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Extract useful information from building permits data to profile a city’s building retrofit history

Building retrofit is one of the key strategies for cities to reduce energy use and GHG emissions. The historical information about changes to buildings is crucial to infer the buildings’ current energy system efficiency levels and to identify candidate buildings for retrofit. In general, a building permit is required before the start of any construction activity of a building, such as changing building structure, remodeling, or installing new equipment. Moreover, many large cities provide public datasets of building permits in history. Therefore, the permits are a potentially good resource for mining information on the city’s retrofit history. In this study, we use the permit dataset from the city of San Francisco as a case study. Location and time information from the dataset is also used to depict the retrofit timeline of each building and the whole building stock. The type of work of the permit is inferred from the descriptive text by a machine learning model. At last, the limitations of the current permit dataset and potential improvements on the permit data management are discussed to better utilize the information in the future.

Zhang, Wanni↗

Hanford site excavation permit application automation project - 15187

Mission Support Alliance, LLC (MSA), on behalf of the Department of Energy's Richland Operations Office (DOE-RL), recently implemented the Site Excavation Permit Application (SEPA) at Hanford. The SEPA automation replaced a 20-year-old manual excavation permit process that governed all Hanford Site excavation activities. The manual process required time consuming interaction between numerous resources for submitting an excavation permit to 15 separate permit organizations for approvals and signature. The process involved numerous information exchanges - usually by phone or E-mails, and substantial vehicle travel. It also generated large amounts of paper, lengthy wait periods and the need for continual status updates to permit reviewers until all approvals were obtained. The new SEPA automated system is an entirely paperless application that streamlines over 25 separate manual permit activities into five Web-based processes. The new application provides sizable environmental sustainability benefits in terms of avoiding: paper waste, air pollution and bio-fuel consumption. SEPA also deploys automated innovations that produce an approximate 50 percent operational cost reduction when compared to the manual permit process. (authors)

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An Historic Perspective of NPDES Individual Permit for Storm Water Discharges from Solid Waste Management Units at Los Alamos National Laboratory - 18667

The Los Alamos National Laboratory (LANL) and the associated communities of Los Alamos and White Rock are located in Los Alamos County in north-central New Mexico approximately 60 mi north-northeast of Albuquerque and 25 mi northwest of Santa Fe. The 36-mi{sup 2} facility is situated on the Pajarito Plateau, which consists of a series of fingerlike mesas separated by deep east-to-west oriented canyons cut by predominately ephemeral and intermittent streams. The mesa tops range in elevation from approximately 7800 ft. on the flanks of the Jemez Mountains to about 6200 ft. at their eastern termination above the Rio Grande Canyon. The land surrounding the Laboratory is largely undeveloped. Public access to much of the facility is limited for safety and security reasons. Large tracts of surrounding land are held by the U.S. Forest Service (Santa Fe National Forest), the Bureau of Land Management (Bandelier National Monument), the General Services Administration and San Ildefonso Pueblo. Storm water discharges from Solid Waste Management Units (SWMUs) have been regulated at the LANL since the early 1990's and have evolved into an Individual Stormwater Permit (IP) that may be one of the most complex in the nation. Historically, storm water discharges from SWMUs at LANL were regulated under a nationwide general permit using a watershed based approach requiring a Storm Water Pollution Prevention Plan (SWPPP), monitoring at sub-watershed scale 'USGS like' gage stations, and inspection and maintenance of erosion controls. In 2001, the Cerro Grande Fire destroyed many Laboratory structures, residential homes and over 80,000 acres of forested lands in the upper watershed above Los Alamos that significantly changed the local hydrology. Several years later, a Federal Facilities Compliance Agreement (FFCA) was issued by U.S. Environmental Protection Agency (USEPA) that was followed by a Clean Water Act lawsuit filed by concerned citizens, the result of which required more focus on stormwater discharges from individual SWMUs and an IP covering over 400 Sites. The IP contains non-numeric technology-based effluent limitations, coupled with a comprehensive, coordinated inspection and monitoring program, to minimize pollutants in LANL's storm water discharges associated with historical industrial activities from specified Sites. Non-numeric technology-based effluent limitations include minimizing pollutants in discharges through erosion and sedimentation controls, management of run-on and runoff, employee training, inspection and maintenance of controls, annual reporting and public involvement. The IP establishes Target Action Levels (TALs) that are equivalent to New Mexico State water-quality criteria. These TALs are used as benchmarks to determine the effectiveness of control measures implemented under the IP. That is, storm water quality sample results from SWMU discharges are compared with applicable TALs. If one or more sample results exceed a TAL, LANL must take additional corrective action. The TAL results are also confounded by high levels of naturally occurring constituents such as aluminum and gross alpha, and urban constituents such as copper, zinc and PCBs which may not be a source from the regulated SWMU. Due to the remote rugged terrain, security access issues, number of monitoring locations, stringent TALs, reporting requirements and public involvement requirements, this permit is likely one of the most stringent and complex in the country. The Laboratory has implemented this permit in a compliant manner for the past seven years and is anticipating the issuance of a new permit in the next few months. This paper will cover permit requirements related to control measure installations, monitoring, reporting and public involvement as well as process improvements and remaining water quality initiatives such as developing studies to address issues such as discriminating between natural background levels and LANL-related contaminants during the execution of this unique permit. (author)

