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AERMOD Screening Dispersion Factors for INL Facilities

This engineering calculations and analysis report (ECAR) documents the calculation of screening level air dispersion factors (DFs) for use in identifying Idaho National Laboratory (INL) air pollutant sources that would not be of concern relative to state of Idaho Department of Environmental Quality (DEQ) significant impact levels for toxic air pollutants (IDAPA 2020). A DF (in units of s/m 3 ) is the maximum time-averaged model-predicted air concentration (g/m 3 ) at an ambient-air receptor location divided by a unit source release or emission rate (1 g/s). DFs were calculated for a generic pollutant released from facilities at the INL Site and the Idaho Falls Research Education Campus (REC) using the Environmental Protection Agency (EPA)-recommended AERMOD air-dispersion model (EPA 2019a) and site-specific meteorological data. The use of AERMOD for air quality analyses is specified by EPA in Appendix W of 40 CFR Part 51, Guideline on Air Quality Models, and by DEQ in their air modeling guidance (DEQ 2013). DFs were calculated for 1-hour, 3 hour, 8-hour, 24-hour, monthly, and annual averaging times.

99 GENERAL AND MISCELLANEOUS↗

Biofuel Air Emissions Analysis

U.S. has goals to produce 3 billion gallons of sustainable aviation fuel (SAF) annually by 2030, increasing to 35 billion gallons by 2050 to decarbonize the aviation sector. Meeting these production targets will require large number of biorefineries to be set up. However, ability to comply with federal air quality standards is prerequisite to being issued a construction permit. Negotiating the permitting process for a new biorefinery can be quite onerous and cost the investors significant time and money. Although there can be numerous reasons for delayed biorefinery construction, air permitting is fraught with pitfalls because the permitting process relies on precedence, which the future SAF biorefineries lack. NREL's Biofuel Air Emissions Analysis project is unique and innovative in terms of the tools, approaches, and analyses provided. NREL is the only national laboratory that is actively working at the intersection of Federal air quality regulations, emissions and air quality analysis across the supply chain, and process design. This project is focused on providing much needed data and analyses that address biorefinery air permitting. This project develops models and quantitative analyses and measures progress towards meeting air quality regulatory requirements. These models and methods are applied to analyze air permitting related to wastewater sludge to biofuel conversion pathways using hydrothermal liquefaction (HTL), impacts of HTL pathway on local and regional air quality including an assessment of health and equity impacts. In addition to filling research gaps, this project also disseminates the findings to the relevant stakeholders at BETO, other national labs, and regulatory agencies.

air quality↗

Air Pollutant Emissions and Regulatory Implications of Co-Processing Raw Bio-Oil in U.S. Petroleum Refineries

Pyrolysis oil, often referred as bio-oil or biocrude, has attracted considerable attention because it has higher energy density and carbon content compared to the raw biomass. Using pyrolysis oil derived from low cost and underutilized biomass to produce renewable hydrocarbon fuels provides a viable link between the agriculture/forestry and (petro-) chemical industry. Co-processing bio-oil with vacuum gas oil (VGO) in petroleum refinery is appealing due to the relatively low capital requirement to retrofit refinery and the compatibility of fuel products with existing infrastructure. In order to implement co-processing, a petroleum refinery would need to consider several process modifications and therefore could be subject to varying levels of air permitting requirements based on bio-oil co-processing ratio, co-processing capacity in existing units, the amount of regulated pollutants expected to be emitted, among other factors. This analysis considers co-processing 5% (by weight) of raw bio-oil with VGO in the fluidized catalytic cracking (FCC) unit(s) in a petroleum refinery. We estimate the potential increase in emissions of regulated air pollutants resulting from the modifications required to implement bio-oil co-processing and evaluate the regulatory and permitting implications for three FCC size categories in the U.S. refineries, which could co-processes raw bio-oil to produce partially renewable transportation fuels. We also assess technically feasible emission control options petroleum refineries could adopt to avoid being subject to major source permitting requirements if the estimated increase in regulated air pollutant emission exceeds the applicable threshold for major modifications. Insights from our analysis can help overcome challenges and risks associated with timely obtaining air permits required to implement bio-oil co-processing in existing refineries. Our analysis also provides needed information for decision makers (e.g., local air quality agencies) to understand the potential air quality implications for retrofitting refineries to co-process bio-oil, particularly in areas with high concentration of petroleum refineries.

