Concentration Averaging and 

Encapsulation Branch Technical 

Position, Revision 1 

Volume 1 

U.S. Nuclear Regulatory Commission 

Office of Nuclear Material Safety and Safeguards 

February 2015
2 

Table of Contents

1. INTRODUCTION ...................................................................................................................... 5 

1.2 Purpose of This Guidance Document ............................................................. 6

1.3 Document Organization .................................................................................. 8

1.4 Overview of Concentration Averaging........................................................... 9

1.5 Relationship to Other NRC Guidance ........................................................... 13

2. SAFETY CULTURE ................................................................................................................ 14 

3. TECHNICAL POSITION ......................................................................................................... 14 

3.1 Waste Characterization ................................................................................. 15

3.1.1 Identifying Waste Streams ........................................................................... 15 

3.1.2 Identifying Waste Types ............................................................................... 15 

3.1.3 Physical Characterization ............................................................................. 15 

3.1.4 Radiological Characterization....................................................................... 16 

3.2 Blendable Waste ........................................................................................... 17

3.2.1 Concentration Averaging for a Single Blendable Waste Stream .................. 18 

3.2.2 Concentration Averaging for Multiple Blendable Waste Streams ................. 19 

3.2.3 Classification of Solidified Waste ................................................................. 21 

3.3 Discrete Items ............................................................................................... 21

3.3.1 Concentration Averaging and Classification of Single Discrete 

Items ............................................................................................................ 21 

3.3.2 Concentration Averaging and Classification of Mixtures of Discrete 

Items ............................................................................................................ 22 

3.3.3 Alternative Treatment of Certain Cartridge Filters ........................................ 29 
3 

3.3.4 Encapsulation of Discrete Items ................................................................... 30 

3.4 Classification of Mixtures of Different Waste Types ...................................... 33

3.5 Determining the Volume or Mass of Waste ................................................... 33

3.6 Quality Assurance Program .......................................................................... 34

3.7 Alternative Requirements for Waste Classification (10 CFR 61.58) .............. 35

3.8 Alternative Approaches for Averaging........................................................... 35

3.8.1 Site-Specific Intruder Assessments ................................................................. 36 

3.8.2 Encapsulation of Discrete Items, Including Sealed Sources ........................... 37 

3.8.3 Likelihood of Intrusion ...................................................................................... 38 

3.8.4 Large Components .......................................................................................... 40 

3.8.5 Time of Intrusion into Blendable Waste ........................................................... 40 

3.8.6 Legacy Wastes ................................................................................................ 40 

3.9 Implementation ............................................................................................ 41

3.10 Backfit Considerations ................................................................................ 41

4. REFERENCES ....................................................................................................................... 42 

APPENDIX A: GLOSSARY ........................................................................................................ 44 

APPENDIX B: MAJOR CHANGES FROM 1995 TO 2015 CA BTP ........................................... 46 

APPENDIX C: SAFETY CULTURE STATEMENT OF POLICY ................................................ 48 

Figures 

Figure 1 CA BTP Guidance Overview ....................................................................................... 10 

Figure 2 Overview of Classification of Mixtures of Discrete Items ............................................ 22 

Figure 3 Classification of Mixtures of Discrete Items Within a Single Waste Type ................... 23 

Figure 4 Classification of Sectioned Components .................................................................... 27 

Figure 5 Classification of Encapsulated Items .......................................................................... 31 
4 

Tables 

Table 1 Thresholds for Demonstrating Adequate Blending ...................................................... 19 

Table 2 Recommended Activity Limits of Primary Gamma Emitters Potentially 

Requiring Piecemeal Consideration in Classification Determinations .......................... 24 

Table 3 Recommended Activity Limits of Radionuclides other than Primary Gamma 

Emitters Potentially Requiring Piecemeal Consideration in Classification 

Determinations ............................................................................................................. 25

Table 4 Volume and Mass for Determination of Concentration ................................................ 33 

 
5 

1. INTRODUCTION 

The U.S. Nuclear Regulatory Commission’s (NRC’s) licensing requirements for land 

disposal of radioactive waste in Title 10 of the Code of Federal Regulations (10 CFR) 

Part 61, “Licensing Requirements for Land Disposal of Radioactive Waste,” include four 

performance objectives: 

• 10 CFR 61.41, “Protection of the general population from releases of radioactivity”: 

• 10 CFR 61.42, “Protection of individuals from inadvertent intrusion”; 

• 10 CFR 61.43, “Protection of individuals during operations”; and 

• 10 CFR 61.44, “Stability of the disposal site after closure.” 

A low-level radioactive waste (LLW) disposal facility must be designed, operated, closed, 

and controlled after closure so that there is reasonable assurance that these performance 

objectives will be met. This document provides guidance for one aspect related to the 

10 CFR 61.42 performance objective regarding protection of an inadvertent intruder 

(i.e., the averaging of radionuclide concentrations for determining the classification of the 

waste). Specifically, this Concentration Averaging (CA) Branch Technical Position (BTP) 

provides guidance on complying with 10 CFR 61.55(a)(8), “Determination of 

concentrations in wastes,” as it applies to the classification of waste for disposal under 

10 CFR Part 61.

1.1 Background 

In developing the regulations in 10 CFR Part 61, the NRC implemented an approach for 

managing the risk to an individual who hypothetically could inadvertently intrude on LLW. 

That approach has a number of different components. Concentration averaging, the 

subject of this document, is one of those components. First, a 100-year institutional 

control program is specified in 10 CFR 61.59 to help ensure that individuals will not intrude 

into the disposal facility after it is closed. The 100-year period allows for substantial decay 

of shorter-lived radionuclides so that the remaining hazard is significantly less than when 

the waste was first disposed. After 100 years, no credit can be taken for the existence of 

active institutional controls. Next, the NRC postulates that an individual unknowingly 

intrudes onto the disposal site after the 100-year institutional control period ends and 

interacts with the waste. To protect this hypothetical1

 individual, the NRC developed a 

waste classification system in 10 CFR Part 61 that requires segregation of LLW into 

classes based on radionuclide concentrations, as well as greater control measures for 

waste with higher radionuclide concentrations. As stated in 10 CFR 61.13, “Technical 

analyses,” analyses of the protection of individuals from inadvertent intrusion must include 

a demonstration that there is reasonable assurance that the waste classification 

 

1

 NRC discusses the hypothetical nature of intrusion in the draft Environmental Impact Statement (draft 

EIS) for 10 CFR Part 61 (NRC, 1981) as well as the final EIS for Part 61 (NRC, 1982). NRC 

reaffirmed the hypothetical nature of intrusion in the “Denial of Petition for Rulemaking Submitted by 

the New England Coalition on Nuclear Pollution,” Docket No. PRM-61-2, March 29, 1994, 

Agencywide Documents Access and Management System (ADAMS) Accession No. ML093490607. 
6 

requirements will be met. The waste classification requirements are designed to limit the 

potential radiation exposure to such an intruder to 5 mSv/yr (500 mrem/yr).2

 

The radiation hazard to an intruder is dependent in part on the particular radionuclides 

involved and their concentrations. Therefore, 10 CFR Part 61 includes a waste 

classification system that categorizes waste based on these characteristics of the waste. 

Three classes (A, B, and C) are defined, and the controls used to manage risk, such as 

engineered barriers, increase with increasing waste class. Class A waste, the lowest 

hazard class, has no special provisions for intruder protection, since it contains types and 

concentrations of radionuclides that typically will decay during the 100-year institutional 

control period to levels that present an acceptable hazard to an intruder. Class C waste, 

on the other hand, presents a greater long-term hazard and requires protection for 500 

years by an intruder barrier, such as deeper disposal or an engineered structure. The 

Class A, B, and C waste classes specified in 10 CFR 61.55 are defined by specific 

radionuclides and their concentrations. For example, 137Cs has a Class A limit of 

3.6 × 1010 Becquerel (Bq) per cubic meter (m3

) (1 Curie (Ci) / m3), a Class B limit of 

1.6 × 1012 Bq/m3 (44 Ci/m3

) and a Class C limit of 167 × 1012 Bq/m3 (4600 Ci/m3). 

The NRC’s waste classification system is also generic (i.e., it applies to all LLW disposal 

sites, regardless of their location in the United States). All generators and waste 

processors that ship waste to a licensed disposal site must use this system. The 

10 CFR 61.55 waste classification tables do not take into account any site-specific 

features or considerations, but licensees could perform site-specific or waste-specific 

intruder analyses in requesting regulatory approval for alternative waste classification 

provisions (10 CFR 61.58). This CA BTP addresses regulatory considerations for 

obtaining such approvals (Section 3.7). 

Like the waste classification system in 10 CFR Part 61, most of the averaging provisions 

specified in this document are also generic (i.e., they are suitable for use by any licensed 

disposal facility or generators or processors shipping waste to a licensed disposal facility). 

This approach might simplify classification for generators, but there might be instances in 

which generators, processors, or disposal-facility operators (hereafter referred to as 

“licensees”) might decide to apply site-specific averaging approaches. This CA BTP 

provides examples of site-specific considerations for averaging that might be useful to 

licensees that propose alternative averaging approaches and to disposal facility regulators 

that review these proposals. See Section 3.8, “Alternative Approaches for Averaging,” for 

additional details. 

1.2 Purpose of This Guidance Document 

The concentration limits for various radionuclides in the 10 CFR Part 61 waste 

classification system in 10 CFR 61.55 were developed for average concentrations of 

wastes. The NRC does not specify in the regulations how radiological “hot spots” are to 

be averaged, other than to specify in 10 CFR Part 61.55(a)(8) that averaging of waste 

 

2

 This dose limit was used in the draft EIS for 10 CFR Part 61 (NRC, 1981) to develop the waste 

classification tables in 10 CFR 61.55, “Waste classification.” 
7 

concentrations is acceptable.3

 The regulations do not define the conditions and 

constraints4

 on such averaging. 

This CA BTP is designed to answer questions such as: “How much waste above the class 

limits is permissible in a waste mixture?” and “How much more concentrated than the limit 

can a portion of this waste be?” and “Over what volume are these concentrations to be 

measured?” Because non-radioactive material is also sometimes added to LLW to make it 

more physically or chemically stable, this CA BTP also answers the question, “How much 

credit can be taken for non-radioactive material that is mixed with LLW?” The CA BTP 

states that extreme measures of adding non-radioactive material, diluting the waste to 

circumvent stricter disposal requirements, should not be used. All of the constraints on 

averaging specified in this CA BTP are designed to help ensure that an inadvertent 

intruder into a disposal site, upon contacting hot spots in waste, will not receive an unsafe 

exposure to radioactivity. 

The guidance in this CA BTP may be used to help demonstrate compliance with the 

following NRC regulations: 

• 10 CFR 61.55. This provision specifies concentrations of various radionuclides and 

other instructions for determining the classification of waste. It includes 

10 CFR 61.55(a)(8), which states that concentration averaging is permissible in 

determining waste class. 

• Appendix G, “Requirements for Transfers of Low-Level Radioactive Waste Intended 

for Disposal at Licensed Land Disposal Facilities and Manifests,” to 10 CFR Part 20, 

“Standards for Protection Against Radiation,” contains several provisions related to the 

classification of waste. Section C, “Disposal Container and Waste Information,” 

item 12, requires that for wastes consigned to a disposal facility, the classification of 

the waste pursuant to 10 CFR 61.55 must be documented on the uniform shipping 

manifest for the waste and each disposal container of waste in the shipment. In 

addition, Section II, “Certification,” requires an authorized representative of the waste 

generator, processor, or collector to certify that the transported materials are properly 

classified, among other things. 

This guidance provides acceptable methods that can be used by waste generators, 

processors, disposal facility operators, Agreement State regulators, and others to perform 

concentration averaging of specific wastes and mixtures of waste for the purpose of 

determining their waste class for disposal. Although Agreement States are required to 

adopt waste classification regulations that are essentially identical to the NRC’s in 

10 CFR 61.55,5

 they may specify averaging approaches in their disposal facility licenses 

that differ from those contained in this guidance.6

 Licensees shipping waste for disposal 

 

3

 10 CFR 61.55(a)(8) states that “...The concentration of a radionuclide may be averaged over the 

volume of the waste, or weight of the waste if the units are expressed as nanocuries per gram.” 4

 As used in this document, “constraint” is used in its normal sense; that is, this guidance recommends 

limits (or constraints) on how much radionuclide concentrations can be averaged. This guidance is 

not using the word constraint as it is defined in 10 CFR 20.1003, “Definitions”: “Constraint (dose 

constraint) means a value above which specified licensee actions are required.” 5

 10 CFR 61.55 is NRC compatibility Category B. This category is for activities that have direct and 

significant transboundary implications. 6 In practice, current disposal facility licenses reference the CA BTP in whole or in part. 
8 

may therefore need to consult with disposal facility operators in order to comply with 

disposal facilities’ license conditions. 

Sections 3.1 – 3.7 represent NRC staff’s most recent and best efforts to identify specific 

concentration averaging methods that will enable licensees to comply with the averaging 

provision in 10 CFR Part 61.55(a)(8). In Section 3.8, NRC staff gives examples of 

alternative approaches for averaging, different from those in Sections 3.1 – 3.7, that may 

be also be appropriate, and considerations for licensees and regulators in determining 

whether such approaches are safe. NRC staff strongly urges licensees to submit 

proposals for “alternative approaches” to the regulator for the disposal facility and to have 

in-depth discussions on the merits of the proposal with the regulator before classifying 

waste under the alternative provisions. Alternative approaches to averaging are generally 

complex, often involving selection of intruder scenarios, for example. Detailed discussions 

between staff of the regulatory agency for the disposal facility and licensee would help to 

ensure that waste is classified appropriately before shipment to and disposal at a licensed 

facility. 

