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At least 163 records · Page 9

National Emission Standards for Hazardous Air Pollutants – Radionuclide Emissions Calendar Year 2020

The U.S. Department of Energy (DOE), National Nuclear Security Administration Nevada Field Office (NNSA/NFO) operates the Nevada National Security Site (NNSS) and the North Las Vegas Facility (NLVF). From 1951 through 1992, the NNSS was the continental testing location for U.S. nuclear weapons. Radionuclides in air from NNSS activities have been monitored since the initiation of atmospheric testing. After 1962, testing was limited to underground detonations, which greatly reduced radiation exposure to the public. Since the end of nuclear testing in 1992, radiation monitoring has focused on detecting airborne radionuclides from historically contaminated soils because this sources dominates the potential offsite dose. These radionuclides are derived from re-suspension of soil (primarily by wind) and emission of tritium-contaminated soil moisture through evapotranspiration. Low amounts of legacy-related tritium are also emitted to air at the NLVF, an NNSS support complex in North Las Vegas. To protect the public from harmful levels of manmade radiation, the Clean Air Act, National Emission Standards for Hazardous Air Pollutants (NESHAP), specifically the National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities (40 CFR 61, Subpart H, 2020) limits the release of radioactivity from a DOE facility to that which would cause 10 millirem per year (mrem/y) effective dose equivalent (EDE) to any member of the public. This limit does not include radiation unrelated to NNSS activities. Unrelated doses could come from naturally occurring radioactive elements, from sources such as medically or commercially used radionuclides, or from sources outside of the United States, such as Japan’s Fukushima nuclear power plant, which was damaged in 2011. NNSA/NFO demonstrates compliance with the NESHAP limit by reporting environmental measurements of radionuclide air concentrations at critical receptor locations on the NNSS. This alternative was proposed and formerly submitted to the U.S. Environmental Protection Agency (EPA) in 2001 (EPA 2001a) and has been the method used to demonstrate compliance with the 40 CFR 61.92 dose standard since 2005. Six locations on the NNSS have been established to act as critical receptor locations to demonstrate compliance with the NESHAP limit. These locations are closer to radionuclide releases than where the public resides so they act as protective substitutes for public receptor locations. Compliance is demonstrated if the measured annual average concentration is less than the NESHAP Concentration Level (CL) for Environmental Compliance listed in Table 2 of 40 CFR 61, Appendix E. For multiple radionuclides, compliance is demonstrated when the sum of the fractions (determined by dividing each radionuclide’s concentration by its CL and then adding the fractions together) is less than 1.0. The EPAapproved air transport model, called the Clean Air Package 1988 (CAP88-PC) is also used to calculate the effective dose equivalent to the maximally exposed individual from NNSS air emissions. CAP88-PC was also used to calculate the population dose, or the collective EDE (expressed as person-rem [roentgen equivalent man] per year [person-rem/y]) for all individuals combined who reside within 80 kilometers (km) of NNSS emission sources. In 2020, the potential dose from radiological emissions to air from both current and past NNSS activities was well below the 10 mrem/y dose limit. This is demonstrated by both the air sampling data collected at critical receptor air monitoring stations and CAP88-PC modeling. The average concentrations of radioactivity at air critical receptor stations ranged from 0.2% to a maximum of 4.2% of the allowed NESHAP limit. CAP88-PC modeling of all 2020 NNSS radionuclide emissions showed the maximally exposed individual to be in Amargosa Valley and this individual received a potential dose of 0.063 mrem/y. The collective dose was calculated to be 0.29 person-rem/year for the 521,300 people who lived within 80 km of NNSS emission sources.

