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Regulatory and Permitting Information Desktop (RAPID) Toolkit (Poster)

The Regulatory and Permitting Information Desktop (RAPID) Toolkit combines the former Geothermal Regulatory Roadmap, National Environmental Policy Act (NEPA) Database, and other resources into a Web-based tool that gives the regulatory and utility-scale geothermal developer communities rapid and easy access to permitting information. RAPID currently comprises five tools - Permitting Atlas, Regulatory Roadmap, Resource Library, NEPA Database, and Best Practices. A beta release of an additional tool, the Permitting Wizard, is scheduled for late 2014. Because of the huge amount of information involved, RAPID was developed in a wiki platform to allow industry and regulatory agencies to maintain the content in the future so that it continues to provide relevant and accurate information to users. In 2014, the content was expanded to include regulatory requirements for utility-scale solar and bulk transmission development projects. Going forward, development of the RAPID Toolkit will focus on expanding the capabilities of current tools, developing additional tools, including additional technologies, and continuing to increase stakeholder involvement.

15 GEOTHERMAL ENERGY↗

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].

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Guide to Permitting Hydrogen Motor Fuel Dispensing Facilities

The purpose of this guide is to assist project developers, permitting officials, code enforcement officials, and other parties involved in developing permit applications and approving the implementation of hydrogen motor fuel dispensing facilities. The guide facilitates the identification of the elements to be addressed in the permitting of a project as it progresses through the approval process; the specific requirements associated with those elements; and the applicable (or potentially applicable) codes and standards by which to determine whether the specific requirements have been met. The guide attempts to identify all applicable codes and standards relevant to the permitting requirements.

08 HYDROGEN↗

Air Dispersion Modeling for the INL Application for a Synthetic Minor Sitewide Air Quality Permit to Construct with a Facility Emission Cap Component

The Department of Energy Idaho Operations Office (DOE-ID) is applying for a synthetic minor, Sitewide, air quality permit to construct (PTC) with a facility emission cap (FEC) component from the Idaho Department of Environmental Quality (DEQ) for Idaho National Laboratory (INL) to limit its potential to emit to less than major facility limits for criteria air pollutants (CAPs) and hazardous air pollutants (HAPs) regulated under the Clean Air Act. This document is supplied as an appendix to the application, Idaho National Laboratory Application for a Synthetic Minor Sitewide Air Quality Permit to Construct with a Facility Emissions Cap Component, hereafter referred to as “permit application” (DOE-ID 2015). Air dispersion modeling was performed as part of the permit application process to demonstrate pollutant emissions from the INL will not cause a violation of any ambient air quality standards. This report documents the modeling methodology and results for the air dispersion impact analysis. 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. Modeling was not performed for toxic air pollutants (TAPs) as uncontrolled emissions did not exceed screening emission levels for carcinogenic and non-carcinogenic TAPs. Modeling for CAPs was performed with the EPA approved AERMOD dispersion modeling system (Version 14134) (EPA 2004a) and five years (2000-2004) of meteorological data. The meteorological data set was produced with the companion AERMET model (Version 14134) (EPA 2004b) using surface data from the Idaho Falls airport, and upper-air data from Boise International Airport supplied by DEQ. Onsite meteorological data from the Grid 3 Mesonet tower located near the center of the INL (north of INTEC) and supplied by the local National Oceanic and Atmospheric Administration (NOAA) office was used for surface wind directions and wind speeds. Surface data (i.e., land use data that defines roughness, albedo, Bowen ratio, and other parameters) were processed using the AERSURFACE utility (Version 13016) (EPA 2013). Emission sources were modeled as point sources using actual stack locations and dimensions. Emissions, flow rates and exit temperatures were based on the design operating capacity of each source. All structures close enough to produce an area of wake effect were included for all sources. For multi-tiered structures, the heights of the tiers were included or the entire building height was assumed to be equal to the height of the tallest tier. Concentrations were calculated at 1,352 receptor locations provided by DEQ. All receptors were considered for each pollutant and averaging period. Maximum modeled CAP concentrations summed with average background concentration values were presented and compared to National Ambient Air Quality Standards (NAAQS). The background concentration values used were obtained using the Washington State University’s Laboratory for Atmospheric Research North West Airquest web-based retrieval tool (http://lar.wsu.edu/nw airquest/lookup.html). The air dispersion modeling results show the maximum impacts for CAPs are less than applicable standards and demonstrate the INL will not cause a violation of any ambient air quality standards.

54 ENVIRONMENTAL SCIENCES↗

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, with minor Modification 1 effective March 7, 2017. 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.