1.3 Document Organization 

This CA BTP contains two volumes. Volume 1 is focused on the specific concentration 

averaging provisions that should be used in classifying waste. Volume 2 contains 

background information that may be of interest to readers who want to better understand 

the technical basis for the positions in the first volume. Volume 2 also addresses how 

issues raised by stakeholders on the 2012 draft of the CA BTP have been addressed by 

the staff. Volume 1 contains the following sections: 

• Section 1 gives background information, describes the purpose of this CA BTP, 

describes the organization of the document, provides an overview of concentration 

averaging, and discusses the relationship between this CA BTP and other NRC 

guidance. 

• Section 2 describes the NRC’s Safety Culture expectations for individuals and 

organizations performing regulated activities, including the classification of LLW for 

disposal. 

• Section 3 contains the positions on concentration averaging for a variety of 

different waste types. It includes the following subsections: 

o Section 3.1 describes considerations for the physical and radiological 

characterization of waste. 

o Section 3.2 discusses concentration averaging for blendable wastes, which 

typically do not have significant hot spots that would be a hazard to an 

inadvertent intruder.

o Section 3.3 addresses concentration averaging for discrete items of a single 

waste type. 
9 

o Section 3.4 describes concentration averaging for mixtures of more than one 

waste type.

o Section 3.5 identifies the volumes and masses acceptable for using in 

concentration averaging for various waste streams and types.

o Section 3.6 describes the quality assurance program that should be used for 

classifying waste. 

o Section 3.7 discusses the use of 10 CFR 61.58, “Alternative requirements 

for waste classification and characteristics,” a regulatory provision which 

enables licensees to request regulatory approval of waste classification 

approaches different from those in 10 CFR 61.55. 

o Section 3.8 discusses potential averaging approaches different from those in 

the above sections, and considerations for licensees’ proposals to disposal 

facility regulators. 

o Section 3.9 describes implementation considerations. 

o Section 3.10 discusses backfit considerations. 

• Section 4 identifies references for Volume 1 of the CA BTP. 

Volume 1 also contains Appendix A, a glossary; Appendix B, a table which identifies the 

major changes from the 1995 CA BTP; and Appendix C, the NRC’s Safety Culture Policy 

Statement. 

Volume 2 of this CA BTP contains the technical basis for the averaging positions in 

Volume 1, as well as staff responses to public comments on a May 2012 draft of the CA 

BTP. Staff responses to public comments on previous drafts of the revised CA BTP are 

available in Appendices C, D, E, and F of the May 2012 draft.7

1.4 Overview of Concentration Averaging 

Concentration averaging is the mathematical averaging of the radionuclide activities in 

waste over its volume or mass. This CA BTP provides guidance on appropriate volumes 

and masses to use in calculating average concentrations, as permitted by 61.55(a)(8). 

Once the average radionuclide concentrations are determined, then the waste 

classification process described in 10 CFR 61.55 is used to determine the class of the 

waste. 

Figure 1 provides an overview of guidance in this document. This CA BTP addresses two 

broad categories of waste: blendable waste and discrete items. In general, blendable 

 

7

 Available in ADAMS at Accession Number ML121170418.
10 

 
11 

wastes are subject to fewer averaging constraints than discrete items because blendable 

wastes are generally not expected to have hot spots that could pose a hazard to an 

inadvertent intruder.8

 In most cases, blendable waste may be averaged over the mass or 

volume of the waste without any demonstration of adequate blending. In cases in which 

highly concentrated blendable waste is combined with a blendable waste with much lower 

radionuclide concentrations, hot spots could be created if the waste is not adequately 

blended. This CA BTP provides guidance for when waste must be blended and how to 

demonstrate that waste is adequately blended. 

The second category is discrete items. The CA BTP recommends constraints for discrete 

items based on their size and the amount or concentration of radioactivity they contain. 

The size, amount of radioactivity and concentration help to define the hazard to an 

inadvertent intruder who might directly handle the discrete item. 

This CA BTP relies on the following key concepts:

• Averaging Constraints: Recommended restrictions on averaging radionuclide 

concentrations as allowed by 10 CFR 61.55(a)(8). Averaging constraints are 

designed to limit potential hot spots in waste. Different averaging constraints apply 

to blendable waste and discrete items. 

• Hot Spot: A portion of the overall waste volume whose radionuclide concentrations 

are above the class limit for the entire container. Because averaging is permitted 

under the regulations, some exceedance of the limits is permissible for portions of 

the overall volume of the waste, as long as the average concentration of the 

container is within the class limit. Classification is based on the average 

radionuclide concentrations of waste in a container according to 

10 CFR 61.55(a)(8), subject to certain constraints on hot spots. 

• Waste Stream: Waste with relatively uniform radiological and physical 

characteristics. Often, the waste results from a single process. Examples of waste 

streams are provided in NRC Information Notice (IN) 86-20, “Low-Level 

Radioactive Waste Scaling Factors, 10 CFR Part 61” (ADAMS Accession No. 

ML103420436); for example, pressurized-water reactor (PWR) primary and 

secondary system ion-exchange resins are separate waste streams. Each facility 

may identify its own waste streams. 

• Waste Type: Wastes with similar physical characteristics but which might have 

different radiological characteristics. Ion-exchange resins from either the primary 

or secondary coolant systems in a nuclear power plant are the same waste type.9

 

However, ion-exchange resins, soils, and activated metals are different waste 

types. 

 

8 The BTP guidance for blendable wastes is based on a scenario similar to the “post-drilling” scenario 

in National Council on Radiation Protection & Measurements (NCRP) Report Number 152 

(NCRP, 2005). The scenario is similar to the agricultural scenarios considered in the Draft 

Environmental Impact Statement for Part 61 (NRC, 1981) except that less waste is exhumed (see 

Volume 2, Section 4). 9

 As defined in 10 CFR Part 20, and for purposes of this BTP, a waste type is a category of waste 

within a disposal container having a unique physical description (i.e., a specific waste descriptor code 

or description; or a waste sorbed on or solidified in a specifically defined media). 
12 

• Waste characterization: Waste characterization has many purposes, and in 

general, it means identifying the physical and radiological properties of LLW. For 

the purposes of applying the concentration averaging constraints described in this 

CA BTP, waste characterization includes the identification of the waste stream

from which waste is produced (e.g., primary or secondary resins in a nuclear power 

plant), the waste type (i.e., wastes with similar physical characteristics), physical 

characterization (e.g., whether waste is “discrete” or “blendable,” and radiological 

characterization (i.e., the determination of the presence and concentrations and 

amounts of radionuclides relevant to waste classification. 

• Waste classification: the process of categorizing waste based on the concentration 

of certain key radionuclides important to protection of an inadvertent intruder into a 

LLW disposal facility. 10 CFR Part 61 defines three classes (A, B, and C). The 

controls used to manage risk to an inadvertent intruder, such as engineered 

barriers, increase with increasing waste class. 

• Discrete Items: For the purposes of this CA BTP, discrete items are items 

belonging to one of the following waste types: activated metals, sealed sources, 

cartridge filters10, contaminated materials, and components incorporating 

radioactivity into their design. Items belonging to these waste types are designated 

as discrete items in this guidance because (1) they are expected to be durable 

(i.e., remain intact at the time of intrusion) and (2) items belonging to these waste 

types often have relatively high amounts or concentrations of radioactivity. 

• Blending: Blending is physically mixing two or more blendable waste streams to 

create a product with relatively uniform radionuclide concentrations. For the 

purposes of this CA BTP, a waste stream is considered to have the properties 

needed for blending (i.e., a waste stream is “blendable”) if: (1) the waste can be 

physically mixed to create relatively uniform11 radionuclide concentrations or (2) the 

waste is not expected to contain durable items with significant activity.12 This CA 

BTP makes a distinction between waste that is “blendable,” indicating that it has 

the properties needed for blending, and waste that is “blended,” indicating two or 

more blendable waste streams have been physically mixed together. 

• Encapsulation: The process of surrounding a radioactive sealed source, a 

collection of such sources, or other materials in a binding matrix within a container, 

where the activity remains within the dimensions of the original source(s) or other 

materials. This CA BTP provides guidance on the amount of encapsulating 

material can be included in concentration averaging. 

 

10 As described in Section 3.3.3, cartridge filters may be treated as blendable waste in some cases. 11 Radionuclide concentrations are “relatively uniform” if an intruder who encounters the waste is 

unlikely to encounter waste more concentrated than the class limit by a factor of 10. 12 Durable items with significant activity are defined as “discrete items.” Although contaminated trash 

may contain durable items, any durable items in trash are not expected to contain significant activity. 

Durable items with significant contamination are considered to be “contaminated materials” instead of 

trash.
13 

• Alternative Approaches: The averaging constraints specified in this CA BTP are 

generic, like the 10 CFR Part 61 waste classification system, and are suitable for 

use at any disposal facility. This CA BTP also provides guidance for alternative 

approaches to concentration averaging based on site- or waste-specific 

considerations that licensees may propose to the disposal facility regulator. 

These terms and others important to this CA BTP are listed in the glossary in Appendix A. 

1.5 Relationship to Other NRC Guidance

This CA BTP has evolved from a section in a guidance document published shortly after 

10 CFR Part 61 was promulgated. The NRC’s Final Waste Classification and Waste Form 

Technical Position Papers (NRC, 1983) described overall procedures acceptable to the 

NRC staff that could be used to determine the presence and concentrations of the 

radionuclides listed in 10 CFR 61.55. That information was also used by licensees to 

classify waste for near-surface disposal. 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.” This provision allows averaging of waste concentrations for 

determining the classification of the waste as Class A, B, or C. 

On January 17, 1995, the NRC replaced Section C.3 of the 1983 Technical Position on 

Waste Classification with the “Branch Technical Position on Concentration Averaging and 

Encapsulation” (NRC, 1995a). A major purpose of the 1995 CA BTP was to provide 

guidance for the disposal of discrete, durable, gamma-emitting items or mixtures of such 

items. The 1995 guidance was designed to ensure that potential exposures from 

exhuming discrete items would be within the “envelope of safety” considered for 

inadvertent intrusion in the environmental impact statement (EIS) for Part 61. The EIS for 

Part 61 did not explicitly consider potential intruder exposures from discrete items. 

Instead, it considered the potential exposure of an inadvertent intruder who lives and 

grows food on a site where waste has inadvertently been exhumed and mixed with soil. 

This document updates the 1995 CA BTP in its entirety.13 However, some of the 

remaining guidance in the 1983 Technical Position on Waste Classification remains in 

effect. Specifically, Section C, “Regulatory Position” (including Sections C.1, “General 

Criteria;” and C.2, “Determination and Verification of Radionuclide Concentrations and 

Correlations”), and Appendix A, General Program for Classifying Wastes at Nuclear Power 

Plants,” may continue to be used. As noted above, this 2015 document replaces 

Section C.3 addressing concentration averaging.14 In addition, Section C.4, “Reporting on 

Manifests” has been superseded by a waste manifesting rule promulgated on 

March 28, 1995, “Low-Level Waste Shipment Manifest Information and Reporting,” (NRC 

1995b). Guidance for implementing that rule is contained in NUREG/BR-0204, 

“Instructions for Completing NRC’s Uniform Low-Level Radioactive Waste Manifest” 

(NRC, 1998b). 

 

13 As discussed in Section 3.10, use of this revised guidance is voluntary. Licensees and applicants 

may choose another method of demonstrating compliance with 10 CFR 61.55(a)(8). In particular, 

current licensees may continue to use the 1995 CA BTP. 14 Corrections to the 1983 guidance identified in the 1995 BTP remain in effect, however. Specifically, 

in p. 6, fourth line, and p. 12, second paragraph, fifth line, replace “biannual” with “biennial.” 
14 

The scope of this revised CA BTP is limited to the averaging of concentrations of 

radionuclides for the purpose of determining the classification of waste being shipped for 

disposal, as provided for by 10 CFR 61.55(a)(8). Licensees shipping waste for disposal 

must meet other requirements, including the disposal facility license conditions, and 

should follow other applicable NRC guidance documents that cover other aspects of LLW 

transportation and disposal (e.g., hydrogen generation15 and waste form stability16). 

2. SAFETY CULTURE 

It is the NRC’s expectation that individuals and organizations performing regulated 

activities, such as characterizing and classifying LLW for disposal, establish and maintain 

a positive safety culture commensurate with the safety and security significance of their 

activities and the nature and complexity of their organizations and functions. This applies 

to all licensees, certificate holders, permit holders, authorization holders, holders of quality 

assurance program approvals, vendors and suppliers of safety-related components, and 

applicants for a license, certificate, permit, authorization, or quality assurance program 

approval, subject to NRC authority. “Nuclear safety culture” is defined as the core values 

and behaviors resulting from a collective commitment by leaders and individuals to 

emphasize safety over competing goals to ensure protection of people and the 

environment. Individuals and organizations performing regulated activities bear primary 

responsibility for safely handling and securing these materials. Experience has shown that 

a positive safety culture exhibits certain personal and organizational traits. A trait, in this 

case, is a pattern of thinking, feeling, and behaving that emphasizes safety, particularly in 

goal conflict situations (e.g., production versus safety, schedule versus safety, and cost of 

the effort versus safety). 