99 GENERAL AND MISCELLANEOUS↗

Preprocessing of municipal solid waste towards thermal insulating material

Municipal solid waste (MSW) is one of the significant challenges in today’s world. A continuous surge in population, increasing living standards, and rapid urbanization are generating an enormous quantity of MSW. For example, the Environmental Protection Agency (EPA) reported that the total generation of MSW in the United States in 2018 was 292.4 million tons. Improper management of this MSW often leads to the release of greenhouse gases, emission of particulate matters, and formation of dioxins, which all ultimately contributes to climate change. Recycling these wastes via landfills with gas recovery and/or energy and material production via thermal and chemical conversions could be viable options to manage these challenges. Depending on the inherent chemical and structural properties of unrecycled wastes, the carbon structures can be tailored for processing and reuse in manufacturing of structural composites, building materials such as insulation, carbon dense reactant materials such as activated carbon, and so on. According to the EPA’s estimation, MSW in the United States is approximately 23% paper and paperboard, 12% plastics, 6% wood and 6% is textiles. Thus, this research focused on the feasibility of using the MSW as insulation material for the construction sector. The goal of this work was to determine the range of particle sizes, consolidation ratios, and component blends that can achieve insulation R-values within at least 70% that of traditional blown cellulose fiber. To achieve this goal, we designed the testing matrix based on five different component blends, three different particle sizes, and three different compaction level. An American Society for Testing and Materials (ASTM) method (C-739) was used to measure the R-value of the insulation material. Results showed that, adding more paper component in addition to smaller particle size and loose compaction made the insulation similar to the traditional blown cellulose fiber insulation as the R-value was within a range of 2.5-3.0 per inch.

42 ENGINEERING↗

Performance Assessment of Low-GWP Refrigerated Reach-In Display Cases

This project is part of an effort by Commonwealth Edison Company (ComEd) to evaluate the energy and peak demand savings potential of emerging technologies in the Chicago area. This document focuses on the assessment of energy-efficient, medium-temperature, self-contained refrigerated display cases utilizing environmentally friendly refrigerants. The results of this evaluation will be considered by ComEd and CLEAResult to develop a new energy efficiency rebate measure for ComEd's incentive programs. This rebate measure will become an addition to the Technical Reference Manual. In 2016, the United Nations passed the Kigali Montreal Protocol Amendment, which placed restrictions on certain types of refrigerants. In compliance with this amendment, the U.S. Environmental Protection Agency (EPA) placed a ban on the manufacture of refrigeration systems using hydrofluorocarbons including R134a starting in January 2020. Although the ban has halted manufacture, the EPA continues to allow the use of these refrigerants. Therefore, it is critical to provide incentives for replacing these refrigerants with other environmentally friendly and energy-efficient alternatives.

alternative refrigerants↗

Generating Emissions Inventory for Carbon Capture and Storage Analysis for Carbon-Intensive Industrial Sectors

Decarbonizing the industrial sector is critical to achieve carbon dioxide (CO2) emissions reductions goals of the Biden Administration. Currently available decarbonization options include electrification, fuel switching to zero carbon fuels like green hydrogen (H2) and carbon capture and storage (CCS). Application of post-combustion carbon capture (PCCC) technology in the power sector, as well as research at the U.S. Department of Energy's Fossil Energy and Carbon Management (FECM) Office has shown that its application in the industrial sector could have co-benefits in the form of emissions reductions of non-CO2 regulated pollutants. For example, solvent based PCCC systems require pre-conditioning of flue gas to remove sulfur and particulate matter (PM) upstream of the CO2 absorber. However, there is a lack of understanding about the type of non-CO2 pollutants which can be captured and the amount of reduction possible. PCCC application differs across industrial sectors as it depends on the availability of decarbonization options, characteristics of industrial processes and the amount and composition of pollutant flows. Certain facilities can also have multiple effluent flows with or without a CO2 stream. As such, understanding industrial processes and their effluent flows in detail is required to quantify the co-benefits opportunities presented by PCCC. Considering this requirement, the goal of this analysis is to develop a high-resolution inventory of effluent flows from facilities of 8 industrial sectors in the U.S. These industrial sectors - ethanol, ammonia, cement, steel, natural gas processing, hydrogen, petroleum refining and wood and pulp products - have carbon-intensive effluent flows, and thus are prime candidates for PCCC applications. In this study, we map the composition of pollutant flow from flue stacks across the identified facilities. Using data available in three Environmental Protection Agency (EPA) databases - the Green House Gas Reporting Program (GHGRP), the National Emissions Inventory (NEI) and the Toxic Release Inventory (TRI), we create a combined inventory which lists the type, amount, and concentration of pollutant flows. Using total weight of the pollutant flow back calculated from observed data for CO2 concentrations in flue gas for individual sectors, we calculate the concentration of each pollutant in the flue gas stream. Thus, the resultant emissions inventory includes the following details for each facility in the sector: facility-level and if possible, process-level pollutant flows, concentrations of pollutants in the flue gas, and geographical coordinates of the facilities. A detailed statistical analysis and summary allows us to search for erroneous data and remove them from the final inventory. The generation of the inventory is achieved using a python-based framework which can recreate this inventory for other industrial sectors as well as using newer releases of emission inventories from EPA. The statistical analysis performed on the inventory is also calibrated and automated to identify outliers efficiently.

