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Notice of Submittal – 2023 Radionuclide Air Emissions Report for Los Alamos National Laboratory

This report describes the emissions of airborne radionuclides from operations at Los Alamos National Laboratory (LANL) for calendar year 2023 and the resulting off-site dose from these emissions. This document fulfills the requirements established by the National Emissions Standards for Hazardous Air Pollutants in 40 CFR 61, Subpart H – Emissions of Radionuclides other than Radon from Department of Energy Facilities, commonly referred to as the Radionuclide NESHAP or Rad-NESHAP. Compliance with this regulation and preparation of this document is the responsibility of LANL’s Rad NESHAP compliance program, which is part of the Environmental Protection and Compliance (EPC) Division. The information in this report is required under the Clean Air Act and is being submitted to the U.S. Environmental Protection Agency (EPA) Headquarters and EPA Region 6. The highest effective dose equivalent (EDE) to an off-site member of the public was calculated using procedures specified by the EPA and described in this report. LANL’s EDE was 0.43 for 2023. The annual limit is 10 millirem per year, established by the EPA in 40 CFR 61 Subpart H. All measured air emissions are modeled to a single location, known as the Maximally Exposed Individual (MEI). During calendar year 2023, LANL continuously monitored radionuclide emissions at 28 “major” release points, or stacks. The Laboratory estimates emissions from an additional 59 “minor” release points using radionuclide usage source terms in lieu of stack monitoring. Also, LANL uses an EPA approved network of air samplers around the Laboratory perimeter to monitor ambient airborne levels of radionuclides. To provide data for dispersion modeling and dose assessment, LANL maintains and operates several meteorological monitoring towers. From these various systems, a comprehensive evaluation is conducted to calculate the MEI dose for the Laboratory. The MEI can be any member of the public at any off-site location where there is a residence, school, business, or office. In 2023, this MEI location was a business at 129 New Mexico State Road 4 (NM-4), located in the northern end of White Rock. The primary contributors to the off-site dose at this location are the ambient air data at that location combined with the collected potential emissions from unmonitored (minor) sources. Overall, the MEI dose in 2023 is similar to that which has been observed in recent years, and it remains well below the EPA’s 10 millirem per year limit. Doses reported to the EPA for the past 10 years are shown in Table E1.

54 ENVIRONMENTAL SCIENCES↗

2019 LANL Radionuclide Air Emissions Report

In June 2020, Los Alamos National Laboratory (LANL) submitted letter ESHQSS: 20-025 to Region 6 of the Unites States Environmental Protection Agency (EPA). This letter transmitted the 2019 LANL Radionuclide Air Emissions Report to the EPA. This report summarizes LANL operations, air emissions of radionuclides, and subsequent off-site dose consequence from these emissions for calendar year 2019. This report is issued to meet requirements of 40 CFR 61 Subpart H, National Emission Standards for Emissions of Radionuclides other than Radon from Department of Energy Facilities. This regulation, called the Radionuclide NESHAP, establishes a limit of 10 millirem per year to the maximally exposed member of the public and requires an annual report to be submitted to the appropriate EPA Region by June 30th of each year. LANL’s off-site dose from airborne emissions of radionuclides in 2019 was 0.43 millirem. The normal practice is to issue this report directly to EPA Region 6 in June of each year, and then after the report is accepted by the EPA, re-issue the report for inclusion in the LANL Electronic Public Reading Room (EPRR). This second part is usually done in July of each year, but this step was overlooked in July 2020 due to other commitments. We regret this error. This omission was noted in late 2020; we are submitting the 2019 LANL Radionuclide Air Emissions Report to the EPRR now in December 2020. Aside from the addition of this cover sheet explaining the delay, the report is unchanged from the version submitted to EPA Region 6 in June.

