FINAL OMB 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)
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EXTENSION REQUEST
Description 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. Although DOT 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. The completed NRC 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. 2, contains instructions for completing NRC Forms 540, 540A, 541, 541A, 542, and 542A.
A. JUSTIFICATION
1. Need for and Practical Utility of the Collection of Information
To meet existing regulations, each shipment of low-level waste (LLW) is currently 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, there are three LLW disposal facilities in operation. The detailed information requested on NRC Form 540 will enhance the ability of NRC and State regulatory agencies to control and safely regulate disposal of LLW. Licensees must use NRC Form 540 and related forms pursuant to Appendix G of 10 CFR Part 20.
2. Agency Use of Information
The agency and States require the information on NRC Forms 540 and 540A to meet DOT shipping paper requirements and NRC tracking requirements.
3. Reduction of Burden through Information Technology
There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them. NRC issued a regulation October 10, 2003 (68 FR 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the pubic the option to make submissions electronically via CD-ROM, e-mail, special Web-based interface, or other means. It is estimated that 95% of the potential responses are filed electronically.
4. Effort to Identify Duplication and Use Similar Information
No sources of similar information are available. There is no duplication of requirements. NRC has in place an ongoing program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.
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. DOE has developed free software (LOW-TRACK) for LLW shippers' use. NRC has evaluated this software to ensure that all regulatory requirements are met.
6. Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Frequently
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 Justify Variation from OMB Guidelines
There are no variations from OMB guidelines.
8. Consultations Outside the NRC
The opportunity for comment on the information collection requirements was published in the Federal Register on January 12, 2007 (72 FR 1561). No comments were received.
9. Payment or Gift to Respondents
Not applicable.
10. Confidentiality of the Information
Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b). However, no information normally considered confidential or proprietary is requested.
11. Justification for Sensitive Questions
This information collection does not involve sensitive questions.
12. Estimated Burden and Burden Hour Cost
It is estimated that 13,400 NRC Forms 540 will be processed annually by 2,500 licensees. The average burden to complete the form is estimated to be .75 hours. The total industry burden for completion of the form is estimated at 10,050 hours annually (13,400 forms x .75 hrs). Based on the availability of software (LOW-TRACK is free), it is estimated that almost all licensees prepare the manifests electronically. Professional personnel will complete this information. Therefore, total cost is estimated to be $2,150,700 (10,050 hrs x $214/hr).
13. Estimate of Other Additional Costs
There are no additional costs.
14. Estimated Annualized Cost to the Federal Government
The estimated annual cost to the Federal Government will be approximately $7,500 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 Changes in Burden or Cost
There is no change in burden, but the hourly cost for professional staff has increased from $156/hr to $214/hr.
16. Publication for Statistical Use
None.
17. Reason for Not Displaying the Expiration Date
The expiration date will be displayed on the hardcopy form. However, the electronic version of NRC Form 540, provided in software developed and distributed by DOE to allow 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 been distributed to licensees.
18. Exceptions to the Certification Statement
There are no exceptions.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of information does not employ statistical methods.
| File Type | application/octet-stream |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |