1

Training for the Concentration 

Averaging and Encapsulation Branch 

Technical Position, Revision 1

Division of Decommissioning, Uranium Recovery 

and Waste Programs 

U.S. Nuclear Regulatory Commission

March 2016
Topics

Part I 

• Purpose, scope, and use of guidance

• Background on Part 61 and need for concentration 

averaging guidance

• History of development 

• Highlights of major changes

Part II 

• Detailed description of 2015 positions, examples and 

discussion

• Wrap up

2
• Explain origin of concentration averaging 

guidance and its evolution

• Discuss major changes from 1995 to 2015

• Provide inspectors with sufficient 

understanding to assess whether guidance 

has been appropriately implemented by 

licensees

• Facilitate common understanding among NRC 

and Agreement State regulators

3

Objectives of Training
Purpose of CA BTP

• Under Part 61, NRC regulations require that individuals 

inadvertently intruding into a closed and unrecognized LLW 

landfill be protected

• Part 61 was developed assuming all LLW is soil-like and 

radiologically homogenous

• CA BTP supplements Part 61, by providing guidance to help 

ensure protection of an inadvertent intruder from durable hot 

spots (e.g., sealed sources) 

• CA BTP guidance has no effect on vast majority of LLW, which is 

not expected to contain durable hot spots (e.g., contaminated 

trash) 

4
Scope of the CA BTP 

• Covers only averaging of radionuclide concentrations in waste 

for the purpose of classifying it as A, B, or C, in accordance with 

10 CFR Part 61

• Provides averaging positions, but does not prescribe inspection 

considerations 

• Meeting the averaging positions in BTP does not affect the 

applicability of other LLW guidance

• Other NRC guidance documents cover related topics: 

– Radiological characterization

– Waste form stability

– Attribution of waste

– Transportation

5
Examples of Other NRC LLW Guidance

• 1983 BTP on waste classification

• “Technical Position on Waste Form, Revision 1,” 1991, ADAMS 

Accession No. ML033630746 

• NUREG/BR-0204 instructions for completing uniform waste 

manifest

• RIS 2015-02 guidance on reporting activity of “Phantom 4” on 

uniform waste manifest 

• Information Notice 84-72, “Clarification of Conditions for Waste 

Shipments Subject to Hydrogen Gas Generation,” September 10, 

1984, ADAMS Accession No. ML082970390

6
Use of CA BTP

• Generators and processors shipping LLW for disposal at licensed 

sites must certify on the uniform waste manifest that waste has 

been properly classified as A, B, or C as defined in 10 CFR Part 61

• Three of four licensed disposal facility licenses reference the CA 

BTP in its entirety. Barnwell license/WAC refers to it in part

• Thousands of shipments each year to disposal facilities

• Licensee staff and NRC and Agreement State staff use the CA BTP

• However, NRC regulations to not require generators shipping 

LLW to processors to classify waste as Class A, B or C 

7
8

Backfit Considerations

• Revised CA BTP Position:

• Either the 1995 or 2015 version may be used by 

licensees – as both versions are protective; and

• If both versions are used, licensees can “mix and 

match”

• Agreement States may use a different approach

• Licensees should document the basis for their 

averaging positions
Inspection Considerations

• CA BTP expected to affect reactor licensees more than 

materials licensees

• Generators and processors should have documentation 

that justifies averaging positions used. NRC regulations do 

not require that the documentation travels with the 

manifest

• BTP averaging positions are linked to waste types

– Uniform manifest will specify waste types in each container

– Discrete item waste types require greatest attention

• Disposal facility licensees may conduct independent 

surveys of activity and concentrations of radionuclides 

and point of origin inspections/audits

9
Future NRC HQ Assistance

• NRC Management Directive 5.7, “Technical Assistance to 

Agreement States”:

– Provides guidance to NRC and Agreement State management on 

the submission and review of requests for NRC technical assistance

– Establishes guidance in determining when and if NRC should 

provide routine, special, or programmatic technical assistance to 

Agreement States

– Establishes a process for determining the extent and conduct of this 

assistance

• NRC Regional staff can follow existing procedures and 

practices for requesting HQ assistance

• Staff will document any necessary clarifications of revised 

guidance in Regulatory Information Summaries or NRC CA BTP 

web page

10
Topics

Part I 

• Purpose, scope, and use of guidance

• Background on Part 61 and need for concentration 

averaging guidance

• History of development 

• Highlights of major changes

Part II 

• Detailed description of 2015 positions, examples and 

discussion

• Wrap up

11
12

10 CFR 61 Subpart C 

Performance Objectives 

• Protection of the general population from 

releases of radioactivity 

• Protection of individuals from inadvertent 

intrusion

• Protection of individuals during operations

• Stability of the disposal site after closure 
Protection of individuals

from inadvertent intrusion

“Design, operation, and closure of the land 

disposal facility must ensure protection of any 

individual inadvertently intruding into the 

disposal site and occupying the site or 

contacting the waste at any time after active 

institutional controls over the disposal site are 

removed.” § 61.42 

13
10 CFR Part 61 employs multiple measures to 

address inadvertent intruder protection

14

10 CFR 61.42

Protect 

Inadvertent 

Intruder

Limit Likelihood 

of Intrusion

Require Active 

Controls (fences, 

surveillance, e.g.) 

Require Passive 

Controls 

(monuments, e.g.)

Require 

Government 

Ownership of 

Site

Classify waste 

according to its 

hazard

Limit Dose Should 

Intrusion Occur

Postulate 

conservative 

exposure scenarios

Identify key 

radionuclides

Limit average 

concentrations

(61.55)

Require Stable 

Waste Form 

(Class B/C)

Bury Waste Deeper 

or with 500 year 

Barrier (Class C)

Address hot 

spots (constrain 

averaging)
15

Section 61.55 – Waste Classification 

Table 2

Radionuclide Concentration, curies per cubic meter 

Col. 1 [Class A] Col. 2 [Class B] Col. 3 [Class C]

Total of all nuclides with less than 5 year half-life 700 ( 1 ) ( 1 )

H-3 40 ( 1 ) ( 1 )

Co-60 700 ( 1 ) ( 1 )

Ni-63 3.5 70 700

Ni-63 in activated metal 35 700 7000

Sr-90 0.04 150 7000

Cs-137 1 44 4600

1 There are no limits established for these radionuclides in Class B or C wastes. Practical considerations such as the 

effects of external radiation and internal heat generation on transportation, handling, and disposal will limit the 

concentrations for these wastes. These wastes shall be Class B unless the concentrations of other nuclides in Table 2 

determine the waste to the Class C independent of these nuclides. 
16

10 CFR 61.55(a)(8)

“The concentration of a radionuclide [for the purpose 

of classifying waste] may be averaged over the volume 

of the waste, or weight of the waste if the units are 

expressed in nanocuries per gram.” 
Hot Spot

A portion of the overall waste volume whose 

radionuclide concentrations are above the class 

limit for the entire container. 

