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Commercialization of the NLR Hydrogen Wide Area Monitor (HyWAM): Cooperative Research and Development (Final Report)

Hydrogen wide area monitoring refers to the temporal and quantitative 3-dimenasional spatial profiling of hydrogen plumes following either intentional or unintentional hydrogen releases. A hydrogen wide area monitor (HyWAM) would have applications as a research tool, for example to provide empirical data on the behavior of hydrogen dispersions following a release, which in turn can be used to validate modelling studies. Support of modeling studies and commercial applications are interrelated, since modeling can serve to guide HyWAM deployment for enhanced safety within medium to large scale hydrogen operations, such as those envisioned by H2@Scale.

08 HYDROGEN↗

Multi-Scale Integrated Monitoring System for Enhancing Methane Emission Detection, Quantification & Prediction

This report details the progress and findings of a comprehensive study on reviewing existing solutions, identifying technology gaps, and formulating an “all-in-one” integrated strategy for developing the next-generation multiscale methane monitoring and modeling platform, conducted under grant number DE-FE0032292. Co-led by Dr. David Ebert, Dr. Binbin Weng, and Dr. Chenghao Wang at the University of Oklahoma, the project’s goal was to develop an integrated approach for building this engineering platform to detect, quantify, and mitigate methane emissions across various temporal scale, spatial scales, and sectors. The planning grant study began with an extensive review of various methane sensing and monitoring technologies and systems, surveying over 100 technology providers globally. This review revealed the prevalence of optical methods over chemical methods in commercially available sensors, with Non-Dispersive Infrared (NDIR), Tunable Diode Laser Absorption Spectroscopy (TDLAS), and Optical Gas Imaging (OGI) cameras being the most prevalent options. A trend towards more advanced optical techniques was observed, driven by increased regulatory focus and technological advancements. The technical evaluation of these sensing technologies provided crucial insights into their capabilities and limitations. The study examined emerging technologies such as Differential Absorption LiDAR (DIAL), which show promise for high-precision and long-range detection. The team then investigated the features and application bandwidth of various sensing platforms, including handheld, fixed/stationary, mobile, aerials, and spaceborne monitors. Pilot field studies were conducted to assess the capabilities of solutions for different emission scenarios. Field work with sensor deployments was conducted at three distinct site types: an oil & gas industry site, a cattle ranching operation, and a waste processing facility. The team also conducted a thorough review of methane flux inverse modeling approaches, focused on physically based methods. These approaches were categorized into simple, intermediate, and advanced methods. A realtime WRF-GHG (Weather Research and Forecasting-Greenhouse Gas) modeling system was developed and applied, incorporating multiple data sources to guide field experiments and inform methane plume detection. The project identified and analyzed numerous categories of methane data sources, including satellite measurements, ground-based sensors, and inventory databases. Key platforms examined include EDGAR, EPA GHGI, NASA TROPOMI, Carbon Mapper, and Climate TRACE, among others. The team proposed an architecture for a comprehensive methane monitoring platform. This system incorporates multi-source data acquisition, advanced data processing and assimilation, interactive visualization tools, and analytical capabilities for emissions forecasting and scenario analysis. The proposed platform aims to provide a user-friendly interface catering to various stakeholders, from researchers to policymakers. The architecture includes sophisticated data ingestion methods, a centralized data warehouse, and advanced analytical tools for data fusion and interpretation. To ensure the relevance and effectiveness of the proposed system, a comprehensive survey was conducted to gather stakeholder input on system requirements. Key findings include a strong need for integrating various data types and formats, a preference for real-time data updates and advanced visualization tools, and a demand for user-friendly interfaces catering to different expertise levels.

