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Equity Considerations in Siting Consolidated Interim Storage Facilities for Commercial Spent Nuclear Fuel

Questions of equity and fairness are often raised by representatives from State, Tribal and local governments and members of the public when resolving conflicts over siting of nuclear facilities. However, the two terms are not synonymous: equity can be quantified while fairness is much more subjective. The Department of Energy's (DOE) December 2021 Request for Information sought input on how to site federal facilities for the temporary, consolidated storage of spent nuclear fuel (SNF) using a consent-based approach. It is anticipated that just such questions about equity and fairness associated with the potential emergence of more than one host site may be raised by the twelve groups of university, nonprofit and private sector partners (Consortia) working to support community engagement, inclusively involve stakeholders, build relationships, and develop innovative forms of mutual learning and public capacity to participate in the consent-based siting process for a federal consolidated interim storage facility during the current Planning & Capacity Building stage of the consent-based siting process. In terms of DOE's Integrated Waste Management System (IWMS), sociopolitical equity concepts are a factor in all aspects of IWMS development and operations and will be particularly applicable should two or more host sites become a possibility, either by the emergence of multiple volunteer hosts or by pursuit as a IWMS program strategy. This paper summarizes recent analyses that explore how four equity metrics - number of states, division of the projected SNF total by the year 2083, current population and land area - might be perceived by host communities, states and regions if two, three or four sites for hosting federal consolidated interim storage facilities were to be contemporaneously realized. Existing institutional arrangements, including Nuclear Regulatory Commission regions, Federal Energy Regulatory Commission regions and Low-Level Radioactive Waste Disposal Compacts, were selected to create hypothetically merged two, three and four-region scenarios to calculate how the four metrics balance out. Projected SNF burden was prioritized with regional contiguity of the consolidated regions a requirement for a functional scenario. The intent was not to promote or suggest any construct as a program objective; the configurations are geopolitical abstractions only to explore potential perceptions of equity. Understanding the possible issues of equity that could arise may benefit program efforts toward achieving a cooperative federalism wherein both the federal and multiple State governments share the goal of manifesting more than one federal consolidated interim storage facility. The main finding is that it is not possible to optimize for all four metrics simultaneously. The analyses demonstrate that trying to create a sense of equity by backfitting a solution to a random population and land distribution will always contain a degree of artificiality.

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Sources of Conservatism in Making Corrective Action Decisions at the NNSS - 20477

During the course of closing nuclear testing release sites at the Nevada National Security Site (NNSS) under the Federal Facility Agreement and Consent Order (FFACO) using the Risk-Based Corrective Action (RBCA) evaluation process, conservative assumptions and estimates were used in many phases of the work. These assumptions and estimates were agreed to during Data Quality Objective (DQO) meetings and published in the FFACO documents. However, the potential cumulative effect of these multiple sources of conservatism was not evaluated. The RBCA process ensures that corrective action decisions minimize the risk of making Type I errors (not applying corrective action to areas that exceed action levels) at the expense of making Type II errors (applying corrective action to areas that do not exceed action levels). Rather than fully characterizing the spatial distribution of contaminants throughout each site, the RBCA process uses a bounding methodology that conservatively estimates spatial boundaries beyond which contamination is not present that exceed corrective action levels. This process accepts that these boundaries may encompass areas that do not exceed corrective action levels and, therefore, may be somewhat larger than for fully characterized sites. This is justified at sites where the reduction in investigation costs are more than any potential increase in corrective action costs. To minimize the risk of making Type I errors, conservatism was used throughout the process. This study documents the many sources of conservatism used in the RBCA process. Conservatism was used in the RBCA process in determining potential receptors, determining action levels, collecting samples, converting sample results into receptor dose, and accounting for uncertainty. This provides decision-makers with a high level of confidence that unacceptable risk to receptors will not result from exposure to residual contamination outside the corrective action boundaries. However, it does not provide an estimate of the actual extent of areas exceeding action levels. This study provides an evaluation of the effects of compounding conservatism on RBCA process decisions. (authors)

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Federal Facility Agreement and Consent Order: Nevada National Security Site Use Restriction Management Plan with ROTC 1

