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10 CFR 61 Scaling Factors



 I am looking for publications discussing the development of 10 CFR 61 scaling factors for decommissioning sites that are being dismantled 20 years after the termination of operating the nuclear reactor.  I have the NRC Branch Technical  Positions (1983 and 1995) discussing classification of wastes.  I am familiar with 10 CFR Parts 20 and 49 CFR for manifesting of wastes, and 10 CFR 61 concerning proper classification of wastes.
 
Specifically, I am looking for information on how to properly scale transuranic radionuclides.  For an operating facility, transuranic radionuclides are traditionally scaled from Ce-144 (radioactive half-life of 284 days).  20 years after the operation of the nuclear reactor, Ce-144 has undergone decay of more than 20 half-lives.  Therefore, I don't think it is appropriate to use Ce-144 to scale other radionuclides.
 
Prior to discussing this issue with regulators or disposal sites, I would like some information from personnel working at decommissioning sites or with people that have experience in this matter.
 
Any personal operating experience or knowledge of publications is appreciated.