FINAL OMB SUPPORTING STATEMENT FOR NRC FORMS 540 AND 540A
UNIFORM LOW-LEVEL RADIOACTIVE WASTE MANIFEST (SHIPPING PAPER) AND CONTINUATION PAGE
(3150-0164)
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Description of the Information Collection
U.S. Nuclear Regulatory Commission (NRC) Form 540 and continuation Form 540A were developed by NRC in collaboration with the Department of Transportation (DOT). The completed NRC Form 540 contains information needed to satisfy DOT shipping paper requirements in 49 CFR Part 172 and the waste manifesting 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. NRC has authorized use of electronic facsimiles of the forms generated by commercially available computer software and the forms can be transmitted electronically if an agreement has been reached between the appropriate parties.
NRC Forms 540 and 540A are completed by shippers of low-level radioactive waste intended for ultimate disposal at a licensed land disposal facility. The disposal facilities and associated agreement states, if applicable, use the information found on the forms to ensure safe burial of the waste for the protection of the public and environment. The NRC does not collect or retain data on the forms and the forms are not sent to or received by the NRC.
JUSTIFICATION
Need for and Practical Utility of the Collection of Information
To meet existing regulations, each shipment of Low Level Waste (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 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.
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.
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. The 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, special Web-based interface, or other means. It is estimated that approximately 90 percent of the potential responses are filed electronically.
Several software packages (e.g. RADMAN and LowTrack) are available that can generate NRC Form 540 electronically; however, DOT requires that shipping papers physically accompany the shipment. Therefore, the data for NRC Form 540 cannot be transmitted between waste generators, brokers, and waste disposal facilities solely electronically.
Effort to Identify Duplication and Use Similar Information
No sources of similar information are available. There is no duplication of requirements. The NRC has in place an on-going program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.
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.
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.
Circumstances Which Justify Variation from OMB Guidelines
There are no variations from OMB guidelines.
Consultations Outside the NRC
Opportunity for public comment on the information collection requirements for this clearance package was published In the Federal Register on June 22, 2016 (81 FR 40728). As part of the public consultation process, the NRC emailed four potential respondents from the LLW distribution list in order to request
feedback on the four questions for which comments were specifically requested. These individuals were: Mike Elsen (State of Washington), Susan Jenkins (State of South Carolina), Rusty Lundberg (State of Utah), and Jennifer Opila (Colorado Department of Public Health and Environment and current Chair of the Conference of Radiation Control Program Directors, Inc.’s E-5 committee on waste management). No comments were received.
Payment or Gift to Respondents
Not applicable.
Confidentiality of 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.
Justification for Sensitive Questions
This information collection does not involve sensitive questions.
Estimated Burden and Burden Hour Cost
It is estimated that 5,740 NRC Forms 540 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 complete the form is estimated to be 0.75 hours. The total industry burden for completion of the form is estimated at 4,305 hours annually (5,740 forms x 0.75 hours). Professional personnel will complete this information. Therefore, total cost is estimated to be
$1,153,740 (4,305 hours x $268/hour).
Estimate of Other Additional Costs
There are no other additional costs.
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 the NRC.
Reasons for Changes in Burden or Cost
There is no change in burden, but the hourly cost for professional staff has decreased from $274/hour to $268/hour resulting in a reduction in total cost of
$25,830.
Publication for Statistical Use
None.
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 to allow licensees to prepare NRC Form 540 electronically, will not display an expiration date because it would not be possible for the NRC to revise the expiration date of software produced by commercial companies.
Exceptions to the Certification Statement
There are no exceptions.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS The collection of information does not employ statistical methods.
| File Type | text/rtf |
| Last Modified By | Miles, Brenda |
| File Modified | 2016-11-10 |
| File Created | 2016-11-02 |