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). (Note: This pertains to those FFACO sites not managed by the U.S. Department of Energy [DOE], Legacy Management.) The closure in place alternative is used for sites closed with residual contamination at levels requiring corrective action as determined using the FFACO process. The URs contain and control all requirements for long-term monitoring. This URMP also serves as the single repository of the URs implemented under the FFACO that identify use restricted areas and contain the current requirements for inspections, maintenance, and monitoring of the UR. The requirements in these URs replace all requirements listed in previous documentation. This consolidates post-closure monitoring requirements into a single source that ensures completeness and consistency of UR requirements and information. Standardized UR forms were developed to clearly document post-closure requirements that are consistent with current protocols and to ensure consistent information is contained in the URs. Standard notification, summary, and site controls statements were developed for all URs with provisions to insert site-specific options in the text. Current protocols for Industrial Sites and Soils URs are defined in this document and in the Soils Risk-Based Corrective Action (RBCA) Evaluation Process (DOE/EMNV, 2018). The standardized UR forms that have been approved to date are listed in Appendix A. Additional UR forms will be added once the review and approval process has been completed.

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STAND Quickstart Guide

STAND is a flexible web application designed to identify and examine potentially feasible sites where advanced nuclear facilities might be welcomed by host communities. STAND allows the user to explore and provide insight on socioeconomic, proximity, and safety data, generate county reports, review regulatory data, and complete a comparative analysis across multiple sites by following several paths, either individually or sequentially based on the user’s needs and where they are in the deployment process. STAND is best used for the contiguous United States. STAND is not a substitute for the in-depth studies required to qualify a site for hosting a nuclear facility, nor is it a substitute for the necessary community engagement to build trust and seek consent. It can, however, be a valuable resource to aid in the siting process.

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Calendar Year 2020 Post-Closure Monitoring Report for Corrective Action Unit 99: Rainier Mesa/Shoshone Mountain, Underground Test Area, Nevada National Security Site, Nevada (Rev. 1)

This report presents the results of monitoring conducted for water quality, water levels, and institutional controls in calendar year (CY) 2020 by the U.S. Department of Energy (DOE), Environmental Management (EM) Nevada Program’s Underground Test Area (UGTA) Activity at Corrective Action Unit (CAU) 99, Rainier Mesa/Shoshone Mountain (RM/SM), at the Nevada National Security Site (NNSS), Nevada. This report also presents analytical laboratory results (including results of quality assurance/quality control samples, such as field duplicates [FDs]), and verification of use restrictions (URs), institutional controls, and water usage. Groundwater samples were collected; water levels were measured; and well site surveillance was conducted in support of the Underground Test Area Closure Report (CR) for Corrective Action Unit 99: Rainier Mesa/Shoshone Mountain, Nevada National Security Site, Nevada (DOE/EMNV, 2020). Rainier Mesa (RM) was the site of 61 underground nuclear tests, and Shoshone Mountain (SM) was the site of 6 underground nuclear tests. As a result of these activities, which took place from 1957 to 1992, radionuclides (RNs) were released in the subsurface in the vicinity of the detonations. These 67 underground nuclear tests are associated with 66 specific corrective action site (CAS) numbers, as listed in the Federal Facility Agreement and Consent Order (FFACO) (1996, as amended). Two tests, HURON LANDING and DIAMOND ACE (conducted simultaneously), are included within one CAS. The CR (DOE/EMNV, 2020) establishes the regulatory boundaries and regulatory boundary objectives, monitoring program, UR boundaries and URs, and other institutional controls agreed to by EM Nevada Program and the Nevada Division of Environmental Protection (NDEP) for closure of CAU 99. Regulatory boundaries for the RM/SM CAU were established to protect receptors of groundwater from RN contamination within the three downgradient groundwater basins that receive recharge from RM. The SM regulatory boundary was established to verify that RN contamination does not reach the lower carbonate aquifer below SM. The UR boundaries were established based on contaminant simulation forecasts from the flow and transport simulations with consideration of site-specific topographical controls. The URs associated with the UR boundaries were identified to protect onsite workers and the public from inadvertent exposure to contaminated groundwater as forecasted to occur assuming current conditions. The UR is intended to restrict activities that might expose workers to contaminated groundwater within the UR area. In addition to the URs, other institutional controls are established to monitor and limit access to groundwater. These include federal ownership and management in perpetuity, controlled access of the NNSS and surrounding areas, and reporting water use on the NNSS and surrounding hydrographic basins.