air pollutants↗

Multi-functional Sorbent Technology (MUST) for the Recovery/Removal of Critical/Heavy Metals from Fossil-Related Wastewater

A collection of remediation and recovery technologies like those predicated on photocatalytic-, electric-, chemical-, membrane-, and adsorptive-based processes currently exists in different stages of development or deployment between these methods of water management. Among these technologies, solid sorbent processes embody an optimal balance between cost-effectiveness, environmental friendliness, and technological maturity. The U.S. Department of Energy’s National Energy Technology Laboratory developed a suit of cross-linked, functionalized silica sorbents tailored to eliminate the most toxic metals regulated by the U.S. Environmental Protection Agency (EPA); critical metals identified by the U.S. Geological Survey (USGS); and harmful organics like the infamous perfluoroalkyl and polyfluoroalkyl substances (PFAS). An array of laboratory and field tests proved that the MUST sorbents removed ppb-level lead from drinking water, selenium from FGD wastewater below EPA limits, aqueous dyes and PFAS; and fractionated low ppm-level critical metals (CM) from AMD and simulated produced water. Proof-of-concept for commercial CM recovery was verified through obtaining milligram-quantities of purified Al solids from a sorbent multi-bed AMD field-site test. Commercial efficacy was further supported by achieving purified fractions of adsorbed Mn upon treating both the AMD and synthetic produced water with the laboratory multi-bed test unit.

Wilfong, Walter C.↗

Challenges in Tracking Waste Reduction Performance Improvement in Manufacturing Plants

The recently released Circularity Gap Report 2023 by Circle Economy Foundation found that the circularity score for the global economy is declining. This indicates that material extraction from virgin sources is climbing over earlier years. As per data released by US Geological Survey, material use in the US economy has increased exponentially with the expanding US economy over last century. EPA tracked municipal solid waste from 1960 to 2018 and found that 50% of the waste is destined for landfills. EPA estimates that US industry is responsible for 2.7 billion ton of solid non-hazardous waste annually in our mostly linear economy model. The circular economy framework aims at decoupling economic value generation from virgin materials extraction from nature. The linear model of material extraction and disposal at end of life is highly unsustainable. Manufacturing companies have realized this and in their commitments to sustainability are adopting ambitious waste reduction targets. Through Better Plants program US Department of Energy has established Waste Reduction Network where it is offering technical assistance to partners to achieve these ambitious waste reduction goals. Basic requirements of establishing a target include identifying a baseline, quantifying waste performance, and measuring progress over time. One problem faced by industry is the unstandardized metrics to quantify waste performance that may not be well suited to demonstrate progress. In this paper, we research methods traditionally used to measure waste performance and highlight advantages, gaps and limitations of each method. Suitability of the methods applicable to different manufacturing circumstances are also examined. Finally, we present a case study of a large manufacturer that faced inconsistencies in their tracked measurement metric. A solution was proposed to alter the methodology to enable more accurate waste performance tracking against a baseline.

Chaudhari, Subodh↗

A Review of Variables Impacting the Indoor Inhalation Radon Equilibrium Factor (FEQ)

With radon and its daughter products estimated as the second leading cause of lung cancer in the United States, it is imperative to understand their relative equilibrium inside commercial, community, and residential dwellings. The radon indoor inhalation fractional equilibrium factor (F eq ) quantifies the disequilibrium between radon and its progeny in indoor air, and recent advances have shown how air exchange rates (ACH) influence F eq . These numerically derived ACH-dependent F eq values are incorporated into the U.S. EPA's Radon Vapor Intrusion Screening Level (RVISL) calculator, which assists risk assessors in evaluating radon exposure. To advance the risk assessment science of actinon (Rn-219), thoron (Rn-220), and radon (Rn-222), the impact of variables such as indoor aerosol concentration and composition, outdoor air quality, household-specific characteristics, and environmental/meteorological conditions on the F eq must be examined. The primary objective of this research is to analyze these additional variables to determine the usefulness of incorporating such adjustment factors into the RVISL calculator and to identify areas of future research. Studies regarding the influence of these parameters are presented along with recommendations regarding the adjustment of the numerically derived F eq value. For example, elevated indoor aerosol concentrations, such as those originating from outdoor PM 2.5 or cigarette smoke, increase the abundance of accumulation- mode particles indoors, which in turn raises F eq values by facilitating the attachment of radon progeny to these aerosols. Smoking increases both the bronchial dose and F eq , while regions with high smog levels demonstrate the impact of regional air quality on F eq . In contrast, air cleaning systems and purifiers have been shown to reduce the F eq , suggesting that these systems could help mitigate radon exposure. Additionally, higher F eq values are typically observed during winter when ventilation rates are lower. This paper presents adjustment factors that may be applied to the RVISL F eq , emphasizing the need for further research to refine these variables and ensure accurate risk assessments in diverse environments. Applying these adjustment factors will minimize calculator over- and underestimations, providing a more accurate representation of the real-world risk associated with radon.