99 GENERAL AND MISCELLANEOUS↗

2018 Idaho National Laboratory Annual Report for Permit to Construct P-2015.0023

The U.S. Department of Energy (DOE) Idaho National Laboratory (INL) Site operates facilities with potential emissions criteria and hazardous air pollutants. This report documents the calendar year 2018 criteria and hazardous air pollutants emissions and has been prepared to comply with permit to construct (PTC) P-2015-0023, Condition 2.9 and Idaho Administrative Procedures Act (IDAPA) 58.01.01.178, Standard Contents of Permits Establishing a Facility Emissions Cap. IDAPA 58.01.01.178.04 requires that all permits establishing a FEC shall include sufficient reporting to assure compliance with the permit establishing the FEC. Total hazardous air pollutant (HAP) emissions for the year were 1.49 tons in aggregate and the maximum individual HAP was hydrochloric acid at 1.26 tons. Criteria pollutant emissions were 2.16 tons for sulfur dioxide, 35.6 tons for oxides of nitrogen, 11.6 tons of carbon monoxide, 3.51 tons of total particulate matter and 2.66 tons of VOCs.

99 GENERAL AND MISCELLANEOUS↗

Marine Energy Environmental Toolkit for Permitting and Licensing

The permitting and licensing process for marine energy in the U.S. could take up to 7 years for even small demonstrations or pilot studies despite existing resources like Tethys, MarineCadstre, and the FERC E-Library. The goal of the Marine Energy Environmental Toolkit Project was to increase regulators, developers, and marine energy innovators’ understanding of potential environmental effects of marine energy conversion devices deployments and provide information to make efficient and effective determinations during permitting and licensing; develop a one-stop shop for existing environmental, spatial, regulatory, and scientific data that allows users to access disparate sources of data through a series of tags and spatial queries. The Toolkit (marineenergy.app) builds upon prior U.S. Department of Energy (DOE) Water Power Technologies Office (WPTO) investments by pulling from WPTO-funded and outside resources to facilitate the permitting and licensing process, inform technology developers of required permits, and disseminate the latest knowledge of the environmental effects of these devices to regulators, developers, and marine energy innovators and stakeholders.

16 TIDAL AND WAVE POWER↗

Idaho National Laboratory Annual Report for Permit to Construct P-2015.0023 for Calendar Year 2020

The U.S. Department of Energy (DOE) Idaho National Laboratory (INL) Site operates facilities with potential emissions criteria and hazardous air pollutants. This report documents the calendar year 2020 criteria and hazardous air pollutants emissions and has been prepared to comply with permit to construct (PTC) P-2015-0023, Condition 2.9 and Idaho Administrative Procedures Act (IDAPA) 58.01.01.178, Standard Contents of Permits Establishing a Facility Emissions Cap (FEC). IDAPA 58.01.01.178.04 requires that all permits establishing a FEC shall include sufficient reporting to assure compliance with the permit establishing the FEC. Total hazardous air pollutant (HAP) emissions for the year were 0.59 tons in aggregate and the maximum individual HAP was hydrochloric acid at 0.35 tons. Criteria pollutant emissions were 1.23 tons for sulfur dioxide, 40.96 tons for oxides of nitrogen, 11.7 tons of carbon monoxide, 3.01 tons of total particulate matter and 1.98 tons of volatile organic compounds (VOC).

99 GENERAL AND MISCELLANEOUS↗

Modular evaluation method for subsurface activities (MEMSA). A novel approach for integrating social acceptance in a permit decision-making process for subsurface activities

We investigate how the decision support system ‘Modular Evaluation Method Subsurface Activities’ (MEMSA) can help facilitate an informed decision-making process for permit applications of subsurface activities. To this end, we analyze the extent the MEMSA approach allows for a dialogue between stakeholders in a transparent manner. We use the exploration permit for the underground gas storage facility at the Pieterburen salt dome (Netherlands) as a case study. The results suggest that the MEMSA approach is flexible enough to adjust to changing conditions. Furthermore, MEMSA provides a novel way for identifying structural problems and possible solutions in permit decision-making processes for subsurface activities, on the basis of the sensitivity analysis of intermediate rankings. We suggest that the planned size of an activity should already be specified in the exploration phase, because this would allow for a more efficient use of the subsurface as a whole. We conclude that the host community should be involved to a greater extent and in an early phase of the permit decision-making process, for example, already during the initial analysis of the project area of a subsurface activity. We suggest that strategic national policy goals are to be re-evaluated on a regular basis, in the form of a strategic vision for the subsurface, to account for timing discrepancies between the realization of activities and policy deadlines, because this discrepancy can have a large impact on the necessity and therefore acceptance of a subsurface activity.

