Branch Technical Position on Concentration Averaging and Encapsulation

The regulatory requirements for licensing a low-level waste (LLW) disposal facility describe a system of Concentration Averaging To Classify LLW for Near-Surface Disposal and evaluate whether the facility meets its performance objectives. The Branch Technical Position (BTP) on Concentration Averaging and Encapsulation expands on those regulatory requirements by describing acceptable classification methods. For details, see the following topics on this page:

• Background
• BTP Revision Schedule
• Public Involvement
  • Public Meetings

Background

10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste," provides licensing procedures, performance objectives, and technical requirements for the issuance of licenses for the land disposal of low-level radioactive waste (LLW). Four performance objectives, including protection of an inadvertent intruder into the waste disposal site, define the overall level of safety to be achieved by disposal (*). Intruder protection is provided in part by the waste classification concentration limits in 10 CFR § 61.55, which are designed to ensure that an inadvertent intruder is not exposed to unsafe levels of radiation. All LLW must be classified in accordance with the waste classification tables in 10 CFR § 61.55. Concentrations of radionuclides that are used to determine the waste classification may be averaged over the volume or weight of the waste, in accordance with 10 CFR § 61.55(a)(8).

The staff has published guidance that defines acceptable approaches for such concentration averaging. In 1983 the NRC issued, "Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification", one of the first guidance documents supporting Part 61. The waste classification technical position paper describes overall procedures acceptable to NRC staff which may be used by licensees to determine the presence and concentrations of the radionuclides listed in 61.55, and thereby classifying waste for near-surface disposal.

In 1995 the NRC revised, in part, the 1983 "Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification." The initial 1983 guidance established a technical position on radioactive waste classification. The initial guidance included a section, "Concentration Volumes and Masses," that provided guidance to waste generators on the interpretation of 10 CFR 61.55(a)(8), as it applies to a variety of different forms and types of low-level waste. The 1995 Branch Technical Position on Concentration Averaging and Encapsulation (CA BTP), expands on, further defines, and replaces the guidance which was provided in Section C.3 of the original 1983 technical position. The 1995 Technical Position represents acceptable methods by which specific waste streams or mixtures of these waste streams may be classified.

In 2007 the NRC staff performed a strategic assessment of the NRC’s regulatory program for LLW. The staff undertook this effort in recognition of significant new and emerging LLW disposal issues. The strategic assessment identified a need to update the CA BTP. The CA BTP has the potential to increase the flexibility of disposal of certain types of LLW, particularly sealed sources and irradiated hardware. The strategic assessment stated that the staff will use risk-informed approaches and knowledge that were not available when the BTP was developed and last updated (in 1995).

In SECY-10-0043, the staff provided the Commission with an analysis of issues related to LLW blending. In the Staff Requirements Memorandum (SRM) for SECY-10-0043 (SRM-SECY-10-0043), the Commission directed the staff to revise the blending position in the CA BTP to be risk-informed and performance-based. With this decision, the staff is in a position to update the entire CA BTP, not only addressing blending, but also the remainder of the CA BTP topics that address mathematical averaging of radioactivity concentrations. Revising the CA BTP aligns with the NRC’s position of moving towards a risk-informed performance-based regulatory approach. Refer to the NRC public website on LLRW blending for more information on this topic.

(*) The others are protection of the general population from releases of radioactivity; protection of individuals during the operation of the facility (as opposed to after the facility is closed) and stability of the disposal site.

BTP Revision Schedule

This schedule reflects work plans that are subject to change. Early completion of a milestone may affect the target date of the future milestones. Subsequent meetings may change based on the revised schedule. This work plan will be revised on a periodic basis. Please see the NRC Public Meetings Page for the latest information on meetings.

*** Schedule dependent on ACRS meeting schedule, as defined by ACRS.

Public Involvement

The NRC considers public involvement to be a cornerstone of strong, fair regulation.

Public Meetings

The U.S. Nuclear Regulatory Commission (NRC) has a long-standing practice of conducting its regulatory responsibilities in an open manner, and keeping the public informed of the agency's regulatory, licensing, and oversight activities. For that reason, we opened a dialogue with stakeholders (including the public) to discuss the Branch Technical Position (BTP) on Concentration Averaging and Encapsulation.

See Public Meetings and Involvement, Hearing Opportunities and License Applications, and NUREG/BR-0215, "Public Involvement in the Regulatory Process," for general information about the available opportunities for public involvement in NRC activities. For more specific information about past public meetings on this topic, see the chronological listing in the following table:

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