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2024 OES-Environmental 2024 State of the Science Report, Chapter 7: Education and Outreach around Environmental Effects of Marine Renewable Energy

The marine renewable energy (MRE) industry has faced many challenges in getting projects in the water. In many cases, this is due to long consenting timelines, and occasionally active public opposition, often related to concerns about environmental effects or potential conflicts with other uses of the ocean space. While these concerns are very real, some of them are based on misconceptions or lack of familiarity with MRE devices and how they function (Boudet et al. 2020; Karytsas & Theodoropoulou 2014), or uncertainty or misinformation regarding how MRE devices may affect the environment. These misconceptions are common challenges for other renewable energy sectors or other developments in the ocean (Caporale et al. 2020; Scott 2022; Wiersma & Devine-Wright 2014), though the details of device design, site-specific environmental effects, risk and benefit perceptions, and workforce development may be unique to MRE

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Effects of small marine energy deployments on oceanographic systems

The placement and operation of marine energy deployments in the ocean have the potential to change flow patterns, decrease wave heights, and/or remove energy from the oceanographic system. Changes in oceanographic systems resulting from harvesting marine energy, particularly tidal and wave energy, may be of concern. These changes include alterations in nearfield and farfield physical processes, as well as potential secondary environmental effects such as changes in sediment transport patterns, biological processes, or coastal erosion. Knowledge of changes in oceanographic systems associated with marine energy is primarily available from numerical modeling studies, informed by some laboratory tests and very few field measurements. A literature review was conducted using the Tethys knowledge base and other online sources, building on conclusions from the Ocean Energy Systems-Environmental State of the Science report. Potential changes in oceanographic systems that may be caused by marine energy differ between tidal and wave devices because of different extraction mechanisms and siting locations. Numerical models show that tidal extraction on the order of hundreds of megawatts or with significant channel blockage is required to create changes in oceanographic processes that exceed natural variability. Effects from wave energy extraction in arrays are localized and dependent on array spacing and proximity to the shore. Here the available evidence supports the conclusion that the risk of significant environmental effects from such changes could be retired (i.e., less investigation required for every project) for small deployments—those representative of the state of the industry in 2021. Determining changes in oceanographic systems to be low risk for small deployments can thereby streamline environmental consenting by reducing monitoring needs at this early stage in the industry.

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Acquisition and Implementation of a Comprehensive Environmental Permits Linking Tool at Savannah River Site - 20234

Historically, Savannah River Nuclear Solutions LLC (SRNS) tracked environmental regulatory commitments and the requirements from hundreds of permits at the Savannah River Site (SRS) using several separate methods, making integrated compliance assurance cumbersome and labor-intensive. When SRNS experienced an increase in environmental issues in 2017, SRNS management and U.S. Department of Energy - Savannah River (DOE-SR) management decided a single, proactive approach was needed to capture environmental permit information (including regulations, Consent Orders, DOE Orders, and any other state or federally issued statement of requirements), track the tasks necessary to ensure compliance with these requirements, and thereby mitigate the risk of noncompliance. SRNS developed a list of mandatory objectives that the tool must meet to function as a Comprehensive Environmental Permits Linking Tool (CEPLT). A key requirement was the ability to map Site permits to their governed locations and display the associated requirements at the compliance point (e.g., outfall, stack, waste unit, etc.). Several options included modifying existing onsite resources, building a custom onsite solution, purchasing an off-the-shelf solution, and contracting an offsite developer to build a custom solution. SRNS concluded an off-the-shelf solution with configuration and customization options would provide the flexibility to fit the unique needs of Savannah River Site (SRS) while taking advantage of industry-tested software and providing a reduced deployment timeline. SRNS chose Gensuite{sup R} a, a cloud-based solution that offers numerous a la carte applications in the environmental, health, and safety arenas, as the best candidate. SRNS selected three (3) integrated applications (Compliance Calendar, Permit Manager, and Mapper) to function as the CEPLT. The Compliance Calendar module allows for creation and tracking of regulatory commitment tasks assigned to responsible environmental professionals. Permit Manager organizes permits and other requirement documents, linking the commitments in each to Compliance Calendar tasks and/or implementing procedures. Mapper provides GIS capability for mapping the data from the other two modules to their physical onsite locations. The CEPLT was configured to allow for other SRS Site Tenants to eventually utilize the applications. Additionally, DOE-SR uses the CEPLT to provide an overview of contractor environmental compliance activities and to organize DOE-specific documents and tasks. The CEPLT fulfilled the requirement of meeting current compliance needs as well as providing the ability to grow as new organizations are incorporated and functionality is expanded. SRNS now uses the CEPLT to more effectively manage permit requirements, improve knowledge transfer, and increase the Site's overall protection of the environment, the Site worker, and the public. Possible future uses of the system include integration of mobile applications for timely communication of potential non-compliant conditions and DOE complex-wide deployment allowing for enhanced DOE site and Head Quarters oversight. Implementation of CEPLT will result in cost savings, both in terms of dollars and man-hours. (authors)

