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Post-closure Nuclear Criticality Safety Evaluations for Disposition of Criticality Control Overpacks at the Waste Isolation Pilot Plant

The Waste Isolation Pilot Plant (WIPP) is a geological repository in southern New Mexico that provides for disposal of transuranic (TRU) wastes from atomic energy defense activities. The Sandia National Laboratories (Sandia) Report, Consideration of Nuclear Criticality When Disposing of Transuranic Waste at the Waste Isolation Pilot Plant, addresses nuclear criticality safety based on the projected inventory characteristics for the initial compliance certification application of WIPP in 1996. As the inventory, waste forms, and disposal package designs change, revised or new analyses are necessary to demonstrate acceptability for these configurations within the WIPP safety basis and compliance with 10,000-year post-closure standards of the US Environmental Protection Agency (EPA). Saylor and Scaglione evaluated criticality control overpacks (CCOs) in 2017 based on conservative assumptions for post-closure repository structural conditions with resulting effects on containers and container spacing, The Saylor and Scaglione evaluation of CCOs addressed a single waste configuration that represents the Surplus Plutonium Disposition Program’s dilute and dispose waste form and composition. This initial CCO study demonstrated that 50 grams of boron carbide (B 4 C) per CCO is sufficient to ensure post-closure criticality safety based on a well-mixed waste composition, and Oak Ridge National Laboratory (ORNL) subsequently determined that this amount of B 4 C does not require constraints on moisture or plastic present as moderator. The Saylor and Scaglione analysis conservatively assumes repository room closure that eliminates all space between fissile gram equivalent (FGE) 239 Pu masses. The close-packed array was selected based on limited availability of repository salt creep modeling results at that time. In 2019, Brickner provided additional evaluations for pipe overpack containers (POCs), building on the conservative basis provided by Saylor and Scaglione. Brickner’s 2019 analysis made use of new geomechanical data for post-closure spacing that rely on advances in repository modeling as documented in the work by Reedlunn and Bean. This current CCO evaluation for generic waste materials expands on earlier work performed at ORNL and includes evaluation of CCOs across a much broader range of possible waste compositions and geometries. This evaluation is intended to provide input for the required feature, event and process (FEP) screening to determine if post-closure criticality must be included as an event in the 10,000-year regulatory evaluation. As such, the approach to modeling post-closure criticality presented in this report has been coordinated with the Sandia team responsible for FEP screening. The resulting analysis supports disposition of fissile materials in the CCO containing up to 380 FGE 239 Pu and expands conditions acceptable for disposal of fissile material in CCOs. This evaluation builds on the methodology of Saylor and Scaglione and Brickner, using the most recently available geomechanical data for CCO spacing under salt creep compaction scenarios provided by Reedlunn and Bean. The broad range of fissile material configurations analyzed in this report are intended to account for configurations that may occur during the post-closure disposal time period, and it also includes waste configurations that are not physically possible to support analysis of conditions that influence neutron fluence.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Assessment of Potential Dose and Environmental Impacts from Proposed Testing at the INL National Security Test Range

This assessment uses screening level models to calculate potential environmental impacts from proposed tests at two locations at the Idaho National Laboratory (INL) National Security Test Range (NSTR) site. Proposed tests could be conducted using 11 different radioactive material types that include K 2 O, LaBr 3 , KBr, Cu, Zr, F, Ga, Ga 2 O 3 , NaNO 2 , Ga-68, and Tc-99m. The tests could potentially release radioactive material to the atmosphere and radionuclides and other contaminants to the soil, which could leach into the unsaturated zone and migrate to the aquifer. Atmospheric transport of radionuclides to potential human receptors and time-integrated air concentrations were calculated with a Gaussian plume model and three years of hourly meteorological data. Potential surface soil impacts were calculated with the computer program Mixing-Cell Model (MCM). Groundwater impacts were calculated with the computer programs MCM and GWSCREEN. Radiological doses from potential atmospheric releases were calculated for public receptors off the INL Site and for workers at nearby INL facilities. Results were compared to regulatory dose limits. Maximum potential groundwater concentrations were estimated in the aquifer below the NSTR site and compared to drinking water standards or risk-based screening levels for resident tap water. Soil concentrations were calculated and compared to risk-based screening levels for workers and potential future residents. All impacts were estimated based on the assumption that 12 tests are conducted annually using all 11 material types for 15 years. This document provides the resources to enable a subject matter expert in the field of environmental assessments to replicate the modeling and calculations. The methodology and parameters are presented in the text. All electronic files, including computer code input, output, executable files, batch files, scripts, and spreadsheet files, are contained in a zip file that can be accessed by selecting “Additional Information” (select Native File) in the INL Electronic Document Management System (EDMS).

