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- 4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION o
K WASHINGTON, D.C. 2060H001
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,o May 22, 1996 ATTENTION:
Potential Low-Level Waste Shippers and Handlers
SUBJECT:
INSTRUCTIONS FOR COMPLETING NRC'S LOW-LEVEL RADIOACTIVE WASTE MANIFEST On March 27, 1995, the Nuclear Regulatory Commission (NRC) published in the Federal Reaister the final rule, " Low-Level Waste Shipment Manifest Information and Reporting" (60 FR 15649). The rule, among other things, establishes a set of forms that serve as a national Uniform Low-Level Radioactive Waste Manifest for NRC and Department of Transportation requirements and most State and Compact information needs. The forms also allow low-level waste (LLW) to be tracked from its origin. The rule requires waste generators, collectors, or processors who ship LLW intended for ultimate disposal at a licensed LLW disposal facility to prepare an NRC Uniform Low-Level Radioactive Waste Manifest.
The manifest includes NRC Form 540 (Shipping Paper), Form 541 (Container and Waste Description), and Form 542 (Manifest Index and Regional Compact Tabulation).
The effective date of the rule and of required use of the NRC forms is March 1, 1998. However, LLW shippers will likely be required (by at least one disposal facility operator) to use the new forms at an earlier date.
On May 15, 1995, the NRC sent a letter to potential LLW shippers and handlers, enclosing NUREG/BR-0204 (April 1995), which provided instructions for completing the NRC Uniform Low-Level Radioactive Waste Manifest.
The brochure also contained sample manifest forms.
Potential users were encouraged to experiment with using the forms to identify any practical problems.
Over the last year, the NRC staff and potential users have identified some changes that are needed to the instructions and forms.
The NRC intends to publish a revised set of instructions and forms prior to the end of 1996.
i This letter describes the intended changes and will allow comments and l
suggestions prior to our first revision. No changes are being made to the final regulations issued on March 27, 1995.
CHANGES IDENTIFIED SINCE APRIL 1995 INSYRUCTIONS FOR COMPLETING NRC's UNIFORM LOW-LEVEL RADI0 ACTIVE WASTE MANIFESI Page 2, footnote 1: This footnote would be updated to indicate that the forms i
and instructions are based on final DOT regulations issued on September 28, 1995 (60 FR 50292).
Page 3, Note: This note on the use of metric and English units would be updated to reflect DOT's final regulation. The second and third sentences would be revised to read as follows:
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Page 12 same item: The last sentence would be changed to italics and revised to read,as fo110ws, " Indicate the total number of disposal containers containing each type of Special Nuclear Material in parentheses after the quantity listing." This change would indicate that this requirement is not a Federal law or regulation and would clarify where to include the information.
Page 17, Item 13, Sorbent, Solidification, Stabilization Media:
The last sentence of the last paragraph would be revised to read as follows:
For all solidified wastes, the vendor and the brand name of the solidification media must be identified in this column.
j This change, to conform to the final NRC regulations and for consistency with
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the change proposed in Note 3 of Form 541, would clarify that shippers must identify the vendor and the brand name for each solidification media entry.
Page 18, Item 15, Radiological
Description:
This item would be clarified to describe how to report LLD values as required in Item 1.
In the first paragraph, the last sentence would be replaced by the following:
When the radionuclides tritium (H-3), C-14, Tc-99, or I-129 are present, but the quantities are below the LLD, note the radionuclide and report the LLD value in parentheses. After listing the individual radionuclides as described above, enter the word " Total" on a new line and enter the total activity contained in the container.
However, if any LLD values were included in the container, these values should not be included in the container sum because they will be totaled separately under Item 1.
Page 19, same item: The note would be modified to show that source material and Special Nuclear Material must be reported in brackets because LLD values are reported in parentheses.
It would also be clarified that source material is to be reported ir kilograms and Special Nuclear Material ir grams.
The note would read as follows:
Note:
The activity for uranium and thorium in source material and U-233, U-235, and plutonium in Special Nuclear Material must be reported in megabecquerels. The quantity of these isotopes must be reported, in kilograms for source material -- including the abbreviation "kg", and in grams for Special Nuclear Material -- including the abbreviation "g".
The weight quantities must be reported in brackets, either adjacent to the activity listing or below the radionuclide listing.
