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At least 19 records

Causal Analysis Report for "Demolition of Historic and Yet-to-be-Determined Radar Towers at TTR Without Completing Required NEPA Process"

Two radar towers at the Tonopah Test Range (TTR), Contraves Towers 22-00 and 12-00, were torn down prior to completion of the required National Environmental Policy Act (NEPA) process. National Technology and Engineering Solutions of Sandia, LLC, (NTESS) submission of the NEPA checklist triggered a Sandia Field Office (SFO) review of the proposed work scope and was to include a required consultation between SFO and the Nevada State Historic Preservation Office (SHPO) to assess any adverse effect(s) on historic properties or contributing element(s) to a historic district and, if so, determine a resolution. Following the consultation, SFO provides approval/denial of the proposed work detailed on the submitted NEPA checklist. Contraves Tower 22-00 is a historic structure, as formally determined by the SFO in consultation with the SHPO. The historical eligibility of Contraves Tower 12-00 is yet to be determined. On February 13, 2018, NTESS notified SFO that Contraves Tower 22-00 at TTR was torn down in May 2017 prior to completion of the required the NEPA process, including consultation with the SHPO. NTESS submitted two NEPA checklists to SFO in 2016 for the removal of several structures no longer required by NTESS. The first NEPA checklist listed three historic structures (one of which was Contraves Tower 22-00) and SFO determination on whether consultation with the SHPO is necessary as well as approval/denial of the NEPA checklist is pending. The second NEPA checklist listed five non-historic structures, one of which was Contraves Tower 12-00. SFO approved the NEPA checklist covering non historic structures except for the Contraves Tower 12-00, as the Contraves Tower 12-00 requires further consultation with the SHPO by SFO. Only after completion of the consultation would SFO determine approval/denial on the remaining property cited within the NEPA checklist. In late January 2018, NTESS personnel discovered that Contraves Tower 22-00 was no longer listed in the Facility Information Management System (FIMS). Upon further investigation, NTESS personnel verified that the Contraves Tower 22-00 had been removed in May 2017. During the initial extent of condition, it was discovered that Contraves Tower 12-00 had also been torn down in May 2017 as part of this same destruction and demolition (D&D) activity. Both Contraves Towers 22-00 and 12-00) had been torn down prior to completion of the NEPA process, including consultation with the SHPO.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

NEPATEC2.0: NEPA Text Corpus v2.0

The National Environmental Policy Act of 1969, as amended (NEPA), is a major environmental law in the United States, requiring Federal agencies to consider and document potential environmental impacts before deciding on a proposed action. Modernization of NEPA and permitting processes faces significant challenges due to the lack of standardized formats and interoperable systems for organizing and sharing NEPA-related information across agencies. Much of the information gathered during NEPA reviews is written into documents such as categorical exclusions, environmental assessments, and environmental impact statements, then filed in predominately independent agency file stores that may or may not be publicly accessible. The application of metadata and data standards, such as those recommended by the Council on Environmental Quality (CEQ), to NEPA documents offers a shared vocabulary and structure for key entities like projects, processes, and documents that can streamline information exchange and enhance collaboration across systems. In this work, we publicly release NEPATEC2.0, an expanded corpus of NEPA documents with associated metadata. NEPATEC2.0 encompasses approximately 120,000 documents from 60,000 projects prepared by more than 60 different agencies. Modeled to align with CEQ metadata standards, NEPATEC2.0 promotes consistency in environmental reviews and supports the ongoing effort to modernize permitting technologies by facilitating more transparent, efficient, and data-driven decision-making. Importantly, NEPATEC2.0 demonstrates the possibilities and limitations of large language model-based prompting to extract information from NEPA documents at scale.

environmental review↗

PermitTEC v0.1: Standardized Metadata Corpus of NEPA Litigation Documents

The National Environmental Policy Act of 1969, as amended (NEPA), mandates that federal agencies assess and document potential environmental impacts before deciding on proposed actions. While significant progress has been made in cataloging and standardizing NEPA documents themselves, the legal challenges that frequently arise from these decisions remain poorly cataloged and largely inaccessible for systematic analysis. Litigation challenging NEPA compliance can substantially delay project timelines, reshape agency decision-making, and establish precedents that influence future environmental reviews — yet no standardized, machine-readable corpus exists that links litigation records to the NEPA projects they contest.

