After several preliminary drafts, the Nuclear Regulatory Commission’s proposed final Branch Technical Position on Concentration Averaging was released to the public for a 120-day public comment period yesterday. The BTP is being updated as part of ongoing NRC efforts to address unique waste streams such as blended radioactive waste in regulations. Major changes were made to the section governing what wastes would be considered acceptable for blending or mixing, and how the NRC or Agreement State regulators could determine whether mixed low-level radioactive wastes are homogeneous. The section, now titled “Classifying Mixable and Homogeneous Wastes,” defines waste streams NRC considers mixable, and made the parameters of what is considered homogenous more liberal in the proposed version. “Mixable” waste is defined as “waste that is amenable to physical mixing to relatively uniform radionuclide concentrations,” and NRC staff wrote that “mixable waste is not necessarily homogeneous.” Waste is homogeneous under the proposed BTP if “the concentrations of the ‘nuclide(s) of concern are likely to approach uniformity in the context of reasonably foreseeable intruder scenarios. Thus, mixability is a physical property of the waste, whereas homogeneity, as used in this guidance, is a radiological property.”
The NRC staff also included alternative methods licensees may use to demonstrate homogeneity of wastes in the body of the BTP, rather than simply pointing generators to an alternative method exception process. Some stakeholders had told the NRC that an exemption process was unlikely to be acceptable or reasonably achievable with Agreement State regulators. Another addition to the regulation in direct response to stakeholder comment came in regard to the inadvertent intruder scenario, where the NRC backed off of assuming in the scenario that an intruder drills directly into a ‘hot spot’: “Because of the low likelihood that an intruder would encounter a hot spot in a waste that typically is expected to be homogenous, the NRC staff does not believe that any benefits realized by quantifying the homogeneity of these wastes would justify the additional dose incurred by workers making the measurements.”
The NRC released a preliminary draft of its revisions to stakeholders in September 2011, and held public meetings and met with the Advisory Committee on Reactor Safeguards during the fall. The agency was initially set to release a draft for public comment early this year, but postponed that process to adequately respond to feedback. The final version is expected sometime in 2013.
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