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Marine Energy Environmental Permitting and Compliance Costs

Costs to permit Marine Energy projects are poorly understood. In this paper we examine environmental compliance and permitting costs for 19 projects in the U.S., covering the last 2 decades. Guided discussions were conducted with developers over a 3-year period to obtain historical and ongoing project cost data relative to environmental studies (e.g., baseline or pre-project site characterization as well as post-installation effects monitoring), stakeholder outreach, and mitigation, as well as qualitative experience of the permitting process. Data are organized in categories of technology type, permitted capacity, pre- and post-installation, geographic location, and funding types. We also compare our findings with earlier logic models created for the Department of Energy (i.e., Reference Models). Environmental studies most commonly performed were for Fish and Fisheries, Noise, Marine Habitat/Benthic Studies and Marine Mammals. Studies for tidal projects were more expensive than those performed for wave projects and the range of reported project costs tended to be wider than ranges predicted by logic models. For eight projects reporting full project costs, from project start to FERC or USACE permit, the average amount for environmental permitting compliance was 14.6%.

16 TIDAL AND WAVE POWER↗

HWMA RCRA Storage and Treatment Permit for the Material and Fuels Complex on the Idaho National Laboratory

Owners and operators of facilities that treat, store, and dispose of hazardous waste must obtain an operating permit required by Subtitle C of the Resource Conservation and Recovery Act (RCRA). The operating permit for the Materials and Fuels Complex is the Hazardous Waste Management Act (HWMA)/RCRA Storage and Treatment Permit. The permit defines the conditions and requirements that apply to the treatment and storage of hazardous waste managed at the treatment, storage and disposal facilities (TSDF). The regulations governing the permitting process are found at 40 CFR Pa 124 and 270.