54 ENVIRONMENTAL SCIENCES↗

Application of pH-dependent environmental protection agency test method 1313 to low-activity nuclear waste glass

Here, in this study, we present results of a room temperature, pH-dependent leach test established by United States Environmental Protection Agency (EPA) Leaching Environmental Assessment Framework (LEAF) (EPA Method 1313 and further abbreviated EPA 1313) to study the alteration behavior of low-activity nuclear waste (LAW) glasses. Implementation of EPA 1313, which is closer to LAW disposal temperatures, could allow for more flexibility in the formulation of Hanford LAW glasses, specifically in terms of increased waste loading. A set of 48 LAW glasses were selected to test with EPA 1313. Briefly, the test method consists of adding glass to a number of solutions at different initial pH values and at a fixed mass-to-solution-volume ratio. The glass is then allowed to corrode for two days and the final solution pH and concentration of different glass elements in solution is measured. The test was modified from the published procedure to constrain particle size to provide more reproducible results, reduce the studied pH range to a more applicable range, and to reduce solution volume to reduce costs associated with material preparation. Compositional modeling was used to predict the measured elemental releases at various pH. The model predictions improved in tests where there was a relatively small difference between initial and final solution pH indicating that pH controls would result in better predictive models.

Accelerated aging↗

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

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

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Multi-State Transportation Electrification Impact Study: Preparing the Grid for Light-, Medium-, and Heavy-Duty Electric Vehicles

Recent U.S. Environmental Protection Agency (EPA) notices of proposed rulemakings for GHG emissions standards for light-, medium-, and heavy-duty on-road vehicles would accelerate ongoing advancements already happening in the industry because of private investment, consumer demand, state-level policies, and federal incentives. As the EPA finalizes these regulations, questions persist regarding the cost of the requisite charging infrastructure and associated upgrades to the nation's electric grid. With support from the U.S. Department of Energy, U.S. Joint Office of Energy and Transportation, and the EPA, a multidisciplinary team conducted a Multi-State Transportation Electrification Impact Study that quantitatively assesses the incremental investment necessary to enable the levels of vehicle electrification expected to be induced by pending EPA regulations and to estimate the potential value of deferred investments in electric distribution infrastructure stemming from proactive vehicle-grid integration planning and deployment. This study finds the simulated incremental capital cost of charging infrastructure (including grid upgrades) to be at least 2.5 times smaller than the lifetime net benefits of vehicle electrification (including fuel savings but excluding the value of avoided emissions). Additionally, the incremental distribution grid upgrade cost of the EPA Action-Unmanaged scenario was found to be approximately 3% of existing utility distribution system investments (on an annual basis). Finally, the potential for managed charging to defer distribution grid upgrades was found to be significant with costs found to decrease from $2.3 billion to an incremental cost of $1 billion across five states in the Action-Managed scenario (relative to the No Action-Unmanaged scenario).

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Transportation Electrification Impact Study (TEIS)

Recent U.S. Environmental Protection Agency (EPA) notices of proposed rulemakings for GHG emissions standards for light-, medium-, and heavy-duty on-road vehicles would accelerate ongoing advancements already happening in the industry because of private investment, consumer demand, state-level policies, and federal incentives. As the EPA finalizes these regulations, questions persist regarding the cost of the requisite charging infrastructure and associated upgrades to the nation's electric grid. With support from the U.S. Department of Energy, U.S. Joint Office of Energy and Transportation, and the EPA, a multidisciplinary team conducted a Multi-State Transportation Electrification Impact Study that quantitatively assesses the incremental investment necessary to enable the levels of vehicle electrification expected to be induced by pending EPA regulations and to estimate the potential value of deferred investments in electric distribution infrastructure stemming from proactive vehicle-grid integration planning and deployment. This study finds the simulated incremental capital cost of charging infrastructure (including grid upgrades) to be at least 2.5 times smaller than the lifetime net benefits of vehicle electrification (including fuel savings but excluding the value of avoided emissions). Additionally, the incremental distribution grid upgrade cost of the EPA Action-Unmanaged scenario was found to be approximately 3% of existing utility distribution system investments (on an annual basis). Finally, the potential for managed charging to defer distribution grid upgrades was found to be significant with costs found to decrease from $2.3 billion to an incremental cost of $1 billion across five states in the Action-Managed scenario (relative to the No Action-Unmanaged scenario).

