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PNNL Review of Federal and State Agency Regulatory Streamlining Practices

All major federal actions that have the potential to significantly affect the environment (e.g., land purchases and/or issuing grants, permits, leases, or licenses) are subject to multiple statutes including the following: • an environmental analysis under the National Environmental Policy Act (NEPA) • potential consultations with the U.S. Fish and Wildlife Service (USFWS) and/or National Marine Fisheries Service (NMFS) under the Endangered Species Act of 1973, as amended (ESA) • potential consultations with State Historical Preservation Officers (SHPOs) and/or tribal nations [often Tribal Historic Preservation Officers (THPOs)] under the National Historic Preservation Act of 1966 (NHPA). Given the size of the federal government and the corresponding variability and complexity in its missions, different branches within the federal government have a fairly wide range of approaches to fulfill their NEPA and consultation requitements. Many of these approaches are founded on the desire to streamline their NEPA and consultation processes while meeting the spirit and letter of the regulations. Some federal and state environmental/engineering agencies have developed web-based dashboards that provide a single web location for permit application submittals. They also use general permits in their various permitting processes. General permits can streamline the permitting process by establishing identical requirements for all eligible applicants. This reduces the time these agencies need to spend reviewing individual permits and setting specific requirements. In addition, general permits do not require a case-specific permit application. This paper presents a sampling of effective agency examples of streamlining the NEPA process and associated agency consultations. It also includes several examples of federal and state agency web portals, online application systems, and general permits that make application processes more efficient and accessible.

54 ENVIRONMENTAL SCIENCES↗

Closure Plan for the Idaho National Laboratory Site's Materials and Fuels Complex Industrial Waste Ditch

The Materials and Fuels Complex industrial waste system currently consists of the Industrial Waste Pond and Industrial Waste Ditch, associated piping, lift station, and flow meter. The Industrial Waste Pond and Industrial Waste Ditch, are land application sites permitted under Idaho Department of Environmental Quality Reuse Permit I-160-02, Modification 1. The Reuse Permit allows for 17 million gallons of industrial wastewater to be discharged to the land application sites. For Reuse Permit year 2017, approximately 7.569 million gallons were discharged to the land application sites, of which 1.649 million gallons were discharged to the Industrial Waste Ditch. A project (MFC West Campus Utility Corridor project) is proposed to begin in the summer of 2018. The project will install a new utility corridor along the west and north sides of the Materials and Fuels Complex. As part of the design, it is proposed to reroute the wastewater currently discharged to the Industrial Waste Ditch into an underground pipe that would connect into the existing Industrial Waste Pipeline. The Industrial Waste Ditch pipe would enter the existing Industrial Waste Pipeline upstream of the existing flow meter and sampling location. This would allow for the combined wastewater streams to be monitored for flow and sampled for parameters required by the Reuse Permit. In accordance with the Reuse Permit, this closure plan is being submitted to the Idaho Department of Environmental Quality for review and approval. Once the closure plan is approved, the Reuse Permit will be modified to remove the Industrial Waste Ditch from the permit. The closure plan includes: • Brief background of the Materials and Fuels Complex. • Reuse Permit history. • Site characteristics. • Description of the Industrial Wastewater System. • History of discharges to the Industrial Waste Ditch. • Summary of the Comprehensive Environmental Response, Compensation, and Liability Act characterization, evaluation, and remediation of the Industrial Waste Ditch. • Contaminant concentrations in the effluent discharged to the Industrial Waste Ditch. • Contaminant concentrations in cross gradient, downgradient, and background monitoring wells. Based on the Comprehensive Environmental Response, Compensation, and Liability Act characterization and remediation of the Industrial Waste Ditch, low volumes and contaminant concentrations in the effluent subsequently discharged to the Industrial Waste Ditch, and contaminant concentrations at or near background levels in the monitoring wells, it is recommended that the Industrial Waste Ditch should be closed without further characterization.