54 ENVIRONMENTAL SCIENCES↗

MS4 - Municipal Separate Storm Sewer System

Stormwater refers to the rainwater or melted snow that flows over land surfaces - including streets, rooftops, and parking lots - that does not infiltrate into the ground. It is collected by storm drains and conveyed through a network of pipes and channels, eventually discharging into streams, rivers, lakes, or oceans. The storm sewer systems on NREL's South Table Mountain (STM) campus, distinct from the sanitary sewer systems, is known as a Municipal Separate Storm Sewer System (MS4).The Environmental Protection Agency (EPA) issued NREL an MS4 Permit for the STM campus to regulate stormwater operations within the boundaries of the STM campus. The STM campus is the only NREL campus to have an MS4 Permit.

ENERGY PLANNING, POLICY, AND ECONOMY↗

Metal Bioavailability and Ecotoxicity of Bioremediated Oils and Tailings by BioTiger{sup TM}, a Microbial Consortium

Oil Sands and Mature Fine Tailings: Oil sand reserves are a major source of oil for the United States. Oil sands are a mixture of sand, clay, water, and bitumen. The refining process requires large volumes of water and generates hazardous Mature Fine Tailings (MFTs) that are stored in engineered settling ponds. They are of major environmental concern due to their persistence and difficulty to naturally biodegrade. MFT Contaminants of Concern: Naphthenic Acids (NAs), Polycyclic Aromatic Hydrocarbons (PAHs), Benzene, Toluene, Ethylbenzene and Xylene (BTEX), Metals, Residual Bitumen. BioTiger{sup TM} (BT{sup TM}), the SRNL patented 12 component microbial consortia was found to cometabolically degrade some NAs and PAHs. Previous studies performing short term exposure (48 hours and 7 days) to BT{sup TM} have resulted in increased toxicity due to the partial degradation of PAHs forming toxic intermediates. Objective: Evaluate the ecotoxicity of BT{sup TM} remediated MFTs exposed to a 2 week period w/ yeast (Y) extract. This work will determine BT{sup TM}'s remediation of MFTs from Fort McMurray, Alberta. Acute toxicity tests will be performed under section 9 of EPA's Method for Measuring Acute Toxicity using the freshwater organism, Ceriodaphnia dubia. Monitor BT{sup TM} growth through Most Probable Number (MPN) counts, pH, and metal bioavailability will also be evaluated. Preparing tailing solutions for biodegradation: BT{sup TM} components were grown in R2A media and combined. Mother BT{sup TM} was centrifuged at 7000 rpm for 20 minutes and resuspended in Bushnell Haus. 33 g of tailings were added to 1100 mL Bushnell Haus along with yeast extract (11 g) to create a 3% tailing solution. Treatments were performed in triplicate. Preparing solutions for toxicity tests using C. dubia: Supernatant was collected immediately after centrifuging at 7000 rpm for 20 min. Supernatant was filtered via a 0.22 μm sterile system. All treatments except MFT, Y peaked at T=4. This decrease in microbial growth could be associated with toxicity from intermediate byproducts. Treatments containing only MFTs decreased in the initial 11 days before growing significantly. Final solution for MFT, Y treatment had the highest pH. This could potentially be due to increased microbial activity linked with yeast consumption. All treatments except MFT, Y peaked at T=4. This decrease in microbial growth could be associated with toxicity from intermediate byproducts. Treatments containing only MFTs decreased in the initial 11 days before growing significantly. Future Direction: Await results from Acute Toxicity Tests and Metal Bioavailability Quantification of biosurfactant production. Evaluate hydrocarbon degradation byproducts using an analytical chemistry approach. More toxicity experiments with variations in time and conditions.