The NRC, as the regulatory agency with an independent oversight role, reviews the 

performance of individuals and organizations to determine compliance with requirements 

and commitments through its existing inspection and assessment processes. Licensees 

are not required by the regulations to incorporate the NRC’s safety culture policy 

statement into their activities. However, many of the safety culture traits may be inherent 

to an organization’s existing radiation safety practices and programs. 

Refer to Appendix C for the NRC’s Safety Culture Policy Statement. More information on 

NRC activities related to safety culture can be found at: http://www.nrc.gov/aboutnrc/regulatory/enforcement/safety-culture.html. 

3. TECHNICAL POSITION 

This section provides guidance on acceptable methods of concentration averaging for 

classification of low-level radioactive waste in accordance with 10 CFR 61.55(a)(8). It also 

provides guidance on characterization and classification of waste for waste manifests 

contained in Appendix G to 10 CFR Part 20.

 

15 See Information Notice 84-72 , “Clarification of Conditions for Waste Shipments Subject to Hydrogen 

Gas Generation,” (NRC, 1984). 16 See Revision 1 of the “Waste Form Technical Position” (NRC, 1991). 
15 

3.1 Waste Characterization 

Waste must be characterized to determine which averaging constraints apply for waste 

classification. In addition, LLW generators shipping waste for disposal, either directly or 

through a waste processor or collector, are required to characterize waste on the uniform 

shipping manifests prescribed in Appendix G to 10 CFR Part 20.17 For the purposes of 

this CA BTP, waste is divided into one of two categories, blendable waste or discrete 

items. Different averaging constraints apply to each category. Discrete items are 

generally individually characterized, and therefore more characterization is required for 

discrete items than for blendable wastes. 

3.1.1 Identifying Waste Streams

Waste is considered to be from a single waste stream if it has relatively uniform 

radiological and physical characteristics. Often, a waste stream results from a single 

process. Waste streams are considered distinct (i.e., different from one another) if the 

concentrations of radionuclides of concern (see the Glossary) typically differ by more than 

a factor of 10 (e.g., primary and secondary resins from nuclear power plants are distinct 

waste streams). 

NRC IN 86-20, “Low Level Radioactive Waste Scaling Factors, 10 CFR Part 61” (NRC, 

1986a), provides a list of typical waste streams at nuclear power plants. For example, for 

pressurized-water reactors (PWRs), IN 86-20 identifies these separate waste streams: 

primary purification filters, primary purification resins, chemical and volume control system 

evaporator bottoms, radwaste polishing resins, secondary system wastes (filters and 

resins), and contaminated trash. For Boiling Water Reactors (BWRs), IN 86-20 identifies 

these separate waste streams: cleanup filters and resins, condensate-polishing resins, 

evaporator bottoms, radwaste ion-exchange resins, and contaminated trash. These lists 

are provided only as examples and licensees may identify waste streams differently.

3.1.2 Identifying Waste Types

Waste is considered to be a single waste type if the waste has relatively uniform physical 

characteristics. For example, primary resin and secondary resin are the same waste type 

but resin and soil are different waste types. 

3.1.3 Physical Characterization 

Most LLW shipped for disposal is in a solid waste form and is subject to 

concentration-averaging constraints based on whether it is blendable waste or discrete 

items. Small amounts of gaseous waste may also be disposed of but are not subject to 

concentration-averaging constraints because the radiological concentrations in gases are 

expected to be uniform. Liquid waste, other than small amounts of free liquid in 

 

17 A waste shipping manifest is not required from the generator when the radioactively contaminated 

material sent by a licensee becomes the waste processor’s “residual waste.” Residual waste is 

defined in Appendix G, 10 CFR Part 20, to mean low-level radioactive waste resulting from 

processing or decontamination activities that cannot be easily separated into distinct batches 

attributable to specific waste generators. This waste is attributable to the processor or 

decontamination facility, as applicable. 
16 

containers, is not authorized for disposal in a licensed disposal facility. However, liquid 

waste may be solidified or absorbed onto solid media in preparation for disposal.18

Blendable waste (see Section 3.2) includes waste types such as soils, resins, filter media, 

compactible trash, non-compactible trash, and ash. Blendable waste is not expected to 

contain discrete durable items that would be a hazard to an inadvertent intruder. 

For the purposes of this CA BTP, discrete items (see Section 3.3) are items belonging to 

one of the following waste types: activated metals, sealed sources, cartridge filters,19

contaminated materials, and components incorporating radioactivity into their design. 

Items belonging to these waste types are designated as discrete items in this guidance 

because (1) they are expected to be durable (i.e., remain intact at the time of intrusion) 

and (2) items belonging to these waste types often have relatively high amounts or 

concentrations of radioactivity. Process knowledge may be used to determine whether 

items are expected to have high amounts or concentrations of radioactivity. 

Another physical characteristic important for waste classification is the volume to be used 

for the purposes of concentration averaging. Table 4 in Section 3.5 identifies constraints 

for the volume or mass that should be used in classifying waste. Most concentrations of 

radionuclides in the 10 CFR 61.55 waste classification tables are based on radioactivity 

per unit volume.20 Weight may also be used and converted to equivalent volume for 

averaging purposes provided that a representative density is used, based on a 

representative distribution of materials. 

3.1.4 Radiological Characterization 

Sections C.1, “General Criteria,” and C.2, “Determination and Verification of Radionuclide 

Concentrations and Correlations,” of the 1983 Technical Position on Waste Classification 

describe acceptable procedures to determine the presence and concentrations of the 

radionuclides listed in 10 CFR 61.55.21 As noted earlier, the concentration averaging 

guidance in Section C.3 of that 1983 document was replaced by the 1995 CA BTP, which 

has been updated in its entirety by this revised CA BTP.22 However, Sections C.1 and C.2 

of the 1983 guidance are still in effect. 

Section C.2 of the 1983 Technical Position on Waste Classification identifies four different 

methods for radiological characterization of waste: 

(1) compliance through materials compatibility, 

(2) classification by source, 

 

18 Liquid waste may also be disposed of as a liquid effluent in accordance with the provisions of 10 CFR 

Part 20. This BTP only covers solid waste shipped for disposal at a licensed facility. 19 As described in Section 3.3.3, cartridge filters may be treated as blendable waste in some cases. 20 Transuranic radionuclide concentration limits are specified as radioactivity per unit of weight. 21 Other NRC guidance on radionuclide characterization may be used as well (see, for example, 

Information Notice 86-20, “Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61” (NRC, 

1986a)). The 1983 Technical Position on Waste Classification is NRC’s principal guidance on 

radionuclide characterization for the purposes of waste classification, however. 22 As discussed in Section 3.10, use of this guidance is voluntary. Licensees and applicants may 

choose another method of demonstrating compliance with 10 CFR 61.55(a)(8). In particular, current 

licensees may continue to use the 1995 CA BTP. 
17 

(3) gross radioactivity measurements, and 

(4) measurement of specific radionuclides. 

The extent of radiological characterization required depends on whether the wastes are 

blendable wastes or discrete items. Discrete items should generally be individually 

characterized because they are subject to averaging constraints in this CA BTP. 

Blendable waste generally requires less characterization than discrete items. In some 

cases, blendable wastes (e.g., contaminated trash) may include durable items that have 

low activity of gamma-emitting radionuclides. These items do not need to be individually 

characterized, as explained in Section 3.2. In a few cases, mixtures of distinct blendable 

waste streams should be shown to be adequately blended, as discussed in Section 3.2.3. 

For radiological characterization of contaminated materials (i.e., components or metals on 

which radioactivity resides near the surface in a fixed or removable condition), the staff 

provides the following guidance. For individual items, classification may be determined by 

representative swipes or radiation survey measurements from which the total activity of 

radionuclides may be estimated through the use of scaling factors. In these cases, the 

volume or weight of the contaminated material should be the total mass or displaced 

volume of the item (i.e., major void volumes subtracted from envelope volume). For 

mixtures of these contaminated items, the total activity of contained radionuclides may 

also be determined by representative23 swipes or radiation survey measurements of the 

container’s contents. The volume or mass of the mixture should be the total mass or 

displaced volume of all the material contributing to the mixture. It is also permissible under 

the constraints for discrete items in Section 3.3 to average concentrations of the 

radionuclides listed in Tables 1 and 2 of 10 CFR 61.55 over the contents of the disposal 

container. 

If generators are shipping to a waste processor or collector, they do not need to classify 

the waste, because classification is only required for the final waste form presented for 

disposal. However, waste processors or collectors might need to rely on the physical and 

radiological characterization provided by generators for classifying the waste for disposal. 

3.2 Blendable Waste 

For the purposes of this guidance, a waste type is considered to have the properties 

needed for blending (i.e., a waste type is “blendable”) if: 

• the waste can be physically mixed to create relatively uniform24 radionuclide 

concentrations or 

• the waste is not expected to contain durable items with significant activity. 

 

23 For swipes or radiation survey measurements to be representative of the mixture, discrete items in 

the mixture should meet the Factors of 2 and 10 described in Section 3.3, as appropriate for the 

mixture. 24 Radionuclide concentrations are “relatively uniform” if an intruder who encounters the waste is 

unlikely to encounter waste more concentrated than the class limit by a factor of 10 or more. 
18 

This CA BTP makes a distinction between waste that is “blendable,” indicating it has the 

properties needed for blending, and waste that is “blended,” indicating two or more 

blendable waste streams have been physically mixed together. Different waste types 

(e.g., resins and soils) can be blended if the licensee documents the physical and 

chemical compatibility of the waste types being combined (see Section 3.2.2). 

A waste type can be considered blendable if it meets either of the criteria listed in the 

previous paragraph. Ion-exchange resins, filter media, evaporator bottom concentrates, 

soil, and ash are each an example of a blendable waste type for the purposes of 

concentration averaging because each of these waste types, individually, can be 

physically mixed to create relatively uniform radionuclide concentrations. Contaminated 

trash is considered to be blendable because it is not expected to contain durable items 

with significant activity.25 Process knowledge may be used to determine whether items 

are expected to have radioactivity in high amounts or concentrations. Similarly, those 

cartridge filters that can be demonstrated (e.g., through process knowledge) not to contain 

primary gamma emitters in excess of the values in Table 2 may be treated as blendable 

waste for the purposes of concentration averaging26 (see Section 3.3.3). As used in this 

CA BTP, the primary gamma-emitting nuclides are cobalt-60 (60Co), niobium-94 (94Nb), 

and cesium-137 (137Cs).27

3.2.1 Concentration Averaging for a Single Blendable Waste Stream 

If a waste package contains a single blendable waste stream, radionuclide concentrations 

for waste classification may be averaged over the waste in the package. That is, an 

average radionuclide concentration may be based on its total activity in the package 

divided by the volume28 or mass of the waste in the package. However, if waste fills 

90 percent or more of a package, average radionuclide concentrations can be based on 

the entire interior volume of the container. Void spaces do not normally need to be 

accounted for in blendable waste29. 

Absorbed liquid (i.e., liquid radioactive waste that is absorbed onto an absorbent medium) 

may not be retained on the absorbent medium. Therefore, radionuclide concentrations 

should not be based on the volume or mass of the absorbent medium, but should be 

based on the original volume or mass of the liquid waste before absorption. 

The activity of small concentrated sources or gauges (less than 3.7 MBq) (100 μCi) that 

may be mixed with contaminated trash may be averaged over the trash volume. 

 

25 The definition of discrete items in this CA BTP (i.e., activated metals, sealed sources, cartridge 

 filters, contaminated materials, and components incorporating radioactivity into their design) is 

 expected to cover all durable items with significant activity. 

26 Note that the requirements in Section I.C.10 of Appendix G to 10 CFR Part 20 related to cartridge 

filters and contaminated equipment continue to apply even though these items may be treated as 

blendable waste for the purposes of concentration averaging. 27 Most 137Cs decays to a metastable nuclear isomer, 137mBa. 137Cs is not a gamma emitter, but 137mBa 

is. When this BTP refers to 137Cs, it includes the 137mBa that is in equilibrium with it. 28 The volume of the waste can be calculated from the weight of the waste divided by its density. 

Licensees may use a representative density based on a representative distribution of materials as 

they occur in waste. 29 The staff expects that in most cases it would not be consistent with “as low as is reasonably 

achievable” (ALARA) principles to determine the internal void spaces in contaminated trash. 
19 

3.2.2 Concentration Averaging for Multiple Blendable Waste Streams 

In some cases, blendable waste streams of the same waste type (e.g., primary and 

secondary resins) may be combined in the same container without blending. If the 

CA BTP Table 1 thresholds are not exceeded, the waste does not need to be 

blended and the radionuclide concentrations can be averaged over the volume of 

the waste or container as a single waste stream (i.e., as in Section 3.2.1). If the 

thresholds in CA BTP Table 1 are exceeded, the waste must be blended and a 

demonstration of adequate blending is needed. These thresholds are based on 

the sum of fractions of the most concentrated influent waste stream, the volume of 

the mixture, and the classification of the final mixture. Waste is adequately 

blended if there is reasonable assurance that there are no hot spots of waste 

0.2 m3

 (7 cubic feet (ft3)) or larger in size that have a sum of fractions greater than 

10 relative to the blended product. Alternative approaches for demonstrating 

blending is adequate may be justified based on site-specific conditions (see 

Section 3.8). Radionuclide concentrations should not be averaged over more than 

one container. 

