ML20217J994

Request for OMB Review & Supporting Statement Re Uniform Low Level Radioactive Waste Manifest (Shipping Paper) & Continuation Pp.Estimated Respondent Burden 9,380 H

ML20217J994
Person / Time
Issue date:	03/05/1998
From:	Shelton B NRC
To:
Shared Package
ML20217J978	List: ML20217J971 ML20217J994
References
OMB-3150-0164, OMB-3150-164, NUDOCS 9805010010
Download: ML20217J994 (7)

Text

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l 5 o PAPERWORK REDUCTION ACT SUBMISSION Pirse rr,cd tha instructions before complating this form. For additionti forma or assisttnce in complsting this form, contact your agency's Paperwork Clearance, Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of information and Regulatory Affairs, Office of )

Management and Budget, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503 l 1. Agency / Subagency originating request l OMB control number __

U.S. Nuclear Regulatory Commission X a. 3150 - 0164 b. None l 3. Type of information collection (check one) J Type of review requested (check one)

a. New collection X a. Regular submission c. Delegated

b. Revision of a curre .W approved collection b. Emergency - Approval requested by (date):

c. Extension of a currently approved conection 5. Will this information collection have a a.Yes X significant economic impact on a  ;

d. Reinstatement, without change. of a previously approved substantial number of sma'l entities? X b.No collection for which approval has expired

e. Reinstatement, with change, of a previously approved X a. Three years from approval date collection for which approval has expired Requested _

6* expiration date

f. Existing collection in use without an OMB control number j 7. Title Uniform Low-Level Radioactive Waste Manifest (Shipping Paper) and Continuation Page l

• 8. Agency form number (s) (if app // cable) i NRC Forms 540 and 540A l

9. Keywords Radioactive waste, transport, manifest, low-level waste management

10. Abstract l

NRC Form 540 and continuation Form 540A were developed by NRC at the request of low-level waste j industry groups. When completed, Form 540 contains information needed to satisfy DOT snipping paper

' requirements in 49 CFR Part 172 and the waste tracking requirements of NRC's 10 CFR Part 20.

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12. obligation to respond (Mart onmary with *P* nmt an erhees that copty with X*)

11. Affected public (Mart primary with *Pyd eR arhers that spotsr wrrn *x*)

a. Individuals or households d. Farms s. voluntary

b. Business or other for-profit X e. Federal Government b. Required to obtem or retain benefits P

c. Not-for. profit institutions X f. state, Local, or Tnbal Govemment P c. Mandetory X

13. Annual reporting and recordkeeping hour burden 14. Annual reporting and recordkeeping cost burden (/n thousamts of do!!srsi 8,000 a. Totalannualized capital /startup costs 0

s. Number of respondents 8,000 b. Total annual costs (o&M) 0

b. Total annual responses

1. Percentage of these responses c. Total annuahred cost requested O collected electronically d. Current OMB Inventory 0 0%

9,380 e. Difference a

c. Total annual hours requested 9,380 f. Explanation of difference

d. Current oMB inventory

1. Program change

e. Difference

f. Explanation of difference 2. Adlustment

1. Program change

2. Adiustment C) -

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16. Purpose of information collection 16. Frequency of recordkeepmg or reporting (Check at/ that apply /

(Mart primary with *P' and all others that apply with *X*) a. Recordkeeping l X lb. Third-party dneclosure l

e. Apphcotion for benefits e. Program plannmg or management T c. Reporting ~ '

""" 2. Weekly 3. Monthly - . i

b. Program ovaiustion f. Research X 1. on occasion

c. General purpose statistics y g. Regulatory or comphence 4. Quarterly 5. Someannually 6. Annually [j. <

d. Audit nnedy 8. Other (describe)

18. Agency contsct leerson who can best answer questions regartfing the

17. statsstacal methods consent of this submissioni Does this mformation collection employ statistical methods?

Robert L. O'Connell Yes @ No ( .

• d Name:

sone: 301-415-7877 9805010010 980305 ,

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% O SUPPORTING STATEMENT FOR NRC FORMS 540 AND 540A UNIFORM LOW-LEVEL RADIOACTIVE WASTE MANIFEST (SHIPPING PAPER)

AND NUREG/BR-0204, " INSTRUCTIONS FOR COMPLETING NRC'S UNIFORM LOW-LEVEL RADIOACTIVE WASTE MANIFEST" (3150-0164)

EXTENSION REQUEST Descrintion of the Information Collection Current industry practice requires standardized forms to meet Department of Transportation (DOT), NRC, and State requirements. NRC Form 540 is specifically designed to meet DOT requirements. Aithough DOT already requires the information, it does not require that it be completed on a Federal form.

