United States Nuclear Regulatory Commission - Protecting People and the Environment

Uniform Waste Manifest

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Appendix G of 10 CFR Part 20, "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 stakeholders 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. Stakeholders 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. Overestimation of activity inflates site inventory which could lead to premature loss of disposal system capacity. Conversely, underestimation of activity could lead to health & safety concerns.

Stakeholders 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.

The ongoing Site-Specific Analysis Rulemaking will also require revisions to the uniform waste manifest. Rather than making revisions to the NUREG/BR and manifest forms twice, NRC will merge the NUREG revisions with the Part 61 rulemaking. However, if the rulemaking does not progress as scheduled, NRC will move forward with modifying the NUREG/BR and the manifest forms.

Regulatory Issue Summary

A DRAFT Regulatory Issue Summary (RIS) titled "Reporting of H-3, C-14, Tc-99, and I-129 on the Uniform Waste Manifest" was published on June 2, 2014 in the Federal Register seeking public comments. The intent of this RIS is to inform addressees of the option to use indirect methods to determine the activity of H-3, C-14, Tc-99, and I-129 reported on the uniform manifest when the radionuclide is present at a concentration less than the lower limit of detection (LLD). Stakeholders previously provided comments on how NUREG/BR-0204 could be updated to provide more accurate estimates for the activities of the DTM radionuclides; however, several of the comments could not be addressed in the NUREG/BR thus staff decided to issue this RlS.

The final RIS (RIS-15-002) was published on February 18, 2015. Responses to public comments received can be found in the Agencywide Documents Access and Management System (ADAMS) using accession number ML14289A361.

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Public Involvement

The NRC considers public involvement to be a cornerstone of strong, fair regulation.

Public Meetings

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 NUREG/BR-0204. Public comments for the NUREG can be found on regulations.gov using Docket Number NRC-2013-0035.

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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Date Description

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.

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Page Last Reviewed/Updated Wednesday, August 09, 2017