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PNNL Sequim Campus Radionuclide Air Emissions Report for Calendar Year 2021

The U.S. Department of Energy Office of Science (DOE-SC) Pacific Northwest Site Office has oversight and stewardship duties associated with the Pacific Northwest National Laboratory Sequim Campus. Some research projects have the potential to emit low levels of radioactive materials. This report is prepared to document compliance with the Code of Federal Regulation, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, "Radiation Protection–Air Emissions." Compliance is indicated by comparing the estimated effective dose equivalent (EDE) to the maximally exposed individual (MEI) member of the public with the 10 millirem per year (mrem/yr) U.S. Environmental Protection Agency (EPA) standard. The PNNL Sequim Campus has only fugitive emissions sources. Despite the fact that the regulations are intended for application to point source emissions, fugitive emissions are included with regard to complying with the EPA standard. The EDE to the Campus MEI due to routine operations in 2021 was 5.4E-05 mrem (5.4E-07 mSv). No non-routine emissions occurred in 2021. The Sequim Campus is in compliance with the federal and state 10 mrem/yr standard.

40 CFR 61 Subpart H↗

PNNL-Sequim Campus Radionuclide Air Emissions Report for Calendar Year 2022

The U.S. Department of Energy Office of Science (DOE-SC) Pacific Northwest Site Office has oversight and stewardship duties associated with the Pacific Northwest National Laboratory Sequim Campus. Some research projects have the potential to emit low levels of radioactive materials. This report is prepared to document compliance with the Code of Federal Regulation, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, "Radiation Protection–Air Emissions." Compliance is indicated by comparing the estimated effective dose equivalent (EDE) to the maximally exposed individual (MEI) member of the public with the 10 millirem per year (mrem/yr) U.S. Environmental Protection Agency (EPA) standard. The PNNL-Sequim Campus has only fugitive emissions sources. Despite the fact that the regulations are intended for application to point source emissions, fugitive emissions are included with regard to complying with the EPA standard. The EDE to the Campus MEI due to routine operations in 2022 was 7.5E-07 mrem (7.5E-09 mSv). No non-routine emissions occurred in 2022. The PNNL-Sequim Campus is in compliance with the federal and state 10 mrem/yr standard.

40 CFR 61 Subpart H↗

Review of Life Cycle Cost Analysis Tools

Life cycle costing (LCC) is a vital aspect of decision-making in building retrofitting. It allows stakeholders to thoroughly assess all expenses involved throughout the lifespan of these retrofits, covering initial costs; ongoing operation, maintenance, and repair costs; and disposal costs of the system. The Federal Energy Management Program of the US Department of Energy has established clear guidelines for conducting LCC analysis, particularly for investments aimed at energy and water conservation, as well as renewable energy projects. These guidelines are detailed in the Code of Federal Regulations, 10 CFR 436, Subpart A, which outlines the methodology and procedure for LCC analysis (Department of Energy 1990). The National Institute of Standards and Technology (NIST) has developed the NIST Handbook 135 (Joshua Kneifel 2022) to standardize the process of LCC analysis within the building industry. Whereas the handbook is tailored to the needs of federal agencies, its principles and methodologies can be valuable for other organizations and industries interested in conducting life cycle costing analyses for their building projects.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Rationale for reconsidering current regulations restricting use of hybrids in orange juice

Huanglongbing (HLB) is a disease that has devastated the Florida citrus industry, threatens the entire U.S. citrus industry, and globally is rapidly spreading. Florida’s citrus production is 90% sweet orange, which is quite sensitive to HLB. The heavy reliance on sweet orange for Florida citrus production makes the industry especially vulnerable to diseases that are damaging to this type of citrus. Furthermore, 90% of Florida oranges are used in producing orange juice that is defined by a federal regulation known as the “orange juice standard”, specifying that at least 90% of “orange juice” must be derived from Citrus sinensis. Genomic analyses definitively reveal that sweet orange is not a true species, but just one of many introgression hybrids of C. reticulata and C. maxima, with phenotypic diversity resulting from accumulated mutations in this single hybrid, the “sweet orange”. No other fruit industry is limited by law to such a narrow genetic base. Fortunately, there are new citrus hybrids displaying reduced sensitivity to HLB, and in some cases they produce juice, alone or in blends, that consumers would recognize as “orange juice”. Reconsidering current regulations on orange juice standards may permit use of such hybrids in “orange juice”, providing greater latitude for commercialization of these hybrids, leading to higher-quality orange juice and a more sustainable Florida orange juice industry.