03 NATURAL GAS↗

Planetesimal Impact Vapor Plumes and Nebular Shocks Form Chondritic Mixtures

The origin of chondrules and the chondritic sedimentary rocks that dominate the meteoritic record is a long-standing problem in planetary science. Here, we develop a physical model for the formation of chondritic mixtures as an outcome of vaporizing collisions between planetesimals that were dynamically excited by the growth and migration of planets. We present calculations of nebular shock waves generated by impact vapor plumes and focus on aspects of the plume interaction with the nebular gas and dust that have been neglected in previous studies of impact ejecta. We find that when water dominates the vapor, the plumes are relatively cool. However, the plume expansion is supersonic and can drive strong shock waves in the dusty nebular gas. Portions of these nebular shock fronts initially melt nebular dust, forming chondrules that are coupled to the moving front. As the shock front expands and cools, the chondrules solidify, while the shock front entrains additional dust. Eventually, the plume expansion stalls and then hydrodynamically collapses, turbulently mixing variably processed dust and size-sorted chondrules. For probable impact parameters and nebular conditions during giant planet growth and migration, the impact-generated mixtures have characteristics that span the range observed in chondritic meteorites, providing an environment for rapid formation of chondritic assemblages after chondrule formation. Our impact vapor and nebular shocks model, named the IVANS model, links chondrule formation to the overall context of planet formation and provides a framework for interpreting the detailed chronological and geochemical record contained in chondritic meteorites.

79 ASTRONOMY AND ASTROPHYSICS↗

Assessing shellfish water exposure to fecal bacteria pollution in Salish Sea: three-dimensional modeling and implications for monitoring

Fecal bacteria (FB) contamination poses significant risks to shellfish safety and management in coastal and estuarine waters. Despite extensive pollution identification and correction efforts, FB contamination in shellfish-growing areas persists in the Salish Sea, highlighting the need to identify overlooked sources and better understand FB transport from riverine and shoreline inputs to shellfish beds. To address this, a high-resolution three-dimensional hydrodynamic model coupled with FB kinetics was developed and applied to a case study site in Salish Sea—Portage Bay—to simulate freshwater plume circulation, flushing dynamics, and bacterial transport. Daily FB loading from the major freshwater inflow—Nooksack River was generated by both linear interpolation and integrating a machine learning approach (XGBoost), trained on historical hydrological and meteorological data. The model successfully reproduced both the magnitude and seasonal variation of FB concentrations in Portage Bay for the year of 2021, demonstrating that simplified FB kinetics with first-order decay due to mortality was effective in this dynamic coastal environment with short flushing time. Model results identified the Nooksack River as the dominant far-field FB source, while scenario simulations showed that near-field coastal stormwater outfalls elevated local FB levels following rainfall, particularly under low-flow conditions. The XGBoost prediction provided comparable or superior accuracy to linear interpolation, particularly during periods of missing observational data, by capturing short-term variability and event-driven loading more effectively. Integrating data-driven riverine FB inputs with mechanistic coastal numerical modeling provides a robust framework for operational forecasting of shellfish bed exposure risk and supports adaptive monitoring and management of shellfish growing areas in the Salish Sea and similar coastal systems.

Salish Sea↗

Computation of Richardson number and entrainment in a turbulent plume using DNS

This presentation will be presented by Pierre Carlotti (French foreign national) at the 1st European Fluid Dynamics Conference (EFDC1) in Aachen, Germany in mid-September. The work focuses on fundamental questions pertaining to entrainment processes in plumes. I am included as a co-author because Pierre used my previously published data to further develop theoretical estimates.

Carlotti, Pierre↗

Common practices for quantifying methane emissions from plumes detected by remote sensing

This document provides a set of community-accepted practices for quantifying methane emissions based on plumes detected via spectroscopic remote sensing. Its primary goal is to promote consistency in the generation, validation, reporting, and quality assessment of methane emission estimates derived from remote sensing radiances. Developed by subject matter experts with deep experience across all stages of the measurement process, this guidance reflects a critical evaluation of current methodologies and highlights key practices needed to produce reliable, interoperable, and traceable products. The focus is specifically on methane emissions quantified from distinct plumes originating from localized sources, rather than diffuse emissions spread over large regions, which are beyond the scope of this work. This document is intended to serve both data producers and users. For producers, it offers a framework for aligning with field-recognized standards to ensure their outputs meet rigorous quality and transparency criteria. For users, it provides a reference to assess dataset fitness-for-purpose by highlighting essential metadata, assumptions, and methodological choices that underpin emission estimates. By fostering a shared understanding of best practices, this work aims to enhance comparability, confidence, and utility of remotely sensed methane emission products.