09 BIOMASS FUELS↗

Biorefinery upgrading of herbaceous biomass to renewable hydrocarbon fuels, Part 2: Air pollutant emissions and permitting implications

The development of advanced biofuel production facilities is still at a nascent stage, and the biorefineries could face challenges in obtaining air permits required for their construction and operation because they are novel emission sources. To fill gaps in knowledge regarding potential emissions, we perform a detailed federal regulatory analysis and estimate air pollutant emissions for an advanced biorefinery that produces renewable diesel blendstock (RDB) from lignocellulosic biomass via aerobic respiration documented in Part 1 of the paper. We evaluate 12 design permutations that include two feedstocks, a uniform format blend (UFB) and corn stover; three biorefinery scales, 2,000, 5,200, and 9,100 dry metric tons per day (dmtd) of lignocellulosic biomass feed; and two lignin uses, as either a boiler fuel or for pellet production. We also evaluate 6 additional design permutations by incorporating non-emitting renewable power, which could reduce up to 63% carbon monoxide (CO) and nitrogen oxides (NO x ) each, 21% volatile organic compounds (VOC), and 43% hazardous air pollutants (HAP) as opposed to on-site power production, for biorefineries that produce pellets, using either UFB or corn stover. Our results indicate that all 18 design permutations would be classified as a major source under the Clean Air Act's New Source Review program without additional emission controls. Compared to using lignin as a boiler fuel, diverting lignin for pellet production reduces the emissions of CO up to 88%, NOx up to 73%, sulfur dioxide (SO 2 ) up to 99%, VOCs up to 72%, and HAPs up to 66%. Additionally, we explore control options that could further reduce emissions and assess whether reductions are enough to achieve minor source classification. Insights from our analysis can help biorefinery developers and regulators develop permitting strategies to mitigate investment risks.

09 BIOMASS FUELS↗

Pacific Northwest National Laboratory Annual Site Environmental Report for Calendar Year 2020. Final Report

The U.S. Department of Energy requires that all its site facilities develop an annual site environmental report to comply with DOE Order 231.1B, Chg 1, and DOE Order 458.1, Admin Chg 4. This report provides a synopsis of calendar year 2020 information related to environmental management performance and compliance efforts at Pacific Northwest National Laboratory. It summarizes site compliance with federal, state, and local environmental laws, regulations, policies, directives, permits, and Orders, and provides environmental management performance benchmarks and their status to the public, regulatory agencies, community officials, Native American tribes, and public interest groups.

54 ENVIRONMENTAL SCIENCES↗

Pacific Northwest National Laboratory Annual Site Environmental Report for Calendar Year 2021 (Final Report)

The U.S. Department of Energy requires that all its site facilities develop an annual site environmental report to comply with DOE Order 231.1B Chg 1 and DOE Order 458.1 Admin Chg 4. This report provides a synopsis of calendar year 2021 information related to environmental management performance and compliance efforts at the Pacific Northwest National Laboratory. It summarizes site compliance with federal, state, and local environmental laws, regulations, policies, directives, permits, and Orders, and provides environmental management performance benchmarks and their status to the public, regulatory agencies, community officials, Native American tribes, and public interest groups.

54 ENVIRONMENTAL SCIENCES↗

Pacific Northwest National Laboratory Annual Site Environmental Report for Calendar Year 2022 (Final Report)

Pacific Northwest National Laboratory (PNNL), one of the U.S. Department of Energy (DOE) Office of Science’s 10 national laboratories, provides innovative science and technology development in the areas of energy and the environment, fundamental and computational science, and national security. There are three DOE offices within the Richland area. Two are responsible for the Hanford Site, whereas the Pacific Northwest Site Office (PNSO) oversees PNNL. PNNL prepares this Annual Site Environmental Report to meet the requirements of DOE Order 231.1B, Environmental, Safety and Health Reporting, and DOE Order 458.1, Radiation Protection of the Public and the Environment, assuring that the public is informed of any PNNL-Richland Campus or PNNL-Sequim Campus event that could adversely affect the health and safety of the public, site staff, or the environment. The report provides a synopsis of ongoing environmental management performance and compliance activities for operations that occur on the PNNL-Richland Campus in Richland, Washington, and at the PNNL-Sequim Campus near Sequim, Washington. It describes the location of and background for each facility; addresses compliance with applicable DOE, federal, state, and local regulations, and site-specific permits; documents environmental monitoring efforts and their status; presents potential radiation doses to staff and the public in the surrounding areas; and describes DOE-required data quality assurance methods used for data verification. The ASER summarizes site compliance with federal, state, and local environmental laws, regulations, policies, directives, permits, and Orders, and provides environmental management performance benchmarks and their status to the public, regulatory agencies, community officials, Native American tribes, and public interest groups.