Page 20, same item:
In the fourth line, replace " met" with " exceeded" to clarify the requirement.
Form 542 (Manifest Index and Reaional Compact Tabulation _1 Page 23, Item 1, Waste Collector / Processor: After the first paragraph, the following new material would be added to provide clarifying information:
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1-UNITED STATES j
i NUCLEAR REGULATORY COMMISSION wasumarow, o.c. sossem May 22, 1996 ATTENTION:
Potential._ Low-Level Wast'e Shippers and~ Handlers
SUBJECT:
INSTRUCTIONS FOR COMPLETING NRC'S-LOW-LEVEL l
RADI0 ACTIVE WASTE MANIFEST I
On March 27,1995,' the Nuclear Regulatory Commission (NRC) published.in the Federal Reaister the-final rule, " Low-Level Waste Shipment Manifest
[
-Information and Reporting" (60 FR 15649). The rule, among other things, 1
establishes:a set of forms that serve as a national Uniform Low-Level e
Radioactive Waste Manifest for NRC and Department of Transportation requirements and most State and Compact information needs. The forms also
- allow low-level waste (LLW) to be' tracked from its origin. The rule requires waste generators, collectors, or processors who ship LLW intended for ultimate j.
disposal at a licensed LLW disposal facility to prepare an NRC Uniform Low-Level Radioactive Waste Manifest. The manifest includes NRC Form 540 (Shipping Paper), Form 541 (Container and Waste Description), and Form 542
-(Manifest Index and Regional Compact Tabulation).
The effective date of the rule and of required use of the NRC forms is March 1, 1998. However, LLW shippers will likely be required (by at least one disposal facility operator) to use the'new forms at an earlier date.
On..May 15, 1995, the NRC sent a letter to potential LLW shippers and handlers, 4
enclosing NUREG/BR-0204 (April 1995), which provided instructions for-completing the NRC Uniform Low-Level Radioactive Waste Manifest. The brochure
- also contained sample manifest forms.
Potential users were encouraged to experiment with using the forms to identify any practical problems.
Over the.last year, the NRC staff and potential users have identified some changes that are needed to the instructions and forms. The NRC intends to publish a revised set of instructions and forms prior to the end of.1996.
This letter describes the intended changes and will allow comments and suggestions prior to our first revision. No changes are being made to the 4
final regulations issued on March 27, 1995.
i CHANGES IDENTIFIED SINCE APRIL 1995 INSTRUCTIONS FOR COMPLETING NRC's UNIFORM LOW-LEVEL RADI0 ACTIVE WASTE MANIFEST Page 2,' footnote 1: This footnote would.be updated to indicate that the forms and instructions are based on-final DOT regulations issued on September 28,
-1995-(60 FR 50292)..
Page,3, Note: This note on the use of metric and English units would be
. updated. to reflect DOT's' fina1' regulation. The second and third sentences
.would.be revised to read as'follows:-
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I Metric units are used in NRC Form 540 as permitted by D0T regulations, and required after April 1,1997, with the exception of Item 18 (Total Weight or Volume) in which DOT allows the shipper to specify appropriate units. 00T allows reporting of English units following the International System of Units (SI).
Form 540 (Shionino Paoer) 1 Page 9, Item 14, Physical and Chemical Form: The list of examples includes i
"Na."
This item would be removed because Na is the chemical symbol for l
sodium, a chemical element, and is not a good example of a chemical form.
Na could also be interpreted to mean, "not applicable."
Page 9, Item 15 Individual Radionuclides: The instructions will no longer require that "all" radionuclides that are present in the transport package be listed.
Based on the final D0T regulations issued on September 28, 1995 (60 FR 50292), DOT no longer requires a listing of all radionuclides, but will accept radionuclides that represent 95 percent of the hazard. The second sentence would be modified to read as follows:
List the radionuclides (as determined in DOT regulations at 173.433(f))
that are present in the transpor' package.
Form 541 (Container and Waste Descriotion)
Page 11, Item 1, Manifest Totals: The first sentence would be clarified by replacing the words " low-level waste containers" in the phrase enclosed in parentheses with the word " packages". This is necessary because DOT regulations apply to a shipment not being sent to a low-level waste disposal facility and packages is the correct term.
Page 12, same item:
In the second sentence, replace "Pu-239" with " plutonium" to be consistent with the NRC definition for Special Nuclear Material.