ADVANCED PROPULSION SYSTEMS,POWER TRANSMISSION AND↗

Hybrid Sorbents for 129 I Capture from Contaminated Groundwater

Radioiodine ( 129 I) poses a risk to the environment due to its long half-life, toxicity, and mobility. It is found at the U.S. Department of Energy Hanford Site due to legacy releases of nuclear wastes to the subsurface where 129 I is predominantly present as iodate (IO 3 – ). To date, a cost-effective and scalable cleanup technology for 129 I has not been identified, with hydraulic containment implemented as the remedial approach. Here, novel high-performing sorbents for 129 I remediation with the capacity to reduce 129 I concentrations to or below the US Environmental Protection Agency (EPA) drinking water standard and procedures to deploy them in an ex-situ pump and treat (P&T) system are introduced. Furthermore, this includes implementation of hybridized polyacrylonitrile (PAN) beads for ex-situ remediation of IO 3 – -contaminated groundwater for the first time. Iron (Fe) oxyhydroxide and bismuth (Bi) oxyhydroxide sorbents were deployed on silica substrates or encapsulated in porous PAN beads. In addition, Fe–, cerium (Ce)–, and Bi–oxyhydroxides were encapsulated with anion-exchange resins. The PAN–bismuth oxyhydroxide and PAN–ferrihydrite composites along with Fe- and Ce-based hybrid anion-exchange resins performed well in batch sorption experiments with distribution coefficients for IO 3 – of >1000 mL/g and rapid removal kinetics. Of the tested materials, the Ce-based hybrid anion-exchange resin was the most efficient for removal of IO 3 – from Hanford groundwater in a column system, with 50% breakthrough occurring at 324 pore volumes. The functional amine groups on the parent resin and amount of active sorbent in the resin can be customized to improve the iodine loading capacity. These results highlight the potential for IO 3 – remediation by hybrid sorbents and represent a benchmark for the implementation of commercially available materials to meet EPA standards for cleanup of 129 I in a large-scale P&T system.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗

Trimethyloxonium-mediated methylation strategies for the rapid and simultaneous analysis of chlorinated phenols in various soils by electron impact gas chromatography–mass spectrometry

Abstract The efficient methylation of a panel of five industrial and environmentally-relevant chlorophenols (CPs) employing trimethyloxonium tetrafluoroborate (TMO) for their qualitative detection and identification by electron impact gas chromatography–mass spectrometry (EI-GC–MS) is presented. The protocol’s execution is simple and smoothly converts the phenols into their O-methylated counterparts conveniently at ambient temperature. The efficiency of two versions of the protocol was successfully tested in their ability to simultaneously derivatize five CPs (2-chlorophenol, 2,4-dichlorophenol, 2,4,6-trichlorophenol, pentachlorophenol and triclosan) in six distinct, separate soil matrices (Nebraska EPA standard soil, Virginia Type A soil, Ottawa sand, Baker sand, Silt and Georgia EPA standard soil) when present at low levels (~ 10 μgg −1 ). The first version involves the direct derivatization of the spiked soils with the methylating salt while the second one involves an initial soil extraction step of the CPs followed by methylation. The MDL values for each methylated CP were determined and lower values were found (4.1–13.2 ng . mL −1 ) for both sand matrices (Ottawa and Baker) as well as for the Georgia EPA standard soil, while larger values (8.2–21.8 ng . mL −1 ) were found for the Virginia Type soil, Nebraska EPA standard soil and Silt. The presented protocol offers a safer and more practical alternative to the universally employed diazomethane method and can be readily applicable to matrices other than soils. Furthermore, the protocols described herein may find applicability to the methylation of other analytes bearing acidic protons.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗

Updated External Exposure Dose Coefficients

In 2018, the Environmental Protection Agency (EPA) updated and expanded the Federal Guidance Report (FGR) No. 12 to No. 15; tabulating age-specific external exposure effective dose rate coefficients for 1,252 radionuclides in the air, water, and soil (EPA 2018). However, the EPA discovered errors in the tables of dose coefficients for soil which led to the report being retracted for correction. This led to the adoption of “a uniform method of data-smoothing and extrapolation of monoenergetic organ doses at low energies across all exposure pathways; the originally-published dose coefficients utilized different methods for each media type” (EPA 2019). This resulted in all the external exposure dose coefficients being updated and FGR 15 being republished in August 2019 with corrected tables.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Joint Comments from the Department of Energy, National Nuclear Security Administration (DOE NNSA) Los Alamos Field Office and Triad National Security, LLC on the U.S. Environmental Protection Agency’s New Mexico State-Wide Municipal Separate Storm Sewer System Strawman General Permit

In December 2020 and March 2021, EPA issued two MS4 strawman permit drafts specific to the Los Alamos area. EPA made text changes in the 2 nd strawman permit based on stakeholder comments related to the initial draft. During the public meeting on the Los Alamos area designation decision held on February 13, 2024, EPA staff stated that comments from the past strawman permits would be incorporated into the new MS4 permit to be issued state-wide. However, it does not appear that any of the text changes from the 2 nd Los Alamos area strawman permit were included in this state-wide general MS4 strawman permit. For reference, the 2 nd Los Alamos area revised strawman permit is included with these comments as Attachment 2. Many of the following comments refer to or state EPA’s updated text included in the 2 nd Los Alamos area strawman permit. The updated text from this 2 nd strawman permit that are referenced in the following comments should be applicable state-wide and it is suggested that this past work be reconsidered and incorporated.

54 ENVIRONMENTAL SCIENCES↗

Engineered Solutions Group's SMR Containment Cable and Electrical Penetration Assembly System

GAIN Project CRADA Number NFE-21-08839, entitled “SMR Containment Cable and EPA System” was initiated by the partnership of Oak Ridge National Laboratory (ORNL) and Engineered Solutions Group (ESG) to test an ESG-designed Electrical Penetration Assembly and Containment Cabling System Qualified for not only legacy LWR designs, but also Small Modular Reactors designs currently being designed by several different suppliers. This project was undertaken to fill the equipment gap of EPA and Cabling Systems that require much more severe environmental requirements than legacy plant applications present due to their smaller containment volumes that result in high energy densities compared to legacy designs. This high energy density results in severe accident environments and more severe normal operating conditions as well. We developed two approaches to qualify Electrical Penetration Assembly (EPA) and Containment Cabling Systems for SMRs and Advanced Reactors. We take into consideration the more severe environmental parameters found with SMR designs. The system will need to meet a qualification test program addressing wear/cyclic aging, potential radiation exposure, thermal aging, vibration aging, thermal cycling, seismic qualification, electrical fault testing (per IEEE 317) and accident simulation. The equipment must meet the requirements of 10CFR50.49, GDC 50 in 10CFR50 Appendix A, and 10CFR50 Appendix J. NRC Regulatory Guides (RGs) identify an acceptable way of meeting regulatory requirements. RGs frequently endorse a standard for meeting these requirements. Specific to this review, equipment would be qualified in accordance with the following IEEE Standards. • IEEE 317-2013 (Electrical Penetration Assemblies), which is endorsed by RG 1.63, Rev. 3, • IEEE 323-2003 and the more current IEC/IEEE 60780-323 (Environmental Qualification of 1E Equipment) which is endorsed by RG 1.89. IEEE 323-2003 is endorsed by RG 1.209, • IEEE 344-2020 (Seismic Qualification. The 2013 version endorsed by RG 1.100, Rev. 4, with exceptions), • IEEE 383-2015 (Electrical Cables) (which is endorsed by RG 1.189 Rev. 4 and the -2003 version endorsed by RG 1.211 rev. 0), • IEEE 572-2019 (Electrical Connectors and Assemblies), which is endorsed by 1.156 Rev 1, and • [IEEE 1202 (endorsed by RG 1.189) would normally be applicable but the advanced cable designs are impervious to this cable flame test.] The primary goal of such a program is to provide an EPA design that can meet the qualification requirements for all legacy light water reactor plants currently operating as well as new plant designs including light water Small Modular Reactors. Thus, these requirements are applicable to plants licensed under 10CFR50 and 10CFR52. Other reactor designs may be evaluated, and this test system and qualification method applied to those applications if the requirements would satisfy the requirements of the intended plant. A secondary benefit of this work is to document some of the history and background in these requirements as there have been recent delays in an SMR licensing process due to NRC Requests for Additional Information in this subject matter area.