99 GENERAL AND MISCELLANEOUS↗

Addendum 2 to the Closure Report for CAU 577 Area 5 Chromium Containing Waste Disposal Cells, NNSS, Nevada

Corrective Action Unit (CAU) 577, “Area 5 Chromium Containing Waste Disposal Cells,” includes five low-level waste cells at the Nevada National Security Site Area 5 Radioactive Waste Management Site where buried waste received from Nuclear Fuel Services, Inc., was subsequently determined to contain chromium that exceeded the toxicity characteristic leaching procedure regulatory limit, which would require the waste to carry hazardous waste code D007. CAU 577 was created to satisfy the requirements of the Settlement Agreement (SA) executed between the Nevada Division of Environmental Protection (NDEP) and the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office (NNSA/NFO) on April 25, 2019 (NDEP 2019). The SA required that the chromium-containing waste received from NFS would be addressed following the closure process laid out in the Federal Facility Agreement and Consent Order (FFACO). The FFACO process ensures proper closure of the chromium-containing waste and documentation of that closure through FFACO-type documents. The following three Corrective Action Sites (CASs) were closed, and their closure was documented in the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030, dated September 2021 (U.S. Department of Energy [DOE] Environmental Management [EM] Nevada Program 2021a): • CAS 05-21-02, Waste Disposal Cell 12 • CAS 05-21-03, Waste Disposal Cell 15 • CAS 05-21-04, Waste Disposal Cell 17 Closure of the following CAS was previously documented in the Addendum to the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030-ADD, dated September 2022 (DOE EM Nevada Program 2022): • CAS 05-21-05, Waste Disposal Cell 20 This second addendum to the Closure Report documents the closure activities that have occurred for CAS 05-21-06, Waste Disposal Cell 21. This is the last CAS in CAU 577. The final waste shipment was placed in the waste disposal cell on November 21, 2022. Following this, closure activities began on November 28, 2022, and were conducted according to the Corrective Action Decision Document/Corrective Action Plan (CADD/CAP) for CAU 577 (DOE EM Nevada Program 2021b). The following closure activities were performed: • Constructing an engineered evapotranspiration cover • Installing two subsidence monuments and vadose zone monitoring equipment • Seeding the cover with a mixture of native plant species • Installing four concrete monuments on the corners of the cover and placing two use restriction (UR) warning signs on each monument These activities fulfill applicable federal and state regulations for closure of CAS 05-21-06 and minimize potential future exposure pathways to buried waste. Completed closure activities are also consistent with closure of the nine historical Resource Conservation and Recovery Act (RCRA) units included in Section 10.2.2 of the RCRA Permit that governs hazardous waste management activities at the Nevada National Security Site (Permit NEV HW0101) (NDEP 2023). UR documentation for this CAS is included in Appendix B of this report. The post-closure plan is presented in detail in the CADD/CAP for CAU 577 (DOE EM Nevada Program 2021b), and the requirements are summarized in Section 5.2 of this document. In accordance with paragraph 5D of the SA, a request to incorporate the requirements for post-closure monitoring of CAU 577 was included with the permit application for RCRA Permit NEV HW0101 that was submitted in January 2022 (NNSA/NFO 2022). The request included the post-closure requirements for the three CASs that had been closed at the time of submittal of the application as well as requirements that would be implemented upon future approval of closure of the remaining two CASs. All CAU 577 post-closure monitoring requirements have been captured in the April 4, 2023, Revision 7 of the RCRA Permit (NDEP 2023). As the RCRA Permit NEV HW0101 has been revised since the submittal of the original CAU 577 Closure Report (DOE EM Nevada Program 2021a) and Addendum 1 (DOE EM Nevada Program 2022), the post-closure requirements in this Addendum 2 report do not align with the previous documents. Specific changes resulting from the issuance of Revision 7 of the RCRA Permit are discussed in Section 5.2 of this report. The requirements in this report are consistent with the current permit (NDEP 2023) and supersede all requirements listed in the CAU 577 Closure Report and Addendum 1. All CAU 577 post-closure requirements should be conducted in accordance with the version of the RCRA Permit that is current at the time of the activities being performed. The DOE EM Nevada Program is requesting a Notice of Completion from NDEP for closure of CAU 577. Although CAU 577 is not a legacy site, the FFACO process is being followed to ensure proper closure of the chromium-containing waste. Therefore, transfer of CAU 577 from Appendix III of the FFACO to Appendix IV, Closed Corrective Action Units, is requested, as all closure activities have been completed.