99 GENERAL AND MISCELLANEOUS↗

NORTH DAKOTA CARBONSAFE PHASE III: SITE CHARACTERIZATION AND PERMITTING OF GEOLOGIC STORAGE OF CARBON DIOXIDE

The Energy & Environmental Research Center (EERC), in partnership with Minnkota Power Cooperative Inc. (Minnkota), SLB, and Computer Modelling Group Ltd. (CMG), supported wide-scale deployment of carbon capture and storage (CCS) as part of the U.S. Department of Energy (DOE) National Energy Technology Laboratory Carbon Storage Assurance Facility Enterprise (CarbonSAFE) Initiative Phase III. This phase included the acquisition, analysis, and development of information to fully characterize two storage complexes to demonstrate viable storage resources for commercial volumes of CO2 (defined by DOE as a minimum of 50 million tonnes [MMt] of CO2 within a 30-year period) (National Energy Technology Laboratory, 2024). Phase III also involved the preparation, submission, and approval of North Dakota underground injection control (UIC) Class VI storage facility permits (SFPs)—required precursors to applications for Class VI injection well permits. The presumed viability of commercial-scale CCS, situated adjacent to Minnkota’s Milton R. Young Station (MRYS), is validated by Minnkota’s continued pursuit of Project Tundra—an initiative to build the world’s largest lignite-based CCS project in central North Dakota (www.projecttundrand.com). Project Tundra comprises two scopes of work, Tundra Capture (installation of postcombustion CO2 capture at MRYS) and Tundra SGS (secure geologic storage). The efforts of North Dakota CarbonSAFE Phase III, Site Characterization and Permitting, supported Tundra SGS. Extensive site-specific characterization activities included a successful multimeasurement geophysical approach and drilling a stratigraphic test well (J-ROC 1, subsequently renamed Liberty-1) adjacent to MRYS. Core collection and analyses, downhole testing and fluid sampling, and geophysical logging were performed on J-ROC 1 and on a nearby stratigraphic test well (known as J-LOC 1), which was drilled, cored, and tested under a complementary project funded by the North Dakota Lignite Research Program. The injection tests performed on J-LOC 1 positively impacted the CarbonSAFE project, resulting in fewer proposed injection wells and significant construction, operations, and monitoring cost savings. The characterization data collected and analyses performed were integrated into geologic models, and successive numerical simulations were run to determine CO2 plume extent and subsurface pressure buildup associated with the planned CO2 injection rate of nearly 4 MMt per year. The latter doubles the CarbonSAFE Initiative goal with an estimated 100 MMt of CO2 stored in 20 years. Application of the U.S. Environmental Protection Agency’s (EPA’s) method for estimating the Class VI Rule area of review (AOR) to the overpressurized Broom Creek Formation inspired an alternative method of calculation, called risk-based AOR delineation. This peer-reviewed method was applied for the first time during the storage facility-permitting process. The two SFP applications submitted in 2021 successfully resulted in North Dakota Industrial Commission (NDIC) orders in 2022 authorizing the creation of the storage facility areas and amalgamation of pore space as well as establishing financial responsibility requirements. After approval of the SFPs, Minnkota filed in 2022 applications for permits to reenter the J-ROC 1 well and to drill two new wells—all with the intended purpose to become Class VI injection wells. To establish eligibility under the Internal Revenue Code for Section 45Q tax incentives, a monitoring, reporting, and verification (MRV) plan was prepared and submitted by Minnkota to EPA in 2022, resulting in the first such plan approved in North Dakota. Also in 2022, under the National Environmental Policy Act (NEPA), Minnkota prepared and submitted an environmental information volume (EIV) describing the proposed CCS project and associated potential environmental impacts. Based on the EIV, DOE determined that the proposed construction project required an environmental assessment, and Minnkota submitted the first draft in 2023 and a revised draft in 2024. Both submissions were followed by a public comment period. Subsequently, DOE issued a finding of no significant impact (FONSI) on September 13, 2024. A successful outreach program, strongly based in the production, presentation, and dissemination of informational material, fostered an environment to aid stakeholders in making informed decisions regarding the planned project. Opportunities for public input were provided at various steps along the way, including at county planning and zoning meetings, before and during the SFP administrative hearing, and during environmental assessment public comment periods. In addition, land/pore space owners and mineral owners had various points of contact, including granting access rights, securing pore space leasing, and mineral owner notifications. Based upon the successful storage facility permitting issued by NDIC, approval of the MRV plan by EPA, and receipt of a FONSI under the NEPA, Minnkota is continuing its pursuit of Project Tundra. In December 2023, the Office of Clean Energy Demonstrations under its Carbon Capture Demonstrations Projects Program announced funding for the capture system (Office of Clean Energy Demonstrations, 2023) and a proposal for CarbonSAFE Phase IV: Construction funding was submitted in March 2024 for the storage project. A go/no-go decision to proceed with construction and operations in the Broom Creek Formation is anticipated in 2024. References National Energy Technology Laboratory, CarbonSafe Initiative, https://netl.doe.gov/carbon-management/carbon-storage/carbonsafe (accessed August 2024). Office of Clean Energy Demonstrations, 2023, OCED selects three projects in CA, ND, and TX to reduce harmful carbon pollution, create new economic opportunities, and advance carbon reducing technologies, December, www.energy.gov/oced/articles/oced-selects-three-projects-ca-nd-and-tx-reduce-harmful-carbon-pollution-create-new (accessed August 2024).

