EPRI Strategies for Managing Liquid Effluents Options Actions and Results

Strategies for Managing Liquid Effluents—
Options, Actions, and Results
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Technical Report
Strategies for Managing Liquid
Effluents—Options, Actions, and
Results
1008015
Final Report, November 2003
EPRI Project Manager

S. Bushart
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iii
REPORT SUMMARY
The challenge of balancing several factors, including public perception and site management
goals, faces utility managers optimizing their radioactive liquid effluent programs. This
document provides a standardized methodology for decision making when setting site effluent
goals, and provides the tools needed to justify equipment or policy changes to utility and public
stakeholders.
Background
A variety of factors impacts the optimized management of a nuclear power plant’s liquid
effluents program. The absence of an acceptable, comprehensive methodology for evaluating and
coordinating that program, along with a host of related issues, continues to pose a challenge to
effluents program managers. This document outlines a generic liquid effluents analysis method.
Objectives
• To develop a generic methodology for accurately analyzing a nuclear power plant’s liquid
effluent processing program, and to thus define site-specific effluents management strategies.
• To provide insight and direction to a team of station experts that will result in a balanced
radioactive liquid effluent management program.
• To strengthen the utility’s ability to demonstrate that the plant has taken reasonable actions to
protect the general public.
Approach
The project team assembled a task force comprised of utility and industry effluents program
professionals representing Radwaste, Effluents, and Chemistry disciplines to review related
challenges and experience. The task force conducted several meetings to define and document an
industry acceptable process for evaluating and, where applicable, improving liquid effluents
strategies. This effluents strategy analysis methodology is the product of that effort.
Results
Very early in this project, it became apparent that defining an effluents strategy that is acceptable
to all nuclear power plants is not practical. The program considerations provided in this
evaluation methodology are representative of the proactive management of liquid effluents that
maintains a focus on environmental stewardship in parallel with regulatory compliance and
process cost-efficiency. Plant managers can use the methodology to facilitate periodic reviews of
a site’s effluents program to validate its current direction and success. Utilities can also use it to
evaluate proposed changes to an existing program to ensure that once implemented, those
changes will result in continued long-term program optimization.
v
EPRI Perspective
Our utility members have been highly successful in managing their effluents to levels well below
regulatory limits. Since the various stations used a wide variety of strategies to realize these
minimal effluent levels, utilities suggested the need for a standardized program evaluation
approach at several EPRI forums. The resulting report will be useful in both program
optimization, and in communicating the need for a balanced effluent program to utility and
public stakeholders. The EPRI team benefited greatly from the experience and knowledge
provided by an expert industry panel for this project. The panel will continue to meet after this
project, and will next focus on tritium management strategies.
Keywords
Liquid effluents
Solid effluent
Gaseous effluent
Effluent activity
Liquid radwaste processing
Public exposure reduction
Occupational exposure reduction
vi
EPRI Licensed Material
ACKNOWLEDGMENTS
EPRI would like to thank the members of the Liquid Effluents committee formed to undertake
this important project. Those sites and the primary site contacts were:
Miguel Azar, Exelon Midwest ROG

John Bundick, DC Cook
Al Castagnacci, FENOC, Beaver Valley
Richard Conatser, Constellation Nuclear Services, Inc., Calvert Cliffs
Kenneth Embury, Ortec
Brian Falcus, British Energy
Jeff Gardner, PG&E, Diablo Canyon
Steve Gebers, OPPD, Ft Calhoun
Paul Genoa, NEI
Ed Hlavin, Southern Company, Vogtle
Clint Miller, PG&E, Diablo Canyon
David Miller, AEP DC Cook
Bob Moore, FENOC, Beaver Valley
Bob Oliviera, ANI
Bernie Pineda, TXU, Comanche Peak
Milt Rejcek, South Texas Project
Steve Sandike, Entergy Nuclear Northeast, Indian Point Energy Center
Ken Sejkora, Entergy Nuclear Northeast, Pilgrim
Paul Snead, Progress Energy
Cindy Weer, NPPD, Cooper
William G. Wendland, P.E., American Nuclear Insurers
Martin Wright, PG&E, Diablo Canyon
vii
CONTENTS
1 SENIOR MANAGEMENT BRIEF......................................................................................... 1-1

Senior Management Brief................................................................................................... 1-1
Business............................................................................................................................. 1-3
Successful Program Management...................................................................................... 1-4
Program Direction and Focus ............................................................................................. 1-4
2 PROJECT BACKGROUND AND OBJECTIVES ................................................................. 2-1

Background ........................................................................................................................ 2-1
Objectives .......................................................................................................................... 2-2
Approach............................................................................................................................ 2-2
Recommended Report Use ................................................................................................ 2-2
Report Organization ........................................................................................................... 2-2
3 DEFINITIONS ...................................................................................................................... 3-1
4 CURRENT INDUSTRY PERFORMANCE AND GOALS...................................................... 4-1

Introduction ........................................................................................................................ 4-1
RadBench .......................................................................................................................... 4-1
Current Industry Performance ............................................................................................ 4-3
Environmental .................................................................................................................... 4-7
Summary............................................................................................................................ 4-9
5 INDUSTRY CHALLENGES ................................................................................................. 5-1

Goals and Performance Indicators ..................................................................................... 5-1
Industry Agencies............................................................................................................... 5-2
Technology......................................................................................................................... 5-2
Business............................................................................................................................. 5-2
The Future.......................................................................................................................... 5-4
ix
6 METHODOLOGY BACKGROUND & RATIONALE & ASSUMPTIONS .............................. 6-1

Phase I – Current Radwaste Strategy ................................................................................ 6-1
1) Draft a program review statement - why is this evaluation being performed?......... 6-1
2) Assemble a multi-discipline site team .................................................................... 6-3
3) Assemble or locate the required documentation .................................................... 6-3
4) Define current plant-specific processing/treatment practices and installed
options ........................................................................................................................... 6-4
5) Define current effluent goals .................................................................................. 6-4
6) Identify current & historical plant-specific performance values for effluents
processing/treatment...................................................................................................... 6-5
7) Benchmark current industry effluents performance ................................................ 6-6
8) Define plant-specific sources of batch processing liquid effluents .......................... 6-7
9) Define plant-specific sources of other release liquid effluents ................................ 6-7
10) Model liquid effluent dispersion.............................................................................. 6-7
11) Define plant system chemical applications............................................................. 6-8
12) Review pending changes to plant system chemical applications............................ 6-9
13) Identify pending changes to plant operating strategies and integrate their
impact into this evaluation .............................................................................................. 6-9
14) Identify and review the status of the source-term reduction initiatives .................... 6-9
15) Review EPRI Radioactive Liquid Processing Guidelines and Radwaste Desk
Reference documents (Appendix G, References 15 & 25) ............................................ 6-9
16) Perform a baseline economic analysis (Refer to Appendix F) ...............................6-10
17) Define target performance and cost goal(s) of strategy review .............................6-11
18) Review alternate or advanced processing options relative to goals and
restrictions.....................................................................................................................6-11
19) Validate existing, or define a proposed strategy....................................................6-11
Phase II – Change to a Radwaste Strategy .......................................................................6-11
20) Evaluate a proposed strategy’s compatibility and its impact..................................6-11
21) Review the program impact on insurance premium and liability position...............6-14
22) Review the program impact on all reporting requirements ....................................6-15
23) Perform a second economic analysis that includes the proposed strategy............6-15
24) Develop a comparison matrix; current values versus projections for proposed
strategy .........................................................................................................................6-16
25) Review initial program review statement relative to that matrix – modify
statement, goals or proposed strategy as necessary.....................................................6-16
26) Presentation to Senior management.....................................................................6-16
27) Document and archive the final decision and its basis ..........................................6-16
x
Phase III – Post Implementation Validation.........................................................................6-17

28) Perform a post-implementation economic analysis (Refer to Appendix F) ...........6-17
29) Document post-implementation performance .......................................................6-17
30) Validation of decision and results following implementation .................................6-18
A STRATEGY REVIEW FLOWCHART ................................................................................... A-1
B TECHNOLOGY OVERVIEW................................................................................................. B-1

Filtration ............................................................................................................................... B-1
Selection and Loading Logic ........................................................................................... B-1
Micron rating versus application ...................................................................................... B-1
Anticipated waste stream characteristic fluctuations ....................................................... B-1
Cost versus application ................................................................................................... B-1
Material versus VR and disposal options (i.e., incinerability) .......................................... B-2
Flux & square feet of media............................................................................................. B-2
Carbon Media....................................................................................................................... B-2
Selection and Loading Logic ........................................................................................... B-2
Operation......................................................................................................................... B-2
Changeout & Disposition ................................................................................................. B-3
Ion-exchange media............................................................................................................. B-3
Selection, Blending and Loading Logic ........................................................................... B-3
Operation......................................................................................................................... B-4
Changeout ....................................................................................................................... B-4
Waste Packaging & Disposal .......................................................................................... B-4
Evaporation/concentration/crystallization ............................................................................. B-5
Use Issues....................................................................................................................... B-5
Operation......................................................................................................................... B-6
Maintenance .................................................................................................................... B-7
Waste Packaging & Disposal .......................................................................................... B-7
Membrane Technology......................................................................................................... B-7
Requirements for Effective Membrane Operations ......................................................... B-8
Water Analysis Data ........................................................................................................ B-8
Typical Components............................................................................................................. B-8
Oil Separator ................................................................................................................... B-8
Activated Carbon Filter .................................................................................................... B-8
xi
Prefilters .......................................................................................................................... B-9

Chemical Pretreatment.................................................................................................... B-9
Membrane Selection and Design .................................................................................... B-9
Ion Exchangers.............................................................................................................. B-10
Data Management System Overview ............................................................................ B-10
Dedicated Personnel ..................................................................................................... B-10
Membrane Cleaning ...................................................................................................... B-10
Biofouling Control .......................................................................................................... B-10
Vendor Versus Site Processing.......................................................................................... B-11
Tritium Management .......................................................................................................... B-11
Molecular Separation Inc. Tritium Resin Separation Process ....................................... B-11
Canadian Tritium Processing ........................................................................................ B-12
Tritium Management Research ..................................................................................... B-13
C TECHNOLOGY OR METHODOLOGY COMPATIBILITY CHECKLIST............................... C-1
D STRATEGY REVISION EFFECTIVENESS REVIEW ........................................................... D-1
E ANI – ENGINEERING RATING FACTORS AND PREMIUM ............................................... E-1
F PROGRAM COST ANALYSIS...............................................................................................F-1

Background ...........................................................................................................................F-1
Example Cost Analysis..........................................................................................................F-1
G REFERENCE DOCUMENTS................................................................................................ G-1
H INDUSTRY INFORMATION SOURCES ............................................................................... H-1
I WEIGHTED DECONTAMINATION FACTOR CALCULATION METHOD...............................I-1
J PROGRAM PERFORMANCE INDICATORS.........................................................................J-1
xii
LIST OF FIGURES
Figure 1-1 Balancing Perspectives to Maintain the Desired Vision .......................................... 1-3
Figure 4-1 Sample Data Entry form for Liquid Processing Benchmarking. ............................. 4-3
Figure 4-2 Average US BWR Liquid Effluent MFP and AP, excluding Tritium 1993-2001 ....... 4-4
Figure 4-3 Average US PWR Liquid Effluent MFP and AP, excluding Tritium 1993-2001 ...... 4-5
Figure 4-4 BWR Industry Average Liquid Volume ................................................................... 4-6
Figure 4-5 PWR Industry Average Liquid Release Volume ..................................................... 4-6
Figure 4-6 Sources of Radiation Exposure to the US Population ............................................ 4-8
Figure 5-1 Balancing Perspectives to Maintain the Desired Vision .......................................... 5-3
Figure 6-1 Principle Ecosystem Components.......................................................................... 6-8
Figure 6-2 Tritium production rate per day for a typical 1,000 MWe pressurized water
reactor............................................................................................................................6-13
xiii
LIST OF TABLES
Table 3-1 Definitions of Commonly Used Terminology........................................................... 3-1