99 GENERAL AND MISCELLANEOUS↗

Summary of GFL Inverter Capability and Performance: Malawi [Slides]

This presentation provides a comprehensive comparison of inverter-based resource (IBR) technical requirements across multiple international grid codes - including IEEE 2800, ESO, EirGrid, and Malawi's evolving regulatory framework - to support capacity building for electricity-sector institutions in Malawi. It highlights key performance expectations for grid-following (GFL) inverters across critical domains such as primary and fast frequency response, ramping behavior, frequency and voltage ride-through capabilities, reactive power and voltage control, ROCOF withstand, phase jump tolerance, system strength considerations, protection schemes, and dynamic modeling requirements. Emphasizing a "Do no harm, do something, do more" philosophy, the document synthesizes best practices and operational benchmarks to guide the integration and stability of inverter-based resources within Malawi's power system. The presentation forms part of the SABESS Center of Excellence initiative supported by the Global Energy Alliance for People and the Planet.

24 POWER TRANSMISSION AND DISTRIBUTION↗

The Relationship Between Dose Rate and Decay Heat for Spent Nuclear Fuel Casks

Decay heat and dose rate are two important limits used for determining the allowable contents of spent fuel (SNF) in dry storage systems and transportation packages. While the decay heat limit is used to maintain fuel cladding integrity and ensure retrievability, dose rates are used to demonstrate compliance with regulatory requirements on radiation protection. Because both dose rate and decay heat result from decay of radioisotopes in SNF, this study is an attempt to examine the relationship between dose rate and decay heat for a given cask design. Dose rates were evaluated for 198 cask configurations, that include various SNF system designs (e.g., storage, transfer, transport), SNF characteristics (e.g., fuel types, burnup, cooling time), and loading maps (e.g., uniform loading, zone loading), while a constant decay heat was maintained. The decay heat was calculated using US Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 3.54, Revision 2, and verified using ORIGEN sequence within SCALE code system. The ORIGEN outputs were used as source terms in the dose analysis using 198 different configurations. A computer script was developed to calculate the cooling time necessary to achieve a given decay heat for a given enrichment, assembly average burnup, assembly mass, and in-core history using a rootfinder algorithm. Initially the computer script was developed to provide cooling time and burnup calculations directly to the analysis of dose rates and decay heats, so a comparison between Used Nuclear Fuel-Storage Transportation and Disposal Analysis Resource Data System (UNF-ST&DARDS) results and RG3.54 data was made; results are included in the appendix to this document. However, an iterative approach was used to compute cooling time, and its accuracy did not depend on the results of the RG3.54r2 algorithm, although the algorithm was still used. The results of the evaluation presented herein clearly demonstrate that a given decay heat does not correspond to a unique dose rate for a variety of cask and package designs. There is no clear pattern to develop a correlation between decay heat and the source terms. Depending on burnup, enrichment, cask type, and loading pattern, dose rates varied for the exact same decay heat—in some cases by 400% for a given cask. For cases in which decay heat was held constant through selection of the appropriate cooling time, dose rates would decrease with increasing burnup, and in other cases, dose rates would increase. The large variation in dose rates for a constant decay heat indicates that casks loaded based on decay heat—that is allowing any burnup, cooling time, and enrichment combinations that yield the qualified decay heat limit(s) —cannot ensure that an Independent Spent Fuel Storage Installation or a spent fuel transportation package will meet the regulatory limits set forth by the respective regulations, i.e., 10 CFR 72 or 10 CFR 71.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Wabash CarbonSAFE. Final Report

