengthen the implementation of IAEA safeguards and security measures. It also identifies AI-assisted tools to strengthen operator, facility, and regulator knowledge management practices and examines the potential risks AI/ML-based tools may introduce to IAEA safeguards and security efforts. It concludes with a set of hypothetical, standards-style requirements for AI/ML systems used in safeguards contexts, grounded in an inspector-centric view of system verification. Despite the potential benefits of AI/ML systems, understanding potential intentional and unintentional failure modes is critical for ensuring adequate protection of nuclear materials and facilities. Unique features of A/SMRs including sealed cores, remote and novel paradigms of operation, off-site reactor fabrication, novel fuel forms, and varied refueling requirements, introduce challenges for traditional safeguards technological approaches (Pensado et al., 2024; Federation of American Scientists, 2025). AI/ML systems deployed to address these challenges may introduce new risks requiring systematic evaluation rooted in both AI-specific risk frameworks, such as the NIST AI Risk Management Framework (NIST AI RMF), and established cyber risk management standards such as NIST SP 800-30 (National Institute of Standards and Technology [NIST], 2023; NIST, 2012).

97 MATHEMATICS AND COMPUTING↗

National Ignition Facility. Facility and Infrastructure Systems Maintenance Plan

Ensuring the reliability of the NIF, including its support systems, laser systems, target diagnostic systems, and utilities, is essential to the availability of the NIF in its support of NNSA missions. NIF is a key capability in the DOE Stockpile Stewardship Program and supports high energy physics experiments for nuclear weapons, energy, and astrophysics applications. High system reliability provides opportunities for shots and scientific discoveries with opportunities to enhance and upgrade capabilities. This Maintenance Plan (MP) identifies the policies and procedures used to perform and support asset management of the NIF Facility and Infrastructure Systems (FInS), NIF Lasers & Alignment (LASE), NIF Target Experimental Operations (TOPS), NIF Target Area Science and Engineering (TASE), and NIF&PS Control Systems (NCS). The FInS systems include the facility, HVAC, contamination control, beampath, and Line Replaceable Units (LRUs) as well as utilities which create the beampath environments, such as vacuum, argon, or clean dry air. The LASE systems are Programmatic systems which include laser diagnostics, alignment, power conditioning, pulsed power, and input laser systems. The TOPS and TASE systems are also Programmatic systems which include target and diagnostic delivery systems and positioners, many different insertable and fixed target diagnostics, and cryogenic and target gas fill systems. Finally, the NCS systems include both software and hardware for industrial and shot operation control systems. Policies governing administrative and operational practices related to maintenance of FInS, LASE, TOPS, TASE, and NCS systems are described in this plan. In addition, the plan provides processes and procedures for managing, tracking, and documenting the work. This document, the NIF Operations Management Plan, NIF-5020544 (Ref. 1), and NIF Shot Operations Plan, NIF-5018506 (Ref. 2), together satisfy the requirements of the Conduct of Operations. Duties, responsibilities, and reporting requirements of the various positions associated with FInS, LASE, and TOPS maintenance are detailed in this plan. The FInS systems include both Real Property systems with asset management requirements specified in DOE Order 430.1C (Ref. 3) and Programmatic systems. In addition, for FInS, there is a list of the System Level Maintenance Plans (SLMPs) in NIF-1007419198 (Ref. 4) which provide the system descriptions and maintenance plan and schedule. In addition, the list includes the Reliability Centered Maintenance (RCM) and Experience Centered Maintenance (ECM) evaluations that have been performed for applicable FInS systems as well as reliability criticality per Section 3.5. The -AM version of the NIF Maintenance Plan focuses on the reliability program for FInS, LASE, TOPS, TASE, and NCS within the context of the overall NIF Reliability, Availability, and Maintainability (RAM) program and incorporates changes since the -AL version from August 2011 and has been updated to be fully consistent with the updates to Ref. 1. It also includes asset management considerations, updates to the Work Order (WO) process within the NIF Computerized Maintenance Management System (CMMS) which is EAM infor® System Maintenance and Reliability Tracking (SMaRT) (Ref. 5), and updates to metrics and key performance indicators (KPIs).

