1. Branch Technical Position on Concentration Averaging and Encapsulation
Maurice Heath
Low-Level Waste Branch
Division of Waste Management and Environmental Protection

2. Topics Background Revisions to 1995 BTP
Stakeholder feedback on August 20, 2011 draft
Path Forward

3. 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

4. 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

5. 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

6. 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

7. 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

8. Major Changes to 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

9. 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

10. 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”

11. 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

12. Sealed Source Activity Limit for Cs-137

13. 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

14. 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

15. 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

16. 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

17. Questions www.regulations.gov Maurice.heath@nrc.gov
Docket ID: NRC–2011–0022