Guidance for Conducting Technical Analyses for 10 CFR Part 61, Draft Report for Comment (NUREG-2175, Revision 1)

This publication has been issued for public comment.  Comments will be accepted until August 17, 2026. To submit comments, please see Docket ID Number NRC-2011-0012.

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• Publication Information
• Abstract

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Publication Information

Manuscript Completed: June 2026
Date Published: June 2026

Prepared by:
D. Esh¹, C. Grossman^1, H. Arlt¹, P. Yadav¹,
T. McCartin¹, C. Barr¹, C. Ridge¹, D. Brown¹,
G. Wittmeyer², P. LaPlante², D. Pickett²,
S. Stothoff², and B. Dasgupta²

¹U.S. Nuclear Regulatory Commission

² Southwest Research Institute
   Center for Nuclear Waste Regulatory Analyses
   9503 W Commerce
   San Antonio, TX 78227-1301

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Abstract

This document provides guidance on conducting technical analyses (i.e., performance assessment, inadvertent intruder assessment, operational safety assessment, site stability assessment, and performance period analyses) to demonstrate compliance with the performance objectives in Title 10 of the Code of Federal Regulations (10 CFR) Part 61, “Licensing Requirements for Land Disposal of Radioactive Waste.” This document provides implementing guidance for the amendments to 10 CFR Part 61 that are detailed in the U.S. Nuclear Regulatory Commission’s (NRC’s) “Integrated Low-Level Radioactive Waste Disposal” (ILLRWD) rule (NRC, 2026). Though this guidance emphasizes technical analyses, it also provides guidance on many other topics relevant to technical analyses.

The information in this document is intended to supplement existing guidance on low-level radioactive waste on issues pertinent to conducting technical analyses to demonstrate compliance with the performance objectives. This document provides detailed guidance in new areas, such as the inadvertent intruder assessment and analyses for the compliance and performance periods. This guidance discusses approaches to selecting the compliance period (1,000 years or 10,000 years after disposal site closure, depending on the quantities of long-lived radionuclides disposed), and covers the performance period analyses (beyond 10,000 years) that should be performed for analysis of long-lived waste.

This guidance should facilitate implementation of the rule by existing licensees and potential applicants and assist regulators in reviewing the technical analyses. This guidance applies to waste streams disposed at 10 CFR Part 61 low-level waste disposal facilities, including significant quantities of depleted uranium, blended waste, and Greater-Than-Class-C (GTCC) waste. Additional topics covered in this document include (1) the use of defense-in-depth to enhance the resiliency of the disposal site to meet performance objectives, (2) the identification and screening of the features, events, and processes to develop scenarios and conceptual models for technical analyses (the scope of the analyses), (3) the use of the waste classification tables or the results of the technical analyses to develop generic or site-specific waste acceptance criteria, and (4) the development of a safety case for a low-level waste disposal facility. This guidance includes a discussion of specific considerations for GTCC waste disposal in both a near-surface disposal facility and a specialized land disposal facility, provides examples for determining the appropriate compliance period for the technical analyses based on the quantities of long-lived radionuclides, and the criteria for disposal facility licensees with licenses in effect before the effective date of the final ILLRWD rule that do not plan to dispose of significant quantities of long-lived radionuclides and do not plan to apply to the NRC to dispose of GTCC waste after the effective date of this rule.