This document summarizes work detailed in separate Wabash CarbonSAFE reports; the report describes the data collection efforts of the project and consolidates the geologic characterization, well testing, and storage complex modeling results for the Mt. Simon Sandstone and Potosi Dolomite, two distinct reservoirs characterized at the Wabash CarbonSAFE project site. Also presented are summaries of work to characterize the CO 2 source and infrastructure network, as well as summaries of reports analyzing stakeholder engagement options, policy, regulatory and legal considerations, and risk assessment associated with the Wabash CarbonSAFE project site. The report then presents recommendations for the next steps for site characterization, identifies data gaps for future activities, and provides an overall assessment of site potential.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

CORAL: A framework for rigorous self-validated data modeling and integrative, reproducible data analysis

Abstract Background Many organizations face challenges in managing and analyzing data, especially when relevant datasets arise from multiple sources and methods. Analyzing heterogeneous datasets and additional derived data requires rigorous tracking of their interrelationships and provenance. This task has long been a Grand Challenge of data science and has more recently been formalized in the FAIR principles: that all data objects be Findable, Accessible, Interoperable, and Reusable, both for machines and for people. Adherence to these principles is necessary for proper stewardship of information, for testing regulatory compliance, for measuring the efficiency of processes, and for facilitating reuse of data-analytical frameworks. Findings We present the Contextual Ontology-based Repository Analysis Library (CORAL), a platform that greatly facilitates adherence to all 4 of the FAIR principles, including the especially difficult challenge of making heterogeneous datasets Interoperable and Reusable across all parts of a large, long-lasting organization. To achieve this, CORAL's data model requires that data generators extensively document the context for all data, and our tools maintain that context throughout the entire analysis pipeline. CORAL also features a web interface for data generators to upload and explore data, as well as a Jupyter notebook interface for data analysts, both backed by a common API. Conclusions CORAL enables organizations to build FAIR data types on the fly as they are needed, avoiding the expense of bespoke data modeling. CORAL provides a uniquely powerful platform to enable integrative cross-dataset analyses, generating deeper insights than are possible using traditional analysis tools.

97 MATHEMATICS AND COMPUTING↗

Assessment of Potential Dose and Environmental Impacts from Proposed Testing at the INL Radiological Response Training Range

This assessment uses screening level models to calculate potential environmental impacts from proposed tests at the Idaho National Laboratory (INL) Radiological Response Training Range (RRTR) site. Proposed tests could be conducted using 11 different radioactive material types that include K 2 O, LaBr 3 , KBr, Cu, Zr, F, Ga, Ga 2 O 3 , NaNO 2 , Ga-68, and Tc-99m. The tests could potentially release radioactive material to the atmosphere and radionuclides and other contaminants to the soil, which could leach into the unsaturated zone and migrate to the aquifer. Atmospheric transport of radionuclides to potential human receptors and time-integrated air concentrations were calculated with a Gaussian plume model and three years of hourly meteorological data. Potential surface-soil impacts were calculated with the computer program Mixing-Cell Model (MCM). Groundwater impacts were calculated with the computer programs MCM and GWSCREEN. Radiological doses from potential atmospheric releases were calculated for public receptors off the INL Site and for workers at nearby INL facilities. Results were compared to regulatory dose limits. Maximum potential groundwater concentrations were estimated in the aquifer below the NSTR site and compared to drinking water standards or risk-based screening levels for resident tap water. Soil concentrations were calculated and compared to risk-based screening levels for workers and potential future residents. All impacts were estimated based on the assumption that 12 tests are conducted annually using all 11 material types for a period of 15 years. This document provides the resources to enable a subject matter expert in the field of environmental assessments to replicate the modeling and calculations. The methodology and parameters are presented in the text. All electronic files, including computer code input, output, executable files, batch files, scripts, and spreadsheet files are contained in a zip file that can be accessed by selecting “Additional Information” (select Native File) in the INL Electronic Document Management System (EDMS).