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Explaining jurisdictional compliance with California’s top-down streamlined solar permitting law (AB 2188)

In the U.S., the process by which residential rooftop solar photovoltaic (PV) system installations are permitted and inspected by an “authority having jurisdiction” (AHJ) varies across AHJs. As the U.S. has roughly 23,000 AHJs with varying degrees of local autonomy, improving the cross-jurisdictional consistency of permitting and inspection is not a straightforward task. One promising approach is a “top-down” streamlined solar permitting (SSP) mandate by U.S. States to their AHJs. This study set out to understand the factors associated with the likelihood that an AHJ either did or did not comply with California’s top-down streamlined solar permitting law, AB2188, and then to consider how these factors might be relevant to the future prospects of top-down SSP outside of California. This report provides background material on AB2188 and tests five hypotheses about the factors that affect the likelihood that an AHJ will comply or not comply with AB2188, as developed from the policy diffusion literature and background knowledge on AB2188 and its implementation.

14 SOLAR ENERGY↗

Understanding Adoption of a Key Soft Cost Reduction Strategy: Modeling Administrative Choices Regarding Streamlined Solar Permitting (Final Technical Report)

In the U.S., the process by which residential rooftop solar photovoltaic (PV) system installations are permitted and inspected by an “authority having jurisdiction” (AHJ) and interconnected to the grid varies across the country. As the U.S. has roughly 23,000 AHJs and 3,000 utilities with varying degrees of local autonomy, permitting, inspection, and interconnection (PI&I) heterogeneity represents a significant “soft cost” barrier to the growth of the residential solar PV market. Burkhardt et al. (2015), for example, finds that variations in local permitting procedures alone can lead to differences in average residential PV prices of approximately ${$}$0.14-${$}$0.18/W. When the authors considered jurisdictional variation in permitting plus regulatory procedures, that price differential grew to ${$}$0.64-${$}$0.93/W between the least-favorable and most-favorable jurisdictions. The objective of this project was to determine suites of PI&I reforms that fit the preferences of AHJs and utilities nationwide, as mediated through the preferences of PV installers, with the hoped-for impact of significantly improving the consistency of PI&I for solar PV across the U.S. To accomplish this objective, the project team set out to design and implement survey instruments with embedded discrete choice experiments (DCEs) that used individual PI&I reforms as attributes, with levels informed by a detailed understanding of the PI&I reforms. The analysis of the surveys was to include both defined and latent class analysis of the survey results, in order to identify different sets of AHJs and utilities that would prefer different “mass customized” SSP practice combinations. Note that this project would also have advanced the social science by applying well-established choice analysis techniques to the novel setting of public administration.

14 SOLAR ENERGY↗

Illinois Storage Corridor - CarbonSAFE Phase III: Policy, Regulatory, Legal and Permitting Characteristics; Subtask 5.5

The Illinois Storage Corridor (ISC) project aims to advance the commercial development and implementation of carbon capture and storage (CCS) technologies within a region in Illinois of suitable geology for carbon dioxide (CO 2 ) storage in deep saline aquifers. The project partners have annual emissions greater than 6.5 million tonnes per year; storage hubs are being explored at two sites—one near the One Earth Energy facility in east-central Illinois, and one near the Prairie State Generating Company campus in southwest Illinois. To implement the technology, legal, policy, and economic considerations must be explored. The United States Environmental Protection Agency (US EPA) administers the Underground Injection Control (UIC) program and is responsible for issuing Class VI permits to construct and operate CO 2 injection wells, i.e., a UIC Class VI well permit is required to inject CO 2 into the subsurface for geologic sequestration. The largest consideration of the Class VI well requirements is to protect underground sources of drinking water (USDWs). Additionally discussed are considerations for Class VI permits relating to public engagement. Besides permitting, property rights to storage sites, subsurface pore spaces, and areas for pipeline transportation must be secured. Pore space rights is still a novel concept being explored and not yet addressed by the Illinois legislature. It is believed that surface property rights are required for the subsurface pore space below, so long as there is not a separated mineral estate in the subsurface. Illinois legislature has addressed securing rights-of-way for CO 2 transportation, allowing for easements and the exercise of eminent domain to secure such rights. Economically, the incentives for CCS are ever-expanding. Recently, the federal government broadened the availability and increased the dollar-amounts for the § 45Q tax credits for geological storage of carbon oxides. Congress has also authorized the Advanced Industrial Facilities Development Program which allocates billions of dollars in funds to installing technology at industrial facilities to reduce greenhouse gas emissions. On the state level, Illinois has had its own incentives for CCS projects since 2009 and expanded its emission-related goals again in 2021. The law enacted in 2021 specifically creates a commission to explore implementing CCS at Prairie State Generating Company, a partner on the Illinois Storage Corridor project.