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2016 Annual Reuse Report for the Idaho National Laboratory Site’s Advanced Test Reactor Complex Cold Waste Ponds

This report describes conditions and information, as required by the state of Idaho, Department of Environmental Quality Reuse Permit I-161-02, for the Advanced Test Reactor Complex Cold Waste Ponds located at Idaho National Laboratory from November 1, 2015–October 31, 2016. The effective date of Reuse Permit I-161-02 is November 20, 2014 with an expiration date of November 19, 2019. This report contains the following information: • Facility and system description • Permit required effluent monitoring data and loading rates • Permit required groundwater monitoring data • Status of compliance activities • Issues • Discussion of the facility’s environmental impacts. During the 2016 permit year, 180.99 million gallons of wastewater were discharged to the Cold Waste Ponds. This is well below the maximum annual permit limit of 375 million gallons. As shown by the groundwater sampling data, sulfate and total dissolved solids concentrations are highest in well USGS-065, which is the closest downgradient well to the Cold Waste Ponds. Sulfate and total dissolved solids concentrations decrease rapidly as the distance downgradient from the Cold Waste Ponds increases. Although concentrations of sulfate and total dissolved solids are significantly higher in well USGS-065 than in the other monitoring wells, both parameters remained below the Ground Water Quality Rule Secondary Constituent Standards in well USGS-065. The facility was in compliance with the Reuse Permit during the 2016 permit year.

2016 Annual Reuse Report for the Idaho National La↗

2012 Update to the Site Discharge Pollution Prevention Plan (Rev. 1): Overview

The U.S. Department of Energy (DOE) and Los Alamos National Security, LLC (LANS), collectively the Permittees, have prepared this Update to the Site Discharge Pollution Prevention Plan, Revision 1 (hereafter, the SDPPP Update) for the Individual Storm Water Permit pursuant to the requirements of National Pollutant Discharge Elimination System (NPDES) Permit No. NM0030759 (hereafter, the Individual Permit or Permit or IP), as authorized by the U.S. Environmental Protection Agency (EPA). The Individual Permit authorizes the discharge of storm water associated with historical industrial activities at Los Alamos National Laboratory (the Laboratory) from specified solid waste management units (SWMUs) and areas of concern (AOCs), collectively referred to as Sites. The Individual Permit does not regulate storm water discharges associated with current conventional industrial activities at the Laboratory. The Permit—NPDES No. NM0030759—incorporating the latest modifications became effective on November 1, 2010.

54 ENVIRONMENTAL SCIENCES↗

Corrective Action Management Unit Report of Post-Closure Care Activities (Calendar Year 2015)

The Corrective Action Management Unit (CAMU) at Sandia National Laboratories, New Mexico (SNL/NM) consisted of a containment cell, two treatment systems, and four associated waste staging and storage areas, and support areas; all were used for management of remediation wastes between 1997 and 2003. The U.S. Department of Energy and Sandia Corporation (Sandia) operated the CAMU in accordance with the requirements of: (1) The Class III Permit Modification Request for the CAMU (SNL/NM September 1997, as amended); and (2) Module IV of Permit NM5890110518, “Special Conditions Pursuant to the 1984 Hazardous and Solid Waste Amendments (HSWA) to Resource Conservation and Recovery Act (RCRA) for Sandia National Laboratory, U.S. Environmental Protection Agency (EPA) Identification Number NM5890110518,” August 1993, (EPA 1993, as amended) and subsequently administered by the New Mexico Environment Department (NMED). The CAMU underwent closure in 2003 in accordance with the Closure Plan in Appendix D of the Class III Permit Modification (SNL/NM September 1997). The containment cell was closed with wastes in place. Hazardous wastes were removed from all other CAMU systems and areas, and they underwent clean closure. The NMED approved completion of closure in May 2004 (Kieling May 2004). From May 2004 until February 2015, the containment cell underwent post-closure care (i.e., monitoring, inspections, maintenance, and repairs) in accordance with the Closure Plan. On December 19, 2014, NMED renewed the Hazardous Waste Facility Operating Permit (Permit) for Sandia National Laboratories. The renewed Permit was issued January 26, 2015 (NMED January 2015) with an effective date of February 26, 2015. The CAMU is undergoing post-closure care in accordance with the Permit.

