Uniform Waste Manifest
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10 CFR Part 20, Appendix G, “Requirements for Transfers of Low-Level Radioactive Waste (LLRW) Intended for Disposal at Licensed Land Disposal Facilities and Manifests” requires that an NRC Uniform Waste Manifest (Shipping Paper and Container and Waste Description) be prepared for LLRW intended for ultimate disposal at a licensed LLRW land disposal facility. The waste generator, collector, or processor who transports, or offers for transportation, LLRW must prepare the manifest reflecting information requested on applicable NRC Forms 540 (Uniform Low-Level Radioactive Waste Manifest (Shipping Paper)) and 541 (Uniform Low-Level Radioactive Waste Manifest (Container and Waste Description)) and if necessary, on an applicable NRC Form 542 (Uniform Low-Level Radioactive Waste Manifest (Manifest Index and Regional Compact Tabulation)). NRC Forms 540 and 540A must be completed and must physically accompany the pertinent LLRW shipment. Per Appendix G of 10 CFR Part 20, the shipper of the waste must include, on the uniform manifest for the waste shipment, “[t]he activity of each of the radionuclides H-3, C-14, Tc-99, and I-129 contained in the shipment.” These isotopes are of concern because they were found to be especially important to safety from groundwater migration in the 10 CFR Part 61 Draft Environmental Impact Statement.
In SECY-13-0001, "Staff Recommendations for Improving the Integration of the Ongoing 10 CFR Part 61 Rulemaking Initiatives", staff noted that involved members of the public have recommended that the earlier assumptions concerning the above isotopes cited in the 10 CFR Part 20, Appendix G should be revisited.
Unfortunately, the activities of H-3, C-14, Tc-99, and I-129 are difficult-to-measure (DTM) in the radioactive waste that is generated. Involved members of the public suggest that H-3, C-14, Tc-99, and I-129 are being over-estimated in current site inventory dose assessments because of a reliance on a default value when the amount of the physical isotope in question is below some lower limit of detection threshold for these isotopes. If true, the cumulative effect of this over reporting results in an over-estimation of the site inventory, thus, if reporting requirements are not updated, disposal sites may have to close prematurely due to over-estimation in site inventory dose assessments.
Additionally, the State of Texas required the performance assessment for the Waste Control Specialists (WCS) LLRW disposal facility in Andrews County to address Cl-36 because it is also a key contributor to the groundwater dose and was analyzed in NUREG-1573, "A Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities". Cl-36 may also be over-reported because of minimum detection reporting criteria, thus it is included in the effort to update NUREG/BR-0204.
Involved members of the public would like the NRC to address the manifesting of these isotopes, potentially by revising NUREG/BR-0204, Rev. 2 to provide improved reporting guidance for the DTM radionuclides. NRC will facilitate public discussion of the issues involving H-3, C-14, Tc-99, and I-129. NRC staff will also evaluate issues with Cl-36 reporting.
The NRC considers public involvement to be a cornerstone of strong, fair regulation.
The U.S. Nuclear Regulatory Commission (NRC) has a long-standing practice of conducting its regulatory responsibilities in an open manner, and keeping the public informed of the agency's regulatory, licensing, and oversight activities. For that reason, we opened a dialogue with stakeholders (including the public) to discuss the Branch Technical Position (BTP) on Concentration Averaging and Encapsulation. Public comments for the BTP can be found on regulations.gov using Project Number 0800.
See Public Meetings and Involvement, Hearing Opportunities and License Applications, and NUREG/BR-0215, "Public Involvement in the Regulatory Process," for general information about the available opportunities for public involvement in NRC activities. For more specific information about past public meetings on this topic, see the chronological listing in the following table:
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The objective of this meeting is to gather comments on revisions to NUREG/BR-0204.
The objective of this meeting is to gather comments from our Agreement State co-regulators on revisions to NUREG/BR-0204.