54 ENVIRONMENTAL SCIENCES↗

Summary Report for the NEPA Impact Analysis. Revision 1

The Waste Isolation Pilot Plant (WIPP), located in southeastern New Mexico, has been developed by the U.S. Department of Energy (DOE) for the geologic (deep underground) disposal of defense-related transuranic (TRU) waste. Containment of TRU waste at the WIPP facility is derived from standards set forth in Title 40 of the Code of Federal Regulations (CFR), Part 191. The DOE assesses compliance with the containment standards according to the Certification Criteria in Title 40 CFR Part 194 by means of Performance Assessment (PA) calculations performed by Sandia National Laboratories (SNL). WIPP PA calculations estimate the probability of radionuclide releases from the repository to the accessible environment for a regulatory period of 10,000 years after facility closure. The DOE Carlsbad Field Office (CBFO) has initiated a National Environmental Policy Act (NEPA) action for a proposal to excavate and use additional transuranic (TRU) waste disposal panels at the WIPP facility. This report documents an analysis undertaken as part of an effort to evaluate the potential environmental consequences of the proposed action. Although not explicitly required for a NEPA analysis, evaluations of a dose indicator to hypothetical members of the public after final facility closure are presented in this report. The analysis is carried out in two stages: first, Performance Assessment (PA) calculations quantify the potential releases to the accessible environment over a 10,000-year post-closure period. Second, dose was evaluated for three hypothetical exposure pathways using the conservative radionuclide concentrations assumed to be released to the accessible environment.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Workshop Summary Report on Using AI Tools to Improve the Efficiency and Outcomes of the NEPA Process: AI for Permitting Workshop at the 2025 National Association of Environmental Professionals (NAEP) Annual Conference

On April 29, 2025, the U.S. Department of Energy and Pacific Northwest National Laboratory hosted a workshop at the National Association of Environmental Professionals 2025 Conference and Training Symposium in Charleston, South Carolina, titled, “Effective and Responsible Use of Customized AI Tools to Improve the Efficiency and Outcomes of the NEPA Process.” The objectives of this workshop were to make environmental practitioners aware of the potential for using artificial intelligence in the National Environmental Policy Act process, demonstrate examples of how artificial intelligence can be integrated effectively to improve efficiency and outcomes and solicit questions and feedback from practitioners. This report summarizes the key points from all talks and case studies, as well as audience questions and feedback on the presentation topics and the broader topic of "AI in permitting". The report concludes by highlighting the key barriers and opportunities for the implementation of AI in permitting, as discussed during the workshop.

54 ENVIRONMENTAL SCIENCES↗

What is NEPA? aka "National Environmental Policy Act"

Give an overview of the NEPA, the National Environmental Policy Act' describing the basics, rule of thumb, what to look for, examples, and how resources are used to prepare environmental documents.

99 GENERAL AND MISCELLANEOUS↗

2020 NEPA Polychlorinated Biphenyl (PCB) Risk Assessment

The Waste Isolation Pilot Plant (WIPP) facility is a U.S. Department of Energy (DOE) operating repository 654 m below the surface in a thick salt formation in southeastern New Mexico. The DOE disposes transuranic (TRU) waste produced from atomic energy defense activities at the WIPP facility. A portion of the waste shipped to the WIPP facility contains TRU radionuclides co-mingled with polychlorinated biphenyls (PCBs), which fall under U.S. Environmental Protection Agency (EPA) regulations implementing the Toxic Substances Control Act (TSCA). This report documents the risks of PCBs co-mingled with TRU waste (hereafter designated as PCB/TRU waste) designated for disposal at the WIPP facility. This analysis is input to the National Environmental Policy Act (NEPA) assessment by the DOE Carlsbad Field Office (CBFO) for the proposed increase of the WIPP facility disposal area to include additional waste panels (but not to increase the legislated WIPP volume). This analysis is not a compliance calculation to support a certification renewal nor does it support a planned change request (PCR) or planned change notice (PCN) to be submitted to the EPA.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

NEPATEC v2.0: Standardized Metadata and Text Corpus of National Environmental Policy Act Documents

The National Environmental Policy Act of 1969, as amended (NEPA), is a major environmental law in the United States, requiring Federal agencies to consider and document potential environmental impacts before deciding on a proposed action. Modernization of NEPA and permitting processes faces significant challenges due to the lack of standardized formats and interoperable systems for organizing and sharing NEPA-related information across agencies. Much of the information gathered during NEPA reviews is written into documents such as categorical exclusions, environmental assessments, and environmental impact statements, then filed in predominately independent agency file stores that may or may not be publicly accessible. The application of metadata and data standards, such as those recommended by the Council on Environmental Quality (CEQ), to NEPA documents offers a shared vocabulary and structure for key entities like projects, processes, and documents that can streamline information exchange and enhance collaboration across systems. In this work, we publicly release NEPATEC2.0, an expanded corpus of NEPA documents with associated metadata. NEPATEC2.0 encompasses approximately 120,000 documents from 60,000 projects prepared by more than 60 different agencies. Modeled to align with CEQ metadata standards, NEPATEC2.0 promotes consistency in environmental reviews and supports the ongoing effort to modernize permitting technologies by facilitating more transparent, efficient, and data-driven decision-making. Importantly, NEPATEC2.0 demonstrates the possibilities and limitations of large language model-based prompting to extract information from NEPA documents at scale.