54 ENVIRONMENTAL SCIENCES↗

Panel Session 116: Waste Management from Remediation of Legacy Sites or Unplanned Releases

Past experiences have shown that there is often a disconnect between Indigenous societies and Western society. This disconnect can be attributed to different value systems between these two group and is not limited to the USA and Canada but also extends into Australia, New Zealand, and the Central Asia Republics (the 'five Stans'). The intent of this Panel Session to give voice to representatives from Indigenous communities, the challenges presented in remediation processes, and potential solutions. Standard risk assessment assumptions developed for Western societies often do not adequately address the cultural and spiritual values that may be unique to indigenous societies. This panel focused on the perspectives of Indigenous societies (e.g., Indian Tribes (US), First Nations (Canada)) related to risk assessment of environmental remediation challenges, including deep geological disposal of HLW and ILW, near-surface disposal of LLW and in-situ entombment of nuclear reactor components, and environmental remediation of abandoned uranium mines and historic wastes. Standard risk assessment assumptions often do not adequately address the cultural and spiritual values that may be unique to indigenous societies. Factoring those into a risk assessment that still meets regulatory requirements and policies such as reasonably anticipated land use at US EPA CERCLA sites can be challenging but has the potential to lead to a site or facility approach that is more accepted. Panelists with presentations: The U.S. Nuclear Regulatory Commission Regulatory Process - A Path for Indigenous Knowledge? (Francis Cameron); Local Community Perceptions and Remediation Projects (Michelle Roberts); Indigenous Perspectives on Risk Assessment (Bob Watts); Navajo Superfund Program: Fundamental Law and Traditional Ecological Knowledge (Dariel Yazzie); Risk Assessment: Two Indigenous Approaches (Whitney Fraser)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Panel Session 26: Risk-Based Approaches to Environmental Remediation and Adaptive Site Management

This panel discussed the needs and importance of developing risk-based approaches to environmental remediation that will enable complex sites to be adaptively managed by applying cost-effective remedies that are protective of human health and the environment. The discussion emphasized risk-based approaches within decision processes and subsequent incorporation into regulatory decision documents. Remedy approaches, remediation exit strategies, and long-term monitoring plans that support risk-based end-states for difficult-to-remediate sites were discussed Panelists with presentations: Risk-Informed Approaches to Environmental Remediation and Adaptive Site Management (Vicky Freedman); ITRC Adaptive Site Management Perspective (Michael Truex); Optimization During Operations and Maintenance Phase at the Hanford Site 200-ZP-1 Groundwater Operable Unit (Emerald Laija, Kate Amrhein, Michael Truex); Adaptive Management: EPA Overview (Benjamin Simes); Decommissioning and Environmental Remediation Section Division of Nuclear Fuel Cycle and Waste Technology (Horst Monken Fernandes)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Radiological Recovery Logistics Tool - 20161

Argonne is building and testing a tool, the Radiological Recovery Logistics Tool (RRLT), that can be used during the response and recovery from a radiological or nuclear incident to effectively allocate appropriate commercial and public works equipment to mitigate, remove, and contain radiological contamination. The requirements for this tool - as well as development of the resulting software - is overseen by a steering committee of stakeholders from DHS's National Urban Security Technology Laboratory (NUSTL), the Federal Emergency Management Agency (FEMA), and the Environmental Protection Agency (EPA). One essential requirement is for RRLT to support the efficient and appropriate allocation of resources for a radiological response. Subsequent discussions between ANL and stakeholders have solidified the nature of this support to include identification of the types of resources to be allocated. The study reported in this paper has both factored fundamental concepts and connections out of this identification process and created a Knowledge Base detailing support goals, response scenarios, and efficacy information on dozens of equipment types. In short, RRLT will dynamically apply these findings to situational conditions surrounding contamination incidents. RRLT's Domain, the model of elements, ideas and relationships with which the tool will work, draws concepts from technical reports and stakeholder vocabularies to connect response goals and scenarios to types of equipment that offer utility towards those goals in those scenarios. RRLT's Knowledge Base will contain details on dozens of equipment types and facilitate the operator's discovery and consumption of these details most pertinent to a dynamically selected subset of goals. The core of its Domain Model is based on a report authored by this team. This report [1] contains a comprehensive list of proposed equipment to accomplish various missions or scenarios that might arise after a large-scale radiological contamination incident in an urban environment or critical infrastructure. The report divides potential response and recovery efforts into five support goals: Survey and monitoring of the contaminated area; Mitigation of received dose to first responders: Decontamination (gross and final) of buildings, vehicles, roadways, parks, and other surfaces: Waste management of solid waste generated during recovery operations: and Containment of wastewater and other waste generated during the response and recovery phases. RRLT's development is driven by use cases. A use case is an intention with which a user approaches the software. Use cases are grouped into delivery increments to schedule development, testing, and presentation to stakeholders. This model partitions the system into seven increments: User Arrival and Authentication, Search and Navigation, Equipment Recommendation, Plan Management, Content Management, and Expanded Access. Once a user 15 authenticated, RRLT will present the user with a dashboard that allows them to explore or search RRLT's content. The dashboard will also include a 'Plan' panel for collecting decisions and relevant observations about an incident at hand to facilitate development of an equipment list. RRLT will offer three general modes of access to items in the knowledge base: - Keyword search for direct discovery of items, - Navigation along predetermined paths from recovery goal towards equipment types, and - Interactive guidance towards equipment types by an autonomous software agent: the Equipment Recommendation Wizard. This presentation will detail progress in the development of the RRLT and also discuss opportunities for those interested in providing feedback on its content and functionality. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Approach to Quality Assurance for Complex Environmental Modeling - 20407