54 ENVIRONMENTAL SCIENCES↗

Efficient and generalizable nested Fourier-DeepONet for three-dimensional geological carbon sequestration

Geological carbon sequestration (GCS) involves injecting CO2 into subsurface geological formationsfor permanent storage. Numerical simulations could guide decisions in GCS projects by predictingCO 2 migration pathways and the pressure distribution in storage formation. However, these simula-tions are often computationally expensive due to highly coupled physics and large spatial-temporalsimulation domains. Surrogate modelling with data-driven machine learning has become a promis-ing alternative to accelerate physics-based simulations. Among these, the Fourier neural operator(FNO) has been applied to three-dimensional synthetic subsurface models. Despite its good accuracyin simulating CO 2 plume migration, it requires large computational resources in training and alsolacks generalizability. Here, to further improve performance, we have developed a nested Fourier-DeepONet by combining the expressiveness of the FNO with the modularity of a deep operatornetwork (DeepONet). This new framework is twice as efficient as a nested FNO for training and has atleast 80% lower GPU memory requirement due to its flexibility to treat temporal coordinates sepa-rately. These performance improvements are achieved without compromising prediction accuracy.In addition, the generalization and extrapolation ability of nested Fourier-DeepONet beyond thetraining range has been thoroughly evaluated. Nested Fourier-DeepONet outperformed the nestedFNO for extrapolation in time with more than 50% reduced error. It also exhibited good extrapolationaccuracy beyond the training range in terms of reservoir properties, number of wells, and injectionrate.

Lee, Jonathan E. [Department of Chemical and Envir↗

Conversion of hydrogen gas to water in soil: Implications to fusion contributions

With the continuing development of fusion energy, it is reasonable to be concerned about contamination from the potential release of tritiated water (HTO) plumes, as well as the oxidation of atmospheric tritiated hydrogen gas (HT) releases in nearby soils. We build on past studies by examining oxidation rates of HT to HTO at two sites representing dry and moist soil. We also examine diurnal changes to better constrain rates of microbial HT oxidation and subsequent deposition into soils. We estimate the potential effects of an HTO plume resulting from an oxidation HT. In conclusion, this methodology framework is expected to be useful in the determination of potential health and environmental impacts from HTO as a result of HT releases.

70 PLASMA PHYSICS AND FUSION TECHNOLOGY↗

Elastic-wave sensitivity-guided adaptive seismic survey design for cost-effective monitoring of geological carbon storage

Effective seismic monitoring is essential for verifying CO₂ containment, detecting potential leakage, and optimizing operational decisions in geologic carbon storage. Here, this study presents a time-adaptive, elastic-wave sensitivity-guided framework for designing cost-effective seismic monitoring layouts for tracking CO₂ plume migration. The method is based on elastic-wave sensitivity analysis, which quantifies how variations in subsurface properties impact seismic wavefields. Two complementary design strategies are developed: one based on selecting a fixed number of seismic sources (Method A), and the other based on selecting source–receiver pairs contributing to a fixed fraction of cumulative elastic-wave sensitivity energy (Method B). The optimization workflow to identify source–receiver configurations with the highest detection potential is demonstrated using a hypothetical GCS scenario at the Kimberlina site in California using simulations of elastic-wave sensitivity data at multiple post-injection timesteps. Results show that both strategies adapt to evolving plume geometries and wavefield sensitivities, with Method B offering broader spatial coverage and Method A ensuring simpler deployment. This framework enables site-specific, cost-effective, and risk-informed seismic survey designs, enhancing the ability to monitor CO₂ migration over time in evolving geological environments

58 GEOSCIENCES↗

Sensor Placement Optimization Study for the Built Environment: Operational Use Cases