54 ENVIRONMENTAL SCIENCES↗

Geologic Seawater Air Conditioning (GeoSWAC) System: Resource Assessment and Techno-Economic Evaluation in Puerto Rico

Puerto Rico's hot, humid climate drives a high and persistent demand for cooling, straining an aging and fuel-dependent energy grid while increasing peak electricity loads. Much of this challenge stems from inefficient air-conditioning systems operating in buildings without passive cooling design, making cooling both costly and vulnerable to disruption - especially during hurricanes. To address these issues, researchers evaluated a new alternative called Geologic Seawater Air Conditioning (GeoSWAC), which uses inland wells connected to naturally cold, deep seawater. By avoiding long offshore pipelines and energy-intensive refrigeration cycles, GeoSWAC can cut electricity use by 75-90%, reduce environmental impacts, and operate more reliably during power outages. A case study at the University of Puerto Rico's Rio Piedras campus found that GeoSWAC could deliver significantly lower levelized costs of cooling, reduced operational expenses, and improved water conservation compared to the campus's existing chilled-water plant. The system offers key advantages - including access to a constant cold heat sink, low pumping requirements, and enhanced resilience - for coastal regions such as Puerto Rico, the broader Caribbean, and Florida. However, its effectiveness depends heavily on site-specific geological conditions, such as subsurface connectivity and aquifer characteristics, which require detailed investigation. Future research should refine hydrogeological models, conduct performance and economic analyses, and address regulatory and permitting frameworks to support broader adoption of this promising technology.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Pacific Northwest National Laboratory Facility Radionuclide Emission Points and Sampling Systems

Battelle–Pacific Northwest Division operates numerous research and development laboratories in Washington State. The U.S. Department of Energy (DOE) contracts to Battelle at Richland facilities on both the DOE Hanford Site and the Pacific Northwest National Laboratory (PNNL) Richland campus. These facilities have the potential for radionuclide air emissions. The PNNL contract with DOE also includes operations at the PNNL-Sequim campus in Sequim, where there is also the potential for radionuclide air emissions. This document is a periodic update that describes current PNNL facility emission units and sampling systems. The National Emission Standard for Hazardous Air Pollutants (NESHAP [40 Code of Federal Regulations 61, Subpart H]) requires an assessment of all emission units that have the potential for radionuclide air emissions. Emission units are registered with the State of Washington. Potential emissions from emission units are assessed annually by PNNL staff. Sampling, monitoring, and other regulatory compliance requirements are designated based on the potential to-emit dose criteria, a graded approach to facility-identified potential impact categories, and regulatory requirements. The purpose of this document is to describe the facility radionuclide air emission sampling program and provide current and historical facility emission unit system performance, operation, and design information. For sampled emission units, the building, exhaust unit, control technologies, and sample extraction details are provided. Additionally, applicable configuration drawings, figures, and photographs are included. For non-sampled emission units, emission estimation and radionuclide source details are provided. Site-wide permits for the lowest potential impact category are described. Deregistered/transitioned emission unit details are also provided as necessary for at least 5 years post-closure/transition. Currently, five emission units are sampled continuously for particulate radionuclides at PNNL managed facilities on the PNNL-Richland campus (3 of the 5) and on the Hanford Site (2 of the 5). Four of these units have sampling systems that comply with the American National Standards Institute/Health Physics Society (ANSI/HPS) N13.1–2011 standard for sampling from stacks and ducts of nuclear facilities, and the fifth is grandfathered and compliant with the older ANSI N13.1–1969 standard. In addition, the PNNL-managed Hanford Site 325 Building EP 325-01-S stack is sampled continuously for emissions of tritium. No emissions sampling is required for the single licensed emission unit on the PNNL-Sequim campus.