17
Why Guidance is Needed

• Provide guidance not included in Part 61 and 

supporting documents

• Reduce need for case-by-case determinations. 

Radioactivity concentrations in waste are not 

always uniform (e.g., control rod blade) 

• Constrain averaging to address potentially 

unsafe practices (e.g., activated metal averaged 

over contaminated trash)

18
19

 Assume

 Classification dominated by 0.65 Ci Ni-63

 Filter medium volume of 0.092 m3

 “Envelope” volume of 0.14 m3

 Average over filter medium only  Class C

 Average according to 1995 BTP  Class B

 Average according to 2015 BTP  Default position is Class B. Could 

be Class A if averaged over lower-activity waste, with documented 

justification that addresses BTP criteria

 Three interpretations of rule  three different classifications 

 Guidance needed to interpret the rule

Why Guidance is Needed–

NPP Cartridge Filter

Cartridge Filter
20

Part 61

waste is assumed to be 

homogeneous

Revised BTP

hot spots are considered 

Why Guidance is Needed –

Blendable Waste
21

Disposal of the Trojan NPP Reactor Vessel

noGTCC 

CONCENTRATIONS
Topics

Part I 

• Purpose, scope, and use of guidance

• Background on Part 61 and need for concentration 

averaging guidance

• History of development 

• Highlights of major changes

Part II 

• Detailed description of 2015 positions, examples and 

discussion

• Wrap up

22
23

1995 CA BTP

 1995 BTP supersedes section C3 of 1983 Guidance

 Detailed guidance for averaging different types of 

waste –21 pages long vs. 1 page in 1983 CA BTP

 Purpose was to achieve consistency among 

regulators

 Agreement States have mostly adopted the 1995 CA 

BTP. Widely used by generators and processors in 

U.S. 
Drivers for Revision to 

1995 Guidance 

• Make positions more risk-informed, performance based

• Make basis for positions easier to understand

• Reduce worker exposures by eliminating unnecessary 

waste surveying and sampling

• Update guidance to be consistent with Commission 

decision on blending of LLW in 2010

• Re-evaluate constraints on sealed source disposal 

– Commission Policy Statement:

• “. . . waste disposal is still considered the safest and most 

secure long-term LLRW management approach.”

• “. . . Commission continues to favor disposal of LLW over 

storage. . .”

24
Topics

Part I 

• Purpose, scope, and use of guidance

• Background on Part 61 and need for concentration 

averaging guidance

• History of development 

• Highlights of major changes

Part II 

• Detailed description of 2015 positions, examples and 

discussion

• Wrap up

25
Highlights of Major Changes

• Added guidance for alternative approaches

• Added criterion for adequate blending with threshold 

volumes below which no demonstration of blending is 

recommended 

• Revised Factors of 1.5 (now 2) and 10 including option to 

use either Factors or activity limits in CA BTP Tables 2 and 3

• Added provision for treating cartridge filters as blendable 

waste

• Revised sealed source limits

• Expanded provisions for encapsulation

26

A summary of major changes is provided in Vol. 1 Appendix B
27

Alternative Approaches

• Like 1995 BTP, the 2015 revision identifies uniform “look 

up” guidance that is applicable to all disposal sites and 

waste types

• New Alternative Approaches provides Licensees / 

Agreement States with specific NRC guidance on factors 

to consider in submitting/reviewing alternative approaches

• Allows for site- and waste-specific considerations

• CA BTP strongly urges licensees to submit proposals for 

alternative approaches to the disposal facility regulator
Blendable Waste vs. 

Discrete Items

• Blendable Waste 

– Majority of LLW (by volume) is blendable and 

concentrations can be averaged without constraint *

– Examples: soils, ash, ion exchange resins, 

contaminated trash

• Discrete Items

– Subject to more complex averaging constraints

– Durable and often have high activities or 

concentrations

– Examples: sealed sources, activated metals

* “average without constraint” means using a sum of fractions 

of the total inventory in the package divided the by total 

volume or mass, as appropriate

28
Blendable Waste vs. 

Discrete Items (cont’d)

• Blendable waste & discrete items are defined by waste 

type (not by test) to reduce the need to survey items 

and to minimize worker dose

• In general, discrete items may present more of an 

intruder hazard because radioactivity is more likely to 

remain concentrated. Therefore, discrete items have 

more averaging constraints than blendable waste.

29
Revised Blending Guidance

• In the 2015 BTP, single blendable waste streams can still 

be averaged without constraint (similar to 1995 position)

• Generators may combine multiple blendable waste 

streams of the same waste type for the purposes of 

operational efficiency, occupational safety, or 

occupational dose reduction and average without 

constraint (similar to 1995 position)

• For other types of blending, the revised BTP addresses 

the outputs of the blending process

– Threshold averaging volumes below which no 

demonstration of blending is recommended 

– Criterion for demonstrating waste is adequately 

blended

30
What are Discrete Items?

• Discrete Items are items of one of these waste 

types: 

– activated metals

– sealed sources

– contaminated materials

– components incorporating radioactivity into design, and

– cartridge filters (Cartridge filters may be treated as 

blendable waste in some cases, see Section 3.3.3)

• Items of these waste types are considered discrete 

because they typically have these two characteristics:

– Items are durable (expected to be intact at time of 

intrusion), and

– Items have high amounts or concentrations of 

radioactivity

31
Big Picture – Averaging a Mixture 

of Discrete Items

• For classifying a mixture of discrete items in single 

container

• Criteria designed to identify hot spots

• If all criteria for identifying hot spots are met, average 

without constraint

• If an item does not meet the criteria for a mixture of 

discrete items, remove the item and average the 

remaining mixture of discrete items 

• Either activity limits (CA BTP Tables 2 and 3) or 

concentration limits (Factors of 2 and 10) may be used, 

as explained later in this presentation

32
33

“Radionuclides of Concern”

• New term for what had been called “classificationcontrolling” radionuclides in 1995 CA BTP

• The term “classification-controlling” has a more 

common-sense definition in the 2015 CA BTP

• Radionuclides of Concern are defined as: Any nuclide(s) 

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
34

Concentration Limits

(Factors of 2 and 10)