Systems of fixed-position radiation sensors can provide information that assists emergency responders following nuclear and radiological incidents. State, local, tribal, and territorial (SLTT) government agencies that implement systems of fixed-position sensors are faced with numerous decisions regarding sensor selection, quantity, and placement. To develop guidance on implementation of radiation detection systems, we simulated the release of radioactive material in an urban environment using a combination of three models: the Weather Research Forecasting (WRF), Quick Urban and Industrial Complex (QUIC), and Monte Carlo N-Particle (MCNP) models. We then evaluated the performance of several hypothetical sensor systems. The small number of simulations we conducted are not sufficient to generate definitive design guidance for radiation sensor systems, but we did identify trends that would be of interest to emergency planners. For a scenario that releases 1000 curies of Cs-137, radiation detectors were needed at 500-meter intervals to have a high likelihood of event detection and to estimate source location and plume detection. We also noted that optimal detector altitude varied with distance to the source. We recommend additional research in this area be conducted to support developing sensor placement guidelines that expand on a range of locations, isotopes, activity levels, and different weather conditions. Original simulation strategies included a range of environments, additional radioisotopes (Am241 and AmBe), and a larger selection of sensor types. These types of expansions would support SLTT guidance on sensor system recommendations.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Simulating Pyrocumulonimbus Clouds Using a Multiscale Wildfire Simulation Framework

Pyrocumulonimbus (pyroCb) clouds, driven by extreme fires under favorable meteorological conditions, can inject smoke into the stratosphere at magnitudes comparable to those of moderate volcanic eruptions, potentially altering the global radiative balance and atmospheric composition. However, simulating pyroCb is particularly challenging in Earth system models. Using the Energy Exascale Earth System Model (E3SM), we developed a novel global multiscale framework to model pyroCb events in California, which includes a high‐resolution fire radiative power time series, a one‐dimensional plume‐rise parameterization, a fire‐induced vertical water vapor transport scheme, and a surface wildfire sensible heat flux representation. Our simulation successfully reproduces many pyroCb features, including cloud height, spatiotemporal evolution, and convective intensity in comparison with satellite and ground‐based observations. Sensitivity experiments show that realistic pyroCb simulation depends on vertical water vapor transport. These advances provide a basis for future exploration of pyroCb impacts at regional and global scales within climate models.

E3SM↗

Evaluating crown scorch predictions from a computational fluid dynamics wildland fire simulator

Abstract Background Crown scorch—the heating of live leaves, needles, and buds in the vegetative canopy to lethal temperatures without widespread combustion—is one of the most common fire effects shaping post-fire canopies. Despite the ability of computational fluid dynamic models to finely resolve fire activity and buoyant plume dynamics including heterogenous 3D distributions of forest canopy heating, these models have had only limited use in simulating fire effects and have not been used to evaluate crown scorch. Here, we demonstrate a method of evaluating crown scorch using a computational fluid dynamics model, FIRETEC, and validate this approach by simulating the experiments that were used to develop Van Wagner’s 1973 crown scorch model. Results The average scorch height prediction from FIRETEC compares well with the empirical model derived by Van Wagner, which is the most widely used empirical model for crown scorch. We further find that the 3D buoyant plume dynamics from a steady and homogeneous idealized heat source on the ground results in a spatially heterogenous crown scorch pattern reflecting complex heating dynamics that are best represented by percent scorch rather than height of scorch. Conclusions The ability of the computational fluid dynamics model to capture variation in crown scorch due to 3D buoyant plume dynamics provides direct links between forest structure, fire behavior, and fire effects that can be used by forest managers and researchers to better understand how fires result in crown damage under various environmental and management scenarios.

54 ENVIRONMENTAL SCIENCES↗

Location generalizability of image-based air quality models

This paper is to be submitted at the IEEE/CVF Winter Conference on Applications of Computer Vision (WACV) Computer Vision for Earth Observation workshop. The full paper abstract is below: The ability to rapidly quantify atmospheric pollutants is important both for global emissions monitoring and for mitigating the adverse effects that follow a hazardous chemical release. In the aftermath of a chemical release, imagery is often the only available resource to assess local conditions. Recent work has demonstrated initial success in predicting particulate matter pollution from imagery; however, these results are tied to a specific site and do not generalize to new geographic locations. In this work, we seek to understand how easily deep learning models generalize to new locations in the context of image-based air quality assessments, targeting two distinct tasks: (1) broad measures of particulate matter pollution, and (2) the mass of a given chemical released in hazardous plumes. For the latter, we focus on sulfur dioxide, a toxic aerosol and a major component of particulate matter pollution caused by industrial fossil fuel consumption. To develop a model that operates in the widest possible range of environments, we test different training strategies, including the use of new geolocation foundation models. The best performing models achieve >80% accuracy when evaluating unseen imagery at previously seen sites, but we find significant drops in performance when evaluating imagery from unseen sites, at best 65%. Additionally, we present the public release of the National Parks Air Quality Index Dataset, a new medium-sized dataset that pairs imagery with sensor-based air quality measurements at 15 different national parks.