A strong Quality Assurance (QA) program for complex environmental modeling is essential for regulatory and public acceptance and trust, but it does not have to be onerous. Neptune and Company, Inc. (Neptune) has developed a strong QA program that improves transparency, traceability, reproducibility, and therefore, defensibility and trust. Neptune's QA program has evolved over the past 27 years, transitioning from an ad hoc QA program, to a program that is currently Nuclear Quality Assurance-1 (NQA-1) compliant, and will soon be NQA-1/DOE approved for DOE EM modeling work. In addition, Neptune is a qualified laboratory assessor and qualified auditor for reference materials, a proficiency testing provider, and fully complies with the Environmental Protection Agency (EPA) QA program. Neptune's President and CEO, Kelly Black, was recently named the Chairperson of the International Organization for Standardization (ISO) Technical Committee 69, Application of Statistical Methods. A strong QA program has been developed for Neptune's radiological performance assessment (PA) program. Although pieces of their QA program are currently in development, their current program includes document control using Subversion, issue tracking and work flow tracking using JIRA, and transparency and traceability via a system of 'calc sheets' for documentation of all data analysis and modeling combined with 'check print' documentation of QA checking, and rigorous model testing and configuration control. All work is reviewed by an independent subject matter expert who is not associated with the collection and assembly of information, for an internal peer review. The program is enforced with a handful of Standard Operation Procedures (SOPs), Work Instructions, QA Project Plans (QAPPs), and Quality Management Plans (QMPs) that are updated frequently, with required annual training and acknowledgment. In addition, effective communication of modeling approaches and results to clients and stakeholders are integral to their QA program. Many of their models are built using the GoldSim modeling platform, for which their models are well-known for their level of transparency, documentation, and QA traceability. This level of QA is also applied to their process-level models. Neptune has taken some lessons learned from the extremely rigorous QA program required for the Yucca Mountain Project (YMP), and imposed the YMP requirements of complete traceability, transparency, and reproducibility, but avoided the inflexibility of a QA program that likely contributed to the suspect e-mails in 2005 that resulted in loss of trust in the YMP, and in nuclear waste disposal (and nuclear power) in general. There are far too many examples of loss of public trust due to poor QA that could have been easily avoided with a simple and straight-forward QA program combined with stakeholder engagement. The purpose of this paper is to share features of Neptune's Radiological Performance Assessment program QA program, and some of their QA related lessons learned over the past 27 years of QA for complex environmental modeling. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Panel Session 12: Effective Aspects of the 2016 Consent Order between DOE-EM-LA Field Office - NM Environment Department and Identifying Comparable Approaches

This panel focused on the extremely effective 2016 Compliance Order on Consent executed between the US Department of Energy (DOE) Office of Environmental Management - Los Alamos Field Office (EM-LA) and the New Mexico Environment Department (NMED) and highlights practices and concepts toward developing an environmental compliance agreement that is mutually productive to both the NMED and the DOE. To further demonstrate successful practices, the panel also highlighted another very effective compliance agreement with comparable approaches - the 1993 Savannah River Site (SRS) Federal Facility Agreement (FFA) executed between DOE, the South Carolina Department of Health and Environmental Control (SCDHEC), and the Environmental Protection Agency (EPA). EM-LA, NMED, SRS, and SCDHEC representatives provided attendees an opportunity to understand and compare extremely effective approaches to regulatory compliance across the complex.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Panel Session 129: Perspectives (US and Non-US) on the Use of Risk and Dose Assessment Tools (R9.3)