54 ENVIRONMENTAL SCIENCES↗

West Valley Demonstration Project (WVDP) Annual Site Environmental Report (ASER) for Calendar Year 2021

The report, prepared for the U.S. Department of Energy West Valley Demonstration Project office (DOE-WVDP), summarizes the environmental protection program at the WVDP for calendar year (CY) 2021. Monitoring and surveillance of the facilities used by the DOE are conducted to verify protection of public health and safety and the environment. The report is a key component of DOE’s effort to keep the public informed of environmental conditions at the WVDP. The quality assurance protocols applied to the environmental monitoring program ensure the validity and accuracy of the monitoring data. In addition to demonstrating compliance with environmental laws, regulations, and directives, evaluation of data collected in 2021 continued to indicate that WVDP activities pose no threat to public health or safety, or to the environment.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Analysis and Recommendation of Tritium Gas Continuous Air Monitor Alarm Setpoints for the RPL Stack Exhaust

The Radiochemical Processing Laboratory (RPL) tritium continuous air monitor (CAM) is used for near real-time detection of tritium gas (i.e., elemental tritium [HT] and tritiated water vapor [HTO]) in the stack exhaust. The CAM interfaces with software developed by the Pacific Northwest National Laboratory (PNNL)—called the “PNNL OS3700 Tritium Monitoring Software”—that provides near real-time estimates of tritium gas air concentrations and integrated daily activities that are calculated from measured CAM counts. The OS3700 software implements alarm setpoints to alert the facility of larger tritium gas releases that if allowed to persist, could begin to challenge permitted emission and established dose constraints. This report performs a detailed review of historical and current tritium alarm setpoints used at RPL, including discussion of the technical basis used in their development, analysis of alarm frequencies using measured historical data, and performs a detailed dose assessment using more realistic release scenarios and meteorology. Based on the results, the tritium air concentration and integrated daily tritium activity alarm setpoints will remain 2.0 × 10 -5 µCi/ml and 25 Ci/day, respectively. These setpoints achieve the right operational balance in identifying larger releases from planned tritium work at RPL, without being overly conservative so as to cause nuisance alarming. Furthermore, implied doses associated with these setpoints are well below defined and regulatory limits.

325RPL↗

West Valley Demonstration Project (WVDP) Annual Site Environmental Report (ASER) for Calendar Year 2020

West Valley Demonstration Project (WVDP) Annual Site Environmental Report (ASER) for Calendar Year 2020. The report, prepared for the U.S. Department of Energy West Valley Demonstration Project office (DOE-WVDP), summarizes the environmental protection program at the WVDP for calendar year (CY) 2020. Monitoring and surveillance of the facilities used by the DOE are conducted to verify protection of public health and safety and the environment. The report is a key component of DOE’s effort to keep the public informed of environmental conditions at the WVDP. The quality assurance protocols applied to the environmental monitoring program ensure the validity and accuracy of the monitoring data. In addition to demonstrating compliance with environmental laws, regulations, and directives, evaluation of data collected in 2020 continued to indicate that WVDP activities pose no threat to public health or safety, or to the environment.

Resource Conservation and Recovery Act↗

Final Status of HEPA Filter 10-Year Lifetime Evaluation

High-efficiency particulate air (HEPA) filters are widely employed by nuclear facilities to remove radiological particulate matter from their effluent exhaust streams. The purpose of this study is to evaluate the relationships between the 10-year HEPA filter lifespan and its other performance indicators. The 10-year-long endeavor to collect and analyze data regarding the lifetime of HEPA filters at the Pacific Northwest National Laboratory began in 2010. Forty-nine HEPA filters were selected and have been surveyed and analyzed at least annually to verify compliance with permit conditions. The study suggests the frequency of filter replacement should be based on the actual operational requirements, such as fume hood face velocity and/or efficiency test results, instead of on the prescribed filter “age limit” of 10 years from the date of manufacture (e.g., birth date) when operating under dry conditions. Over the past decade, the study has now been completed, and all forty-nine HEPA filters have been replaced, due to either technical issues listed in this report, or the previously recommended filter “age limit” of 10 years.