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SolarAPP+ Enhancements and Commercialization (Final Technical Report)

With millions of distributed photovoltaic (PV) systems expected to be installed over the next five years, the permitting and inspection processes of authorities having jurisdiction (AHJs) may become overburdened, causing delays and increased costs for installed systems (Cruce et al. 2022). The central goal of this project was to automate and streamline permitting processes for distributed PV systems and complementary technologies, such as battery storage. Deploying automated permitting has been hypothesized to reduce permit review times, resulting in reduced costs and improved customer experience. This has the potential to expand the PV and PV-plus-storage market nationwide. The National Renewable Energy Laboratory (NREL) and its project partners, including UL Solutions, the Interstate Renewable Energy Council (IREC), the International Code Council (ICC), and more, developed the Solar Automated Permit Processing (SolarAPP+™) software platform to reduce permit review times. NREL and its partners also collaborated with the solar industry, the building safety community, and local governments to develop SolarAPP+.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

FutureGen 2.0 Pipeline and Regional Carbon Capture Storage Project - Final Report

The U.S. Department of Energy’s (DOE) FutureGen 2.0 Program involves two projects: (1) the Oxy-Combustion Power Plant Project and (2) the CO2 Pipeline and Storage Project. This Final Technical Report is focused on the CO2 Pipeline and Storage Project. The FutureGen 2.0 CO2 Pipeline and Storage Project evolved from an initial siting and project definition effort in Phase I, into the Phase II activity consisting permitting, design development, the acquisition of land rights, facility design, and licensing and regulatory approvals. Phase II also progressed into construction packaging, construction procurement, and targeted early preparatory activities in the field. The CO2 Pipeline and Storage Project accomplishments were significant, and in some cases unprecedented. The engineering, permitting, legal, stakeholder, and commercial learnings substantially advance the nation’s understanding of commercial-scale CO2 storage in deep saline aquifers. Voluminous and significant information was obtained from the drilling and the testing program of the subsurface, and sophisticated modeling was performed that held up to a wide range of scrutiny. All designs progressed to the point of securing construction contracts or comfort letters attesting to successful negotiation of all contract terms and willing execution at the appropriate time all major project elements – pipeline, surface facilities, and subsurface – as well as operations. While the physical installation of the planned facilities did not proceed in part due to insufficient time to complete the project prior to the expiration of federal funding, the project met significant objectives prior to DOE’s closeout decision. Had additional time been available, there were no known, insurmountable obstacles that would have precluded successful construction and operation of the project. Due to the suspension of the project, site restoration activities were developed and the work was accomplished. The site restoration efforts are also documented in this report. All permit applications had been submitted to all agencies for those permits or approvals required prior to the start of project construction. Most of the requisite permits were received during Phase II. This report includes information on each permitting effort. Successes and lessons learned are included in this report that will add value to the next generation of carbon storage efforts.

54 ENVIRONMENTAL SCIENCES↗

Corrective Action Management Unit Report of Post-Closure Care Activities Calendar Year 2017.

The Corrective Action Management Unit (CAMU) at Sandia National Laboratories, New Mexico (SNL/NM) consists of a containment cell and ancillary systems that underwent regulatory closure in 2003 in accordance with the Closure Plan in Appendix D of the Class 3 Permit Modification (SNL/NM September 1997). The containment cell was closed with wastes in place. On January 27, 2015, the New Mexico Environment Department (NMED) issued the Hazardous Waste Facility Operating Permit (Permit) for Sandia National Laboratories (NMED January 2015). The Permit became effective February 26, 2015. The CAMU is undergoing post-closure care in accordance with the Permit, as revised and updated. This CAMU Report of Post-Closure Care Activities documents all activities and results for Calendar Year (CY) 2017 as required by the Permit. The CAMU containment cell consists of engineered barriers including a cover system, a bottom liner with a leachate collection and removal system (LCRS), and a vadose zone monitoring system (VZMS). The VZMS provides information on soil conditions under the cell for early leak detection. The VZMS consists of three monitoring subsystems, which include the primary subliner (PSL), a vertical sensor array (VSA), and the Chemical Waste Landfill (CWL) sanitary sewer (CSS) line. The PSL, VSA, and CSS monitoring subsystems are monitored quarterly for soil moisture concentration, the VSA is monitored quarterly for soil temperature, and the VSA and CSS monitoring subsystems are monitored annually for volatile organic compound (VOC) concentrations in the soil vapor at various depths. Baseline data for the soil moisture, soil temperature, and soil vapor were established between October 2003 and September 2004.