42 ENGINEERING↗

Hydropower Infrastructure - LAkes, Reservoirs, and RIvers (HILARRI), v4

HILARRI is a database of links between major datasets of operational hydropower dams and powerplants, and inland water bodies. These connections are critical for conducting large-scale analysis of hydropower infrastructure and their associated natural and engineered water systems. Features include: – Dams from the National Inventory of Dams (2025) and the Global Reservoir and Dam Database (GRanD v1.3) – Hydropower plants from the Existing Hydropower Assets dataset (EHA 2025) – Power plants that are listed in the 2025 U.S. Hydropower Development Pipeline Data or were listed in previous versions of the dataset These hydropower infrastructure features are linked to several major datasets that provide hydrologic and hydraulic information relevant for analysis of hydropower systems that includes the integral water resources. That information comes from: – Products from the National Hydrography Dataset (NHD) – NHDPlusV2 Medium Resolution river network flowlines, – NHD waterbodies (limited to lakes and reservoirs), – NHD Watershed Boundary Dataset (HUC12-level for the Conterminous United States (CONUS)) – NHD High Resolution waterbodies – HydroLAKES water bodies (lakes and reservoirs) – LAGOS-US lakes and reservoirs – EPA National Lakes Assessment (2007, 2012, 2017, and 2022) – The Reservoir Sedimentation Database (RESSED) – EPA SuRGE sampling locations Unique identifiers are used to facilitate joining to the original full datasets. For example, characteristics of NHD flowlines such as estimated average flow rate can be joined from the NHDPlusV2 dataset to a dam or power plant listed in HILARRI based on the ID field, “COMID”, that is common to both datasets. HILARRI only includes basic information about identifiers, location, and data quality or usage notes. It does not contain the attributes or time series data associated with these sites. The HILARRI dataset incorporates information from several datasets to facilitate more effective and accurate analysis of hydropower infrastructure and their associated waterbodies. For example, dams were checked against the most recent American Rivers Dam Removal Database to identify and flag facilities that may no longer exist. Additionally, dams that are listed multiple times in the NID are identified and flagged to avoid double-counting when analyzing and summarizing information. Other quality flags include certainty of operational hydropower (i.e., if one or more datasets indicates hydropower at a particular location), whether an associated water body is accurate or composed of multiple polygons, or whether there is a known issue with reported characteristics in one of the underlying datasets. These additional data flags are designed to increase confidence in data usage for individual to large-scale analyses.