Byler, Eleanor B. [BATTELLE (PACIFIC NW LAB)]↗

Illinois Storage Corridor, CarbonSAFE Phase III: UIC Class VI Permitting Plan

The Illinois Storage Corridor (ISC) project evaluated two distinct sites to determine the feasibility of commercial-scale CO₂ storage at each. The project leveraged the region's exceptional geological characteristics, particularly the well-characterized Cambro-Ordovician Storage Complex, to enable permanent geological storage of more than 50 million tonnes of CO₂ over 30 years. The two storage sites are located at One Earth Energy (OEE) facility in northcentral Illinois and Prairie State Generating Company (PSGC) in southcentral Illinois. Once operational, these facilities will combine to capture and store more than 6.5 million tonnes of CO₂ per year, positioning the ISC among the largest carbon storage regions globally. Preliminary homogeneous dynamic modeling based on regional and site-specific reservoir characteristics indicates promising injection capabilities at both locations. For the OEE site, modeling predicts a maximum allowable injection rate of 3.7 MTPA, with a baseline scenario of 1.7 MTPA over 30 years producing a CO₂ plume radius of 1.4 miles at end of injection. For the PSGC site, incorporating recent well data, modeling indicates a single-well maximum injection rate of 2.1 MTPA, with a plume radius of 4.2 miles at end of injection for the 60 MT over 30 years scenario. The primary objective of this CarbonSAFE Phase III project is to develop and submit Class VI Underground Injection Control (UIC) permit applications to the U.S. Environmental Protection Agency Region 5. The permitting plan outlines comprehensive site characterization, Area of Review delineation, monitoring programs, well construction designs, financial responsibility provisions, and post-injection site care procedures necessary to demonstrate safe, permanent CO₂ storage protective of underground sources of drinking water. Three UIC Class VI permit applications for the OEE site were submitted to EPA in October 2022 and are progressing through technical review, with final permit decision projected by June 2026. Through five rounds of Requests for Additional Information and responses, the applications have been refined to address computational modeling, area of review delineation, well integrity, monitoring protocols, and financial assurance requirements. For the PSGC site, finalized characterization and permitting documentation was delivered directly to the facility in July 2023 due to business constraints precluding formal federal regulatory submission. This comprehensive permitting effort builds upon extensive prior subsurface evaluations and demonstration projects that have confirmed the feasibility of widespread commercial-scale carbon storage in the region.

01 COAL, LIGNITE, AND PEAT↗

A novel conditional generative model for efficient ensemble forecasts of state variables in large-scale geological carbon storage

Integrating monitoring data to efficiently update reservoir pressure and CO 2 plume distribution forecasts presents a significant challenge in geological carbon storage (GCS) applications. Inverse modeling techniques are commonly used to fuse observational data and refine reservoir model parameters, thereby improving state variable forecasts. However, these techniques often rely on linear or Gaussian assumptions, which can limit their effectiveness in accurately predicting state variables. Moreover, simulating large-scale three-dimensional (3D) GCS problems is computationally expensive, making iterative runs in inverse problems prohibitive. To address these challenges, we propose a conditional generative model utilizing the score-based diffusion method for real-time 3D pressure and saturation field distribution predictions. Our approach involves solving the score function with a mini-batch-based Monte Carlo estimator to generate labeled data. This data is subsequently employed to train a fully connected neural network, enabling it to learn the conditional sample generator within a supervised learning framework. This method enables the rapid generation of a large ensemble of predictions, facilitating comprehensive uncertainty quantification of state variables. Here we applied our method to forecast the dynamic 3D distributions of pressure and saturation fields over a 30-year injection period. The statistical assessment with low root mean square error (RMSE) values demonstrates that our method can accurately predict the spatiotemporal distributions of both pressure and saturation fields. Moreover, the developed conditional generative model shows high computational efficiency by generating 100 ensemble forecasts of 3D state variables in less than 10 min. The consistency between ensemble averages and ground truth values further illustrates the model’s capability to capture state variable dynamics during the CO 2 plume injection process. Notably, the ground truth values fall within the ensemble forecasts, indicating that our uncertainty quantification effectively captures variability and potential noise in the observations. Thus, the developed conditional generative model proves to be a more efficient, accurate, and practical tool for GCS applications, facilitating timely risk analysis and informed decision-making.