• Factor of 2 – the concentration of each 

primary gamma-emitting nuclide* in each 

item should be less than 2 times the 

classification limit for that nuclide

• Factor of 10 – the concentration of each 

radionuclide of concern in each item 

should be less than 10 times the 

classification limit for that radionuclide

* Factor of 10 applies to primary gamma-emitting nuclides when they do 

not control the waste classification
35

More Risk-Informed Averaging Constraint

for Discrete Items

Example: average concentration in each package is the 

same and meets the Class B limit

A

B

C C

B

A

Factor of 1.5 Factor of 2

Primary gammas in each item 

should be within a factor of 1.5 

of the average of the mixture

Primary gammas in each 

item should be within a 

factor of 2 of the class limit 

1995 Guidance Revised Guidance
36

Sealed Sources
37

Cs-137 Limit, Class C, Ci

0

50

100

150

200

1995 BTP Revised

BTP

0

10

20

30

40

1995 BTP Revised

BTP

C-14 Activity Limits, Class C, Ci

0

2

4

6

8

10

12

1995 BTP Revised BTP

0

200

400

600

800

1995 BTP Revised

BTP

Am-241, Cm-244, Pu-238, Pu239 Limits, Class C, mCi

H-3 Activity Limits, Class A 

and B (no limit for Class C) 

(Ci)

0

2

4

6

8

10

1995 BTP Revised BTP

Co-60 Activity Limit, Class 

A, Ci

0

200

400

600

800

1995 BTP Revised

BTP

Co-60 Activity Limit, 

Class B, Ci

Revised Sealed Source Limits Are 

Higher, Lower and the Same as the 1995 CA BTP
38

Class C Cs-137 Sealed Source Activity Increased

0

20

40

60

80

100

120

140

Activity (Ci)

30 Ci

130 Ci

1995 BTP

Source

2015 BTP

Source
39

1995 BTP vs Revised CA BTP Exposure

Scenario for Cs-137 Sealed Source 

* 450 mem exposure from other waste

Cap

Revised BTP

500 mrem from sealed source

No encapsulation

4 hours in pocket

720 hours at 2 m

Cap

1995 BTP

50* mrem from sealed source 

Encapsulation intact

2360 hours 

Contact dose
Overview of Encapsulation of 

Discrete Items

• Encapsulation is 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

• When CA BTP conditions are met, credit can be taken for volume or 

mass of the binding matrix

– 1995 CA BTP provision preserved – any size item can be averaged over the 

volume of a 55 gallon drum (0.2 m3). Activity limits for items changed in 

some cases

– 2015 CA BTP allows for volumes up to 9.5 m3 (331 ft3) with 14% minimum 

waste loading

• Application of concentration and activity limits are the same as for 

mixtures of discrete items

40
Next Steps

• Continue training with Agreement States 

and Regional inspectors

• Continue dialogue with and respond to 

questions from inspection staff

• Continue stakeholder outreach 

(licensees, EPRI, etc.) 

• Provide formal clarifications as 

necessary

41
Summary—Part I

42

• 2015 CA BTP is an extensive revision of 1995 version 

to make it more risk-informed, performance-based, 

and transparent

• Part II presents the details of the 2015 version

• NRC staff committed to helping to ensure smooth 

transition to revised CA BTP
43

Part II
Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

44

Part II Detailed description of 2015 positions 
Waste Type

• A Waste Type has relatively uniform physical 

characteristics – but not necessarily the same 

radiological characteristics

• As defined in 10 CFR Part 20, “Standards for Protection 

against Radiation,” a waste type is waste having a 

unique physical description (i.e., a specific waste 

descriptor code). For example:

– Spent ion exchange resins and contaminated soils are different 

waste types 

– Primary and secondary spent ion exchange resins are the same 

waste type 

45
Waste Stream

• A Waste Stream has relatively uniform physical and

radiological characteristics 

• Often, a waste stream results from a single 

process. For example:

– Primary spent ion exchange resins from a single 

NPP are a single waste stream

– Secondary spent ion exchange resins from the same 

NPP are a separate waste stream

– Primary spent ion exchange resins from a different 

NPP are a separate waste stream

46
47

The relationship between

Waste Types, Waste Streams, 

Blendable Wastes, and Discrete Item 

Wastes
Waste Types and 

Blendable Wastes 

Waste Types

Soil

Ash

Trash

Resins

Cartridge Filters

48

Blendable Waste 

Discrete Items

Examples of Waste Types 

that are Blendable Waste
Waste Types and 

Discrete Items

Waste Types

Cartridge Filters

Sealed sources

Activated metals

Contaminated materials

Components incorporating 

radioactivity in design

49

Blendable Waste 

Discrete Items

Entire list of Waste Types 

that are Discrete Items
Waste Types & Streams

Waste Types

Soil

Ash

Trash

Resins

Cartridge Filters

Sealed sources

Activated metals

Contaminated materials

Components incorporating 

radioactivity in design

Waste Streams

(resin waste stream examples)

Primary resins from single NPP

Cleanup resins from single NPP

Secondary resins from single NPP

CA BTP does not divide these 

waste types into waste streams

50

Blendable Waste 

Discrete Items
51

Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

Part II Detailed description of 2015 positions 
52

Overview of BTP Guidance
53

Overview of BTP Guidance

Blendable Waste

Discrete Items
Guidance for Blendable Waste

3.2 Blendable Waste

3.2.1 Concentration Averaging for a Single Blendable Waste Stream

3.2.2 Concentration Averaging for Multiple Blendable Waste Streams

3.2.3 Classification of Solidified Waste

54
“Homogeneous Waste” vs. 

“Blendable Waste”

• Blendable Waste (2015 BTP) is similar to

homogeneous waste in the 1995 BTP 

• In the 1995 BTP 

– homogeneous waste types were assumed to be 

radiologically homogenous

– Inputs to blending were limited to within a Factor of 

10 of the product

• In SRM-SECY-10-0043, the Commission 

directed the staff to revise this position to be 

more risk-informed and performance-based

55
Blendable Waste

• Revised BTP provides guidance for blending outputs

– Criterion to demonstrate adequate blending

– Table 1 volume thresholds below which no demonstration is 

recommended

• Blendable Waste has one of two characteristics:

a. Can be physically mixed to create relatively uniform 

radionuclide concentrations (e.g., soils, ash, resins) 

or

b. Is not expected to contain durable items with significant 

activity (e.g., contaminated trash)

• Most LLW (by volume) is blendable

56
57

Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

Part II Detailed description of 2015 positions 
Single Blendable Waste Streams

Average without constraint – i.e., average based on the 

sum of fractions using the total inventory divided by 

total volume (or mass, as appropriate)