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Federal Facility Agreement and Consent Order Nevada National Security Site Use Restriction Management Plan

This Use Restriction Management Plan (URMP) provides the information needed to create, modify, and manage use restrictions (URs) for sites on the Nevada National Security Site (NNSS), and sites accessed through the NNSS main gate, that were closed using the corrective action alternative (CAA) of closure in place under the Federal Facility Agreement and Consent Order (FFACO) (1996, as amended).

54 ENVIRONMENTAL SCIENCES↗

E-Area Low-Level Waste Facility Multitiered Groundwater and Intruder Radionuclide Screening

Solid Waste Management (SWM) operates the E-Area Low-Level Waste Facility (ELLWF) where low level on-site and off-site solid waste streams are buried. The facility has been in operation since late 1994 and is currently projected to remain in operation until 2065. This facility can accommodate a broad range of waste forms resulting from the six different types of disposal unit (DU) options (i.e., varying degrees of engineered barriers → trenches to concrete vaults). This facility is currently operating under a Performance Assessment (PA) issued back in 2008 (WSRC 2008), along with several subsequent supporting Special Analyses (SAs). The Savannah River National Laboratory (SRNL) developed the prior PAs and SAs and was tasked to update the facility’s upcoming PA, most likely to be issued during FY2023. For operating the E-Area facility, a Consolidated Waste Tracking System (CWTS) is actively employed by waste generators where every radionuclide entering the facility, to be buried in one of its many DUs1, must be either directly or indirectly tracked. Since there are many radionuclides in existence (>3,000), the International Commission on Radiological Protection (ICRP), specially ICRP Publication 107, has provided guidance on the subset of radionuclides requiring further assessment in landfills such as the ELLWF. The ICRP 107 publication provides critical radiological information on 1,252 radionuclides consisting of 97 elements. This database, along with the current dose coefficients that have been developed for these radionuclides in DOE-STD-1196-2011 (DOE 2011), is the critical starting point for developing a consistent inventory limit system.

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Integrating the PanDA Workload Management System with the Vera C. Rubin Observatory

The Vera C. Rubin Observatory will produce an unprecedented astronomical data set for studies of the deep and dynamic universe. Its Legacy Survey of Space and Time (LSST) will image the entire southern sky every three to four days and produce tens of petabytes of raw image data and associated calibration data over the course of the experiment’s run. More than 20 terabytes of data must be stored every night, and annual campaigns to reprocess the entire dataset since the beginning of the survey will be conducted over ten years. The Production and Distributed Analysis (PanDA) system was evaluated by the Rubin Observatory Data Management team and selected to serve the Observatory’s needs due to its demonstrated scalability and flexibility over the years, for its Directed Acyclic Graph (DAG) support, its support for multi-site processing, and its highly scalable complex workflows via the intelligent Data Delivery Service (iDDS). PanDA is also being evaluated for prompt processing where data must be processed within 60 seconds after image capture. This paper will briefly describe the Rubin Data Management system and its Data Facilities (DFs). Finally, it will describe in depth the work performed in order to integrate the PanDA system with the Rubin Observatory to be able to run the Rubin Science Pipelines using PanDA.