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Stormwater Pollution Prevention Plan for the TA-60-02 Salvage Warehouse, Los Alamos National Laboratory, Revision 3, January 2018

This Storm Water Pollution Prevention Plan (SWPPP) was developed in accordance with the provisions of the Clean Water Act (33 U.S.C. §§1251 et seq., as amended), and the Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activity (U.S. EPA, June 2015) issued by the U.S. Environmental Protection Agency (EPA) for the National Pollutant Discharge Elimination System (NPDES) and using the industry specific permit requirements for Sector P-Land Transportation and Warehousing as a guide. The applicable stormwater discharge permit is EPA General Permit Registration Number NMR053915 (Los Alamos National Security (LANS) (U.S. EPA, June 2015). Contents of the June 4, 2015 Multi-sector General Permit can be viewed at: https://www.epa.gov/sites/production/files/2015- 10/documents/msgp2015_finalpermit.pdf This SWPPP applies to discharges of stormwater from the operational areas of the TA-60-02 Salvage and Warehouse facility at Los Alamos National Laboratory. Los Alamos National Laboratory (also referred to as LANL or the “Laboratory”) is owned by the Department of Energy (DOE), and is operated by Los Alamos National Security, LLC (LANS). Throughout this document, the term “facility” refers to the TA-60-02 Salvage/ Warehouse and associated areas. The current permit expires at midnight on June 4, 2020. A copy of the facility NOI and LANS Delegation of Authority Letter are located in Appendix C of this SWPPP.

54 ENVIRONMENTAL SCIENCES↗

Stormwater Pollution Prevention Plan, TA-03-38 Carpenter's Shop, Revision 4: LANS Archived 2019

This Storm Water Pollution Prevention Plan (SWPPP) was developed in accordance with the provisions of the Clean Water Act (33 U.S.C. §§1251 et seq., as amended), and the Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activity (U.S. EPA, June 2015) issued by the U.S. Environmental Protection Agency (EPA) for the National Pollutant Discharge Elimination System (NPDES) and using the industry specific permit requirements for Sector A–Timber Products, Subsector A4 (Wood Products Facilities not elsewhere classified) as a guide. The applicable stormwater discharge permit is EPA General Permit Registration # NMR053915 (Los Alamos National Security (LANS) (U.S. EPA, June 2015). This SWPPP applies to discharges of stormwater from the operational areas of the TA-03-38 Carpenter’s Shop at Los Alamos National Laboratory. Los Alamos National Laboratory (also referred to as LANL or the “Laboratory”) is owned by the Department of Energy (DOE), and is operated by Los Alamos National Security, LLC (LANS). Throughout this document, the term “facility” refers to the TA-03-38 Carpenter’s Shop and associated areas. The current permit expires at midnight on June 4, 2020. As the LANS contract ended for LANL MSGP facilities on October 31, 2018, a Notice of Termination (NOT) for permit coverage was filed and is effective as of 11/02/18. A copy of the NOT acknowledgment is located in Appendix C of this SWPPP. This is the archived and final revision of the SWPPP for LANS.

54 ENVIRONMENTAL SCIENCES↗

Stormwater Pollution Prevention Plan, TA-60-02 Salvage/Warehouse, Revision 4: LANS Archived 2019

This Storm Water Pollution Prevention Plan (SWPPP) was developed in accordance with the provisions of the Clean Water Act (33 U.S.C. §§1251 et seq., as amended), and the Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activity (U.S. EPA, June 2015) issued by the U.S. Environmental Protection Agency (EPA) for the National Pollutant Discharge Elimination System (NPDES) and using the industry specific permit requirements for Sector P-Land Transportation and Warehousing as a guide. The applicable stormwater discharge permit is EPA General Permit Registration Number NMR053915 (Los Alamos National Security (LANS) (U.S. EPA, June 2015). This SWPPP applies to discharges of stormwater from the operational areas of the TA-60-02 Salvage and Warehouse facility at Los Alamos National Laboratory. Los Alamos National Laboratory (also referred to as LANL or the “Laboratory”) is owned by the Department of Energy (DOE), and is operated by Los Alamos National Security, LLC (LANS). Throughout this document, the term “facility” refers to the TA-60-02 Salvage/ Warehouse and associated areas. The current permit expires at midnight on June 4, 2020. As the LANS contract ended for LANL MSGP facilities on October 31, 2018, a Notice of Termination (NOT) for permit coverage was filed and is effective as of 11/02/18. A copy of the NOT acknowledgment is located in Appendix C of this SWPPP. This is the archived and final revision of the SWPPP for LANS.