An explanation and example of determining the sum of fractions is provided in 

10 CFR 61.55(a)(7). In summary, the first step in determining “Sum of Fractions of 

the Most Concentrated Influent Waste Stream” listed in this revised CA BTP Table 

1 is to determine the intended waste class of the blended product. Then the 

licensee should take the concentration of each nuclide in the most concentrated 

influent waste stream and divide it by the 10 CFR Part 61 concentration limit for 

that radionuclide, based on the waste class of the final blended product. The 

licensee should then sum the fractions over all the radionuclides in the influent 

waste stream. For example, if a licensee is blending waste to produce Class A 

waste, and the most concentrated influent waste stream has a 60Co concentration 

of 20,000 Ci/m3

, the licensee would divide 20,000 Ci/m3 by the 10 CFR 61.55 

Table 2 Column 1 (Class A) limit for 60Co of 700 Ci/m3

. If 60Co were the only 

radionuclide in the most concentrated influent waste stream, then the “Sum of 

Fractions of the Most Concentrated Influent Waste Stream” would be 20,000 Ci/m3

divided by 700 Ci/m3

, which is 28. In this case, based on the CA BTP Table 1, the 

licensee would either need to limit the volume the waste is averaged over to less 

than 60 m3

 (2,100 ft3) or provide a demonstration of adequate blending. 

A demonstration that waste is adequately blended can be based on process 

knowledge, reasoned conclusions, calculations, or direct measurements. For 

example, a licensee can show that a particular process blends waste adequately 

by testing the process with physically similar30 but nonradioactive materials 

(e.g., resins colored with dye tracers). Direct measurements are not necessarily 

preferable to indirect methods because direct measurements are likely to require

 

 

30 In this context, “physically similar” refers to characteristics that could affect physical mixing 

(e.g., particle size or liquid content). 
20 

Table 1. Thresholds for Demonstrating Adequate Blending 

Characteristics of Most 

Concentrated Influent 

Waste Stream‡

Volume†

 of Mixture in m3 (ft3) 

Class A 

Mixture 

Class B 

Mixture 

Class C 

Mixture 

Sum of fractions less than 

10 No limit No limit No limit 

Sum of fractions between 

10 and 20 No limit No limit 50 (1800) 

Sum of fractions between 

20 and 30 60 (2100) No limit* 20 (700) 

Sum of fractions between 

30 and 50 20 (700) No limit* 6 (210) 

Sum of fractions between 

50 and 100 6 (210) 40 (1400)* 2 (70) 

† Licensees using larger averaging volumes or more concentrated influent waste streams should 

demonstrate the waste has been adequately blended (see Section 3.2.3). 

‡ Sum of fractions is based on the class of the blended product. 

* In the draft EIS for Part 61, class limits were derived based on a dose calculation. In the final EIS 

for Part 61, adjustments were made differently to the Class A, B, and C limits (see Volume 2, 

Section 4.6). 

closer proximity to the waste than indirect methods. Therefore, making direct 

measurements may not be consistent with “as low as is reasonably achievable” 

(ALARA) principles if indirect methods are available that can quantify relevant 

radionuclide concentrations adequately. 

If multiple waste streams of a single waste type generated31 at a licensee’s facility 

are aggregated for the purposes of operational efficiency, occupational safety, or 

occupational dose reduction, the aggregated waste can be treated as a single 

waste stream for the purposes of this CA BTP (see Section 3.2.2). Table 1 of the 

CA BTP does not apply to this aggregated waste and no demonstration of 

adequate blending is needed. This reasoning does not apply to wastes that are 

blended after they have already been packaged separately for shipping (e.g., from 

a generator to a processor)—a demonstration of adequate blending may be 

necessary for such wastes. 

Licensees combining one or more blendable waste types with each other or with discrete 

waste types (e.g., combining ion-exchange resins with soils, or ion-exchange resins with 

cartridge filters) should document the physical and chemical compatibility of the waste 

types and make the documentation available for inspection. Wastes that could interact to 

cause undesirable chemical reactions (e.g., unacceptable amounts of hydrogen 

 

31 This provision is not intended to apply to waste processors.
21 

generation) should not be combined.32 Additional constraints may be necessary to meet 

the Waste Acceptance Criteria of a specific disposal facility. 

The 1983 Technical Position on Waste Classification indicates that more sophisticated 

waste classification analyses should be used for waste for which minor process variations 

may cause a change in waste classification. For example, if one or more influent waste 

streams in a blending process are much more concentrated than the waste class of the 

blended product, there is an increased chance of misclassifying waste because of 

radiological hot spots. If no practical means exist of demonstrating that waste streams are 

adequately blended, licensees should not exceed the threshold volumes in Table 1. 

3.2.3 Classification of Solidified Waste 

Solidification is the process of incorporating radioactive waste into a binding matrix to 

create a solid, physically and radiologically uniform waste form.33 Examples of solidified 

waste include solidified liquids, solidified ion-exchange resins, and solidified shredded 

cartridge filters. Both NRC guidance (NRC, 1991) and industry standards (American 

National Standards Institute (ANSI)/American Nuclear Society (ANS)-55.1) state that 

solidified waste should be adequately mixed to produce a physically uniform product. The 

NRC staff expects that the degree of mixing required to create a physically uniform 

product will also eliminate radiological hot spots. Therefore, if solidification is performed to 

create a physically uniform waste form in accordance with NRC guidance for solidification 

and industry standards, the average radionuclide concentrations in solidified waste may be 

based on the total volume or mass of the solidified waste form. As discussed in Section 

3.5, nonradioactive materials used in solidification should have a purpose (e.g., 

stabilization of waste), other than lowering the waste class. 

3.3 Discrete Items 

This section provides guidance on the classification of discrete items. For the purposes of 

this CA BTP, discrete items are items belonging to one of the following waste types: 

activated metals, sealed sources, cartridge filters, contaminated materials, and 

components incorporating radioactivity into their design. Items belonging to these waste 

types are designated as discrete items in this guidance because (1) they are expected to 

be durable (i.e., remain intact at the time of intrusion) and (2) items belonging to these 

waste types often have relatively high amounts or concentrations of radioactivity. This 

position applies to classifying a container of items of a single waste type and includes a 

number of criteria to ensure that individual items are unlikely to compromise the safety of 

an inadvertent intruder. 

3.3.1 Concentration Averaging and Classification of Single Discrete Items

Individual discrete items may be classified based on the activity of their 10 CFR 61.55 

radionuclides divided by the volume or weight of the item, as applicable. If an individual 

item is encapsulated, the concentration may be averaged over the volume or weight of the 

 

32 See, e.g., Information Notice 84-72, Clarification of Conditions for Waste Shipments Subject to 

Hydrogen Gas Generation.” (NRC, 1984). 33 Encapsulation is different from solidification in that a discrete item is placed in a non-radioactive 

matrix without creating a uniform concentration of radioactivity. 
22 

final waste form, including the encapsulating material, subject to the constraints in 

Section 3.3.4. 

3.3.2 Concentration Averaging and Classification of Mixtures of Discrete 

Items

This section addresses concentration averaging and classification of discrete items of 

waste within a single waste type. Classification of mixtures of different waste types is 

addressed in Section 3.4. Figure 2 is an overview of the averaging positions presented in 

this section. 

3.3.2.1 Screening Criteria for Simplified Classification 

In classifying a mixture of discrete items of the same waste type, screening criteria may be 

used to simplify classification of the waste (Figure 2). These screening criteria are 

conservative, may provide efficiencies to licensees, and are optional. If these screening 

criteria are not used, the averaging constraints in Section 3.3.2.2 apply. 

• If each item has an activity less than 37 MBq (1 mCi), the radionuclide activities 

may be divided over the volume or mass of the entire mixture. 

• If any item has an activity greater than 37 MBq (1 mCi), the mixture may be 

conservatively classified according to the discrete item with the highest 

classification. For example, if a mixture of items in a waste container includes a 

single item classified as Class C based on 10 CFR 61.55, and the remaining items 

are classified as Class A, the entire waste container may be conservatively 

classified as Class C LLW. 

3.3.2.2 Classification of Mixtures of Discrete Items Within a Single Waste Type

If the screening criteria in Section 3.3.2.1 are not used, the concentration averaging 

constraints in this section should be used for classifying a mixture of items belonging to a 

single waste type. Figure 3 is a flow chart of the averaging positions presented in this 

section. 

As used in this CA BTP, the primary gamma-emitting nuclides are cobalt-60 (60Co), 

niobium-94 (94Nb), and cesium-137 (137Cs). These radionuclides are subject to averaging 

constraints because of the hazard they could present to an intruder handling a discrete 

item of waste.34 As used in this CA BTP, radionuclides other than primary gamma 

emitters are all radionuclides from Tables 1 and 2 of 10 CFR 61.55 other than 60Co, 94Nb, 

or 137Cs. If primary gamma-emitting radionuclides control the waste classification, more 

restrictive averaging constraints apply (see below). If radionuclides other than primary 

gamma-emitting radionuclides control the classification, less restrictive averaging 

constraints apply (see below). 

 

34 The NRC staff does not expect other gamma-emitting radionuclides in the 10 CFR Part 61 waste 

classification tables to cause a hazard to an intruder who handles the waste.
23 
24 
25 

To determine whether the primary gamma emitters control the classification, the licensee 

should evaluate their relative significance as compared to the other radionuclides in the 

waste. The licensee should first determine the sums of fractions for 10 CFR 61.55 

Tables 1 and 2.35 Then the licensee should determine which 10 CFR 61 table would result 

in a higher waste classification. This is the more restrictive table. If Tables 1 and 2 of 

10 CFR 61.55 result in the same waste classification, the table that has the greater sum of 

fractions is the more restrictive table. Finally, the licensee should determine the fractional 

contribution that the primary gamma emitters make to the sum of fractions in the more 

restrictive table. If the primary gamma emitters contribute more than 50 percent of the 

sum of fractions36 in the more restrictive table, the primary gamma emitters are considered 

“classification controlling.” 

For discrete items, the licensee has a choice of applying an activity limit or concentration 

limit.37 For primary gamma-emitting radionuclides, the activity limits are provided in 

Table 2. The appropriate concentration limit depends on whether the primary gammaemitting radionuclides control the waste classification as follows: 

• If the primary gamma-emitting radionuclides are classification-controlling, the 

appropriate concentration limit is the “Factor of 2” concentration limit. The 

Factor of 2 concentration limit specifies that the concentration of each primary 

gamma-emitting nuclide in each item should be less than 2 times the classification 

limit for that nuclide. 

• If the primary gamma-emitting radionuclides are not classification-controlling but 

are radionuclides of concern, the appropriate concentration limit is the 

“Factor of 10” concentration limit. The Factor of 10 specifies that the concentration 

of each radionuclide of concern in each item should be less than 10 times the 

classification limit for that radionuclide. 

Table 2. Recommended Activity Limits of Primary Gamma Emitters Potentially 

Requiring Piecemeal Consideration in Classification Determinations 

Nuclide Waste Classified as 

Class A 

Waste Classified as 

Class B 

Waste Classified as 

Class C 

60Co 5.2 TBq (140 Ci) No limit No limit 

94Nb 37 MBq (1 mCi) 37 MBq (1 mCi) 37 MBq (1 mCi) 

137Cs 266 MBq (7.2 mCi) 27 GBq (0.72 Ci) 4.8 TBq (130 Ci) 

 

35 An explanation and example of determining a sum of fractions is provided in 10 CFR 61.55(a)(7). 36 For example, if the total sum of fractions for 10 CFR 61.55 Table 2 is 0.3, and 60Co and 137Cs 

together contribute 0.2 to the sum of fractions, the primary gammas contribute more than half to the 

Table 2 sum of fractions because 0.2/0.3 = 0.67 (67 percent). 37 In general, the Table 2 limits are less restrictive for small items, and the Factor of 2 concentration limit 

is less restrictive for larger items. Because both limits are protective of an inadvertent intruder, the 

licensee may choose the less restrictive limit. 
26 

Table 3. Recommended Activity Limits of Radionuclides Other Than Primary 

Gamma Emitters Potentially Requiring Piecemeal Consideration in 

Classification Determinations 

Nuclide* For Waste Classified as 

Class A or B 

For Waste Classified as 

Class C 

3

H 0.3 TBq (8 Ci) No limit 

14C 0.04 TBq (1 Ci) 0.4 TBq (10 Ci) 

59Ni 0.15 TBq (4 Ci) 1.5 TBq (40 Ci) 

63Ni 0.26 TBq (7 Ci) 55 TBq (1500 Ci) 

Alpha-emitting transuranic 

(TRU) waste with half-life 

greater than 5 years 

(excluding 241Pu and 242Cm) 

111 MBq (3 mCi) 1.1 GBq (30 mCi) 

* Other nuclides listed in the tables in 10 CFR 61.55 are not expected to be important in 

determining waste classification. 

The Table 2 limits should be applied using a sum of fractions. The Factors of 2 and 10 are 

applied separately to each radionuclide (i.e., a sum of fractions is not applied). For 

comparison to Table 2 values, items larger than 280 cc (0.01 ft3

) may be treated 

individually. However, items smaller than 280 cc (0.01 ft3

) should be grouped together. 