Table 4-1 Exposure Comparison Table................................................................................... 4-9
Table C-1 Compatibility Checklist............................................................................................ C-1
Table D-1 Strategy Effectiveness Review ............................................................................... D-1
Table E-1 ERF Summary Table .............................................................................................. E-2
Table F-1 Example - Annual Processing Cost Analysis........................................................... F-3
Table H-1 Industry Information Sources.................................................................................. H-1
xv
1
SENIOR MANAGEMENT BRIEF
Senior Management Brief
This document outlines a methodology for accurately analyzing nuclear power plant’s liquid
effluent processing strategies. It is specifically intended to provide insight and direction that will
result in a balanced radioactive liquid effluent management program. The strategies provided are
representative of proactive management of that effluent stream such that environmental risk is
minimized. These strategies continue to ensure that reasonable actions have been taken to protect
the public health and safety.
Recent global risk management experience suggests that achieving compliance with applicable
regulations does not always offer protection from future environmental liabilities. Based on this
experience, the EPRI sponsored Liquid Effluents Task Force systematically examined:
• A spectrum of nuclear and conventional environmental programs
• Technology applications
• International perspectives
• Varying reactor types including existing U.S. and international, and proposed advanced
reactor designs
• Public consciousness of environmental issues.
The results of that evaluation revealed that the nuclear industry environmental risk due to
radioactive liquid effluent releases trends closely parallel those of other industries. The
evaluation also revealed that application of proactive contemporary risk management principles,
that are not necessarily regulatory driven, but in all cases are regulatory compliant, could
optimize plant operational requirements with environmental risk considerations (27).
In the past decade, the commercial nuclear industry has achieved dramatic reductions in activity
discharged to the environment. A common, widespread goal to be among those few plants
discharging the least amount of activity has caused radioactive effluents to spiral down rapidly.
Further, the design and proposed operation for a new generation of reactors continues to
incorporate the optimal treatment technologies and methodologies to ensure the environmental
impact related to their operation and subsequent decommissioning is minimized. This reflects a
sense of pride in the nuclear power industry and continues to demonstrate the industry’s focus on
environmental stewardship.
1-1
Liquid effluents program coordinators are challenged by the requirement to comply with
jurisdictional regulations, while simultaneously improving their performance and reducing
operating costs. Further, the technological advances in activity detection and measurement
equipment and techniques, have facilitated quantification at much lower levels. This in itself
creates another challenge to the industry from a regulatory, oversight, and liability perspective,
how low is the acceptable threshold, and when is it low enough? Many stations have responded
to these challenges by re-evaluating existing effluents strategies, evaluating alternate or advanced
technologies and methodologies in their quest to maintain a balanced effluents program.
Carefully analyzing and coordinating the effluents program will ensure that changes to one of the
program elements does not result in undesirable consequences with respect to one or more of the
competing factors.
That type of analysis process is extremely complex and requires careful review and coordination
of several key factors that include:
• Regulatory compliance,
• Environmental responsibility,
• Cost,
• Liquid effluent quality,
• Airborne effluents,
• Solid waste effluents,
• Dose to on-site personnel,
• Dose to offsite personnel,
• Local environmental sensitivities,
• Legal and financial liability, and
• Political liability.
One important aspect of this balancing effort for consideration is the roles of mixed fission
product (MFP) and activation product (AP) activity, tritium and gaseous effluents. If the focused
effort to reduce liquid effluent MFP and AP activity continues, there may be a point where
mixed fission products will no longer be the major contributors to dose and/or stand out as a
negative social factor. Several U.S. sites are currently at or near this site-specific value. This
could result in a significant public perception shift to significantly more challenging exposure
constituents such as tritium or more difficult to remove, but relatively innocuous nuclides.
In an effort to assist utilities with analyzing and developing a balanced effluents strategy, EPRI
undertook this initial project to develop a liquid effluents strategy analysis methodology for use
by both boiling and pressurized water reactors. The project targeted the regulatory,
environmental and business aspects of liquid effluents management. It included a detailed
review of utility and vendor process experience, technology, methodologies, and industry lessons
learned. This document is a product of that project and identifies a specific program evaluation
methodology.
1-2
Business
To optimize a site’s effluent program, utility management must maintain a “vision” that balances
various “perspectives” and defendable, high quality decisions. The vision of an effective liquid
radwaste effluent program should include the following perspectives: Customer (public),
Financial (profitability, insurance, and investor risk), Environmental, Innovation and Learning
(technology), and Internal Business (O&M, capital). The key considerations are depicted below
in Figure 1-1.
Figure 1-1
Balancing Perspectives to Maintain the Desired Vision
Management decides how much weight (and resources) should be applied to each element in
order to balance the station’s effluent program. The particular effluents strategy selected at each
site will be dependent on management’s vision for that program. For example, if the perspective
is purely financial, there may be little motivation to reduce liquid radwaste discharges beyond
the degree required by established regulations. However, if the internal business perspective
includes a goal of “activity reduction,” and the public perspective includes the concept of
“environmental stewardship,” the vision must include the financial liability or financial reward
of such a decision. The financial liability would include costs to reduce radwaste, and the
financial rewards may include decreased exposure to the risk of litigation. In order to balance
the station’s effluents strategy, reducing activity, and supporting environmental stewardship, the
use of new or alternate technologies may be required (innovation and learning).
1-3
When selecting the measures of performance, a station should select perhaps at most 3 or 4
“primary” indicators to track at the management level. If too many indicators are presented,
people tend to get lost in the data and lose focus. If this occurs, it may be difficult to put ideas
into actions. If there are additional indicators to track, it is sometimes desirable to make them
“secondary indicators” that are tracked at a lower level. Examples of program elements and their
indicators are captured in Appendix J of this document.
Successful Program Management
Industry experience has repeatedly confirmed that the leading liquid effluents programs achieve
success only with senior station management support of high quality decisions. The most
successful program managers are diligent in obtaining and maintaining site support of processes,
issues and goals.
Effluents programs do not normally impact capacity factor or plant reliability. Therefore,
effluents management issues may be assigned a less than ideal priority relative to the cost benefit
associated with their resolution. An effluents program and its associated processes can have a
significant impact on both O&M and decommissioning costs. As a result, program
enhancements in this area can result in significant, tangible savings to the utility. Also, major
changes to effluents strategies often impact external programs and resources. Therefore, those
changes need to be carefully assessed to ensure program costs for those organizations are
captured. This process can take several years to fully implement the effluents strategy and
identify actual program costs associated with that change. The station should consider this time
frame when assessing the cost benefit of a program revision.
Further complicating management of liquid effluents programs is the “invisible” nature of the
process. Liquid radwaste is generated and routed to treatment processes that are not normally
accessed by the balance of the plant staff. This creates an artificial barrier between the person
generating the liquid and the end result – effluent quality, producing a challenging environment
for radwaste program managers to effectively communicate the impact of liquid effluents
improvements to external organizations. Clearly defined high quality decisions and station
expectations that are effectively communicated by senior station management to the plant staff,
will help the station achieve the desired liquid effluents program goals.
Program Direction and Focus
For those programs that are successful, senior management’s level of effort is significant in that
it provides focus and direction related to the desired program endpoint. Middle and low level
managers need to be provided educated, clear, and achievable direction related to program
expectations and the resources to attain those expectations.
Finally, in order to fully understand and appreciate the effluent program management challenge,
it is strongly recommended that all managers review this document, with a focus on Section 6,
the analysis methodology.
1-4
2
PROJECT BACKGROUND AND OBJECTIVES
Background
Historically, a liquid radwaste processing strategy that included the term “zero liquid release”
has only been an option for a limited number of stations. With the advent of advanced processing
technologies and an even greater sense of environmental stewardship, many stations are
aggressively pursuing a “balanced effluents” processing strategy targeting reductions in liquid
effluent volume and/or effluent activity. Environmental, regulatory and business considerations
are implicit in a balanced effluents strategy. (See definition of “balanced effluents program” in
the next section.)
There are a variety of factors that can impact the quality and effectiveness of an effluent
management program. Developing a strategy to balance the effects of mixed fission products,
activation products, tritium, gases, on and offsite dose, liquid volumes and unprocessed liquid
waste streams can present a severe challenge to the decision making processes. Additionally,
across the industry station goals related to liquid effluent activity, on and off site exposure, and
liquid release volume continue to be lowered. Conversely, the costs associated with processing
liquid radwaste and disposing of the resultant solid waste continues to rise.
The potential benefits of developing an analysis methodology and standardizing terminology

include, but are not limited to the following:
• Improved environmental stewardship.

• Reductions to on and offsite radiation exposure.
• Standard definition of a “balanced effluent program” facilitating more accurate
benchmarking.
• An industry standard tool for assisting program managers when evaluating site-specific
strategies.
• Validation of cost-benefit prior to implementing the desired strategy.
• Capture and documentation of industry experience for future program managers – succession
planning for long term success.
2-1
Project Background and Objectives
Objectives
The primary objective of this document is to provide a tool for completing a thorough analysis of
a site’s long-term liquid processing effluents strategy. The results of that review should be used
to develop a tailored implementation plan and actions that will optimize and coordinate the
environmental, social, economic and technical aspects of the station’s liquid, airborne, and solid
effluents streams.
The specific objectives of this document are to provide:

• A tool to develop the liquid portion of a site-specific balanced effluents program.
• A compilation of considerations for use when evaluating a liquid effluents program.
Approach
A multi-discipline team of industry experts from the liquid radioactive waste (LRW) processing,
liquid and solid effluents, and chemistry disciplines were assembled to develop an outline for
evaluating a LRW effluents program. EPRI team members facilitated three working meetings to
review available technologies, local issues (to the extent practical), costs, benefits and challenges
related to a balanced liquid effluents program. The document was authored as a joint effort by
team members, the Contractor, and EPRI staff members. A non-participant peer review by an
industry professional(s) was completed prior to report finalization.
Recommended Report Use
It is highly recommended that the user(s) of this methodology have a thorough understanding of
available plant radwaste processing and effluent systems, and that they first review the entire
document to become familiar with the method, its limitations, and its supporting rationale.
During the change analysis process, the user should ensure that several key factors are satisfied
including:
• Regulations and licensing documents
• Management expectations regarding derived benefits
• Long-term environmental, political, and economic success
• Knowledge of site specific parameters and constraints
• The site’s liquid, airborne and solid effluents programs are balanced
Report Organization
Section 1 provides a senior management brief containing a document synopsis as well as the
most critical attributes and goals of a model effluent program. Section 2 contains a project
background, report objectives, and general report use considerations. Section 3 provides a
summary of definitions for terminology found in this document. Sections 4 captures information
related to current industry performance and goals. Section 5 presents a brief compilation of
2-2
Project Background and Objectives
challenges faced by the industry today and Sections 6 contains the methodology developed as
part of this project.
Appendices A through J provide supporting information, checklists and a strategy flowchart.
2-3
3
DEFINITIONS
This section of the report contains definitions for terminology used throughout this document. It
is understood by the authors that various meanings, periods of time, etc. may apply to a user’s
site specific definitions. The terms are listed in alphabetical order.
Table 3-1
Definitions of Commonly Used Terminology
Airborne Activity Activity that is a component of a plant’s ventilation stack

effluent, and is gaseous or particulate in nature.
AP Activation Products created by the bombardment of

stable substances by neutrons during plant operations.
ANI American Nuclear Insurers - A joint underwriting

association which is a pool of insurance companies that
provides financial protection to the nuclear industry.
AOA Axial Offset Anomaly - A condition related to fuel crud

deposition and thermal characteristics.
Arisings The international equivalent of “generated volumes”

pertaining to both solid and liquid wastes.
Balanced Effluents Program A term that describes the best effluents management
strategy for an individual reactor site based on the use
of this document’s methodology and high quality
decisions. It reflects a thorough analysis, optimization
and coordination of the environmental, social, economic
and technical aspects of a station’s liquid, airborne, and
solid effluents streams.
Conditioning The international equivalent of “solid waste processing”.
DF Decontamination Factor – a unit-less value that defines

the relationship between the influent and effluent
activity parameters. The weighted DF calculation
includes the liquid volume parameter. A weighted DF
calculation methodology is illustrated in Appendix I.
USEPA United States Environmental Protection Agency
3-1
Definitions
ERF Engineering Rating Factor - An ANI program that is

used to redistribute nuclear liability insurance premium
based on individual nuclear plant performance and a
select engineering plant performance indicators.
Gaseous Activity A component of an airborne or liquid waste stream. In

this document it is assumed that it does not include
particulate or tritium activity.
HPS Health Physics Society
INPO Institute of Nuclear Power Operations - INPO's mission

is to promote the highest levels of safety and reliability -
to promote excellence - in the operation of nuclear
electric generating plants.
ISOE Information System on Occupational Exposure - A data

collection and communications network for nuclear
electric utilities and national regulatory agencies.
Sponsored by OECD/NEA and IAEA
LLD Lower Limit of Detection.
MDA Minimum detectable activity. Varies by site based on

counting equipment, statistics and background radiation
levels. Often linked to “MDA Plants” meaning liquid
effluents are at or below the minimum level of detection,
but are or may be releasing activity at lower
concentrations creating a cumulative effluent activity
burden. Should not be use interchangeably with LLD.
MFA Mixed Fission and Activation – A combination of MFP

and AP
MFP Mixed Fission Products - Activity comprised of fission

fragments formed by the fission of heavy elements plus
those formed by fission fragment decay.
NATC North American Technical Center
NCRP National Council on Radiation Protection
NPDES National Pollutant Discharge Elimination System - A

permit program that controls water pollution by
regulating point sources that discharge pollutants into
waters of the United States.
ODCM Offsite Dose Calculation Manual
PCP Process Control Program
Processing The intentional modification of a liquid or solid waste to

achieve desired values for volume, activity, or chemical
parameters. Equivalent to the term treatment.
3-2
Definitions
RadBench An EPRI software program that contains liquid radwaste

related processing performance data.
TM TM
RIVRISK An EPRI Windows based modeling tool that provides
a comprehensive evaluation of a power plant’s effects
on its receiving river.
Treatment The intentional modification of a liquid or solid waste to

achieve desired values for volume, activity, or chemical
parameters. Equivalent to the term processing.
UFSAR Updated Final Safety Analysis Report – a regulatory

required document that contains site-specific safety
performance requirements.
USNRC United States Nuclear Regulatory Commission
WANO World Association of Nuclear Operators
VR – volume reduction A ratio of the initial waste volume to the final waste
volume. Typically applied to packaging and
compression or thermal reduction processes.
Zero Release A historical industry term that implies no release of

liquid volume and/or activity from a station. The term is
often incorrectly applied. Examples of incorrect
application include:
Liquid activity released in secondary, non-radwaste

applications.
Waterborne and/or airborne gaseous and tritium activity

released.
Non-treated waste streams may be released that

contain minimal activity
3-3
4
CURRENT INDUSTRY PERFORMANCE AND GOALS
Introduction
A “benchmark” is a point of reference for measurement. It also serves as a standard against

which other activities, processes or programs can be compared. Taking this a step further,
“benchmarking” is a form of comparative analysis by which any given activity, process or
program is compared to one or more similar activities, processes or programs. The intent is to
identify areas of individual excellence and areas in need of improvement. Focusing on these
improvement opportunities will typically result in higher overall performance and cost
efficiency.
In order to evaluate a liquid effluent strategy for improvement, a discussion of current industry
performance, goals and performance measures is warranted. That information is useful for
developing a baseline database that can be used for benchmarking proposed improvements and
their post-implementation results. There are many sources of data, but because each plant reports
effluent results on an annual basis, data obtained from these sources may lag current
performance by 12 to 18 months. Additionally, variations in reporting format, content, results,
units, and reactor types and operational differences will impact the data used for benchmarking.
As a result, obtaining the most current information from each power plant is challenging. Several
organizations including EPRI’s RadBench, INPO, NATC’s industry effluents database, and ANI
track and trend commercial nuclear power reactor radioactive releases using a variety of
performance measures or performance indicators.
RadBench
EPRI’s RadBench web application is currently focused on in-plant liquid processing and
effluent, as well as liquid processing and solid waste disposition programs. This web application
provides the nuclear industry with the following:
• Secure, consistent, and accurate method for benchmarking an individual nuclear plant's
radiological performance.
• Benchmarking for radioactive system liquid volumes, pH, conductivity, activity
concentration, wet solid wastes generated (resin, filters, precoat media, membranes, etc.),
liquid effluents, and program costs.
• Benchmarking for low and intermediate level waste (LILW) management programs,
including LILW generation, shipping, storage and disposal volumes for a wide range of
liquid and solid waste types, waste streams, and mixed waste.
4-1
Current Industry Performance and Goals
• Benchmarking for associated key considerations which affect LILW management