58
59

Topics

• Waste Streams and Waste Types

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

59

Part II Detailed description of 2015 positions 
Mixing Multiple Blendable 

Waste Streams

• Generator Facilities may mix multiple blendable 

waste streams of the same waste type for the 

purposes of operational efficiency, occupational 

safety, or occupational dose reduction (similar to 

1995 position) and average without constraint

• In other cases, Generator Facilities mixing multiple 

blendable waste streams of the same type should 

ensure either:

– Table 1 volume and concentration thresholds are met; or

– The blended product meets the criterion for adequate blending

60
• Waste Processors mixing multiple blendable waste 

streams of the same type should ensure either:

– Table 1 volume and concentration thresholds are met; or

– The blended product meets the criterion for adequate blending

• Blending criterion: the sum of fractions of any volume of 

the blended waste larger than 0.2 m3 (7 cubic ft3) should 

not exceed 10

• Criterion may be applied to a process or to individual 

containers. CA BTP emphasizes use of process 

knowledge instead of direct measurements to limit worker 

dose.

61

Mixing Multiple Blendable 

Waste Streams (cont’d)
62

Table 1 from BTP

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 & 20 No limit No limit 50 (1800)

Sum of fractions between 20 & 30 60 (2100) No limit 20 (700)

Sum of fractions between 30 & 50 20 (700) No limit 6 (210)

Sum of fractions between 50 & 100 6 (210) 40 (1400) 2 (70)

Table 1. Thresholds for Demonstrating Adequate Blending

‡ Sum of fractions is based on the class of the blended product
63

Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

63

Part II Detailed description of 2015 positions 
Solidified & Absorbed 

Wastes

• Solidified waste should be adequately mixed to produce a physically 

uniform product in accordance with existing NRC guidance and 

industrial standards 

– For example: NRC’s “Technical Position on Waste Form, Revision 1,” 1991, 

ADAMS ML033630746 and American Nuclear Society (ANS) 55.1

• Nonradioactive materials used in solidification should have a 

purpose other than lowering the waste classification

• For solidified waste – classification based on average radionuclide 

concentrations in final solidified volume or mass as appropriate

• For absorbed liquids - Average radionuclide concentrations in 

solidified waste shall be based on the volume or mass of original 

liquid 

64
65

For determining the waste classification for disposal, the BTP divides 

wastes into two broad categories, discrete items and blendable wastes. 

Which of these broad categories is not expected to contain durable hot 

spots?

i. Discrete items

ii. Blendable waste

Can waste from a single blendable waste stream be concentration 

averaged (i.e., based on the sum of fractions using the total inventory,

divided by total volume) without consideration of hot spots and special 

averaging constraints?

i. Yes

ii. No

Sample Problems
66

For determining the waste classification for disposal, the BTP divides 

wastes into two broad categories, discrete items and blendable wastes. 

Which of these broad categories is not expected to contain durable hot 

spots?

i. Discrete items

ii. Blendable waste

Can waste from a single blendable waste stream be concentration 

averaged (i.e., based on the sum of fractions using the total inventory,

divided by total volume) without consideration of hot spots and special 

averaging constraints?

i. Yes

ii. No

Sample Problems
67

Is contaminated trash a blendable waste? 

i. Yes

ii. No

Are pieces of activated metal a blendable waste? 

i. Yes

ii. No

Are spent ion exchange resins a blendable waste? 

i. Yes

ii. No

Sample Problems
Is contaminated trash a blendable waste? 

i. Yes

ii. No

Are pieces of activated metal a blendable waste? 

i. Yes

ii. No

Are spent ion exchange resins a blendable waste? 

i. Yes

ii. No

68

Sample Problems
69

A waste processor has combined primary and secondary spent 

ion exchange resins (two blendable wastes) in a single container 

with a volume of 7 m3 (247 ft3). Based on the sum of fractions 

using the total inventory divided by total volume, the container 

will be classified as Class A. The sum of fractions for the most 

concentrated influent resin is 60 times the Class A limit. Will the 

waste processor need to demonstrate adequate blending of the 

primary and secondary spent ion exchange resins? 

i. Yes

ii. No 

Sample Problems
70

A waste processor has combined primary and secondary spent 

ion exchange resins (two blendable wastes) in a single container 

with a volume of 7 m3 (247 ft3). Based on the sum of fractions 

using the total inventory divided by total volume, the container 

will be classified as Class A. The sum of fractions for the most 

concentrated influent resin is 60 times the Class A limit. Will the 

waste processor need to demonstrate adequate blending of the 

primary and secondary spent ion exchange resins? 

i. Yes

ii. No 

Sample Problems
71

Table 1 from BTP

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 & 20 No limit No limit 50 (1800)

Sum of fractions between 20 & 30 60 (2100) No limit* 20 (700)

Sum of fractions between 30 & 50 20 (700) No limit* 6 (210)

Sum of fractions between 50 & 100 6 (210) 40 (1400)* 2 (70)

Table 1. Thresholds for Demonstrating Adequate Blending
72

The operator of a nuclear power plant, for operational 

efficiency, has combined primary and secondary spent ion 

exchange resins (two blendable wastes) in a single container 

with a volume of 7 m3 (247 ft3). Based on the sum of fractions 

using the total inventory divided by total volume, the container 

will be classified as Class A. The sum of fractions for the most 

concentrated influent resin is 60 times the Class A limit. Will 

the operator need to demonstrate adequate blending of the 

primary and secondary spent ion exchange resins? 

i. Yes

ii. No 

Sample Problems
73

The operator of a nuclear power plant, for operational 

efficiency, has combined primary and secondary spent ion 

exchange resins (two blendable wastes) in a single container 

with a volume of 7 m3 (247 ft3). Based on the sum of fractions 

using the total inventory divided by total volume, the container 

will be classified as Class A. The sum of fractions for the most 

concentrated influent resin is 60 times the Class A limit. Will 

the operator need to demonstrate adequate blending of the 

primary and secondary spent ion exchange resins? 

i. Yes

ii. No 

Sample Problems
74

One fundamental purpose of the BTP is to provide guidance 

on acceptable methods for concentration averaging of hot 

spots for the purpose of determining the waste classification 

for disposal. A hot spot is:

i. A site that offers internet access over a wireless local 

area network

ii. An unshielded radioactive source

iii. A portion of the overall waste volume whose 

radionuclide concentrations are above the class limit 

for the entire container. 

Sample Problems
One fundamental purpose of the BTP is to provide guidance 

on acceptable methods for concentration averaging of hot 

spots for the purpose of determining the waste classification 

for disposal. A hot spot is:

i. A site that offers internet access over a wireless local 

area network

ii. An unshielded radioactive source

iii. A portion of the overall waste volume whose 

radionuclide concentrations are above the class limit 

for the entire container. 