54 ENVIRONMENTAL SCIENCES↗

A Comprehensive Survey of Coal Ash Law and Commercialization: Its Environmental Risks, Disposal Regulation, and Beneficial Use Markets

This white paper was commissioned by the National Association of Regulatory Utility Commissioners (NARUC) under a grant from the U.S. Department of Energy (DOE), in response to a major rule, Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals From Electric Utilities; Final Rule (Final Rule) issued by the U.S. Environmental Protection Agency (EPA) on April 17, 2015, on coal ash disposal and remediation of disposal sites, which has significant implications to states. It subjects state environmental agencies and public utility commissions to regulatory responsibilities to implement federal regulations under the Final Rule and oversee the cost implications on electric customers. To better evaluate the regulatory issues underlying the choices facing utilities and independent power producers (IPPs) regarding coal ash management options under the Final Rule, an overview of coal ash production and disposal practices is helpful. This comprehensive survey provides background information on the following topics: (a) coal ash production by a coal combustion generation plant, (b) the historical practices of utility waste management practices, (c) coal ash toxicity and related constituents, (d) further understanding of potential impacts to groundwater, and (e) the aging structures and outdated designs of coal ash surface impoundments and landfills.

01 COAL, LIGNITE, AND PEAT↗

Evaluation of Dose- and Risk-Based Groundwater Cleanup Levels for Low Energy Beta Radioisotopes

Low-energy beta-emitting radionuclides that were released historically during reactor operations and plutonium separations activities at some U.S. Department of Energy sites have migrated into the groundwater, forming contaminant plumes that are subject to federally regulated remediation actions. At the Hanford Site, the low-energy beta-emitting radionuclides include iodine-129, technetium-99, chlorine-36, carbon-14, and tritium (H-3). All are highly mobile in the subsurface, and except for tritium, and have very long half-lives—thousands to millions of years. The geochemistry and transport behavior of these contaminants in the subsurface present significant challenges for remediation of groundwater to federal drinking water standards (DWS)—the appropriate or relevant and applicable requirements (ARARs) for cleanup. For some of the low-energy beta-emitter contaminants, particularly iodine-129, cleanup and restoration of groundwater to DWS may not be attainable within a reasonable timeframe using currently available treatment technologies.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

A Circular Economy for Solar Photovoltaic System Materials: Drivers, Barriers, Enablers, and U.S. Policy Considerations

As PV capacity increases, owners are also decommissioning older system assets. Estimates based on a 30-year lifetime assumption found that cumulative U.S. end-of-life (EoL) PV modules could total one million metric tons (Mt) by 2030 and up to 10 million Mt by 2050 (Weckend, Wade, and Heath 2016). Beyond maintenance replacements, early retirements that are due to efficiency upgrades and extreme weather, as well as PV deployment beyond earlier expectations, would increase these projections. PV system owners must evaluate equipment management options for used modules and system components retired during maintenance activities, refurbishment, repowering and system decommissioning. PV manufacturers must also evaluate material management options from customer returns, defects, and scrap. Management options for early retired and EoL PV system material include reuse, repair for reuse, recycling-based resource recovery, storage, and disposal. Disposal of PV system material increases the burden on landfill capacity, while reuse, repair for reuse, and recycling-based resource recovery (reuse/repair/recovery) options salvage valuable materials and provide secondary market opportunities and ancillary benefits (Weckend, Wade, and Heath 2016; EPA 2019c; SWEEP 2019). PV system owners may also decide store used modules and components as spares, or in the interim before a reuse or EoL management decision is made. Despite potential secondary market opportunities and the potential benefits associated with the repair/reuse/recovery of PV system material, anecdotal evidence suggests that in the United States decommissioned PV modules are stored, landfilled or otherwise disposed of (Salim et al. 2019; CPUC 2019b; DTSC 2019b; NREL 2019a). Some modules are being disposed of in municipal nonhazardous landfills and federally regulated hazardous treatment, storage, and disposal facilities, and others are being stored in warehouses until economically viable repair/reuse/recycling becomes available (CPUC 2019b; DTSC 2019b; NREL 2019a; Libby and Shaw 2018). As awareness of current practices grows, and the demand for critical PV module material increases, U.S. industry stakeholders, regulators, and policymakers are starting to (1) consider solutions to drive and enable environmentally sustainable materials management decisions and behaviors and (2) identify barriers to a circular economy for PV system materials. Circular economy principles attempt to transition from a "take-make-consume-dispose" linear economic system to a circular system that allows for the long life, and the reuse/repair/recovery of products and materials (Ellen MacArthur Foundation 2020). We begin this report by summarizing the drivers, barriers, and enablers to a circular economy for PV system materials in the United States. We then report on our analysis of federal and state regulatory considerations that may impact the repair/reuse/recovery of PV materials, and potential civil and criminal liabilities associated with noncompliance. We then discuss state policies and initiatives in the United States that expressly address PV system decommissioning and repair/reuse/recovery of PV materials. We conclude by providing case studies of U.S. business models for the repair/reuse/recovery of PV system materials. Our results are based on legal and literature-based research and interviews with solar industry stakeholders, regulators, and policymakers.