performance and program costs, including fuel cycle, reactor types (BWR, PWR, etc.),
reactor size (MWe), number of refueling or major maintenance outages in comparative data
years, containment and reactor cavity decontamination options and critical path impacts, and
disposal sites used.
• Benchmarking for individual plant comparative analyses by reactor type, reactor size, single
or multi-unit stations, and outage and non-outage years.
• Facilitates communication among key industry representatives by providing useful utility and
plant information. This includes a comprehensive database with contact names, addresses,
phone numbers, and email addresses, as well as email messaging and distribution group
capabilities. This provides an efficient mechanism for gathering industry data supporting
plant-specific analyses of individual programs for LILW.
• Data import/export from/to other Waste Logic programs.
Data is collected for the following parameters; liquid volume generated; solid waste generated
from liquid processing; Mixed-Fission Activity (MFA) products released (activity and dose), and
tritium released (activity and dose). Participation varies somewhat by year, with typically from
86 to 101 units reporting data. Data is reported by plant type (BWR or PWR). Beginning in
2000, additional liquid processing benchmarking parameters, such as pH, conductivity and
influent activity were collected on a voluntary basis.
The EPRI effort to provide the industry with a technical benchmarking tool meets the need to
perform more sophisticated comparisons of data between plants with similar operating
characteristics. This can be of strong value to plants which are currently poorly benchmarked by
generic industry indicators. The Radbench web application also reintroduces solid waste
benchmarking for the US utilities, which has been discontinued by other organizations.
The Radbench program allows EPRI utility members to run sophisticated benchmarking
scenarios from their desktop without having to install software. The web format also allows for
faster access to current data, as there is no waiting period for a CD-ROM software product to be
produced. The advanced web-based programming used by the website allows for future
expansion of the capabilities of the website, such as, import/export of data from EPRI Waste
Logic or commercial applications, automated import/ export of annual effluent data reported to
the NRC, and corporate oversight of plant performance data using a secure internet connection.
The EPRI Radbench website is expected to be fully functional by the end of 2003 and data will
be able to be viewed by EPRI members at www.epriwastelogic.com after receiving a password
from the EPRI project manager.
4-2
Figure 4-1
Sample Data Entry form for Liquid Processing Benchmarking.
Current Industry Performance
Trends in the reduction of liquid Low Level Waste volumes and activities show that the U.S.
nuclear power industry continues to be successful in improving performance and in responsibly
managing environmental effluents. Effluent activity and dose, already well below regulatory
limits, continue to be driven downward.
Regardless of the organization tracking effluent performance — and regardless of the particular
effluent performance measure tracked — there is a common conclusion: Radioactive effluents
from commercial nuclear power plants have decreased significantly over the last decade.
Carefully tracking and trending this data not only benefits currently operating stations, but also is
critical information for development of strategies and technologies for the next generation of
advanced reactors. The knowledge that effluent activities are trending downward presents a clear
challenge to reactor suppliers to identify and incorporate plant design considerations that will
result in continued performance improvement in this area.
One of the most common “performance indicators” is total activity released in a calendar year.
In order to maintain a high level of confidence in the data’s quality, all data provided to EPRI by
utilities is tracked and reviewed by a panel of technical experts. The data is also checked against
published annual effluent reports. In cases where discrepancies are found, the responsible utility
manager is asked for clarification and the change is documented. This review process was
recently enacted for data collected by EPRI, (1999-2002). It is known that some historical data
4-3
has not been thoroughly reviewed for accuracy, making it difficult to accurately trend effluent
activity trends. However, it was included as provided by utilities and typically errs on the high
side, making it probable that the true performance improvement trend was even more dramatic.
Additionally, North American Technical Center (NATC) data is now used to further validate the
EPRI data, and to complete the database for cases in which data was not provided directly to
EPRI. The data results shown below were summarized using the data provided by participating
utilities and include suspect data for earlier years.
Figure 4-2 and Figure 4-3 clearly illustrate the continuous improvement in this area for both
BWRs and PWRs for 1993 through 2001.
0.4500
0.4000
0.3500
0.3000
MFA Activity (Curies)
0.2500
0.2000
0.1500
2
R = 0.7762
0.1000
0.0500
0.0000
1993 1994 1995 1996 1997 1998 1999 2000 2001
Year
Figure 4-2
Average US BWR Liquid Effluent MFP and AP, excluding Tritium 1993-2001
4-4
0.450000
0.400000
0.350000
0.300000
MFA Activity (Curies)
0.250000
0.200000
2
R = 0.8452
0.150000
0.100000
0.050000
0.000000
1993 1994 1995 1996 1997 1998 1999 2000 2001
Year
Figure 4-3
Average US PWR Liquid Effluent MFP and AP, excluding Tritium 1993-2001
The current trend in reducing released activity is related to a number of site-specific initiatives.
While it is recognized that there are a host of improvement opportunities available to utilities,
some of the more common program enhancements include:
1. Improving the input waste stream quality through improved segregation and other techniques
(low conductivity and high conductivity or some other similar approach)
2. Improved fuel reliability
3. Improved filtration – new and in existing plant processing equipment
4. Advanced primary system chemistry controls (e.g., noble metals, zinc injection, elevated pH,
etc.)
5. Use of specialty resins that target specific nuclides
6. Upgrades to existing evaporation processes (and associated solid waste disposal options)
7. Reduction of radwaste system inputs (volume, and/or activity)
8. Abandoning much of the existing processing equipment and installing advanced processing
systems (membrane and/or chemical adjustment).
4-5
Figure 4-4 and Figure 4-5 contain liquid release volume data from PWR and BWR stations.
Figure 4-4
BWR Industry Average Liquid Volume
Figure 4-5
PWR Industry Average Liquid Release Volume
4-6
The increasing trend in released volumes from 1998 to 2000 was the result of a variety of factors.
Several stations have not been satisfied with the performance of their evaporator processes and
have retired those in place. Similarly, in BWR stations the effort required to maintain zero liquid
volume release relative to more stringent recycle water quality specifications, has proven to be
cost and resource intensive, making some release a more attractive option. At PWRs that recycle
processed RCS waste, issues such as silica and tritium concentrations in recovered liquid
requires either additional processing, or changing to a 100% release or partial feed and bleed
strategy.
Environmental
As measurement techniques and processing technologies advance, the relevance of historical

performance becomes more limited. Utilities are challenged to meet environmental (or lower)
limits of detection for radionuclides, requiring significant changes to input quality and/or
processing technologies. Additionally, technological advances in analytical equipment
measurement sensitivity has resulted in significant program challenges related to more
aggressive effluent goals and maintaining top-quartile/decile industry effluents performance.
These issues require the program shareholders to develop a strategy that carefully balances
radioisotopes of concern, liquid, airborne and solid waste effluents, and human and wildlife
exposure.
From a risk perspective, the concern is related to the public perception that increased activity
equals increased risk. However, from a scientific aspect, the real issue is exposure, not activity.
One curie of Cobalt-60 does not have the same biological effect on a person as one curie of
tritium. Because of this, using activity as a measure of performance can be misleading. A more
accurate indicator is the dose received by a given population from dispersing the radioactivity in
the liquid waste produced by nuclear power plants.
At the 49th session of UNSCEAR in Vienna, Austria in May 2000, the Committee reported on
further assessments of the cancer risks from radiation exposures based on reviews of
epidemiological studies and results from fundamental radiological research. The primary source
of information remains the Life Span Study of the survivors of the atomic bombings of
Hiroshima and Nagasaki. For a population of all ages and both genders, the lifetime risk of dying
from cancer is about 9% for men and 13% for women after an acute dose of 100,000 millirem.
For comparison, the worldwide annual per caput dose is <300 millirem from natural radiation.
The greatest contribution to the world population’s dose comes from natural background
radiation. The second largest contribution comes from medical radiation procedures. Human
activities cause further radiation exposure in addition to the natural exposure, for instance does
contamination from nuclear weapons testing and nuclear power production contribute to the
radiation exposure of the public. Occupational radiation exposure is incurred by workers in
industry, medicine and research.
4-7
The sources of radiation exposure to the United States population are depicted below in Figure
4-6.
Liquid Effluents, 0.3%

Medical X-Rays, 11%
Nuclear Medicine, 4%
Consumer Products, 3%
Internal, 11%
Radon , 54%
Terrestrial, 8%
Cosmic, 8%
Other, 1%
Figure 4-6
Sources of Radiation Exposure to the US Population
As the graph above indicates, slightly greater than 80% of the dose received by the average
individual comes from natural sources (radon, cosmic, terrestrial, and internal). Man-made
sources (medical, consumer products, and other) account for less than 20% of the exposure.
Medical procedures are responsible for the vast majority of man-made exposure. The graph
above indicated that 11% of the exposure is from internal sources. This means that the
maximum annual exposure received by an individual is about 17 mR from natural sources such
as potassium-40 in the body. (Adapted from NCRP 93) If applicable, the exposure associated
with liquid effluents from nuclear power plants would equate to less than 0.03% when compared
to the total annual exposure.
10CFR Part 50, Appendix I A. “Numerical Guides for Design Objectives and Limiting
Conditions for Operation to Meet the Criterion "As Low as is Reasonably Achievable" for
Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents” states that:
4-8
“The calculated annual total quantity of all radioactive material above background to be released
from each light-water-cooled nuclear power reactor to unrestricted areas will not result in an
estimated annual dose or dose commitment from liquid effluents for any individual in an
unrestricted area from all pathways of exposure in excess of 3 millirems to the total body or 10
millirems to any organ.”
Table 4-1
Exposure Comparison Table
Natural 10CFR50 US Typical from Fraction of

(millirem) Regulatory Liquid Regulatory
1
Total Body Effluents Limit
Exposure Limit
(millirem)
(millirem)
Annual
Exposure 288 3 ~<0.02 < 0.01
(mRem)
Note 1: This data is applicable only to persons in the ecosystem pathways. It is based on data
from several sources including UNSCEAR 2000 and the ISOE/NATC database.
This data would indicate that the true benefit of reducing radioactive effluents from nuclear
power plants has little, if any scientific value. However, as stated previously, public perception
continues to be focused on the “atom” principle, that any activity is undesirable regardless of its
fact-based risk.
Summary
As evidenced by the continued decline in commercial nuclear power related liquid effluent
activity, the industry continues to manage their programs with a deep commitment to
environmental stewardship. For all domestic power plants, this commitment is deeper than that
required by regulations.
4-9
5
INDUSTRY CHALLENGES
Similar to other industries, utilities are constantly challenged by changes to regulations,

environmental and political sensitivities, cost efficiencies, insurance premiums, litigation, and a
host of other issues. This section contains a brief summary of several of those challenges that
impact the management of liquid effluents.
Goals and Performance Indicators
The majority of stations have established specific goals related to liquid volume and radioactivity
releases on a per-period basis. The use of a goal system has provided a mechanism to
continuously challenge utilities to further reduce liquid effluent activity while remaining
economically viable. U.S. utilities utilize an industry standard that employs a performance
measure in terms of quartile rankings. In this system, the first quartile represents the first 25% of
the total number of nuclear power plants discharging the least activity.
Maintaining this level of performance has an associated economic impact. For a given liquid
radwaste treatment strategy (e.g., mechanical filters and ion-exchange), the associated processing
costs typically increase as the amount of released activity is reduced. To achieve first quartile
performance it is imperative that operating strategies be optimized to offset or minimize the
increase in processing costs. If the existing plant equipment is inherently expensive to operate it
may be necessary to replace or supplant the installed plant equipment with new processing
technologies. For this reason, many plants have discovered that existing processing equipment
may be too expensive to operate if first quartile performance is desired. Even though the new
processing technology may be quite expensive, it may be the only economically beneficial means
to meet an aggressive management goal such as first quartile performance with respect to
effluent activity.
It is clear that as performance improves at all power plants, it will become increasingly
challenging to achieve first quartile performance for effluent activity. Additionally, variations in
plant design, rating and geographical location (body of water) all impact the cost efficiency of
effluent program options. Once effluents are reduced to a very small value at all nuclear power
plants, the incentive to target a lower quartile ranking, individual plants will no longer be able to
meet the objectives of a balanced effluents program. A utility will have to decide if it is prudent
to spend a large amount of money to reduce effluents by one or two millicuries (37 or 74 million
Bq). A long-term strategy based on “maintaining first quartile performance” will necessitate
large capital expenditures for little real improvement. As a result, the industry must look to other
indicators as meaningful measures of performance. This document and EPRI’s RadBench
program captures the information necessary to normalize process results for more accurate
benchmarking. Appendix J of this document contains a performance indicator matrix to assist
5-1
Industry Challenges
with defining those indicators that will accurately portray the program’s status. A holistic
approach may prove to be a better indicator upon which a successful strategy can be based.
Using several related factors such as site and population dose, effluent activity, and program cost
as measures of performance provides alternate — perhaps better — indication of effluents
management success.
Industry Agencies
The regulatory aspects of liquid effluents management are quite clear. Each unit/site has defined
limitations on effluents typically dictated by multiple layers of governing agencies. However,
while it is clear what the effluent limits are, the pressure from a variety of international and
domestic organizations to reduce effluent activity, often through a historically tagged “zero
release” strategy, typically results in increased on-site efforts, exposure, and solid radioactive
waste volumes. Several countries continue to be severely challenged by increasingly stringent
regulations. Additionally, the term zero release continues to be misused as it implies no liquid,
no activity, and the airborne and solid waste effluent component is still present and in fact may
increase using a zero liquid release strategy. Finally, the exposure associated with on-site
processes, waste handling, offsite vendor processing and over-the-road waste shipments needs to
be factored into the equation. Trying to find the delicate balance between true exposure reduction
and best quartile or decile performance can be very challenging to a program manager.
Technology
The performance and cost success for any effluents program can be significantly impacted by
limitations related to available technology. Similarly, attempting to resolve effluents challenges
through the sole use of advanced technology may result in less than desirable results. Influent
waste stream characteristics, funding, and effluent goals are typically the decisive factors for
technology selection and success. Regardless of those factors, not all activity can be removed in
all circumstances using reasonable technological tools.
Application of advanced technologies continues to provide solutions to unique processing

problems, but has not resulted in a single technology for 100% activity removal efficiency.
Further, technologies such as those required for tritium or other difficult to remove isotopes have
not been developed for the scale required for the majority of operating units. However, it is
critical that the industry as a whole continue to support the development, testing and deployment
of advanced processing technologies. That effort will help not only the currently operating units
attain optimal performance, but will also help to ensure the next generation of advanced reactors
are designed and operated in the most environmentally efficient manner possible.
Business
To optimize a site’s effluent program, utility management must maintain a “vision” that balances
various “perspectives” and defendable, high quality decisions. The vision of an effective liquid
radwaste effluent program should include the following perspectives: Customer (public
perception and impact), Financial (profitability, insurance, and investor risk), Environmental
5-2
Industry Challenges
Impact, Innovation and Learning (technology), and Internal Business (O&M, resources, capital).
The key considerations are depicted below in Figure 5-1.
Figure 5-1
Balancing Perspectives to Maintain the Desired Vision
Management decides how much weight (and resources) should be applied to each element in
order to balance the station’s effluent program while minimizing effluent activity. The particular
effluents strategy selected at each site will be dependent on management’s vision for that
program. For example, if the perspective is purely financial, there may be little motivation to
reduce liquid radwaste discharges beyond the degree required by established regulations.
However, if the internal business perspective includes a goal of “activity reduction,” and the
public perspective includes the concept of “environmental stewardship,” the vision must include
the financial liability or financial reward of such a decision. The financial liability would include
costs to reduce radwaste, and the financial rewards may include decreased exposure to the risk of
litigation, or credit for pollution abatement from regulatory agencies. In order to balance the
station’s effluents strategy, reducing activity, and supporting environmental stewardship, the use
of new or alternate technologies may be required (innovation and learning).
When selecting the measures of performance, a station should select perhaps at most 3 or 4
“primary” indicators to track at the management level. If too many indicators are presented,
people tend to get lost in the data and lose focus. If this occurs, it may be difficult to put ideas
into actions. If there are additional indicators to track, it is sometimes desirable to make them
5-3
Industry Challenges
“secondary indicators” that are tracked at a lower level. Examples of program elements and their
indicators are captured in Appendix J of this document.
The Future
The industry’s current downward trend for liquid effluent activity creates a future challenge in
itself. If liquid activity continues to be reduced, what is the next issue of concern? Gaseous and
tritium effluents are extremely challenging to minimize and they may become the major
contributor to doses. If this occurs, effluent processing strategies may again have to be
optimized to effect further reductions in a cost-effective manner. Similarly, in many instances the
reduction in liquid effluent activity comes with a price related to increased solid waste activity
and volume generation. This results in additional over-the-road waste shipments and offsite
volume reduction and disposal operations and their associated exposure. Additionally, the next
generation of reactors should be operated with a balanced effluents program by design, reducing
liquid effluent activity to minimal amounts, while simultaneously minimizing the gaseous and
tritium release components. EPRI’s Advanced Light Water Reactor (ALWR) project is
attempting to address these issues as part of a planned program update and feedback to reactor
suppliers, by focusing on:
• plant and processing equipment design
• system and component integrity
• fuel integrity
• single point release
• elevated (2.5 times highest structure) for tritium release
• receiving body (site location)
• chemistry controls
These concepts, while applicable to the next generation of reactors, are also critical to the
success of existing effluents programs.
5-4
6
METHODOLOGY BACKGROUND & RATIONALE &
ASSUMPTIONS
The following analysis methodology is for use when defining a site specific liquid effluent
strategy. It is divided into three phases, Current Performance Review, Strategy Definition and
Evaluation, and Post Implementation Validation. It includes site-specific, economic,
environmental, technological, and global considerations. When using this process, it is important
to carefully capture all aspects of the evaluation as a basis document that can be retrieved for
periodic internal or independent review and update.
Phase I – Current Radwaste Strategy
1) Draft a program review statement - why is this evaluation being performed?