That is, the sum of fractions should be based on the total inventory of each primary 

gamma-emitting radionuclide in the items smaller than 280 cc (0.01 ft3

). The Factors of 2 

and 10 are applied to each item individually, irrespective of size. 

In addition to applying concentration averaging constraints to primary gamma emitting 

radionuclides, licensees should also apply concentration averaging constraints to 

radionuclides of concern that are not primary gamma emitters. The licensee may choose 

to apply either the Table 3 values or the Factor of 10 concentration limit to radionuclides of 

concern other than primary gamma-emitting radionuclides.38 Table 3 is applied separately 

to each radionuclide (i.e., the sum of fractions is not applied). The Factor of 10 and Table 

3 are applied to each item individually, irrespective of size. 

 

For radionuclides of concern that are not represented in Tables 2 or 3, the Factor of 10 

concentration limit should be applied. 

If an item in the mixture cannot meet the constraints described in this section, the item 

should be removed from the average and classified as an individual item39 in accordance 

with Section 3.3.1. The classification of the remaining mixture may be based on the 

volumetrically averaged or weight-averaged concentrations of the mixture. 

 

38 In general, the Table 3 limits are less restrictive for small items and the Factor of 10 concentration 

limit is less restrictive for larger items. Because both limits are protective of an inadvertent intruder, 

the licensee may choose the less restrictive limit. 39 If items smaller than 280 cc (0.01 ft3

) collectively exceed the Table 2 limits, using a sum of fractions, 

and they do not individually meet the Factor of 2 or 10 (as applicable), their concentrations should not 

be averaged to meet the Factor of 2 or 10.
27 

Example 1

If 94Nb is classification-controlling in a Class A mixture of discrete items that are each 

larger than 280 cc (0.01 ft3

), then each individual item could have an 94Nb activity of 

37 MBq (1 mCi) (the Table 2 value) or a concentration up to 1.5 GBq/m3

 (0.04 Ci/m3) (two 

times the Class A limit for 94Nb). If 137Cs or 60Co were also radionuclides of concern in the 

Class A mixture, the licensee could choose to apply either the Table 2 or the Factor of 2 to 

these radionuclides. The Table 2 limits would be applied using a sum of fractions, but the 

Factor of 2 would apply to each primary-gamma emitting radionuclide individually. The 

licensee could choose to apply either the Table 3 or the Factor of 10 to other radionuclides 

of concern in the mixture. 

Example 2

If 94Nb is a nuclide of concern in a Class A mixture of discrete items that are each larger 

than 280 cc (0.01 ft3

) but primary gamma-emitting radionuclides are not 

classification-controlling, then each individual item could have an 94Nb activity of 37 MBq 

(1 mCi) (the Table 2 value) or a concentration up to 7.5 GBq/m3

 (0.2 Ci/m3) (ten times the 

Class A limit for 94Nb). If 137Cs or 60Co were also radionuclides of concern, the licensee 

could choose to apply either the Table 2 or the Factor of 10 to these radionuclides. The 

Table 2 limits would be applied using a sum of fractions but the Factor of 10 would apply 

to each radionuclide individually. The licensee could choose to apply either the Table 3 or 

the Factor of 10 to other radionuclides of concern in the mixture. 

3.3.2.3 Classification of Sectioned Components 

If a component is sectioned for operational considerations (e.g., packaging for 

transportation), the activities of the pieces may be averaged over the volume (or mass, as 

appropriate) of the original larger component, provided that the individual pieces are all 

placed in the same container and the activities of radionuclides are less than the Table 2 

and Table 3 values. For sectioning, meeting the Table 2 criteria means that no piece that 

is smaller than 280 cc (0.01 ft3

) has primary gamma activity that exceeds the values 

shown in Table 2. Meeting the Table 3 criteria means that no individual piece of any size 

has activity that exceeds the values shown in Table 3. As for individual items, the Table 2 

limits are applied using a sum of fractions and the Table 3 limits are applied to each 

radionuclide individually. 

Example 3

An activated metal component is cut into four individual pieces for operational 

considerations and the four individual pieces each meet the Table 2 and Table 3 criteria. 

The four pieces are then combined with other items in a single container. The four pieces 

(from the single larger component) are assessed as a single component in determining 

whether the averaging and classification constraints for discrete items are fulfilled. 

Figure 4 is a flowchart of the positions in this section. 
28 
29 

3.3.3 Alternative Treatment of Certain Cartridge Filters 

Cartridge filters do not necessarily need to be treated as discrete items. Cartridge filters 

that do not contain significant amounts or concentrations of long-lived gamma radioactivity 

may be treated as blendable waste for the purpose of concentration averaging, with 

justification. A justification should be documented and made available for inspection. 

For cartridge filters, the justification should address these factors that potentially affect 

protection of an inadvertent intruder, such as: 

• A history of the activity levels of primary gamma emitters in the filters covered by 

the analysis that is sufficient to demonstrate that their activity is within the Table 2 

values in this CA BTP for the appropriate waste class and that the concentrations of 

non-primary gamma emitters are not greater than Class C. Because the 

recommended activity limits in Table 2 were developed for small items (< 280 cc 

(< 0.01 ft3

)) and are therefore conservative for larger40 items, other activity limits 

may be proposed and justified. 

• The items covered by the analysis (e.g., the design and manufacturer of the filter 

and the reactor system it is employed in). 

• The physical characteristics of the filter design that justify not treating it as a 

discrete waste, such as: 

• the design characteristics of the filter that would enable radioactivity on the filter 

not to remain within the filter during an intrusion event, such as perforations in 

the filter housing; and 

• the filter medium (if, for example, it is non-metallic and expected to degrade 

during disposal and before intrusion occurs). 

Individual cartridge filters that cannot be justified as blendable waste in accordance with 

the above are subject to the averaging constraints for discrete items in this CA BTP (see 

Section 3.3). 

If cartridge filters are treated as blendable waste, the reporting requirements for filters in 

Sections I.C.10 and I.E.2 of Appendix G to 10 CFR Part 20 continue to apply. These 

sections state that for each disposal container of waste in a shipment, the identities and 

activities of individual radionuclides contained on filters within a container must be 

reported. 

 

40 Larger items with the same activity would experience more self-shielding. In addition, intruders are 

 expected to be exposed to larger items at a larger distance, because larger items would not be 

 placed in a pocket. 
30 

3.3.4 Encapsulation of Discrete Items 

Encapsulation is the process of surrounding discrete items of radioactive waste, such as 

sealed sources or cartridge filters,41 in a non-radioactive binding matrix, where the activity 

remains within the dimensions of the original item of waste. Encapsulation differs from 

waste solidification, in which radioactive waste is uniformly mixed into a binding matrix to 

create a physically uniform final waste form. The advantages of encapsulation are that it 

can mitigate waste dispersion to the general environment after disposal, provide additional 

shielding to limit external radiation, and satisfy the stability requirements of 

10 CFR 61.56(b) and the technical requirements for land disposal facilities of 

10 CFR 61.52(a), when applicable. However, the amount of credit allowed for 

encapsulation in the averaging of radionuclide concentrations to determine the 

classification of waste should be limited, so that extreme measures cannot be taken solely 

for the purposes of lowering the waste classification. The positions identified below are 

acceptable for the encapsulation of low-level waste for disposal in a licensed facility. 

• Volume of container/encapsulated mass 

o Containers up to 9.5 m3

 (331 ft3) may be used for encapsulating waste provided 

that the minimum waste loading (volume of waste divided by the total volume, 

including encapsulating material) is at least 14 percent. 

o For waste loadings less than 14 percent (such as a single sealed source), the 

maximum volume or mass used in determining the average radionuclide 

concentrations and waste class should be 0.2 m3

 or 500 kg (approximately 

55 gallons or 1,100 pounds). The volumes and masses may be larger than these 

values to allow for disposal of an item (such as a sealed source) in its shielded 

housing or source device or both, but no more than 0.2 m3

 or 500 kg may be 

used in the calculation of waste class. The shape of the final encapsulated 

package does not have to be a cylinder. 

o The minimum solid volume or mass used to encapsulate waste should be 

sufficient to make handling the radioactive waste by an inadvertent intruder 

prohibitively difficult. The size or weight of the encapsulated waste should be 

large enough to preclude movement without the assistance of mechanical 

equipment. 

o Larger volumes for encapsulation (such as grouting of reactor internals into a 

reactor pressure vessel) may be proposed on a case-by-case basis in 

accordance with Section 3.8.4, “Large Components.” 

• Radioactivity constraints 

The constraints on the amount of radioactivity or concentrations of individual 

encapsulated items are similar to those that apply to mixtures of discrete items 

addressed in Section 3.3.2. As in Section 3.3.2, Table 2 is applied using a sum of 

 

41 Note that cartridge filters can also be treated as blendable waste when this is justified according to 

the provisions in Section 3.3.3. 
31 

fractions. Because it has a different technical basis (see Volume 2, Section 4), Table 

3 is applied to each item individually (i.e., a sum of fractions is not used). The 

Factors of 2 and 10 also are applied to each radionuclide individually. For 

comparison to Table 2 values, items larger than 280 cc (0.01 ft3) may be treated 

individually. However, items smaller than 280 cc (0.01 ft3

) should be grouped 

together. That is, the sum of fractions should be based on the total inventory of each 

primary gamma-emitting radionuclide in the items smaller than 280 cc (0.01 ft3

). The 

Factors of 2 and 10 are applied to each item individually, irrespective of size. 

o For radionuclides other than primary gamma emitters, a licensee may choose 

either Table 3 or the Factor of 10 concentration limit for individual items. 

Demonstrating that either the Table 3 limit or the Factor of 10 concentration limit 

has been met is sufficient. These constraints on non-primary gamma-emitting 

radionuclides are the same irrespective of which radionuclides control the waste 

classification. 

o For the gamma emitters: 

 If primary gamma-emitting radionuclides control the waste classification, 

the licensee may apply either 

• the Factor of 2 concentration limit to each item; or

• the Table 2 activity limits. 

 

 If non-primary gamma emitters control the waste classification, the 

licensee may apply either 

• the Factor of 10 concentration limit to each item; or 

• the Table 2 activity limits. 

 A licensee may pick the less restrictive limits or may base the selection 

on other operational considerations. In choosing between these limits, 

the licensee is not restricted by the size of the item.42

• Multiple items may be encapsulated together, so long as the final encapsulated 

package meets the other criteria described herein. 

• The maximum amount of any radioactive waste that should be encapsulated in a 

single disposal container is that which, when averaged over the waste and the 

encapsulating media, does not exceed the maximum concentration limits for Class C 

waste defined in Tables 1 and 2 of 10 CFR 61.55.43

 

42 The size at which the Factor of 2 becomes less limiting is different for each radionuclide. However, in 

general, the Table 2 limits are less restrictive than the Factor of 2 limits for items smaller than 280 cc 

(0.01 ft3

) as well as for items slightly larger than 280 cc (0.01 ft3). Thus, a licensee may choose to 

apply the Table 2 limits to items larger than 280 cc (0.01 ft3

). 43 For mass-based concentrations (such as for transuranic radionuclides), it is generally acceptable to 

take credit for the actual density of the encapsulating material) if the density is less than 2.5 g/cc 

(156 lbs/ft3

). 
32 

• For encapsulating media that are described in an approved Topical Report, the terms 

and conditions associated with the Topical Report approval apply.44

• In all cases in which one or more items are encapsulated, written procedures should 

be established to ensure that all such waste items are reasonably centered within the 

encapsulating media. 

For encapsulated materials, Class B and C waste must also meet the structural stability 

criteria of 10 CFR 61.56, “Waste Characteristics,” and be segregated from disposal units 

with unstabilized Class A waste, as specified in 10 CFR 61.56(b). Figure 5 is a flowchart 

depicting the decisions to be used for concentration averaging of encapsulated waste. 

 

44 A listing of the approved topical reports for encapsulation processes and materials at the time of 

publication of this revision can be found at ADAMS Accession No. ML14063A124. 
33 

3.4 Classification of Mixtures of Different Waste Types 

Mixtures of different waste types are subject to different averaging constraints from those 

for mixtures within a single waste type. If one or more of the waste types in a mixture are 

blendable (e.g., mixing ion-exchange resins with soils or mixing ion-exchange resins with 

cartridge filters45), the licensee should document the physical and chemical compatibility of 

the waste types and make the documentation available for inspection (see Section 3.2.2). 

For mixtures of discrete items of different waste types, the classification of the entire 

mixture of waste types should be the highest classification of any of the individual waste 

types in the mixture. Individual waste types should be averaged in accordance with the 

provisions in Section 3.3. If discrete items are mixed with blendable wastes, the averaging 

constraints in Section 3.3 should be applied to the discrete items.

3.5 Determining the Volume or Mass of Waste 

Table 4 contains guidance for determining the volume or mass that should be used in 

classifying waste. In general, waste volumes may be calculated from the mass of the 

waste divided by a representative density. The volumes and masses listed are those at 

the time the waste is ready for shipment to a licensed disposal site, consistent with the 

Part 61 requirements for waste classification.46 Other averaging volumes may be 

acceptable as provided in Section 3.8, “Alternative Approaches,” if there is reasonable 

assurance that the performance objectives of 10 CFR Part 61 will be met. See for 

example, Section 3.8.4, “Large Components.” 

