1. 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

2. 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

3. 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

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

5. 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 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.

6. 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.

7. 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

8. 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

9. 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

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