• Are plant conditions known to be changing?
Is the station planning on changing equipment or strategies for LRW

processing/conditioning? Are changes being made to plant chemistry controls that may
impact effluents? Has an operating perturbation occurred that changes the volume, chemistry
or activity characteristics of the LRW influent waste stream?
• Is the station eliminating batch liquid releases from their LRW processes/conditioning
strategy?
With currently available technology, this will result in a quantifiable activity transfer from
the liquid effluent stream to in-plant liquid systems, and airborne and solid waste streams.
• Is the activity in liquid effluents to be reduced?
Is there a specific liquid effluent characteristic that is challenging goals? Can it be removed
using available processes such as MFP/AP?
• Increasing tritium concentration in plant inventory?
Have the impacts on other processes, effluents and solid waste been considered for issues
such as tritium?
6-1
Methodology Background & Rationale & Assumptions
• Are radwaste processing and disposal no longer cost efficient?
Have all options related to improving the quality of and reducing the volume of liquid inputs
been evaluated, implemented and the cost-benefit defined? Are the existing processes
optimized? Has an EPRI Waste LogicTM: LWM analysis been performed?
• Have nuclear liability insurance premiums increased?
Define the specific ANI Engineering Rating Factor (ERF) that will be impacted that will
result in the liability or premium reduction.
• Is the station attempting to reduce offsite exposure?
How will the dose (individual, population) be reduced? Total activity, specific isotope,
tritium, pathway change?
• Is the station attempting to reduce on-site exposure?
How will the dose be reduced? Improved processes, increased effluent activity (less retained
on media), soluble versus insoluble species management?
• Are effluent goals shifting from “activity” to a “dose” basis (individual or population)?
Why is this change being implemented? Define impacted parties, education process, public
perception, and reporting changes. Can the existing process equipment facilitate this strategy
revision? Tritium impact on exposure – gaseous versus liquid.
• Are improvements required with respect to regulations or permit compliance
Define the specific nuclides and parameters that will be impacted by this change.
• Does public perception need to be improved?
Resulting from litigation, media attention, public record accessibility and review? Consider
education, cost and “the next public perception issue”.
• Is INPO/WANO best quartile performance a primary consideration?
Is benchmarking accurate? Are tritium values available and accurate? Business and
regulatory performance weighed against benefit of change?
• Is the station revising its decommissioning strategy?
Define specific improvement area, outfall dredging, contaminated soil, aquifers, site
structures, drinking water supplies?
• Have solid waste disposal options changed?
Is issue related to media in use, disposal site access, vendor processing?

• Other
6-2
2) Assemble a multi-discipline site team
Assemble a team of site experts to perform the program strategy review and analysis. Liquid
effluents are managed by one organization or individual, but are impacted by, or will impact
numerous station organizations. Including all affected groups or organizations in the process
promotes ownership, accuracy and helps to minimize the overall impact of the proposed change.
At a minimum, consider participation or consultation from the following organizations:
• Effluents – program owners
• Chemistry – impact of chemistry controls; sampling and analysis
• Radwaste Processing - liquid processing, solid waste generation
• Radiological Protection/ALARA – RP controls; dose assessment
• Operations – plant operation impact; lineups; release permitting
• Engineering –system engineers; design changes; modifications; 50.59 evaluations
• Licensing – permitting; regulatory; INPO/ANI interface
• Work Control - work scheduling; outage planning; site resource priorities; strategies
incorporated into site planning
• Fuels - fuel integrity; cladding material; ultrasonic fuel cleaning for AOA PWRs or for dose
reduction at PWRs or BWRs
• Public Relations/Information Services – public impact; education; benchmark industry for
public impact from similar process changes
• Corporate effluents and/or LRW program manager (processing lead) – global overview;
industry benchmark; corporate strategy verification; resource support contact
• Maintenance: manpower required to change filters or for related maintenance activities.
3) Assemble or locate the required documentation
The documentation requirements will vary by site, however the following generic list is provided
for consideration:
• UFSAR
• Technical Specifications
• 10CFR50.59 evaluations
• NPDES permit
• ODCM
• PCP (impact on waste packaging due to media change)
• 10CFR61 Analysis
• Regulatory guide 1.21 report requirements
6-3
• NRC inspection reports

• INPO assessment reports
• Basis documents, white papers
• Budgetary information
• EPRI Liquid Waste Processing Assessment reports
• EPRI LWM analysis results
• Current station goals
• System drawings
• Vendor process schematics and procedures
• Processing procedures
• Site release permit procedures
• Vendor proposals
• Active corrective action or deficiency reports
• Improvement tracking lists
• Historical effluents performance documents
• Applicable documents in Appendix G of this document
• Other?
4) Define current plant-specific processing/treatment practices and installed

options
Define the station’s current processing/treatment strategy. Using the system

drawings/schematics, identify the station’s processing configuration for normal, off-standard,
reprocessed, recycled and released liquid volumes. Include all available, operable components,
even if they are not currently used. They may be considered for inclusion in the effluents
processing strategy revision.
5) Define current effluent goals
Define the specific values for the goals listed below. These goals may be fixed performance
based values and are critical to assessing changes and their impact on the effluents program
• Offsite dose
– Tritium
– MFP/AP
– Gaseous
6-4
• On-site dose
– Tritium
– MFP/AP
– Gaseous
• Liquid Activity
– Tritium
– MFP/AP
– Gaseous
• Airborne Activity
– Tritium
– MFP/AP
– Gaseous
• Solid Activity
– Tritium
– MFP/AP
– Gaseous
• Dose
– Tritium
– MFP/AP
– Gaseous
• Processing related occupational dose
• LRW volume released
• Outage LRW waste generation
• Depleted processing media volume
• Processing costs
• Best quartile, best decile, best in industry
• Other
6) Identify current & historical plant-specific performance values for effluents

processing/treatment
• Liquid volume
– generated
6-5
– processed
– reprocessed
– released
– Liquid Activity
Tritium
MFP/AP
Gaseous
– Airborne Activity
Tritium
MFP/AP
Gaseous
– Solid Activity
Tritium
MFP/AP
Gaseous
7) Benchmark current industry effluents performance
Variations in reporting format, content, results, units, and reactor types and operational
differences will impact the data used for benchmarking. Benchmarking requires a careful review
of both the data in question and the specifics of the plants to which that data applies. The
benchmarking should include a thorough review of the current techniques used at the plants with
the lowest activity releases, including their costs and technical challenges. It is important to
remember that low liquid release volume does not equal low activity release values and it is also
important to remember that high release volume does not necessarily equal high activity release
values. Additionally, site-specific costs can vary radically due to locale, processes in service,
vendor contracts, disposal options, equipment performance, plant physical arrangement, and
period of time.
Similar (sister) units should be benchmarked where practical. Consider:

• Processing systems in use
• Does the station release, partial release or 100% recycle
• Days of operation (cycle length)
• MWe output
• MWth output – used by ANI
• Outage duration and scope
• Population density
6-6
• Outfall dilution source

• Fuel condition
Sources of benchmark data include:

• EPRI RadBench
• INPO
• NRC 1.21 reports
• NATC/ISOE
• International sources
• HPS
• ANI
8) Define plant-specific sources of batch processing liquid effluents
Consider all applicable site-specific sources of liquid as they will have a bearing on the ability to
meet the goals of this evaluation. Examples include:
• RCS waste
• Floor drains
• Mop water
• Laundry waste
• SFP
• Air compressor and HVAC condensation – potential tritium sink
• System draining, etc.
Include any potentially radioactive wastes that are transferred (processed or unprocessed) to a
collection tank for monitored batch release.
9) Define plant-specific sources of other release liquid effluents

• Continuous
• Unmonitored
10) Model liquid effluent dispersion

• Existing plant or vendor software or using the EPRI RIVRISK tool (applicable to river based
outfall only)
• Environmental impact evaluation tool
6-7
• Dispersion, concentration
Figure 6-1 captures the components of a “typical” ecosystem that should be considered during
this process. (35)
Figure 6-1
Principle Ecosystem Components
11) Define plant system chemical applications
This includes any system or component to which chemicals are applied that may impact LRW
processing and effluent water quality. It includes primary chemistry controls, secondary
chemistry controls, corrosion inhibitors, pH adjustments to LRW, etc.
6-8
12) Review pending changes to plant system chemical applications

• Identify pending revisions to plant system chemical application strategies
This may include changes such as primary chemistry controls, corrosion inhibitors, or
operating at an elevated pH.
• Review the identified changes for their impact on effluent activity, tritium production and
controls, and process technologies.
– Moderator - boron (PWR)
– Hydrogen water chemistry, noble metals, zinc, lithium, etc.
– Secondary systems (PWR)
– Closed cooling system corrosion inhibitors
– Fuel leakage
– PWR Primary to Secondary Leak
– Chemical decontamination
– Others
13) Identify pending changes to plant operating strategies and integrate their
impact into this evaluation
Consider items such as high duty fuel, load following, power uprate, shorter refueling outages,
major component replacements, etc. Many changes to operation strategies will result in the
increased generation of liquid, solid, and airborne activity (MFP/AP, tritium and gaseous).
14) Identify and review the status of the source-term reduction initiatives
Consider such items as system or component chemical decontamination, material changes for
primary components, fuel integrity, fuel cleaning, improved primary filtration, and cleanup
system media improvements.
15) Review EPRI Radioactive Liquid Processing Guidelines and Radwaste Desk
Reference documents (Appendix G, References 15 & 25)
These documents are available from EPRI and were developed as tools to manage and measure
the success of a liquid processing program. They contain a compilation of the most effective
liquid processing techniques and methodologies based on lessons learned from actual industry
experience. In this application the documents should be reviewed to define opportunities for
improvement that would result in the desired performance. Following this review, revisit the
target goal(s) associated with this strategy analysis, and determine if either document’s guidance
can be used to implement the program changes to meet the desired goal(s). If not, then continue
with this process for evaluating a change to the station’s effluents strategy.
6-9
16) Perform a baseline economic analysis (Refer to Appendix F)
Typically, the cost of liquid radwaste treatment is directly related to the extent of purification
desired. As the degree of radwaste treatment and the amount of activity removed from the waste
stream increases, the processing costs increase. Using currently available technology, the cost to
remove all radioactive material (including tritium) in liquid effluents prior to release to the
environment is prohibitive.
This analysis should be performed to determine the station’s current cost for liquid effluent
TM
management. The EPRI Waste Logic : Liquid Waste Manager (LWM) tool has been used to
assist over 27 sites-to-date with evaluating the cost associated with managing liquid and solid
wet waste processing. The program models plant specific cradle-to-grave liquid and solid wet
waste process methodologies considering the following cost factors:
• Processing equipment cost/lease. For leased systems/components, use vendor proposal data.
• New waste characteristics, VR options, new and/or revised packaging and/or disposal cost
factors.
• Benchmark other station’s cost factors using similar strategies and technologies.
• Modification engineering and installation.
• Site labor impact
– Processing/conditioning
– Packaging
– Transport
– Chemistry analyses
– Other
• O&M costs
– Procedure revision
– Training
– Public relations information dissemination
It analyzes this information and provides the site with a detailed economic analysis of the cost
and performance of their waste processing activities. The analysis is based on a standardized
methodology for calculating and comparing costs and system performance. The program was not
specifically designed to facilitate liquid effluents cost and performance analyses. Additional
external calculations should be performed to supplement the LWM analysis. Factors to be
considered in this additional analysis include:
• Replaced equipment disposition
• Cost per person-Rem associated with dose reductions or increase
• Cost escalation factors (NUREG-1307, RG 1.110)
6-10
• Insurance premium reduction
The results of a comprehensive analysis will provide a clear depiction of current processing costs
which can be used to evaluate the cost efficiency of a proposed effluents strategy revision, both
prior to and following change implementation. The data can be used to evaluate the relative
impact changes to a program have on other aspects of the program. Simple examples include
comparing an increase in waste media generation to a reduction in released liquid volume, or
possibly a cost per curie released versus a curie recycled.
In order to facilitate comprehensive, accurate effluents program analysis, the LWM program will
require modification.
17) Define target performance and cost goal(s) of strategy review
Develop specific numerical goals that the review will help the station attain. The goal may be
performance based (activity, dose, volume), cost reduction, reduced labor requirements, etc. This
goal(s) should be a “living” target that will be modified as the analysis process progresses.
18) Review alternate or advanced processing options relative to goals and

restrictions
This section provides a brief overview of currently available processing options. The
considerations in this section are both important and complex. It is strongly suggested that this
portion of the evaluation include additional industry input from vendors, experts and benchmark
data prior to selecting processing alternatives. Ensure that the information is current and is not
biased by supplier interpretation of specific process results. More detailed technology
information is outlined in Appendix B of this document.
19) Validate existing, or define a proposed strategy
Using the collated information, either validate the effectiveness of the existing strategy, or define
a proposed alternative strategy.
Phase II – Change to a Radwaste Strategy
20) Evaluate a proposed strategy’s compatibility and its impact
a) An analysis of the desired strategy should be performed to ensure alternate or advanced

process/conditioning is compatible with existing structures, systems and administrative issues.
Items to consider when choosing a particular option include:
• Waste stream characteristics – MFP/AP, gaseous and tritium constituents
• Process rate
• Solid waste generation
6-11
• Generated liquid volume/arisings

• Will the process remove the target isotopes or chemical species
• Impact of plant system chemical applications on alternate or advanced process
• Actual versus projected performance of the processing system at similar plants. Items for
consideration when benchmarking include:
– Validate plant physical and structural compatibility
– Effluent dilution source, volume, and flow
• Compliance with effluent standards, permits, and regulatory limitations
• Liquid recycle impact on recycle waste stream chemical impurity concentrations (e.g., silica,
chlorides)
• Liquid recycle potential transfer of liquid borne effluent activity to airborne or solid waste
forms.
• Liquid recycle may increase exposure to plant staff due to increased activity concentrations
of tritium retained in recycled liquid, spent fuel pool/reactor cavity and
processing/conditioning media
• Is the technology within the established budget
• Equipment requirements
• The overall costs of replacing the processing components versus upgrading to a new system.
• 1.21 reporting requirements
• The impact of higher radiation dose factors for ion-exchange and evaporation equipment than
for membrane elements.
• Replacement and disposal costs of contaminated membrane elements, evaporator
components or contaminated filters and ion-exchange resins.
• The cost impact of influent water quality excursions for evaporation, membrane, or ion-
exchange.
• The ability to remove small radioactive particles. Small radioactive particles that are easily
removed by membrane or evaporative processes may pass through ion-exchange resin beds.
• Long-term effluents impact on decommissioning strategy.
b) An analysis of the desired strategy should also be performed specifically to evaluate the
process impact on tritium management. Items to consider include:
• Tritium production mechanisms and rate
– Ternary fission… 3rd fission fragment
– 1-2% fissions are ternary, 10% of which yield 3H
–
2
H (n,γ) 3H … heavy water reactors
– 2
H (D,p) 3H … heavy water reactors
6-12
– 6
Li (n,α) 3H
– 7
Li (n,nα) 3H
–
10
B (n,2α) 3H
– 10
B (n,α) 7Li (n,nα) 3H
– BWRs: Control Rods
– PWRs: Li, B
Figure 6-2 illustrates the typical PWR tritium production rate.
Figure 6-2
Tritium production rate per day for a typical 1,000 MWe pressurized water reactor
• Its impact on the station’s land use plans

