Lisa Edwards Sr. Program Manager, EPRI LLW Forum April 13-14, 2016 EPRI Implementation Guide for NRC Branch Technical Position on Concentration Averaging and Encapsulation Lisa Edwards Sr. Program Manager, EPRI LLW Forum April 13-14, 2016 Date: March 30, 2016

EPRI R&D: Three Prong Strategy BTP = Branch Technical Position on Concentration Averaging Waste Minimization Class A Minimization Class B/C (ILW) Minimization Liquid Waste Processing Safe Storage Facility Design Waste Forms Waste Containers Storage Facility Operating Guidelines Disposal Flexibility BTP Revision & Implementation Guidance 10CFR61 (US Waste Disposal Regulation) VLLW Global Profiles International Waste Characterization 2016 approach – first don’t generate, second what you do generate if there isn’t disposal – then safely store it (no events) and finally, improve regulatory framework to get increase disposal. 2016 Generate Less, Store Safely, Facilitate Disposal

Part of Overall EPRI Objective to Facilitate Disposal Disposal Flexibility BTP Revision & Implementation Guidance 10CFR61 VLLW Global Profiles International Waste Characterization Produce a sound technical basis to more accurately assess the hazard and risk associated with LLW Use this information to inform discussions related to regulatory changes Maintain disposal safety Reduce worker exposures Potentially increase disposal flexibility approach – first don’t generate, second what you do generate if there isn’t disposal – then safely store it (no events) and finally, improve regulatory framework to get more into the disposal site at a lower cost. The following slides will let you go into deeper discussion about each of the areas. Strategic rather than reactive

Review of Project History 2005 ACNW Issues White Paper on the Need for an Updated Framework for LLW 2006 EPRI Begins Investigating Bases and Technical Options 2007 NRC Strategic Assessment Opens the Door 2007-2012 EPRI Research Identifies Opportunities for Regulatory Change and Supports BTP Revision (EPRI Report 1021098) 2012 Draft BTP Revision 1 Issued by NRC (May) 2012 EPRI Research and Comments (EPRI Report 1025302) 2015 BTP Revision 1 Issued by NRC (February) 2016 Implementation Guide to be published ACNW= Advisory Committee on Nuclear Waste

NRC BTP on Concentration Averaging Document is important to waste classification & disposal costs New revision issued February 2015 Incorporated much of the technical input from EPRI Most significant changes center on: Clear definitions of blendable waste (can be averaged) and discrete items (cannot be averaged) Averaging related to Class limits rather than to container average Clear technical path to determine if filters are blendable Key change: High activity resins can now be averaged with low activity resins May 2016 2016 BTP Implementation Guidance Plant experts, Characterization experts, Disposal site representatives, State regulators, NRC In parallel with the BC Reduction Guide efforts, EPRI was highly engaged with providing technical input to the revision of the NRC Branch Technical Position on Concentration Averaging. In the US, this document is very important in determining how a plant determines the waste classification of particular package of waste - which in turn has a big impact on the disposal cost. The actual NRC guidance was revised and issued last year. It incorporates many suggestions from EPRI. Its complicated, but what this means in a nutshell is that with this revision, if you put your low activity and your high activity resin in the same package, you can average the combined activity over the combined volume of the waste. You couldn’t do that before. This means , if you do the calculations up front, you can figure out the exact right mixture to make it all class A. To take advantage of these changes, EPRI is working on guidance for implementing the new BTP changes due out in the first half of 2016. The working group that developed this guidance was unusual. It of course included shipping experts from the plants, but it also included industry experts on waste classification, disposal site representatives, state regulators from Texas, Utah, South Carolina, and Washington (the agreement states that have disposal facilities), and a representative from the US NRC. The idea was to develop a common understanding of the guidance across the multiple layers of organization that will be responsible for its implementation.

Waste Control Specialists Working Group US NRC South Carolina DHEC Texas TCEQ Washington DoH Exelon Pacific Gas & Electric Southern Company TVA Energy Solutions James Consulting Waste Control Specialists WMG Development of Implementation Guidance Supported by Working Group: Utility subject matter experts Industry waste characterization experts representatives from disposal sites representatives of disposal site state regulatory bodies representatives of the NRC Provided perspectives of the BTP Documented a common understanding and interpretation of the BTP Goal: Consistent Implementation It was not our job to re-write, change, or alter the interpretations but to provide clarification, explanations, flowcharts and examples. The strength in the IG is the working group, perspectives brought to the table, discussions and final consensus.

Implementation Guidance Content Described what each chapter of the BTP meant and how to implement it for each applicable waste stream Provided flow charts and working examples Evaluated the alternative approaches discussed in the BTP; when they may be appropriate and what to consider Compared the revised BTP guidance with the old, identifying what changed analyzed the impact of the change Facilitate full implementation of the BTP Important Slide

Biggest Changes in the BTP Virtually all constraints on blending were removed Averaging is based on waste class limits, rather than package averages Discrete averaging constraint is now a factor of 2 (γ) and factor of 10 (non γ) of the class limit OR activity limits in BTP Tables 2 and 3 Previously 1.5 (γ) and Factor of 10 (non γ) of the package average   Added provisions for treating cartridge filters as blendable waste Expanded Provisions for encapsulation If multiple [blendable] waste streams of a single waste type generated at a licensee’s facility are aggregated for the purposes of operational efficiency, occupational safety, or occupational dose reduction . . . . no demonstration of adequate blending is needed” (similar to 1995 position) For other types of blending, the revised BTP addresses the outputs of the blending process Threshold averaging volumes below which no demonstration of blending is recommended Criterion for demonstrating waste is adequately blended

Regulatory Guidance Change: Impact on U.S. Industry Generation Volumes Design Case Regulatory Actions Required US PWR Units US BWR Units % Higher Classification Waste Remaining Current Practice No Change 100% With Regulatory Guidance Changes 2015 Revision (completed) 10% 1% So going beyond just the container -- What is the potential impact to the US industry overall? Compared to the current generation , PWR generation of the higher activity waste resin could be reduced to 10% of today’s values, and BWRs to 1% of today’s values. This excludes irradiated HW. There other areas of active work investigating institutional control period and use of updated dose conversion factors, this work is not expected to add significantly to the economic benefits previously discussed, they would however increases international alignment on how the risk associated with LLW is treated. 9

Associated EPRI Reports (Reference) 3002003121 Dose Conversion Factor Evaluation and IMPACTS Analysis of Low Level Radioactive Waste 3002000587 A Generic Technical Basis for Implementing a Very Low Level Waste Category for Disposal of Low Activity Radioactive Wastes 1026575 EPRI Global LLW Profile – Generation, Treatment, Conditioning, and Disposition 1025304 Technical Basis to Risk Inform 10CFR61: 2012 Update 1025302 Additional Research Supporting Changes to the Branch Technical Position: Summary of EPRI Input to the Process 1024844 Basis for National and International Low Activity And Very Low Activity Low Level Waste Disposal Classifications 1021098 Options for Improved Low Level Waste Disposal Using 10CFR61.58 1019222 Developing Alternative Low Level Waste Disposal Criteria Per 1-CFR61.58 1016761 Proposed Modification to the NRC Branch Technical Position on Concentration Averaging and Encapsulation 1016120 An Evaluation of Alternative Classification Methods for Routine Low Level Waste from the Nuclear Power Industry 1013506 Technical Development of New Low Level Waste Disposal Options: Industry Strategic Database 1013585 Preliminary Investigation of Alternatives to the Current Disposal Criteria 1009905 Development of New LLW Disposal Options: Phase 1 Interim Report of the EPRI Industry Strategic Database