61 RADIATION PROTECTION AND DOSIMETRY↗

Design and permitting considerations of a floating hydrogen production and dispensing Barge for the Port of San Francisco

This paper reports on the design of a Floating Hydrogen Production and Dispensing Barge destined for the Port of San Francisco (SF). The H 2 Barge is designed to produce renewable H 2 at the rate of ∼530 kg/day, storing 512 kg of hydrogen at 517-bar, allowing fast refueling of hydrogen fuel cell vessels and land-side hydrogen delivery trailers for distribution into the nascent SF hydrogen ecosystem. The broader considerations that impacted H 2 Barge design are also described. An account is given of a new review process formulated by the United States Coast Guard (USCG) to review this first-of-its-kind maritime implementation of hydrogen technology. Furthermore, the immediate goals of the H 2 Barge Project are to 1) demonstrate the feasibility, viability and methods of hydrogen production, storage and fueling in a maritime context, 2) help shape (where needed) and navigate the required local, state and federal regulatory gauntlet and 3) catalyze a “green hydrogen ecosystem” (both marine and landside) with locally produced renewable hydrogen at the San Francisco waterfront.

08 HYDROGEN↗

Radiological HEPA Filter 10-year Lifetime Evaluation in Research Facilities

High-efficiency particulate air (HEPA) filters are widely employed by nuclear facilities to remove radiological particulate matter from their effluent exhaust streams. The purpose of this study is to evaluate the relationships between the 10-year HEPA filter lifetime deployment and its other performance indicators. This 10-year-long endeavor to collect and analyze data regarding the service life of HEPA filters at the Pacific Northwest National Laboratory began in 2010. A set of HEPA filters were selected and have been surveyed and analyzed at least annually to verify compliance with permit conditions. The study suggests the frequency of filter replacement should be based on the actual operational requirements, such as fume hood face velocity and/or efficiency test results, instead of on the prescribed filter “age limit” of 10 years from the date of manufacture (e.g., birth date) when operating under dry conditions. The study has now been completed, and over the past decade all the HEPA filters have been replaced, due to either technical issues as listed in this report or the previously recommended filter “age limit” of 10 years as prescribed by the oversight bodies. Experimentally determined failure rates are also determined from the data set and can be used to estimate the chances of HEPA filters surviving 15, 20, or even 30 years.

61 RADIATION PROTECTION AND DOSIMETRY↗

Assessment of the 3420 Building Filtered Exhaust Stack Sampling Probe Location: Stack Verification Following Fan and Air Blender Additions

The Pacific Northwest National Laboratory (PNNL) 3420 Building, which is part of the Physical Sciences Facility (PSF), houses radiological capabilities that results in the requirement that emissions monitoring must be conducted for potential radionuclides in the exhaust air discharge of this building. The air monitoring system is required to conform to Title 40 of the Code of Federal Regulations part 61 (40 CFR 61) Subpart H, which in turns requires a sampling probe in the exhaust stream to conform to the criteria of American National Standards Institute / Health Physics Society (ANSI/HPS) N13.1-2011, Sampling and Monitoring Releases of Airborne Radioactive Substances from the Stack and Ducts of Nuclear Facilities. To support the air emissions permit for the 3420 Building on the PNNL campus, stack testing that used computational fluid dynamics (CFD) modeling as a surrogate stack and verification tests of velocity uniformity and flow angle on the retrofitted facility stack was performed. The ANSI/HPS N13.1-2011 criteria for the air monitoring probe location are that velocity uniformity, gaseous tracer uniformity, and particulate tracer uniformity must be less than or equal to 20%COV. Furthermore, no point in the sampling location may have a gaseous tracer concentration that varies from the mean concentration by more than 30%. Additionally, the flow angle at the sampling location must not be more than 20°. The CFD modeling of the stack, as reported by Recknagle et al. (2018) demonstrated that the stack meets the criteria at the probe location. The velocity uniformity and flow angle results from the 3420 stack verification tests, performed in October 2020, demonstrated that the CFD model results may be used to support the qualification of the stack sampling location. The measured velocity uniformity verification test result was 1.4%COV. This value is well within the uniformity criterion, which is that the velocity uniformity be =20%COV. Additionally, this value is well within the criterion that the actual stack measurement must be within 5% of the surrogate stack result of 2.1%COV when all four fans were operating. Additionally, the measured average flow angle at the 3420 stack monitor location was 15.5 degrees. Although this is higher than expected based on the CFD model, the result is =20 degrees, so the criterion is met. Based on these stack verification test results, the reconfigured 3420 Building filtered exhaust stack meets the qualification criteria given in the ANSI/HPS N13.1-2011 standard. Further changes to the system configuration or operating conditions that are outside the bounds described in this and the CFD report (Recknagle et al., 2018) may require additional tests and additional analysis to determine compliance with the standard.

3420 Building↗