99 GENERAL AND MISCELLANEOUS↗

Marine Energy Technology Development Risk Management Framework

Over the past decades, the global marine energy industry has suffered a number of serious technological and commercial setbacks. To help reduce the risks of industry failures and advance the development of new technologies, the U.S. Department of Energy (DOE) and the National Renewable Energy Laboratory (NREL) developed a Marine Energy Risk Management Framework in 2015, with this revision published in 2024. This risk management framework shall be utilized on all DOE Water Power Technologies Office (WPTO) projects that require system testing in the open water. By addressing uncertainties, the Marine Energy Risk Management Framework increases the likelihood of successful development of marine energy converter technology. It covers projects of any technology readiness level technology performance level (TPL) and all risk types (e.g. technological risk, regulatory risk, commercial risk) over the development cycle. This risk framework is not a substitute for other risk management procedures that may be required for marine operations, such as installations at sea, hoisting and rigging, safe diver operations, and other safety requirements. This risk framework is intended to meet DOE's risk management expectations for marine energy technology research and development efforts from WPTO. It also provides an overview of other relevant risk management tools and documentation.

16 TIDAL AND WAVE POWER↗

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. MNA can also be used after active remediation has been completed (e.g., pump-and-treat) as a polishing step to reach ultimate remedial action objectives. However, MNA and existing monitoring guidance primarily target situations where the remedial action objectives are met within a few decades. When timescales for passive remediation extend to many decades, 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 receptors will not be impacted within the remediation timeframe.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Batch Extraction Studies to Evaluate Trace Element Behavior in PUREX Conditions

The multilab Intentional Forensics Venture is working to identify which stable elements (i.e., taggants) at trace concentrations relative to U would persist throughout the nuclear fuel cycle in a voluntary fuel tagging scheme. A taggant would provide the nuclear forensics community with a “barcode” to help identify nuclear materials found outside of regulatory control. A portion of this project was focused on reprocessing effects and determining which, if any, elements would coextract with U(VI) in standard Pu–U reduction extraction (PUREX) conditions. Elements with a propensity to coextract could, in theory, be used as taggants from a PUREX perspective. Although retention is not a performance requirement, the taggant signature would need to partition predictably from the U stream after the PUREX process to maintain forensic utility. This report documents results from several batch extraction studies with numerous trace elements from HNO 3 (1.5–5 M), with and without U(VI), into 30% tri-n-butyl phosphate (TBP) in kerosene. Extraction and back-extraction tests were used to evaluate nearly 60 elements in surrogate conditions for PUREX, and distribution coefficients (i.e., D-values) for most species were <0.1, indicating few species are likely to co-extract with U through PUREX. Additional studies are needed to optimize sample volumes and dilutions to dial in these low D-values. The D-values (D) were determined for several of the more promising elements, including Re and Se. Ultimately, we conclude that only a limited number of the ~ 60 elements investigated are extractable in the U stream of PUREX, based on measured D values, meaning most candidate elemental taggants would likely be lost at this stage of the nuclear fuel cycle, even when considering a range of acid concentrations.

