1. 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

2. 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

3. 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.”

4. 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

5. 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

6. 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

7. 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)

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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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.

15. Resources CA BTP in ADAMS Vol. 1 ML12254B065 Vol. 2 ML12326A611
Any Questions contact Maurice Heath or