For any wastes that include mixing of nonradioactive constituents with the LLW (such as 

for solidification, encapsulation, or additives used in thermal processing), nonradioactive 

materials added to the mixture should have a purpose other than reducing the waste 

class, such as waste stabilization or process control. To be consistent with other 

provisions in this CA BTP, extreme measures to lower the waste classification should be 

avoided. 

 

45 Licensees should document the physical and chemical compatibility of cartridge filters in a mixture of 

different waste types, one of which is blendable, whether the filters are treated as a discrete waste, or 

justified as blendable waste in accordance with Section 3.3.3, “Alternative Treatment of Cartridge 

Filters.” 46 Waste is often processed before classification and shipment to a disposal facility, in some cases 

significantly changing its volume through compaction or incineration. This table does not apply to 

in-process waste volumes. 
34 

Table 4. Volume and Mass for Determination of Concentration 

Waste Allowable Classification Volume or Mass 

Single blendable waste stream If a waste container is more than 90% full of 

waste (by volume), the nominal interior volume 

(“fill volume”) of the container may be used. 

For bulk waste, or for waste containers that are 

less than 90% full, the actual waste volume or 

mass should be used.a

Two or more blendable waste streams 

that have been combined (e.g., placed 

in a single container) but which have 

not been physically mixed together 

Table 1 volumes. 

Blended waste (i.e., two or more 

blendable waste streams that have 

been physically mixed together) 

Table 1 volumes, or larger volumes if adequate 

blending is demonstrated. 

Solidified waste (e.g., solidified liquid, 

solidified ion-exchange resins, or 

solidified shredded cartridge filters) 

Volume or mass of solidified waste form.b

Absorbed liquids Volume or mass of original liquid. 

Cartridge filters treated as discrete 

items 

Envelope volume or mass of filters. The 

envelope volume is the volume obtained using 

the outer dimensions of the filter (interstitial 

volume is included in the envelope volume). 

Activated components, components 

containing radioactivity in their design, 

or contaminated materials 

Displaced volume (major void volumes 

subtracted from envelope volume) or mass of 

components. 

Encapsulated cartridge filters, sealed 

sources, or other wastes 

The encapsulating medium may be included in 

the volume or mass, subject to certain 

constraints (see Section 3.3.4). 

a For ion-exchange resins, the volume and mass of the waste are the dewatered volume and 

mass. For cartridge filters treated as blendable waste, concentrations may be averaged over 

the total mass of the filters or their total envelope volume. 

b

 Averaging over the solidified mass or volume is appropriate if the solidification creates a 

physically uniform waste form, in accord with relevant NRC guidance (NRC, 1991) and industry 

standards (e.g., ANSI, 1992) for solidified waste.

3.6 Quality Assurance Program

In accordance with Appendix G to 10 CFR Part 20, the licensee classifying the waste must 

have a quality assurance program in place to ensure compliance with the waste 

classification provisions of 10 CFR 61.55. As part of this quality assurance program, if the 
35 

classification of a waste is based on the volumetrically averaged or weight-averaged 

nuclide concentration, the licensee responsible for classification of the waste should 

prepare, retain with manifest documentation, and have available for inspection a record 

documenting the licensee’s waste classification analysis. It is generally expected that this 

record or analysis, in and of itself, should be sufficient to show that the classification was 

undertaken in a way consistent with the guidance found in this CA BTP. 

3.7 Alternative Requirements for Waste Classification 

(10 CFR 61.58) 

Under 10 CFR 61.58, “Alternative Requirements for Waste Classification and 

Characteristics,” the Commission may, upon request or on its own initiative, authorize 

other provisions for the classification and characteristics of waste on a specific basis if 

(after evaluation of the specific characteristics of the waste, disposal site, and method of 

disposal) it finds reasonable assurance of compliance with the performance objectives in 

Subpart C, “Performance Objectives,” of 10 CFR Part 61. The waste classification 

requirements for near-surface disposal are contained in 10 CFR 61.55. 

In 10 CFR 61.58, the regulation allows licensees the flexibility to establish alternate 

requirements for waste classification and characteristics when this is justified by 

site-specific conditions and the unique characteristics of the waste. These alternative 

provisions would not affect the generic waste classifications established in 10 CFR 61.55. 

Thus, the radionuclide concentrations in the waste define the class of the waste in 

accordance with the 10 CFR 61.55 waste classification tables. If it could be demonstrated 

that the performance objectives of 10 CFR Part 61 would be met, waste containing 

Class B concentrations of radionuclides could be authorized for disposal in a Class A 

disposal cell using 10 CFR 61.58, for example. The averaging positions in the CA BTP 

were developed for waste classification under 10 CFR 61.55. Different requirements for 

waste classification may be approved under 10 CFR 61.58. The averaging constraints in 

this guidance were not developed for and do not have to be applied to 10 CFR 61.58 

authorizations. 

The NRC’s waste classification system is generic (i.e., it could be applied to any 

near-surface disposal facility) and, as noted above, a site-specific approach for waste 

classification could be approved using 10 CFR 61.58. The averaging provisions of this CA 

BTP are also generic (i.e., suitable for use by any licensed disposal facility or generators 

or processors shipping waste to a licensed disposal facility). Although this generic 

approach may simplify classification, there might be instances in which generators, 

processors, or disposal facility operators may request review of site-specific averaging 

approaches by the disposal facility regulatory authority. This CA BTP provides examples 

of site-specific considerations for averaging, which might be useful to licensees in 

proposing alternative approaches and to regulators that review these proposals, in 

Section 3.8 below. 

3.8 Alternative Approaches for Averaging 

The approaches in Sections 3.2 through 3.5 of this CA BTP may be used to classify LLW 

for shipment to a licensed disposal site. Most of the approaches are generic and apply to 

all LLW disposal sites. Other averaging methods may be used, however, and the 
36 

following guidance discusses considerations for site- and waste-specific methods and 

other approaches to intruder protection that could potentially justify 

concentration-averaging positions different from those in this CA BTP. Licensees also 

could propose other approaches different from those below for the disposal facility 

regulator’s review. 

NRC staff strongly urges licensees to submit proposals for alternative approaches to the 

regulator for the disposal facility and to have in-depth discussions on the merits of the 

proposal before classifying waste using the alternative approach. Alternative approaches 

to averaging are generally complex, often involving selection of intruder scenarios, for 

example. Detailed discussions between staff of the regulatory agency and licensee would 

help to ensure that waste is classified appropriately before shipment and disposal at a 

licensed facility, and that enforcement actions and/or return of waste to the shipper will not 

be necessary. 

Alternative approaches as described in this section or other averaging approaches as may 

be reviewed by the disposal facility’s regulator may be acceptable methods to demonstrate 

compliance with the provisions to determine the concentration of waste under 

10 CFR 61.55(a)(8), depending on site-specific conditions. Use of 10 CFR 61.58 or an 

exemption is not necessary to invoke the provisions of this section. 

3.8.1 Site-Specific Intruder Assessments

Site-specific concentration-averaging approaches that are different from those in 

Sections 3.2 through 3.5 may be proposed by disposal-facility licensees. Information 

provided to the regulatory authority should include, as applicable: 

• An overview of the proposed alternative approach (e.g., depth of burial or other 

factors) and how it will protect an inadvertent intruder. 

• A detailed description of the waste form(s) covered by the alternative averaging 

approach. 

• An identification of the CA BTP’s existing position for which an alternative is requested. 

• For proposals based on inadvertent intruder exposure scenarios different from those in 

the CA BTP,47 a discussion of how they were selected should be provided. The 

following criteria are applicable: 

o The scenario should be reasonably foreseeable in that it is based on the 

intruder performing normal activities consistent with regional social 

customs; current well drilling, excavation and construction practices; and 

land uses similar to land uses in the region currently or reasonably 

foreseeable in the near future (i.e., approximately 100 years or during the 

operational lifetime of a facility). 

 

47 See Volume 2, Section 4 for a discussion of the scenarios used as a basis for the technical 

positions in this CA BTP. 
37 

o The time period for intrusion should be appropriate for the class of the 

waste (e.g., 100, 300, or 500 years) as discussed in 10 CFR 61.7(b). In 

some cases, averaging approaches based on depth of burial, or the use of 

intruder barriers or durable waste forms or containers, may be proposed. 

• A description of site characteristics pertinent to the proposal. 

• An analysis of the effects of degradation on packaging and engineered barriers over 

the period that the waste remains hazardous to an intruder. 

Several NRC guidance documents might be useful in addressing the above 

considerations. NUREG-1854, “NRC Staff Guidance for Activities Related to 

U.S. Department of Energy Waste Determinations” (NRC, 2007), provides guidance for 

site-specific intruder assessments that might be of use to those preparing proposals, 

because it involves waste disposal using the performance objectives in Subpart C of 

10 CFR Part 61. NUREG-1757, Volume 2, “Consolidated NMSS Decommissioning 

Guidance: Characterization, Survey and Determination of Radiological Criteria” 

(NRC, 2006), provides guidance on the evaluation of engineered barriers used in site 

decommissioning; it might be useful if similar barriers are used in land disposal of LLW. 

Finally, the NRC staff’s “Summary of Existing Guidance That May Be Relevant for 

Reviewing Performance Assessments Supporting Disposal of Unique Waste Streams” 

(NRC, 2010a) also addresses site-specific performance assessments. 

If the radiological hazard will persist beyond time frames used for the 10 CFR 61.55 waste 

classification tables (e.g., for disposal of large quantities of depleted uranium), licensees 

should consider intruder activities typical of generic scenarios (e.g., those discussed in 

NUREG-0782 (NRC,1981), NUREG-0945 (NRC,1982), and NUREG/CR-4370 

(NRC,1986b)) that are plausible within the compliance period considering the capabilities 

of intruder barriers and the natural evolution of site characteristics. Use of generic 

scenarios limits excessive speculation about future human activity. 

3.8.2 Encapsulation of Discrete Items, Including Sealed Sources

The position on encapsulation in Section 3.3.4 is considered generally suitable for all LLW 

disposal facilities licensed under 10 CFR Part 61 or the equivalent Agreement State 

regulation. Other provisions may be used on a specific basis for the encapsulation of 

items if—after an evaluation of the specific characteristics of the waste form, the disposal 

site, intrusion scenarios, and the method of disposal—there is reasonable assurance of 

compliance with the inadvertent intruder performance objective in 10 CFR 61.42. 

As long as the proposed alternative provisions for an encapsulated item meet the 

10 CFR 61.55 waste classification requirements, licensees do not need to seek 

authorization under 10 CFR 61.58 or request an exemption. For example, if a proposal is 

made to justify disposal of a 33 TBq (900 Ci) 137Cs sealed source in a shielded cask buried 

12 m (40 ft) deep, in a 0.5-m3 (18-ft3

) encapsulated waste form, a 10 CFR 61.58 

authorization or an exemption is not necessary, because 33 TBq (900 Ci) of 137Cs in 

0.5 m3

 (18 ft3) is within the 10 CFR 61.55 Class C limits of 4,600 Ci/m3 (4.8 TBq/ft3) for 

137Cs. Alternative proposals for encapsulating individual items that would exceed the 

10 CFR 61.55 waste classification limits would require use of 10 CFR 61.58 or an 

exemption. 
38 

The encapsulation guidance in Section 3.3.4 is based on the assumption that, in the 

future, the encapsulating media has fallen away, and a sealed source or other discrete 

item is exposed at the land surface (e.g., by a civil works project). Because the 

encapsulation is assumed to fail, the same assumptions are used for encapsulated items 

as are used for other discrete items (i.e., the small and large item carry-away scenarios). 

The full details are presented in Section 4 of Volume 2 of this CA BTP. 

Proposals to use alternative intrusion scenarios should provide reasonable assurance that 

the scenarios for gamma-emitting items described in Section 4 of Volume 2 are very 

unlikely. Factors that could provide reasonable assurance that the applicable carry-away 

scenario is not credible for a specific disposal configuration (site and waste form) include, 

but are not limited to: 

a) disposal of the item in a robust and long-lived case that cannot be opened 

easily in the field (the entire package would still require encapsulation); or 

 

b) disposal of the encapsulated item at a sufficient depth to make the carry-away 

scenario not credible (e.g., 10 meters), with evidence that the depth of burial 

will be maintained for the period that the hazard exists. 

In preparing a proposal that justifies a different approach, the proposal should contain the 

following types of information: 

• a detailed description of the item(s), including physical and radiological characteristics; 

• a description of how the alternative approach differs from the CA BTP’s position on 

encapsulation in Section 3.3.4; 

• an overview of the proposed alternative provision (e.g., depth of burial), and how the 

alternative provision protects the intruder; 

• a description of site characteristics pertinent to the proposal; 

• a description of any source-containing devices, encapsulating media, and any 

additional packaging proposed for disposal; 

• an analysis of the effects of degradation of packaging and engineered barriers over the 

period that the item remains hazardous to an intruder, as applicable; and 

• an identification of the proposed limits for items to be disposed, based on the 

alternative inadvertent intruder analysis. 

3.8.3 Likelihood of Intrusion

Inadvertent intrusion is only expected if required active controls and passive controls 

(e.g., markers and barriers) and societal memory of the site are lost. This makes 

inadvertent intrusion unlikely, but possible, especially as time passes after closure of the 

disposal facility. However, there is no scientific basis for quantitatively predicting the 
39 

nature or probability of a future human activity (NAS,1995; ICRP,1998, paragraph 62). 