54 ENVIRONMENTAL SCIENCES↗

Stormwater Pollution Prevention Plan, TA-03-38 Metals Fabrication Shop, Revision 4: LANS Archived 2019

This Storm Water Pollution Prevention Plan (SWPPP) was developed in accordance with the provisions of the Clean Water Act (33 U.S.C. §§1251 et seq., as amended), and the Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activity (U.S. EPA, June 2015) issued by the U.S. Environmental Protection Agency (EPA) for the National Pollutant Discharge Elimination System (NPDES) and using the industry specific permit requirements for Sector AA-Fabricated Metal Products as a guide. The applicable stormwater discharge permit is EPA General Permit Registration Number NMR053915 (Los Alamos National Security (LANS) (U.S. EPA, June 2015).This SWPPP applies to discharges of stormwater from the operational areas of the TA-03-38 Metals Fabrication Shop at Los Alamos National Laboratory. Los Alamos National Laboratory (also referred to as LANL or the “Laboratory”) is owned by the Department of Energy (DOE), and is operated by Los Alamos National Security, LLC (LANS). Throughout this document, the term “facility” refers to the TA-03-38 Metals Fabrication Shop and associated areas. The current permit expires at midnight on June 4, 2020. As the LANS contract ended for LANL MSGP facilities on October 31, 2018, a Notice of Termination (NOT) for permit coverage was filed and is effective as of 11/02/18. A copy of the NOT acknowledgment is located in Appendix C of this SWPPP. This is the archived and final revision of the SWPPP for LANS.

54 ENVIRONMENTAL SCIENCES↗

Corrective Action Management Unit Report of Post-Closure Care Activities Calendar Year 2019

The Corrective Action Management Unit (CAMU) at Sandia National Laboratories, New Mexico (SNL/NM) consists of a containment cell and ancillary systems that underwent closure in 2003 in accordance with the Closure Plan in Appendix D of the Class 3 Permit Modification (SNL/NM September 1997). The containment cell was closed with wastes in place. On January 27, 2015, the New Mexico Environment Department (NMED) issued the Hazardous Waste Facility Operating Permit (Permit) for Sandia National Laboratories (NMED January 2015) to the U.S. Department of Energy/National Nuclear Security Administration (DOE/NNSA) and its Management and Operating (M&O) contractor. The current M&O contractor is National Technology & Engineering Solutions of Sandia, LLC (NTESS). The Permit became effective February 26, 2015. The CAMU is undergoing post-closure care in accordance with the Permit, as revised and updated. This CAMU Report of Post-Closure Care Activities documents all activities and results for calendar year (CY) 2019, as required by the Permit.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Corrective Action Management Unit Report of Post-Closure Care Activities (CY 2018)

The Corrective Action Management Unit (CAMU) at Sandia National Laboratories, New Mexico (SNL/NM) consists of a containment cell and ancillary systems that underwent regulatory closure in 2003 in accordance with the Closure Plan in Appendix D of the Class 3 Permit Modification (SNL/NM September 1997). The containment cell was closed with wastes in place. On January 26, 2015, the New Mexico Environment Department (NMED) issued the Hazardous Waste Facility Operating Permit (Permit) for Sandia National Laboratories (NMED January 2015). The Permit became effective February 26, 2015. The CAMU is undergoing post-closure care in accordance with the Permit, as revised and updated. This CAMU Report of Post-Closure Care Activities documents all activities and results for calendar year (CY) 2018 as required by the Permit.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Corrective Action Management Unit Report of Post-Closure Care Activities. Calendar Year 2020