Page 12, same item:
The fifth sentence of Item I would be modified to note that the total lower limit of detection (LLD) values represent the sum of the respective LLDs reported under Item 15.
It would read as follows:
If the radionuclides are present in any of the containers within a shipment, but are identified in Item 15 in quantities no greater than the lower limit of detection (LLD), the quantities of these nuclides must be recorded as the sum of the respective LLD values (with the summed value included in parentheses).
(Note that Item 15, beginning on page 18, would also be expanded to h
reflect the reporting of tritium (H-3), C-14, Tc-99, and I-129 below LLDs).
I Page 12, same item:
In the last paragraph, the spacing after U-235 will be l
corrected.
2
Page 12, same item:
The last sentence would be changed to italics and revised to read as follows, " Indicate the total number of disposal containers coritaining each type of Special Nuclear Material in parentheses after the quantity-listing." This change would indicate that this requirement is not a Federal law or regulation and would clarify where to include the information.
Page 17, Item 13, Sorbent, Solidification, Stabilization Media:
The last sentence of the last paragraph would be revised to read as follows:
For all solidified wastes, the vendor and the brand name of the solidification media must be identified in this column.
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This change, to conform to the final NRC ' regulations and for consistency with the change proposed in Note 3 of Form 541, would clarify that shippers must identify the vendor and the brand name for each solidification media entry.
Page 18, Item 15, Radio 1ogical
Description:
This item would be clarified to describe how to report LLD values as required in Item 1.
In the first paragraph, the last sentence would be replaced by the following:
When the radionuclides tritium (H-3), C-14, Tc-99, or I-129 are prese*'.,
but the quantities are below the LLD, note the radionuclide and report the LLD value in parentheses. After listing the individual radionuclides as described above, enter the word " Total" on a new line and enter the total activity contained in the container.
However, if any LLD values were included in the container, these values should not be included in the container sum because they will be totaled separately under Item 1.
Page 19, same item: The note would be modified to show that source material and Special Nuclear Material must be reported in brackets because LLD values are reported in parentheses.
It would also be clarified that source material is to be reported in kilograms and Special Nuclear Material in grams.
The note would read as follows:
Note: The activity for uranium and thorium in source material and U-233, U-235, and plutonium in Special Nuclear Material must be reported in megabecquerels.
The quantity of these isotopes must be reported, in kilogramr for source material -- including the abbreviation "kg", and in grams for Special Nuclear Material -- including the abbreviation "g".
j The weight quantities must be reported in brackets, either adjacent to the activity listing or below the radionuclide listing.
Page 20, same item:
In the fourth line, replace " met" with " exceeded" to clarify the requirement.
Form 542 (Manifest Index and Reaional Compact Tabulation)
Page 23, Item 1, Wa;te Collector / Processor: After the first paragraph, the following new material would be added to provide clarifying information:
A waste collector or processor is an entity, operating under a Commission or Agreement State license, whose principal purpose,for possessing the radioactive material or waste is as follows:
e A collector collects and consolidates waste generated by others and l
transfers this waste, without processing or repackaging, to another waste collector, processor, or land disposal facility.
A processor processes, repackages, or otherwise treats low-level e
radioactive material or waste generated by others before the eventual transfer of the waste to a land disposal facility.
UNIFORM LOW-LEVEL RADI0 ACTIVE WASTE MANIFEST i
Form 540 (Shionino Paper) l No changes.
I Form 541 (Container and Waste Description)
Note 3: Sorption, Solidification, Stabilization Media Codes.
This note would be modified to eliminate the restriction to 3 code numbers. Also, the note is clarified to conform to the final NRC regulations which require the vendor and the brand name for each solidification media entry.
Note 3 would read as follows:
For solidification media that meet disposal site structural stability requirements, the numerical code must be followed by "-S".
For all solidification media, the vendor and brand name must also be identified in Item 13. Code 100-N0NE REQUIRED.
Form 542 (Manifest Index and Reaional Compact Tabulation)
No changes.
Questions or comments on the instructions and forms may be referred to William R. Lahs, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301) 415-6756, or to Mark Haisfield, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory l
Commission, Washington, DC 20555, telephone (301) 415-6196.
M%%
Thomas 0. Martih, C ief Regulatory Development Branch Division of Regulatory Applications Office of Nuclear Regulatory Research 4
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