75

Sample Problems
76

Discrete items are divided into 5 waste types. Three of the five 

waste types are: contaminated materials, cartridge filters, and 

components incorporating radioactivity into their design. The 

other two waste types are:

i. Depleted uranium and NORM

ii. Sealed sources and spent ion exchange resins

iii. Deactivated metals and open sources

iv. Activated metals and sealed sources 

Sample Problems
77

Discrete items are divided into 5 waste types. Three of the five 

waste types are: contaminated materials, cartridge filters, and 

components incorporating radioactivity into their design. The 

other two waste types are:

i. Depleted uranium and NORM

ii. Sealed sources and spent ion exchange resins

iii. Deactivated metals and open sources

iv. Activated metals and sealed sources 

Sample Problems
78

The BTP uses the terms Waste Stream and Waste Type. These two 

terms sound similar, but they have different meanings. Which of 

these two is expected to have relatively uniform physical 

characteristics and radiological characteristics?

i. Waste Stream

ii. Waste Type

Sample Problems
79

The BTP uses the terms Waste Stream and Waste Type. These two 

terms sound similar, but they have different meanings. Which of 

these two is expected to have relatively uniform physical 

characteristics and radiological characteristics?

i. Waste Stream

ii. Waste Type

Sample Problems
Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

80

Part II Detailed description of 2015 positions 
What are Discrete Items?

• Discrete Items are items of one of these waste types: 

– activated metals

– sealed sources

– contaminated materials

– components incorporating radioactivity into design, and

– cartridge filters (Cartridge filters may be treated as blendable 

waste in some cases, see Section 3.3.3)

• These waste types typically

– Contain durable items (expected to be intact at time of intrusion), 

and

– Have high amounts or concentrations of radioactivity 

81
Guidance on Discrete Items

3.3 Discrete Items

3.3.1 Averaging and Classification of Single Discrete Items

3.3.2 Averaging and Classification of Mixtures of Discrete Items

3.3.2.3 Sectioning Components

3.3.3 Alternative Treatment of Certain Cartridge Filters

3.3.4 Encapsulation of Discrete Items

82
83

Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Requirements and Approaches

• Wrap up

Part II Detailed description of 2015 positions 
Single Discrete Item

• Average based on the sum of fractions of the total 

inventory, divided by the volume or mass, as 

appropriate

• See Table 4 for guidance on volume

– Cartridge Filters – Use 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 –

Use displaced volume (major void volumes subtracted 

from envelope volume) or mass of components

84
85

Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

8585

Part II Detailed description of 2015 positions 
Mixture of Discrete Items

• For classifying a mixture of discrete items in a single 

container

• May be the most complex of all averaging positions in the 

revised CA BTP

• However, there are two simple screening options

• Mixtures that meet one of the simple screening criteria do 

not have to use the more complex criteria to identify hot 

spots

86
87

Mixture of Discrete Items

Simple Screening Options
Mixture of Discrete Items

• If one of the screening options is not used, then 

more rigorous criteria are used to identify hot 

spots 

• If all criteria for identifying hot spots are met, then 

use simple averaging to classify mixture (i.e., 

average based on the sum of fractions using the 

total inventory in all of the items in the mixture, 

divided by the total volume or mass, as 

appropriate)

• If an item fails, remove the piece that failed the test 

and reevaluate remaining pieces

88
Mixture of Discrete

Items (cont’d)

• Criteria used to identify hot spots depend on whether 

or not “primary gammas” control classification of 

mixture

• Primary gammas are: Co-60, Cs-137, and Nb-94

• Determining whether or not the primary gammas 

control the classification is addressed in detail later in 

the presentation

89
Mixture of Discrete Items

• “Radionuclides of Concern” other than primary 

gammas should meet either the Factor of 10 

concentrations OR Table 3 activities

• For primary gammas

– If they control the classification, they should meet 

either the Factor of 2 or Table 2

– If they do not control classification, they should 

meet either the Factor of 10 or Table 2

• Table 2 is applied with a sum of fractions, Table 3 and 

the Factors of 2 and 10 are not

• Items smaller than 280 cc (0.01 ft3) are grouped for 

comparison to Table 2 activities, other tests are applied 

to individual items 

90
“Radionuclides of Concern”

• New term for what had been called “classificationcontrolling” radionuclides in 1995 CA BTP

• The term “classification-controlling” has a more 

common-sense definition in the 2015 CA BTP

• Radionuclides of Concern are defined as: Any nuclide(s) 

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.

91
92
Do Primary Gammas Control?

• Use the total volume of the items and determine the sum 

of fractions (SOF) for the total inventory, using 

10 CFR 61.55 Tables 1 and 2 

• Use the 61.55 Table that gives higher classification 

• If Tables 1 and 2 give same classification, use Table with 

greater SOF

• Determine fractional contribution the primary gamma 

emitters make to that SOF 

• If the primary gamma emitters contribute more than 50% 

of the SOF, then primary gamma emitters are 

“classification controlling”

93
94
Table 2 or Factor of 2? 

• If primary gammas control classification of the mixture, then the 

licensee can use the least restrictive of:

– Factor of 2 for each item in the mixture OR

– Table 2 activity limits

• For items > 0.01 ft3, evaluate items individually

• For items < 0.01 ft3, evaluate items collectively

– It is acceptable to use Factor of 2 for some items and Table 2 for 

others, as long as all items < 0.01 ft3 in package are grouped for 

comparison to Table 2 (i.e., a comparison to Table 2 cannot 

include some items < 0.01 ft3 but exclude others)

• Factor of 2 means that that the concentration of each primary 

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

classification limit for that nuclide, based on the waste class of the 

mixture

95
Table 2 of the Revised CA BTP

96

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)

Table 2. Recommended Activity Limits of Primary Gamma Emitters Potentially 

Requiring Piecemeal Consideration in Classification Determinations
97
Factor of 10 or Table 3?

• For Table 3 nuclides in each item in the mixture

• Licensee can use least restrictive:

– Factor of 10 or

– Table 3

– OK to mix-and-match (use Factor of 10 for some and Table 3 for 

others)

• Factor of 10 - the concentration of each Table 3 nuclide, in 

each item, should be less than 10 times the classification 

limit for that nuclide, using the classification of the mixture 

98
Table 3 of BTP

99

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

3H 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)
100
All remaining nuclides 

less than Factor of 10? 