NRC Form 540 and continuation Form 540A were developed by NRC at the request of low-level waste industry groups. When completed, Form 540 contains information needed to satisfy DOT shipping paper requirements in 49 CFR Part 172 and the waste tracking requirements of the NRC's 10 CFR Part 20. NUREG/BR-0204, Rev.1, contains instructions for completing NRC Forms 540, 540A, 541, 541 A, 542, and 542A.

A. JUSTIFlCATION

1. Nged for and Practical Utility of the Collection of Information i To meet existing regulations, each shipment of low-level waste (LLW) is currently l accompanied by a manifest that describes the shipment contents as required in 10 CFR Part 20 and the DOT regulations in 49 CFR Part 172. Presently tnere are three LLW disposal facilities in operation; however, more LLW disposal facilities are expected to be l licensed in the future. Therefore, the need for additional control and uniformity of data is i foreseen. The detailed information requested on Form 540 will enhance the ability of j NRC and State regulatory agencies to control and safely regulate disposal of LLW. As j of March 1,1998, licensees must use NRC Form 540 and related forms pursuant to Appndix G of 10 CFR Part 20.

2. Aaency Use of information The agency and States will require the information on Forms 540 and 540A to meet DOT shipping paper requirements and NRC tracking requirements.

3. Reduction of Burden throuoh Information Technology The Department of Energy (DOE) has developed software to allow licensees to prepare NRC Form 540 electrcnically and is making the software available free to licensees.

However, DOT requires that shipping papers physically accompany the shipment.

Therefore, the data for Form 540 cannot be transmitted between waste generators, brokers, and waste disposal facilities solely electronically, as is permitted with NRC Forms 541 and 542.

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4. Effort to identifv Duolication and Use Similar Information Duplication will be reduced by requ

ring all LLW shipments undertaken by various agencies to use the uniform NRC shipment manifest forms. There is no reasonable and economic way to obtain the information other than through the use of shipment manifests. NRC Form 540 replaces previously-used manifests.

5. Effort to Reduce Small Business Burden The required information is necessary from all shippers of LLW. To the extent that small entities may make fewer. waste shipments than larger entities, fewer manifests would be required of small entities and their burden would be proportionately less. The Department of Energy (DOE) has developed free software for LLW shippers' use. NRC  ;

is evaluating this software to ensure that all regulatory requirements will be met. l

6. Conseauences to Federal Proaram or Policy Activities if the Collection is Not Conducted or is Conducted Less Freouentiv 1

If the collection is not conducted at all or is conducted less frequently, NRC and State regulatory agencies will not be able to obtain information needed to control and safely regulate disposal of LLW.

7. Circumstances Which Justifv Variation from OMB Guidelines There are no variations from OMB guidelines.

8. Consultations Outside the NRC Based on public input from users, NUREG/BR-0204 was revised in November 1996 to clarify some of the instructions. No changes were made to NRC Forms 540 or 540A.

An opportunity to comment on the information collection requirements in NRC Forms 540 and 540A was pro"ided in the Federal Reaister Notice published for this clearaneo extension (62 FR 65288, Dec.11,1997). No comments were received.

9. Pavment or Gift to Resoondents Not applicable.

10. Confidentiality of the Information Not applicable. No confidential information is requested.

11. Justification for Sensitive Questions This information collection does not involve sensitive questions.

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12. Estimated Burden and Burden Hour Cost it is estimated that 8,000 NRC Forms 540 will be processed annually. The total industry burden for completion of the form will be 9,380 hours0.0044 days <br />0.106 hours <br />6.283069e-4 weeks <br />1.4459e-4 months <br /> annually (7,770 hours0.00891 days <br />0.214 hours <br />0.00127 weeks <br />2.92985e-4 months <br /> from generators and 1,610 hours0.00706 days <br />0.169 hours <br />0.00101 weeks <br />2.32105e-4 months <br /> from collectors / processors. The average burden to complete the form will be 1.17 hrs (9,380 hours0.0044 days <br />0.106 hours <br />6.283069e-4 weeks <br />1.4459e-4 months <br /> divided by 8,000 forms). Non-professional personnel will complete this information. Therefore, total cost is estimated to be $609,700 (9,380 hrs x $65/hr).

