Branch Technical Position on Concentration Averaging and

Encapsulation

Maurice HeathLow-Level Waste Branch

Division of Waste Management and Environmental Protection

Topics

• Background

• Revisions to 1995 BTP

• Stakeholder feedback on August 20, 2011 draft

• Path Forward

2

Background – What is the BTP?

• Guidance document for waste generators and processors

– classifying low-level waste for disposal under 10 CFR Part 61

– provides a method for averaging and classifying radionuclide concentrations in waste over a volume or mass of waste package

Background• Explains use of 10 CFR 61.55(a)(8)

– “. . . the concentration of a radionuclide may be averaged over the volume of the waste . . .”

• Used by waste generators, processors, disposal facility operators, and regulators of these facilities

• Ensures that appropriate safety measures are employed when waste is disposed

• First published in 1983• Significantly expanded in 1995

4

Regulatory Requirements Applicable to BTP

• § 61.42, “Protection of individuals from inadvertent intrusion”

• § 61.55, “Waste classification”

– Tables 1 and 2 – define Class A, B, and C waste

– Concentration based (Ci/cubic meter, e.g.)– § 61.55(a)(8) - Allows for concentration

averaging in determining waste class

• 10 CFR Part 20, Appendix G

5

Drivers for Revising the BTP

• Adoption of risk-informed, performance-based regulatory approach by NRC

• Sealed source security• Closure of Barnwell facility to out-of compact

waste in 2008– Industry proposal for LLW blending– EPRI research and presentation to NRC

June 2008• More transparent text

6

Major Changes to 1995 BTP

• Added new section on “Alternative Approaches,” to allow for site- and waste-specific approaches

• Replaced factor of 10 constraint on inputs for blended waste with more performance-based test on outputs

• Increased activity limit for Cs-137 sealed source disposal and other sources

7

Major Changes to 1995 BTP

• Tied constraints on mixtures of discrete items in a container (factors of 2 and 10) to class limit, not average of the mixture

• Rewritten to increase clarity

Alternative Approaches• New philosophy:

− BTP provides broadly applicable “look up” guidance & sets uniform level of safety

− Alternative Approaches provides Licensees / Agreement States with specific NRC guidance on factors to consider in submitting / approving alternative guidance

• 1995 BTP significantly constrained use of alternatives

• Intruder protection, with flexibility

9

Mixable and Homogeneous Waste

• Certain wastes are homogeneous waste types without a specific demonstration of homogeneity

• Homogeneous waste have no averaging constraints

• New term, “mixable waste”

10

Mixable and Homogeneous Waste

• BTP defines concentrations and volumes of mixable wastes below which no specific demonstration of homogeneity is needed

• Mixability is a physical characteristic, while homogeneity (used in the BTP), is a radiological property of the waste

Sealed Source Activity Limit for Cs-137

Class A0

0.001

0.002

0.003

0.004

0.005

0.006

0.007

0.008

Ac

tiv

ity

Lim

it (

Ci)

Class B0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

Class C0

20

40

60

80

100

120

140

1995 BTPRevised Draft BTP

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Stakeholder Outreach• Public comment period on CA BTP - January 2011• Public workshop on CA BTP - February 2011• Public workshop on CA BTP - October 2011• Advisory Committee on Reactor Safeguards (ACRS)

October 2011• ACRS December 2011• Meeting Disused Source Working Group - February

2012• Public comment period on CA BTP - June 2012• Meeting Disused Source Working Group

July 2012

State and LLW Forum Comments

• NRC staff met with LLW Forum’s Disused Sources Working Group on February 9 and July 17, 2012

• Formal comments from sited States and LLW Forum in mid-February

• Some issues– NRC participation in public meetings to explain

revisions– Greater assurance of generator/processor

classification adequacy– BTP as guidance

14

Path Forward

• Published June 11, 2012 (77 FR 34411)

• Comment period closes October 8, 2012

• Staff expects to make further revisions

• Final BTP expected in Spring 2013

15

Acknowledgements

• James Kennedy, Senior Project Manager (NRC)

• Dr. Christianne Ridge , SPM (NRC)

• Donald Lowman, Project Manager (NRC)

• John Cochran, Principal member of Technical Staff, Sandia National Laboratory

Questions

• www.regulations.gov – Docket ID: NRC–2011–0022

• Maurice.heath@nrc.gov– 301-415-3137