• Determine nuclides in mixture that are in Tables 1 and 2 of 

Part 61, but which are not in Table 2 and Table 3 of BTP

• For all those remaining nuclides, in each piece, each must 

be less than Factor of 10 of the classification limit for the 

mixture

• If the classification of the mixture is Class B, and there are 

Table 1 long-lived nuclides, then apply Factor of 10 to 

Table 1 Class A limits, not Class C limits 

101
102
103

Example: What if an item 

fails a test?
Summary for 

Mixture of Discrete Items

• Applies to durable items that often have relatively high 

activities or concentrations (e.g., pieces of activated 

metal) 

• Averaging positions for mixtures of discrete items are 

designed to allow flexibility (e.g., operator can chose 

the least restrictive of Table 2 or Factor of 2)

• However, this position may be the most complex of all 

averaging positions in BTP (unless one of the two 

simple screening options is used)

• Use the flowchart and BTP text and proceed one step at 

a time

104
105

Ten pieces of activated metal are in a container. The contents will be 

classified as Class A , based on the sum of fractions using the total 

inventory, divided by total volume. The primary gammas control 

classification. One item exceeds the BTP’s Table 2 limit for Co-60, but is 

less than 2X the Class A limit for Co-60 in that piece. All other primary 

gamma emitters in all other pieces are less than 2x the Class A limit. All 

remaining nuclides of concern, in each piece, are less than 10X the 

Class A limit. Is this a Class A waste?

i. Yes

ii. No

Sample Problems
106

Ten pieces of activated metal are in a container. The contents will be 

classified as Class A , based on the sum of fractions using the total 

inventory, divided by total volume. The primary gammas control 

classification. One item exceeds the BTP’s Table 2 limit for Co-60, but is 

less than 2X the Class A limit for Co-60 in that piece. All other primary 

gamma emitters in all other pieces are less than 2x the Class A limit. All 

remaining nuclides of concern, in each piece, are less than 10X the 

Class A limit. Is this a Class A waste?

i. Yes

ii. No

Sample Problems
Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

107

Part II Detailed description of 2015 positions 
Alternative Treatment of Cartridge 

Filters

• Cartridge filters that do not contain significant amounts or 

concentrations of primary gamma emitters may be treated 

as blendable waste – with justification

• Such justification might include:

• A history showing primary gamma emitters are less than 

Table 2 of BTP (activity limits for primary gamma emitters) 

• Concentrations of non-primary gamma emitters are not greater 

than Class C, and

• The physical characteristics of the filter do not justify treating 

it as a discrete waste:

• Filter is designed so radioactivity will not remain concentrated 

inside the filter during human intrusion

• Filter medium is not metal and is expected to degrade before 

intrusion

• This justification should be available for inspection

108
109

Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

Part II Detailed description of 2015 positions 
Sectioning

• Policy unchanged from 1995 BTP

• A component may be sectioned for operational 

considerations (e.g., packaging for transportation)

• 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 in the same container, and 

• The activities of radionuclides are less than the Table 3 values 

and

• The activities of all pieces smaller than 0.01 ft3 are less than 

Table 2 values. 

110
111
Sectioning and Classifying 

Mixture of Discrete Items 

• A sectioned item may be combined with other items in 

a single container

• For concentration averaging, the sectioned item is to 

be treated as if the item had not been sectioned

• For example:

• A piece of activated metal is sectioned into 4 pieces, and all 4 

pieces meet the Sectioning Criteria (so the item can be 

classified as if it had not been sectioned)

• The sectioned 4 pieces are added to a liner, along with 8 other 

pieces of activated metal 

• When the “Mixture of Discrete Items” criteria are applied, the 

sectioned pieces is treated as one item (i.e., 9 items are 

evaluated, not 12 items) 

112
113

A 4-m long control rod blade is cut into four 1-m long sections to 

facilitate packaging for transportation for disposal. No piece is 

smaller than 0.01 ft3. When the total activity of each nuclide in the four 

pieces is averaged over the total volume of the four pieces, the SOF 

meets the Class C limit. All items are to be shipped and disposed in 

the same waste container, and no item has an activity that exceeds 

BTP’s Table 3 criteria. Is this acceptable?

i. Yes

ii. No

Sample Problems
114

A 4-m long control rod blade is cut into four 1-m long sections to 

facilitate packaging for transportation for disposal. No piece is 

smaller than 0.01 ft3. When the total activity of each nuclide in the four 

pieces is averaged over the total volume of the four pieces, the SOF 

meets the Class C limit. All items are to be shipped and disposed in 

the same waste container, and no item has an activity that exceeds 

BTP’s Table 3 criteria. Is this acceptable?

i. Yes

ii. No

Sample Problems
115

For the problem above (a 4-m long control rod blade cut into four 1-m 

long sections), the operator also wants to place eight additional pieces 

of activated metal into the container. When the total activity of each 

radionuclide in all 12 pieces is averaged over the total volume of the 12 

pieces, using the SOF, the contents of the container meets the Class C 

limit. No item has an activity that exceeds BTP’s Table 3 criteria. Is this 

acceptable?

i. Yes, because the average meets Class C, all items are less 

than the BTP’s Table 3, and all items are in the same 

container

ii. Possibly, but must demonstrate criteria for averaging a 

“Mixture of Discrete Items” is met 

iii. No, individual pieces should not be mixed with an item that 

has been sectioned. 

Sample Problems
116

For the problem above (a 4-m long control rod blade cut into four 1-m 

long sections), the operator also wants to place eight additional pieces 

of activated metal into the container. When the total activity of each 

radionuclide in all 12 pieces is averaged over the total volume of the 12 

pieces, using the SOF, the contents of the container meets the Class C 

limit. No item has an activity that exceeds BTP’s Table 3 criteria. Is this 

acceptable?

i. Yes, because the average meets Class C, all items are less 

than the BTP’s Table 3, and all items are in the same 

container

ii. Possibly, but must demonstrate criteria for averaging a 

“Mixture of Discrete Items” is met 

iii. No, individual pieces should not be mixed with an item that 

has been sectioned. 

Sample Problems
Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

117

Part II Detailed description of 2015 positions 
Encapsulation of Discrete Items 

• 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.

• Encapsulation may help meet stability criteria, provides 

shielding, limits migration

• When conditions defined in the CA BTP are met, credit 

can be taken for volume or mass of the binding matrix, 

when determining concentration of the final waste form 

• CA BTP constraints are designed to limit the amount of 

non-radioactive material used in concentration averaging

118
Overview of Encapsulation of 

Discrete Items

• Volumetric constraints are specific to encapsulation

– 1995 CA BTP provision preserved – any size item can be 

averaged over the volume of a 55 gallon drum (0.2 m3). 