14 SOLAR ENERGY↗

PNNL-Richland Campus Radionuclide Air Emissions Report for Calendar Year 2024

This report documents radionuclide air emissions that result in the 2024 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The total dose to the MEI from all PNNL-Richland campus radionuclide emissions in 2024, including fugitive emissions and radon, is 1.3E-05 mrem (1.3E-07 mSv) EDE, or 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland campus is in compliance. The dose attributable to radon emissions is 4.1E-10 mrem (4.1E-12 mSv) EDE.

40 CFR 61 Subpart H↗

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2025

This report documents radionuclide air emissions that result in the 2025 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The total dose to the MEI from all PNNL Richland Campus radionuclide emissions in 2025, including fugitive emissions and radon, is 1.8E-05 mrem (1.8E-07 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance. The dose attributable to radon emissions is 1.5E-13 mrem (1.5E-15 mSv) EDE.

40 CFR 61 Subpart H↗

PNNL-Richland Campus Radionuclide Air Emissions Report for Calendar Year 2023

This report documents radionuclide air emissions that result in the 2023 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The dose to the PNNL-Richland campus MEI from routine emissions sources, excluding radon, in 2023 from campus sources is 2.0E-5 mrem (2.0E-7 mSv) EDE. The dose from radon emissions is 4.0E-7 mrem (4.0E-09 mSv) EDE. No nonroutine emissions occurred in 2023. The total radiological dose to the MEI from all PNNL-Richland campus radionuclide emissions, including fugitive emissions and radon, is 2.1E-5 mrem (2.1E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL-Richland campus is in compliance.

40 CFR 61 Subpart H↗

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2019

This report documents radionuclide air emissions that result in the 2019 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2019 from PNNL Richland Campus sources is 1.4E-5 mrem (1.4E-7 mSv) EDE. The dose from all fugitive sources is 1.3E-6 mrem (1.3E-8 mSv) EDE. The dose from radon emissions is 1.5E-10 mrem (1.5E-12 mSv) EDE. No nonroutine emissions occurred in 2019. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 1.5E-5 mrem (1.5E-7 mSv) EDE, or more than 10,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart H↗

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2020

This report documents radionuclide air emissions that result in the 2020 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2020 from PNNL Richland Campus sources is 1.5E-5 mrem (1.5E-7 mSv) EDE. The dose from all fugitive sources is 2.0E-6 mrem (2.0E-8 mSv) EDE. The dose from radon emissions is 9.3E-9 mrem (9.3E-11 mSv) EDE. No nonroutine emissions occurred in 2020. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 1.7E-5 mrem (1.7E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart H↗

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2021

This report documents radionuclide air emissions that result in the 2021 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2021 from PNNL Richland Campus sources is 1.7E-5 mrem (1.7E-7 mSv) EDE. The dose from all fugitive sources is 1.2E-6 mrem (1.2E-8 mSv) EDE. The dose from radon emissions is 2.1E-9 mrem (2.1E-11 mSv) EDE. No nonroutine emissions occurred in 2021. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 1.8E-5 mrem (1.8E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart H↗