13. Estimate of Other Additional Costs There are no additional costs. For licensees required to complete Form 540, it is most

, likely that purchases of equipment and services were made (1) prior to October 1,1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the govemment, or (4) as part of customary and usual business or private practices.

14. Estimated Annualized Cost to the Federal Government The estimated annual cost to the Federal Govemment will be approximately $7,000 for manifest printing and distribution. This cost will be fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and/or 171. The forms are not submitted to NRC. .

15. Reasons for Chanaes in Burden or Cost There are no changes in burden. A decrease in cost has been estimated based on a i decrease in the license fee recovery rate since the previous clearance.

16. Publication for Statistical Use None.

17. Reason for Not Disolavina the Exoiration Date The expiration date will be displayed on the hardcopy form. However, the electronic vercion of Form 540, provided in software developed and distributed by DOE to allow l licensees to prepare NRC Form 540 electronically, will not display an expiration date because it would not be possible to revise the expiration date after the diskettes have l

j been distributed to licensees.

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18. Exceotions to the Certification Statement )

i There are no exceptions. i i

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS l

The collection of information does not employ statistical methods, f l

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• 0 QY OMB: No. 31604164 Estimated burden per response to cornply with this information collection request: 1.17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. This uniform manifest EXPirft!s:MM/DDIYYYY Forward comments regarding burden eshmate to the information and Records Management Branch (T-6 F33). U.S. H1 Budget. Washington. DC 205C3. If an information collection does ncW display a currently valid OMB control number, the, NRC FORM 640 U. S. NUCLEAR REGULATORY COMMISSION 5 SHIPPER - NAME AND F ACILITY (MM-YYYY)

UNIFORM LOW-LEVEL RADIOACTIVE WASTE MANIFEST SHIPPtNG PAPER USER PERMIT NUMBER SHIPMENT NUMB

1. EMERGENCY TELEPHONE NUMBER (incfwJe Area Cooe) l CONTACT ORGANIZATION

6. CARRIER - Name and Address 1 (S THIS AN "EACLUSIVE USE" SHIPMENT 7 3 TOTAL NUMBER OF YES PACKAGES IDENTIFIED

~ ON THtS MANIFEST NO =====>

7 00 CONTACT WASTE REQUIRING A -

MANIFEST ACCOMPANY N e Manifest Nurnber g>

11. U S DEPARTMENT OF TRANSPORTATION DESCRIPTION 12 13 (includmg proper snippmg name. hazard clama UN 10 numoer. 14 DOT LABEL TRANSPORT PHYSICAL AND and any addthonal information) " RADIOACTIVE" lNDEX CHEMICAL FORM hI l ~wwNs~ m so -

NM ft4- Y f Y TJ

quired by NRC to meet reporting rsquirements of Feoarai and State Agencies for the same transportation and disposal of low level Waste r Regulatory Commasion, Washmgton, DC 20555-0001, and to the Paperwork Reduction Project (31504164), Office of Managernent and -

may not conduct or sponsor, and a person is not required to respond to, the information collection.

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7. NRC FORM 540 AND 504A PAGE 1 OF PAGE;S) 6M.pages) m umber all contnuaton .

NRC FORM $41 AND 541 A PAGE(S)

COLLECTOR NRC FORM 542 AND $42A PAGE(S)

PROCESSOR ADDmONAL INFORMATION PAGEfS)

G ATOR WPE 9 CONSIGNEE - Name sna Fecmty Acaress CONTACT 4E ER TELEPHONE NUMBER (include Area Codel SIGNATURC - Aufnanzed consgnee ecAnowMogetg weJie receipt DATE EPA 1.D NUMBER SHIPPING DATE 10 CERTiFICATON This a to cerDfy that the herein-named matonais are properly classaed, desenbed, packaged, ma*ed and labeled and are in Proper condition sor transportanon according to the apphcaDie regulabons of the Department of Transportaton inra amo TEt.EPHONE NUMBER Onclude Area Cooe) ceruftes that the matenens are classMed. pecuaged, ma*ed. and labeled and are m proper cond%on for transportanon afwi disposal as desenbod in accordance vnth the requirements of 10 CFR Pais 20 and 81, or equivaient state regulations TITLE DATE DATE AUTHORIZED SIGNATURE 16 17 16 TOTAL WECHT 19 IDENTIFICATON 15 NUMBER OF fNDivlDUAL TOTAL PACKAGE LSA/SCO OR VOLUME ACTMTY IN SI UNITS CLASS (Use appropnele umtsJ PACKAGE RADONUCLlDES a a i n app sms M AND i r. obr A

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