54 ENVIRONMENTAL SCIENCES↗

Adding Impacts and Mitigation Measures to OpenEI's RAPID Toolkit

The Open Energy Information platform hosts the Regulatory and Permitting Information Desktop (RAPID) Toolkit to provide renewable energy permitting information on federal and state regulatory processes. One of the RAPID Toolkit's functions is to help streamline the geothermal permitting processes outlined in the National Environmental Policy Act (NEPA). This is particularly important in the geothermal energy sector since each development phase requires separate land analysis to acquire exploration, well field drilling, and power plant construction permits. Using the Environmental Assessment documents included in RAPID's NEPA Database, the RAPID team identified 37 resource categories that a geothermal project may impact. Examples include impacts to geology and minerals, nearby endangered species, or water quality standards. To provide federal regulators, project developers, consultants, and the public with typical impacts and mitigation measures for geothermal projects, the RAPID team has provided overview webpages of each of these 37 resource categories with a sidebar query to reference related NEPA documents in the NEPA Database. This project is an expansion of a previous project that analyzed the time to complete NEPA environmental review for various geothermal activities. The NEPA review not only focused on geothermal projects within the Bureau of Land Management and U.S. Forest Service managed lands, but also projects funded by the Department of Energy. Timeline barriers found were: extensive public comments and involvement; content overlap in NEPA documents, and discovery of impacted resources such as endangered species or cultural sites.

15 GEOTHERMAL ENERGY↗

Data call questions related to potential NEPA/Data gaps

Based on review of the related NEPA documents, and consideration of the potential gaps in NEPA coverage, a number of questions have been generated. These questions are generally higher level (less detailed) questions that should help to establish the applicability of analyses in existing NEPA documents and the ability of these documents to provide NEPA coverage for the Proposed Action. These questions do not request detailed information about SRS facilities/activities and the Proposed Action like typically would be requested when performing impacts analyses for an EIS. We do not believe detail information is needed; if it is needed, it may be an indication that an SA is not the appropriate level of NEPA documentation for the Proposed Action.

54 ENVIRONMENTAL SCIENCES↗

PNNL Review of Federal and State Agency Regulatory Streamlining Practices

All major federal actions that have the potential to significantly affect the environment (e.g., land purchases and/or issuing grants, permits, leases, or licenses) are subject to multiple statutes including the following: • an environmental analysis under the National Environmental Policy Act (NEPA) • potential consultations with the U.S. Fish and Wildlife Service (USFWS) and/or National Marine Fisheries Service (NMFS) under the Endangered Species Act of 1973, as amended (ESA) • potential consultations with State Historical Preservation Officers (SHPOs) and/or tribal nations [often Tribal Historic Preservation Officers (THPOs)] under the National Historic Preservation Act of 1966 (NHPA). Given the size of the federal government and the corresponding variability and complexity in its missions, different branches within the federal government have a fairly wide range of approaches to fulfill their NEPA and consultation requitements. Many of these approaches are founded on the desire to streamline their NEPA and consultation processes while meeting the spirit and letter of the regulations. Some federal and state environmental/engineering agencies have developed web-based dashboards that provide a single web location for permit application submittals. They also use general permits in their various permitting processes. General permits can streamline the permitting process by establishing identical requirements for all eligible applicants. This reduces the time these agencies need to spend reviewing individual permits and setting specific requirements. In addition, general permits do not require a case-specific permit application. This paper presents a sampling of effective agency examples of streamlining the NEPA process and associated agency consultations. It also includes several examples of federal and state agency web portals, online application systems, and general permits that make application processes more efficient and accessible.

54 ENVIRONMENTAL SCIENCES↗

Environmental Concerns and Mitigation Associated with Geothermal Resource Confirmation Drilling Activities

In 2017-2018, the Bureau of Land Management's National Renewable Energy Coordination Office, through its Geothermal Program, funded the National Renewable Energy Laboratory (NREL) to analyze technical and environmental considerations related to geothermal resource confirmation drilling. NREL solicited input from a group of technical and environmental experts in the geothermal industry, along with analyzing National Environmental Policy Act of 1969 (NEPA) documentation for previously approved projects. The collected data and analysis will be used by the Bureau of Land Management to examine the possibility of developing a new classification of wells and/or expediting the NEPA compliance process, which could potentially reduce permitting and regulatory compliance timelines when compared to the current process for obtaining a geothermal drilling permit for resource confirmation drilling activities.