54 ENVIRONMENTAL SCIENCES↗

The Kinematics of the Permitted C ii λ 6578 Line in a Large Sample of Planetary Nebulae

We present spectroscopic observations of the C ii λ 6578 permitted line for 83 lines of sight in 76 planetary nebulae at high spectral resolution, most of them obtained with the Manchester Echelle Spectrograph on the 2.1 m telescope at the Observatorio Astronómico Nacional on the Sierra San Pedro Mártir. We study the kinematics of the C ii λ 6578 permitted line with respect to other permitted and collisionally excited lines. Statistically, we find that the kinematics of the C ii λ 6578 line are not those expected if this line arises from the recombination of C{sup 2+} ions or the fluorescence of C{sup +} ions in ionization equilibrium in a chemically homogeneous nebular plasma, but instead its kinematics are those appropriate for a volume more internal than expected. The planetary nebulae in this sample have well-defined morphology and are restricted to a limited range in H α line widths (no large values) compared to their counterparts in the Milky Way bulge; both these features could be interpreted as the result of young nebular shells, an inference that is also supported by nebular modeling. Concerning the long-standing discrepancy between chemical abundances inferred from permitted and collisionally excited emission lines in photoionized nebulae, our results imply that multiple plasma components occur commonly in planetary nebulae.

79 ASTRONOMY AND ASTROPHYSICS↗

RCRA Part A Permit Application for Waste Management Activities at the Nevada National Security Site Hazardous Waste Storage Unit (HWSU), Explosive Ordnance Disposal Unit (EODU), Mixed Waste Storage Unit (MWSU), and Mixed Waste Disposal Unit (MWDU)

This document is the first volume in a Resource Conservation Recovery Act (RCRA) Permit Application to the Nevada Division of Environmental Protection for continued operation of certain facilities on the Nevada National Security Site (NNSS), owned by the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office (NNSA/NFO). This RCRA permit application pertains to the Hazardous Waste Storage Unit (HWSU), the Explosive Ordnance Disposal Unit (EODU), the Mixed Waste Storage Unit (MWSU), and the Mixed Waste Disposal Unit (MWDU). This volume lists the relevant permits for each of these facilities and provides maps and drawings of many aspects of them. The companion volumes, which provide descriptive text and discussion and additional graphics, are jointly considered Part B of the permit application. Those volumes are identified by the following document numbers: DOE/NV/25946--2442, DOE/NV/25946--2448, DOE/NV/25946--2425, and DOE/NV/25946--2429.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Recycled water reuse permit renewal application for the materials and fuels complex industrial waste ditch and industrial waste pond

This renewal application for the Industrial Wastewater Reuse Permit (IWRP) WRU-I-0160-01 at Idaho National Laboratory (INL), Materials and Fuels Complex (MFC) Industrial Waste Ditch (IWD) and Industrial Waste Pond (IWP) is being submitted to the State of Idaho, Department of Environmental Quality (DEQ). This application has been prepared in compliance with the requirements in IDAPA 58.01.17, Recycled Water Rules . Information in this application is consistent with the IDAPA 58.01.17 rules, pre-application meeting, and the Guidance for Reclamation and Reuse of Municipal and Industrial Wastewater (September 2007). This application is being submitted using much of the same information contained in the initial permit application, submitted in 2007, and modification, in 2012. There have been no significant changes to the information and operations covered in the existing IWRP. Summary of the monitoring results and operation activity that has occurred since the issuance of the WRP has been included. MFC has operated the IWP and IWD as regulated wastewater land treatment facilities in compliance with the IDAPA 58.01.17 regulations and the IWRP. Industrial wastewater, consisting primarily of continuous discharges of nonhazardous, nonradioactive, routinely discharged noncontact cooling water and steam condensate, periodic discharges of industrial wastewater from the MFC facility process holdup tanks, and precipitation runoff, are discharged to the IWP and IWD system from various MFC facilities. Wastewater goes to the IWP and IWD with a permitted annual flow of up to 17 million gallons/year. All requirements of the IWRP are being met. The Operations and Maintenance Manual for the Industrial Wastewater System will be updated to include any new requirements.

99 GENERAL AND MISCELLANEOUS↗

E Tunnel Wastewater Disposal System Quarterly Monitoring Report and Annual Summary Report Nevada National Security Site, Nevada, Water Pollution Control Permit NEV 96021: Fourth Quarter and Calendar Year 2018

This annual report includes the results of the ETOS sample collection and analysis of the effluent water from the ETOS. The effluent sample was collected on October 9, 2018. Sampling activities were performed in accordance with the requirements of WPC Permit NEV 96021, Revision 1, which is effective October 1, 2013. Although the stated end date of the WPC permit is September 3 O, 2018, the NDEP, in a letter dated September 21, 2018, provided guidance that indicated the WPC Permit NEV 96021, Revision 1, is in effect until NOEP notifies NNSA/NFO otherwise.

54 ENVIRONMENTAL SCIENCES↗