FINAL OMB SUPPORTING STATEMENT FOR
NRC FORMS 541 AND 541A
UNIFORM LOW-LEVEL RADIOACTIVE WASTE MANIFEST
CONTAINER AND WASTE DESCRIPTION
(3150-0166)
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EXTENSION
Description of the Information Collection
Current industry practice requires standardized forms to meet Department of Transportation (DOT), NRC, and State requirements. Although DOT requires the information, it does not require that it be completed on a Federal form.
NRC Form 541 and continuation Form 541A were developed by NRC at the request of Low-Level Waste (LLW) industry groups. The completed NRC Form 541 contains information needed by disposal site facilities to safely dispose of LLW and information to meet NRC and State requirements regulating these activities. 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 LLW, either directly or indirectly, to a licensed disposal facility 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 four LLW disposal facilities in operation. The detailed information requested on NRC Form 541 will enhance the ability of NRC and State regulatory agencies to control and safely regulate disposal of LLW. Licensees must use specified NRC forms, including NRC Form 541, pursuant to Appendix G to 10 CFR Part 20.
2. Agency Use of Information
The agency and States require the information on NRC Forms 541 and 541A to control and safely regulate disposal of LLW.
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 on October 10, 2003 (68 FR 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the public the option to make submissions electronically via CD-ROM, e-mail, or other means. It is estimated that approximately 95% of the potential responses are filed electronically.
There are no legal obstacles to the use of information technology. NRC has structured the forms so that LLW generators may transmit the information electronically to either waste brokers or the LLW disposal site facility on a voluntary basis for their convenience. Several software packages are available that can generate NRC Forms 541 and 541A electronically. The information is not transmitted to NRC.
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.
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
Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register on July 9, 2013 (78 FR 41116). No comments were received.
9. Payment or Gift to Respondents
Not applicable.
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.
Estimated Burden and Burden Hour Cost
It is estimated that 5,600 NRC Forms 541 will be processed annually by 220 NRC and Agreement States licensees. It is assumed all shippers prepare the manifests electronically; therefore, the average burden to gather the information and record it on the form is estimated at 3.3 hours. The total industry burden for completing the form is estimated at 18,480 hours annually (5,600 forms x 3.3 hours). The total industry cost to complete the forms is $2,521,120 [$1,994,720 for professional personnel (5,600 forms x 1.3 hours to gather information x $274/hour) and $526,400 for administrative personnel (5,600 forms x 2 hours to electronically complete the manifests x $47/hour)].
13. Estimate of Other Additional Costs
The NRC has determined that the quantity of records to be maintained is roughly proportional to the recordkeeping burden and, therefore, can be used to calculate approximate records storage costs. Based on the number of pages maintained for a typical clearance, the records storage cost has been determined to be equal to 0.0004 times the recordkeeping burden cost. Because the recordkeeping burden is estimated to be 0 hours, the storage cost for this clearance is $00.00 (0 hours x 0.0004 x $274/hour).
14. Estimated Annualized Cost to the Federal Government
The estimated annual cost to the Federal Government 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 Changes in Burden or Cost
There is no change in burden, but the hourly cost for professional staff has increased from $257/hour to $274/hour.
16. Publication for Statistical Use:
None.
17. Reason for Not Displaying the Expiration Date
The expiration date will be displayed on the hard copy form. However, the electronic version of NRC Form 541, provided in software developed and distributed by DOE to allow licensees to transmit NRC Form 541 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/msword |
| Author | anl |
| Last Modified By | bpm |
| File Modified | 2013-12-18 |
| File Created | 2013-11-06 |