he Corrective Action Management Unit (CAMU) at Sandia National Laboratories, New Mexico (SNL/NM) consists of a containment cell and ancillary systems that underwent closure in 2003 in accordance with the Closure Plan in Appendix D of the Class 3 Permit Modification (SNL/NM September 1997). The containment cell was closed with wastes in place. On January 27, 2015, the New Mexico Environment Department issued the Hazardous Waste Facility Operating Permit (Permit) for Sandia National Laboratories (NMED January 2015) to the U.S. Department of Energy/National Nuclear Security Administration (DOE/NNSA) and its Management and Operating (M&O) contractor. The current M&O contractor is National Technology & Engineering Solutions of Sandia, LLC (NTESS). The Permit became effective February 26, 2015. The CAMU is undergoing post-closure care in accordance with the Permit, as revised and updated. This CAMU Report of Post-Closure Care Activities documents all activities and results for calendar year (CY) 2020, as required by the Permit.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada (CY2021)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): CAU 90, Area 2 Bitcutter Containment, CAU 91, Area 3 U-3fi Injection Well, CAU 92, Area 6 Decon Pond Facility, CAU 110, Area 3 WMD U-3ax/bl Crater, CAU 111, Area 5 WMD Retired Mixed Waste Pits, and CAU 112, Area 23 Hazardous Waste Trenches. This report covers calendar year 2021. The post-closure requirements for these sites are described in RCRA Permit NEV HW0101 and are summarized in each CAU-specific section of this report. The results of the inspections, a summary of maintenance activities, and an evaluation of monitoring data are presented in this report. This report will address all monitoring requirements noted in the RCRA Permit NEV HW0101, except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site. All required inspections, maintenance, and monitoring were conducted in accordance with the post-closure requirements of the permit. Revision 6 of RCRA Permit NEV HW0101 was issued effective December 10, 2015, and remained in effect until December 10, 2020. At the time of this report submittal, the new RCRA permit application was in review.

54 ENVIRONMENTAL SCIENCES↗

Innovative Advanced Hydrogen Mobile Fueler (Final Technical Report)

The US Department of Energy (DOE) funded a project to design, develop, deploy and analyze the economic viability of an innovative Advanced Hydrogen Mobile Fueler (AHMF). As part of the design activity the project team defined specifications based upon vehicle requirements and compliance with specific fueling performance criteria. The AHMF was originally designed to fuel 10-20 fuel cell vehicles (FCV) per day, consistent with the requirements of the H70 fueling category. The AHMF is able to operate without remote power connections, is modular for easy transport and deployment, and can provide expanded daily capacity and multi-day operations using delivered gaseous hydrogen. Toward the end of the project, due to request from the hydrogen industry and some necessary modifications of the AHMF, the system is now modified to fuel heavy duty vehicles. The project was conducted over two primary phases, each including several key tasks, subtasks, and project milestones. Phase 1 involved the design, development, and construction of the AHMF, moving from a conceptual design through to completion of assembly and testing. In addition to reviewing several different approaches, the team chose to take a conventional station design and modify it for mobile fueling. There were several innovative components included in the design. The high pressure storage was the first to achieve a US Department of Energy (DOE) Special Permit (SP 20391) to transport high pressure hydrogen (95 MPa) in a composite cylinder. The second novel system was a liquid nitrogen (LIN) cooling system with a compact heat exchanger. Without this change, the cooling system would not be able to fit into the AHMF. Phase 2 demonstrated the AHMF by fueling fuel cell buses at a fleet in Pomona, CA. The site was chosen because a temporary fueling solution was required while a fixed station was being installed. The existing permits for the fixed station and non-public access also was a determining factor. Over two months, the buses were fueled 320 times with over 5000 kg of hydrogen from tube trailers. Existing shore power was used, and the average electrical efficiency was 0.13 kWh/kg. The average liquid nitrogen (LIN) consumption was 90.68 scf/kg. The fueling and consumption data was provided to the National Renewable Energy Laboratory (NREL) for analysis. An economic analysis was performed and will be provided in a separate report. The project was successful, but not without challenges and lessons learned. The DOT special permit led the way for the use of high pressure, composite cylinders and is being by multiple other systems and applications. The pandemic along with time for the DOT special permit approval delayed the project for years. The team also believes that hydrogen mobile fueling has a use for the industry, especially during this upcoming phase of expansion. However, it does have its limitations due to high cost to build and operate, and the same permitting challenges as a fixed station. A fully capable system at the speeds and pressures of the AHMF may not be necessary for most applications and would help reduce the cost and increase storage capacity. The on-board generator can be easily replaced with shore power or the wide range of power generation solutions in the marketplace. One of the major results of the project was the development of new code language in National Fire Protection Agency (NFPA) 2 and the International Fire Code (IFC) for on-demand mobile fueling. This will provide guidance for Authorities Having Jurisdiction (AHJ) and user on how to permit temporary fueling sites across the nation.

08 HYDROGEN↗