Therefore, an inadvertent intruder assessment typically does not explicitly consider a 

probability or likelihood of less than one of the inadvertent intrusion occurring. Rather, the 

assessment assumes reasonably conservative scenarios that could occur and evaluates 

the radiological consequences that individuals who might actually intrude onto the disposal 

site could experience if active and passive controls and societal memory were lost 

(NCRP, 2005; IAEA, 2008). 

Therefore, an intruder assessment typically is based on the assumption that the intruder 

directly contacts the disposed waste. This assumption sometimes is characterized as an 

assumption that the probability of intrusion is 1. While it is accurate to say that intrusion 

analyses typically result in estimates of consequences (i.e., dose) rather than risk 

(i.e., dose multiplied by probability), it would be inaccurate to say the staff assumes 

intrusion will occur. Because it is not possible to make precise estimates of the probability 

of intrusion, the likelihood of intrusion is acknowledged implicitly in the 5-mSv/yr (500-

mrem/yr) dose limit used for intruder protection. For example, the NRC has previously 

indicated that it is appropriate to use an intruder dose limit of 5 mSv/yr (500 mrem/yr) 

instead of 1 mSv/yr (100 mrem/yr), the public dose limit in 10 CFR Part 20, because 

intrusion is a “hypothetical” event that might not occur (NRC, 1994). This higher limit 

essentially provides for a 20 percent probability of intrusion. Furthermore, the 5-mSv/yr 

(500-mrem/yr) limit is greater by a factor of 20 than the 0.25-mSv/yr (25-mrem/yr) limit 

established in 10 CFR 61.41, “Protection of the General Population from Releases of 

Radioactivity,” for protection of the general population from releases of radioactivity. This 

difference is largely attributable to the difference between the hypothetical nature of 

intrusion and the more likely possibility of exposure to small offsite releases, implying a 

5 percent probability of intrusion. In addition, the inaccessibility of Class C waste to 

intruders was explicitly considered in establishing the Class C limits in 10 CFR 61.55, 

further reducing the implied probability of intrusion into Class C waste. 

In some circumstances, the likelihood of intrusion might be considered in justifying the 

selection of scenarios different from those used in this CA BTP (described in Section 4 of 

Volume 2). As an example, construction of an exploratory water well could be considered 

as possible, and a domestic drinking water well very unlikely, in areas without viable 

sources of groundwater. This is an example of a site-specific approach that could be 

considered in preparing a proposal for concentration-averaging methods different from 

those described in this CA BTP. This provision for alternative approaches in this CA BTP 

cannot be used, however, to justify or approve alternatives to the waste classification 

tables in 10 CFR 61.55. 

Notwithstanding the difficulty in quantitatively predicting future human activities, DOE’s 

Order 435.1, “Radioactive Waste Management,” requires that inadvertent intruder 

assessments be conducted at all DOE-owned disposal facilities in the unlikely case that 

the government loses those institutional controls. DOE allows consideration of the 

likelihood of intrusion scenarios. Its use of this provision has been limited to date, 

according to DOE. Licensees for commercial disposal facilities under long-term DOE 

control and stewardship could develop an alternative averaging approach to submit to a 

regulator based on intrusion scenarios and/or likelihoods different from this CA BTP. 
40 

3.8.4 Large Components

Sections 3.3.4 and 3.5 of this CA BTP on encapsulation and volume for averaging 

respectively specify averaging positions for containers of radioactive waste, such as a 

0.2-m3

 (~55-gallon) drum. Other averaging approaches may be proposed by the applicant 

or licensee to the disposal facility regulator. For example, regulators have approved the 

disposal of a reactor vessel with highly radioactive internal hardware grouted into the 

vessel cavity using averaging approaches unique to the waste types involved. In 1998, 

the State of Washington authorized the Portland Gas and Electric Co. to dispose of the 

Trojan nuclear plant reactor vessel with components grouted into the vessel and averaged 

over the volume of the vessel (Washington Department of Health, 1998). This approval 

and its disposition of technical and safety issues can be used as a model for other similar 

types of disposals. 

3.8.5 Time of Intrusion into Blendable Waste

As described in Section 3.2.3 of Volume 1 and Section 4 of Volume 2, both the threshold 

volumes in Table 1 and the criterion for demonstrating waste is adequately blended are 

based on the potential dose to an individual who inadvertently exhumes waste from a hot 

spot in blendable waste. This analysis was conducted assuming an intruder drills into 

Class A waste at 100 years, Class B waste at 300 years, or Class C waste at 500 years. 

In practice, many Class A and B wastes are disposed of with robust engineered intruder 

barriers. If Class A or B waste is disposed of with a barrier that meets the requirements of 

10 CFR 61.52(a)(2) for Class C waste, it might be appropriate to consider intrusion at 

500 years instead of 100 or 300 years. Depending on the nature of the barrier and the 

drilling technique, barriers that meet the requirements of 10 CFR 61.52(a)(2) could 

preclude drilling scenarios during the lifetime of the engineered barrier and it might be 

appropriate to consider the effects of the barrier on the timing of possible inadvertent 

intrusion. 

This alternative approach is not likely to be useful if the waste classification is controlled by 

long-lived radionuclides because the additional decay time gained with a robust barrier is 

unlikely to affect projected doses. However, licensees are encouraged to consider this 

approach for wastes with short-lived radionuclides of concern disposed of with robust 

barriers to intrusion that could preclude drilling scenarios beyond the end of institutional 

controls. Direct measurements to demonstrate the homogeneity of these wastes are likely 

to be unnecessary as well as counter to efforts to minimize worker dose in accordance 

with ALARA principles if a reasoned argument based on barriers to intrusion would 

demonstrate homogeneity. 

3.8.6 Legacy Wastes

“Legacy wastes” means wastes that were generated by past activities (typically decades 

ago), that may not be well characterized for the purpose of disposal. Additional technical 

studies, characterization, treatment, or resources may be required to ensure that there is 

reasonable assurance that the intruder-protection performance objective and waste 

classification requirements in 10 CFR Part 61 can be met. Opening waste containers, 

removing individual items of waste, and fully characterizing them for the purposes of 

meeting the averaging constraints in this guidance could cause additional hazards to 

workers and might not be justified. In some cases, licensees may document averaging 
41 

approaches that demonstrate that the provisions of this CA BTP have been met. For 

example, expected radionuclide concentrations based on process knowledge could be 

considered. In other cases, to avoid unnecessary waste handling and to minimize worker 

doses, a licensee may propose averaging provisions different from those in this CA BTP, 

such as spot checking of discrete items of legacy wastes. The alternative approach 

should be identified, documented, justified, and discussed with the disposal facility 

regulator. Wastes packaged for disposal whose classification is based on the 1995 CA 

BTP should still be acceptable for disposal.

3.9 Implementation 

This CA BTP describes and makes available (to NRC and Agreement State licensees, 

Agreement States, and the public) methods that the NRC believes are acceptable for 

implementing specific parts of the Commission’s regulations. The positions in this 

document are not intended as a substitute for regulations, and compliance with them is not 

required. Agreement States may use this information in establishing waste acceptance 

criteria for their licensees who are operating waste disposal sites. Subject to the 

limitations in the last paragraph of this section, applicants and licensees may use the 

information in this CA BTP when developing applications for initial licenses, amendments 

to licenses, or requests for NRC regulatory approval. Licensees may use the information 

in this CA BTP for actions (i.e., in determining average radionuclide concentrations in 

waste) that do not require prior NRC review and approval. Licensees may also use the 

information in this CA BTP to assist in attempting to resolve regulatory or inspection 

issues. Agreement States and current licensees may continue to use the previous 

guidance for complying with the concentration averaging provision in 10 CFR 61.55(a)(8), 

i.e., the January 17, 1995, “Final Branch Technical Position on Concentration Averaging 

and Encapsulation.” Current licensees may also voluntarily use positions in this revised 

CA BTP. 

Licensees that ship waste for disposal in a 10 CFR Part 61 or Agreement State equivalent 

facility should ensure that the waste meets the concentration-averaging provisions in the 

land disposal facility license. Where there are conflicts with this guidance, the land 

disposal facility license conditions issued by the regulatory authority (currently, an 

Agreement State in all cases) must be met. 

3.10 Backfit Considerations 

This CA BTP revision describes a voluntary method that the NRC staff considers 

acceptable for complying with the regulation in 10 CFR 61.55(a)(8) regarding averaging of 

radionuclide concentrations for the purpose of determining waste classification. 

Compliance with this CA BTP is not an NRC requirement and licensees and applicants 

may choose this or another method to achieve compliance with this provision in the 

10 CFR Part 61. In particular, current licensees may continue to use the averaging 

positions in the 1995 CA BTP. This CA BTP does not require a backfit analysis as 

described in 10 CFR 50.109(c), because the NRC is not imposing a new or amended 

provision in the NRC’s rules or presenting a regulatory staff position that interprets the 

NRC’s rules in a manner that is either new or different from a previous staff position, and it 

does not require the modification of or addition to the systems, structures, components, or 
42 

design of a facility or the procedures or organizations required to design, construct, or 

operate a facility. 

4. REFERENCES 

ANSI/ANS 55.1-1992, “Solid Radioactive Waste Processing System for Light-WaterCooled Reactor Plants,” 1992 

 

IAEA (2008), “Draft Safety Case and Safety Assessment for Radioactive Waste Disposal,” 

Safety Guide DS 355, Vienna, Austria, 2008. 

International Commission on Radiological Protection (ICRP) (1998), Annuals of the ICRP, 

Publication 81, “Radiation Protection Recommendations as Applied to the Disposal of 

Long-Lived Solid Radioactive Waste,” Volume 28, No. 4, Paragraph 62, 1998. 

National Academy of Sciences (NAS) (1995), “Technical Bases for Yucca Mountain 

Standards,” National Academy Press, Washington, DC, 1995. 

National Council on Radiation Protection and Measurements (NCRP) (2005), 

“Performance Assessment of Near-Surface Facilities for Disposal of Low-Level 

Radioactive Waste,” Recommendations of the National Council of Radiation Protection 

and Measurements, Bethesda, MD, NCRP Report No. 152, December 31, 2005. 

U.S. Nuclear Regulatory Commission (NRC) (1981), “Draft Environmental Impact 

Statement on 10 CFR Part 61, ‘Licensing Requirements for Land Disposal of Radioactive 

Waste,’” NUREG-0782, September 1981, Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML052590348. 

NRC (1982), “Final Environmental Impact Statement on 10 CFR Part 61 ‘Licensing 

Requirements for Land Disposal of Radioactive Waste,’” NUREG-0945, November 1982, 

ADAMS Accession No. ML052590182. 

NRC (1983), “Low-Level Waste Licensing Branch Technical Position on Radioactive 

Waste Classification,” Rev. 0, and “Technical Position on Waste Form,” Rev. 0, ADAMS 

Accession No. ML033630755. Federal Register, Vol. 48, No. 110, May 11, 1983, p. 

26295. (48 FR 26295). 

NRC (1984), “Clarification of Conditions for Waste Shipments Subject to Hydrogen Gas 

Generation,” September 10, 1984, ADAMS Accession No. ML082970390. 

NRC (1986a), Information Notice 86-20, “Low-Level Radioactive Waste Scaling Factors, 

10 CFR Part 61,” March 28, 1986. ADAMS Accession No. ML103420436. 

NRC (1986b), “Update of Part 61 Impacts Analysis Methodology,” NUREG-CR/4370, 

January 1986, ADAMS Accession Nos. ML100251399 and ML100250917.

NRC (1991), “Technical Position on Waste Form, Revision 1,” January 1991, ADAMS 

Accession No. ML033630746. 
43 

NRC (1994), “Denial of Petition for Rulemaking Submitted by the New England Coalition 

on Nuclear Pollution,” Docket No. PRM-61-2, March 29, 1994, ADAMS Accession 

No. ML093490607. 

 

NRC (1995a), “Branch Technical Position on Concentration Averaging and 

Encapsulation,” ADAMS Accession No. ML033630732. Federal Register, Vol. 60, No. 14, 

January 17, 1995, p. 4451. (60 FR 4451) 

NRC (1995b), “Low-Level Waste Shipment Manifest Information and Reporting, Final 

Rule,” Federal Register, Vol. 60, No. 58, March 27, 1995, pp. 15649–15667 

(60 FR 15649). 

NRC (1998b), “Instructions for Completing NRC’s Uniform Low-Level Radioactive Waste 

Manifest,” NUREG/BR-0204, Rev. 2, July 1998, ADAMS Accession No. ML071870172. 

NRC (2006), “Consolidated NMSS Decommissioning Guidance: Characterization, Survey 

and Determination of Radiological Criteria,” NUREG-1757, Vol. 2, Rev. 1, 

September 2006, ADAMS Accession No. ML063000252. 

NRC (2007), “NRC Staff Guidance for Activities Related to U.S. Department of Energy 

Waste Determinations,” NUREG-1854, August 2007, ADAMS Accession 

No. ML072360184. 

NRC (2010a), “Summary of Existing Guidance That May Be Relevant for Reviewing 

Performance Assessments Supporting Disposal of Unique Waste Streams,” 

April 13, 2010, ADAMS Accession No. ML100250501. 

NRC (2010b), “Staff Requirements – SECY-10-0043 – Blending of Low-Level Radioactive 

Waste,” October 13, 2010, ADAMS Accession No. ML102861764. 