Activity limits for items changed in some cases in revised 

BTP (e.g., Cs-137)

– 2015 CA BTP also allows for larger volumes up to 9.5 m3

(331 ft3), if there is a 14% minimum waste loading

• Application of Tables 2 and 3 and the Factors of 2 and 10 

are the same as for mixtures of discrete items

119
Encapsulation of Discrete Items

Waste Loading Boundary

• “Waste Loading” – (volume of waste / final volume) x 100

• 14% waste loading boundary 

– < 14% waste loading – maximum volume for averaging* is 0.2 m3

or 500 kg (~ 55 gallons or 1,100 pounds)

– > 14% waste loading – maximum volume 9.5 m3 (331 ft3) 

* Larger encapsulation volumes can be used, but maximum credit 

is for 0.2 m3

120
Encapsulation of Discrete Items

Additional Considerations

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

final encapsulated package meets the CA BTP criteria

• Total activity divided by final volume* (or mass) of 

encapsulated waste form cannot exceed the appropriate 

class limit (e.g., Class C)

* when waste loading is < 14%, maximum averaging volume 

is limited to 0.2 m3, even if final waste form is larger

121
122

**

** This figure is reproduced from Figure 5 of the revised CA BTP, which incorrectly uses 9.4 m3. The correct value is 9.5 m3.
123

Five Cesium-137 sealed sources are to be encapsulated by a 

stabilizing agent in a 200 L (55 gallon) drum* and disposed as 

Class C waste. The Cs-137 sources have activities of 13, 19, 28, 

33, and 47 curies, and each source has a volume much smaller 

than 0.01 ft3. The waste loading is < 14%. The activity of each 

source is well below the BTP’s Table 2 limits for Cs-137 for 

Class C, and when the total curies are averaged over 200 L (55 

gallons), the final waste form meets 61.55 Class C 

concentration limits. Is the final waste form acceptable for 

disposal as Class C waste?

i. Yes

ii. No

Sample Problems

*activity on surface of drum could exceed 200 mrem/hr surface dose shipping criteria
Five Cesium-137 sealed sources are to be encapsulated by a 

stabilizing agent in a 200 L (55 gallon) drum* and disposed as 

Class C waste. The Cs-137 sources have activities of 13, 19, 28, 

33, and 47 curies, and each source has a volume much smaller 

than 0.01 ft3. The waste loading is < 14%. The activity of each 

source is well below the BTP’s Table 2 limits for Cs-137 for 

Class C, and when the total curies are averaged over 200 L (55 

gallons), the final waste form meets 61.55 Class C 

concentration limits. Is the final waste form acceptable for 

disposal as Class C waste?

i. Yes

ii. No

124

Sample Problems

*activity on surface of drum could exceed 200 mrem/hr surface dose shipping criteria
125

Ten pieces of activated metal are in a 1 m3 (35 ft3) waste container. The 

total curies in the 10 pieces, divided by the summed volume of the 10 

pieces, on a SOF basis, exceeds the Class C limit by 20%. There are 

no pieces < 0.01 ft3

, the classification is not controlled by the primary 

gamma emitters, and no item has nuclide concentrations that exceed 

the Factor of 10. Therefore, the waste processor would like to center 

the pieces and add a stabilizing agent to the container, encapsulating 

the pieces of metal and bringing the specific activity of the waste 

container below the Class C limits for disposal. The operator 

understands that the revised BTP allows averaging over encapsulated 

volumes of up to 331 ft3 – if the waste loading is > 14% and in this 

case, the waste loading (volume of waste / final waste volume) is > 

14%. Is this acceptable?

i. Yes

ii. No

Sample Problems
Ten pieces of activated metal are in a 1 m3 (35 ft3) waste container. The 

total curies in the 10 pieces, divided by the summed volume of the 10 

pieces, on a SOF basis, exceeds the Class C limit by 20%. There are 

no pieces < 0.01 ft3

, the classification is not controlled by the primary 

gamma emitters, and no item has nuclide concentrations that exceed 

the Factor of 10. Therefore, the waste processor would like to center 

the pieces and add a stabilizing agent to the container, encapsulating 

the pieces of metal and bringing the specific activity of the waste 

container below the Class C limits for disposal. The operator 

understands that the revised BTP allows averaging over encapsulated 

volumes of up to 331 ft3 – if the waste loading is > 14% and in this 

case, the waste loading (volume of waste / final waste volume) is > 

14%. Is this acceptable?

i. Yes

ii. No

126

Sample Problems
127

An experimental irradiator was recovered from a university and 

it contains a Co-60 sealed source that is a cylinder, 1 cm (0.39 

in.) tall and 1 cm (0.39 in.) in diameter (i.e., volume < 0.01 ft3). 

The irradiator is old and the strength of the source has 

decayed to 5 Ci. The 61.55 Class A limit for Co-60 is 700 Ci/m3. 

Does this 5 Ci source qualify for disposal as Class A waste?

i. Yes

ii. No, because this 5 Ci source has a specific activity of 

5,000,000 Ci/m3

Sample Problems
128

An experimental irradiator was recovered from a university and 

it contains a Co-60 sealed source that is a cylinder, 1 cm (0.39 

in.) tall and 1 cm (0.39 in.) in diameter (i.e., volume < 0.01 ft3). 

The irradiator is old and the strength of the source has 

decayed to 5 Ci. The 61.55 Class A limit for Co-60 is 700 Ci/m3. 

Does this 5 Ci source qualify for disposal as Class A waste?

i. Yes

ii. No, because this 5 Ci source has a specific activity of 

5,000,000 Ci/m3

Sample Problems
129

If the Co-60 source described in the previous problem is 

encapsulated by a stabilizing agent in a 200 L (55 gallon) 

drum, the waste loading is < 14%. The Co-60 source has a 

volume < 0.01 ft3. The activity of the source is below the 

BTP’s Table 2 limits for Co-60 for Class A, and when the total 

curies are averaged over 200 L (55 gallons), the final waste 

form meets Class A concentration limits. Is this acceptable for 

disposal as Class A waste?

i. Yes

ii. No

Sample Problems
130

If the Co-60 source described in the previous problem is 

encapsulated by a stabilizing agent in a 200 L (55 gallon) 

drum, the waste loading is < 14%. The Co-60 source has a 

volume < 0.01 ft3. The activity of the source is below the 

BTP’s Table 2 limits for Co-60 for Class A, and when the total 

curies are averaged over 200 L (55 gallons), the final waste 

form meets Class A concentration limits. Is this acceptable for 

disposal as Class A waste?