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Achieving the End State for the Pahute Mesa Corrective Action Units at the Nevada National Security Site - 20355

Underground nuclear testing at the Nevada National Security Site (NNSS) ended in 1992. To address the impact of radionuclide contamination from underground nuclear testing on the groundwater resources of Nevada, the U.S. Department of Energy (DOE) Environmental Management (EM) Nevada Program created the Underground Test Area (UGTA) activity to characterize the radionuclides in groundwater, understand the nature and extent of radionuclide migration, and forecast the distribution of radionuclides in groundwater for 1,000 years. The UGTA activity is regulated by the Federal Facility Agreement and Consent Order (FFACO), an agreement negotiated between the Nevada Division of Environmental Protection (NDEP), DOE, and the U.S. Department of Defense (DoD). DOE is close to achieving the end state (closure in place with monitoring and institutional control) for three of the five UGTA corrective action units (CAUs) on the NNSS. A number of challenges remain to achieve the end state of the other two CAUs, both located on Pahute Mesa. Pahute Mesa was the location of 82 underground nuclear tests, less than 10% of the total number of tests on the NNSS. Yet, Pahute Mesa contains slightly more than 60% of the total radionuclides (in curies). Based on groundwater sampling in monitoring wells, two radionuclide plumes have migrated several kilometers (km) in groundwater from selected test cavities and have crossed the boundary of the NNSS (yet remain within the boundaries of Federally controlled land). The path to achieve the end state continues to evolve as more data are collected and a better understanding of radionuclide migration in groundwater is developed. DOE has invested in drilling and sampling more than 50 characterization and monitoring groundwater wells over the past 25 years. The data indicate that the primary radionuclide of concern is tritium as it is about 89% of the total radionuclide inventory (in curies). As well, only tritium has been measured in groundwater outside of cavities at concentrations exceeding the Safe Drinking Water Act (SDWA) standard. For one of the tritium plumes that has migrated across the NNSS boundary, the average rate of migration has been measured as about 45 meters (m) per year with the rate of migration at the leading edge of the plume of about 85 meters per year. At that rate of migration, the tritium plume will decay to safe levels and not reach the publicly accessible environment at concentrations above the SDWA standard. Other radionuclides, at concentrations below the SDWA standards, will be monitored to ensure they remain at safe levels. Consequently, the end state path forward for Pahute Mesa has evolved to take full advantage of the data from the monitoring network to constrain uncertainty in model forecasts and to reduce reliance on probabilistic simulations. The focus of the end state approach relies on developing a monitoring well network that is protective of human health by increasing confidence that no radionuclide plume in the groundwater will migrate undetected to the accessible environment, located about 22 km from the nearest up-gradient underground nuclear test. Using the measured data to remove uncertainty, the evaluation of radionuclide migration from Pahute Mesa is directed toward meeting the goals of the end state. (authors)

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Streamlined Approach for Environmental Restoration (SAFER) Plan for Corrective Action Unit 114: Area 25 EMAD Facility Nevada National Security Site, Nevada

This Streamlined Approach for Environmental Restoration (SAFER) Plan addresses the actions needed to achieve closure for Corrective Action Unit (CAU) 114, Area 25 EMAD Facility, identified in the Federal Facility Agreement and Consent Order (FFACO). CAU 114 comprises the following corrective action sites (CASs) located in Area 25 of the Nevada National Security Site: • 25-41-03, EMAD Facility (Building 3900) • 25-99-23, Manned Control Car (MCC) and Engine Installation Vehicle (EIV) • 25-33-05, Building 3901, Engine Transport System Maintenance Building (Train Shed) This plan provides the methodology for field activities needed to gather the necessary information for closing CAU 114. There is sufficient information and process knowledge from historical documentation and investigations of similar sites regarding the expected nature and extent of potential contaminants to recommend closure of CAU 114 using the SAFER process. Additional information will be obtained by conducting a field investigation before selecting the appropriate corrective actions for CAU 114. It is anticipated that the results of the field investigation and implementation of corrective actions will support a defensible recommendation that no further corrective action is necessary. The purpose of the corrective action investigation will be to document and verify the adequacy of existing information; to affirm the decision for either clean closure, closure in place, or no further action; and to provide sufficient data to implement the corrective action. The actual corrective action selected will be based on characterization activities implemented under this SAFER Plan. If specific conditions or findings fall outside the bounds of the conceptual site model, such as an unanticipated release, the Nevada Division of Environmental Protection (NDEP) will be consulted to determine the path forward before proceeding. Upon completion of SAFER activities, a closure report (CR) will be prepared and submitted to NDEP for review and approval. The schedule for completion of the CR will be established in consultation with NDEP.