• Waste stream characteristics –tritium constituents
• Tritium liquid versus airborne concentrations – diversion from one source term and release
point to another
– Gaseous dose MAY BE 100X to 1000X higher than liquid effluent dose
– Does the process change justify gaseous discharge over liquid release?
– Will the shift result in localized ‘fallout’ that could contaminate groundwater? This
may necessitate an increase in environmental sampling for H-3 in water samples
• Tritium cannot be removed using conventional or economically viable options
6-13
• Impact of plant system chemical applications on tritium production

• Compliance with effluent standards, permits, and regulatory limitations
• Liquid recycle impact on recycle waste stream tritium concentration
– Liquid recycle may increase exposure to plant staff due to increased activity
concentrations of tritium retained in recycled liquid, spent fuel pool/reactor cavity
and processing/conditioning media
• Tritium monitoring programs – education, equipment, resources, and reporting
• Long-term tritium management impact on decommissioning strategy
This compatibility analysis is captured as a more detailed, ready-to-use checklist in Appendix

C of this document.
21) Review the program impact on insurance premium and liability position
Discuss processing and effluents options with ANI. Evaluate impact of dual units. Evaluate
potential impact on other aspects of ERFs.
American Nuclear Insurers is a joint underwriting association which is a Pool of insurance

companies that provides financial protection to the nuclear industry. ANI has substantial
financial assets at risk. Through insurance, financial protection is provided to cover the third
party nuclear liability exposures of nuclear utilities and other businesses that support nuclear
utility operations. Claims alleging third party bodily injury or offsite property damage as a result
of the nuclear energy hazard are covered under an insurance policy referred to as the Facility
Form Policy. For the purpose of this EPRI Guideline it is important to note that liquid effluent
releases have a direct financial impact on nuclear liability insurance premiums via the ERF
program. Beginning with the 2002 NRC 121 reports the ERF for each environmental pathway is
now considered separately, increasing the importance of proper liquid effluents management.
There is also an indirect financial impact. ANI provides nuclear liability insurance of US $300
million to each US nuclear power plant. This protection covers the operators of nuclear facilities
and their suppliers for liability for damages because of bodily injury or property damage caused
by the nuclear energy hazard. Insurance losses can be of the catastrophic or non-catastrophic
type. Expenses that might be paid under the nuclear liability policy include the payment of
claims that are presented under the policy and the costs of defense of those claims. Often, these
claims defense costs are a major portion of the expense of providing insurance to the nuclear
industry, and may be reduced considerably when there is clearly-documented evidence of due
care and proper operation of the insured facility. Performance indicators that are part of the ANI
Engineering Rating Factor program can be used to demonstrate such care.
Additional detailed information related to the ANI ERF and premium program is contained in
Appendix E of this document.
6-14
22) Review the program impact on all reporting requirements
Ensure that the proposed change will accommodate the necessary data collection to meet all site
reporting requirements. Consider RG 1.21, RETS/REMP, state, local and site-specific periodicity
reporting. Additionally, consider that changes to processing programs and effluent
concentrations may require additional reporting. Some technical specifications or ODCMs may
specifically require special reporting or NRC approval for modifications to Radwaste systems.
For example, 10CFR50.36a Technical specifications on effluents from nuclear power reactors
requires that:
“(2) Each licensee shall submit a report to the Commission annually that specifies the quantity
of each of the principal radionuclides released to unrestricted areas in liquid and in gaseous
effluents during the previous 12 months, including any other information as may be required by
the Commission to estimate maximum potential annual radiation doses to the public resulting
from effluent releases. The report must be submitted as specified in §50.4, and the time between
submission of the reports must be no longer than 12 months. If quantities of radioactive materials
released during the reporting period are significantly above design objectives, the report must
cover this specifically. On the basis of these reports and any additional information the
Commission may obtain from the licensee or others, the Commission may require the licensee to
take action as the Commission deems appropriate.”
23) Perform a second economic analysis that includes the proposed strategy
Review the applicable budget to determine the total funding available for a strategy revision.
Define the site’s amortization period for new equipment costs, and then perform an EPRI LWM
analysis considering the following cost factors:
• Processing equipment cost/lease. For leased systems/components, use vendor proposal data.
• New waste characteristics, VR options, new and/or revised packaging and/or disposal cost
factors.
• Benchmark other station’s cost factors using similar strategies and technologies.
• Modification engineering and installation.
• Tritium Monitoring
– Education
– Equipment
– Sampling and analysis
– Reporting
– Bioassay program due to activity shift
– Packaging
6-15
– Transport
– Other
• Procedure revision
• Training
• Public relations information dissemination
• Insurance premium reduction
24) Develop a comparison matrix; current values versus projections for

proposed strategy
Capture elements of both the current and proposed change and evaluate the impact of the
proposed change. Ensure the impact related to tritium is included in that evaluation. This matrix
can be a valuable tool for updating station management and other plant staff as necessary.
Section 7 of this document contains a comparison matrix that includes entry points for values for
the current program, the proposed change projections, and the post-implementation validation.
25) Review initial program review statement relative to that matrix – modify
statement, goals or proposed strategy as necessary
Review the statement drafted at the beginning of this analysis and make changes to the statement
to reflect desired results.
26) Presentation to Senior management
Review the proposed strategy with station management using the comparison matrix in Step 23.
Following their concurrence, obtain regulatory input as required. Additionally, having the
program review evaluated by ANI will preclude unanticipated premium or liability issues.
27) Document and archive the final decision and its basis
This step is critical to ensure that documentation exists for review by station personnel and
industry agencies. Additionally, careful documentation of the change and its basis will benefit
the stations succession planning strategy.
6-16
Phase III – Post Implementation Validation
28) Perform a post-implementation economic analysis (Refer to Appendix F)
Perform an analysis to capture the actual, post-implementation costs associated with the selected
effluents strategy. Actual invoice data is the preferred source of cost data for this analysis.
Consider the use of the EPRI LWM analysis tool. Ensure the analysis captures the costs
associated with:
• New equipment procurement costs or lease.
• Revised solid waste stream packages, transport, VR, and disposal costs.
• Modification engineering and installation costs.
– Equipment
– Reporting
– Bioassay program due to activity shifts
– The strategy review and change process
– Packaging
– Transport
– Other
• Procedure revision
• Training
• Insurance premium impact
29) Document post-implementation performance
Document the program’s actual performance. Consider implementing the use of a liquid
processing and effluents diary. This archive would be used to maintain a historical summary of
liquid processing technologies and methodologies and their effectiveness. It could prove useful
for future strategy reviews, regulatory validation, and future site remediation efforts.
6-17
30) Validation of decision and results following implementation
Compare the program’s historical, projected and actual environmental impact, compliance,
performance, and costs. This step is critical to ensure that the results attained following
implementation are in line with the review statement and the goals that were developed as part of
this process. Section 7 of this document contains a matrix to assist with this critical last step in
the strategy revision process.
6-18
A
STRATEGY REVIEW FLOWCHART
This appendix contains a flow chart that reflects a graphical representation of the analysis
methodology contained in Section 6 of this report. It merely offers an optimization pathway and
demonstrates how to apply the tool documented in Section 6.
Each power plant tailors their radwaste effluent program to individual site and locale needs,
therefore, all liquid radwaste programs may not identically match the flow chart configuration.
Indeed, it is not intended that all plants strategy assessment will correspond with the chart.
Some plants may choose to modify the evaluation sequence, however, if the tool presented in
Section 6 is judiciously applied, liquid radwaste effluents performance can be optimized.
The flow chart is presented in two phases. Phase 1 is intended to describe the current radwaste
strategy at a particular site. Phase 2 contains information related to changing a radwaste
strategy. This arbitrary division was selected merely as a convenience in presentation.
Within each of these two parts, major actions are listed in large, yellow boxes. Supporting tasks
are listed in smaller boxes along the left side of the page. There are boxes that represent each of
the 30 tools contained in Section 6. Numbers have been placed beside the boxes as a cross-
reference to the 30 tools contained in section 6. Some numbers (actions) may appear more than
once in the flow chart. For example, number 7 (“Benchmark Radwaste Programs”) appears
twice in the flow chart even though Section 6 covers “benchmarking” in a single paragraph.
Benchmarking at a site may occur at different times for different needs. As a result,
“benchmarking” appears twice on the flow chart. Also notice that the 30 tools listed in Section 6
do not appear in sequence on the flow chart.
A-1
Strategy Review Flowchart
Process to Optimize Liquid Radwaste Treatment
Phase 1: Current
Radwaste
Strategy
Sampling and monitoring

Operate and sample radwaste systems and inputs program
Identify batch effluents, 8,

continuous effluents, others 9
Evaluations of Ci, liquid

Identify current source term volume, water quality, etc
Plant system chemicals

impact LRW processing 11
4
Source term reduction
Outline current processing practices and installed initiatives
14
options
Yes
10
EPRI RIVRISK code
Model current liquid radwaste dispersion (freshwater sites)
6
Economic analysis including:
16,
money, Ci, mR to workers,
Measure current performance mR to public, liquid volume,
28
solid radwaste volume, etc
Site historical performance

(Reg. Guide 1.21 Report, 6
1 30 etc)
Is Validate that performance

19,
performance meets program goals and
29
OK? document
Benchmark industry
performance (e.g., EPRI
RadBench, INPO/WANO, 7
No NATC/ISOE, site visits, etc)
Current effluent goals

Go to Phase 2: 5
"Change a Input from Sr. Management

Radwaste and/or Radwaste Manager
Strategy"
A-2
From Phase 1:
"Current Phase 2:
Radwaste ”Change a Radwaste Radwaste program manager,
Sr. Management
Strategy" Strategy”
:
Define new, balanced goals
1 based on site-specific
desires ($, Ci, mR, liquid
17
Draft a program review statement volume, solid radwaste vol.,
etc...)
2
Chemistry, Operations,
Assemble multidiscipline team Maintenance, Rad Con,
Engineering, etc
3
Review (1) EPRI LRW
Guideline, (2) EPRI Desk
Assemble documentation and references Reference, and (3) other 15
documents
7
Review advanced processing
18
options
Benchmark other radwaste programs
Future plant operating 12,
strategies and plant chemical 13
19 applications
Propose a new strategy Insurance/Risk liability 21
20 Potential regulatory impact 22
Evaluate proposed strategy

Economic analysis 23
24
Current radwaste strategy
No Develop comparison matrix
Proposed radwaste strategy
25 New surveillances
Will new
strategy satisfy New liquid radwaste New radwaste operating
program change Yes
statement & new strategy practices
goals?
Presentation to Management 26
27
Document all decisions and bases
Go to Phase 3:
“Post
Implementation
Validation”
A-3
From Phase 2:
”Change a Phase 3:
Radwaste Post Implementation Validation
Strategy”
28
Perform a post-implementation cost analysis Actual costs, invoices, etc.
29
Document post-implementation performance
30
Compare actual results
to goals and
Validate of decision and results projections to verify
long-term success will
be attained
End of
Process
26
A-4
B
TECHNOLOGY OVERVIEW
This appendix contains a brief overview of current technologies and related process and effluent
considerations.
Filtration
Filters by definition are intended to remove insoluble particles from a liquid waste stream as a
stand alone effort, or to provide protection to follow-on demineralizers or other advanced process
technologies. Short, inconsistent filter runs can make the overall processing system inefficient
due to reduced effluent quality, reduced processing rates, depleted filter media and associated
labor and disposal costs.
Selection and Loading Logic
Developing a set of selection criteria for a single use disposable filter requires knowledge of both
process application and available alternatives. When selecting a filter, the user should thoroughly
research the intended function of the filter and the “typical” characteristics of the liquid waste to
be processed. Several additional considerations are specific to filtration processing.
Micron rating versus application
A sub-micron filter used in a process and release scenario can, dependent on the waste stream,
provide little additional benefit at a substantially increased cost. Similarly, a small micron filter
as the lead component in a demineralizer train or with an evaporator used for processing low
quality floor drain wastes would foul frequently with minimal resultant benefit.
Anticipated waste stream characteristic fluctuations
Off-standard inputs to the system can seriously challenge the performance of the filter. A large
influx of decontamination, housekeeping liquid waste, or auxiliary cooling water (river, lake,
ocean) could rapidly blind a bag or cartridge filter.
Cost versus application
The costs associated with filtration are directly related to specifications provided by the site and
the filter manufacturer. The cost can vary dramatically with minor changes in filtration
specifications.
B-1
Technology Overview
Material versus VR and disposal options (i.e., incinerability)
The VR and disposal options and costs are largely based on filter material and activity. Several
of the VR options available for filters include chopping, shredding, supercompaction and
incineration of filters constructed of certified incinerable material. Depending on the nature of
the solids collected, biogassing may occur in waste containers.
Flux & square feet of media
The rate at which a filter will be fouled is directly influenced by the filter flux (process flow rate
per area of filter media-gpm/ft2), and the waste stream characteristics. This knowledge is critical
when developing a filter selection specification to ensure filter performance is optimized.
For additional information on this topic review Section 6 of the EPRI Radioactive Liquid
Processing Guidelines as referenced in Appendix G of this document.
Carbon Media
Activated carbon media is effective for organics and solids removal, providing protection for
follow-on demineralizers and advanced filtration technology. The use of polymers has enhanced
the applicability of carbon for cobalt and other specific isotope’s removal. However, because
this is typically a lead bed in any processing configuration, it has the potential to rapidly become
fouled or depleted, generating a solid radwaste. Several vessel designs incorporate a high energy
backwash or top sluice feature. This technique results in a slurry requiring phase separation and
decant, potentially introducing a volume of concentrated chemical and solid impurities into the
radwaste processing system.
Selection and Loading Logic
Activated granular carbon is graded by mesh size. Selection of the appropriate mesh size is
highly dependent on the characteristics of the influent waste stream and downstream processes.
The material can be effectively used as depth filtration by layering the bed with various mesh
sizes, such as a coarse-fine-coarse configuration. The media selection analysis should also take
into consideration handling, packaging and disposition of the resultant solid waste. Equally
important in the selection analysis is consideration of vessel design, location and shielding to
support normal operations and maintenance.
Operation
When used in a lead filtration mode, the carbon performance will degrade with throughput,
primarily as a result of particulate loading and biogrowth. There are four options for restoring
performance:
• High energy backwash.
• Top sweep – crud removal, minimal carbon removal.
B-2
Technology Overview
• Top sluicing and reloading several cubic feet of media.