PNNL-Richland Campus Radionuclide Air Emissions Report for Calendar Year 2022

This report documents radionuclide air emissions that result in the 2022 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The dose to the PNNL Richland Campus MEI from routine major and minor point source emissions in 2022 from PNNL Richland Campus sources is 2.1E-5 mrem (2.1E-7 mSv) EDE. The dose from all fugitive sources is 1.2E-6 mrem (1.2E-8 mSv) EDE. The dose from radon emissions is 9.2E-9 mrem (9.2E-11 mSv) EDE. No nonroutine emissions occurred in 2022. The total radiological dose to the MEI from all PNNL Richland Campus radionuclide emissions, including fugitive emissions and radon, is 2.3E-5 mrem (2.3E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance.

40 CFR 61 Subpart↗

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↗

Establishing Regulatory Jurisdictional Boundaries at Collocated Advanced-Reactor Facilities

This white paper discusses establishing and applying nuclear facility jurisdictional boundaries at advanced-nuclear-reactor facilities. It was written for industry review and evaluation with possible consideration by the U.S. Nuclear Regulatory Commission (NRC) for subsequent regulatory action. The paper proposes a regulatory basis for establishing jurisdictional boundaries at operational advanced (i.e., non-light water) reactor installations at sites proximate to and sharing systems with non-NRC regulated facilities (e.g., users of process heat, fossil-plant retrofits, microgrid electrical power, desalination, etc.). Advanced-reactor technologies can be applied to support many industrial applications to replace the burning of fossil fuels as well as produce steam for electricity. The principal application of the current light-water reactor fleet is electricity generation. These varied industrial applications may involve an advanced-reactor design in combination with different site-specific energy-conversion systems. Some of these process-heat applications will require process-heat delivery systems to lie partially outside the advanced-reactor operator’s facility. Energy conversion systems are conventional, non-nuclear equipment and buildings. Given these varied applications, there should be a clear understanding between the advanced-reactor applicant and the NRC regarding a nominal demarcation between those systems that reside within the nuclear facility under the regulatory jurisdiction of the NRC (i.e., within the scope of a 10 Code of Federal Regulations (CFR) 50 operating license or Part 52 design certification and a combined license) and those that fall outside the scope of the NRC (e.g., an industrial facility). Additionally, it is important to have a clear understanding regarding the plant scope that should be addressed in an advanced-reactor facility Part 52, design certification application and the part of the plant scope that could be addressed as part of a site specific combined license application.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Tank Waste LDR Organics Data Summary for Sample-and-Send (Rev.1A)