Peck, Wesley↗

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

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

01 COAL, LIGNITE, AND PEAT↗

Air Permitting Implications of a Biorefinery Producing Raw Bio-Oil in Comparison with Producing Gasoline and Diesel Blendstocks

A biorefinery, considered a chemical process plant under the Clean Air Act permitting program, could be classified as a major or minor source based on the size of the facility and magnitude of regulated pollutants emitted. Our previous analysis indicates that a biorefinery using fast pyrolysis conversion process to produce finished gasoline and diesel blendstocks with a capacity of processing 2,000 dry metric tons of biomass per day would likely be classified as a major source because several regulated pollutants (such as particulate matter, sulfur dioxide, nitrogen oxide) are estimated to exceed the 100 tons per year (tpy) major source threshold, applicable to chemical process plants. Being subject to a major source classification could pose additional challenges associated with obtaining an air permit in a timely manner before the biorefinery can start its construction. Recent developments propose an alternative approach to utilize bio-oil produced via the fast pyrolysis conversion process by shipping it to an existing petroleum refinery, where the raw bio-oil can be blended with petroleum-based feedstocks (e.g., vacuum gas oil) to produce gasoline and diesel blendstocks with renewable content. Without having to hydro-treat raw bio-oil, a biorefinery is likely to reduce its potential-to-emit to below the 100 tpy major source threshold, and therefore expedite its permitting process. We compare the PTE estimates for the two biorefinery designs with and without hydrotreating of bio-oils and examine the air permitting implications on potential air permit classification and discuss the best available control technology requirements for the major source biorefinery utilizing hydrotreating operation. Our analysis is expected to provide useful information to new biofuel project developers to identify opportunities to overcome challenges associated with air permitting.

09 BIOMASS FUELS↗

Air Dispersion Modeling for the Idaho National Laboratory Permit to Construct P-2020.0045 Facility Emission Cap Revision Request

The U.S. Department of Energy Idaho Operations Office (DOE-ID) is seeking to modify permit to construct (PTC) P-2020.0045 issued to U S Dept. of Energy – Idaho National Laboratory (INL) on January 29, 2021 by the Idaho Department of Environmental Quality (DEQ). This PTC allowed the INL to become a synthetic minor source of air pollutants using a facility emission cap (FEC). Air dispersion modeling was performed as part of the permit revision application process to demonstrate that the modifications will comply with the National Ambient Air Quality Standards (NAAQS). This report documents the modeling methodology and complete results for the air dispersion impact analysis and is supplied as an appendix to the permit revision request, Idaho National Laboratory Permit to Construct P-2020.0045 (INL 2025). All criteria air pollutants (CAPs) regulated under Section 109 of the Clean Air Act were modeled with the exception of lead (Pb) and ozone which are not required to be modeled by DEQ. Consistent with the original permit application, modeling was not performed for toxic air pollutants (TAPs) as uncontrolled emissions did not exceed screening emission levels for carcinogenic and non-carcinogenic TAPs. Acceptable model design values (concentrations) for each CAP and averaging period were summed with average background concentrations and compared to NAAQS. The results demonstrate the impacts of requested FEC limits for CAPs are less than applicable standards and demonstrate emissions up to FEC limits will not cause a violation of ambient air quality standards.