• Total bed sluice and reload.
Changeout & Disposition
Carbon vessels are typically operated to a predetermined dP endpoint, minimum flow rate,
activity or DF. At that time, the vessel is backwashed, top sluiced or a full changeout is
performed to re-establish the desired performance. Any of the four performance restoration
options will result in generating a low quality, potentially higher activity waste stream that
requires additional treatment prior to recycle or release. The waste solids are normally
transferred directly to a transportation liner for shipment to VR facilities or directly for disposal.
Ion-exchange media
Demineralizers have the primary function in LRW applications of removing ionic impurities, and
in some cases insoluble metals (corrosion products). The media removes insoluble products both
by mechanical filtration and electrostatic attraction. Bead resin can also act as a depth filter
which is accomplished by trapping particulates in “pinch points” located between the resin
beads.
Selection, Blending and Loading Logic
Ion exchange resin design performance is predicated by system inlet characteristics. As such, the
waste stream characteristics and fluctuations impact the resin’s performance. The expense
associated with more costly custom or advanced media applications, should be commensurate
with the desired effluent results.
Fundamentally, there are two types of whole bead ion exchange resins typically used for LRW
demineralizers, strong acid cation and strong base anion resins. Ion exchange resin is organic in
construction. Therefore, as oxidation of resin occurs, organic impurities can be introduced to the
system if the anion resin doesn’t remove it. For process and release, this is probably an
insignificant issue; however, if the station is evaluating 100% recycle, this issue needs to be
considered. For reactor water recycle applications, resin fines are broken down in the neutron
flux and temperature of the reactor to carbon dioxide, weak organic acids, and the acid form of
the functional groups associated with the resin type, cation or anion.
The stoichiometric mix, or ratio of anion to cation resin in a mixed bed, can directly impact the
generated volume of solid radwaste. The stoichiometric mix used should be based on the relative
concentration of anion and cation impurities to be removed from the influent waste stream.
Targeting difficult to remove isotopes such as cobalt and cesium may require the use of specialty
media. This media is typically significantly more costly and requires careful oversight to ensure
B-3
Technology Overview
it is not depleted due to a high influent concentration of non-targeted species. In most

applications the vessel should have isolation and by-pass capabilities, allowing customized
lineups to prevent undesirable media challenges.
If the liquid treated is to be discharged, ion exchange selection can be based solely upon the
removal of radionuclides. The use of segregated ion exchange beds with a different media in
each bed has been adopted by many plants processing for discharge. By separating the media
into different vessels, each media type can be used to depletion. No media must be disposed of
prematurely due to the exhaustion of other media in the same vessel.
Operation
The primary objective of demineralizer operation is to achieve the desired effluent quality with
minimal radwaste generation in a cost effective manner. The treated waste stream characteristics
and potential fluctuations can dramatically impact media performance. Low quality influent can
rapidly foul, or deplete ion exchange media. Resin that is improperly loaded, rinsed or “fluffed”
can result in fractured beads, effluent chemistry fluctuations and destruction of chromatographic
bands. These deviations all negatively impact media performance.
When evaluating an effluents strategy that involves ion exchange media, review the station’s
ability to align demineralizers in various series and parallel configurations. This option allows
an operator to establish custom line-ups, tailoring the process to accommodate influent LRW and
to achieve the desired effluent quality.
Changeout
Data such as dP limitations, media activity, chemistry/activity breakthrough, or total processing

throughput are used to develop changeout criteria. Defining changeout criteria (i.e., dP,
throughput, DF, activity, dose) requires careful analysis of the desired effluent for individual
beds and an analysis of the costs associated with spent resin packaging, transport, VR and
TM
disposal. The EPRI Waste Logic : LWM has been used specifically for this purpose in
numerous applications.
Waste Packaging & Disposal
Waste bead resin is normally packaged in liners or HICs and either volume reduced through
incineration, thermal reduction processes or directly disposed. Similar to other waste streams,
the primary factor for determining immediate disposition is the waste activity.
When evaluating revisions to media use, consideration must be given to spent resin packaging,
VR and disposition options that are impacted by:
• Plant structural and space constraints.
• Waste resin blending and concentration averaging.
• Dewatering equipment.
B-4
Technology Overview
• Disposal availability (long and short term).

• Disposal price structuring – e.g., curie surcharges
• Vendor services available for use.
Evaporation/concentration/crystallization
In order to reduce liquid effluents, much of the international nuclear power industry relies
heavily on evaporation and subsequent solid waste disposal. This reduces liquid radwaste but
shifts the burden to solid waste. This option may increase capital expenditure, solid radwaste,
personnel exposure, and operating costs.
The use of evaporators for processing LRW typically results in a high quality, low activity
effluent suitable for recycle to reactor or condensate systems. In a few PWRs, evaporators are
used for recovering boron from reactor letdown and draindown for recycle.
Evaporators have been replaced by alternate technologies at the majority of stations. Industry
experience has shown that this process frequently results in program attributes which include:
• High quality, low activity effluent.
• Relatively high maintenance costs
• High personnel exposure during maintenance and operation.
• Concentrates waste requiring final processing prior to disposal.
Use Issues
Evaporators can produce a high quality product; however they typically require a significant
amount of operator attention during operation. In process and recycle applications, there is a
significant benefit to achieving this quality relative to reactor water chemistry and its
consequences. At several stations, antimony is a major component of the total effluent activity.
The use of evaporators is an effective method for antimony removal. For process and release
applications, the benefit of efficient processing is often overshadowed by operating and
maintenance considerations.
The need for prefiltration and pre-demineralization is dependent on the influent quality. An
evaporator’s function is to effectively concentrate impurities including solids; however,
excessive impurity loading can foul heat transfer surfaces or result in carryover to the effluent
stream. This issue becomes more critical with system influent fluctuations related to system
maintenance, refueling (cavity draindown), and other outage evolutions.
B-5
Technology Overview
Frequently, the performance of LRW evaporators is affected by surfactants and organics

generated during routine and outage housekeeping and decon campaigns. These inputs can cause
foaming and/or heat transfer loss resulting in decreased effluent quality.
The energy required to operate an evaporator is also significant and those requirements are also
negatively impacted by evaporator influent quality perturbations.
Many stations have also determined that operating boron recovery evaporators is not cost
effective when compared to demineralization and release, procuring replacement boron and
makeup water. Additionally, boron has a “useful” life and is depleted over time, requiring
replacement. Boron recycle also has the potential to concentrate undesirable species such as
silica, and tritium, requiring periodic process and release or alternate processes to reduce the
concentrations to an acceptable level. However, the potential for increased boron costs
associated with the use of enriched boron as a reactivity control agent may make evaporation for
recycle a cost effective operation.
The following factors also impact process use and cost:

• Energy costs
• Evaporator performance - wt. %.
• Plant structural and space constraints.
• Available plant drying/VR equipment.
• Available vendor services for on and offsite drying/VR.
• Liquid concentrates packaging and transport.
• Disposal pricing structure.
• Disposal availability (long and short term).
• Exposure
Operation
As discussed previously, evaporation requires a significant amount of Operator attention to

maintain high quality effluent. The goal is to maximize heat transfer at the lowest temperature
and highest process rate. During outages, the demands on operators rise with increased influent
volume and the increased potential for lower quality influent following shutdown and startup
crudbursts and cavity cleanup. The quality is also adversely affected by an increased input of
surfactants and organic cleaners related to outage cleanup evolutions. Furthermore, steam and
cooling water maintenance during refueling outages can result in evaporator down time during
periods when influent volumes are often at peak capacity.
B-6
Technology Overview
Maintenance
Evaporator maintenance involves costs associated with labor, parts, warehousing fees, personnel
exposure, and waste disposal. The use of routine PM and major overhauls, has proven to be
effective at maintaining some evaporators in there optimum condition. However, as evaporators
age and manufacturers focus on alternate technologies, parts become less available or require
costly custom manufacture.
Some stations routinely clean evaporators using a chemical process which results in a chemical
waste that requires treatment and disposal.
Waste Packaging & Disposal
Evaporator concentrates are typically dewatered and dried using thermal processes or solidified
for disposal. Solidification significantly increases the volume of waste requiring disposal.
Thermal VR and packaging processes require shipment of the slurry to offsite vendors for
processing. LRW evaporator concentrates packaging and disposal options are primarily
controlled by the activity and drying/VR processes.
As discussed previously, evaporator operation requires fairly close oversight and routine
maintenance/overhauls. Activity and dose rate buildup in components over time is typical for
evaporators, particularly for those used for recycle in PWRs without influent ion exchangers or
for equipment drains in BWRs. Concentrates handling operations related to transfer, drying/VR
and packaging result in additional exposure. Evaporator chemical cleaning, while primarily
intended to improve heat transfer coefficients can result in reduced dose rates, however, the
impact time is limited.
Membrane Technology
Existing radwaste process-for-release applications have demonstrated that membrane technology

is effective at removing radioactivity from radwaste streams while allowing a substantial amount
of boron to pass. Typical goals for membrane-based radwaste processing-for-release applications
are to:
• Meet the liquid discharge limits to the local environment.
• Minimize concentrate volume to reduce the treatment requirements for that volume.
• Increase boron passage through the membrane.
• Increase system reliability.
• Reduce costs.
B-7
Technology Overview
Requirements for Effective Membrane Operations
The challenge for the nuclear industry is to apply pretreatment, design, operation, monitoring,
and maintenance principles that have already been developed and applied over the last quarter of
a century in non-nuclear membrane applications. Such principles include:
• Assessing and characterizing wastewater streams with constituents that may vary greatly in
composition and concentration.
• Implementing liquid improvement programs that reduce the volume and variability of non-
radioactive constituents that adversely impact membrane performance.
• Applying well-designed pilot studies to evaluate various pretreatment methods and
membrane designs under actual operating conditions before full-scale systems are
implemented.
• Controlling biofouling issues that are endemic in the use of membrane technology in the
batch treatment of waste streams.
• Implementing monitoring systems and procedures that empower maintenance, cleaning, and
troubleshooting efforts.
• Providing dedicated technicians and managers with the training required to understand the
theory and operation of membrane components.
• Fine tuning site-specific membrane cleaning procedures that effectively restore performance
and extend membrane element life.
Water Analysis Data
Typical water analysis includes constituents such as oil, grease, iron, bacteria, barium, and
strontium which can have a significant impact on membrane design and performance. One of the
most common causes of membrane operational problems is the insufficient reduction of
suspended solids, organics, and microbiological material by the pretreatment equipment.
Typical Components
Oil Separator
If required, an oil separator is used to remove oil and grease whose presence in membrane
system feedwater can quickly cause fouling of the elements.
Activated Carbon Filter
Carbon filters are used in some applications to remove chlorine, organic material, and particles
from the feedwater stream. Carbon filters upstream of an membrane system can result in
B-8
Technology Overview
increased biofouling of the membrane elements. The high surface area of the carbon provides an
excellent food source for bacteria creating an ideal environment for bacteria to multiply.
Prefilters
Prefilters are typically used to protect the high pressure pumps from debris that could damage
them. They can also be used as mixing chambers for chemicals such as acid and antiscalants.
Chemical Pretreatment
Chemical injection capabilities may be required to inject cleaning and pH adjustment chemicals.
Membrane Selection and Design
A site-specific plan is required to identify those chemical and radioactive species that are
acceptable in the permeate (release or recycle) stream and those that will remain in the reject
concentrate stream (waste requiring processing). Influent characteristics will assist a utility in
selecting either ultra filtration or reverse osmosis components. The allowable concentrations of
salts or particulate matter in the permeate are also used to make this determination. Additionally,
the process flow rate required by plant technical specifications, UFSAR, and influent generation
rates is incorporated into the design parameters.
One of the best ways to ensure the successful design and operation of future radwaste membrane
application is to conduct a small-scale pilot study with a well designed test plan before
implementing full scale processing. The pilot study should be based upon a representative
sampling and detailed analysis of the feedwater stream(s). Both pilot pretreatment and pilot
membrane equipment should be tested simultaneously. The pilot study should include
conservative operating conditions, and should push the conditions, such as % recovery, to the
limit to determine the point at which the membrane system will not be effective. This can be
accomplished using relatively inexpensive small diameter spiral wound membrane elements.
Typical parameters that are studied and optimized during a pilot study include:
• Determining the % rejection and % passage of ions of interest for a variety of membrane
elements that are currently available.
• Determining the effectiveness of various membrane pretreatment methods.
• Determining the rate of fouling and frequency of cleaning that can be expected in a full-scale
system.
• Identifying cleaning chemicals and procedures that can effectively restore membrane
performance to baseline conditions.
• Optimizing the % recovery that will produce satisfactory rejection and passage of specific
ions, while resulting in a satisfactory rate of fouling.
• Optimizing equipment and procedures to reduce the membrane cleaning frequency.
B-9
Technology Overview
Ion Exchangers
In order to meet effluent standards, membrane systems typically require the use of ion exchange
media. The number and size of vessels will vary by plant-specific application and effluent water
quality standards.
Data Management System Overview
Efficient data management requires the capture and analysis of large amounts of information
including:
• Periodic wastewater analysis results,
• Pretreatment equipment operating data,
• Membrane operating data, normalization, and other calculations,
• Chemistry results and decontamination factors for each piece of equipment, and
• Liquid discharge monitoring.
Dedicated Personnel
The most successful station assign dedicated operators to the system that thoroughly understand
membrane operations and have operating experience. Effective membrane operation and
maintenance procedures require vigilant oversight by knowledgeable persons and include the
following:
• Substantial amounts of operating and chemistry data collected.
• Operating data collected every two hours during processing.
• Flushing membrane elements after each run or as recommended by the manufacturer.
• Precautions to reduce biofouling by flushing the membranes per the manufacturer’s
recommendations.
Membrane Cleaning
Membrane systems must be periodically cleaned to prevent irreversible fouling. Often, a variety
of cleaning solutions and procedures must be tried before an effective one for the specific
application is found.
Biofouling Control
Aggressive cleaning of the membrane system after each run followed by storing the membrane
elements in a preservative solution may be sufficient to control microbiological fouling.
B-10
Technology Overview
Vendor Versus Site Processing
When making a process change the role of vendor processes may be an issue requiring
resolution. When evaluating options, consider the following issues.
• A lease with the option to buy.
• Require the vendor to provide on-site technical assistance for a period of time to ensure the
system performance is optimized and that the process results are acceptable.
• Will the system be operated by plant personnel? If yes consider the following:
– The vendor should be retained on-site to train a sufficient number of personnel to
effectively operate the system. The longer the vendor is on-site the better the site
operator’s understanding of system operation under varying conditions.
• Requiring the vendor to provide procedures in the plant approved format.
• Obtaining guarantees from the vendor that the plant goals will be met
– Typically available only with vendor operation of the equipment.
• Establishing realistic guarantees of generation volume and influent water quality.
Tritium Management
Industry experience to date indicates that existing technologies for the removal of tritium from
liquid waste streams require a very large capital investment which utilities cannot justify based
on the extremely low risk level from the related exposure. Two differing approaches to tritium
management are described below.
Molecular Separation Inc. Tritium Resin Separation Process
A media based process under development by Molecular Separation Inc. (MSI) generated
considerable interest within the nuclear industry when initial laboratory data showed significant
reduction in wastewater tritium concentrations. As part of an EPRI project cosponsored by
Progress Energy, a comprehensive evaluation of a number of details relating to the process was
performed to assess the viability for commercialization of the process.
The Tritium Resin Separation (TRS) Process is a proprietary method for the preferential removal
of tritium from liquids. The process has been shown to selectively adsorb tritiated water (HTO)
through the hydration of ions loaded onto a conditioned resin media. Typical adsorption
materials include commercial exchange resins such as sulfonated polystyrene/divinylbenzene
(cation) resin. Prior to use the resin is pretreated by loading the ion exchange sites with
+3
aluminum sulfate to form an Al site bonded to at least one sulfonated group in the media
structure. Aluminum in this form has a high number of waters of hydration and due to the energy
associated with the hydration the resin has a greater affinity for tritiated water (HTO) over light
water (HOH). The tritium removal is conducted at near ambient temperatures (870 F, 300 C) and
low pressure (30 psi, 2 bar absolute). Preconditioning is required to remove competing cations
B-11
Technology Overview
from the feed stream. Their presence would adversely affect the process by removing the
aluminum ions from the resin media.
Once removed from the wastewater, the captured tritium is released from the media by a
stepwise drying process. The first drying stages remove interstitial and adsorbed light water from
the media. This water is returned to the inlet stream for reprocessing. The last stage of the
process involves subjecting the media to high temperature air (3000 F, 1500 C) to completely
dehydrate the media. The liquid removed in this step is elevated in tritium and is ultimately
captured for disposal on a molecular sieve.
The EPRI sponsored testing clearly demonstrated that the tritium removal with the TRS Process
does work. However, that data strongly indicated that the commercialization of the process, as it
is presently defined, is unlikely. This conclusion was based on the exceedingly low capacity of
the media and the need for complete media drying. Both the drying requirement and the low
capacity translate into significant capital expenditures for hardware, facilities, and required
support services.
Canadian Tritium Processing
Canadian reactors operate on a heavy water cycle producing significantly higher levels of tritium
during plant operation. This has led them to be leaders in the field of tritium removal based on
their experience and technology development programs. Ontario Power Technologies has
developed a Tritium Removal Plant (TRP) that incorporates both a flexible and simple design
into a smaller, more compact system. However for a U.S. nuclear plant, this tritium removal
process would be considered to represent a large capital investment. Such investments cannot be
justified based on the extremely low dose values being experienced.
1
Ontario Power Technologies has developed a Tritium Removal Plant (TRP) that incorporates
both a flexible and simple design into a smaller, more compact system. The CANDU-6 TRP
“consists of a low inventory, leak-tight electrolysis cell or group of cells in the front-end to
convert the D2O (mixed with HDO and DTO) from the moderator system to D2, HD, or DT.”
(Sood, S.K. et al., 13). A Cryogenic Distillation (CD) system follows the electrolysis section “to
enrich the moderator tritium to between 50% and 80% DT while detritiating the bulk of the D2
gas which is then converted back to heavy water by recombining the D2 with oxygen.” (Sood,
S.K. et al, 13). This CD system is smaller than the traditional one found in the Darlington
Tritium Removal Facility (TRF) and is much simpler than the Princeton Tritium Purification
System (TPS). Consequently, this new, compact system has the potential for modularity and may
reduce costs for tritium decontamination equipment for CANDU-6 reactors.
The researchers at Ontario Power Technologies compared their existing tritium removal systems
(Darlington TRF and Princeton TPS) to the CANDU-6 TRP and found many technical
advantages to using this new system.
1
Sood, S.K., C. Fong, K.M. Kalyanam, and K.B. Woodall. “A Compact, Low Cost, Tritium Removal Plant for
CANDU-6 Reactors”.
B-12
Technology Overview
1. Detritiation is done onsite, thus costs associated with off-site processing are avoided.
2. Its simple design denotes fewer components and an easier process control implementation,
which in turn will result in lower maintenance and lower operating costs.
Tritium Management Research
Additional research and development related to novel tritium removal technologies is currently
being studied in the U.S. and in the international community. This research includes tools and
technologies to quantify and track, separate, contain and abate tritium resulting from both
commercial power operation and research generators. EPRI, with utility concurrence and
support, has committed to near term development of a tritium inventory and assessment
management tool.
B-13
C
TECHNOLOGY OR METHODOLOGY COMPATIBILITY
CHECKLIST
This compatibility or impact checklist is for use prior to choosing a particular option. The user
should review each item on this list to verify that the issue has been included in the review
process, validated as compatible, and those results documented as necessary.
Table C-1
Compatibility Checklist
• Waste stream characteristics
– Normal
– Off-standard
– Special project related wastes
• Process rate
• Solid waste generation
• Generated liquid volume/arisings
– Normal
– Outage
– Surge
• Will the process remove the target isotopes, chemical

