Uniform Waste Manifest
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On June 25, 2021, the U.S. Nuclear Regulatory Commission (NRC) published a Federal Register Notice (86 FR 33783) announcing that the revised Uniform Low-Level Radioactive Waste Manifest (UWM) Forms, consistent with NUREG/BR-0204, Revision 3, are available. These UWM forms are NRC Form 540 (Uniform Low-Level Radioactive Waste Manifest (Shipping Paper)), NRC Form 541 (Uniform Low-Level Radioactive Waste Manifest (Container and Waste Description)), and NRC Form 542 (Uniform Low-Level Radioactive Waste Manifest (Manifest Index and Regional Compact Tabulation)) located in the NRC Forms library. As noted in the FRN, the forms have a 90-day implementation period and users should transition to the revised forms on or before September 23, 2021.
On February 11, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 public meeting to collect stakeholder input on the status of the implementation of NUREG/BR-0204, Revision 3, and its revised UWM Forms. The meeting was attended by more than 50 stakeholders from industry, disposal facilities, waste generators and shippers, regulators, and software vendors. The NRC Staff Presentation, public meeting summary; and meeting transcript are all available for reference. Staff answered several frequently asked questions (FAQs) in the NRC Staff Presentation and has answered more FAQs.
NRC staff published NUREG/BR-0204, Revision 3, "Instructions for Completing NRC's Uniform Low-Level Radioactive Waste Manifest," on July 2, 2020 (85 FR 39936). This document provides instructions to prepare the UWM forms. NRC Agreement States were also notified with State and Tribal Communications Letter STC-20-050.
In a September 14, 2020 public meeting NRC staff announced that the use of NUREG/BR-0204, Revision 3 has been delayed. This action was taken in response to industry requests that more time was needed to implement the changes included in Revision 3 to NUREG/BR-0204.
The delay of NUREG/BR-0204, Revision 3 was also announced in a September 30, 2020 Federal Register Notice (85 FR 61576), and licensees were instructed to continue to use NUREG/BR 0204, Revision 2 and the versions of NRC Forms 540, 541 and 542 that were renewed in January 2020, or equivalent, as defined in NRC's regulations. The NRC Forms website reflects the versions of NRC Forms 540, 541 and 542 that licensees should use.
The previous revision to NUREG/BR-0204, Revision 2, was published in July 1998. In SECY-13-0001, "Staff Recommendations for Improving the Integration of the Ongoing 10 CFR Part 61 Rulemaking Initiatives", staff noted stakeholders' suggestion that NUREG/BR-0204 be rewritten and that assumptions concerning the reporting of certain hard-to-detect isotopes (i.e., H-3, C-14, Tc-99 and I-129) on the UWM be revisited. In SECY-16-0118, "Programmatic Assessment of Low-Level Radioactive Waste Regulatory Program," the staff identified "Update NUREG/BR-0204, Rev. 2 (July 1998), as a high priority task.
To address stakeholder comments, the NRC staff held two public workshops, in March and June of 2013, to collect comments specifically on NUREG/BR-0204. The NRC staff identified several changes to make to the UWM forms and associated guidance in NUREG/BR-0204 based on stakeholder comments. Many of the stakeholder comments were focused on reporting of hard-to-detect radionuclides on the manifest, though the NRC also received comments on other aspects of the forms and guidance. Additionally, the NRC staff identified additional changes that may be needed for the forms and associated guidance as a part of the ongoing 10 CFR Part 61 rulemaking.
A request for comments on the draft NUREG/BR-0204, Revision 3 and its associated forms was published in the Federal Register on October 30, 2018 (83 FR 54620) with a 60-day comment period ending on December 31, 2018. An extension of the comment period until January 31, 2019, was subsequently published on December 21, 2018 (83 FR 65759). The revision of NUREG/BR-0204 was also discussed with the Agreement States and the U.S. Department of Transportation (DOT). The staff considered these comments as well as those received in 2013 in developing NUREG/BR-0204, Revision 3 and its associated forms (see analysis of public comments). Additional information regarding Public Involvement with NRC activities is described below.
The primary changes in Revision 3 include the following: updated instructions to reflect changes to the Uniform Manifest forms; updated references to DOT regulations to reflect the current DOT regulations; additional discussion on the reporting of inventories based on lower limit of detection values, the potential use of indirect methods to determine these inventories, and the use of indirect methods in waste classification calculations; additional clarification of the certification statement on Form 540 to account for cases where waste is shipped to a processor or collector; and overall improvements to the clarity of the document.
Regulatory Issue Summary 2015-02 and Reporting of Hard-to-Detect Radionuclides on the Uniform Waste Manifest
Per Appendix G of 10 CFR Part 20, a waste shipper must include, on the UWM, "[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.
Unfortunately, the activities of H-3, C-14, Tc-99, and I-129 are hard-to-detect 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 (LLD) 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.
To address stakeholder concerns regarding the reporting of hard-to-detect radionuclides on the Uniform Low-Level Radioactive Waste Manifest while the Part 61 rulemaking was still ongoing, NRC staff developed Regulatory Information Summary (RIS-2015-02). This RIS, entitled "Reporting of H-3, C-14, Tc-99, and I-129 on the Uniform Waste Manifest", informs 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 UWM when the radionuclide is present at a concentration less than the LLD.
A notice of opportunity for public comment on the draft RIS was published in the Federal Register (79 FR 31348) on June 2, 2014. Responses to public comments received can be found using Accession Number ML14289A361. The final RIS-2015-02 was published on February 18, 2015.
The NRC considers public involvement to be a cornerstone of strong, fair regulation. 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 dialogue with stakeholders (including the public) to discuss NUREG/BR-0204 and RIS-2015-02. Public comments for the NUREG can be found on regulations.gov using Docket Numbers NRC-2013-0035 and NRC-2018-0155.
NRC staff plans to conduct additional stakeholder outreach to discuss industry challenges with reporting hard-to-detect radionuclides on the UWM.
See Public Meetings and Involvement, and Hearing Opportunities and License Applications for general information about the available opportunities for public involvement in NRC activities.
Appendix G of Title 10 of the Code of Federal Regulations Part 20, "Requirements for Transfers of Low-Level Radioactive Waste (LLRW) Intended for Disposal at Licensed Land Disposal Facilities and Manifests" requires that a waste generator, collector, or processor who transports LLRW, or offers for LLRW for transportation must prepare a manifest (OMB Control Numbers 3150-0164, 3150‑0165, and 3150-0166) 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, 540A, 541, 541A, 542, and 542A are official NRC Forms referenced in this appendix. Licensees need not use originals of these NRC Forms as long as any substitute forms are equivalent to the original documentation in respect to content, clarity, size, and location of information. Upon agreement between the shipper and consignee, NRC Forms 541 (and 541A) and NRC Forms 542 (and 542A) may be completed, transmitted, and stored in electronic media. The electronic media must have the capability for producing legible, accurate, and complete records in the format of the uniform manifest.
Persons preparing the UWM should consult with the receiving facility and associated Agreement State for specific requirements related to the use of the forms.
Page Last Reviewed/Updated Friday, June 25, 2021