This panel focused on various dose and risk assessment tools for assessments, Deactivation and Decommissioning, remediation, and closure of sites of chemical and radioactive wastes. Representatives from the US government agencies, non-US countries and their representative regulatory bodies or authorities, as well as performance/risk assessment practitioners compared and contrasted the various guidance from regulatory agencies and authorities on how tools such as the Preliminary Remediation Goals (PRG) calculator, the Dose Compliance Concentrations (DCC) calculator, and Residual Radioactivity (RESRAD) should be used in support of analyses and decisions for environmental cleanup activities. Panelists with presentations: Cumulative Impact Evaluation: Innovative Tools for Evaluation of Groundwater Protection (Alaa Aly); Superfund Evaluation Process for Alternative Risk and Dose Models (with Focus on EPA and DOE Tools) (Stuart Walker); NRC Staff Perspective on Risk-Informed Approach and Reasonable Safety Assurance in D and D and LLW (Rateb (Boby) Abu Eid)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Panel Session 2: Hot Topics in US DOE Environmental Management

The well-attended Panel Session was chaired by Martin Schneider. The four panelists did not provide presentations. Rather the session was a discussion focusing on pressing issues facing US DOE Environmental Management (EM) sites and how the program is moving forward. The session began by momentarily reflecting on a success: the three Tank Waste Treatment Facilities will soon be coming online. These three facilities will treat as much waste in two years as was treated in the past 30 years. That is a significant milestone in progress. Also, safety enhancements at WIPP are a big success. The panelists noted that there will be challenges with the victories of the startup of the Waste Treatment Facilities. Treating tank waste is the last EM mission and will help with the relationships with the stakeholders, regulators and Congress. One of the biggest challenges will be moving back to full operation mode. Although the operation will increase productivity of reducing/managing the tank waste, it will decrease life cycle cost and lessen years of cleanup. The challenge will be having people understand that EM will be operating 24/7 and that maintenance will be key in keeping the operations. EM will be working together with the regulators to show tangible progress that will be effective and efficient. By working together, they can find opportunities/technologies for streamlining and accelerating cleanup. Recent changes to the regulatory framework between DOE-EM Los Alamos Field Office and New Mexico Environmental Department have helped cleanup in Los Alamos. Every year EM and the agencies review progress and come to agreements on the next work priorities. At Savannah River Site, the Federal Facility Agreement among EM, South Carolina Department of Health and Environmental Control, and Environmental Protection Agency (EPA) has developed a small core team that work are shared by together in resolving issues that come up. The discussion moved on to how progress can be made by sharing lessons learned among the contractors. An example of how these learned lessons can be shared is that key representatives from projects across the EM sites participate in various forums to review/contribute to the work planned. Other opportunities can be by temporary assignments of DOE staff to gain experience and by monthly EM Headquarters report that provide the lessons learned across the EM sites. The panelists discussed how skyline changes are the best examples of tangible progress. Decontamination and Demolition (D and D) of structures are the easiest tangible progress that can be seen. Whereas tank waste cleanup is the hardest to see. Disposal of waste onsite versus offsite is another challenge, and timely discussions are necessary to get to the best value to the government.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Calculating Potential Radiological Emissions for Waste Management Activities at INL - 20068