79 ASTRONOMY AND ASTROPHYSICS↗

Federal Water Management Planning Manual

This Federal Water Management Resource Guide provides direction to Federal agencies on how optimize water use at Federal facilities, use water balance analysis methods, identify design elements and procurement best practices, and expand use of alternative water. It provides best practices for managing water to be considered when developing or improving an effective facility water management program. PNNL developed this guide for the Federal Energy Management Program (FEMP). FEMP was directed by the Council on Environmental Quality (CEQ) to develop a Federal Water Management Resource Guide per the Implementing Instructions for Executive Order (E.O.) 13834, Efficient Federal Operations. This document serves to satisfy this requirement in order to provide best water management practices within the Federal Government.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

Federal Water Management Planning Manual

This Federal Water Management Resource Guide provides direction to Federal agencies on how optimize water use at Federal facilities, use water balance analysis methods, identify design elements and procurement best practices, and expand use of alternative water. It provides best practices for managing water to be considered when developing or improving an effective facility water management program. PNNL developed this guide for the Federal Energy Management Program (FEMP). FEMP was directed by the Council on Environmental Quality (CEQ) to develop a Federal Water Management Resource Guide per the Implementing Instructions for Executive Order (E.O.) 13834, Efficient Federal Operations. This document serves to satisfy this requirement in order to provide best water management practices within the Federal Government.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

Federal Facility Agreement and Consent Order Nevada National Security Site Use Restriction Management Plan, Revision 2

This Use Restriction Management Plan (URMP) provides the information needed to create, modify, and manage use restrictions (URs) for sites on the Nevada National Security Site (NNSS), and sites accessed through the NNSS main gate, that were closed using the corrective action alternative (CAA) of closure in place under the Federal Facility Agreement and Consent Order (FFACO). It addresses URs established under the FFACO for releases related to the development, testing, and production of nuclear weapons that are located on the NNSS and that are accessed through the NNSS main gate. FFACO URs are established at sites where contamination remains at levels exceeding final action levels (FALs) or is forecasted to exceed Safe Drinking Water Act (SDWA) maximum contaminant levels (CFR, 2025a) over the next 1,000 years following completion of corrective actions. Administrative URs are established at Industrial Sites and Soils sites where contamination remains at levels exceeding industrial action levels as defined in the Soils RBCA document. All URs stipulate restrictions sufficient to ensure the protection of human health, safety, and the environment.

54 ENVIRONMENTAL SCIENCES↗

National and regional waste stream in the United States: conformance and disparity

Accurate estimation of municipal solid waste (MSW) composition is critical for efficient waste management. In the United States, site-specific and material flow approaches determine the MSW composition at regional and national levels. The material flow-based national estimates are determined by the US EPA; the US EPA’s estimates are known to differ substantially from the aggregated tonnage of MSW managed by waste handling facilities in the United States. However, the material class-specific discrepancies of the US EPA’s material flow approach resulting in these differences are unknown. To find the basis of these discrepancies, we analyze the discarded MSW stream of 27 US states, which roughly accounts for 73 percent of the US population. Our analysis indicates that the material flow-based national estimates are accurate for the food, plastic, and glass material classes. In contrast, we find that the US EPA’s material flow-based predictions underestimate paper waste disposal by at least 15 million tons annually. These differences likely stem from incorrect assumptions of residence time. These results highlight the material class-specific strengths and drawbacks of the US EPA’s material flow-based MSW estimates.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Vadose Zone Model for B-3A/B Pond for Composite Analysis