58 GEOSCIENCES↗

Development of a forced advection sampling technique (FAST) for quantification of methane emissions from orphaned wells

Abstract. Orphaned wells, meaning unplugged and non-producing wells lacking responsible owners, pose a significant and undersampled environmental challenge due to their vast number and unknown associated emissions. We propose, develop and test an alternative method for estimating emissions from orphaned wells using a forced advection sampling technique (FAST) that can overcome many of the limitations in current methods (cost, accuracy, safety). In contrast to existing ambient Gaussian plume methods, our approach uses a fan-generated flow to force advection between the emission source and a point methane (CH4) sensor. The fan flow field is characterized using a colocated sonic anemometer to measure the 3D wind profile generated by the fan. Using time-series measurements of CH4 concentration and wind, a simple estimate of the CH4 emission rate of the source can be inferred. The method was calibrated using outdoor controlled-release experiments and then tested on four orphaned wells in Lufkin, TX, and Osage County, OK. Our results suggest that the FAST method can provide a low-cost, portable, fast and safe alternative to existing methods with reasonable estimates of orphaned well emissions over a range of leak rates below 40 g h−1 and within certain geometric and atmospheric constraints.

Dubey, Mohit L↗

Reduced-Order Modeling of Hydrogen Releases from Vent Stacks and with Wind Effects

Here, the physical release behavior of hydrogen is important to understand from a safety and design perspective. The consequences of unignited pressurized gaseous hydrogen plumes exiting vent stacks were considered by extending and modifying existing general hydrogen plume models. Entrainment, vent stack backpressure, and the flow regime of hydrogen exiting the vent were found to be significant factors affecting plume shape and size, but further investigation and validation with unchoked, low-Froude-number flows is recommended to improve the model’s robustness. Additionally, models for the effects of wind on unignited plume momentum and entrainment were added to explore this behavior. Wind was assumed to increase mixing of hydrogen with the ambient air, and to affect the momentum of the released jet. Introducing wind into the plume model led to a shorter plume for all wind and jet directions. A high counter-flowing wind led to non-physical results and challenges in interpreting the visualization. The proposed jet plume wind sub-models (specifically entrainment coefficients) were fit and compared to experimental data of different releases of hydrogen into a wind tunnel, but the quantity of data available and experimental conditions were limited. Thus, collection of more empirical data and for a wider range of conditions is recommended for improvement of the proposed computational models. Developing reduced-order models for these physical phenomena can improve accessibility to predicted physical behavior and the rate at which hydrogen systems can be safely designed and deployed.