Hansen, Carly [ORNL] (ORCID:0000000193280838)↗

Middlesex South FUSRAP Site: Collaboration Towards Beneficial Reuse - 20338

The US Department of Energy (DOE) Office of Legacy Management (LM) manages DoE's post-closure responsibilities and ensures the future protection of human health and the environment with respect to sites that have no continuing DOE mission after undergoing remediation. LM's beneficial reuse program promotes the LM strategic goal to sustainably manage and optimize use of public lands. The beneficial reuse program aims to repurpose former contaminated sites to restore the environment, protect the public health, revitalize communities, and spur economic growth. Benefits from the reuse of a site may increase the local tax base, facilitate job growth, utilize existing infrastructure, and enhance or protect natural resources. Beneficial reuse also promotes protectiveness by ensuring activities are compatible with long-term maintenance and protection of public health and the environment, as well as by retaining good stewardship of natural resources. LM actively participates in promoting the economic development vision of the surrounding communities by collaborating with local communities to promote regional or municipal initiatives. The Borough of Middlesex, New Jersey, has prepared the Lincoln Boulevard Redevelopment Plan, which will reinvent a once-viable downtown and enhance the quality of life for the community. The Middlesex South, New Jersey, Formerly Utilized Sites Remedial Action Program (FUSRAP) site lies within the boundaries of this redevelopment area. In support of this development plan, the Borough is interested in acquiring the site for its Department of Public Works and to increase street access in the future commercial district to be built near adjacent properties. The opportunity to put the FUSRAP site into productive use aligns with LM's mission and strategic goals. In support of beneficial reuse activities, DOE can dispose of excess real property using several mechanisms. The two disposal options applicable to the Middlesex south site include (1) utilizing the US General Services Administration (GSA) or (2) using the Title 10 Code of Federal Regulations Section 770, 'Transfer of Real Property at Defense Nuclear Facilities for Economic Development' (known as a '770 transfer') process. Using the 770 transfer requires economic development as the primary driver, and a specific redevelopment proposal must be submitted. If there is no interest in specific economic development, the GSA option becomes the default mechanism for disposal of the property. In the case of the Middlesex south site, the 770 transfer process is being utilized and the Borough has submitted its economic development proposal to LM. Although LM is encouraged by the opportunity to put the site into productive use, the Middlesex south site is currently on the US Environmental Protection Agency (EPA) National Priorities List and remediation is being performed by the US Army Corp of Engineers (USACE) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Consequently, any property transfer must meet the requirements under CERCLA Section 120(h), 'Property Transferred by Federal Agencies.' As the groundwater remedy will not be in place for several years, approval would be required from the US EPA administrator and the governor of the state of New Jersey to perform an early transfer of the site (before all response actions have been completed). The time frame for these approvals to occur under the normal process conflicts with the proposed redevelopment schedule; therefore, various options for expedited sale, transfer, or lease of portions of the site to the Borough were evaluated. The subsequent decision on a mutually beneficial path forward was the result of a collaborative effort between LM, USACE, the Borough and its redevelopment team, EPA, and the New Jersey Department of Environmental Protection. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Low Count and Background Radionuclides Analysis - 20488