Price, Alan (2002), Site Vice President for Dominion Electric Connecticut, letter to 

Document Control Desk, U.S. Nuclear Regulatory Commission, “Millstone Nuclear Power 

Station, Unit No. 1, Response to a Request for Additional Information Regarding Safety 

Analysis of Millstone Unit No. 1 Missing Fuel Rods,” May 15, 2002, ADAMS Accession 

No. ML021500428. 

Washington Department of Health (1998), “Technical Evaluation Report related to the 

report covering the Evaluation of Potential Dose Pathways From Disposal of Portland 

General Electric’s Trojan Reactor Vessel at US Ecology’s Low-Level Radioactive Waste 

Disposal Facility Richland, Washington,” September 1998, ADAMS Accession 

No. ML112170287. 

 
44 

APPENDIX A: GLOSSARY 

Blending Physically mixing two or more blendable waste streams to create a product with 

relatively uniform radionuclide concentrations.

Blendable 

Waste

For the purposes of this CA BTP, a waste type is “blendable” if: (1) the waste 

can be physically mixed to create relatively uniform48 radionuclide 

concentrations or (2) the waste is not expected to contain durable items with 

significant activity.

Concentration 

Averaging

The mathematical averaging of radionuclide concentrations in waste over its 

volume or mass, for the purpose of determining its classification in accordance 

with Tables 1 and 2 in 10 CFR 61.55, “Waste Classification.”

Contaminated 

Materials

Components or metals on which radioactivity resides near the surface in a fixed 

or removable condition. This term does not include other materials, such as 

plastic, wood, or glass.

Discrete Item For the purposes of this CA BTP, discrete items are items belonging to one of 

the following waste types: activated metals, sealed sources, cartridge filters49, 

contaminated materials, and components incorporating radioactivity into their 

design. Items belonging to these waste types are designated as discrete items 

in this guidance because (1) they are expected to be durable (i.e., remain intact 

at the time of intrusion) and (2) items belonging to these waste types often have 

relatively high amounts or concentrations of radioactivity.

Encapsulation The process of surrounding a radioactive sealed source, a collection of such 

sources, or other materials in a binding matrix within a container, where the 

activity remains within the dimensions of the original source(s) or other 

materials.

Hot spot A portion of the overall waste volume whose radionuclide concentrations are 

above the class limit for the entire container. Hot spots can occur in blendable 

waste, single discrete items, or mixtures of discrete items. Because averaging 

is permitted under 10 CFR Part 61, “Licensing Requirements for Land Disposal 

of Radioactive Waste,” some exceedance of the limits is permissible for 

portions of the overall volume of the waste, as long as the average 

concentration of the container is within the class limit.

Primary 

GammaCobalt-60 (60Co), Niobium-94 (94Nb), and Cesium-137 (137Cs).

 

48 Radionuclide concentrations are “relatively uniform” if an intruder who encounters the waste is 

unlikely to encounter waste more concentrated than the class limit by a factor of 10. 49 As described in Section 3.3.3, cartridge filters may be treated as blendable waste in some cases. 
45 

Emitting 

Radionuclides

Radionuclides 

of Concern

Any nuclides in the waste in concentrations greater than either 1 percent of the 

concentration of that nuclide listed in Table 1 in 10 CFR Part 61 or 1 percent of 

the applicable class-dependent concentration of that nuclide in Column 2 or 3 of 

Table 2 in 10 CFR Part 61.

Radionuclides 

other than 

Primary 

GammaEmitting 

Radionuclides

All 10 CFR 61.55 Table 1 and Table 2 radionuclides other than 60Co, 94Nb, or 

137Cs.

Solidification The process of incorporating radioactive material in a binding matrix to create a 

solid, physically and radiologically uniform material.

Stability As defined in 10 CFR Part 61, means structural stability. In the context of the 

concentration averaging, stability is a property of waste or a waste form.

Waste Stream Waste with relatively uniform radiological and physical characteristics. Often, 

the waste results from a single process. 

Waste Type As defined in 10 CFR Part 20, “Standards for Protection against Radiation,” and 

for purposes of this CA BTP, a category of waste within a disposal container 

having a unique physical description (i.e., a specific waste descriptor code or 

description or a waste sorbed on or solidified in a specifically defined media).

For example, ion exchange resins, soils, and activated metals are different 

waste types. 
46 

APPENDIX B: MAJOR CHANGES FROM 1995 TO 2015 CA BTP 

1. Reorganized to improve readability. Added background material in Section 1, 

“Introduction,” and Section 3, “Technical Position;” and added a Glossary of Terms. 

Consolidated and reorganized sections addressing discrete items (i.e., activated 

metals, sealed sources, cartridge filters, contaminated materials, and components 

incorporating radioactivity into their design) into one section, rather than the three 

in the 1995 Concentration-Averaging Branch Technical Position (CA BTP), 

because most averaging positions for each of these waste types are the same. 

2. Changed the definition of “classification-controlling” to match the common-sense 

meaning of the term (i.e., radionuclides are classification-controlling if they are the 

main contributors to the table in 10 CFR 61.55, “Waste Classification,” that results 

in a higher waste classification; see text in Section 3.3.2.2 for specific guidance). 

A new term, “radionuclide(s) of concern,” has been given to the 1995 term 

“classification controlling radionuclides” to better describe their meaning. 

3. Removed the “Factor of 10” rule for mixing blendable wastes to be consistent with 

the U.S. Nuclear Regulatory Commission (NRC) decision in SRM-SECY-10-0043, 

“Blending of Low-Level Radioactive Waste” (NRC, 2010b). Replaced it with a 

demonstration of adequate blending when blendable waste might contain an 

unacceptable hot spot. 

4. Revised the provision for considering operational factors when blending waste in a 

generator’s facility to include non-radiological operational safety. Previously, the 

guidance indicated that the Factor of 10 constraint on blending waste (previously 

referred to as mixing homogeneous waste types) did not apply to a “designed 

collection of homogeneous waste from a number of sources within a licensee’s 

facility, for purposes of operational efficiency or occupational dose reduction.” The 

revised position, specifying a test for whether a homogeneity demonstration is 

needed, does not apply to wastes aggregated in a generator’s facility for the 

purpose of “operational efficiency, occupational safety, or occupational dose 

reduction.” 

5. Defined conditions under which cartridge filters may be treated as a blendable 

waste. 

6. Changed the “Factor of 1.5” rule to a “Factor of 2” rule for primary gamma emitters. 

In addition, both the Factor of 2 and Factor of 10 rules are now linked to the 

classification limit (Class A, B, or C) of the mixture rather than to the average 

concentration, making them more risk-informed. 

7. Consolidated averaging constraints on discrete items, so that radionuclides in a 

discrete item must meet either the Table 2 activity constraint or the Factor of 2 or 

10 concentration limit, as applicable, for primary gamma-emitting radionuclides, 

and either the Table 3 activity constraint or Factor of 10 concentration limit for other 

than primary gamma-emitting radionuclides. 

8. Increased the recommended activity limit for discrete items containing 137Cs (from 

1.1 TBq (30 Ci) to 4.8 TBq (130 Ci)) for Class C items, based on a new intruder 

scenario for Class C items. 

9. Changed the cobalt-60 (60Co) Ci discrete item activity limits for Class A from 26 

TBq (700 Ci) to 5.2 TBq (140 Ci) (140 Ci is the activity resulting from the product of 
47 

the Class A limit times the volume of a 0.02 m3

 (55 gal.) drum), and for Class B 

from 26 TBq (700 Ci) to no limit, based on a new sealed-source scenario. See 

Section 4.3.1, “Small Item Carry-Away Scenario (Basis for Table 2)” in Volume 2 

for details. 

10. Clarified use of 10 CFR 61.58, “Alternative Requirements for Waste Classification 

and Characteristics,” as applicable to alternatives to certain regulatory 

requirements as defined in 10 CFR 61.58, and not applicable to alternatives to 

guidance in the CA BTP. 

11. Added guidance which states that, for encapsulated waste, container volumes up 

to 9.5 m3

 (331 ft3) may be used for averaging (previously was 0.2 m3 (55 gallons)), 

if the waste loading is at least 14 percent and the Factors of 2 and 10 constraints 

are met. 

12. Added Alternative Approaches for Averaging section to CA BTP that provides 

guidance on using averaging approaches different from those specified in the 

document.

13. Altered and clarified the Technical Basis for Concentration Averaging and 

Encapsulation Guidance (Section 4 of Volume 2) to support the homogeneity 

demonstration for blendable wastes, the Factor of 2 and Factor of 10 constraints 

on mixtures of discrete items, and the radioactivity constraints on these same 

items.

14. Added the Safety Culture Policy Statement in Appendix C to Volume 1 and added 

background on the Policy Statement to the body of the CA BTP.

15. Added section “Backfit Considerations” that states that either the 1995 CA BTP or 

this revised version can be used by licensees.

16. Added Implementation section that addresses the use of this guidance, including 

the relationship between this revised CA BTP, the 1995 version, and disposal 

facility license conditions regarding concentration averaging.

 
48 

APPENDIX C: SAFETY CULTURE STATEMENT OF POLICY 

The safety culture policy statement was published in the Federal Register (76 FR 34773) 

on June 14, 2011 and can be found at http://www.gpo.gov/fdsys/pkg/FR-2011-06-

14/pdf/2011-14656.pdf. It is also posted in the U.S. Nuclear Regulatory Commission’s 

(NRC’s) Agencywide Documents Access and Management System (ADAMS) Accession 

Number ML11146A047. 

Safety Culture Policy Statement 

The purpose of this Statement of Policy is to set forth the Commission’s expectation that 

individuals and organizations establish and maintain a positive safety culture 

commensurate with the safety and security significance of their activities and the nature 

and complexity of their organizations and functions. This includes all licensees, certificate 

holders, permit holders, authorization holders, holders of quality assurance program 

approvals, vendors and suppliers of safety-related components, and applicants for a 

license, certificate, permit, authorization, or quality assurance program approval, subject to 

NRC authority. The Commission encourages the Agreement States, Agreement State 

licensees, and other organizations interested in nuclear safety to support the development 

and maintenance of a positive safety culture as articulated in this Statement of Policy. 

Nuclear Safety Culture is defined as the core values and behaviors resulting from a 

collective commitment by leaders and individuals to emphasize safety over competing 

goals to ensure protection of people and the environment. Individuals and organizations 

performing regulated activities bear the primary responsibility for safety and security. The 

performance of individuals and organizations can be monitored and trended and, 

therefore, may be used to determine compliance with requirements and commitments and 

may serve as an indicator of possible problem areas in an organization’s safety culture. 

The NRC will not monitor or trend values. These will be the organization’s responsibility 

as part of its safety culture program. Organizations should ensure that personnel in the 

safety and security sectors have an appreciation for the importance of each, emphasizing 

the need for integration and balance to achieve both safety and security in their activities. 

Safety and security activities are closely intertwined. While many safety and security 

activities complement each other, there may be instances in which safety and security 

interests create competing goals. It is important that consideration of these activities be 

integrated so as not to diminish or adversely affect either; thus, mechanisms should be 

established to identify and resolve these differences. A safety culture that accomplishes 

this would include all nuclear safety and security issues associated with NRC-regulated 

activities. 

Experience has shown that certain personal and organizational traits are present in a 

positive safety culture. A trait, in this case, is a pattern of thinking, feeling, and behaving 

that emphasizes safety, particularly in goal conflict situations, e.g., production, schedule, 

and the cost of the effort versus safety. It should be noted that although the term 

“security’’ is not expressly included in the following traits, safety and security are the 

primary pillars of the NRC’s regulatory mission. Consequently, consideration of both 

safety and security issues, commensurate with their significance, is an underlying principle 

of this Statement of Policy. 
49 

The following are traits of a positive safety culture: 

1. Leadership Safety Values and Actions—Leaders demonstrate a commitment to 

safety in their decisions and behaviors; 

2. Problem Identification and Resolution—Issues potentially impacting safety are 

promptly identified, fully evaluated, and promptly addressed and corrected 

commensurate with their significance; 

3. Personal Accountability—All individuals take personal responsibility for safety; 

4. Work Processes—The process of planning and controlling work activities is 

implemented so that safety is maintained; 

5. Continuous Learning—Opportunities to learn about ways to ensure safety are 

sought out and implemented; 

6. Environment for Raising Concerns—A safety-conscious work environment is 

maintained where personnel feel free to raise safety concerns without fear of 

retaliation, intimidation, harassment, or discrimination; 

7. Effective Safety Communication—Communications maintain a focus on safety; 

8. Respectful Work Environment—Trust and respect permeate the organization; and 

9. Questioning Attitude—Individuals avoid complacency and continuously challenge 

existing conditions and activities in order to identify discrepancies that might result 

in error or inappropriate action. 

There may be traits not included in this Statement of Policy that are also important in a 

positive safety culture. It should be noted that these traits were not developed to be used 

for inspection purposes. It is the Commission’s expectation that all individuals and 

organizations performing or overseeing regulated activities involving nuclear materials 

should take the necessary steps to promote a positive safety culture by fostering these 

traits as they apply to their organizational environments. The Commission recognizes the 

diversity of these organizations and acknowledges that some organizations have already 

spent significant time and resources in the development of a positive safety culture. The 

Commission will take this into consideration as the regulated community addresses the 

Statement of Policy.