The objectives of the vadose modeling for the updated Hanford Site composite analysis (CA) are to simulate the flow and transport of water and radionuclide releases from the surface to the water table and to provide radionuclide transfer rates for the plateau to river (P2R) model, version 8.3 (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). Water additions include natural recharge and water discharged to the ground as a result of industrial processes associated with Hanford Site operations. Contaminant sources include radionuclides in water discharged to the ground during operations and radionuclides disposed “dry” in solid waste burial grounds or other means. The following 16 radionuclides were selected for this modeling effort; carbon-14 (C-14), chlorine-36 (Cl-36), tritium (H-3), iodine-129 (I-129), neptunium-237 (Np-237), rhenium-187 (Re-187), strontium-90 (Sr-90), technetium-99 (Tc-99), uranium-232 (U-232), uranium-233 (U-233), uranium-234 (U-234), uranium-235 (U-235), uranium-236 (U-236), uranium-238 (U-238), radium-226 (Ra-226), and thorium-230 (Th-230). The simulation time starts in 1943 and ends at 12070, which is 10,000 years after assumed Hanford Site closure in 2070. The parallel version of the Subsurface Transport Over Multiple Phases (STOMP) simulator officially named the exascale Subsurface Transport Over Multiple Phases (eSTOMP), is used to simulate flow and transport for the vadose models. The documentation for the STOMP code is comprehensive. The theoretical and numerical approaches applied in the STOMP code are documented in a published theory guide (PNNL-12030, STOMP Subsurface Transport Over Multiple Phases Version 2.0 Theory Guide). The code has undergone a rigorous verification procedure against analytical solutions, laboratory-scale experiments, and field-scale demonstrations. The application guide (PNNL-11216, STOMP Subsurface Transport Over Multiple Phases Application Guide) provides instructive examples in the application of the code to classical groundwater problems. The user’s guide (PNNL-15782, STOMP: Subsurface Transport Over Multiple Phases Version 4.0: User’s Guide) describes the general use, input file formatting, compilation, and execution of the code. The primary output of the vadose zone modeling is radionuclide transfer rates to the groundwater for input into the P2R model. The rates will be summed over the 100 by 100 m P2R grid cells that fall within the vadose zone model source domain. The Hanford Site Central Plateau was subdivided into 26 individual vadose zone models, with 13 in the 200 East Area and 13 in the 200 West Area. Waste sites that have a completed performance assessment (PA) or past-leak analysis were not included as sources of radionuclides. Instead the vadose zone to groundwater transfer rates of the Environmental Restoration Disposal Facility, Integrated Disposal Facility, US Ecology, and Waste Management Area C (WMA C) PAs and the past-leak analysis for WMA C were used as direct input to the P2R model. Each of the vadose zone models is documented in separate environmental calculation files (ECFs). This ECF describes the B-3A/B Ponds model. The scope of this ECF is to document the development and results of the B-3 A/B Ponds vadose zone model. CP-63515, Model Package Report: Central Plateau Vadose Zone Models, describes the approach, assumptions, process of determining the number of models required and domain of each model, input data, and processing common to all the models.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Vadose Zone Model for SALDS for Composite Analysis

The objectives of the vadose modeling for the updated Hanford Site composite analysis (CA) are to simulate the flow and transport of water and radionuclide releases from the surface to the water table and to provide radionuclide transfer rates for the plateau to river (P2R) model, version 8.3 (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). Water additions include natural recharge and water discharged to the ground as a result of industrial processes associated with Hanford Site operations. Contaminant sources include radionuclides in water discharged to the ground during operations and radionuclides disposed “dry” in solid waste burial grounds or other means. The following 16 radionuclides were selected for this modeling effort: carbon-14 (C-14), chlorine-36 (Cl-36), tritium (H-3), iodine-129 (I-129), neptunium-237 (Np-237), rhenium-187 (Re-187), strontium-90 (Sr-90), technetium-99 (Tc-99), uranium-232 (U-232), uranium-233 (U-233), uranium-234 (U-234), uranium-235 (U-235), uranium-236 (U-236), uranium-238 (U-238), radium-226 (Ra-226), and thorium-230 (Th-230). The simulation time starts in 1943 and ends at 12070, which is 10,000 years after assumed Hanford Site closure in 2070. The parallel version of the Subsurface Transport Over Multiple Phases (STOMP1) simulator, officially named the exascale Subsurface Transport Over Multiple Phases (eSTOMP) is used to simulate flow and transport for the vadose models. The documentation for the STOMP code is comprehensive. The theoretical and numerical approaches applied in the STOMP code are documented in a published theory guide (PNNL-12030, STOMP Subsurface Transport Over Multiple Phases Version 2.0 Theory Guide). The code has undergone a rigorous verification procedure against analytical solutions, laboratory-scale experiments, and field-scale demonstrations. The application guide (PNNL-11216, STOMP Subsurface Transport Over Multiple Phases Application Guide) provides instructive examples in the application of the code to classical groundwater problems. The user’s guide (PNNL-15782, STOMP: Subsurface Transport Over Multiple Phases Version 4.0: User’s Guide) describes the general use, input file formatting, compilation, and execution of the code. The primary output of the vadose zone modeling is radionuclide transfer rates to the groundwater for input into the P2R model. The rates will be summed over the 100 by 100 m P2R grid cells that fall within the vadose zone model source domain. The Hanford Site Central Plateau was subdivided into 26 individual vadose zone models, with 13 in the 200 East Area and 13 in the 200 West Area. Waste sites that have a completed performance assessment (PA) or past-leak analysis were not included as sources of radionuclides. Instead the vadose zone to groundwater transfer rates of the Environmental Restoration Disposal Facility, Integrated Disposal Facility, US Ecology, and Waste Management Area C (WMA C) PAs and the past-leak analysis for WMA C were used as direct input to the P2R model. Each of the vadose zone models is documented in separate environmental calculation files (ECFs). This ECF describes the State-Approved Land Disposal Site (SALDS) model. The scope of this ECF is to document the development and results of the SALDS vadose zone model. CP-63515, Model Package Report: Central Plateau Vadose Zone Models, describes the approach, assumptions, process of determining the number of models required and domain of each model, input data, and processing common to all the models.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