The presence of organic chemicals regulated under the Resource Conservation and Recovery Act (RCRA) Land Disposal Restrictions (LDR) adds complexity to treating and disposing of the low activity fraction of Hanford tank waste if a low temperature treatment method such as grouting is used (SRNL-STI-2020-00228). The complexity arises from the fact that the baseline vitrification method is considered by the Washington State Department of Ecology (Ecology) as providing adequate thermal treatment for organics; a status not automatically extended to a lowtemperature process, such as solidifying the waste in a cementitious waste form. In addition, the Environmental Protection Agency (EPA) LDR program is intended to ensure that wastes are properly treated prior to disposal. Proper treatment makes hazardous waste less harmful to groundwater by reducing the mobility and/or toxicity of the hazardous constituents in the waste. EPA guidance indicates that stabilization/solidification of waste for organics could be considered impermissible dilution under the LDR dilution prohibition. In addition, waste storage activities at Hanford have required transferring and blending waste within the tank system and these activities have potentially altered the concentrations of the hazardous constituents. The LDR dilution prohibition found in 40 Code of Federal Regulations (CFR) 268.3 states that “… no generator, transporter, handler, or owner or operator of a treatment, storage, or disposal facility shall in any way dilute a restricted waste or the residual from treatment of a restricted waste as a substitute for adequate treatment …”. Hence, if LAW is to be treated using low temperature stabilization (such as cementation), then it is important to demonstrate both how past storage activities have contributed to the removal (by vacuum evaporation), or destruction (by in situ decomposition) of the LDR organics and how future retrieval and waste feed preparation will contribute to their removal (by filtration and ion exchange). Demonstrating these processes helps validate that cementation without additional organic treatment does not necessarily represent impermissible dilution. To aid in implementing cementitious solidification of Low Activity Waste (LAW), WRPS has been developing a regulatory and processing LDR treatment variance strategy termed “Sampleand-Send” that relies, in part, on demonstrating that in situ decomposition reactions along with historic evaporation of tank waste has destroyed or removed most of the LDR organics possibly associated with Hanford Tank Waste (SRNL-STI-2020-00582, SRNL-STI-2021-00453, SRNL-STI-2022-00391). Under the Sample-and-Send concept, Hanford tank waste would be retrieved, processed through a Tank-Side Cesium Removal-like system, and staged as a candidate feed that would then be sampled to confirm the waste acceptance criteria is met for solidification in an LAW cementitious treatment facility. If it can be shown that LDR organics are at concentrations below the waste acceptance criteria (WAC) for cementitious stabilization and have been sufficiently removed (by historic evaporation or by filtration and ion exchange during Cs removal), destroyed (by historic in situ decomposition), or are not soluble in LAW above the WAC then additional organic treatment is not needed prior to creating a cementitious final waste form and the concept of Sample-and-Send would be proposed to establish a non-rulemaking site-specific treatment variance using the specified method of treatment “STABL” to remove sampling requirements of the waste form after treatment. Waste not meeting the WAC could either be routed to the Hanford Waste Treatment and Immobilization Plant for LAW vitrification, or further processed by evaporation or chemical oxidation before solidifying in a cementitious waste form. A key component in implementing the Sample-and-Send strategy is identifying which of the 207 LDR organic compounds associated with the RCRA Part A permit application waste codes for the Double Shell Tanks (DSTs) and Single Shell Tanks (SSTs) and any applicable Underlying Hazardous Constituents (UHCs) from 40 CFR 268.48 should be considered as potentially present and thus subject to regulation. In addition, it is also necessary to understand the solubility volatility, and reactivity of these compounds in LAW to identify which of the potentially present LDR organic compounds are not soluble above regulatory levels or are likely to have been removed by historic evaporation or destroyed by in situ decomposition reactions. If there are potentially present LDR organic compounds that have not been removed or destroyed and are soluble above regulatorily significant concentrations then a treatability variance may be needed for these species to eliminate any concerns pertaining to impermissible dilution. The spreadsheet accompanying this calculation report contains the data and logic computations needed to screen the list of 207 LDR organics associated with Hanford tank waste to identify those potentially present and to indicate which compounds may need to be included in a treatability variance.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Floating Photovoltaics in Hydropower Reservoirs in the United States

This report presents a comprehensive analysis of the feasibility of floating photovoltaics (FPV) in federally regulated reservoirs within the continental United States (CONUS) and to present a methodology for capturing the true costs of deployment, potential environmental impacts, and regulatory pathways for open-loop hydropower reservoirs. It is intended for stakeholders who may not be solar industry experts but who are interested in exploring the potential for FPV in their reservoirs. While there are promising opportunities, particularly in enhancing dissolved oxygen (DO) levels and potentially improving compliance with existing hydropower licenses, the current capital costs of FPV are not yet competitive with traditional land-based solar installations at the utility-scale when comparing the LCOE results. A competitive financial outlook is achievable when applying a 30% Investment Tax Credit (ITC) and considering a 5% reduction from the baseline capital expenditures (CapEx) at the Tuckertown Reservoir in North Carolina case study. The study is structured around three key pillars of research: technical potential, environmental impacts and regulatory considerations, and technoeconomic analysis. This report provides a nationwide assessment of the opportunities for FPV in terms of capacity, measured in direct current megawatts (MWDC), in reservoirs managed by the U.S. Bureau of Reclamation (USBR), the U.S. Army Corps of Engineers (USACE), and the Federal Energy Regulatory Commission (FERC). Additionally, the report introduces a heuristic model for estimating the CapEx of utility-scale FPV projects (1–100 MW), offering a baseline cost estimate for stakeholders. Finally, the report applies these models to a case study of a hydropower reservoir in North Carolina to present site-specific results.

13 - HYDRO ENERGY↗