38 RADIATION CHEMISTRY, RADIOCHEMISTRY, AND NUCLEA↗

Hot Springs and Geysers: Exploring Historical and Modern Impacts of Geothermal Energy Production on Associated Natural Surface Systems and Standardizing Management Practices

Surface thermal features, most notably hot springs and geysers are increasingly being recognized for their importance to ecosystems, indigenous cultures, and in some cases agriculture, recreation, and tourism. Geothermal project development poses a potential risk to these natural features but current regulatory requirements for assessing and managing these risks during exploration, permitting and monitoring are somewhat inconsistent and unpredictable across different geothermal fields. This has resulted in uncertainty and increases in exploration risk for geothermal energy developers that have led to costly project delays, cancellations, or hesitation to commit. Varying regulatory requirements may also influence public perception, fostering confusion, distrust and ultimately opposition to geothermal projects, further contributing to project delays or cancellations. At a time when there is an increasing urgency for reliable baseload clean energy, geothermal is a net-zero, renewable solution that additionally provides access to more equitable and environmentally just clean power. Continued integration of geothermal energy into the national energy roadmap can be facilitated through consistent and predictable permitting, providing regulators the framework they need, developers a clear path forward, and transparency that the public deserves. This project, currently in its beginning phases, seeks to address this important issue by providing a technical basis from which to build a preliminary protocol for assessing and managing potential impacts from new or existing geothermal energy projects to surface thermal features and their associated ecosystems. Development of this preliminary protocol will be informed by (1) a literature review of well-documented case studies in the western U.S. and New Zealand to understand the range of conditions that exemplify geothermal-surface thermal systems; (2) development of generic illustrative conceptual-numerical models to quantify, understand, and predict the first-order controls (e.g., pressure and permeability) on surface flows; and (3) additional independent and scientifically rigorous evaluations of geothermal-surface thermal system case studies from the Basin and Range Province that incorporate publicly available data as well as data provided by industry through data-sharing agreements. Learning from the successes of the process used to develop the Induced Seismicity Management Protocol (ISMP), we ultimately aim to use these initial efforts as a springboard for establishing a surface thermal feature management working group that will work collaboratively to finalize the protocol as well as co-create recommended best practices for implementation. We envision that the working group will primarily be composed of representatives from regulatory entities, government agencies, Tribes, academia, national laboratories, and industry, and will include early and regular engagement with community organizations and environmental groups. This will help ensure broad acceptance and implementation of the protocol, which will facilitate a more consistent, predictable, and standardized regulatory process, and help to ensure that geothermal energy continues to provide a reliable source of clean energy, and a pathway to achieving greater energy equity in the U.S.

Best Practices↗

ORNL Infrastructure: Status Update on BEA Research Reactor Cask Planning Activities Completed During FY 2025

This report documents Oak Ridge National Laboratory’s (ORNL’s) FY 2025 progress toward establishing readiness to use the Battelle Energy Alliance (BEA) Research Reactor (BRR) shipping cask in support of the Nuclear Science User Facilities (NSUF). The BRR cask will provide a new shared infrastructure capability for transporting irradiated fuels and materials between ORNL and Idaho National Laboratory (INL), thereby supporting NSUF’s mission of enabling user access to advanced nuclear research facilities. In FY 2025, ORNL advanced the regulatory, contractual, safety review, and planning activities necessary to qualify its facilities and staff for BRR cask handling. Although loaded shipments were delayed due to fabrication lead times for Orano Federal Services LLC’s internal basket hardware, the program progressed to the point where an empty cask dry run is scheduled for October 2025. This dry run represents a critical step in demonstrating ORNL’s ability to receive, handle, and return the BRR cask.

99 GENERAL AND MISCELLANEOUS↗

Gulf of Mexico Health & Air Quality: Mapping Methane Emission Plumes Using Sunglint-configured Imagery for Monitoring Offshore Oil and Gas Activity