LLNS Request for Permanent Variance from 10 CFR 851 for Construction

Lawrence Livermore National Security, LLC (LLNS) requests variance from 10 CFR 851 (the Rule) for construction work at Lawrence Livermore National Laboratory (LLNL). The request is based upon successful application of similar variances granted to LLNS in continued support of the National Nuclear Security Administration (NNSA) initiative to streamline the delivery of line-item construction projects under $50 million. This request is aligned with the approved NA 50 safety approach. Experience gained in the construction of the new LLNL Emergency Operations Center (EOC) under the variance granted in June 2020 and construction preparations to date on the Digital Infrastructure Capabilities Expansion (DICE) under the variance granted April 2022 is very encouraging. There are strong indicators that a benefit has been realized by both the subcontractors executing the work and the Laboratory. The variance has permitted local/regional construction businesses contracted to Management & Operation Contractor operated facilities and lower tier subcontractors to bid, operate, execute, and comply with safety and health standards they utilize in their business outside of the Department of Energy (DOE) Complex. While compliance to standards that are as safe and healthful as those in 10 CFR 851: confusion, additional cost, and inefficiencies associated with the burden of compliance to an unfamiliar regulatory spectrum has been avoided. Safety and health performance on the construction project including the number of inspection and surveillance issues is comparable to other subcontractors and projects at LLNL executed under 10 CFR 851. This variance application was prepared according to the requirements in 10 CFR 851, Subpart D – Variances, § 851.31 Variance Process. This request is limited to subcontractor executed construction at LLNL.

42 ENGINEERING↗

Documentation of Air Emissions Source Term for Radionuclide NESHAP Compliance: TA-53 Building 0984 Isotope Production Facility

This paper will document the air emissions source term for the TA-53 Building 0984 Isotope Production Facility (IPF). The facility has historically been managed as a minor source under Radionuclide NESHAP regulations, but began using a wider variety of irradiation targets and a higher beam current. To support expanded generation of actinium-225 for medical diagnostic and therapeutic uses, IPF is now irradiating thorium targets and the beam current is planned to increase from 250 microamperes up to 600 microamperes. These changes merit a review of the anticipated source term under the new proposed operational conditions. The end result of the review indicates the main stack (Exhaust Stack ES-1) needs to be managed as a major source with continuous emissions monitoring. No additional advance notifications or permitting is required as a result of these operational changes.

54 ENVIRONMENTAL SCIENCES↗