Revisions to the Concentration Averaging and Encapsulation Branch Technical Position A. Christianne Ridge Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Low-Level Radioactive Waste Forum's Spring 2015 Meeting April 21, 2015

Outline Previous guidance and need for revision Input received from Agreement States with disposal facilities, compacts, facility operators, and other interested stakeholders New guidance and potential effect on waste management and disposal options Implementation plans

Background 10 CFR 61.55(a)(8) allows averaging over volume or weight of waste The Concentration Averaging and Encapsulation Branch Technical Position (CA BTP) provides guidance to address potential “hot spots” in waste containers Originally part of another technical position in 1983, extensively revised in 1995 and 2015 Revised CA BTP was issued on February 25, 2015, Federal Register Vol. 80, No. 37, 10165 The 1983 Technical Position on Waste Classification included Section C.3, “Concentration Volumes and Masses,” which provided guidance to waste generators on the interpretation of 10 CFR 61.55(a)(8), “Determination of concentrations in wastes.”

Goals for Revision Maintain protection of public health and safety Make positions more risk-informed and performance-based Reduce worker exposures from unnecessary waste characterization and surveys Improve documentation of technical bases and clarify the guidance

Major Changes Reorganized to improve readability Removed Factor of 10 constraint for mixing blendable waste Revised Factors of 1.5 and 10 for discrete items Increased Cs-137 sealed source activity limit Added Alternative Approaches section

Stakeholder Involvement Public Meetings Three workshops soliciting public input (2 on BTP, 1 on blending) Commission meeting on blending Three meetings with companies that expressed interest in blending Meeting with a sub-committee and the full committee of the Advisory Committee on Reactor Safeguards (ACRS) Meetings with Agreement State regulators, DOE counterparts, and LLW Forum Disused Source Working Group Three drafts for comment with detailed comment responses Outcomes Significant revisions of original positions Substantial documentation of bases for positions Positive feedback on consideration of comments Process considered lengthy by some stakeholders

Comments on Drafts Provide specific guidance on alternative approaches Emphasize that Agreement States with a disposal facility are not obligated to accept larger (higher activity) sources Provide guidance on interactions between Agreement State regulators of disposal sites and licensees shipping waste to those sites Treat cartridge filters as blendable waste Revise basis for thresholds for demonstrating adequate blending Provide training for Agreement States and NRC inspectors, and support public meetings in Agreement States with disposal facilities Provide specific guidance on alternative approaches Emphasize that States with a disposal facility are not obligated to accept larger (higher activity) sources (LLWF DSWF) Provide guidance on interactions among States (LLWF DSWF) Treat cartridge filters as blendable waste Revise basis for thresholds for demonstrating adequate blending Provide training for States and NRC inspectors, and support public meetings in States with disposal facilities (LLWF DSWF)

Revised Positions: Three Examples Alternative Approaches Revision to Factors of 1.5 and 10 Revised sealed source activity limits

Alternative Approaches As in the past, revised CA BTP provides broadly applicable “look up” guidance Alternative approaches encourage consideration of site- and waste-specific factors Revision provides Licensees and Agreement States with specific guidance for factors to consider when developing or evaluating alternative approaches 3.8.1 Site-Specific Intruder Assessments 3.8.2 Encapsulation of Discrete Items, Including Sealed Sources 3.8.3 Likelihood of Intrusion 3.8.4 Large Components 3.8.5 Time of Intrusion into Blendable Waste 3.8.6 Legacy Wastes

Alternative Approaches (cont’d) Examples include Site-specific intruder assessments Encapsulation of sealed sources Likelihood of intrusion Large components Time of intrusion into blendable waste Legacy wastes

Factor of 1.5 Average concentration in each package is the same and meets the Class B limit Factor of 1.5 Factor of 2 C C B B Gamma-emitting radionuclides must be within a factor of 1.5 of the average of the mixture, for each item in mixture Average 1995 position encourages uniformity, but is not directly related to risk Revised position is more risk-informed A A 1995 Guidance Revised Guidance

Revised Exposure Scenario Sealed Sources Cap Revised BTP 500 mrem from sealed source No encapsulation 4 hours in pocket 720 hours at 2 m Revised scenario for gamma-emitting sealed sources. Basis for the CA BTP Table 2 values. 1995 BTP 50 mrem from sealed source* Encapsulation intact 2360 hours Contact dose *450 mrem assumed from other sources

Implementation Revised CA BTP states that licensees may use either the 1995 or 2015 positions because both are protective; however, Agreement States can specify a more restrictive position Timeline NRC beginning training of inspectors in April First training sessions with Agreement States in May Further guidance Clarifications that arise from training will be posted to NRC’s CA BTP website Generic communications (e.g., Regulatory Issue Summary) will be published if needed

Conclusions Stakeholder involvement Revised CA BTP provides Thorough evaluation of technical positions Significant revisions of positions Better documentation of technical bases Revised CA BTP provides Generic “look-up” guidance for use if licensees choose not to develop alternative approaches Guidance on developing and evaluating alternative approaches to consider site- and waste-specific situations Revised BTP has potential to Reduce worker exposures Permit disposal of more LLW while maintaining public health and safety. Commission favors disposal of LLW over storage Main point – if the revision accomplishes this goal of reducing worker exposures and permitting disposal of more LLW while maintaining public health and safety, then I think it will have made a contribution to optimizing LLW disposal.

Resources CA BTP in ADAMS Vol. 1 ML12254B065 Vol. 2 ML12326A611 Any Questions contact Maurice Heath 301-415-3137 or Email: Maurice.Heath@nrc.gov