We had three project objectives that we set out to accomplish. The first objective is to demonstrate how remote sensing can complement the current bottom-up methane emission assessments. Currently, quantities of disposed gas vented and flared are self-reported by operators to BOEM and BSEE. Meanwhile, inspections are uncommon, and ground sensors are non-existent. Therefore, remote sensing may be the agencies' best bet in verifying these operator accounts. The second objective is to identify methane plumes in the Gulf of Mexico, Asia, and elsewhere using Sentinel-2, LandSat, and PRISMA images, and then present an estimate of their emission rate. While methane retrievals from oil and gas infrastructure on-shore has been relatively well-documented, doing so on the offshore oil and gas platforms is more difficult, less prevalent, and contingent on the presence of specific conditions. The final objective is to give our partners, BOEM and BSEE, a more robust understanding of methane emissions from oil and gas production in the Gulf of Mexico. This increased knowledge, paired with a demonstration of methane monitoring, is intended to help our partners think about how they can incorporate remote sensing into their monitoring, regulatory and enforcement framework.

Ben Dahan↗

Alternative Technologies Adopters Outreach Survey Report

Brookhaven National Laboratory (BNL), in collaboration with Ioanna Iliopulos and Christopher Boyd (independent contractors), conducted quantitative and qualitative surveys to document views and opinions of scientists and researchers with firsthand experience operating x-ray devices for a wide range of research applications. The goal of the study was to fill critical information gaps and identify misconceptions widely held among the research community regarding the transition from Cesium-137 irradiators to x-ray devices. The survey instrument focused on three distinct yet interrelated areas that impact users' experience: operational impacts, including infrastructure needs, workflow, personnel management, and training, and regulatory compliance; research design and investigation impacts, including calibration, dosimetry, continuity of previous studies, development of new research agendas, and the outcomes for both; and funding impacts, specifically how grant sources and opportunities have responded to the transition.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Environmental Impacts of Closed-Loop Pumped Storage Hydropower

The goal of this report is to help license applicants, resource agencies, and other members of the hydropower community involved in closed-loop pumped storage hydropower permitting and licensing process, focus the scope of environmental reviews, and more quickly identify impacts with project nexus and potential mitigation measures for these impacts. Pumped storage hydropower (PSH) is an energy storage technology that uses energy to pump water up from a lower reservoir to an upper reservoir where water is stored until electricity is needed and the water is released to a lower reservoir passing through turbines. Closed-loop PSH—PSH that is not continuously connected to a naturally flowing water feature—is one of the lowest greenhouse gas emitting energy storage technologies and is therefore a critical part of the transition to renewable energy (Simon et al. 2023). Proposals for closed-loop PSH facilities in the United States currently account for more than 40% of original licenses and 99% of potential generation capacity in the Federal Energy Regulatory Commission (FERC) hydropower licensing pipeline (Johnson et al. 2023). While closed-loop PSH facilities can have lower environmental impacts than open-loop PSH facilities, no closed-loop facilities have been constructed in the United States to enable direct accounting of project impacts and efficacy of mitigations. Many proposals for closed-loop PSH submitted to FERC are abandoned early in the permitting and licensing process prior to license applications and environmental assessments, so there is little documentation describing potential project impacts and proposed mitigations. The newness of closed-loop PSH proposals in the United States may mean that tribal, federal, and state agencies with authorities for cultural and natural resources protection and management involved in the FERC licensing process may not have experience with closed-loop PSH regulation. Moreover, many proposed closed-loop PSH facilities are in areas that do not have high concentrations of conventional hydropower, so these agencies may also be unfamiliar with the FERC hydropower licensing process. The goal of this report is to help license applicants, resource agencies, and other members of the hydropower community focus the scope of environmental review for the closed-loop PSH development, licensing, and federal authorization process enabling quicker identification of potential impacts, mitigations, and situations where mitigation may not be possible. We found that environmental impacts of closed-loop PSH are highly site-specific, and generalizations about the types of environmental impacts across closed-loop PSH projects are difficult to make. Environmental impacts of closed-loop PSH are like those for open-loop PSH with a few exceptions including water sourcing, which can lead to delays and contention due to potential complexities with water rights, impacts to aquatic resources, and greenhouse gas emission potential. Cultural resource impacts were commonly reported in National Environmental Policy Act (NEPA) documents reviewed and discussed in interviews, but in many cases such impacts cannot be mitigated.