species, or particles by size as desired
– DF
– In general, cobalt, nickel, iron, cesium, iodine and
antimony are predominant nuclides in effluent.
• Impact of plant system chemical applications on alternate or
advanced process
– Boron – concentration for reuse, disposal, or process
and release
C-1
Technology or Methodology Compatibility Checklist
• Actual versus projected performance of the processing

system at similar plants. Items for consideration when
benchmarking include:
– Volume of water processed
– Process rate
– Solid waste generation
– Normal quality of water processed (conductivity,
pH, activity, specific isotope removal for isotopes
you have problems with, particle size, etc.)
– Are plant goal for released curies met
– Vendor or plant operators used? For how long?
– Equipment problems encountered (this information
can sometimes be misleading due to proprietary
issues or “image” concerns)
• Plant physical and structural compatibility
– Processing
– Solid waste transfer, package and ship
– Shielding
• Effluent dilution source, volume, and flow
– All reactor modes

• Compliance with effluent standards, permits, and regulatory
limitations
– Tritium concentration approaching drinking water
standards.
– Potential transfer of liquid borne effluent activity to
airborne or solid waste forms. Whether the effluents
medium is liquid, solid, or air, activity will be
released.
– The political sensitivities related to airborne, solid,
and liquid waste disposition will vary by locale and
country.
– ANI – ERFs for Environmental Releases versus ERF
for solid waste shipment total curies
– Regulatory compliance
– Solid waste generation, transport and disposal
C-2
Technology or Methodology Compatibility Checklist
– Tritium in ground water

• Balanced effluents program impact on recycle waste stream
chemical impurity concentrations (e.g., silica, chlorides)
• Increased liquid recycle or reduced effluent activity program
may impact the plant staff occupational exposure
– Increased activity concentrations retained in recycled
liquid, spent fuel pool/reactor cavity, open top tanks
(particularly tritium), and processing/treatment
media
– Airborne tritium concentrations and exposure
contribution
– Tritium increase may necessitate institution of a
plant staff bioassay program
– Process media retains higher activity concentrations,
increasing handling, packaging and transport
exposure
• Is the technology within the established budget
• Equipment requirements
– Capital or O&M cost

– Procurement or vendor lease
• The overall costs of replacing individual plant processing
components versus upgrading to a new complete system.
• The impact of higher radiation dose factors for ion-

exchange and evaporation equipment than for membrane
elements.
• Replacement and disposal costs of contaminated membrane
elements, evaporator components or contaminated filters and
ion-exchange resins.
• The cost impact of influent water quality excursions for
evaporation, membrane, or ion-exchange.
• The ability to remove small radioactive particles. Small
radioactive particles that are easily removed by membrane or
evaporative processes may pass through ion-exchange resin
beds.
• Long-term effluents impact on decommissioning strategy.
C-3
D
STRATEGY REVISION EFFECTIVENESS REVIEW
This section of the documents contains a suggested approach for documenting the impact of an
effluents strategy change. It captures the most significant validation points; however, similar to
the method in which an individual effluent strategy will be site specific, this confirmation matrix
should also be tailored to the site’s needs.
Table D-1
Strategy Effectiveness Review
Program Element Current Value or Proposed Post

Result Strategy Implementation
Projected Value Value or Result
or Result (Goals)
• Released liquid activity
– Tritium
– MFP/AP
– DF
– Other
• Airborne effluent activity Captures transfer of activity burden from liquid to another
effluent stream
– Tritium
– MFP/AP
– Other
• RCS Activity
– Tritium
– MFP/AP
– Other
• SFP Activity
– Tritium
– MFP/AP
D-1
Strategy Revision Effectiveness Review
– Other
• LRW processing related
solid waste
– Generated volume
– Disposed volume
– Disposed activity
– Shipped activity
– Number of shipments
• Other solid radioactive Reactor, SFP, condensate, etc.
processing media waste
– Generated volume
– Disposed volume
– Disposed activity
– Shipped activity
– Number of shipments
• Compare activity results to
identify transfer of burden
between effluent streams
• O&M Cost
• Cost-efficiency
– Cost per gallon

– Total program cost
– Program change cost
• Site resource impact Labor for operation, chemistry, radwaste, effluents, etc.
• Insurance
– Premium
– Liability exposure
• Offsite gaseous dose
(excluding tritium)
• Offsite airborne tritium dose
D-2
Strategy Revision Effectiveness Review
• Offsite liquid dose

(excluding tritium)
• Offsite liquid tritium dose
• On-site liquid processing

dose
• On-site solid waste
processing dose
• Federal regulatory
compliance
• Local regulation and release
permit compliance
• Business plan objectives (list
most significant)
• Public perception impact
• Decommissioning strategy
impact
• Review “program review
statement” developed at
inception of project
• Other
D-3
E
ANI – ENGINEERING RATING FACTORS AND
PREMIUM
Additional detailed information related to the ANI program
Direct Impact - Beginning in 1981, ANI implemented a program for its insurance purposes to
monitor and evaluate industry and individual nuclear plant performance based on select
engineering plant performance indicators. The program is also used to redistribute a portion of
total power reactor nuclear liability insurance premium based on the results of the select
engineering performance indicators. The program is referred to as the ANI Engineering Rating
Factor (ERF).
ANI currently evaluates twelve areas of plant performance under the ERF Program. Based on
aggregate plant performance, a portion of the total nuclear plant liability premium is
redistributed. The best plant performers are eligible to receive a credit of up to 20 percent.
Those plants with the highest perceived nuclear insurance risk can be assessed a surcharge of up
to 30 percent. Performance information also plays an important part in the development of
insurance risk profiles that support loss control strategies at each nuclear power plant facility.
There are six rating factors used to calculate nuclear liability insurance premium.
• Reactor Type
• Reactor Use
• Reactor Size (Thermal Power Level)
• Plant Location
• Containment Type
• Engineering Rating Factor (ERF)
Each of these six factors is a direct multiplier in the premium computation. While plant
operations have very little effect on each of the first five rating factors (i.e., Type, Use, Size,
Location, and Containment), plant operations have a substantial impact on the sixth factor – the
ERF.
The ERF serves as the mechanism to rate power reactor insureds on a comparative risk basis.
The fundamental criteria for the ERF required that total ANI power reactor nuclear liability
premium not change as a result of implementation. There are eight broad performance areas of
perceived nuclear liability insurance. Each of the performance areas is described in E-1 below.
E-1
ANI – Engineering Rating Factors and Premium
Table E-1
ERF Summary Table
Performance Area Description
The Environmental Performance Area is comprised of five components

accounting for releases of radioactive material in the effluent streams.
Environmental Releases
Effluent releases (airborne & waterborne) represent an increasing level
of insurance exposure, which is proportional to the amount of activity
(curies) released, the population density and distribution surrounding the
• Noble Gases insured, and the local environmental uses (drinking water, aquifers,
fishing, etc.) of the surrounding properties.
• Airborne Iodine &
Particulate
• Airborne Tritium
The amount of release to the environment can be controlled by actions
• Waterborne Mixed such as proper chemistry control and by the proper design and operation
of radioactive waste processing systems.
• Waterborne Tritium
This sub factor is referred to as the Regulatory Performance Sub factor.

Regulatory Performance The sub factor reflects the ability of the utility to operate within
prescribed rules and regulations. Deviations from operational
compliance may result in a higher nuclear liability exposure. The NRC
Violations component includes only NRC violations that result in a fine
NRC Violations that is paid by the utility. The worst performance is weighted 100 times
more than the best performance
ANI Liability recommendations that are not accommodated by the

insured are candidates for inclusion into the ERF. Recommendations
ANI Liability
that fall into this category are reviewed and processed by the ANI
Recommendations
Recommendation Review Committee for insurance risk significance and
consistency.
This data is from the NRC’s Performance Indicator Program. Events

classified as “significant” include:
• Degradation of important safety equipment
• Unexpected plant response to a transient
• Degradation of fuel integrity, primary coolant pressure boundary,
Significant Events etc.
• Scrams with complications
• Unplanned releases of radioactivity
• Operation outside the limits of technical specifications.
Radioactive waste shipments represent an insurance exposure to the

general population and property while in transit. The exposure is
Radioactive Waste proportional to the volume, activity and distance shipped. Because of
reporting inconsistencies, only activity (curies) shipped is included in the
ERF.
E-2
Performance Area Description
Events or conditions that could prevent the fulfillment of the safety

Safety System Failures function of structures or systems are included. This data is from the
NRC’s Performance Indicator Program.
This sub factor monitors the number of unplanned automatic scrams that
occurred while critical, such as those that resulted from unplanned
transients, equipment failures, spurious signals or human error. Also
Unplanned Automatic
included are those that occurred during the execution of procedures in
Scrams
which there was a chance of a scram occurring, but the occurrence of a
scram was not planned. This data is from the NRC’s Performance
Indicator Program.
This sub factor monitors automatic or manual safety system actuations

of the logic or actual equipment of either certain Emergency Core
Safety System Actuations
Cooling Systems or in response to an actual low voltage on a vital bus.
This data is from the NRC’s Performance Indicator Program.
When viewed on a comparative basis, they reflect relative nuclear liability insurance risk. These
performance areas are combined using statistical methods to produce a composite ERF value that
corresponds to an adjustment of nuclear liability insurance premium based on operational
performance. The best performers are eligible to receive a credit of up to 20 percent and the
highest insurance risk performers would be assessed a surcharge of up to 30 percent. The ERF is
computed on a yearly basis.
Of significance is that nuclear liability insurance premiums may also be impacted by ANI
Liability Recommendations which may be offered by ANI Engineers. Any ANI
recommendation, including effluent/environmental recommendations, that has not been
implemented (i.e., open or pending categories) is subject to rating by the ANI Recommendation
Review Committee. Rating in this area is based on insurance risk significance. A
recommendation’s impact within the ERF can be between approximately $3,000 and $52,000
per recommendation, based on the significance of the recommendation. For a multi-unit site, the
impact can be 1.5 times that.
For 2003, the average nuclear liability premium for an operating nuclear reactor site is
approximately $725,000. The relative contribution for the aggregate environmental component
in the ERF for an average hypothetical nuclear plant site that exhibited best industry performance
in all sub factor performance areas other than environmental, could be in the range of
approximately $20,000 to $250,000.
Indirect Impact - There is also the potential of indirect impact on nuclear liability premium
due to claims activity. The costs associated with defending nuclear liability claims are factored
into overall premium on an actuarial basis.
There is a growing public consciousness of offsite contamination issues, in particular