54 ENVIRONMENTAL SCIENCES↗

Air Dispersion Modeling for the Idaho National Laboratory Permit to Construct P-2015.0023 Facility Emission Cap Revision Request

The U.S. Department of Energy Idaho Operations Office (DOE-ID) is seeking to modify permit to construct (PTC) P-2015.0023 issued to U S Dept. of Energy – Idaho National Laboratory (INL) on January 11, 2018 by the Idaho Department of Environmental Quality (DEQ). This PTC allowed the INL to become a synthetic minor source of air pollutants using a facility emission cap (FEC). Air dispersion modeling was performed as part of the permit revision application process to demonstrate that the modifications will comply with the National Ambient Air Quality Standards (NAAQS). This report documents the modeling methodology and complete results for the air dispersion impact analysis and is supplied as an appendix to the permit revision request, Idaho National Laboratory Permit to Construct P-2015.0023 Facility Emission Cap Revision Request (DOE-ID 2020). All CAPs regulated under Section 109 of the Clean Air Act were modeled with the exception of lead (Pb) and ozone which are not required to be modeled by DEQ. Consistent with the original permit application, modeling was not performed for toxic air pollutants (TAPs) as uncontrolled emissions did not exceed screening emission levels for carcinogenic and non-carcinogenic TAPs. Acceptable model design values (concentrations) for each CAP and averaging period were summed with average background concentrations and compared to NAAQS. The results demonstrate the impacts of requested FEC limits for CAPs are less than applicable standards and demonstrate emissions up to FEC limits will not cause a violation of ambient air quality standards.

99 GENERAL AND MISCELLANEOUS↗

Environmental Permitting and Compliance Cost Reduction Strategies for the MHK Industry: Lessons Learned from Other Industries

The marine and hydrokinetic (MHK) industry plays a vital role in the U.S. clean energy strategy by providing a renewable, domestic energy source that may offset the need for traditional energy sources. The first MHK deployments in the U.S. have incurred very high permitting costs and long timelines for deploying projects, which increases project risk and discourages investment. A key challenge to advancing an economically competitive U.S. MHK industry is reducing the time and cost required for environmental permitting and compliance with government regulations. Other industries such as offshore oil and gas, offshore wind energy, subsea power and data cables, onshore wind energy, and solar energy facilities have all developed more robust permitting and compliance pathways that provide lessons for the MHK industry in the U.S. and may help inform the global consenting process. Based on in-depth review and research into each of the other industries, we describe the environmental permitting pathways, the main environmental concerns and types of monitoring typically associated with them, and factors that appear to have eased environmental permitting and compliance issues.

other industries↗

Economic Impact of Permitting Timelines on Produced Geothermal Power

Despite having a large geothermal power potential in the United States, only a small fraction has been developed for power generation. Various barriers, including technical, financial, and regulatory permit delays, are attributed to lower contribution of geothermal energy in the national grid. Unpredictable environmental reviews and permitting timelines are some of the non-technical barriers that can cause delays in geothermal exploration and utilization plans. This study shows that the geothermal permitting timelines can vary from six months to several years, depending on the presence or absence of biological resources, cultural resources, and sensitive environmental issues at the project site. The potential impacts of these permit barriers can range from investors abandoning geothermal development to making the product (i.e., electricity) more expensive and uncompetitive.

15 GEOTHERMAL ENERGY↗

A phased workflow to define permit‐ready locations for large volume CO 2 injection and storage

Abstract To‐date, only two UIC Class VI permits have been issued by the US Environmental Protection Agency. We illustrate a four‐phase workflow to first identify regional storage resources and then down‐select sites to yield permit‐ready locations that can accept and store large volumes of CO 2 . Specific permit requirements should guide objectives and define deliverables of respective workflow phases. In the first phase we used available regional data and screened structure and injection zones to locate resources that match CO 2 volumes planned to be captured. Available data were also used to assess presence and depth of usable groundwater, the key resource being protected via permitting. We then used advanced, closed‐form, analytical solutions (EASiTool) to estimate CO 2 injectivity into each hydrologically connected injection compartment. In the second phase we acquired and conditioned additional wireline logs and leased available seismic datasets. We interpreted the depositional systems from wireline well‐log character and mapped sandbody geometry to interpolate injection and confining‐zone distribution. Using available data, we mapped faults and locations of freshwater and overpressure (or other capacity‐limiting geologic parameters) in more detail. In the third phase, we used the augmented geologic data to develop a static model for the selected area, extracted the areas of highest interest, and generated and ran dynamic (flow) models. In a fourth phase, we reduced major uncertainties identified in earlier phases. Our case study indicates that to complete preparation of a permit application requires (1) improved lithologic characterization information (thicknesses and horizontal and vertical connectivity) and (2) better definition of poorly defined local faults. © 2023 The Authors. Greenhouse Gases: Science and Technology published by Society of Chemical Industry and John Wiley & Sons Ltd.

