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Branch Technical Position on Concentration Averaging and Encapsulation

Branch Technical Position on Concentration Averaging and Encapsulation . Maurice Heath Low-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.

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Branch Technical Position on Concentration Averaging and Encapsulation

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  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 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

  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 • Docket ID: NRC–2011–0022 • Maurice.heath@nrc.gov • 301-415-3137

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