NUREG BR-0204, Revision 3 Update
October 05, 2020
WMG Update Notification and Timeline of the NUREG BR-0204, Revision 3 Implementation
On June 30, 2020, the Nuclear Regulatory Commission (NRC) published NUREG/BR-0204 Revision 3 titled Instructions for Completing the U.S. Nuclear Regulatory Commission’s Uniform Low-Level Radioactive Waste Manifest. On July 2 they made notice of this publication in the Federal Register, stating that, “Revision 3 and its forms became effective on July 2, 2020. Use of the NUREG/BR0204, Revision 2 forms should be discontinued on or before September 30, 2020.” This release caught many stakeholders by surprise, some of whom had been commenting and working with the NRC on the development of the revision. Of particular concern was the relatively short 3-month suggested implementation period. Multiple utilities requested the Nuclear Energy Institute (NEI) to ask the NRC to delay the implementation of Rev 3 of the 540/541 forms beyond the 9/30 date.
On September 14, 2020, the NRC held a Webinar titled Implementation Status of NUREG/BR-0204, Revision 3, and Associated NRC Forms. Based on discussions and input from stakeholders, the NRC agreed to publish a notice in the Federal Register soon after evaluating an extension to the implementation date. Stakeholders and the NEI suggested a date of 3/31/2021. For the near future, the NRC has indicated that they would be willing to “exercise enforcement discretion” so that no one would be cited for using Revision 2 beyond the 9/30 date.
The preface of NUREG/BR-0204 Revision 3 states that the changes from Revision 2 include:
- Updated instructions to reflect changes to the Uniform Manifest Forms.
- Updated references to U.S. Department of Transportation (DOT) regulations to reflect the current DOT regulations.
- Additional discussion on the reporting of inventories based on lower limit of detection values, the potential use of indirect methods to determine these inventories, and the use of indirect methods in waste classification calculations.
- Clarification of the intent of the certification statement on Form 540.
- Overall improvements to the clarity of the document.
As with many things nuclear power related, “the devil is in the details”.
- Changes to the forms include page size, layout, the title of numerous columns, and minor formatting changes.
- The methods for annotating that a nuclides inventory is based on a lower limit of detection (LLD) value has changed, including the addition of a # symbol to indicate if that value was determined by “the use of indirect methods”.
- The revised certification statement will now consist of a statement based on the DOT’s certification statement required by 49 CFR 172.204 and statements based on the NRC’s certification statement required in 10 CFR 20, Appendix G, Section II.
On September 30th, the last day of the original “grace period”, NRC published an update in the Federal Register stating, “Use of NUREG/ BR–0204, Revision 3 has been delayed. Until further notice, licensees should continue to use NUREG/BR–0204, Revision 2 and the versions of NRC Forms 540, 541 and 542 that were renewed in January 2020, or equivalent, as defined in NRC’s regulations.”
WMG is working on inclusion of compliant NRC 540/540A and 541/541A forms in the RADMAN™ suite. We will likely be “holding” that software release, Version 9.5, pending further guidance from the NRC about an updated implementation date.
Until then, we are working on a revision to the RADMAN™ software (version 9.4.2), targeted for release by the end of October, that will have the updated 2020 Emergency Response Guides in addition to the January 2020 Uniform Waste Manifest.