United States Nuclear Regulatory Commission - Protecting People and the Environment

Uniform Waste Manifest

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Appendix G of Title 10 of the Code of Federal Regulations (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 540A, 541A, and 542A should be used if additional pages are needed for Forms 540, 541, and 542, respectively. Collectively, NRC Forms 540/540A, 541/541A, and 542/542A are referred to as the NRC's Uniform Low-Level Waste Manifest and can be found on the NRC Forms webpage under Document Collections.

NUREG/BR-0204, "Instructions for Completing the NRC's Uniform Low-Level Radioactive Waste Manifest," provides guidance on completing NRC Forms 540, 541, and 542. The current version of this NUREG is Revision 2, and as discussed below, the NRC staff is currently finalizing Revision 3. The information on NRC Form 540 is needed to meet DOT shipping paper requirements for radioactive material shipments and the information on NRC Form 541 describe the waste and its container. Pursuant to the requirements of Appendix G of 10 CFR Part 20, NRC Forms 540 and 541 must be prepared for LLRW intended for ultimate disposal at a licensed LLRW land disposal facility. NRC Form 542 is required only if processors and collectors of LLRW are shipping LLRW attributed to others for disposal at a licensed LLRW land disposal facility.

Regulatory Issue Summary and Reporting of Hard-to-Detect Radionuclides on the Uniform Waste Manifest

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 isotopes cited in the 10 CFR Part 20, Appendix G be revisited.

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, staff developed Regulatory Information Summary (RIS-15-002). This RIS, entitled "Reporting of H-3, C-14, Tc-99, and I-129 on the Uniform Waste Manifest" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14272A217), 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 Uniform Low-Level Radioactive Waste Manifest 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-15-002 was published on February 18, 2015.

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NUREG Revision

The last revision to NUREG/BR-0204, "Instructions for Completing the NRC's Uniform Low-Level Radioactive Waste Manifest," Rev. 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" (ADAMS Accession No. ML12199A412), 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 Uniform Waste Manifest be revisited. To address these 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 a number of changes to make to the Uniform Low-Level Radioactive Waste Manifest 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. However, the 10 CFR Part 61 rulemaking was still in progress at the time and the specific changes to the Uniform Low-Level Radioactive Waste Manifest forms and NUREG/BR-0204 as a result of it were not known with certainty.

As described in SECY-16-0118, "Programmatic Assessment of Low-Level Radioactive Waste Regulatory Program," the staff conducted a programmatic assessment to consider future high priority activities given the current LLRW landscape and to identify what changes, if any, should be made to the current LLRW program's regulatory framework, as well as specific activities that NRC staff may undertake to facilitate such changes. A list of activities responsive to identified programmatic needs was developed to improve the LLRW national program. These activities were assigned priorities of high, medium, or low. One of the tasks considered was the revision of NUREG/BR-0204 and the NRC Forms 540/540A, 541/541A, and 542/542A as stakeholders and the NRC had identified items on the forms for revision, and additionally, through work on the 10 CFR Part 61 rulemaking, the staff identified additional revisions needed for the forms. As a result of this assessment, a new high priority task was added to the list, "Update NUREG/BR-0204, Rev. 2 (July 1998), 'nstructions for Completing NRC's Uniform Low-Level Radioactive Waste Manifest.'"

The NRC staff published Draft Revision 3 of NUREG/BR-0204 with a notice of opportunity for public comment on October 30, 2018 in the Federal Register (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 NRC staff has used these comments, as well as those from 2013, in the changes for the final Rev 3 of the NUREG as it prepares to finalize the NUREG. The primary changes include the following: updated instructions to reflect changes to the Uniform Manifest forms; updated references to U.S. Department of Transportation (DOT) regulations to reflect the current DOT regulations; additional discussion on the reporting of inventories based on lower limit of detection (LLD) 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 intent of the certification statement on Form 540; and overall improvements to the clarity of the document. The staff plans to publish the Final Revision 3 of NUREG/BR-0204 in 2020.

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 dialogue with stakeholders (including the public) to discuss NUREG/BR-0204. Public comments for the NUREG can be found on regulations.gov using Docket Numbers NRC-2013-0035 and NRC-2018-0155.

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
03/01/2013

The objective of this meeting is to gather comments on revisions to NUREG/BR-0204.

06/26/2013
(Webinar)

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 Monday, March 30, 2020