15 GEOTHERMAL ENERGY↗

Fueling Nuclear Research at MFC: The Environmental Backbone of Nuclear Operations

The National Environmental Policy Act (NEPA) review guidelines are an essential part of the approval process of any construction or modification being done at Idaho National Laboratory (INL). The Material and Fuels Complex (MFC) Environmental team is responsible for writing and reviewing Environmental Impact Statements (EISs), Environmental Assessments (EAs), Environmental Compliance Permits (ECPs), Air Permitting Applicability Determinations (APADs), and other NEPA compliance documentation. This documentation allows for innovation in MFC research by permitting the introduction of new laboratory equipment, research facilities, and materials for researchers to use in their experiments. Without the work of the Environmental team, nuclear research and operations at MFC would not be possible.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Savannah River Site nuclear materials management plan FY 2017-2031

The purpose of the Nuclear Materials Management Plan (herein referred to as “this Plan”) is to integrate and document the activities required to disposition the legacy and/or surplus Enriched Uranium (EU) and Plutonium (Pu) and other nuclear materials already stored or anticipated to be received by facilities at the Department of Energy (DOE) Savannah River Site (SRS) as well as the activities to support the DOE Tritium mission. It establishes a planning basis for EU and Pu processing operations in Environmental Management Operations (EMO) facilities through the end of their program missions and for the tritium through the National Nuclear Security Administration (NNSA) Defense Programs (DP) facilities. Its development is a joint effort among the Department of Energy - Savannah River (DOE-SR), DOE – Environmental Management (EM), NNSA Office of Material Management and Minimization (M3), NNSA Savannah River Field Office (SRFO), and the Management and Operations (M&O) contractor, Savannah River Nuclear Solutions, LLC (SRNS). Life-cycle program planning for Nuclear Materials Stabilization and Disposition and the Tritium Enterprise may use this Plan as a basis for the development of the nuclear materials disposition scope and schedule. This Plan assumes full funding to accomplish the required project and operations activities. It is recognized that some aspects of this Plan are pre decisional with regard to National Environmental Policy Act (NEPA); in such cases new NEPA actions will be required.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Oak Ridge Response to Versatile Test Reactor Environmental Impact Statement Data Request

The Versatile Test Reactor (VTR) is a fast-spectrum test reactor being developed in the United States under the direction of the US Department of Energy Office of Nuclear Energy (DOE-NE). The VTR mission is to enable accelerated testing of advanced reactor fuels and materials required for advanced reactor technologies. The conceptual design of the 300 MWth sodium-cooled metallic-fueled pool-type fast reactor has been led by the US National Laboratories in collaboration with General Electric–Hitachi and Bechtel National, Inc. In support of the VTR project, DOE issued a Notice of Intent (NOI) in the Federal Register on August 5, 2019, announcing the intent to prepare an Environmental Impact Statement (EIS) in accordance with the National Environmental Policy Act (NEPA) and its implementing regulations. The EIS will evaluate alternatives for a versatile reactor–based fast-neutron source facility and associated facilities for the preparation, irradiation, and post-irradiation examination (PIE) of test/experimental fuels and materials. Specifically, the NOI identified two siting alternatives for the VTR reactor facility: Idaho National Laboratory (INL) or Oak Ridge National Laboratory (ORNL). In addition, the NOI also specified two siting alternatives for VTR fuel fabrication: INL and the Savannah River Site (SRS). This report provides information in response to data requests made to ORNL to fill in site-specific knowledge gaps to develop a high-quality EIS. The responses provided are not required to provide full details in every aspect; instead, they adequately bound possible environmental impacts or provide sufficient information to adequately assess likely environmental impacts. This work is being performed under a subcontract from INL to ORNL using DOE-NE funds and is directed by DOE-NE and DOE-ID. Leidos has been contracted by DOE-NE to write the VTR EIS, so most data requests have come from Leidos but were often routed through INL or DOE-ID. DOE-ID is overseeing the NEPA and EIS processes for the VTR project. Leidos will use the information provided in this report to inform the VTR EIS and will also cite this document to establish a clear, publicly available source of the information. Section 2 of this report briefly describes the proposed ORNL VTR Alternative and illustrates the location of the proposed site for the ORNL VTR Alternative. Sections 3 through 7 provide direct responses to data requests received by ORNL. These sections use a tabular format in which data requests are divided into separate items to be addressed; the items are numbered, the data requests are restated with more topical information included, and then the responses are provided. Initial data requests and follow-on requests for additional information (RAIs) are combined under the original data request fields. Finally, Section 8 presents summarized conclusions and describes future work.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

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↗