13 HYDRO ENERGY↗

Current and future federal and state sampling guidance for per- and polyfluoroalkyl substances in environmental matrices

Per- and polyfluoroalkyl substances (PFAS) are a class of emerging contaminants composed of an estimated 5000 to 10,000 human-made, fluorinated, organic chemicals. Due to the complexity of PFAS, the need for multiple environmental matrix considerations and the absence of a promulgated federal standard for environmental sampling and analysis, U.S. states have begun developing health-based regulatory and/or guidance values for a limited number of PFAS in environmental matrices. As there is a growing body of science to inform PFAS sampling guidance standard development, it is important to understand which U.S. states are implementing sampling guidelines and how they plan to handle emerging PFAS. This critical review discusses the current and impending federal and state sampling guidelines for PFAS in environmental matrices, the data gaps surrounding PFAS sampling guidance in U.S. states, and the future impacts of impending guidance documents and regulations. Ten federal guidance documents are available for PFAS sampling guidance and analysis. The maximum number of PFAS covered in these guidance documents is 25 analytes spanning across 8 unique media. While the EPA has developed several different sampling and analytical guidelines for PFAS, there is no formal regulation of PFAS or requirements of states to enforce these guidelines. Consequently, only 31 states have informally adopted sampling guidelines, while the other 19 states have no guidance documentation in place for PFAS. The introduction of new PFAS sampling guidelines by the EPA, as well as updated analytical guidelines that target more PFAS or total organofluoride, is expected to continuously shift the landscape of federal and state guidance for PFAS sampling moving forward.

54 ENVIRONMENTAL SCIENCES↗

Making the Implicit Explicit: Towards an Assurance Case for DO-178C

For about two decades, compliance with Software Considerations in Airborne Systems and Equipment Certification (DO-178B) has been the primary means for receiving regulatory approval for using software on commercial airplanes. A new edition of the standard, DO-178C, was published in December 2011, and regulatory bodies have started the process towards recognizing this edition. The stated purpose of DO-178C remains unchanged from its predecessor: providing guidance “for the production of software for airborne systems and equipment that performs its intended function with a level of confidence in safety that complies with airworthiness requirements.” Within the text of the guidance, little or no rationale is given for how a particular objective or collection of objectives contributes to achieving this purpose. Thus the assurance case for the document is implicit. This paper discusses a current effort to make the implicit explicit. In particular, the paper describes the current status of the research seeking to identify the specific arguments contained in, or implied by, the DO-178C guidance that implicitly justify the assumption that the document meets its stated purpose.

Holloway, C. Michael↗

Survey of Methods for Assessing Safety Compliance of sUAS BVLOS Operations

To ensure the safety of small Unmanned Aircraft System (sUAS) Beyond Line of Sight (BVLOS) operations in the National Airspace System (NAS), the FAA offers a guideline on how sUAS operators can demonstrate compliance with FAA rules, including regulations, advisory circulars, policy statements, and acceptable means of compliance (AMOC), using a formal and top-down approach. According to FAA Advisory Circular 23.2010-1, the AMOC refers to “one method, but not the only method, to show compliance with a regulatory requirement.” It is common for regulations to include a performance and safety standard rather than a detailed design or operation requirement, which allows for flexibility in fulfilling the regulatory requirements while still achieving a predetermined level of safety. This technical report explores existing frameworks for sUAS BVLOS safety analysis. It begins by discussing how sUAS BVLOS operations can be strategically deconflicted and then discusses their hazards. The next step is to establish safety assessment methods commonly used by the aviation industry and the FAA, illustrate how these methods can be applied to several safety-critical air traffic systems, and list collision models that the FAA and industry use. This investigation documents the processes for assessing safety risks in sUAS BVLOS operations and will allow sUAS BVLOS operations to be assessed for safety compliance more efficiently.

sUAS BVLOS Operations↗