At Idaho National Laboratory (INL), work involving radionuclides is evaluated for potential emissions from a project in order to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations, 40 CFR 61 Subpart H. Emission calculations are documented in an Air Permitting Applicability Determination (APAD) to analyze unmitigated and mitigated emissions and determine if an Application to Construct (ATC) or continuous monitoring is required. To calculate the unmitigated and mitigated emissions, a spreadsheet was developed to provide ease in determining potential emissions by providing the maximum operating temperature and the material being used. The spreadsheet aids in determining the potential emissions for research projects and waste management activities at Materials and Fuels Complex (MFC) and other locations across the INL site. Furthermore, it can also be used for periodic confirmatory measurements (PCM) to justify low emissions. Elements that factor into the unmitigated and mitigated calculations include the amount of each radionuclide used (in curies or grams), specific activity (if amount is given in grams), the temperature the material is heated to in Celsius, the dose conversion factor which is derived from Clean Air Act Assessment Package - 1988 (CAP-88) modeling, and the number of HEPA filters used for mitigated measures. The main drivers for calculating the unmitigated emissions for a project are the amount used per radionuclide, the maximum operating temperature, and the location of the work. The maximum operating temperature determines the airborne release factor which is dependent on the physical state of the radionuclide. Prior to October 2017, if the radionuclide was heated to greater than 100 deg. C, the radionuclide was assumed to be a gas, which has the highest airborne release factor. This assumption would be overly conservative for radionuclides with high melting and boiling points, which provided a challenge to demonstrate low emissions. In October 2017, the Environmental Protection Agency (EPA) approved an alternative method for INL. This method allows the airborne release factor to be determined by using the melting point and 90% of the boiling point of the radionuclide. This methodology was included in the spreadsheet to allow unmitigated emission calculations for APADs to be completed more efficiently and effectively. Results show a reduction in time completing air emission calculations as well as lower total emissions across all facilities at INL. MFC annual emissions were reduced by 62% from the previous year and Research and Education Campus (REC) facilities were reduced by 38% due to implementation of the approved alternative method. Time spent on APADs, PCMs, and documentation for the annual NESHAP report was also reduced significantly. The spreadsheet provided in Table I provides the potential emission calculations for the 'Advanced Retrieval and Disposition Techniques for Remote Handled Mixed Low Level Waste (RH MLLW) at the Radioactive Scrap and Waste Facility (RSWF)' project. Calculations show the Potential Effective Dose Equivalent (PEDE) at RSWF to be 7.27 E-04 mrem/yr (7.27 E-09 Sv/yr) which is well below the 0.1 mrem/yr threshold. (authors)

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A Preliminary Radiological Risk Assessment Model for Disposition of Remote-Handled Transuranic Wastes at Los Alamos National Laboratory Area G - 20116

The U.S. Department of Energy (DOE) operates a low-level radioactive waste (LLW) disposal site at Material Disposal Area G, in Los Alamos, New Mexico, USA. Area G has been the primary LLW disposal site for Los Alamos National Laboratory (LANL) since the 1960's. In addition to LLW, Area G is host to a variety of other wastes, the disposition of which must be determined before closure of the site. A probabilistic Radiological Risk Assessment (RRA) for Area G is used in order to support decision making regarding some wastes that are not addressed in the extant Area G Performance Assessment (PA) and Composite Analysis (CA). Between 1979 and 1987, 33 special shafts were augered into the Bandelier Tuff at Area G. This volcanic tuff is present across Pajarito Plateau on the eastern slopes of the Jemez Mountains, and varies widely in its consistency, from weakly indurated non-welded layers to welded layers that uphold the mesa cliffs of the Plateau. These mesas are home to LANL, Area G, and the townsites of Los Alamos and White Rock, with residences about 1400 m from Area G. The 33 Shafts were lined with steel casing, and contain remote-handled (RH) transuranic wastes (TRU) resulting from experiments and analysis performed in special glove boxes at the Chemistry and Metallurgy Research (CMR) facility at LANL. Some of these wastes originated as used nuclear fuel. The purpose of the Area G RRA is to evaluate the potential future risk to humans and the environment from the RH TRU in the 33 Shafts in the context of the risk associated with the surrounding wastes at Area G. The analysis is responsive to expectations outlined in DOE Order 458.1, Radiation Protection of the Public and the Environment, and is informed by the Manual and Guidance accompanying DOE O 435.1, Radioactive Waste Management. Because the waste meets the definition of TRU, the regulatory context necessarily takes into consideration the regulation governing the disposal of TRU from the U.S. Environmental Protection Agency (EPA): 40 CFR 191, Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes. Given the broader regulatory context for the RRA, the analysis is subject to different assumptions from those made in the existing DOE O 435.1 PA and CA, such as allowing for future occupation of the site. The analysis begins with a comprehensive evaluation of features, events, processes, and exposure scenarios (FEPS) for Area G and the wastes it contains. These FEPSs are screened to eliminate from further consideration those of extremely low probability and/or consequence, and a conceptual site model (CSM) is subsequently developed. The scope and structure of the Area G RRA Model is informed by this CSM, and the Area G RRA Model is developed using the GoldSim systems analysis modeling platform. This paper presents the initial version of a defensible, transparent, and reasonably realistic model, which is based on the state of knowledge of the wastes, the site, and the FEPSs that govern contaminant transport from wastes into the environment and subsequent exposures to humans and other biota. Probabilistic model input distributions represent uncertainties inherent in the real and modeled systems. The results of the Area G RRA Model inform decisions regarding the disposition of the RH TRU in the 33 Shafts. (authors)

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