The US Department of Energy (DOE) is often faced with the need to evaluate radionuclides at low concentrations. When site sample data are likely to be close to threshold activity concentrations of interest, then the means by which the radiochemical analysis is performed and reported is critical. This situation can occur when differentiating from zero (presence/absence) for radionuclides that do not occur naturally, close comparison with environmental background for naturally occurring radionuclides, close comparison with a risk- or dose-based threshold concentrations of interest, or even comparisons across studies. There are several analytical issues that are of concern, but the two that appear to cause incorrect decisions to be made most often involve establishing detection limits and subtracting ambient background conditions in the laboratory. These issues are not critical when radionuclide activity concentrations are large relative to thresholds of concern, but they seem to be poorly understood when it matters. When the comparisons are important and are likely to be close to a threshold of interest, then the general contract with the analytical laboratories needs to be changed so that the right or appropriate data are obtained. The concern is that important decisions are made incorrectly more often as greater scrutiny is placed on DoE's radionuclide cleanup or monitoring decisions by the public and other stakeholders. Examples are presented of problems that have been observed for different projects, both within and outside the realm of DOE and NRC remediation and radioactive waste disposal problems, and solutions are offered that should lead to better data from which important decisions need to be made. The first example is from Los Alamos National Laboratory (LANL) and involves radionuclide concentrations in soil and rock beneath LANL's Material Disposal Area (MDA) G. An initial review of the data led to a conclusion that americium and plutonium are a long way present beneath MDA G. A more thorough review of the data that accounted properly for ambient background and the detection limits that had been established led to the opposite conclusion. Another example is from the Nevada National Security Site where tritium results from one of the wells were unexpectedly high. Proper understanding and analysis of ambient background led to the conclusion that the increased concentrations were not so obvious, and that a different contract with the analytical laboratory was needed to provide more appropriate data to support a better determination. Other examples are used from regulatory review of projects in Nevada, where background levels and secular equilibrium for naturally occurring radionuclides are not established correctly because of analytical issues. The same basic issues have also been found to create difficulties analyzing historical data from the West Valley Demonstration Project. There is evidence in the data that the apparent lack of secular equilibrium where it is expected to exist is related to ambient background subtraction or other analytical issues. A final example is presented for analysis of Tc-99 in samples of depleted uranium. In this case, two different studies that were performed only three months apart provide quite different results. The US Environmental Protection Agency (EPA) established the data quality objectives (DQO) process in the mid-1980's to establish decision performance criteria for data collection. EPA guidance (EPA G-4, for example) clearly distinguishes between DQOs and measurement performance objectives (MQOs) that should be addressed for laboratory analysis of samples. The language of DQOs and MQOs has become confused over time it seems, and the subsequent effects seem to include a lack of attention to decision performance and a routine approach to measurement quality. In order to better address radionuclide sample analysis when the concentrations are close to thresholds of concern, which might be zero for some radionuclides, background for others, and risk-based thresholds for yet others, it is important that routine laboratory analysis methods are adjusted, and that the project team and the laboratory work closely together to ensure that the data meets the MQO requirements of laboratory analysis and reporting of results, and that the MQOs effectively support project-specific DQOs. This basic approach will be applied in Los Alamos in the coming year to the collection of moisture data from underneath MDA T that will be analyzed for americium and neptunium isotopes. Proper understanding of the radiochemistry methods and reporting, and of appropriate statistical methods is critical to the success of such projects, ensuring that the right decisions are made. (authors)

07 ISOTOPE AND RADIATION SOURCES↗

Methane Exhaust Measurements at Gathering Compressor Stations in the United States

Unburned methane entrained in exhaust from natural gas-fired compressor engines (“combustion slip”) can account for a substantial portion of station-level methane emissions. A novel in-stack, tracer gas method was coupled with Fourier transform infrared (FTIR) species measurements to quantify combustion slip from natural gas compressor engines at 67 gathering and boosting stations owned or managed by nine “study partner” operators in 11 U.S. states. The mean methane emission rate from 63 four-stroke, lean-burn (4SLB) compressor engines was 5.62 kg/h (95% CI = 5.15–6.17 kg/h) and ranged from 0.3 to 12.6 kg/h. The mean methane emission rate from 39 fourstroke, rich-burn (4SRB) compressor engines was 0.40 kg/h (95% CI = 0.37– 0.42 kg/h) and ranged from 0.01 to 4.5 kg/h. Study results for 4SLB engines were lower than both the U.S. EPA compilation of air pollutant emission factors (AP-42) and Inventory of U.S. Greenhouse Gas Emissions and Sinks (GHGI) by 8 and 9%, respectively. Study results for 4SRB engines were 43% of the AP-42 emission factor and 8% of the GHGI emission factor, the latter of which does not distinguish between engine types. Total annual combustion slip from the U.S. natural gas gathering and boosting sector was modeled using measured emission rates and compressor unit counts from the U.S. EPA Greenhouse Gas Reporting Program. Modeled results [328 Gg/y (95% CI = 235–436 Gg/y) of unburned methane] would account for 24% (95% CI = 17–31%) of the 1391 Gg of methane emissions for “Gathering and Boosting Stations”, or 6% of the net emissions for “Natural Gas Systems” (5598 Gg) as reported in the 2020 U.S. EPA GHGI. In conclusion, gathering and boosting combustion slip emissions reported in the 2020 GHGI (374 Gg) fall within the uncertainty of this model.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗

Exploring Climate-Disease Connections in Geopolitical Versus Ecological Regions: The Case of West Nile Virus in the United States

