Implementation of the Revised
Branch Technical Position on
Concentration Averaging and Encapsulation
A. Christianne Ridge
Division of Decommissioning, Uranium Recovery, and Waste Programs
Office of Nuclear Material Safety and Safeguards
Low-Level Radioactive Waste Forum
Spring 2016 Meeting
April 14, 2016
Outline
• Training with Agreement States and NRC
Regions and participation in EPRI working group
• Public Q&A based on training and working group
participation
• Federal Register Notice (FRN) on Contaminated
Materials and Public Comments
• Next steps
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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
• Revised CA BTP was issued on February 25, 2015,
Federal Register Vol. 80, No. 37, 10165
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Training
• BTP authors offered training to Agreement State
partners and NRC regional staff
• Training slides are publicly available on the NRC
CA BTP website:
http://www.nrc.gov/waste/llw-disposal/llw-pa/llw-btp.html
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EPRI Working Group Participation
• EPRI presentation today on working group
• NRC participation limited to clarification of
positions in the CA BTP and did not result in
regulatory decisions or commitments
• NRC clarifications made to working group are
publicly available as Q&A on the NRC CA BTP
website
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Q&A
• NRC committed to making Q&A gathered from
training sessions and stakeholders publicly
available
• First batch of Q&A made publicly available on
10/30/2015. Additional Q&A added on
2/18/2016 and 3/2/2016
• Updates have been limited to additions and
have not changed previously-published Q&A
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Q&A – Waste Types & Streams
• Several questions related to the relationship between
waste types and waste streams
• For the purposes of the CA BTP
– Waste types based on physical characteristics
– Waste streams based on physical and radiological
characteristics
• Guidance for blendable waste (e.g., resins, soils,
contaminated trash) relies on distinctions between waste
types and waste streams
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Q&A – Waste Types & Streams
• Several questions related to the relationship between
waste types and waste streams
• For the purposes of the CA BTP
– Waste types based on physical characteristics
– Waste streams based on physical and radiological
characteristics
• Guidance for blendable waste (e.g., resins, soils,
contaminated trash) relies on distinctions between waste
types and waste streams
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Q&A – Waste Types & Streams
(continued)
Q: Given that Revision 1 of the CA BTP relies on the
Uniform Waste Manifest (UWM) to identify waste types, can
anion and cation exchange resins be considered a single
waste type even though they are listed on the UWM
separately?
A: Yes. Anion and cation resins need not be treated as
separate waste types for the purposes of the CA BTP.
Similarly, for the purposes of the CA BTP, a bed of mixed
ion exchange media is considered a single waste type
(even when charcoal is a constituent of the mixed bed).
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Q&A – Waste Types & Streams
(continued)
Q: Guidance for mixing blendable waste types only
discusses physical and chemical compatibility of the waste
types. What are the averaging constraints for mixtures of
two or more blendable waste types?
A: Once physical and chemical compatibility are shown,
the separate waste types can be treated as one waste
type. The guidance for combining separate waste streams
of the same waste type applies.
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Q&A – Waste Types & Streams
(continued)
Q: The CA BTP includes a provision for combining waste
streams at a generator’s facility for operational efficiency,
occupational safety, or occupational dose reduction, but the
CA BTP specifies it applies only to wastes of the same
waste type. Can it be applied to different waste types?
A: Once physical and chemical compatibility are shown,
the provision can be used as if the wastes belong to the
same waste type.
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Q&A – Extreme Measures
Q: What does staff interpret as “extreme measures” to
avoid when performing solidification or thermal processing?
A: As in the 1995 CA BTP, the staff interprets the phrase to
mean that any non-radioactive material added to the waste
should have a purpose other than lowering the waste
classification (e.g., stabilization or thermal process control).
As in the 1995 CA BTP, the staff has not specified any
particular numerical constraints, and instead gives State
regulators flexibility in identifying “extreme measures.”
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Q&A – Extreme Measures
(continued)
Q: Absent a specific numerical standard for “extreme
measures,” can the 14 percent waste loading criterion used
for encapsulation in containers larger than 0.2 m3 also be
used for solidification and thermal processing?
A: No. The 14 percent waste loading value is based on a
topical report for an encapsulation process submitted to the
NRC and is not necessarily transferrable to other
processes. The key factor in determining whether a waste
loading is appropriate is to determine whether the material
added has a purpose other than changing the waste
classification. The NRC staff encourages communication
with disposal State regulators on these issues.
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Q&A – Applicability
Q: The revised CA BTP states that its scope is limited to
averaging concentrations of radionuclides to determine
waste classification for disposal (i.e., per 10 CFR
61.55(a)(8)). Does that mean that the CA BTP does not
apply to waste being shipped for processing?
A: Yes. The CA BTP does not apply to waste being shipped
from a waste generator to a waste processor. The CA BTP
applies to waste after it is in final form and is being shipped
directly to a licensed waste disposal facility for disposal.
Concentration averaging methods are evaluated as part of
processors’ licensed activities.
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Q&A – Encapsulation
Q: The revised CA BTP lists stability as one of the benefits
encapsulation can provide but does not address stability as an
averaging constraint. Should it?
A: Neither the 1995 nor the revised CA BTP states that concentrations
should only be averaged if encapsulation provides stability.
Class B and C waste must meet the stability requirement of 10 CFR
61.56(b). This requirement may be met by the encapsulating medium
or by other means (e.g., disposal in a high integrity container).
For Class A waste, the NRC staff did not assume waste stability in
calculating hypothetical intrusion doses. Intrusion was assumed to
occur at the end of the active institutional control period (i.e., 100 years
after site closure), and the intruder was assumed to come into direct
contact with the encapsulated waste (i.e., encapsulation was assumed
to have failed). Therefore, changing the guidance to state encapsulated
Class A waste should provide stability like the 10 CFR 61.56(b)
requirements was unnecessary.
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Contaminated Materials
• When the NRC issued the revised CA BTP staff
noted that the distinction between contaminated
materials and contaminated trash might need
further clarification.
• NRC published an FRN soliciting public
comment on 1/20/2016
• Comment period closed on 3/21/2016
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Contaminated Materials
(continued)
• NRC received three comment letters
– Two letters expressed the view that additional
guidance is not necessary
– One of those letters also recommended that if any
clarification is made, CA BTP Tables 2 and 3 should
be used to distinguish between contaminated
materials and contaminated trash
– One expressed concerns about undocumented
chemical waste disposal
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Next Steps
• Determine whether additional guidance is needed
for distinguishing contaminated materials from
contaminated trash
• Provide guidance or explain decision that no
additional guidance is needed and address
comment letters
• Continue to respond to stakeholder questions and
publish Q&A on public website
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Resources
• CA BTP in ADAMS
– Vol. 1 ML12254B065
– Vol. 2 ML12326A611
• CA BTP public website, including Q&A
http://www.nrc.gov/waste/llw-disposal/llw-pa/llw-btp.html
• Any Questions contact Maurice Heath 301-415-3137
or Email: [email protected]
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