entrainment↗

Pantex Plant Ogallala Aquifer and Perched Groundwater Contingency Plan

The Pantex Plant Ogallala Aquifer and Perched Groundwater Contingency Plan has been developed in accordance with the requirements identified in the: • Interagency Agreement for the Pantex Superfund Site, Article 8.5 Work to be Performed, • Compliance Plan Provision of Hazardous Waste Permit No. 50284, and • Record of Decision for Groundwater, Soil, and Associated Media, Pantex Plant. A Long‐Term Monitoring System Design has been designed to monitor conditions in the perched groundwater including changes in the perched aquifer as a result of implementing the response actions. Monitoring is required for verifying the effectiveness of perched groundwater response actions (i.e., conditions in the perched aquifer are being affected as intended) and for confirming that the perched aquifer and Ogallala Aquifer characterization as defined in the Resource Conservation and Recovery Act Facility Investigation Report and the Corrective Measure Studies/Feasibility Study remains accurate. If monitoring results obtained through the monitoring network identify an unexpected condition or deviation, contingent actions will be considered and implemented as necessary to ensure continued protection of the Ogallala Aquifer and human health and the environment. Potential deviations to expected technology performance may be encountered for each of the four primary response actions that compose the selected remedy for perched groundwater; Playa 1 Pump and Treat System, Southeast Area Pump and Treat System, Southeast Area In‐Situ Bioremediation System (comprised of the Southeast In‐Situ Bioremediation System Original System, Southeast Area In‐Situ Bioremediation System Extension System, Offsite In‐Situ Bioremediation System, Perchlorate/Chromium ISB, Northeast ISB and County Road 8 ISB), and Zone 11 In‐Situ Bioremediation System. Monitoring will also be conducted to determine if there are deviations to the expected characterization, e.g., contaminants not expected as a result of the RCRA Facility Investigation characterization. Deviations to expected conditions in the Ogallala Aquifer could also be encountered if the response actions in the perched groundwater are not performing as expected, i.e., preventing contaminants from migrating to the Ogallala Aquifer. Currently, Pantex has begun investigation of detections of high explosives above groundwater protection standards in wells on the Texas Tech University property and a plume that is moving to the northeast from that area. Due to those detections, this Plan recognizes the fact that future detections in the Ogallala will be focused on first‐ time detections of analytes. After a remedy is determined, this Plan will require modification to address-deviations and contingent actions. This Plan was developed to identify the contingent actions necessary to mitigate impacts resulting from deviations to site conditions or response action performance. The Plan defines the environmental problem being addressed by the response actions, clarifies the expected conditions and objectives of the response actions, and identifies the potential deviations to the response actions (due to site conditions or technology performance) that could be encountered. The deviations were evaluated to determine the likelihood of occurrence, potential impact, and time to respond to avoid impact. The Plan also identifies the monitoring outlined in the Long‐Term Monitoring System Design Report (Consolidated Nuclear Security, 2024) and Sampling Analysis Plan (PanTeXas Deterrence, 2024) that will be used to detect the deviations. Lastly, the Plan specifies the contingent actions that could be implemented in response to the deviations. Because each response focuses on a discrete portion of the perched aquifer and contaminant plume, each response action has a different set of expected conditions, and therefore differing impacts from deviations to the site and technology expectations. As a result, the contingent actions are identified for each response action and potential deviation including specific constituents, location, and conditions. If deviations are encountered that impact the ability of the response action to meet performance objectives, the contingent actions will be focused on ensuring the response action can meet the performance objective. Contingent actions may be implemented as interim actions (ISMs/removal actions) in accordance with the Record of Decision, Interagency Agreement, and Hazardous Waste Permit‐50284, if warranted by the specific circumstances. For deviations to site characterization expected conditions, the contingent action will focus on determination of the source of the deviation, determination of the appropriate response, and evaluation of additional work to be completed. However, if the deviation to characterization impacts the performance of the response action, the contingent action will again focus on ensuring performance objectives can be met. Early source term removals and cleanup actions have been implemented to protect the Ogallala Aquifer. Because of these actions and based on modeling results, the expected conditions in the Ogallala Aquifer are that constituents of concern will not be detected above the Groundwater Protection Standards (GWPSs) nor will they reach potential points of exposure above the GWPS. The primary deviation of concern for the Ogallala is if constituents are detected in the Ogallala Aquifer near or above GWPSs. If it occurs, this change in expected conditions would require further evaluation of site and contaminant characteristics to determine an appropriate course of action. The evaluation would include additional monitoring, source identification, implementation of interim protective measures (if necessary), and delineation of extent. These evaluations are necessary to determine an appropriate response action for the Ogallala. The primary goal of the Plan is to provide for the continued protection of the Ogallala Aquifer and the health of its consumers. In recognition, this Plan presents a flexible and rational approach for making future decisions associated with confirming the change in perched and Ogallala aquifer conditions and identifying a response (technical activities, changes to response actions, regulatory oversight, and public involvement).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