58 GEOSCIENCES↗

SolarAPP+ ® (Solar Automated Permit Processing Plus) [SWR-19-51]

SolarAPP+ ®: Safe and affordable home solar through permitting automation. NREL has launched a collaborative effort with key code officials, authorities having jurisdiction (AHJs), and the solar industry to develop an instant online solar permitting platform for code compliant residential systems. SolarAPP (Solar Automated Permit Processing) will: -Provide a flexible, web-based PV-permitting tool for residential systems at no-cost to AHJs. -Enable standardization of instant permitting processes. -Evaluate applications for safety and code compliance. -Offer opportunities to incorporate energy storage and expand to other market segments.

Cook, Jeffrey↗

Request for Exemption and Permit Modification for S-6008: Sewer Diversion Complex

Lawrence Livermore National Laboratory (LLNL) operates its Sewer Diversion Complex (SDC) under two relevant permits: discharges to air are controlled by Condition 5533 of LLNL’s BAAQMD permit for Source 6008, and discharges to the municipal sewer system are controlled by LLNL’s Wastewater Discharge Permit (Permit #1250). LLNL intends to modify the SDC by changing the currently permitted tanks to new models. Generally, this change will increase the volume of the tanks, update the abatement carbon system to suit the larger volume, and switch to a set of taller but thinner tanks.

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Case study on the novel permitting and authorization of PacWave South, a US grid-connected wave energy test facility: Development, challenges, and insights

Marine energy (i.e., energy from waves, tides, currents, and rivers) in the United States is a nascent industry. In particular, permitting processes—an uncertainty for industry advancement that can be costly and time consuming to navigate—have rarely been tested and used for marine energy. The novelty of the marine energy industry and utilization of open ocean permitting processes that were not originally developed for marine energy have led to extensive efforts to gain consensus amongst state and federal regulatory agencies to authorize marine energy projects. In 2021, Oregon State University successfully completed permitting of a wave energy test facility, called PacWave South, off the coast of Oregon, which is designed to advance wave energy research and development. This article documents the multi-year process that Oregon State University used to receive federal and state authorization for a pre-permitted commercial-scale grid connected facility by detailing the development of the test facility, management of uncertainty and challenges, and key decisions. The PacWave South case study provides insights for the larger marine energy community as the industry advances towards commercialization.

16 TIDAL AND WAVE POWER↗

Reuse Permit I-161-02 Quality Assurance Project Plan (QAPP) for Required Environmental and Process Monitoring. Idaho National Laboratory Advanced Test Reactor (ATR) Complex Cold Waste Ponds

The Department of Environmental Quality (DEQ) issued Reuse Permit No. I-161-02 (hereafter permit) for the Idaho National Laboratory (INL) Advanced Test Reactor (ATR) Complex Cold Waste Ponds (CWP) on November 20, 2014. Permit Section 3 compliance activity (CA), CA-161-02, requires the permittee to prepare and implement a Quality Assurance Project Plan (QAPP) within 6 months of permit issuance. This QAPP is prepared in accordance with CA-161-02 using a template provided by DEQ.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Materials and Fuels Complex Hazardous Waste Management Act/Resource Conservation and Recovery Act Storage and Treatment Permit Reapplication, Environmental Protection Agency Number ID4890008952

Hazardous Waste Management Act/Resource Conservation and Recovery Act Storage and Treatment Permit Reapplication for the Idaho National Laboratory Materials and Fuels Complex Hazardous Waste Management Act/Resource Conservation and Recovery Act Partial Permit, PER-116. This Permit Reapplication is required by the PER-116 Permit Conditions I.G. and I.H., and must be submitted to the Idaho Department of Environmental Quality in accordance with IDAPA 58.01.05.012 [40 CFR §§ 270.10 and 270.13 through 270.29].

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