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Streamlined Approach for Environmental Restoration (SAFER) Plan for Corrective Action Unit 114: Area 25 EMAD Facility Nevada National Security Site, Nevada, (Rev.0, with ROTC 1)

This Streamlined Approach for Environmental Restoration (SAFER) Plan addresses the actions needed to achieve closure for Corrective Action Unit (CAU) 114, Area 25 EMAD Facility, identified in the Federal Facility Agreement and Consent Order (FFACO). CAU 114 comprises the following corrective action sites (CASs) located in Area 25 of the Nevada National Security Site (formerly, the Nevada Test Site): 25-41-03, EMAD Facility; 25-99-23, Manned Control Car (MCC) and Engine Installation Vehicle (EIV); and 25-33-05, Building 3901, Engine Transport System Maintenance Building. This plan provides the methodology for field activities needed to gather the necessary information for closing CAU 114. There is sufficient information and process knowledge from historical documentation and investigations of similar sites regarding the expected nature and extent of potential contaminants to recommend closure of CAU 114 using the SAFER process. Additional information will be obtained by conducting a field investigation before selecting the appropriate corrective actions for CAU 114. It is anticipated that the results of the field investigation and implementation of corrective actions will support a defensible recommendation that no further corrective action is necessary. The purpose of the corrective action investigation will be to document and verify the adequacy of existing information; to affirm the decision for either clean closure, closure in place, or no further action; and to provide sufficient data to implement the corrective action. The actual corrective action selected will be based on characterization activities implemented under this SAFER Plan. If specific conditions or findings fall outside the bounds of the SAFER Plan, the Nevada Division of Environmental Protection (NDEP) will be consulted to determine the path forward before proceeding. Upon completion of SAFER activities, a closure report will be prepared and submitted to NDEP for review and approval. The schedule for completion of the closure report will be established at the FFACO annual meeting.

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Streamlined Approach for Environmental Restoration (SAFER) Plan for Corrective Action Unit 572: Test Cell C Ancillary Building and Structures - Nevada National Security Site, Nevada with ROTC 1

This Streamlined Approach for Environmental Restoration (SAFER) Plan addresses the actions needed to achieve closure for Corrective Action Unit (CAU) 572, Test Cell C Ancillary Building and Structures, identified in the Federal Facility Agreement and Consent Order (FFACO). CAU 572 comprises the following corrective action sites (CASs) located in Area 25 of the Nevada National Security Site: CAS 25-33-01, Building 3220, Equipment Building; CAS 25-33-02, Building 3230, Motor Drive Building; CAS 25-33-03, Building 3231, Pump House; CAS 25-33-04, Building 3232, Cryogenic Evaluation Lab; CAS 25-99-22, Ancillary Facilities. This plan provides the methodology for field activities needed to gather the necessary information for closing CAU 572. There is sufficient information and process knowledge from historical documentation and investigations of similar sites regarding the expected nature and extent of potential contaminants to recommend closure of CAU 572 using the SAFER process. Additional information will be obtained by conducting a field investigation before selecting the appropriate corrective action. It is anticipated that the results of the field investigation and implementation of corrective actions will support a defensible recommendation that no further corrective action is necessary. The purpose of the corrective action investigation (CAI) will be to document and verify the adequacy of existing information; to affirm the decision for either clean closure, closure in place, or no further action; and to provide sufficient data to implement the corrective action. The actual corrective action selected will be based on characterization activities implemented under this SAFER Plan. If it is determined that complete clean closure cannot be accomplished during the CAI, then a hold point will have been reached and the Nevada Division of Environmental Protection (NDEP) will be consulted to determine whether the remaining contamination will be closed under the alternative corrective action of closure in place. This will be presented in a closure report that will be prepared and submitted to NDEP for review and approval.