Many infectious disease forecasting models in the United States (US) are built with data partitioned into geopolitical regions centered on human activity as opposed to regions defined by natural ecosystems; although useful for data collection and intervention, this has the potential to mask biological relationships between the environment and disease. We explored this concept by analyzing the correlations between climate and West Nile virus (WNV) case data aggregated to geopolitical and ecological regions. We compared correlations between minimum, maximum, and mean annual temperature; precipitation; and annual WNV neuroinvasive disease (WNND) case data from 2005 to 2019 when partitioned into (a) climate regions defined by the National Oceanic and Atmospheric Administration (NOAA) and (b) Level I ecoregions defined by the Environmental Protection Agency (EPA). We found that correlations between climate and WNND in NOAA climate regions and EPA ecoregions were often contradictory in both direction and magnitude, with EPA ecoregions more often supporting previously established biological hypotheses and environmental dynamics underlying vector-borne disease transmission. Using ecological regions to examine the relationships between climate and disease cases can enhance the predictive power of forecasts at various scales, motivating a conceptual shift in large-scale analyses from geopolitical frameworks to more ecologically meaningful regions.

60 APPLIED LIFE SCIENCES↗

Aureochromes maintain polyunsaturated fatty acid content in Nannochloropsis oceanica

Abstract Nannochloropsis oceanica, like other stramenopile microalgae, is rich in long-chain polyunsaturated fatty acids (LC-PUFAs) such as eicosapentaenoic acid (EPA). We observed that fatty acid desaturases (FADs) involved in LC-PUFA biosynthesis were among the strongest blue light-induced genes in N. oceanica CCMP1779. Blue light was also necessary for maintaining LC-PUFA levels in CCMP1779 cells, and growth under red light led to a reduction in EPA content. Aureochromes are stramenopile-specific proteins that contain a light–oxygen–voltage (LOV)-sensing domain that associates with a flavin mononucleotide and is able to sense blue light. These proteins also contain a basic leucine zipper DNA-binding motif and can act as blue light-regulated transcription factors by associating with an E-box like motif, which we found enriched in the promoters of blue light-induced genes. We demonstrated that, in vitro, two CCMP1779 aureochromes were able to absorb blue light. Moreover, the loss or reduction of the expression of any of the three aureochrome genes led to a decrease in the blue light-specific induction of several FADs in CCMP1779. EPA content was also significantly reduced in NoAUREO2 and NoAUREO4 mutants. Taken together, our results indicate that aureochromes mediate blue light-dependent regulation of LC-PUFA content in N. oceanica CCMP1779 cells.

Plant Sciences↗

Modification in Applying Appendix D of 40 CFR Part 61 to Heated Solid Radionuclide Materials With High Melting and Boiling Points

Appendix D of Title 40 Part 61 of the US Code of Federal Regulations (CFR) provides a procedure that US Department of Energy (US DOE) facility owners and operators can use to estimate radionuclide emissions to the atmosphere for dose calculations instead of measuring emissions for minor sources under the 40 CFR Part 61, Subpart H, National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities, regulation. The procedure assumes that any radioactive material heated above 100 °C is completely vaporized and emitted to the atmosphere. In 1991, the US DOE Oak Ridge Reservation (ORR) requested approval to use different release fractions (RFs) for uranium because of its high melting and boiling points. In response to the request, the US Environmental Protection Agency (US EPA) Region IV approved the use of modified RFs for elemental uranium provided no reaction had taken place to alter its chemical form. In 2015, the ORR requested approval to use different RFs for tungsten, again because of its high melting and boiling points. EPA Region IV approved the use of modified RFs for heated radioactive tungsten metal. In accordance with the two precedents set for heating uranium and radioactive tungsten metals, in 2016, the ORR requested approval to use modified RFs in a similar fashion for other radioactive solid metals and compounds with melting and boiling points above 500 °C that might be heated above 100 °C in future research projects and experiments. EPA Region IV again granted approval to use modified RFs for the list of compounds. This note discusses the proposed modified RFs and their development.

36 MATERIALS SCIENCE↗