i. Yes

ii. No

Sample Problems
131

Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

131

Part II Detailed description of 2015 positions 
Mixture of Different Waste Types

• Addressed averaging of blendable wastes

• Addressed averaging of mixture of discrete items

• Now address averaging of different waste types 

132
Mixture of Different Waste Types

• When mixing different blendable waste types (e.g., ion-exchange 

resins with soils or mixing ion-exchange resins with cartridge 

filters), the licensee should document the physical and chemical 

compatibility of the waste types and make the documentation 

available for inspection

• When mixing discrete items of different waste types (e.g., sealed 

sources with pieces of activated metal), the classification of the 

entire mixture of waste types should be the highest classification 

of any of the individual waste type(s) in the mixture

• If discrete items are mixed with blendable wastes, the averaging 

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

and physical and chemical compatibility must be demonstrated

133
134

A waste container is full and contains spent ion exchange 

resins (IERs) and a discrete item (a piece of activated 

metal). When the total curies inside the waste container are 

divided by the total volume of the waste container, the 

contents of the container, on a SOF basis, would be Class 

A. However, the piece of activated metal by itself would be 

classified as Class C. The spent IERs and the piece of 

activated metal are chemically compatible. Can this discrete 

item (the piece of activated metal) be disposed in the same 

waste container as the blendable waste (the spent IERs)?

i. Yes

ii. No

Sample Problems
135

A waste container is full and contains spent ion exchange 

resins (IERs) and a discrete item (a piece of activated 

metal). When the total curies inside the waste container are 

divided by the total volume of the waste container, the 

contents of the container, on a SOF basis, would be Class 

A. However, the piece of activated metal by itself would be 

classified as Class C. The spent IERs and the piece of 

activated metal are chemically compatible. Can this discrete 

item (the piece of activated metal) be disposed in the same 

waste container as the blendable waste (the spent IERs)?

i. Yes

ii. No

Sample Problems
136

A waste container is full and contains spent ion exchange 

resins and a discrete item (a piece of activated metal). When 

the total curies inside the waste container are divided by the 

total volume of the container, the contents of the waste 

container, on a SOFs basis, would be classified as Class A 

waste. However, the piece of activated metal by itself will be 

classified as Class C. How must the waste container be 

classified for disposal?

i. The spent IERs and the piece of activated metal 

cannot be disposed in the same container

ii. Class A

iii. Class C

Sample Problems
137

A waste container is full and contains spent ion exchange 

resins and a discrete item (a piece of activated metal). When 

the total curies inside the waste container are divided by the 

total volume of the container, the contents of the waste 

container, on a SOFs basis, would be classified as Class A 

waste. However, the piece of activated metal by itself will be 

classified as Class C. How must the waste container be 

classified for disposal?

i. The spent IERs and the piece of activated metal 

cannot be disposed in the same container

ii. Class A

iii. Class C

Sample Problems
Topics

• Waste Types and Waste Streams

• Blendable waste and discrete items

• Blendable waste

– Single blendable waste stream

– Mixture of blendable waste streams of same waste type

– Solidified Wastes 

• Discrete items

– Single item

– Mixture of discrete items 

– Alternative treatment of filters 

– Sectioning

– Encapsulation

• Mixture of different waste types

• Alternative Approaches

• Wrap up

138 138

Part II Detailed description of 2015 positions 
139

Alternative Approaches

• Like 1995 BTP, the 2015 revision identifies uniform “look 

up” guidance that is applicable to all disposal sites and 

waste types

• New Alternative Approaches section provides Licensees / 

Agreement States with specific NRC guidance on factors 

to consider in submitting/reviewing site- and wastespecific averaging methods

• CA BTP “strongly urges” licensees to submit proposals to 

regulator

– Note that proposal is to be submitted to disposal facility regulator

– CA BTP notes that detailed discussions of proposal would help to ensure 

that enforcement actions or return of wastes to the shipper will not be 

necessary
Alternative Approaches, Section 3.8

3.8.1 Site Specific Intruder Assessments

3.8.2 Encapsulation of Discrete Items, Including Sealed 

Sources

3.8.3 Likelihood of Intrusion

3.8.4 Large Components

3.8.5 Time of Intrusion into Blendable Waste

3.8.6 Legacy Wastes

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Example—Alternative Approach

• A disposal facility licensee wants to accept an 800 Ci Cs-137 

sealed source encapsulated in a 0.2 m3 (55 gallon) drum for 

Class C disposal

– When averaged over 0.2 m3, 800 Ci Cs-137 meets the Class C limit, so 

no exception from Part 61 is needed

– However, the CA BTP recommends a 130 Ci limit for Cs-137 in 0.2 m3

– Licensee would propose disposal of larger source to disposal facility 

regulator, addressing relevant considerations in Section 3.8.2, 

“Encapsulation of Discrete Items, Including Sealed Sources”

– Primary consideration is whether there is reasonable assurance of 

compliance with the inadvertent intruder performance objective in 10 

CFR 61.42

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Alternative Requirements 

and Alternative Approaches

• Revised CA BTP clarifies use of 10 CFR 61.58, 

“Alternative Requirements for Waste Classification and 

Characteristics”

– 1995 CA BTP stated that licensees must obtain approval under 10 

CFR 61.58 to deviate from positions in BTP

– However, 10 CFR 61.58 is designed for deviations from 

regulations for waste classification, not averaging guidance

– 2015 CA BTP discusses use of 10 CFR 61.58 in the context of 

deviations from disposal regulations

– A new section, “Alternative Approaches for Averaging,” 

discusses deviations from generic averaging positions in CA BTP

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Summary

• CA BTP covers averaging of radionuclide concentrations in waste for 

the purpose of classifying it in accordance with 10 CFR Part 61

• Guidance has been extensively revised and is expected to be widely 

used by industry

• Revised positions will affect reactor licensee waste management 

practices. Materials licensees, with the exception of waste 

processors, may be less impacted by revised guidance

• The BTP divides wastes into two broad categories, blendable wastes 

and discrete items

• Some of the averaging constraints for discrete items are complex: 

Use the flowchart and BTP text and proceed one step at a time 

• NMSS staff is conducting training of NRC and Agreement State 

inspection staff to facilitate implementation

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For Additional Information contact:

Maurice Heath

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission,

Washington, DC 20555–0001

telephone: 301–415–3137

email: Maurice.Heath@nrc.gov

CA BTP Volume 1 – ADAMS ML12254B065 

CA BTP Volume 2 – ADAMS ML12326A611 

More information on the CA BTP can be found at 

http://www.nrc.gov/waste/llw-disposal/llw-pa/llw-btp.html

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Thank You