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Tribal Revegetation Project Final Project Report: 92-Acre Area, Area 5 Radioactive Waste Management Complex, Nevada National Security Site, Nevada

Nuwu (Southern Paiute), Newe (Western Shoshone), and Nuumu (Owens Valley Paiute) are linguistically related, Numic-speaking peoples who are part of the broader Uto-Aztecan language group. Numic peoples view the land as a holistic, living, sentient being with feelings and purpose. The land is personified with human characteristics and it needs to be experienced to be understood through “learning by doing.” Numic peoples do not support ground disturbing activities within their ancestral lands, including activities tied to the storage of low-level radioactive waste or classified materials on the NNSS, which they view as culturally inappropriate. These deep-rooted ancestral connections are the impetus for reinforcing Numic responsibility for healing disturbed areas by integrating respect and patience with consistent Tribal interaction. Tribal Ecological Knowledge (TEK) is the science of describing Tribal approaches for understanding natural resources. Numic TEK is embedded in traditional teachings learned incrementally over time though experience and it evolves through lessons learned and responses to environmental changes over millennia. Therefore, TEK can broaden and enhance Western scientific knowledge associated with revegetation, especially in highly disturbed areas. The project blended TEK with Western scientific ecological methods to create a vegetative cover within test plots on the 92-Acre Area located at the Radioactive Waste Management Complex (RWMC) located in Area 5 on the Nevada National Security Site (NNSS). The vegetated test plots were systematically created for the Department of Energy (DOE) in tandem with the existing Federal Facilities Agreement and Consent Order (FFACO) with the Nevada Department of Environmental Protection (NDEP). Three previous contractor-lead attempts at revegetation, one targeting full cover revegetation and two targeting test plot revegetation, did not achieve the anticipated results at this location. When presented to the 16 American Indian Tribal nations and affiliated groups with cultural and historical ties to the NNSS, the group appointed a Tribal Revegetation Committee (TRC) that included six expert Tribal knowledge holders to collaborate with an ethnoecologist/cultural anthropologist and two biologists. Project design, planning, seed and outplant selection, spiritual land preparation, and methodology were guided by the TRC and an ethnoecologist/cultural anthropologist from Portland State University (PSU) and biologists from Desert Research Institute (DRI). Using TEK, the TRC recommended a specific seed mixture that contained nine native plant species and three species of outplants. The revegetation effort included preparing and planting thirty 10 m × 10 m (32.8 ft × 32.8 ft) seeded plots, twelve of which also included outplants; and eight 10 m × 100 m (32.8 ft × 328 ft) plots that only received outplants, all atop a waste cell cover. The TRC and the project team creatively adapted TEK with Western scientific methods so that the planned revegetation efforts could occur within the safety and security parameters of the RWMC. Test plots were subjected to one of five soil treatments with varying combinations of straw or mulch applications, soil amendment, and/or outplant planting and one of two watering treatments (watered or unwatered). Planting was divided into two events: one in the fall season and another during the subsequent spring season based on TEK and a corresponding recommendation from the TRC. Monitoring and spiritual management was conducted by the TRC to evaluate plant progress on a monthly basis (in conjunction with the biologist and anthropologist) during each respective growing season for a period of three years after planting. This approach allowed Tribal members the opportunity to conduct traditional blessings and other culturally appropriate activities to restore balance to the land in accordance with Tribal protocols. Following TEK-guided methods, successful plant establishment from seed stock and outplants was observed in many plots. Overall, plots planted in the spring, as recommended by the TRC, showed higher rates of outplant survival and native seedling emergence than those planted in the fall. This finding is significant because it is contrary to the original guidance and previous approaches provided for planting in this region. The TRC believes the frequent co-occurrence of native seedlings near surviving outplants indicates an important symbiotic relationship understood by Tribal communities and overlooked by others. Watered outplants displayed much higher survivability than unwatered plants, even after watering was reduced after the plants were established. Soil amendments and mulch created higher densities of native plants from seed. Many native seedlings showed significant delays in germination, which is considered a normal adaptation to desert climates. Some native plants did not germinate until the third growing year, whereas others germinated during the first growing year, which demonstrates the complexity of the desert environment. Evidence of native insects, reptiles, mammals, and birds, as well as native plants that were not part of the planted species, were noted and considered culturally significant. Despite the presence of non-native plants, native outplants continued to thrive and the incidence of native plant germination from seed increased over time. These successful revegetation results where previous efforts were unsuccessful reinforce the importance of integrating regionally appropriate, TEK-guided methodology with Western science to achieve positive results and the necessity of integrating Tribal involvement in all stages of the revegetation effort. Expanded approaches coupled with Tribal knowledge and tools from Western science addressed a complex problem tied to revegetating atop a low-level radioactive waste cell. The level of Tribal participation serves as a progressive model for building collaborative relationships and addressing ecological challenges on the NNSS.

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