radiological. We note also global risk management experience which suggests that achieving
compliance with applicable regulations does not always offer protection from claims alleging
bodily injury or offsite contamination caused by the nuclear energy hazard. And, there have
E-3
been several financially significant nuclear liability claims alleging damage caused by a release
of radioactive effluents from nuclear facilities. In consideration of this experience, we believe
that proactive management of radiological effluents serves to strengthen an insured’s ability to
demonstrate that reasonable actions have been taken to protect the general public and therefore,
justly defend claims.
The term used to describe this proactive concept, is risk minimization. In brief, risk
minimization utilizes proactive, contemporary, systematic risk minimization principles, that are
not necessarily regulatory driven, to address the potential or actual release of radioactive
materials which may present insurance risk to the public from plant systems, structures or
property. Risk minimization also considers the public’s perception of risk which often is much
more significant than the risk as determined by the release, measurement and computational
methodologies used today. For example; we know based on science, that a curie of cobalt-60
presents a markedly more significant biological impact than does a curie of tritium. The public,
however, does not differentiate between these isotopes with regard to the level of concern and
perception of harm caused by different radioactive constituents that are released from nuclear
facilities.
E-4
F
PROGRAM COST ANALYSIS
Background
EPRI developed the Waste LogicTM: Liquid Waste Manager (LWM) program for analyzing costs
associated with liquid processing and its resultant solid waste disposition. The program data is
used to perform analysis of currently available treatment processes, waste packaging techniques,
and associated costs. Additionally, it was designed to analyze the costs and basic performance
parameters associated with program enhancements and anomalies that have the potential to
impact processing costs. The program was most recently modified to include a more functional
vendor processing analysis format. It has been used at over 30 domestic and foreign utilities to
perform >100 program cost scenarios.
The program is capable of evaluating a comprehensive array of data related to liquid processing
and the resulting solid waste. These include:
• Capital cost for liquid system and waste processing.
• Labor for specific tasks.
• Media cost and efficiency.
• Maintenance cost.
• Solid waste processing cost.
• Transportation cost.
• Storage cost.
• Disposal fees and surcharges – includes curie surcharges, per cubic foot, etc.
• Equipment and processing changes.
The use of the program provides the utility manager with a powerful tool for assessing various
options to optimize their LRW system. Comprehensive cost analyses of various options can be
rapidly performed that will assist in developing new process strategies and selecting new
technologies.
Example Cost Analysis
This example cost analysis was performed using the EPRI LWM program and 100% release data
from an operating1100 Mwe PWR. It is not intended for an individual site’s specific use, but
does factor in the cost data previously discussed in this section. It does not include all of the cost
F-1
Program Cost Analysis
factors associated with liquid effluents management. Site specific cost factors will vary
dramatically due to isotopic mixture, physical site layout, etc. The factors that should be included
in the analysis include:
• Personnel exposure
– 10CFR50 currently reflects a value of $1,000 per person Rem that is being updated to
reflect $2,000 per person Rem. However, the majority of sites use a value of $10,000
per person Rem or greater with at least one site reporting a per-Rem value of
>$80,000.
• Site remediation during decommissioning efforts
– Site remediation costs will vary dramatically based on operating history, geographical
location, groundwater patterns, weather patterns, etc.
• Costs for specialized monitoring programs such as tritium due to increased RCS and spent
fuel pool concentrations
• Insurance premium impact
– Education
– Equipment
– Reporting
– Bioassay program due to activity shift
The analysis assumed that based on consistent influent quality and media capacity, the volume of
solid waste media generated would be scaled based on removed activity. This in fact will not
normally occur in operating applications. However, it is true that reducing the activity in liquid
waste streams WILL present an increased challenge to media performance and life expectancy,
thereby increasing operating costs and the cost for avoided activity release.
F-2
Program Cost Analysis
Table F-1
Example - Annual Processing Cost Analysis
Scenario Released Generated Cost per Total program Cost per unit
Activity media volume gallon cost ($US) of released
(Curies) (ft3) processed activity
($US/gallon) ($US/Curie)
1 – 100% 0.060 64 0.10 48,087 801,450

Release
2 – 50% 0.030 94 0.14 68,248 2,274,933

Recycle
3 – 100% 0.0 124 0.18 88,408 >88,000,000

Recycle
Table F-1 clearly illustrates that the cost associated with liquid effluent activity diversion must
be carefully analyzed. That analysis, using site specific factors and performance will create a
solid platform for informed decision making.
F-3
G
REFERENCE DOCUMENTS
Copies of EPRI reports can be obtained by utility members by contacting:
EPRI Orders and Conferences, 1355 Willow Way, Suite 278, Concord, CA 94520. Toll-free
number: 800.313.3774, press 2; voice: 925.609.9169; fax: 925.609.1310.
1. USNRC., "Preparation of Radiological Effluent Technical Specifications for Nuclear Power

Plants", USNRC Report NUREG-0133, Washington D.C. 20555, October 1978.
2. USNRC. “REGULATORY GUIDE” 1.109, "Calculation of Annual Doses to Man from

Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with
10CFR50, Appendix I, Revisions 1 and 0”, USNRC Washington D.C. 20555, October 1977.
3. USNRC., “10CFR50.36a Technical Specifications on Effluents from Nuclear Power

Reactors”; July 29, 1996.
4. USNRC., "XOQDOQ Program for the Meteorological Evaluation of Routine Effluent

Releases at Nuclear Power Stations", USNRC Report NUREG-0324, Washington D.C.
10555, September 1977. (Later updated by NUREG CR 2919).
5. USNRC. “REGULATORY GUIDE” 1.113, "Estimating Aquatic Dispersion of Effluents

from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix",
Revision 1, USNRC, Washington D.C. 10555, October 1977.
6. NUREG/CR-4007, 1984, "Lower Limit of Detection: Definition and Elaboration of a

Proposed Position for Radiological Effluent and Environmental Measurements".
7. USNRC., NUREG 1301.
8. USNRC., “IE Bulletin 79-19, Packaging Of Low-Level Radioactive Waste For Transport
And Burial”; 1979.
9. Improved Technical Specifications from NUREG 1431, Feb 2001.
10. ERDA 660 (ORNL-4992), “A Methodology for Calculating Radiation Doses from
Radioactivity Released to the Environment “.
11. International Atomic Energy Agency, “Generic Models and Parameters for Assessing the
Environmental Transfer of Radionuclides from Routine Releases: Exposures of Critical
Groups”, Safety Series No. 57, IAEA, Vienna (1978).
G-1
Reference Documents
12. EPRI. TR-016780, “EPRI Advanced Light Water Reactor Utility Requirements Document,
Volumes I, II, & III”, Revisions vary by Chapter; 1999. (Most applicable document is
Volume 3, Revision 7, V3R7.)
13. EPRI. TR- 1003434, “Radioactive Waste Processing Systems for the Next Generation of
Nuclear Reactors: Interim Progress Report”, November 2002.
14. EPRI., TR (no number assigned), “Simulation of Radionuclides in RIVRISK, Transport and
Human Health Risk Calculations”, October 2002.
15. EPRI. TR- 107976, “Radioactive Liquid Processing Guidelines”, September 1997.
16. USNRC. “NUREG-1242, Volume 3, Part 2, NRC Review of Electric Power Research
Institute’s Advanced Light Water Reactor Utility Requirements Document”.
17. USNRC. “NUREG-1307, Revision 10, Report on Waste Burial Charges: Changes in
Decommissioning Waste Disposal Costs at Low-Level Radioactive Waste Burial Facilities”.
18. USNRC. “REGULATORY GUIDE 1.110, Cost Benefit Analysis for Radwaste Systems for
Light-Water-Cooled Nuclear Power Reactors”; March 1976.
19. USNRC. “REGULATORY GUIDE 1.21, Measuring, Evaluating, and Reporting

Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous
Effluents from Light-Water-Cooled Nuclear Power Plants”; June 1974.
20. Robert S. Kaplan and David P. Norton, The Balanced Scorecard - Measures That Drive
Performance, Harvard Business Review, January-February, 1992.
21. EPRI. “Pressurized Water Reactor Plant, Radwaste Test Facility Phase II  Liquid
Radwaste Processing: Reverse Osmosis Assessment at the Surry Radwaste Facility”
22. RadBench
23. NCRP 93
24. 10CFR61
25. EPRI Radwaste Desk Reference
26. Performance Indicator Primer, http://www.raguide.org/index_of_topics.htm
27. “American Nuclear Insurers Environmental Guidelines, March 1996”
28. Merril Eisenbud and Thomas Gesell. Environmental Radioactivity. San Diego, California:
Academic Press, 1997.
29. Generic Models for use in Assessing the Impact of Discharges of Radioactive Substances to
the Environment. Vienna, Austria: International Atomic Energy Agency, 2001, Safety
Reports Series No. 19.
G-2
Reference Documents
30. D. M. Hamby, “Site-specific Parameter Values For the Nuclear Regulatory Commission's
Food Pathway Dose Model.” Health Physics, 62(2):136-1431; 1992.
31. Ronald L. Kathren, Radioactivity in the Environment: Sources, Distribution and

Surveillance, New York, New York: Harwood Academic Publishers, 1984.
32. Radiological Assessment: Predicting the Transport, Bioaccumulation, and Uptake by Mon of
Radionuclides Released to the Environment. Bethesda, Maryland: National Council on
Radiation Protection and Measurements, 1992, NCRP Report No. 76.
33. John E. Till and H. Robert Meyer, Radiological Assessment: A Textbook on Environmental
Dose Analysis – NUREG/CR-3332. Washington, DD: U.S. NRC, 1983.
34. F. Ward Whicker, “Radionuclide Transport Processes in Terrestrial Ecosystems.” Radiation

Research Vol. 97, pp 135-150 (1983).
35. Radioecology: Nuclear Energy and the Environment, Volume 1, Page 131.
Authors are F. Ward Whicker and Vincent Schultz. Published by CRC Press,
1982.
36. Basic Nuclear Engineering – Second Edition, Foster, A. R., & Wright, Jr., R. L., Allyn and
Bacon, Inc., Boston, MA, 1978.
37. EPRI. TR- 1006710, Evaluation of a Low Level Waste Technology – “A Media Based
Tritium Removal Process”, January 2002.
G-3
H
INDUSTRY INFORMATION SOURCES
Table H-1
Industry Information Sources
Name or Organization Internet Address
Asian Technical Centre (ISOE) http://www.nupec.or.jp/isoe/
ANI http://www.amnucins.com
CEPN http://ean.cepn.asso.fr/
DOE Radiation Exposure http://rems.eh.doe.gov/

Homepage
EPRI http://www.epri.com
HPS http://www.hps.org
IAEA Home http://www.iaea.or.at/
IAEA ISOE Technical Centre http://www-

rasanet.iaea.org/programme/rmps/isoe-tech.htm
INPO http://www.inpo.org
http://tis.eh.doe.gov/nsps/inpo
NATC alternate www.natcisoe.org
NATC/ISOE http://hps.ne.uiuc.edu/natcisoe
NRC http://www.nrc.gov
Nuclear Energy Agency Joint http://www.nea.fr/html/jointproj/isoe.html

Projects: The Informational System
on Occupational Exposure
Performance Indicator Primer http://www.raguide.org/index_of_topics.htm
Public Radiation Safety Research hps.ne.uiuc.edu/natcenviro

Program
RETS/REMP Organization http://www.rets-remp.org
UNSCEAR http://www.unscear.org/
H-1
I
WEIGHTED DECONTAMINATION FACTOR
CALCULATION METHOD
This appendix contains a sample Weighted DF Calculation.
Decontamination Factor – a unit-less value that defines the relationship between the influent
and effluent activity parameters. The weighted DF calculation includes the liquid volume
parameter.
Calculate Individual Set's DF based on a matched sample set by dividing the influent activity by
the effluent activity.
Multiply individual set DF by gallons processed for that data set to obtain the Derived Value.
Add all Gallons Processed for the same user defined period of time (e.g., last 24 hours, week,
etc.).
Add all derived values for the user defined period of time .
Divide Sum of Derived Values by Total Gallons to get Weighted DF.
Influent
Sample Activity Effluent Individual Set Gallons Derived Value
Set (A) Activity (B) DF Processed (C) [(A/B)*C]
1 0.06 0.006 10 10,000 100,000
2 0.03 0.0005 60 5,000 300,000
3 0.05 0.00005 1,000 7,000 7,000,000
Total Gallons
22,000
Sum of Derived
Values 7,400,000
Weighted DF 336
I-1
J
PROGRAM PERFORMANCE INDICATORS
This appendix contains examples of meaningful performance factors and their primary and
secondary indicators. No attempt is made to define target values (goals) as each station has
markedly different reactor and sub-system designs, processing equipment, physical layout
constraints, effluent dilution sources and local political agendas.
Performance Factor Primary Secondary
Effluent Activity Curies released Processing system effluent Curies
Exposure Maximum dose to an individual in the Site processing related dose

public
Regulatory No compliance issues Percent of compliance ranking = site

Compliance indicator value ÷ regulatory
requirement value
Effluents Program Processing program O&M cost, $ Site resource costs to manage
Cost per gallon processed, $ per cubic administrative and monitoring
foot of media generated program, $/Rem
Public Perception Number of adverse media reports n/a

per period of time
Liability Number of offsite legal actions Number of employee legal actions

implemented related to liquid implemented related to liquid
effluents management effluents management
Technology Implementation of advanced or Attendance at industry meetings,

alternate technologies technology evaluations
Effluents Processing Gallons released per cubic foot of Gallons released per cubic foot of
Media Management media generated media disposed
Others??? ?? ??
J-1
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Final Report, November 2003

EPRI Project Manager

(A) MAKES ANY WARRANTY OR REPRESENTATION WHATSOEVER, EXPRESS OR IMPLIED, (I)

(B) ASSUMES RESPONSIBILITY FOR ANY DAMAGES OR OTHER LIABILITY WHATSOEVER

ORGANIZATION(S) THAT PREPARED THIS DOCUMENT

Suncoast Solutions, Inc.

This report was prepared by

Suncoast Solutions, Inc.

This report describes research sponsored by EPRI.

Miguel Azar, Exelon Midwest ROG

1 SENIOR MANAGEMENT BRIEF......................................................................................... 1-1

2 PROJECT BACKGROUND AND OBJECTIVES ................................................................. 2-1

3 DEFINITIONS ...................................................................................................................... 3-1

4 CURRENT INDUSTRY PERFORMANCE AND GOALS...................................................... 4-1

5 INDUSTRY CHALLENGES ................................................................................................. 5-1

6 METHODOLOGY BACKGROUND & RATIONALE & ASSUMPTIONS .............................. 6-1

Phase III – Post Implementation Validation.........................................................................6-17

A STRATEGY REVIEW FLOWCHART ................................................................................... A-1

B TECHNOLOGY OVERVIEW................................................................................................. B-1

Prefilters .......................................................................................................................... B-9

C TECHNOLOGY OR METHODOLOGY COMPATIBILITY CHECKLIST............................... C-1

D STRATEGY REVISION EFFECTIVENESS REVIEW ........................................................... D-1

E ANI – ENGINEERING RATING FACTORS AND PREMIUM ............................................... E-1

F PROGRAM COST ANALYSIS...............................................................................................F-1

G REFERENCE DOCUMENTS................................................................................................ G-1

H INDUSTRY INFORMATION SOURCES ............................................................................... H-1

I WEIGHTED DECONTAMINATION FACTOR CALCULATION METHOD...............................I-1

J PROGRAM PERFORMANCE INDICATORS.........................................................................J-1

Table 3-1 Definitions of Commonly Used Terminology........................................................... 3-1

Senior Management Brief

Senior Management Brief

Senior Management Brief

Senior Management Brief

Successful Program Management

Program Direction and Focus

The potential benefits of developing an analysis methodology and standardizing terminology

• Improved environmental stewardship.

Project Background and Objectives

The specific objectives of this document are to provide:

Recommended Report Use

Project Background and Objectives

Appendices A through J provide supporting information, checklists and a strategy flowchart.

Airborne Activity Activity that is a component of a plant’s ventilation stack

AP Activation Products created by the bombardment of

ANI American Nuclear Insurers - A joint underwriting

AOA Axial Offset Anomaly - A condition related to fuel crud

Arisings The international equivalent of “generated volumes”

Conditioning The international equivalent of “solid waste processing”.

DF Decontamination Factor – a unit-less value that defines

USEPA United States Environmental Protection Agency

ERF Engineering Rating Factor - An ANI program that is

Gaseous Activity A component of an airborne or liquid waste stream. In

HPS Health Physics Society

INPO Institute of Nuclear Power Operations - INPO's mission

ISOE Information System on Occupational Exposure - A data

LLD Lower Limit of Detection.